HomeMy WebLinkAbout23SITE9 125 DepotRd CTDEEP SWDPExt2024Correspondence Rec101923
Tipping Point Resources Group, LLC
2 Poplar Street, P.O. Box 8532
New Haven, Connecticut 06531-0532
Corporate: (800) 603-8902 Web: www.TPRGLLC.com Page 1
16 October 2023
Commissioner Katie Dykes
Connecticut Department of Energy and Environmental Protection
79 Elm Street
Hartford, Connecticut 06106-5127
Subject: SWDP Demonstration Project Approval No: 08601340-DP - Issuance January 5, 2022
[Extension Request]
Dear Commissioner Dykes,
The purpose of this leter is to request an extension of the Solid Waste Demonstra�on Project
Authoriza�on on file (atached) for the above subject.
Sec�on 18 of the SWDP states:
The dura�on of the Demonstra�on Project shall not exceed twenty-four (24) months, beginning
with the date of this approval, unless an extension is first granted in wri�ng by the Commissioner.
Presently, the CT DEEP SWDP Authoriza�on will be expiring on January 5, 2024, for assessing the
viability of manufacturing engineered fill for beneficial use u�lizing sediment dredged from Long
Island Sound and other dredging loca�ons for upland placement.
Tipping Point Resources Group (TPRG) is reques�ng the extension as a result of the
environmental management and local development/permi�ng process which includes Site
Plan/Coastal Site Plan Approval at the Gateway Terminal Thames River waterfront facility located
at 125 Depot Road, Montville, Connec�cut. For the past two 2 years TPRG has made significant
progress with Gateway Terminals and the Town of Montville Department of Land Use and
Development in the permi�ng for this loca�on to process dredged materials. TPRG con�nues to
be on target for a Fall 2023 permi�ng approval from the Town of Montville.
As we con�nue to “break ground” on this endeavor, we have not processed dredged material to
date at Gateway Montville as evidenced in our Quarterly Reports that we submit to CT DEEP. As
stated above, this is the result of the mul�-process undertakings with Gateway Corporate and
the Town of Montville. TPRG is op�mis�c that we are at that juncture in that final approval by
the Town of Montville.
Under the exis�ng Authoriza�on, there is a requirement that states “TPRG proposes to
manufacture engineered fill through its Pneuma�c Flow Tube Mixing (“PFTM”) process in which
contaminated dredged sediments will be treated with Portland cement in order to stabilize, and
thereby immobilize, contaminants present in the dredged sediments”.
Tipping Point Resources Group, LLC Page 2
It has been discussed with CT DEEP through the Client Concierge Service which Ms. Amy
Richardson coordinated with TPRG and the different regulatory bodies that “other” dredged
material stabiliza�on processes could be employed at the Gateway Terminal facility other than
the PFTM process.
TPRG would like to respec�ully request a modifica�on to the SWDP Authoriza�on for an
inclusion with this “addi�on of u�lizing other dredged material stabiliza�on processes for
amending dredged material”.
Below, is the discussion that was detailed to this request:
From: Richardson, Amy <Amy.Richardson@ct.gov>
Sent: Friday, October 28, 2022 12:55 PM
Waste: your contacts are Brent Madho and Gabrielle Frigon
The request to modify the beneficial use determina�on is acceptable. The addi�onal sources and
technology to implement the project are acceptable so long as the final product meets the
residen�al direct exposure criteria as indicated in the Remedia�on Standard Regula�ons and
does not contradict the Department’s an�-degrada�on policy. The BUD includes a condi�on for
there to be no detec�on of PCBs so the Department will not proceed with the request to modify
that condi�on of the BUD. However, if trace amounts of PCBs are detected and material is
treated and tested where no PCBs are detected, the BUD would not need to be modified for
placement but if instrumenta�on detec�on is sensi�ve to detect below <1PPM then WEED would
need an okay from other divisions (Remedia�on, An�-deg) that any material which contained
trace amounts of PCBs and was treated can be placed at the site.
TPRG acknowledges and will comply with the above BUD determina�on by CT DEEP on
“addi�onal sources and technologies” for the stabiliza�on of dredged materials.
Ques�ons related to this request can be directed to Alfred Kovalik at alfred@tprgllc.com
(203)858.4034 or Eric Stern at eric@tprgllc.com (201) 247.3281.
Thank you for your considera�on.
Sincerely
Alfred N. Kovalik, PE
Managing Director
Cc: Gabrielle Frigon (CT DEEP)
Eric Stern (TPRG)