KARL A.

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AD^I11LD I |, Y, anu RI
kmignone@veiiilluana.com



243 1RLSSLR BLVD
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203-355-3620 IAX 203-355-3621
vvv.veiiilluana.com



Portland Augusta Boston Stamford Providence Washington, D.C.

September 12, 2014

VIA ELECTRONIC MAIL

Oswald Inglese, Jr., Director
Water Permitting and Enforcement Division
Bureau of Materials Management and Compliance Assurance
79 Elm Street
Hartford, CT 06106-5127

Re: Fusion Paperboard Closure Plan

Dear Mr. Inglese:

Attached is the closure report for the Fusion Paperboard facility located in Sprague,
Connecticut. We are submitting this report today pursuant to the deadline set forth in your
August 26, 2014 correspondence.

As you will see, the report and the adjoining tables focus predominantly on securing,
inventorying, and arranging for disposal of all process-related materials and wastes at the
facility. This task has been given priority due to its time and labor intensive nature. Removal of
such materials is scheduled to be complete by the end of September. With this phase of closure
nearing completion, our focus can shift to the larger and more complex issues facing the facility.
The largest closure issue at the facility relates to the decommissioning of the waste water
treatment system. There are significant unknowns associated with the remainder of the work; the
most significant of these relates to the closure of the waste water treatment system and
specifically the three aeration basins and two polishing lagoons. Fusion cannot and will not be
able to guarantee its ability to fund the entire closure plan until an outline for the waste water
system is fully developed and the associated cost ranges known. Once Fusion obtains the range
of costs associated with the plan, Fusion cannot guarantee that it will have sufficient
funding to complete the work contemplated by the plan. Obviously, it is not Fusions intent
to fail to complete the environmental closure, but as DEEP has been previously advised, Fusion
has limited resources available to do so.

September 12, 2014
Page 2
Fusion continues to work closely with its environmental consultants in developing the
appropriate environmental closure plan. Fusion has been and remains ready to work with DEEP
and DECD to develop a closure plan that is both appropriate and fiscally sound. Please feel free
to contact me if you have questions.



Very truly yours,

Karen A. Mignone

KAM/mtt
Enclosure
cc: Robert C. Isner (w/encl.)
Nicole Lugli (w/encl.)