II 115

(ft UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

s1f2 f IQION I

~ _ J KENNEDY fiOIItAL IUILOINQ IOITON IIIAHACHUHTTIIHIS-1111

URGENT LEGAL MAITEB- -PROMpt REPLY NECESSARY CERTIFIEQ MAIL RETtJRH RECEIPJ REOUESTEQ

Mr Gary Veat Deputy Aaaiatant Secretary ot the Air Force (Environment Safety and Occupational Health) SAFRQ RK4C916 Waahington DC 2033 0-1000

RE Pinettebull Salvage Yard Superfund Site Wa a hbyrn Maine Ctht bulls itbullbull)

Dear Mr Veat

The United Statea Environaental Protection Agency (EPA) ia aubaittincJ thia letter to notify you of the United Stataa Air Forcabulla (Air Force potential liability with reapect to the above rataranced Superfund SitaJ to raquaat the Air Forcabulla voluntary participation in undertaking cleanup activitiaa at the Site to raquaat that the Air Force bullaka reatitution by paYJient of coata incurred by the EPA for past reaponae actionbull at the Site and to requeat that the Air Force provide further information concernin9 ita involvement in connection with the diapoaal of hazardoua aubatancea at the Site

The h iatory of thia Site datea back to 1979 when tranafoners belonging to the Air Force were tranaported to the Pinette a aalva9e yard where they were diaaantlad Evidently i n the courae of dismantling the transformera the fluida in the transformers which contained polychlorinated biphenyls (PCBamp) were d iapoaed of or releaaad at the Site Below ia a brief suDUDary of the Agencybull actions in relation to this Site and of the facts which form the basis of t he Air Forces liability pursuant to Section 107(a) (3) of CERCLA 42 usc sect9607(a) (3)

o In February 1979 torin9 Air Force Base (AFB) contracted with Avon C Brown Inc an electrical contractor in Bangor Maine for replacement of a Central Heating Plant Substation The work to be performed by Avon C Brown Inc required the removal ot three ( 3) transtorJDera from Lori n9 AFB

o In June 1979 the transformers each containing approximately 265 gallons of PCB Uuida were transported from Loring AFB to the Pinette 1 s salvage yard located in Washburn Maine At the nlvage yard the transformers vera reportedly dismantled and their contents vera leaked onto the ground resulting in PCB contamination at the Site

o From approximately November 1979 to early 1983 EPA and the Kaine Department of Environmental Protection (MEDEP) conducted numerous inquiries into the circumstances surrounding this incident In addition soil samples vera taken and analyzed to confira that the Site vas contaminated with PCBs

o In November 1982 EPA issued a Hazardous Ranking System (HRS) score tor the Site and in December 1982 placed the site on the National Priorities List (NPL)

o On May 17 and July 13 1983 representatives of EPA Region I EPA Headquarters the state of Kaine and the Air Force aet to infant the Air Force of ita responsibility tor the disposal of the transforaera and to discuss the nature of the contaaination at the Site and the steps to be undertaken to clean up the Site

0 In OCtober 1983 1 EPA Req-ion I again inforaed the Air Force ot ita potential liability for the contaaination at the Site and of the need for an i-ediate response action to be undertaken at the site

o In October-November 1983 EPA undertook a reaoval action to abate an i-inent and substantial endangeraent at the Site pursuant to Section 104 ot CERCLA 42 US C 19604

o From August 1985 to August 1986 EPA performed a Deletion Remedial Investigation (DRI) at the Site to determine if the Site warranted deletion from the NPL

o In May 1986 EPA determined that the Site vas not suitable for deletion from the NPL due to residual PCB contamination at the Site

o In october 1986 EPA requested that the Air Force make restitution by payment of the amount expended by EPA tor removal actions at the Site plus interest on such amount

o From Auquat 1987 to preaent EPA haa undergone a Supplemental Remedial Inveatigation (SRI) at the Site and ia currently in the proceaa of hauing (for public comment) the results ot the readbility Study (FS) and Proposed Plan tor the Site

NOTICE Of POTENTIAL LIABILITX AND REQUEST FOB PARTICIPATION IN CLEANUP ACTIVITIES

As noted above EPA has documented the release and threatened r e l ease of hazardous aubatancea pollutants and contaminants at the site EPA has spent and is considering apending additional public funds on actions to investigate and control the releases or threatened releaaea at the Site Unlesa EPA deterainea that a responaible party will properly perform such ac t ions EPA will itself perfona these ac t ions pursuant t o Section 104 o f t he comprehensive Environmental Reaponse Compenaat i on and Liabilit y Act o f 1980 42 U S C 19601 ~ (CERCLA)

Under Sections 106(a) and 107(a) ot CERCLA 42 u s c J19606(a ) and 9607 (a) Secti on 7003 of the Re aource Conservation and Recovery Act 42 US C 16973 (RCRA) and other lava r esponsible parties a ay be obligated to iapleaent r e lie f actions deed nece ssary by EPA to protect the public health welfare or envirorme nt and aay be liable for all coats incurred by the gove rnaent in reaponding to any release or threatened r e lease at the Site Such cos ta a ay include but are not liaited to expe nditures for inves tigation planning cleanup and e nforcement activ ities Reapona ible parties under CERCLA include current and for~~~er owne r bull and ope rators of the Site aa wa ll as pers ona who arranged for d isposal of hazardous subs tances at or for t r ans port of hazardous aubatance s to the Site

EPA baa evaluated the ev i dence in connection wi th ita i nvestigat i on of the Si te Baaed upon thia evidence EPA has -infor~~ation ind icating that the Air Force is a pote ntially r esponsible par ty wi th r eapect to this Site Speci fically EPA has reas on to believe that the Air Force by contract agreement bullor otherwise arranged f or the d ispoaal or transportati on f or disposal of hazardous substances f ound a t t he Si t e By this latter EPA is notifyi ng t he Air Force of ita potentia l liability 8 with regard to this matter and encourages t he Air Force as a potentially responsible party t o reimburse EPA for costa N incurred t o date and to voluntarily perform or finance the response activities described below that EPA has determined are required at the Site

FORTHCOMING RESPONSE ACTIVITIES AT THE SITE

EPA is planning to conduct the following activities at the Site in the near future

1 Begin the public comment period on EPAs preferred remedial alternative for the Site

2 deaign and iapleaent the reaebullSial action aelected and approved by EPA for the Site1 and

3 conduct operation aaintananca and aonitoring deemed neceaaary at the Site

EPA a Supplemental Remedial InveatigationjFeadbility Study and Propoaed Plan for Remedial Action at the Site b expected to be available for public r eview and couent in March 1989 In addition to the cleanup activitiea enUBerated upon above EPA -ay purauant to ita authority under CERCLA and other lava dec i de that other meaaurea are neceaaary to protect public health welfare or the envirorment

DEMAND FOB PAYMENT OF CQSTS INCURRED TO QATE

In accordance with CERCLA and other authoritiea EPA haa already undertaken certa in actionbull and incurred coata aaounting to approximately $156400000 in reeponae to conditione at the Site Theae reaponae actionbull include an 1-ediate Rea oval Action in 1983 the parforance of a Deletion Reaedial Inveatigation and the perforanca of a Suppleaental Reaadial Inveatigationjreaaibility Study The agency anticipatebull expanding additional funda for reaponae actionbull at the Site under the authority of CERCLA and other lava including thoae reaponae activitiea deacribad above In accordance with Section 107(a) (4) (D) of CERCLA dea and ia hereby aade tor payaent of all paa t reaponae coata and all intereat authorized to be recovered under that Section or under any other proviaiona of lav Demand ia aleo he reby aade under theae authoritiea for payaent and intereat on all future coata that EPA aay accrue in regard to the Site

INFORMATION REQUEST

EPA ia continuing to i nveatigate the aource extent and nature of shythe r eleaae or threatened releaae of hazardoua aubstancea pollutantbull or contaainanta or hazardoua waatea on or about the bullSite Thia inveatigation requirea inquiry into the identification nature and quantity of materialbull that have been or are being generated treated stored disposed of or abandoned at or transported to the Site It further seeks 8 information concerning the nature and extent of releases or threatened releaaea of hazardoua substances or pollutants or N contaainants at or from the Site

Pursuant to the authority of Section 104(e) of CERCLA 42 usc 19604 and Section 3007 of RCRA 42 usc 16927 you are hereby requested to respond to the Information Request attached herein

Compliance with the Information Request is mandatory Failure to respond tully and truthfully to the Information Request within thirty (30) days of recei pt of this letter or to adequately

W justify such failure to respond may result in enforcement action

o In June 1979 the transformers each containing approximately 265 gallons of PCB Uuida were transported from Loring AFB to the Pinette 1 s salvage yard located in Washburn Maine At the nlvage yard the transformers vera reportedly dismantled and their contents vera leaked onto the ground resulting in PCB contamination at the Site

o From approximately November 1979 to early 1983 EPA and the Kaine Department of Environmental Protection (MEDEP) conducted numerous inquiries into the circumstances surrounding this incident In addition soil samples vera taken and analyzed to confira that the Site vas contaminated with PCBs

o In November 1982 EPA issued a Hazardous Ranking System (HRS) score tor the Site and in December 1982 placed the site on the National Priorities List (NPL)

o On May 17 and July 13 1983 representatives of EPA Region I EPA Headquarters the state of Kaine and the Air Force aet to infant the Air Force of ita responsibility tor the disposal of the transforaera and to discuss the nature of the contaaination at the Site and the steps to be undertaken to clean up the Site

0 In OCtober 1983 1 EPA Req-ion I again inforaed the Air Force ot ita potential liability for the contaaination at the Site and of the need for an i-ediate response action to be undertaken at the site

o In October-November 1983 EPA undertook a reaoval action to abate an i-inent and substantial endangeraent at the Site pursuant to Section 104 ot CERCLA 42 US C 19604

o From August 1985 to August 1986 EPA performed a Deletion Remedial Investigation (DRI) at the Site to determine if the Site warranted deletion from the NPL

o In May 1986 EPA determined that the Site vas not suitable for deletion from the NPL due to residual PCB contamination at the Site

o In october 1986 EPA requested that the Air Force make restitution by payment of the amount expended by EPA tor removal actions at the Site plus interest on such amount

o From Auquat 1987 to preaent EPA haa undergone a Supplemental Remedial Inveatigation (SRI) at the Site and ia currently in the proceaa of hauing (for public comment) the results ot the readbility Study (FS) and Proposed Plan tor the Site

NOTICE Of POTENTIAL LIABILITX AND REQUEST FOB PARTICIPATION IN CLEANUP ACTIVITIES

As noted above EPA has documented the release and threatened r e l ease of hazardous aubatancea pollutants and contaminants at the site EPA has spent and is considering apending additional public funds on actions to investigate and control the releases or threatened releaaea at the Site Unlesa EPA deterainea that a responaible party will properly perform such ac t ions EPA will itself perfona these ac t ions pursuant t o Section 104 o f t he comprehensive Environmental Reaponse Compenaat i on and Liabilit y Act o f 1980 42 U S C 19601 ~ (CERCLA)

Under Sections 106(a) and 107(a) ot CERCLA 42 u s c J19606(a ) and 9607 (a) Secti on 7003 of the Re aource Conservation and Recovery Act 42 US C 16973 (RCRA) and other lava r esponsible parties a ay be obligated to iapleaent r e lie f actions deed nece ssary by EPA to protect the public health welfare or envirorme nt and aay be liable for all coats incurred by the gove rnaent in reaponding to any release or threatened r e lease at the Site Such cos ta a ay include but are not liaited to expe nditures for inves tigation planning cleanup and e nforcement activ ities Reapona ible parties under CERCLA include current and for~~~er owne r bull and ope rators of the Site aa wa ll as pers ona who arranged for d isposal of hazardous subs tances at or for t r ans port of hazardous aubatance s to the Site

EPA baa evaluated the ev i dence in connection wi th ita i nvestigat i on of the Si te Baaed upon thia evidence EPA has -infor~~ation ind icating that the Air Force is a pote ntially r esponsible par ty wi th r eapect to this Site Speci fically EPA has reas on to believe that the Air Force by contract agreement bullor otherwise arranged f or the d ispoaal or transportati on f or disposal of hazardous substances f ound a t t he Si t e By this latter EPA is notifyi ng t he Air Force of ita potentia l liability 8 with regard to this matter and encourages t he Air Force as a potentially responsible party t o reimburse EPA for costa N incurred t o date and to voluntarily perform or finance the response activities described below that EPA has determined are required at the Site

FORTHCOMING RESPONSE ACTIVITIES AT THE SITE

EPA is planning to conduct the following activities at the Site in the near future

1 Begin the public comment period on EPAs preferred remedial alternative for the Site

2 deaign and iapleaent the reaebullSial action aelected and approved by EPA for the Site1 and

3 conduct operation aaintananca and aonitoring deemed neceaaary at the Site

EPA a Supplemental Remedial InveatigationjFeadbility Study and Propoaed Plan for Remedial Action at the Site b expected to be available for public r eview and couent in March 1989 In addition to the cleanup activitiea enUBerated upon above EPA -ay purauant to ita authority under CERCLA and other lava dec i de that other meaaurea are neceaaary to protect public health welfare or the envirorment

DEMAND FOB PAYMENT OF CQSTS INCURRED TO QATE

In accordance with CERCLA and other authoritiea EPA haa already undertaken certa in actionbull and incurred coata aaounting to approximately $156400000 in reeponae to conditione at the Site Theae reaponae actionbull include an 1-ediate Rea oval Action in 1983 the parforance of a Deletion Reaedial Inveatigation and the perforanca of a Suppleaental Reaadial Inveatigationjreaaibility Study The agency anticipatebull expanding additional funda for reaponae actionbull at the Site under the authority of CERCLA and other lava including thoae reaponae activitiea deacribad above In accordance with Section 107(a) (4) (D) of CERCLA dea and ia hereby aade tor payaent of all paa t reaponae coata and all intereat authorized to be recovered under that Section or under any other proviaiona of lav Demand ia aleo he reby aade under theae authoritiea for payaent and intereat on all future coata that EPA aay accrue in regard to the Site

INFORMATION REQUEST

EPA ia continuing to i nveatigate the aource extent and nature of shythe r eleaae or threatened releaae of hazardoua aubstancea pollutantbull or contaainanta or hazardoua waatea on or about the bullSite Thia inveatigation requirea inquiry into the identification nature and quantity of materialbull that have been or are being generated treated stored disposed of or abandoned at or transported to the Site It further seeks 8 information concerning the nature and extent of releases or threatened releaaea of hazardoua substances or pollutants or N contaainants at or from the Site

Pursuant to the authority of Section 104(e) of CERCLA 42 usc 19604 and Section 3007 of RCRA 42 usc 16927 you are hereby requested to respond to the Information Request attached herein

Compliance with the Information Request is mandatory Failure to respond tully and truthfully to the Information Request within thirty (30) days of recei pt of this letter or to adequately

W justify such failure to respond may result in enforcement action

o From Auquat 1987 to preaent EPA haa undergone a Supplemental Remedial Inveatigation (SRI) at the Site and ia currently in the proceaa of hauing (for public comment) the results ot the readbility Study (FS) and Proposed Plan tor the Site

NOTICE Of POTENTIAL LIABILITX AND REQUEST FOB PARTICIPATION IN CLEANUP ACTIVITIES

As noted above EPA has documented the release and threatened r e l ease of hazardous aubatancea pollutants and contaminants at the site EPA has spent and is considering apending additional public funds on actions to investigate and control the releases or threatened releaaea at the Site Unlesa EPA deterainea that a responaible party will properly perform such ac t ions EPA will itself perfona these ac t ions pursuant t o Section 104 o f t he comprehensive Environmental Reaponse Compenaat i on and Liabilit y Act o f 1980 42 U S C 19601 ~ (CERCLA)

Under Sections 106(a) and 107(a) ot CERCLA 42 u s c J19606(a ) and 9607 (a) Secti on 7003 of the Re aource Conservation and Recovery Act 42 US C 16973 (RCRA) and other lava r esponsible parties a ay be obligated to iapleaent r e lie f actions deed nece ssary by EPA to protect the public health welfare or envirorme nt and aay be liable for all coats incurred by the gove rnaent in reaponding to any release or threatened r e lease at the Site Such cos ta a ay include but are not liaited to expe nditures for inves tigation planning cleanup and e nforcement activ ities Reapona ible parties under CERCLA include current and for~~~er owne r bull and ope rators of the Site aa wa ll as pers ona who arranged for d isposal of hazardous subs tances at or for t r ans port of hazardous aubatance s to the Site

EPA baa evaluated the ev i dence in connection wi th ita i nvestigat i on of the Si te Baaed upon thia evidence EPA has -infor~~ation ind icating that the Air Force is a pote ntially r esponsible par ty wi th r eapect to this Site Speci fically EPA has reas on to believe that the Air Force by contract agreement bullor otherwise arranged f or the d ispoaal or transportati on f or disposal of hazardous substances f ound a t t he Si t e By this latter EPA is notifyi ng t he Air Force of ita potentia l liability 8 with regard to this matter and encourages t he Air Force as a potentially responsible party t o reimburse EPA for costa N incurred t o date and to voluntarily perform or finance the response activities described below that EPA has determined are required at the Site

FORTHCOMING RESPONSE ACTIVITIES AT THE SITE

EPA is planning to conduct the following activities at the Site in the near future

1 Begin the public comment period on EPAs preferred remedial alternative for the Site

2 deaign and iapleaent the reaebullSial action aelected and approved by EPA for the Site1 and

3 conduct operation aaintananca and aonitoring deemed neceaaary at the Site

EPA a Supplemental Remedial InveatigationjFeadbility Study and Propoaed Plan for Remedial Action at the Site b expected to be available for public r eview and couent in March 1989 In addition to the cleanup activitiea enUBerated upon above EPA -ay purauant to ita authority under CERCLA and other lava dec i de that other meaaurea are neceaaary to protect public health welfare or the envirorment

DEMAND FOB PAYMENT OF CQSTS INCURRED TO QATE

In accordance with CERCLA and other authoritiea EPA haa already undertaken certa in actionbull and incurred coata aaounting to approximately $156400000 in reeponae to conditione at the Site Theae reaponae actionbull include an 1-ediate Rea oval Action in 1983 the parforance of a Deletion Reaedial Inveatigation and the perforanca of a Suppleaental Reaadial Inveatigationjreaaibility Study The agency anticipatebull expanding additional funda for reaponae actionbull at the Site under the authority of CERCLA and other lava including thoae reaponae activitiea deacribad above In accordance with Section 107(a) (4) (D) of CERCLA dea and ia hereby aade tor payaent of all paa t reaponae coata and all intereat authorized to be recovered under that Section or under any other proviaiona of lav Demand ia aleo he reby aade under theae authoritiea for payaent and intereat on all future coata that EPA aay accrue in regard to the Site

INFORMATION REQUEST

EPA ia continuing to i nveatigate the aource extent and nature of shythe r eleaae or threatened releaae of hazardoua aubstancea pollutantbull or contaainanta or hazardoua waatea on or about the bullSite Thia inveatigation requirea inquiry into the identification nature and quantity of materialbull that have been or are being generated treated stored disposed of or abandoned at or transported to the Site It further seeks 8 information concerning the nature and extent of releases or threatened releaaea of hazardoua substances or pollutants or N contaainants at or from the Site

Pursuant to the authority of Section 104(e) of CERCLA 42 usc 19604 and Section 3007 of RCRA 42 usc 16927 you are hereby requested to respond to the Information Request attached herein

Compliance with the Information Request is mandatory Failure to respond tully and truthfully to the Information Request within thirty (30) days of recei pt of this letter or to adequately

W justify such failure to respond may result in enforcement action

2 deaign and iapleaent the reaebullSial action aelected and approved by EPA for the Site1 and

3 conduct operation aaintananca and aonitoring deemed neceaaary at the Site

EPA a Supplemental Remedial InveatigationjFeadbility Study and Propoaed Plan for Remedial Action at the Site b expected to be available for public r eview and couent in March 1989 In addition to the cleanup activitiea enUBerated upon above EPA -ay purauant to ita authority under CERCLA and other lava dec i de that other meaaurea are neceaaary to protect public health welfare or the envirorment

DEMAND FOB PAYMENT OF CQSTS INCURRED TO QATE

In accordance with CERCLA and other authoritiea EPA haa already undertaken certa in actionbull and incurred coata aaounting to approximately $156400000 in reeponae to conditione at the Site Theae reaponae actionbull include an 1-ediate Rea oval Action in 1983 the parforance of a Deletion Reaedial Inveatigation and the perforanca of a Suppleaental Reaadial Inveatigationjreaaibility Study The agency anticipatebull expanding additional funda for reaponae actionbull at the Site under the authority of CERCLA and other lava including thoae reaponae activitiea deacribad above In accordance with Section 107(a) (4) (D) of CERCLA dea and ia hereby aade tor payaent of all paa t reaponae coata and all intereat authorized to be recovered under that Section or under any other proviaiona of lav Demand ia aleo he reby aade under theae authoritiea for payaent and intereat on all future coata that EPA aay accrue in regard to the Site

INFORMATION REQUEST

EPA ia continuing to i nveatigate the aource extent and nature of shythe r eleaae or threatened releaae of hazardoua aubstancea pollutantbull or contaainanta or hazardoua waatea on or about the bullSite Thia inveatigation requirea inquiry into the identification nature and quantity of materialbull that have been or are being generated treated stored disposed of or abandoned at or transported to the Site It further seeks 8 information concerning the nature and extent of releases or threatened releaaea of hazardoua substances or pollutants or N contaainants at or from the Site

Pursuant to the authority of Section 104(e) of CERCLA 42 usc 19604 and Section 3007 of RCRA 42 usc 16927 you are hereby requested to respond to the Information Request attached herein

Compliance with the Information Request is mandatory Failure to respond tully and truthfully to the Information Request within thirty (30) days of recei pt of this letter or to adequately

W justify such failure to respond may result in enforcement action

by EPA pursuant to Section 104 (e) of CERCLA andor Section 3008 of RCRA Each of these statutes peBita EPA to seek the imposition of penalties of up to twenty-five thousand dollars ($25000) for each day of continued non-compliance Please be further advised that provision of false fictitious or fraudulent statements or representationbull may subject you to criminal penaltiea under 18 u sc 11001 or Section 3008 of RCRA

Thia Inforaation Request ie not aubject to the approval requirementbull of the Paperwork Reduction Act of 1980 U u s c 13501 ltUll

TIMING AND FORM OF RESPONSES TO THIS JETTEB

Aa a potentially responsible party the Air Force should notify EPA in writing within thirty (30) daya of receipt of this letter of ita willingness to perfona or finance the activities described above Your letter should indicate the appropriate naae addreaa and telephone nutJer for further contact with you If you are already i nvolved in d iacuaaiona with State or local authorities engaqed in voluntary cleanup action or involved in a lawauit regardinq thia Site you should continue auch activities aa you aee fit Thia letter is not intended to advise you or direct you to r estrict or diecontinue any auch activities however you are advised to report the etatua of thoae diecuaaiona or actions in your responaea to thia letter and to provide a copy of any written couunicationa between you and any other parties involved in thobullbull dbcusaiona or actions

Your reaponae to thia letter s hould be aailed to Marilyn JC Goldberg US Environaental Protection Agency (HES-CAN6) JFI( Federal Building Boaton MA 02203 -

If you have an attorney representinq you in this matter please d irect his or her queationa to Franciaco Leal of EPAbull Office of bullRegional counsel at (617) 565-3334

INFORMATION TO ASSIST RESPONSIBLE PJRTIES 8 EPA would like to encourage good faith negotiations between the Air Force and the Agency and among you and other parties N potentially responsible for the Site To assist responsible parties in preparing a proposal and in negotiating with EPA concerninq this matter EPA is providing a list of the names and addresses of potentially responsible parties to whom this notification is being provided (Attachment A) This list represents EPA bulla preliminary findinqs on the identities of potentially responsible partieamp Inclusion on or exclusion from this list does not constitute a final determination by this Agency concerning the liability of any party for the hazard(s) or contamination at the Site

Please be advised that EPA haa detenained that the lht ia an investigatory record compiled tor law enforcement purpoaea The public release of the record deacribed above may interfere with enforcement proceedingbull and diacloae inveatigatory techniquebull and procedures As such the record ia exempt from mandatory diaclosure under the inveatigatory recorda exemption of the Freedom of Infor~~ation Act 5 US C 1552(b) (7 Nevertheleaa a limited diacloaure of the record ia being 11ade in order to further the aettlement negotiationbull and to encourage communication among the partiea The record ia being provided abull a discretionary releaae of intor111ation to the potentially reaponaible partiebull and ahould not be diacloaed further or made publicly available in any context unlebullbull you are given prior approval by EPA

The factual and legal diacuaaiona in thia letter are intended sol ely to provide notice and i nforaation and auch diacuaaiona are not to be conatrued abull a final Agency poaitlon on any aatter aet forth herein Due to the aeriouaneaa of the envirormental and l egal problema poaed by conditionbull at the Bite EPA urgebull that iWDediate attention and a probullpt reaponae be given to thia letter

By copy of thia l etter EPA ia notifying the State of Maine and the Federal Natural Reaource Truateea of our intent to perfora or enter into negotiationbull tor the perforaance or financing of reaponae actiona at the Site

i cerely middot ~nA llJ JZ1~r rrill s Hohci oiroctor __V Waate Management Diviaion -Attachmentbull bullcc Michael R Deland Regional Administrator Bruce Diamond Director

Office of Waste Programbull Enforcement Edward E Reich Acting Assistant Adbulliniatrator 8

Office of Enforcebullent and Cobullpliance Monitoring Bruce Marshall Chief N

Superfund Enforcement Support Section Francisco Leal EPA Office of Regional Counsel Michael Jasinski EPA Remedial Project Manager Rebecca Hewitt State Of Maine Remedial Project Manager William Patterson Federal Natural Resource Trustee Kenneth Finkelstein Federal Natural Resource Truatee

ATTACHMENT A

POTENTIALLY RESPONSIBLE PARTIES I PINETtE bull S SALVAGE XARQ SUPERniND SITE

Mr Paul Philbrick Preaident ELCO Electric Inc 311 Perry Road Bangor ME OUOl

Mr Gary o Veat Oputy Aaaiatant Secretary ot t he Air Force ( Envirom~ental Safety and Occupational Health) opartbullent ot Otenae SAPRQ RM4 C916 Waahint~ton DC Z OJJ0 - 1000

cynthia C and Roger J Pinette Gardne r Creek Road (Wade Road) Waahbum D 04716

Rita M Pinette Gardner creek Road (Wade Road) Waahburn D 04786

ATTACHMENT B

REQUEST FOR INFORMATION PINEME 1 S SALVAGE YARD SUPERFUND SITE

Inttructionbull o~1 A separate responte bullust be aade to each of the IZ

Quettionbull set forth in this Infonaation Requett H ~~

2 Precede each answer with the number of the Question to which it correaponds Hr3 In answering each Question identify all docUilents and ltlt peraona that contributed inforaation relating to your retponse

4 If infonaation not known or not available to you a a of 0-lt the date of subbulliaaion of a responae to thia Inforation Requebullt Olgt

should later becobulle known or available to you you bulluat 00

aupplebullent your response to EPA Moreover should you find at any tibulle after the aubbullbsion of this reaponte that any portion of the subaitted inforaation is false or aisrepreaenta the truth you bullust notify EPA thereof as soon as poaaible

5 For all documents produced in response to this Information Request arrange and label the documents to correspond with the Queation to which they are retponaive or indicate on the docuaent or in aoae other reaaonable aanner the nuaber of the Question to which they are responsive

6 The inforaation and docuaents requested herein aust be provided notwithstanding their possible characterization as confidential inforation or trade secreta You may if you desire asbullert a confidentiality claia covering part or all of the infor~~ation and documents requested pursuant to Sections l04(o) (7) (E) and (F) of CERCLA 42 usc II 9604(e) (7) (E) and (F) and 40 CFR f 2203(b) by attachinq to such intonation or documents at the time it is submitted a cover sheet bulltamped or typed lagend or other suitable form of notice employinq lanquage such a a trade secret proprietary or company confidential Information covered by such a claim will be disclosed by EPA only to the extent and only by means of the procedures set forth in 40 CFR Part 2 Subpart B If no such claim accompanies the information when it is received by EPA it may be made available to the public by EPA without further notice to you You should read the above cited regulations carefully before asserting a business confidentiality claim since certain categories of information are not properly the subj act of such a claim

7 Where apecitic intoration haa not been bullebullorialhecl in any docuaent but ibull nonethelebullbull reaponaive to bull Queation you bulluat reapond to the Queation vith bull written reaponae

ATTACHMENT 8 (continued)

petinitionbull

The following definitions shall apply to the following worda as they appear in thia Attachment B

l The term you or Respondent ahall mean the addrebullaee of thia Information Request the addreueea ofticera managerbull employees contractors and agentbull

2 The tent bullperson a a uaed herein includea in the plural aa well abull the singular any natural peraon tira unincorporated association partnerahip corporation trust or other anti ty

J The terms Pinettebull J unkyard Sitebull or Pinettebull Junkyard facility s hall mean and i nc lude the property on or about t he Pinet tes Junkyard or Salvage Yard l ocat ed on Gar dner Cr eek Road (aka Wade Road) in Wa l hburn Ma i ne

4 The term hazardoubull s ubatance shall have the bull bull bullbull defin i tion a s that contained i n Section 101(14) o f the Comprehena ive Envi ronmental Re1pon1e Cobull penl ation and Liability Ac t (CERCLA) 42 usc I 9601(14) and includea any bullixturea of auch hazardous aubs tancebull inc luding petrole um producta For pur poaea of this Inforaat i on Requebullt it ahall albullo include ma t e r ials with in the de fi ni tion of hazardous waa t e abull de fined by Section 1004 (5) o f the Resource Conbull ervation and Recovery Act (RCRA) 4 2 us c I 6903 (5)

5 The t erm pollutant or contami nant s ha ll have the same defi nition as t ha t contained in Section 101(33) of CERCLA 42 US C t 9601(33) a nd includebull any bullixturea of auch pollutants and contaminants wi th any othe r substances incl uding shypet rol eum products bull6 The term material or aater ial s shall mean and i nclude any and all goods objects aubatances and matter of any kind including but not limited to all hazardous substances pollutants and contaminants as defined above 8

N7 The term identify means with respect to a natural person to set forth the person a name present or last known business address and business telephone number present or last known home address and home telephone number and present or last known job title position or businesa

8 The term identify means with respect to a corporation partnership business trust or other association or business entity (including a sole proprietorship) to set forth its full name address legal form (eg corporation partnership etc ) organization if any and a brief description of its business

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

Please be advised that EPA haa detenained that the lht ia an investigatory record compiled tor law enforcement purpoaea The public release of the record deacribed above may interfere with enforcement proceedingbull and diacloae inveatigatory techniquebull and procedures As such the record ia exempt from mandatory diaclosure under the inveatigatory recorda exemption of the Freedom of Infor~~ation Act 5 US C 1552(b) (7 Nevertheleaa a limited diacloaure of the record ia being 11ade in order to further the aettlement negotiationbull and to encourage communication among the partiea The record ia being provided abull a discretionary releaae of intor111ation to the potentially reaponaible partiebull and ahould not be diacloaed further or made publicly available in any context unlebullbull you are given prior approval by EPA

The factual and legal diacuaaiona in thia letter are intended sol ely to provide notice and i nforaation and auch diacuaaiona are not to be conatrued abull a final Agency poaitlon on any aatter aet forth herein Due to the aeriouaneaa of the envirormental and l egal problema poaed by conditionbull at the Bite EPA urgebull that iWDediate attention and a probullpt reaponae be given to thia letter

By copy of thia l etter EPA ia notifying the State of Maine and the Federal Natural Reaource Truateea of our intent to perfora or enter into negotiationbull tor the perforaance or financing of reaponae actiona at the Site

i cerely middot ~nA llJ JZ1~r rrill s Hohci oiroctor __V Waate Management Diviaion -Attachmentbull bullcc Michael R Deland Regional Administrator Bruce Diamond Director

Office of Waste Programbull Enforcement Edward E Reich Acting Assistant Adbulliniatrator 8

Office of Enforcebullent and Cobullpliance Monitoring Bruce Marshall Chief N

Superfund Enforcement Support Section Francisco Leal EPA Office of Regional Counsel Michael Jasinski EPA Remedial Project Manager Rebecca Hewitt State Of Maine Remedial Project Manager William Patterson Federal Natural Resource Trustee Kenneth Finkelstein Federal Natural Resource Truatee

ATTACHMENT A

POTENTIALLY RESPONSIBLE PARTIES I PINETtE bull S SALVAGE XARQ SUPERniND SITE

Mr Paul Philbrick Preaident ELCO Electric Inc 311 Perry Road Bangor ME OUOl

Mr Gary o Veat Oputy Aaaiatant Secretary ot t he Air Force ( Envirom~ental Safety and Occupational Health) opartbullent ot Otenae SAPRQ RM4 C916 Waahint~ton DC Z OJJ0 - 1000

cynthia C and Roger J Pinette Gardne r Creek Road (Wade Road) Waahbum D 04716

Rita M Pinette Gardner creek Road (Wade Road) Waahburn D 04786

ATTACHMENT B

REQUEST FOR INFORMATION PINEME 1 S SALVAGE YARD SUPERFUND SITE

Inttructionbull o~1 A separate responte bullust be aade to each of the IZ

Quettionbull set forth in this Infonaation Requett H ~~

2 Precede each answer with the number of the Question to which it correaponds Hr3 In answering each Question identify all docUilents and ltlt peraona that contributed inforaation relating to your retponse

4 If infonaation not known or not available to you a a of 0-lt the date of subbulliaaion of a responae to thia Inforation Requebullt Olgt

should later becobulle known or available to you you bulluat 00

aupplebullent your response to EPA Moreover should you find at any tibulle after the aubbullbsion of this reaponte that any portion of the subaitted inforaation is false or aisrepreaenta the truth you bullust notify EPA thereof as soon as poaaible

5 For all documents produced in response to this Information Request arrange and label the documents to correspond with the Queation to which they are retponaive or indicate on the docuaent or in aoae other reaaonable aanner the nuaber of the Question to which they are responsive

6 The inforaation and docuaents requested herein aust be provided notwithstanding their possible characterization as confidential inforation or trade secreta You may if you desire asbullert a confidentiality claia covering part or all of the infor~~ation and documents requested pursuant to Sections l04(o) (7) (E) and (F) of CERCLA 42 usc II 9604(e) (7) (E) and (F) and 40 CFR f 2203(b) by attachinq to such intonation or documents at the time it is submitted a cover sheet bulltamped or typed lagend or other suitable form of notice employinq lanquage such a a trade secret proprietary or company confidential Information covered by such a claim will be disclosed by EPA only to the extent and only by means of the procedures set forth in 40 CFR Part 2 Subpart B If no such claim accompanies the information when it is received by EPA it may be made available to the public by EPA without further notice to you You should read the above cited regulations carefully before asserting a business confidentiality claim since certain categories of information are not properly the subj act of such a claim

7 Where apecitic intoration haa not been bullebullorialhecl in any docuaent but ibull nonethelebullbull reaponaive to bull Queation you bulluat reapond to the Queation vith bull written reaponae

ATTACHMENT 8 (continued)

petinitionbull

The following definitions shall apply to the following worda as they appear in thia Attachment B

l The term you or Respondent ahall mean the addrebullaee of thia Information Request the addreueea ofticera managerbull employees contractors and agentbull

2 The tent bullperson a a uaed herein includea in the plural aa well abull the singular any natural peraon tira unincorporated association partnerahip corporation trust or other anti ty

J The terms Pinettebull J unkyard Sitebull or Pinettebull Junkyard facility s hall mean and i nc lude the property on or about t he Pinet tes Junkyard or Salvage Yard l ocat ed on Gar dner Cr eek Road (aka Wade Road) in Wa l hburn Ma i ne

4 The term hazardoubull s ubatance shall have the bull bull bullbull defin i tion a s that contained i n Section 101(14) o f the Comprehena ive Envi ronmental Re1pon1e Cobull penl ation and Liability Ac t (CERCLA) 42 usc I 9601(14) and includea any bullixturea of auch hazardous aubs tancebull inc luding petrole um producta For pur poaea of this Inforaat i on Requebullt it ahall albullo include ma t e r ials with in the de fi ni tion of hazardous waa t e abull de fined by Section 1004 (5) o f the Resource Conbull ervation and Recovery Act (RCRA) 4 2 us c I 6903 (5)

5 The t erm pollutant or contami nant s ha ll have the same defi nition as t ha t contained in Section 101(33) of CERCLA 42 US C t 9601(33) a nd includebull any bullixturea of auch pollutants and contaminants wi th any othe r substances incl uding shypet rol eum products bull6 The term material or aater ial s shall mean and i nclude any and all goods objects aubatances and matter of any kind including but not limited to all hazardous substances pollutants and contaminants as defined above 8

N7 The term identify means with respect to a natural person to set forth the person a name present or last known business address and business telephone number present or last known home address and home telephone number and present or last known job title position or businesa

8 The term identify means with respect to a corporation partnership business trust or other association or business entity (including a sole proprietorship) to set forth its full name address legal form (eg corporation partnership etc ) organization if any and a brief description of its business

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

ATTACHMENT A

POTENTIALLY RESPONSIBLE PARTIES I PINETtE bull S SALVAGE XARQ SUPERniND SITE

Mr Paul Philbrick Preaident ELCO Electric Inc 311 Perry Road Bangor ME OUOl

Mr Gary o Veat Oputy Aaaiatant Secretary ot t he Air Force ( Envirom~ental Safety and Occupational Health) opartbullent ot Otenae SAPRQ RM4 C916 Waahint~ton DC Z OJJ0 - 1000

cynthia C and Roger J Pinette Gardne r Creek Road (Wade Road) Waahbum D 04716

Rita M Pinette Gardner creek Road (Wade Road) Waahburn D 04786

ATTACHMENT B

REQUEST FOR INFORMATION PINEME 1 S SALVAGE YARD SUPERFUND SITE

Inttructionbull o~1 A separate responte bullust be aade to each of the IZ

Quettionbull set forth in this Infonaation Requett H ~~

2 Precede each answer with the number of the Question to which it correaponds Hr3 In answering each Question identify all docUilents and ltlt peraona that contributed inforaation relating to your retponse

4 If infonaation not known or not available to you a a of 0-lt the date of subbulliaaion of a responae to thia Inforation Requebullt Olgt

should later becobulle known or available to you you bulluat 00

aupplebullent your response to EPA Moreover should you find at any tibulle after the aubbullbsion of this reaponte that any portion of the subaitted inforaation is false or aisrepreaenta the truth you bullust notify EPA thereof as soon as poaaible

5 For all documents produced in response to this Information Request arrange and label the documents to correspond with the Queation to which they are retponaive or indicate on the docuaent or in aoae other reaaonable aanner the nuaber of the Question to which they are responsive

6 The inforaation and docuaents requested herein aust be provided notwithstanding their possible characterization as confidential inforation or trade secreta You may if you desire asbullert a confidentiality claia covering part or all of the infor~~ation and documents requested pursuant to Sections l04(o) (7) (E) and (F) of CERCLA 42 usc II 9604(e) (7) (E) and (F) and 40 CFR f 2203(b) by attachinq to such intonation or documents at the time it is submitted a cover sheet bulltamped or typed lagend or other suitable form of notice employinq lanquage such a a trade secret proprietary or company confidential Information covered by such a claim will be disclosed by EPA only to the extent and only by means of the procedures set forth in 40 CFR Part 2 Subpart B If no such claim accompanies the information when it is received by EPA it may be made available to the public by EPA without further notice to you You should read the above cited regulations carefully before asserting a business confidentiality claim since certain categories of information are not properly the subj act of such a claim

7 Where apecitic intoration haa not been bullebullorialhecl in any docuaent but ibull nonethelebullbull reaponaive to bull Queation you bulluat reapond to the Queation vith bull written reaponae

ATTACHMENT 8 (continued)

petinitionbull

The following definitions shall apply to the following worda as they appear in thia Attachment B

l The term you or Respondent ahall mean the addrebullaee of thia Information Request the addreueea ofticera managerbull employees contractors and agentbull

2 The tent bullperson a a uaed herein includea in the plural aa well abull the singular any natural peraon tira unincorporated association partnerahip corporation trust or other anti ty

J The terms Pinettebull J unkyard Sitebull or Pinettebull Junkyard facility s hall mean and i nc lude the property on or about t he Pinet tes Junkyard or Salvage Yard l ocat ed on Gar dner Cr eek Road (aka Wade Road) in Wa l hburn Ma i ne

4 The term hazardoubull s ubatance shall have the bull bull bullbull defin i tion a s that contained i n Section 101(14) o f the Comprehena ive Envi ronmental Re1pon1e Cobull penl ation and Liability Ac t (CERCLA) 42 usc I 9601(14) and includea any bullixturea of auch hazardous aubs tancebull inc luding petrole um producta For pur poaea of this Inforaat i on Requebullt it ahall albullo include ma t e r ials with in the de fi ni tion of hazardous waa t e abull de fined by Section 1004 (5) o f the Resource Conbull ervation and Recovery Act (RCRA) 4 2 us c I 6903 (5)

5 The t erm pollutant or contami nant s ha ll have the same defi nition as t ha t contained in Section 101(33) of CERCLA 42 US C t 9601(33) a nd includebull any bullixturea of auch pollutants and contaminants wi th any othe r substances incl uding shypet rol eum products bull6 The term material or aater ial s shall mean and i nclude any and all goods objects aubatances and matter of any kind including but not limited to all hazardous substances pollutants and contaminants as defined above 8

N7 The term identify means with respect to a natural person to set forth the person a name present or last known business address and business telephone number present or last known home address and home telephone number and present or last known job title position or businesa

8 The term identify means with respect to a corporation partnership business trust or other association or business entity (including a sole proprietorship) to set forth its full name address legal form (eg corporation partnership etc ) organization if any and a brief description of its business

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

ATTACHMENT B

REQUEST FOR INFORMATION PINEME 1 S SALVAGE YARD SUPERFUND SITE

Inttructionbull o~1 A separate responte bullust be aade to each of the IZ

Quettionbull set forth in this Infonaation Requett H ~~

2 Precede each answer with the number of the Question to which it correaponds Hr3 In answering each Question identify all docUilents and ltlt peraona that contributed inforaation relating to your retponse

4 If infonaation not known or not available to you a a of 0-lt the date of subbulliaaion of a responae to thia Inforation Requebullt Olgt

should later becobulle known or available to you you bulluat 00

aupplebullent your response to EPA Moreover should you find at any tibulle after the aubbullbsion of this reaponte that any portion of the subaitted inforaation is false or aisrepreaenta the truth you bullust notify EPA thereof as soon as poaaible

5 For all documents produced in response to this Information Request arrange and label the documents to correspond with the Queation to which they are retponaive or indicate on the docuaent or in aoae other reaaonable aanner the nuaber of the Question to which they are responsive

6 The inforaation and docuaents requested herein aust be provided notwithstanding their possible characterization as confidential inforation or trade secreta You may if you desire asbullert a confidentiality claia covering part or all of the infor~~ation and documents requested pursuant to Sections l04(o) (7) (E) and (F) of CERCLA 42 usc II 9604(e) (7) (E) and (F) and 40 CFR f 2203(b) by attachinq to such intonation or documents at the time it is submitted a cover sheet bulltamped or typed lagend or other suitable form of notice employinq lanquage such a a trade secret proprietary or company confidential Information covered by such a claim will be disclosed by EPA only to the extent and only by means of the procedures set forth in 40 CFR Part 2 Subpart B If no such claim accompanies the information when it is received by EPA it may be made available to the public by EPA without further notice to you You should read the above cited regulations carefully before asserting a business confidentiality claim since certain categories of information are not properly the subj act of such a claim

7 Where apecitic intoration haa not been bullebullorialhecl in any docuaent but ibull nonethelebullbull reaponaive to bull Queation you bulluat reapond to the Queation vith bull written reaponae

ATTACHMENT 8 (continued)

petinitionbull

The following definitions shall apply to the following worda as they appear in thia Attachment B

l The term you or Respondent ahall mean the addrebullaee of thia Information Request the addreueea ofticera managerbull employees contractors and agentbull

2 The tent bullperson a a uaed herein includea in the plural aa well abull the singular any natural peraon tira unincorporated association partnerahip corporation trust or other anti ty

J The terms Pinettebull J unkyard Sitebull or Pinettebull Junkyard facility s hall mean and i nc lude the property on or about t he Pinet tes Junkyard or Salvage Yard l ocat ed on Gar dner Cr eek Road (aka Wade Road) in Wa l hburn Ma i ne

4 The term hazardoubull s ubatance shall have the bull bull bullbull defin i tion a s that contained i n Section 101(14) o f the Comprehena ive Envi ronmental Re1pon1e Cobull penl ation and Liability Ac t (CERCLA) 42 usc I 9601(14) and includea any bullixturea of auch hazardous aubs tancebull inc luding petrole um producta For pur poaea of this Inforaat i on Requebullt it ahall albullo include ma t e r ials with in the de fi ni tion of hazardous waa t e abull de fined by Section 1004 (5) o f the Resource Conbull ervation and Recovery Act (RCRA) 4 2 us c I 6903 (5)

5 The t erm pollutant or contami nant s ha ll have the same defi nition as t ha t contained in Section 101(33) of CERCLA 42 US C t 9601(33) a nd includebull any bullixturea of auch pollutants and contaminants wi th any othe r substances incl uding shypet rol eum products bull6 The term material or aater ial s shall mean and i nclude any and all goods objects aubatances and matter of any kind including but not limited to all hazardous substances pollutants and contaminants as defined above 8

N7 The term identify means with respect to a natural person to set forth the person a name present or last known business address and business telephone number present or last known home address and home telephone number and present or last known job title position or businesa

8 The term identify means with respect to a corporation partnership business trust or other association or business entity (including a sole proprietorship) to set forth its full name address legal form (eg corporation partnership etc ) organization if any and a brief description of its business

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

7 Where apecitic intoration haa not been bullebullorialhecl in any docuaent but ibull nonethelebullbull reaponaive to bull Queation you bulluat reapond to the Queation vith bull written reaponae

ATTACHMENT 8 (continued)

petinitionbull

The following definitions shall apply to the following worda as they appear in thia Attachment B

l The term you or Respondent ahall mean the addrebullaee of thia Information Request the addreueea ofticera managerbull employees contractors and agentbull

2 The tent bullperson a a uaed herein includea in the plural aa well abull the singular any natural peraon tira unincorporated association partnerahip corporation trust or other anti ty

J The terms Pinettebull J unkyard Sitebull or Pinettebull Junkyard facility s hall mean and i nc lude the property on or about t he Pinet tes Junkyard or Salvage Yard l ocat ed on Gar dner Cr eek Road (aka Wade Road) in Wa l hburn Ma i ne

4 The term hazardoubull s ubatance shall have the bull bull bullbull defin i tion a s that contained i n Section 101(14) o f the Comprehena ive Envi ronmental Re1pon1e Cobull penl ation and Liability Ac t (CERCLA) 42 usc I 9601(14) and includea any bullixturea of auch hazardous aubs tancebull inc luding petrole um producta For pur poaea of this Inforaat i on Requebullt it ahall albullo include ma t e r ials with in the de fi ni tion of hazardous waa t e abull de fined by Section 1004 (5) o f the Resource Conbull ervation and Recovery Act (RCRA) 4 2 us c I 6903 (5)

5 The t erm pollutant or contami nant s ha ll have the same defi nition as t ha t contained in Section 101(33) of CERCLA 42 US C t 9601(33) a nd includebull any bullixturea of auch pollutants and contaminants wi th any othe r substances incl uding shypet rol eum products bull6 The term material or aater ial s shall mean and i nclude any and all goods objects aubatances and matter of any kind including but not limited to all hazardous substances pollutants and contaminants as defined above 8

N7 The term identify means with respect to a natural person to set forth the person a name present or last known business address and business telephone number present or last known home address and home telephone number and present or last known job title position or businesa

8 The term identify means with respect to a corporation partnership business trust or other association or business entity (including a sole proprietorship) to set forth its full name address legal form (eg corporation partnership etc ) organization if any and a brief description of its business

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

ATTACHMENT 8 (continued)

petinitionbull

The following definitions shall apply to the following worda as they appear in thia Attachment B

l The term you or Respondent ahall mean the addrebullaee of thia Information Request the addreueea ofticera managerbull employees contractors and agentbull

2 The tent bullperson a a uaed herein includea in the plural aa well abull the singular any natural peraon tira unincorporated association partnerahip corporation trust or other anti ty

J The terms Pinettebull J unkyard Sitebull or Pinettebull Junkyard facility s hall mean and i nc lude the property on or about t he Pinet tes Junkyard or Salvage Yard l ocat ed on Gar dner Cr eek Road (aka Wade Road) in Wa l hburn Ma i ne

4 The term hazardoubull s ubatance shall have the bull bull bullbull defin i tion a s that contained i n Section 101(14) o f the Comprehena ive Envi ronmental Re1pon1e Cobull penl ation and Liability Ac t (CERCLA) 42 usc I 9601(14) and includea any bullixturea of auch hazardous aubs tancebull inc luding petrole um producta For pur poaea of this Inforaat i on Requebullt it ahall albullo include ma t e r ials with in the de fi ni tion of hazardous waa t e abull de fined by Section 1004 (5) o f the Resource Conbull ervation and Recovery Act (RCRA) 4 2 us c I 6903 (5)

5 The t erm pollutant or contami nant s ha ll have the same defi nition as t ha t contained in Section 101(33) of CERCLA 42 US C t 9601(33) a nd includebull any bullixturea of auch pollutants and contaminants wi th any othe r substances incl uding shypet rol eum products bull6 The term material or aater ial s shall mean and i nclude any and all goods objects aubatances and matter of any kind including but not limited to all hazardous substances pollutants and contaminants as defined above 8

N7 The term identify means with respect to a natural person to set forth the person a name present or last known business address and business telephone number present or last known home address and home telephone number and present or last known job title position or businesa

8 The term identify means with respect to a corporation partnership business trust or other association or business entity (including a sole proprietorship) to set forth its full name address legal form (eg corporation partnership etc ) organization if any and a brief description of its business

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

9 The term identify means with respect to a document to provide ita customary business description ita data ita number if any (invoice or purchase order number) the identity ot the author addressor addressee andjor recipient and the substance or the subject bullattar

10 The term release has the same definition as that contained in Section 101(22) of CERCLA 42 usc I 9601(22) and includes any spilling leaking pumping pouring ebullitting emptying discharging injecting escaping leaching duping or disposing into the environment includift9 the abandonment or discharging of barrels containers and other closed receptacles containinq any hazardous substance or pollutant or contabullinant

11 Tha term document and documents means any way of recordinq s torinq or transmitting intonation and shall include writings ot any kind fontal or intonal whether or not wholly or parti ally in handwriting including by way of illustrat i on and not by way of l iaitati on any invoice receipt endoraaaent check bank draft cance lled check deposit slip withdrawal slip order correspondence record book ainutes aeaorandua of telephone and other conversations includift9 etings agreeaenta and the lika diary calendar des k pad scrapbook notebook bulletin circular fora paaphlet atateaent journal postcard letter teleqraa telex report notice aeaaage analysis coaparison graph chart interoffice or intraoffice couunications photostat or other copy of any docuenta aicrofila or other fila record any photographs sound recordinq on anymiddot typa of device any punch card disc or disc pack any tape or other type of bullbullbullory generally associated with computers and data processing (together with the proqraa ing instructions and othe r written material necessary to usa such punch card disc or disc pack tape or other type of aeaory and together with printouts of such punch card disc or disc pack -tape or other type of memory) r and (a) every copy of each document which is not an exact duplicate of a document which is produced (b) every copy which has any writing figure or bullnotation annotation or the like on it (c) drafts (d) attachments to or enclosures with any document and (e) every document referred to in any other document 8

12 The terms and and or shall be construed either N disjunctively or conjunctively as necessary to brinq within the scope of this Information Request any information which might otherwise be construed to be outside ita scope

13 The term arrangement means every separate contract or other agreement between two or more persons

14 The terms transaction or transact mean any sale transfer giving delivery change in ownership or change in possession

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

ATTACHMENT 8 (continued)

1 Identify the Respondent and each and every person answering these Questions on behalf of the Respondent

2 For each and every Question contained herein identi ty all persona consulted in the preparation of the answer

J For each and every Question contained herein identi fy all documents consulted examined or referred to in the preparation of the answer and provide true and accurate copies of all such documents

4 If you have a reason to believe that there bullay be persona able to provide a bullore de tailed or cobullplete response to any Question contained here in or who aay be able to provide additional r esponsive docubullents identify such persona and the additional intoraation or docubullenta that they uy have

5 For each and every person including Respondents employees agents attorneys contractors and representatives who you know believe or suspect have knowledge inforation or docUienta concerning the generation use purchase treataent storage disposal or other handling of transforaers or other materials at or transportation of such aaterials to the Pinette s Junkyard

a identify the person1 and

b for each person identified describe the knowledge i nfonuttion or docWie nts he or she has is be lieved to have or i s s us pected to have

6 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the transportation of transformers andor any other materials to the Pinettes Junkyard Site

7 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the generation use purchase treatment storage disposal or other handling of transformers andor any other materials that were transported directly or indirectly to the Pinettes Junkyard Site

8 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the use treatment storage disposal or other handling of transformers andor any other materials at the Pinettes Junkyard Site

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

9 Produce all documents that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persona who caused or contributed to the transportation of transformers andor any other materials to the Pinettes Junkyard Site

10 Produce all docu~~enta that in any way relate or pertain to evidence or have any bearing upon the identities of any and all persons who caused or contributed to the generation use purchase treatment storage disposal or other handling of transfoBera andor any other aateriala that were transported directly or indirectly to the Pinettes Junkyard Site

11 Produce all docuaents that in any way relate or pertain to evidence or have any bearing upon any and all arranqeaenta between any persona for disposal or transportation tor disposal ot transformerbull andor any other aaterialbull at or to the Pinettebull Junkyard site

12 With respect to any arranqeaenta tor disposal or treatbullent or arranqebullenta tor transportation tor disposal or treatment of tranafon~ers andor any other aateriala at or to the site identify each and every person with whoa you aada

such arraft9enta 1

b identify each and every person who accepted such aaterials for disposal or for transportation for diapoaall

c specify the dates of such arranqeaents1

d describe in detail the nature including the chemical content characteristics physical state (aq solid liquid) and quantity (volume and weight) of all materials involved in each such arrangement identify each and every parson who selected the Pinettabull Junkyard Site as the location at which materials ware to be disposed or treated

t state the amount paid in connection with each such arrangement the method of payment and the identity of the persons involved in each arrangement

describe what was done to the materials once they were brought to the Pinettes Junkyard Site

9 middot

h describe the final disposition of each of the transformers or other materials involved in each arrangement

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

i specify all measures taken by you to determine how and where treatment or disposal of the tranafoBere or other bullateriale involved in each arrangement would actually take place

j identify all participantbull and provide the substance of (and if written produce all documents relating to) any couunicationa between any persona relating to such disposal or transportation of the transformers or other OH

gtZ aaterials Hffl

~ 13 Describe the acta or omissions of any persona other

than your employees agents or those persona with whom you had a contractual relationship which aay have caused the release or Hr Junkyard Site In addition ltltthreat of release of hazardous substances at the Pinette bull a

i a identify such peraoneJ 0-lt Olgt b identify any daaagee relating to or reaul ting from 00 such act or oliiasions

c describe all precautions you took against middot foreseeable acta or oaissions of any such third parties Include the consequences that could foreseeably result troa any such acta or oaiesiona r and

d describe the care you exercised with respect to the hazardous substances found at the Pinettes Junkyard Site

14 With respect to the transformers that were removed from Loring Air Force Base (the Base) by Avon C Brown Inc provide all intonation and all underlying documentation pertaining to the 11anufacture purchase installation and remaining use of each transformer

15 With respect to any contracts or agreements oral or written between the Air Force or the Base and Avon c Brown Inc provide all information and all underlying documentation to include the identity of any and all parties pertaining to any representations made by any and all parties regarding the replacement removal salvage or disposal of transformers andor any other materials from the Base

16 With respect to the replacementremoval if any of transformers other than those covered in the contract ot February 1979 between the Air Force and Avon C Brown Inc provide all information and all underlying documentation pertaining to

a the type of transformer(s) replacedi

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

b the rebullaining use if any ot the transtoner(s)

c the dates) of the removal of the transformer(bull) 1

d the identity of the person responaible tor removing andjor replacing the transtoraer(s) and the contract evidencing auch agreementJ and

e the method and place of disposal of the transtor111er(a)

16 Provide copies of any existing policies or quidelinea used by t he Air Force andor the Departbullent of Oetenae pertaining to the removal replacement or disposal of tranafoBera

17 Provide all intonation and all underlying documentation pertaining to any couunications or attempts to co-unicate with EPA to inquire about requlationa regarding the rebulloval replacebullent or diaposal of transtonera Your answer should include the following

a the identity of any peraon(s) counicatinq or attebullpting to couunicate with PAJ

b the identity of EPA representatives responding to any co-unicationa J

c the date of the counicationa(a) or attebullpted couunicationas) and

d any actions taken by the Air Force probullpted by the co-unication(a) it any with EPA

19 Provide all intonation and all underlying documentation pertaining to the Air Force bull intentions or to any alternatives contemplated by the Air Force regarding the removal and eventual diapoaal of the transformers frobull the Central Heating Plant Substation Your answer should include any alternatives proposed or discussed prior to contracting with Avon c Brown Inc

20 Provide all information and all underlying documentation pertaining to the Air Force bulla knowledge that the transporters removed by Avon C Brown were to be or had been transported to the Pinettes Junkyard Site Your answer should specify the following

a the date when the Air Force learned that the transformers were to be or had been transported to the Sitet

b the person(s) who informed the Air Force that the

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450

rebulloved tranbullfonera were to be or had been tranaported to the Pinettebull Junkyard Site1 and

c a debullcription of any actionbull taken by the Air Force upon learning that the rebulloved tranaforaera were to be or had been tranaported to the Pinettebull Junkyard Site

1. barcode 581450
2. barcodetext SDMS Doc ID 581450