Greenwich is not considering all the liabilities from contamination

FI-Letter-to-the-EditorTo the Editor

Pursuant to SEC Act Rule 15c2-12, The Town of Greenwich (TOG) is required to disclose contingent liabilities regarding issuance of “MISA Construction Bonds.”

The following contingent liabilities must be disclosed:

1. MISA construction is planned on a known “Superfund” site containing massive quantities of PCBs, arsenic, lead, and chlordane. There is no current approved site plan. The USEPA Toxic Substances Control Act (TSCA) administrator has been advised her issuance of a “conditional approval” is based on materially false information. MISA construction cannot start until all terms of this “conditional approval” are met.

2. The USEPA penalty for submission of a materially false application dating back to before passage of “The Clean Water Act” is up to $351,312,500, to be used to remediate the site to the level required by the TSCA conditional approval. This amount may not be sufficient to remediate the MISA site. TOG is additionally liable for penalties not to exceed three times the total spent.

3. AECOM tests have determined chemicals controlled by TSCA, buried throughout the 54.75 acre GHS campus, have the same “finger-print” as chemicals tested by AECOM at the Cos Cob Power Plant. AECOM neither sought nor received permits required to move the chemicals from CCPP to GHS.

4. The USEPA penalty for moving restricted materials without required manifests is potentially $271,012,500, proceeds to be used to remediate the CCPP site to the level required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA commonly called ”The Superfund Act”). This amount may be insufficient to remediate CCPP. TOG is additionally liable for penalties not to exceed three times the total spent.

5. Owners of all properties surrounding GHS, CCPP, and The Holly Hill Resource Recovery Facility must file deed restrictions, in perpetuity, with USEPA, stating the purposes for which the land cannot be used, based on testing not yet conducted by AECOM. Some land may be condemned. Land owner suits for damages could exceed $1,000,000,000.

6. Medical claims for exposure to toxic substances at all three facilities could exceed $1,000,000,000.

 

Bill Effros
Greenwich

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