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1-13320_RAO A3-P C1-P Statement_2011-02-Full Class A3 RAO-P & Class C1 RAO-P Statements FORMER CUTLERY RACEWAY RTN #1-13320 320-360 RIVERSIDE DRIVE NORTHAMPTON, MASSACHUSETTS February 8, 2011 Prepared for: Cutlery Building Assoc. c/o Alan Verson 56 Main Street Northampton, MA 01060 NEE Project No.02-2053-H February 8, 2011 Mr. Ben Fish Massachusetts DEP 436 Dwight Street Springfield, Massachusetts 01103 RE: Class A3 & Class C1 Response Action Outcome (RAO-P) Statements Former Cutlery Raceway 320-360 Riverside Drive Northampton, Massachusetts RTN #1-13320 Dear Mr. Fish: New England Environmental Inc., (NEE) is pleased to submit this Class A3 Partial Response Action Outcome (RAO-P) Statement for the portion of the Site on the two southerly lots (firehouse and cutlery buildings) and a Class C1 RAO-P for the northern portion of the Site (raceway/levee) on behalf of Cutlery Building Associates for the above-referenced property. The objective of this investigation was to determine and remediate the extent of the release at the Site as defined under the Massachusetts Oil and Hazardous Materials Release Prevention and Response Act (Massachusetts General Law, chapter 21E) and the Massachusetts Contingency Plan (MCP)[310 CMR 40.0000]. The remediation activities described below indicate that the extent of the release is is known, and that the actions completed have resulted in a condition of No Significant Risk for the southerly portion of the Site and No Substantial Hazard for the northerly lot, and therefore the Site is eligible for a Response Action Outcome (RAO). If you have any questions or comments, please contact our office. cc: Cutlery Building Associates, PRP, Site Owner, c/o Mr. Alan Verson Mr. Nelson Shifflett, PRP, Site Owner-Former Firehouse City of Northampton: Planning Office Conservation Commission H:\Projects\02-2053_RAO-Report.doc Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page i Northampton, Massachusetts TABLE OF CONTENTS 1.0 INTRODUCTION ..................................................................................................................... 1 2.0 BACKGROUND ............................................... ........................................................................ 2 2.1 Previous Investigations and Activities ................................................................................. ....... 2 2.2 Recent Groundwater Sampling & Results ................................................................................... 3 2.3 Bank Stabilization Monitoring ........................... ......................................................................... 5 3.0 REPRESENTATIVENESS EVALUATION & DATA USABILITY ASSESSMENT ....... 9 3.1 Data Usability Assessment ..................... ..................................................................................... 9 3.1.1 Analytical Data Usability Assessment .................................................................... ............ 9 3.1.2 Field Quality Control Data Usability Assessment ............................................................ 10 3.1.3 Data Quality Objectives .................................... ................................................................ 10 3.2 Representativeness Evaluation ................................................................................................. . 10 3.2.2 Data Collection Approach ................................................................................................ 11 3.2.3 Field Screening Data .................................... .................................................................... 11 3.2.4 Selection of Sampling Locations and Depths .................................................................... 11 3.2.5 Number and Spatial Distribution of Sampling Locations ................................................. 12 3.2.6 Temporal Distribution of Samples ............................................ ........................................ 12 3.2.7 Critical Samples ................................................................................................................ 12 3.2.8 Data Collection Evaluation .............................................................................................. 12 3.2.9 Data Validation .............................................. ................................................................... 13 3.2.10 Completeness ............................................................................................................ ........ 13 3.3 Summary of REDUA................................................................................................................. 13 4.0 EXTENT OF CONTAMINATION ...................... ................................................................. 14 4.1 Raceway Fill ................................................................................................................. ............. 14 4.2 Exposed Levee ........................................................................................................................... 15 4.3 Conceptual Site Model .............................................................................................................. 16 5.0 RISK CHARACTERIZATION ..................................................... ........................................ 18 5.3.1 Reportable Concentrations for Soil and Groundwater ..................................................... 20 5.3.2 Method 1 Soil and Groundwater Cleanup Categories ...................................................... 20 5.3.3 Applicability of Method 1 Risk Assessment .............................................................. ........ 21 6.0 CLASS A3 RESPONSE ACTION OUTCOME: AOC-1 .................................................... 22 6.2 Activity & Use Limitation-AOC-1 ................................................... ........................................ 23 6.2 RAO Statement Transmittal Form ............................................................................................. 25 6.3 Public Involvement .................................................................................................................... 25 7.0 CLASS C1 RESPONSE ACTION OUTCOME: AOC-2 & AOC-3 ................................... 26 7.1 RAO Statement Transmittal Form ............................................................................................. 28 7.2 Public Involvement .................................................................................................................... 28 8.0 CONCLUSIONS ................................................... .................................................................. 29 Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page ii Northampton, Massachusetts FIGURES Figure 1 Locus Map Figure 2 Air Photo Figure 3 Site Plan Figure 4 Sample Location Site Plan – AOC-1 Figure 5 Sample Location Site Plan – AOC-3 Figure 6 Priority Resource Map Figure 7 AUL Plan – AOC-1 Figure 8 AUL Plan – AOC-2 & AOC-3 Figure 9 As-Built Site Plan – Limit of RAO TABLES Table 1 Groundwater Sample Laboratory Results Table 2-1 OTO 2006 Groundwater Data Table 2-2 OTO 2006 Riverbank Soil Data Table 2-3 OTO 2006 Surface Water Data Table 2-4 OTO 2006 Sediment Data Table 3 Data Summary Table Table 4-1 Confirmatory Soil Results SA-1 Excavation Table 4-2 Confirmatory Soil Results SA-2 Excavation Table 4-3 Confirmatory Soil Results SA-3 Excavation Table 4-4 Confirmatory Soil Results SA-4 Excavation Table 4-5 Confirmatory Soil Results SA-5 Excavation Table 4-6 Confirmatory Soil Results CB-1 Excavation Table 5 Confirmatory Soil Results Levee Excavations Table 6-1 Maximum and Minimum COC Concentrations – AOC-1 Table 6-2 Maximum and Minimum COC Concentrations – AOC-2 and AOC-3 PHOTOGRAPHS APPENDICES Appendix A Terms & Conditions Appendix B Wetland Certificates of Compliance Class A-3 RAO Statement – Transmittal Form -BWSC-104 AUL AREA #1 -Transmittal Form – BWSC-113 AUL AREA #2 -Transmittal Form – BWSC-113 Class C-1 RAO Statement – Transmittal Form -BWSC-104 AUL AREA #3 -Transmittal Form – BWSC-113 Appendix C Summary of Previous Submittals Appendix D NEE Standard Operating Procedures Appendix E Laboratory Results & Groundwater Sampling Log Appendix F Risk Assessment Appendix G AUL Documents Appendix H Public Involvement Letters Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 1 Northampton, Massachusetts 1.0 INTRODUCTION A Class A-3 and a Class C-1 Partial Response Action Outcome (RAO-P), as described by 310 CMR 40.0030 have been achieved relative to disposal of industrial waste materials, demolition debris, and common refuse in an unregulated landfill within and along the former raceway leading to the Cutlery Building at 320-360 Riverside Drive in Northampton, Massachusetts (Figures 1 & 2). For the Area AOC-1, a Permanent Solution has been achieved, the level of OHM in the environment has not been reduced to background, an Activity and Use Limitation has been implemented, and the OHM material at the disposal Site does not exceed any UCL in soil and groundwater, therefore this portion of the Site is eligible for a Class A-3 RAO. For the portions of the Site labeled AOC-2 and AOC-3, a condition of No Substantial Hazard exists, and response actions to achieve a permanent solution are not currently feasible. This portion of the Site is eligible for a Class C-1 RAO. The objective of this investigation was to determine the extent of and remediate the release at the Site as defined under the Massachusetts Oil and Hazardous Materials Release Prevention and Response Act (Massachusetts General Law, chapter 21E) and the Massachusetts Contingency Plan (MCP)[310 CMR 40.0000]. This investigation was completed under the Terms & Conditions of our contract (Appendix A). The activities described below indicate that the extent of the release is known, and that the actions completed have resulted in a condition of No Significant Risk within AOC-1 and No Substantial Hazard at AOC-2 and AOC-3, and therefore the Site is eligible for a Response Action Outcome (RAO). An RAO Transmittal Form (BWCS-104) is included with this eDEP submittal for each section of the Site. Copies of the completed Transmittal Forms are included in Appendix B of paper copies of this report. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 2 Northampton, Massachusetts 2.0 BACKGROUND The Site is the former raceway that carried water from the Mill River to the former Northampton Cutlery mill building (Figure 3). A steep bank separates the former raceway from the east bank of the Mill River, approximately 15 feet below. The course of the former raceway follows a long, relatively flat strip of land approximately 40 to 60 feet wide. The strip extends in the north-south direction and is bordered on the east by Riverside Drive. A slight rise of 5 to 10 feet and a guardrail separate the flat strip of land from the road. The former raceway is not directly visible at most of the ground surface because it has been filled and is now covered in different portions by trees, shrubs, organic debris, and the Cutlery Building and Valley Home Improvement parking lots. The course of the raceway has been determined by using historic maps and inspections of ground topography. The downstream end of the raceway abuts the back (western-most) portion of the Cutlery Building. Following its course upstream it then winds north through (under) the now paved parking lots of the Cutlery Building (Lot 32) and Valley Home Improvement (VHI, Lot 76) behind the former firehouse building, and then continues in the narrow strip of undeveloped land between Riverside Drive and the Mill River to the northern portion of Lot 77, where water entered the raceway at a former dam. The raceway was built in the mid 1800’s and carried water until the mid 1900’s. Some time in the 1940’s or 1950’s the water from the raceway was no longer needed and it was drained. For the next 20 to 30 years, the southerly portion of the raceway, extending approximately 600 feet north from the Cutlery Building (400 feet into Lot 77) was used as a dumping site for household garbage, demolition debris, and industrial wastes. The levee that separates the raceway from the river has also been found to contain hazardous materials (metals). The levee becomes topographically prominent from approximately 600 ft to 880 ft north of the Cutlery Building, where the former raceway has not been filled. The Site has been divided into three Areas of Concern (AOC): AOC-1: This portion of the Site includes the northwestern portion of the southerly Cutlery Lot 32 and the western portion of the Valley Home Improvement (VHI) Lot 76 as shown on Figures 3 and 5. This includes the paved parking lots behind the Cutlery building and the VHI building and the sloped bank down to the Mill River west of these parking lots. AOC-2 and AOC-3: These areas of the Site occupy the narrow strip of undeveloped land between Riverside Drive and the Mill River, from the northern VHI property line to the northern portion of Lot 77, where water entered the raceway at a former dam (Figure 3). AOC-2 includes the filled portion of the raceway, but does not include the bank of the Mill River west of this section. AOC-3 includes the entire exposed levee from the northerly end of AOC-2 north to the chain link fence at the north end of the Site. 2.1 Previous Investigations and Activities Previous investigations documented the character of the fill material (contains solid and industrial waste, and demolition debris), and the excavation and stabilization of these materials on Site. A brief summary of these activities is presented below, and a detailed summary of all the previous investigations is included in Appendix C. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 3 Northampton, Massachusetts In all areas of AOC-1 where heavy metals were identified in excess of their respective UCLs in 2005, this material was moved to the existing soil stockpile within AOC-2. This includes several areas under the Cutlery and Valley Home Improvement parking lots, and an area on the bank of the Mill River on the Cutlery property. Confirmatory soil samples indicated that the UCL contaminated soil had been removed from AOC-1. Changes to several UCL concentrations were incorporated in the 2006 MCP “Wave 2 Changes”. As a result, the soil sample CB-12 is now identified as containing lead (4,480 mg/kg) and antimony (471 mg/kg) at concentrations in excess of their respective UCL concentrations (3,000 mg/kg and 400 mg/kg). These concentrations are part of the calculated Exposure Point Concentrations (EPCs) calculated in the Method 3 risk characterization (see see Sections 5.4 and 6.1). The resulting EPCs indicate this material does not need to be removed in order to close this portion of the Site. Residual contamination in this and other areas of AOC-1 is still present in soil. The areas of the parking lot where residual contamination remains have been paved and this pavement will be maintained in good condition. The remaining metals-impacted soil along the bank leading down to the Mill River (including CB-12) was physically stabilized in place to prevent any further erosion and these erosion controls will be maintained in good condition. The unpaved areas within AOC-1 have been fenced off with a chain link fence and this fence will be maintained in good condition. In AOC-3, the bank of the Mill River was stabilized using erosion control fabric and grass seed. One section of the stone rip-rap at the base of the bank was re-built in an effort to control erosion. These activities have stabilized this portion of the Site and dramatically reduced erosion. Bank stabilization was not required in AOC-2 as this portion of the Site is relatively flat, the bank is further from the Mill River, and is thickly wooded with mature trees. The filled portions of the raceway in AOC-2 were used as the location of a soil stockpile accepting primarily UCL soil from AOC-1. The fill in this area was similar in nature to the stockpile soil, in that it had been found to exceed UCL concentrations of several metals in multiple places, so placement of the stockpile in AOC-2 did not make this location worse. The stockpile was then graded in such a way as to reduce its height and was covered in geo-textile fabric and loam. The pile was then seeded with grass to prevent erosion. A five-foot high chain link fence was then installed at both ends of AOC-2 and AOC-3 and along the entire length of Riverside Drive in such a fashion as to isolate these areas from trespassers. 2.2 Recent Groundwater Sampling & Results April 2006 On April 3, 2006 the “Wave 2 Changes” to the MCP were implemented. These revisions and updates to the regulations included a change in the GW-3 standard for nickel from 80 ug/L(ppb) to 200 ug/L. This change has been incorporated in the groundwater tables for this Site and renders the nickel results for the two most recent rounds of groundwater sampling discussed below to be acceptable (less than the GW-3 standard; Tables 1 & 2). June 2006 O’Reilly, Talbot & Okun (OTO) completed a Brownfields Investigation Report (July 2006) for the City of Northampton with the stated goals of filling existing gaps in the environmental data set and informing the City of current site conditions. This was conducted as part of the City’s evaluation of portions of the Site for possible future acquisition for recreational purposes, not for any specific MCP requirements. This report was copied to the MADEP at the time of its publication. Tasks completed included: Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 4 Northampton, Massachusetts 1) Installation of five (5) groundwater monitoring wells spaced along the length of the Site; 2) Analysis of soils from borings to provide information on the vertical extent of impact; 3) Installation of two (2) hand-driven groundwater monitoring points along the river; 4) Riverbank soil and groundwater testing along the length of the parcel, including re-testing of the existing well MW-4; 5) Surface water and sediment testing in the abutting Mill River. The OTO data points have been incorporated in the Site Plans (Figures 3 & 4). The OTO data tables are included as Tables 2-1 through Table 2-4. The OTO report is summarized in Appendix C and the groundwater results are discussed in this section. On June 5, 2006, OTO sampled groundwater at the Site from five new monitoring wells, one existing monitoring well, and two hand-driven well points along the Mill River. OTO’s groundwater results indicate that no VOCs or EPH constituents were detected in Site groundwater (Table 2-1). Metals were detected above GW-3 groundwater standards in samples from two wells (CR-6 and MW-4). Well CR-6 is located approximately 40 feet southeast of well MW-4 and is adjacent to or within raceway fill materials. The concentration of lead in CR-6 (158 ug/L) slightly exceeds the GW-3 standard (100 ug/L). OTO states this result may indicate the possibility of lead migrating from the Site into surface water at a concentration of concern for aquatic life. However, OTO did not detect lead or other metals at concentrations of concern (exceeding MADEP 2006 Sediment Screening Values) in the surface water samples they collected from the Mill River. At MW-4, OTO noted that there was only a small amount of groundwater in the screened section of the well, and that the water collected had a high visual entrained sediment content. Two samples were submitted to the lab for analysis from this well, a filtered sample and an unfiltered sample. Metals analytical results for the filtered sample from MW-4 indicate no metals above GW-3 standards, while the unfiltered sample contained elevated concentrations of nickel, lead, chromium, silver and zinc. It was noted that the nickel concentration in the unfiltered sample (3,670 ug/L) was similar to earlier NEE March 2003 data from this well (4,180 ug/L). OTO concludes that well MW-4 is not optimally constructed, with very little screen intercepting the water table, and may not produce groundwater samples representative of conditions in this portion of the Site. NEE checked the March 2003 laboratory report, which does indicate the sample was filtered prior to analysis, and concludes from the OTO data and follow-up sampling data below, that this may not have been the case. NEE recommends removing the March 2003 MW-4 data from further evaluation of the Site groundwater. October 2008 Groundwater samples were collected from the five NEE on-site groundwater monitoring wells by NEE personnel on October 27, 2008, following NEE’s standard operating procedures (see Appendix D). 1-Liter samples were collected from all five monitoring wells and analyzed by Spectrum Analytical for thirteen soluble priority pollutant metals (PP13). Groundwater Sampling Logs are included in Appendix E. No metals were detected above the laboratory reporting limits in the samples collected from wells MW-2S, MW-2D, or MW-3. Nickel was reported at a concentration of 9.5 ug/L in MW-1 and 84.2 ug/L in MW-4, both of which are below the GW-3 Standard of 200 ug/L. Laboratory results are summarized in Table 1, and are included in Appendix E. Groundwater Summary Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 5 Northampton, Massachusetts The groundwater laboratory results suggest that nickel contamination from the raceway fill does leach to the groundwater in detectable concentrations at seven of the 11 locations tested in the last two rounds of sampling, but at concentrations below the GW-3 standard. The concentration of lead in CR-6 (158 ug/L) slightly exceeds the GW-3 standard (100 ug/L). Arsenic, chromium, copper, and zinc were also detected in various monitoring wells at concentrations below the GW-3 standard. NEE recommends removing the March 2003 MW-4 data from further evaluation of the Site groundwater. 2.3 Bank Stabilization Monitoring NEE has conducted numerous Site Visits to monitor the progress of bank stabilization, fence installations, sign posting, and sediment trap implementation. The following are a selection of Site Visit summaries when notable progress was made: 7/29/2005: “Posted, No Trespassing” signs and orange construction fence placed at top of bank west of Cutlery parking lot to protect against Imminent Hazard near the CB-1 soil sample area. 11/11/2005: Silt fence installation appears intact. Orange construction fence is intact along the eastern side of the Site just below Riverside Drive. “Posted, No Trespassing” signs along Riverside Drive are intact. Landscape fabric is installed/pinned to the soil on steep portion of the levee above the Mill River. The entire levee has been seeded and covered in hay mulch. The stone retaining wall has not been rebuilt yet at the southern end of the levee. Plastic cover on the soil stockpile is intact and edges held in place, ready for winter. 6/9/2006: The sediment trap concrete wall within the former tail race is complete. Wash patterns on the Cutlery parking lot pavement indicate that stormwater runoff from the pavement does enter the sediment trap. Orange construction fence and signs along western side of Cutlery parking lot are still intact. 7/31/2006: New black plastic has been installed over the old clear plastic on the soil stockpile. It is adequately held in place. The new OTO monitoring wells are evident along the length of the raceway. The landscape fabric installed last fall has degraded and the seed sprout rate appears spotty. While this situation is better than the previously unprotected levee bank, it is not up to specification. Some areas of erosion are evident along the western slope of the levee above the Mill River. Most of the silt fence appears intact, with one area at the northern end of the levee where sediment appears to have overwhelmed the fabric and pinned it to the ground, and a second near the VHI parking lot where the wooden stakes were broken. The poor conditions of portions of the silt fence and landscape fabric were brought to Alan Verson’s attention, and he contacted the contractor to remedy same. 10/24/2006: The VHI concrete block retaining wall at the western edge of their parking lot is is complete. Seed on the re-graded soil stockpile is starting to take and no erosion is evident on the edges of the stockpile. Excavation along the bank west of the Cutlery parking lot is complete, but the area has not yet been physically stabilized. 5/31/2007: The orange marker layer of plastic construction fence is installed from the edge of the new pavement down to the base of the bank west of the Cutlery parking lot and pinned in place. It is not yet covered. Coconut wattle and blown compost sediment booms are installed along the base of the bank west of the parking lots. The sediment trap concrete wall was noted to have an erosion hole under it in Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 6 Northampton, Massachusetts the sediment, thus negating its intended purpose. This was brought to the contractor and owner’s attention for immediate repair. 6/1/2007: The sediment trap erosion hole was filled with stone and new fill dirt. Grass on the re-graded soil stockpile is healthy and no erosion is evident on the edges of the stockpile. 6/5/2007: Blown compost, which includes new grass seed, is being installed over the orange construction fence marker layer. 6/7/2007: Blown compost/seed fully installed over the orange construction fence marker layer. Layer of erosion control blanket being installed over the compost and pinned in place. Retaining wall not re-built yet, but went over the details with the contractor at the Site. 6/12/2007: Some areas of compost erosion evident, contractor working to repair these sections. 6/15/2007: Blown compost/seed repaired and heavier erosion control blanket installed in troubled areas. Seed sprouting in blown compost installed last week. Steep areas of bank near tailrace are too steep to hold compost, so orange fence is still visible. Compost and erosion control blanket installations along levee look good. Pea stone was installed inside the sediment trap as another blow-out occurred under the concrete wall. 7/31/2007: This site inspection found the new compost seed and erosion control blanket working nicely over 95% of the area where these were installed. Trouble areas are the steepest near the tailrace and near CB-1. Tailrace pea stone did not hold; eroded under the wall as the previous fill had done. Grass on the soil stockpile is still in good shape even after the contractor drove over it numerous times in the past several months; no erosion evident. Grass on levee and steep western side of levee has sprouted and appears off to a good start. 10/3/2007: Repaired tailrace sediment trap did not hold; eroded under the wall again. Steepest riverbank areas near tailrace have some erosion of compost and some grass growth where the compost held. The riverbank near CB-1 also has some compost erosion and the orange fence marker layer is exposed. When notified from the field, Alan Verson indicated he would take care of these items. The remaining portions of the bank appear in good condition with adequate growth to hold the bank in place. The levee grass growth is healthy and the steepest areas directly above the re-built stone retaining wall is still being held in place by initial grass growth and the erosion control blanket. Signs are still posted along the length of the Site on Riverside Drive and the parking lots. 12/12/2007: The new five-foot high chain link fence (CLH) along Riverside Drive and the four-foot high CLF along the western side of the Cutlery and VHI parking lots is installed, including two gates in the four-foot fence. This fencing connects to the original two sections of CLF at the north and south ends of AOC-2 and AOC-3 to make one continuous fence from the former dam at the north to the tailrace to the south. One small section of fence at the northern end between the original northerly fence up the slope to the new fence along Riverside Drive was not yet installed. The fence is located on the western side of public areas (Riverside Drive and the Cutlery and VHI parking lots). The remaining areas of the Site east of the fence are now paved or covered by the VHI building addition. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 7 Northampton, Massachusetts 1/2/2008: NEE noted that the fence along both the west side of Riverside Drive and the west side of the Cutlery and VHI parking lots was complete. Padlocks were needed on the two gates west of the parking lot and “No Trespassing” signs were needed on these gates and the rest of the four-foot fence. When notified from the field, Alan Verson indicated he would take care of these items. 10/27/2008: NEE performed annual padlock maintenance and added an NEE padlock in series with the VHI lock on their rear gate. The stabilized bank on the west side of the levee appeared in good condition. Several small areas of the bank near CB-1 eroded again, exposing the orange marker layer. When notified from the field, Alan Verson indicated he would have this area of compost repaired. The sediment trap erosion continued to be problematic and the base was filled with a layer of concrete flow-fill earlier this past spring. The base of the sediment trap appears intact and the structure appears to be operating as designed. 11/20/2008 NEE conducted a Site Visit to inspect replacement mulch west of the Cutlery parking lot. The orange marker layer which had been visible on the previous Site Visit had been covered, and all areas appeared to have adequate cover and/or stable vegetation. 6/9/2009: Tailrace sediment trap has standing water in it indicating that the flow-fill concrete base now has long-term functionality over an extended period of time. Vegetation on the bank looks great with several small exceptions: 1) two areas near CB-1 have eroded down to the orange marker layer and therefore need repair with compost and seed; 2) several small areas along the steep part of the levee appear too dry to support vegetation. Re-built stone retaining wall looks great. Vegetation along levee top and soil stockpile is healthy and vibrant; maple and locust tree saplings are growing along with the grasses, Japanese knot weed and shrubs. Fence along Riverside Drive is in excellent condition. Fence along west side of parking lots is in fine condition with two exceptions: 1) area near Cutlery gate was pushed hard by plowed snow. The fence top rail has come apart from the posts and needs to be fixed, and the gate hinge posts need to be re-aligned. Alan Verson was notified of these situations and indicated they would be repaired. 2) area of fence behind VHI was pushed hard by plowed snow. A gap has developed between the bottom of the fencing and the pavement, and the fence top rail has come apart from the posts. Nelson Shifflett was notified of these situations and indicated the top rail would be repaired and additional fence material added to the bottom to close the gap. “No Trespassing” signs are present along entire length of the fences, gate locks are in good condition, and the parking lot pavement in the proposed AUL Areas is in excellent condition. Photographs from this Site Visit are included in the photographs section of this report. 7/1/2009: The areas of thin compost cover in AOC-1 noted during the last Site Visit have been replenished and reseeded. 11/17/2009: Compost cover thickness and cover vegetation on the Mill River bank appear in good condition except in the area from the tailrace north approximately 100 feet where the orange marker layer was exposed in the steepest portions of the bank. The area closest to the tailrace also included erosion of underlying soil under one tree. This 100-feet of the bank needs physical stabilization and re-planting in the Spring. The chain link fencing all appears in good condition in AOC-1, AOC-2 and AOC-3. Gates were all locked. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 8 Northampton, Massachusetts Between June 28 and July 14, 2010, NEE field staff installed 160 linear feet of 12” diameter coir logs along the toe of the existing river bank. The location of the coir logs included the 100-feet of bank directly north of the tailrace, plus the next 30 feet which were also determined to be eroded and in need of stabilization, and an additional 30-foot section further north near CB-1. This last 30-foot section was in the best condition of the three, but still showed signs of erosion and was stabilized to ensure future slope stability. Once the coir logs were placed, NEE field staff installed CF 700 erosion control blanket under the coir logs, then secured both in place with duckbill earth anchors and alloy wire. The anchored erosion control blanket was left rolled at the base of the slope in order to secure the placed loam on the slope at the conclusion of the project. On June 29, 2010, NEE began placing loam, above the coir logs, on the slope at the downstream-most portion, where a scoured hole had formed during winter/spring storms. Shortly after loam placement began, NEE discovered that loam was gathering at the toe of slope and not accumulating on the exposed bank. NEE concluded at that time, that placed loam and erosion control blanket would not be a viable long term solution and that the slope needed more stability. On July 1, 2010, Lyons Witten, LSP with NEE, met at the Site with Sarah LaValley, Northampton Conservation Agent, to explain the difficulties encountered and to propose completing the project using a vegetated geo-lift system to finish the bank restoration and prevent future erosion. This proposal was accepted by Ms. LaValley as a valid and acceptable alternative for the difficult conditions. The vegetated geo-lift system was installed between July 5-14, 2010. During the July 1, 2010 site visit, the chain link fencing all appeared in good condition in AOC-1, AOC-2 and AOC-3. Gates were all locked. The prior bank stabilization engineering controls appeared in good condition and the planted vegetation appeared healthy. On July 28, 2010, Lyons Witten, LSP and Karro Frost, PWS, both with NEE, visited the Site to assess initial vegetative growth after completion of the bank stabilization work. The grass seed had germinated across most of the newly restored areas and the geo-lifts were tight and secure. Karro Frost re-inspected the Site on November 11, 2010 and found that growth had continued through the growing season and that the restoration appeared in good condition heading into winter. She completed a Slope Stabilization and Wetland Restoration Monitoring Report dated November 16, 2010 for the Northampton Conservation Commission based in part upon these Site visits. On September 2, 2010 NEE applied for a Certificate of Compliance with the Northampton Conservation Commission for the collective bank stabilization efforts in AOC-1 and AOC-3. Two Certificates of Compliance were approved by the Northampton Conservation Commission at their November 18, 2010 meeting, one for each of the two open Notices of Intent (DEP File #246-546 and 246-593) under which this work was completed. These Certificates of Compliance were recorded at the Registry of Deeds (Bk: 10401 Pg: 169 and Bk: 10401 Pg: 171 ) on December 8, 2010. Copies are included in Appendix B. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 9 Northampton, Massachusetts 3.0 REPRESENTATIVENESS EVALUATION & DATA USABILITY ASSESSMENT A Representativeness Evaluation & Data Usability Assessment (REDUA) is a systematic evaluation of the uncertainty associated with the analytical data points in terms of accuracy, precision, and completeness. Data determined to be scientifically valid, defensible, and of a sufficient level of accuracy, precision, and completeness to support this submittal are then considered to be suitable for use in a Representativeness Evaluation. The Representativeness Evaluation serves as a final determination of data reliability with respect to the accuracy, precision, representativeness (temporal and spatial), comparability, completeness, and sensitivity of the data collected to represent the attributes and analytical concentration of the total data set. The Representativeness Evaluation, pursuant to 310 CMR 40.1056(2)(k), must encompass, consider and compile the full range of data gathered over the course of the response action process. A Data Summary which includes the Sample ID #s, Parameters analyzed, EPA Methods used, date, media sampled, use of the data within this investigation, and a summary of laboratory statistics related to this Data Usability Assessment is included in Table 3. This provides a quick overview of the types, quality and use of the laboratory data for this project. 3.1 Data Usability Assessment 3.1.1 Analytical Data Usability Assessment The DEP’s Compendium of Analytical Methods (CAM) is a collection of laboratory methods designed and approved by DEP to produce data of known accuracy, precision and sensitivity. As such, the accuracy, precision and sensitivity of CAM Compliant data do not require additional evaluation in an Analytical Data Usability Assessment; they provide presumptive certainty to the regulated community from a laboratory data generation perspective. Other types of analytical data (CAM Non-compliant, Non-CAM, and Pre-CAM), however, require evaluation to identify what information is available to assess the accuracy, precision, and sensitivity of these data points, and the comparability of these data to CAM compliant data. All data for this project analyzed after August 1, 2003 were acquired using CAM compliant analyses (Table 3). As such, all confirmatory soil and groundwater data was analyzed using CAM compliant analyses. CAM compliant analyses are determined using an “MCP Analytical Method”. CAM compliant analyses comply with method-specific QC analytical requirements specified in CAM. CAM compliant analyses are determined with an evaluation of compliance with method-specific performance standards, with deficiencies narrated, and are reported in the format specified in the CAM for MCP analytical data. While samples collected during the early assessment phases of this investigation were not analyzed using CAM methods, follow-up confirmatory soil samples collected after the several rounds of selective excavation were analyzed using CAM methods, as were the post 2003 assessment soil and sediment samples. The Site coverage and representativeness of the CAM-compliant analyses is significant and the overall confidence in the earlier laboratory work is not altered by the later CAM analyses. It is true that the earliest soil samples were analyzed for a smaller number of heavy metals, and that this was increased in steps over the years. However, the number of primary metals of concern did not increase beyond the basic set (Pb, As, Cr, Ni), and follow-up confirmatory sampling continues to indicate these are the primary contaminants of concern at the Site. Other metals which were detected in either lower Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 10 Northampton, Massachusetts concentrations or in smaller areas of the Site can and will likely be treated in the same manner as these four. Closure of this Site from a soil and sediment perspective is based upon the CAM-compliant analyses. Initial groundwater samples in 2001 were analyzed using the methods available at that time (non-CAM compliant). More recent samples were analyzed using CAM methods and the results are similar. Closure of this Site from a groundwater perspective is based upon the CAM-compliant analyses. 3.1.2 Field Quality Control Data Usability Assessment The purpose of the field quality control program is to ensure that the data are of a quality suitable for their intended uses. Quality control in the field is primarily assured by following standard operating procedures for each type of sample collection activity and/or field screening. NEE’s standard standard operating procedures (Appendix D) are based on industry standard practices, DEP guidance documents/policies, and EPA protocols. NEE personnel follow these standard procedures. Proper sampling containers, preservation, hold times, and handling procedures were employed when sampling, as indicated in each case narrative and/or the chain of custody. The number and location of sampling points chosen in the field were designed to be representative of the media sampled and reflect both the “release”, and the remediated Site. Field duplicate soil samples were collected for metals analyses on a number of occasions, especially when large numbers of samples were collected on particular rounds (Table 3). The collection of field duplicate samples did not follow a strict regimen. 3.1.3 Data Quality Objectives The Data Quality Objectives (DQOs) for data collected during the course of this investigation are to provide data of adequate quality to: 1. Identify exceedances of applicable soil, sediment, surface water, water, and groundwater standards and/or screening criteria; 2. Define the horizontal and vertical extent of OHM released at the site; 3. Assess potential migration pathways, potential exposure points, and potential exposure point concentrations; 4. Assess risk to human health, safety, public welfare, and the environment; and, 5. Support closure of the Site from the DEP/MCP system. As such the data will be used to support the LSP Opinion of No Significant Risk. The MCP standards, action limits, and laboratory reporting limits were all chosen based upon Site-specific criteria. These objectives were met. 3.2 Representativeness Evaluation The Representativeness Evaluation includes analysis of the conceptual site model, data collection approach, field screening data, selection of sampling locations and depths, number and spatial distribution of sampling locations, temporal distribution of data points, critical samples, and completeness. A detailed discussion of the adequacy of these aspects is included in the following subsections. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 11 Northampton, Massachusetts 3.2.2 Data Collection Approach The initial data collection was based on the goal of delineating the extent of impacted raceway fill, identifying the number and types of contaminants of concern, and if groundwater had been impacted. As the extent of the fill was delineated, the number of metals tested was increased. The initial detection of metals at the Site included elevated concentrations of lead and chromium (GZA, 1989). Huntley’s 1996 investigation detected no RCRA 8 metals above reportable concentrations. Initial site assessment activities for the PRP included testing only for lead and arsenic. This was later expanded to testing for 5 metals, then to RCRA 8 metals, and later in 2001 to PP13 metals (Table 3). By the time excavation of UCL metals occurred, most of the Site had been evaluated for PP13 metals. This is illustrated in Figure 4 which shows the distribution of the four metals of primary concern at the Site. All confirmatory soil testing for metals was conducted with PP13 metals, the current standard for metals analyses under the MCP. 3.2.3 Field Screening Data Field screening data/techniques were used during site investigation activities to determine if soil impacts existed. In particular, visual observations were recorded and soil was screened with a photo-ionization detector (PID) during soil excavation activities. The PID was not a useful tool at this Site as the primary contaminants of concern are non-volatile heavy metals. Visual observations of soil color and texture were quite useful since most of the metals-impacted soil displayed various shades of red, green, or white in a fine uniform texture, which were different from the natural soils. 3.2.4 Selection of Sampling Locations and Depths Selection of sampling locations was influenced by the nature of the release. Onsite sampling locations were selected in an effort to identify and characterize the horizontal and vertical extent of impacts. Groundwater monitoring well locations were selected to identify potential migration of constituents to the adjacent ecological receptor, the Mill River. Thus, sampling locations were selected to include both upgradient (background) and downgradient (potentially contaminated) monitoring well locations. A monitoring well pair was installed (MW-2S/MW-2D) to evaluate the vertical extent of migration. The two sets of upgradient/downgradient monitoring wells were later augmented by the OTO Brownfields Investigation monitoring wells and well points, providing adequate spatial distribution of groundwater samples. The one monitoring well installed and sampled by OTO which has elevated concentrations of lead (CR-6), is located near MW-4. This indicates an isolated area of groundwater contamination near an area of known elevated concentrations of the same metals in raceway fill materials. The remaining six OTO monitoring wells provide the previously lacking adequate site coverage for groundwater assessment. Soil sampling at the Site focused on sampling from test pits primarily cut across the raceway to provide both depth profiles of the fill material and representative fill and below-fill soil samples. Sediment and surface water sample locations were chosen to be upstream, sidestream and downstream of the filled portion of the raceway. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 12 Northampton, Massachusetts 3.2.5 Number and Spatial Distribution of Sampling Locations The number and spatial distribution of sampling locations selected during various phases of site investigations and remediation activities are appropriate for the size of the site and for characterization of the impacts associated with the release. As noted in Section 3.2.4 above, the spatial distribution of soil, sediment, surface water and groundwater samples was designed to be both representative of the impacted materials and to sample adjacent non-impacted media in order to quantify the extent of the release. The number of samples collected during this investigation is extensive, spans all possible impacted media, and is adequate to meet the DQOs. 3.2.6 Temporal Distribution of Samples Groundwater samples were collected from the five original monitoring wells two times during 2001. Well MW-4 was re-sampled in March 2003 and March 2003. OTO included MW-4 in the groundwater sampling event with their five monitoring wells and two well points in June 2006. The five original wells were again sampled in October 2008. With the marked exception of the March 2003 sample from MW-4, temporal variations are a minor factor in groundwater at the Site. As discussed in Section 2.2 above, NEE recommends removing the March 2003 MW-4 data from further evaluation of the Site groundwater. With this removal, the temporal trend at MW-4 is downward for dissolved nickel (Chart 1). 3.2.7 Critical Samples The confirmatory soil samples collected in November and December 2004 after excavation of the worst soil under the parking lots are considered critical samples. These soil samples were collected to demonstrate the concentration of metals remaining in AOC-1 after these spot excavations. These soil concentrations and the concentrations of metals stabilized and re-located to the soil stockpile in AOC-2 are listed in the Phase IV-Revised RIP (NEE, September 2005: Table 1-SA-1 through Table 1-SA-5). These samples demonstrate that the highest concentrations of metals, including all the UCL soil, under the parking lots were re-located prior to paving the parking lots. The sediment and surface water samples collected over the course of this project are critical in that they demonstrate no significant impact to the Mill River from the raceway fill materials and metals dumped on the levee. The groundwater samples collected in October 2008 are critical samples in that they demonstrate that the concentration of dissolved nickel in MW-4 is going down over time. The last two rounds of groundwater analyzed from MW-4, and all samples from the other monitoring wells and well points, except CR-6 where lead was detected above the GW-3 standard, all show metals concentrations below the GW-3 standard. This indicates that the impact to the Mill River is likely to remain insignificant, especially since the banks of the Mill River and the levee have been physically stabilized and planted. 3.2.8 Data Collection Evaluation Quality control in the field is primarily assured by following standard operating procedures for each type of sample collection activity and/or field screening. NEE’s standard operating procedures (Appendix D) are based on industry standard practices, DEP guidance documents/policies, and EPA protocols. NEE personnel follow these standard procedures. The number and location of sampling points chosen in the field were designed to be representative of the media sampled and reflect both the “release”, and the remediated Site. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 13 Northampton, Massachusetts 3.2.9 Data Validation There are no known deviations in the data collection or analytical methods for this project. Some flags were marked within the laboratory report indicating variations in reporting limits or problems during analysis. Each of these were evaluated at the time of report receipt and determined not to impact the usability of the data. The NEE March 2003 groundwater data from MW-4 was questioned by OTO during their June 2006 Brownfields Investigation. OTO noted that there was only a small amount of groundwater in the screened section of the well, and that the water collected had a high visual entrained sediment content. Two samples were submitted to the lab for analysis from this well, a filtered sample and an unfiltered sample. Metals analytical results for the filtered sample from MW-4 indicate no metals above GW-3 standards, while the unfiltered sample contained elevated concentrations of nickel, lead, chromium, silver and zinc. It was noted that the nickel concentration in the unfiltered sample (3,670 ug/L) was similar to earlier NEE March 2003 data from this well (4,180 ug/L). NEE checked the March 2003 laboratory report, which does indicate the sample was filtered prior to analysis, and concludes from the OTO data and follow-up sampling data discussed above (Section 2.2), that this may not have been the case. NEE recommends removing the March 2003 MW-4 data from further evaluation of the Site groundwater. Based on the validation summarized above, these data are considered valid and acceptable for Site closure, with the exception of the March 2003 groundwater data from MW-4. 3.2.10 Completeness All the Site data were subject to data validation. There are no significant data gaps. One goal of the OTO Brownfields Investigation (2006) was to fill in perceived data gaps in groundwater, sediment and surface water data at that time. time. This was accomplished and the overall data set is improved by this effort. Recent groundwater data indicate a downward trend in overall metals concentrations. All confirmatory soil sampling was accomplished using CAM methods. 3.3 Summary of REDUA The data for this project were collected using standard operating procedures and analyzed using CAMcompliant analyses. The number and location of samples are representative of the Site and sufficient to characterize both the “release” and the soil, sediment, surface water, and groundwater remaining at the Site. Qualifications have been made to some results based on analytical quality control performance standard deficiencies described in Laboratory Case Narratives. In our opinion, the data generated meet the requirements of a Representativeness Evaluation. Based on the Analytical Data Usability Assessment and Representativeness Evaluation, all data collected for the Site, except the march 2003 groundwater data for MW-4, are deemed acceptable for their intended purposes, and collectively to support both the Class A-3 RAO-P for AOC-1 and the Class C-1 RAO-P for AOC-2 and AOC-3. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 14 Northampton, Massachusetts 4.0 EXTENT OF CONTAMINATION Previous investigations have identified contamination at various locations on the Site due to inappropriate disposal activities, including metals (primarily arsenic, chromium III, lead, and nickel), and to a lesser degree extractable petroleum hydrocarbons (EPH), PAHs, and PCBs at one location in AOC-3. Nonaqueous phase liquid (NAPL) has not been identified on the Site. Locations of contamination can be separated into two broad categories or areas for soil. The raceway with waste fill and debris, and the levee with high metal concentrations in near-surface soil are the two broad categories. The raceway fill can now be divided further into that portion within AOC-1 and the remainder in AOC-2. The heavy metals listed above are also detected in Site groundwater, but only exceed GW-3 groundwater standards in one monitoring well (Tables 1 & 2-1). 4.1 AOC-1 Parking Lots and River Bank In the Fall 2004 and again in the Fall 2006, NEE excavated the soil with the highest concentrations of detected metals within AOC-1. These were primarily soils with concentrations in excess of the UCL concentration of one or more metals. The soil excavated from test pits in AOC-1 was stabilized and/or consolidated to the soil stockpile in AOC-2. Confirmatory soil analyses from these excavations indicated that all soil in excess of UCL concentrations within AOC-1 had been removed. Figure 4 illustrates the confirmatory soil sample locations and Tables 4-1 through 4-6 list the sample results for excavated and final confirmatory soil samples. While the data in these tables is primarily from 2003, 2004 and 2005, the standards listed have been updated to include the 2006 MCP “Wave 2 Changes” and the sample locations excavated to AOC-2 have been updated. In some cases, several rounds of excavation and samples were necessary to remove all the UCL soil. soil. These tables were included in previous submittals, but were updated to include current MCP soil standards and are presented here as a representation of soil remaining within AOC-1. Since these results indicate metals concentrations in excess of Method 1 standards, an AUL and Method 3 risk characterization (Section 5.0) will be required to close this portion of the Site (AOC-1) with a Class A3 RAO-P (Section 6.0). 4.2 Raceway Fill Elevated concentrations of metals have been identified in surface and near-surface soils along the raceway (Figure 4). Elevated EPH and PCB concentrations have also been identified in the fill, but in isolated areas (see Section 5.1). In the area of the raceway, the buried debris is concentrated in a strip, approximately 30-40 feet wide, which runs in a north/south direction parallel to the bank, as depicted on Figure 3. The vertical extent of buried debris generally decreases moving towards the east/west limits of the strip, and is greatest near the center of the raceway extending to approximately 5 to 8 feet below ground surface. The horizontal extent of the fill material in the northern portion of the Site has been defined as north of GZA TP-7 and south of SP-2 within the boundaries of the former raceway. The horizontal extent of the fill material in the southern portion of the Site confines to the channel of the former raceway and extends as far as the Cutlery building (Figure 3). West of the Cutlery and VHI buildings, elevated concentrations of metals have been detected in the fill materials under the parking lots and comprising the sloped bank leading down to the Mill River. North of the VHI property, near AOC-2, the river bank does contain elevated metals concentrations, but these do not exceed UCL concentrations (Table 2-2) until the levee becomes topographically prominent (see Section 4.2 below) and AOC-3 begins. The horizontal extent of the fill material in the southern portion of the Site includes the former raceway, extends from the western edge of the raceway and raceway overflow to and beyond the edge of Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 15 Northampton, Massachusetts the bank down to the toe of the slope near the edge of the Mill River. The contaminated fill material located below the driveways of the former Firehouse and Cutlery building parking lots, is now covered with asphalt paving to reduce infiltration, reduce erosion, and separate these materials from the general public. Laboratory results indicate a dramatic decrease in concentration of contaminants in samples collected in the sand and sediment below the fill material as compared to samples collected within the fill material. The dateable fill materials (soda and beer cans) closer to the Cutlery Building are older, and decrease with age as one travels north, away from the building. This defines the order of fill placement within the raceway. PCBs were only detected in one sample collected within the fill material. This portion of the fill appeared appeared visually quite different than the material around it. It was dark black and oily in appearance while the surrounding material was brown, sandy, and primarily composed of demolition debris. The dark material containing PCBs appeared to be less than one cubic yard in volume and is located at the north end of AOC-2. 4.2 Exposed Levee Elevated concentrations of metals have been identified in surface and near-surface soils along the levee. During April and May 2005, NEE attempted to excavate the metals impacted soil along the levee and consolidate this soil within the stockpile in AOC-2. This objective was not achieved. The total volume and extent of metals impacted soil was under-estimated. The Interim Construction Report (NEE 2005) details these efforts and reported that 38 of the 40 confirmatory soil samples collected after this excavation indicate concentrations of metals above Method 1 standards, 28 above UCL concentrations. The Interim Construction Report (NEE 2005) Figure 5 and Table 2 illustrating these results are included herein as Figure 5 and Table 5 and represent the concentrations of metals still present along the levee in AOC-3 (under the physical stabilization) and within portions of the stockpile in AOC-2. These impacted soils are readily identified in the field by their bright colors (red/pink and green), and test pit observations confirm that the impact from these soils does not typically extend to the natural-colored soil (tan and brown) below them. The depth of impacted soil along the exposed levee was originally thought to be between one and two feet below grade, with selected areas demonstrating impact within the first foot (green soil), and other areas extending slightly deeper to a total depth of three to four feet below grade. The 2005 confirmatory soil sampling results demonstrate that the impacts extend deeper along the levee than originally believed. Additional investigation would be necessary to quantify the depth and volume of impacted soils remaining along the levee. After the 2005 excavation effort along the levee, the project focus shifted from attempting remediation to physical stabilization toward the new goal of Class C RAO. This latter goal was achieved. There have been no significant detections of elevated concentrations of metals within the un-filled portion of the raceway adjacent to the exposed levee. Sediment samples from the interior wetland in this area did contain concentrations of arsenic, cadmium, chromium, mercury and lead above the TEC Benchmarks, but below Method 1 soil standards. Detection of metals of concern for the Site within river sediment are similar in concentration in both upgradient and downgradient samples (Interim Construction Report (NEE 2005) Table 3), indicating that while the Site may have contributed metals to the river sediment, the Site is not a major contributor, or the sole contributor. Similar concentrations of these metals along with Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 16 Northampton, Massachusetts nickel, copper, and zinc were found in river bank samples listed in this same table. OTO river bank soil samples results (Table 2-4) indicate concentrations of antimony, chromium, lead and nickel above the UCL concentrations of these metals. These results and observations indicate the area of impact along the exposed levee includes the surface and near-surface soil along the top and sides of the levee as well as the riverbank soils adjacent to AOC-3. Recent physical stabilization of the top and sides of the levee has dramatically reduced erosion and therefore potential negative impacts from these metals. 4.3 Conceptual Site Model The Site is a former water-powered industrial mill which manufactured cutlery table ware. This process involved metal plating, and wastes from the plating were deposited both along the levee and in the former raceway once it was no longer in use. Other waste materials were also deposited in the raceway, but the heavy metals arsenic, antimony, lead, chromium, and nickel are the primary contaminants of concern at the Site, and these have origins with the metal plating process involved in the manufacture of cutlery. Some of these metals were buried deep in the raceway and others were dumped on or near the ground surface of the raceway, the levee, and likely also the bank down to the Mill River. Since the Northampton Cutlery was in operation from about 1865 through the early 1980s, it is likely that some metals eroded into or were simply dumped in the Mill River at one time or another. Erosion of surface soil was evident on the banks of the Mill River and the levee during the early parts of this investigation and this investigation has shown that levee and bank soils contain elevated concentrations of these same metals. Sampling of the Mill River surface water and sediments indicates that concentrations of the metals present present at the Site are not present at significant concentrations within the river at this time. Upstream and downstream sediment samples yield similar concentrations of metals, indicating that the Northampton Cutlery was not the only source of heavy metals to the Mill River sediments. It would not be possible at this late juncture in time to effectively quantify what portions of the metals detected in the river are attributable to this Site. It was possible to change the surface characteristics of the Site in such a way as to eliminate most of the erosion to the Mill River. A systematic and thorough evaluation of the river bank was completed and the following activities were completed toward this goal of limiting erosion: The parking lots were paved, UCL concentrations of metals were excavated from the river bank in AOC-1 and both stabilized and relocated at the Site to the soil stockpile in AOC-2, a portion of the stone retaining wall in AOC-3 was rebuilt at the foot of the levee, the steep and eroding portions of the levee and river bank in AOC-1 and AOC-3 were physically stabilized with a combination of orange plastic fencing, compost, and erosion control blankets, and the soil stockpile was re-graded to have a lower profile, covered in landscape fabric, loam and seed. With these improvements to the ground surface at the Site, virtually all of the erosion has been stopped, thus protecting the Mill River and the public. The metals are still present at the Site, both in and on top of the former raceway, and that is why portions of the Site will have an Activity and Use Limitation (AUL) and others will have a Class C RAO. With these improvements and the addition of an AUL for AOC-1, the level of concern for the Site has been reduced from Significant Risk to No Substantial Hazard (NSH) for AOC-2 and AOC-3, and from Significant Risk to No Significant Risk (NSR) for AOC-1. The current Conceptual Site Model includes a former water-power raceway which was filled with industrial wastes, including several heavy metals. The highest concentrations of these metals within AOC-1 have been moved to the soil stockpile in AOC-2. The banks of the river and the levee have been Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 17 Northampton, Massachusetts physically covered and planted to stabilize former erosion. The soil stockpile has been physically stabilized and planted to prevent any possible erosion. The parking lots have been paved and a fence installed around unpaved portions of AOC-1 and all of AOC-2 and ACO-3 to restrict access to these portions of the Site. Limited amounts of metals are leaching to groundwater under the raceway, but these concentrations do not appear to be impacting the Mill River surface water or sediments in a significant way. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 18 Northampton, Massachusetts 5.0 RISK CHARACTERIZATION 5.1 Contaminants of Concern (COCs) 5.1.1 Metals The following priority pollutant (PP13) metals have been identified as COCs at the Site: antimony, arsenic, cadmium, chromium (III), nickel, lead and thallium. The distribution of metals within AOC-1 at the Site is illustrated in Figure 4 and Tables 4-1 through 4-6. Within the levee in AOC-3 the current distribution of metals is illustrated in Figure 5 /Table 5 and Figure 3 /Tables 2-2, 2-3, and 2-4. In the remaining portions of AOC-2 and AOC-3, the distribution of metals detected at depth in test pit soil samples is represented in the Phase II/III Report (NEE, 10/2003). The maximum and minimum concentrations of each COC is listed in Table 6-1 for AOC-1, and Table 6-2 for AOC-2 and AOC-3. Repeated speciation analyses of chromium indicates that high detections of chromium chromium in various locations and times across the Site all contain trivalent chromium, not hexavalent chromium. The remaining chromium results are all interpreted to be chromium III. One or more of these metals have been detected at elevated concentrations in soil, raceway fill, on the levee, and the bank down to the Mill River. Concentration of metals in excess of the TEC Benchmarks but not in excess of the Method 1 standards have been detected in sediment samples from the interior wetland and from the Mill River. Elevated nickel and lead concentrations have been detected in groundwater samples collected at the Site. Chromium, copper and zinc have also been detected in groundwater samples, but below GW-3 standards. 5.1.2 PCBs Concentrations exceeded the method detection limit for two out of three samples analyzed for total PCBs as part of the Phase II/III Report (NEE, 10/2003). In one of the two samples, SP-15 2-3’, was reported to have a concentration of 250.2 mg/Kg, which exceeds the Method 1 standard. Mr. Lyons Witten notified Mr. Tony Kurpaska of the DEP on July 19, 2002. DEP verified this condition was not an imminent hazard because the PCBs were not within foot of the ground surface and DEP advised against separate notification. Mr. Witten notified Mr. Randy Rice of the EPA on the same day and EPA concluded the PCBs were less than a pound and were as a result of inappropriate disposal activities over thirty years ago and therefore did not fall under jurisdiction of TSCA or require notification to the EPA. More recent sampling as part of the Brownfields Investigation (OTO 2006) included sample analyses for PCBs in select Mill River sediment samples. No PCBs were detected in these samples. PCBs are therefore a COC for raceway fill material at the Site. 5.1.3 Coal/Coal Ash Four samples (SP-1 1-2’, SP-9B 2’, SP-16 0-1’ (Sed), and Sed-7) were submitted for coal/coal fly ash identification as part of the Phase II/III Report (NEE, 10/2003). The EDX data, texture and morphology of the particles as seen by the PLM and SEM were consistent for the presence of a heavy loading of anthracite coal and moderate amount of coal ash in sample SP-1 1-2’. A heavy concentration of coal ash and a moderate loading of both anthracite and bituminous coal were identified in sample SP-9B 2’. Sample SP-16 0-1’ contained a moderate loading of anthracite coal. Only light to trace amounts of anthracite coal and coal ash were detected in sample Sed-7. The metals content of samples SP-9B 2’ and Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 19 Northampton, Massachusetts SP-16 0-1’ was above the method detection limit for Beryllium, Chromium, Copper, Lead, Nickel, and Zinc, but below the applicable Method 1 Standards. While it is likely that coal and coal ash are responsible for some of the metals detected at the Site, particularly in areas where the ash is thick enough to identify, it is also clear that another source exists at the Site for metals. 5.1.4 Petroleum and VOCs Analyses for VOCs have been conducted on select soil and groundwater samples at the Site. No elevated PID readings have been detected during field investigations at this Site. No VOCs have been detected during the laboratory analyses, and VOCs are therefore not a COC at this Site. Soil samples have been analyzed for extractable and volatile petroleum hydrocarbons (EPH/VPH). No VPH carbon fraction or target analytes were detected. EPH compounds were detected in select samples at concentrations which are below method 1 standards except in a few isolated samples. Given the widespread distribution of coal and coal ash at this Site along the entire length of the levee, river bank, and within the raceway fill, it is our opinion that the relatively low concentrations of EPH are derived from the coal and/or coal ash and are therefore exempt. Sediment, surface water and groundwater samples have been analyzed for EPH. No EPH carbon fraction or target analytes were detected except that select EPH target PAH analytes were detected in one sediment sample at concentrations in excess of the TEC Benchmark values and below method 1 standards. This sample (OSS-22) was collected from a location near the center of the Mill River and may, or may not, have origins at the Site. Petroleum (EPH/VPH) and VOCs are therefore not considered COCs at this Site. 5.2 Environmentally Sensitive Receptors The Flood Insurance Rate Map (FIRM) of Northampton, Massachusetts, (Community Panel Number 250167 0002 A, April 3, 1978) indicates that the upland areas of the Site are located in Zone C, an area of minimal flooding, while the lower portions along and including the Mill River are located in Zone A7, an area within the 100-year flood zone. The MassGIS’s DEP Priority Resource Map data layers of the Easthampton, MA Quadrangles indicate the Site is not located within a medium yield potential productive aquifer, a Non-Potential Drinking Water Source area, a DEP-Approved Zone II area, a public water supply, Interim Wellhead Protection Area or Zone A of a Class A Surface Water Body (Figure 6). No mapped “areas of critical environmental concern,” are located on the Site. Areas of protected open space are located within 500 feet of the Subject Site. No schools, hospitals or nursing homes are located within 500 feet of the Site. A former school building is located approximately 400 feet southeast of the Site along Riverside Drive. This building is currently used for administrative and storage purposes only. No classes are taught at this facility. The Mill River flows immediately adjacent to, and west of, the Site from north to south. The river is approximately 30 ft wide and approximately 2 to 3 ft deep in the center during the winter. This river is assumed to be the receptor of Site groundwater. The DEP’s BWSC Priority Resource Map of the Easthampton Quadrangle (Figure 6) indicates there are estimated habitats of rare or endangered species along this portion of the Mill River. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 20 Northampton, Massachusetts There are no known water supplies within a one-half mile radius of the Site. Two public water supply wells are located adjacent to upstream tributaries of the Mill River at a distance between one-half mile and one mile (Figure 6). Both of these wells are upgradient of the Site. 5.3 Identification of Soil and Groundwater Categories 5.3.1 Reportable Concentrations for Soil and Groundwater Appropriate soil and groundwater Reportable Concentration categories for the Site were discussed in the Phase I Report (C&C, Feb. 2001). To determine if a reporting obligation exists under the MCP [310 CMR 40.0315], two soil categories (RCS-1 and RCS-2) have been established. Measured concentrations of any oil or hazardous material are compared to the soil category that best characterizes the current use of the Site. Reporting category RCS-1 is applied to all soil samples obtained at or within 500 feet of a residential dwelling, a residentially-zoned property, school, playground, recreational park, or park, or within the geographic boundaries of a groundwater resource area categorized as RCGW-1. Reporting category RCS-2 is applied to all soil samples that are not obtained from category RCS-1 areas. The Site is bordered by residential properties, therefore the applicable soil Reportable Concentration category was RCS-1. The DEP was notified of a release of petroleum, lead, and chromium to Site soil on February 16, 2000. To determine whether a notification obligation exists under the MCP [310 CMR 40.0315] for dissolved concentrations of oil or hazardous materials in groundwater, two groundwater categories have been established (RCGW-1 and RCGW-2). Reporting Category RCGW-1 shall be applied to all groundwater samples obtained:  Within the Zone II for a public water supply;  Within the Interim Wellhead Protection Area for a public water supply;  Within all Potentially Productive Aquifers;  Within the Zone A of a Class A surface water body used as a public water supply;  At any point located 500 or more feet from a public water supply distribution pipeline, except for sampling points that are located on a parcel of land or at a facility where any portion of that parcel of land or facility is located within 500 feet of a public water supply distribution pipeline; or  At any groundwater sampling point located within 500 feet of a private water supply well. Reporting Category RCGW-2 is applied to all groundwater samples that are not obtained from a RCGW-1 area. Since the Site does not meet any of the RCGW-1 criteria listed above, the applicable groundwater reporting category was RCGW-2. 5.3.2 Method 1 Soil and Groundwater Cleanup Categories The MCP has established three soil categories (S-1, S-2, and S-3) for evaluating risk to human health, public safety, public welfare, and the environment. Site-specific soil cleanup categories are determined by accessibility to site site soils, and the frequency and intensity of use by adults and children. Most of the accessible portions of the Site are paved or covered by building. The remaining portions have been fenced to restrict access. Soil in the paved areas (0-15’) would be considered potentially accessible. Since children live adjacent to the Site and access to the paved areas is not restricted, this would be considered Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 21 Northampton, Massachusetts high frequency and low intensity use, and the soil classified as Category S-2. Soils below 15 ft. and beneath the footprint of the building would be considered Category S-3 as isolated subsurface soils. Soils behind the locked and gated CLF north and west of the paved parking lots would be considered a Category S-3 soil for adult visitors having a low frequency and low intensity of use. Workers in this area who climb the river banks or dig in soil would have a low frequency and high intensity of use and this would bring the soil to a Category S-2. Groundwater may be characterized as GW-1, GW-2, and/or GW-3. Category GW-1 is defined as groundwater within a Current or Potential Drinking Water Source Area. As discussed above, the Site is not located within a GW-1 area. GW-2 includes groundwater located within 30 ft. of an existing occupied building or structure where the average annual depth to groundwater is 15 ft. or less. Depths to groundwater measured in existing wells on the Site property are less than 15 ft. All groundwater is considered GW-3 by the default assumption of discharge to surface water. 5.3.3 Applicability of Method 1 Risk Assessment The concentrations of multiple metals remaining in soil at the Site exceed Method 1 Standards. This is true in AOC-1, AOC-2, and AOC-3. In order to close AOC-1 at the Site with a Class A-3 RAO-P, an AUL will be required, as will a Site-specific Method 3 risk characterization (see Section 5.4 below). For this reason, a Method 1 risk characterization is not applicable to this Site. 5.4 Method 3 Risk Characterization A Method 3 characterization of the risk of harm to health, safety, public welfare and the environment, with respect to the oil and hazardous materials remaining in soil, sediment, surface water, and groundwater at the Site, has been completed by OTO. The full risk characterization is included included in Appendix F. The risk characterization conclusions are divided into two sections for the two different portions of the Site. These are discussed separately in Section 6.1 (for AOC-1) and Section 7.1 (for AOC-2 and AOC-3) below. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 22 Northampton, Massachusetts 6.0 CLASS A3 RESPONSE ACTION OUTCOME: AOC-1 A Class A-3 Response Action Outcome-Partial, as described in 310 CMR 40.1036(3), has been achieved at the Site, which is described as a portion of the property addressed as 320-360 Riverside Drive in Northampton, Massachusetts. AOC-1 includes the northwestern portion of the southerly Cutlery Lot 32 and the western portion of the Valley Home Improvement (VHI) Lot 76 as shown on Figures 3, 5, and 7. A permanent solution has been achieved, the level of OHM in the environment has not been reduced to background in soil, sediment, surface water, or groundwater, and an Activity and Use Limitation has been implemented, as described below. The boundaries of the AUL and the Disposal Site are illustrated on Figure 7 and Figure 9. 6.1 Risk Assessment Conclusions for AOC-1 AOC-1: This portion of the Site includes includes the northwestern portion of the southerly Cutlery Lot 32 and the western portion of the Valley Home Improvement (VHI) Lot 76 as shown on Figures 2, 3, and 5. In all areas of AOC-1 where heavy metals were identified in excess of their respective UCLs in 2005, this material was moved to the existing soil stockpile within AOC-2. This includes several areas under the Cutlery and Valley Home Improvement parking lots, and an area on the bank of the Mill River on the Cutlery property. Confirmatory soil samples indicated that the UCL contaminated soil had been removed from AOC-1. Changes to several UCL concentrations were incorporated in the 2006 MCP Wave 2 changes. As a result, the soil sample CB-12 is now identified as containing lead (4,480 mg/kg) and antimony (471 mg/kg) at concentrations in excess of their respective UCL concentrations (3,000 mg/kg and 400 mg/kg). These concentrations are part of the calculated Exposure Point Concentrations (EPCs) calculated in the Method 3 risk characterization. The resulting EPCs indicate an average concentration well below the UCLs for these metals, therefore this material does not need to be removed in order to close this portion of the Site. Residual contamination in this and other areas of AOC-1 is still present in soil. The areas of the parking lot where residual contamination remains have been paved and this pavement will be maintained in good condition. The remaining metals-impacted soil along the bank leading down to the Mill River (including CB-12) was physically stabilized in place to prevent any further erosion and these erosion controls will be maintained in good condition. The unpaved areas within AOC-1 have been fenced off with a chain link fence and this fence will be maintained in good condition. The Method 3 risk characterization for this Site was completed by OTO, is discussed in Section 5.4 above, and is included in full in Appendix F. Conclusion of the Method 3 risk characterization pertaining to AOC-1 are as follows: This portion of the Disposal Site currently poses No Significant Risk to human health, safety, public welfare, and the environment under current conditions and uses. The Risk Characterization concludes that the residual concentrations in soil and groundwater pose No Significant Risk to workers, utility workers, or other visitors to the Site. However, since a level of No Significant Risk is not supported for future unrestricted activities and uses of the impacted portion of the Site which may result in exposure to soils via dermal contact and incidental ingestion, an AUL is warranted. These exposures are not present currently because the metals impacted soil is isolated beneath pavement or has been isolated under an orange plastic fencing marker layer and stabilization layer of compost mulch, seed, erosion control fabric, and isolated behind a chain link fence. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 23 Northampton, Massachusetts Therefore to ensure that a condition of No Significant Risk is maintained at the Site for future foreseeable site activities and uses, an AUL is necessary to eliminate exposure pathways and exposure to the metals and petroleum impacted soil. Activities which may result in the disturbance of soil in the AUL area must be restricted to prevent exposures which may pose a significant risk to sensitive receptors. The Risk Characterization conducted relative to DEP RTN #1-13320 at the portion of property referenced as AOC-1 at 320-340 Riverside Drive in Northampton, Massachusetts has determined that with the implementation of an Activity and Use Limitation (AUL), a condition of “No Significant Risk” to health, safety, public welfare and the environment exists at this portion of the Site. This portion of the Site is therefore eligible for a Class A-3 RAO-P. 6.2 Activity & Use Limitation: AOC-1 An AUL is required at all disposal sites for which a RAO, and the risk characterization pursuant to 310 CMR 40.0900 used to support the RAO, are based upon the restriction or limitation of Site Activities and Uses to achieve or maintain a level of No Significant Risk including any Site where a Method 3 Risk Characterization performed relies on reduced exposure potential due to the assumption of limited site use. An Activity & Use Limitation (AUL) will be placed on the portion of the Site identified as AOC-1 as shown on Figure 7 as part of this submittal. Since AOC-1 incorporates portions of two different tax parcels under different ownership, two AULs will be recorded for AOC-1, one on each of the two deeds. These AULs are identical in their restrictive and permissive content. Note that neither the Cutlery building nor the Firehouse building and its addition are included in these AUL areas. The Cutlery and Firehouse buildings were never part of the Disposal Site, and the Firehouse building addition foundation excavation included the removal of all metals-impacted soil so that this new addition could be excluded from the then-proposed AUL area. 6.2.1 Permitted Activities and Uses Set Forth in the AUL Opinion The AUL Opinion provides that a condition of no significant risk to health, safety, public welfare, or the environment (such condition being defined in 310 CMR 40.0000) exists for any foreseeable period of time so long as any of the following activities and uses occur on the Property restricted by the AUL: i. Permitted Site uses include multi-family residential, commercial, and mixedresidential/commercial activities including, but not limited to, condominiums, offices, retail business, garages, vehicular and pedestrian traffic, landscaping, and routine maintenance of landscaped areas which do not cause and/or result in the relocation of soil located between 0-15 feet below grade within the paved AUL area at the Site as shown on Exhibit B. Relocation of soil is permitted within the paved AUL area provided the activities conform to the conditions outlined in Section 8 of this LSP Opinion (Obligations and Conditions); ii. Short-term (6 months or fewer) construction, development, emergency utility repair and/or other subsurface activities within the AUL area. iii. Activities and Uses which are not identified in this Opinion as being inconsistent with maintaining a condition of no significant risk; iv. Such other activities or uses which, in the Opinion of an LSP, shall present no greater risk of harm to health, safety, public welfare, or the environment that the activities and uses set forth in this Paragraph; and, Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 24 Northampton, Massachusetts v. Such other activities and uses not identified in Section 7 of this LSP Opinion as being Activities and Uses Inconsistent with the AUL. 6.2.2 Activities and Uses Inconsistent with the AUL Opinion Activities and uses which are inconsistent with the AUL Opinion, and which, if implemented at the portion of the Property restricted by the AUL, may result in a significant risk of harm to health, safety, public welfare, or the environment at the Site are as follows: i. Use of the AUL area for single-family residence, school, daycare, nursery, playground, recreational area, and/or other such activities or uses where a child is likely to be present and engage in high-intensity activities (e.g., digging, playing, gardening) that have the potential to result in disturbance of or direct contact with OHM-impacted Site soils; ii. Use of any portion of the the AUL area soil for the growth or production of homegrown produce for human consumption; iii. Use of any portion of the un-paved and fenced portion of the AUL area for any reason other than maintenance of the erosion controls on the bank of the Mill River, or monitoring, assessment or remediation of the Site. iv. Soil within the AUL area may not be moved to another area of the Property, or off the Site, without first being evaluated by an LSP who shall render an opinion, in accordance with 310 CMR 40.1080 et seq., as to whether the soil relocation will present a significant risk of harm to health, safety, public welfare, or the environment. 6.2.3 Obligations and Conditions Set Forth in the AUL Opinion The AUL Opinion provides that a condition of no significant risk to health, safety, public welfare, or the environment (such condition being defined in 310 CMR 40.0000) exists for any foreseeable period of time so long as any of the following obligations and conditions are maintained on the Property restricted by the AUL: i. The four-foot high chain link fence on the west side of the paved parking lots and the fivefoot high chain link fence on the north side of Lot 76 shall be maintained in good condition; ii. Gates in the chain link fences shall remain locked at all times. The property owner(s) shall restrict access to the locked areas to authorized personnel who are familiar with the terms of this document. iii. Signs stating the fenced areas within the chain link fences are off limits (“No Trespassing”) shall be posted in visible locations along each section of fence, and shall be maintained in good condition; iv. The parking lot pavement shall be maintained in good condition. The purpose of the pavement is to restrict access to the underlying soil which contains heavy metals. Therefore, minor cracks in the pavement are acceptable, but cracks penetrating the full pavement thickness or potholes must be repaired promptly; v. Erosion controls have been installed on the bank of the Mill River west of the chain link fence. This includes an orange marker layer of plastic construction fencing under a layer of seeded and planted organic soil. The layer of seeded organic material should be maintained to a thickness sufficient so as the orange marker layer is not visible. It should be noted that the orange marker layer was installed over rock in some areas and organic material and planting Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 25 Northampton, Massachusetts are not expected to stay or grow on top of the rock. In these limited areas, the orange marker layer will remain visible. In steeper areas, erosion control fabric or blanket was installed over the organic layer and pinned in place to assist in the establishment of planted materials. This material may be supplemented as necessary, or allowed to compost in place as the planted materials become established. Erosion of the steep bank west of the chain link fence is not permitted and eroded areas will be repaired promptly; The surveyed boundaries of the AULs for AOC-1 are shown on Figure 7. Copies of the AUL LSP Opinion are included in Appendix G. The recorded AULs will be submitted to the Department. 6.3 RAO Statement Transmittal Form In accordance with 310 CMR 40.1000, a RAO Statement Transmittal Form (BWSC-104), has been completed for the Site on the eDEP system. A copy of the electronically signed form is included in Appendix B of paper copies of this report. 6.4 Public Involvement Public involvement activities have been conducted in accordance with 310 CMR 40.1403(3)(f). These activities included notification of the Chief Municipal Officer, the Board of Health, the Planning Department, and the Conservation Commission in the City of Northampton of the availability of the Class A3 RAO Statement and the AULs. Copies of letters sent to these offices are included in Appendix H. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 26 Northampton, Massachusetts 7.0 CLASS C1 RESPONSE ACTION OUTCOME: AOC-2 & AOC-3 A Class C-1 Response Action Outcome, as described in 310 CMR 40.1036(1), has been achieved at the Site, which is described as a portion of the property addressed as 320-360 Riverside Drive in Northampton, Massachusetts. A condition of No Substantial Hazard exists, and response actions to achieve a permanent solution are not currently feasible. The boundaries of the Disposal Site are illustrated on Figure 8 and Figure 9. 7.1 Risk Assessment Conclusions for AOC-2 & AOC-3 AOC-2 and AOC-3: These areas of the Site occupy the narrow strip of undeveloped land between Riverside Drive and the Mill River, from the northern VHI property line to the northern portion of Lot 77, where water entered the raceway at a former dam (Figures 2 & 3). The Method 3 risk characterization for this Site was completed by OTO, is discussed in Section 5.4 above, and is included in full in Appendix F. Conclusion of the Method 3 risk characterization pertaining to AOC-2 and AOC-3 are as follows: This portion of the Disposal Site currently poses No Substantial Hazard to human health, safety, public welfare, and the environment under current conditions and uses. The Risk Characterization concludes that the residual concentrations in soil and groundwater pose No Substantial Hazard to workers, utility workers, or other visitors to the Site. However, since a level of No Substantial Hazard is not supported for future unrestricted activities and uses of this impacted portion of the Site which may result in exposure to soils via dermal contact and incidental ingestion, or contaminant migration via erosion, an AUL is warranted. These exposures are not present currently because the metals impacted soil is isolated beneath a stabilization layer of compost mulch, seed, erosion control fabric, and isolated behind a chain link fence. Therefore to ensure that a condition of No Substantial Hazard is maintained at the Site for future foreseeable site activities and uses, an AUL is necessary to eliminate exposure pathways and exposure, and to prevent erosion of the metals impacted soil. Activities which may result in the disturbance of soil in the AUL area must be restricted to prevent exposures which may pose a substantial hazard to sensitive receptors. The Risk Characterization conducted relative to DEP RTN #1-13320 at the portion of property referenced as AOC-2 and AOC-3 at 360 Riverside Drive in Northampton, Massachusetts has determined that with the implementation of an Activity and Use Limitation (AUL), a condition of “No Substantial Hazard” to health, safety, public welfare and the environment exists at this portion of the Site. This portion of the Site is therefore eligible for a Class C-1 RAO-P. 7.2 Activity & Use Limitation: AOC-2 & AOC-3 An AUL is required at all disposal sites for which a RAO, and the risk characterization pursuant to 310 CMR 40.0900 used to support the RAO, are based upon the restriction or limitation of Site Activities and Uses to achieve or maintain a level of No Significant Risk/No Substantial Hazard including any Site Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 27 Northampton, Massachusetts where a Method 3 Risk Characterization performed relies on reduced exposure potential due to the assumption of limited site use. An Activity & Use Limitation (AUL) will be placed on the portions of the Site identified as AOC-2 and AOC-3 as shown on Figure 8 as part of this submittal. The restrictive and permissive content of this AUL is as follows: 7.2.1 Permitted Activities and Uses Set Forth in the AUL Opinion The AUL Opinion provides that a condition of no substantial hazard to health, safety, public welfare, or the environment (such condition being defined in 310 CMR 40.0000) exists for any foreseeable period of time so long as any of the following activities and uses occur on the Property restricted by the AUL: i. Permitted Site uses include routine maintenance of erosion controls which do not cause and/or result in the relocation of soil soil located between 0-15 feet below grade within the AUL area at the Site as shown on Exhibit B. Relocation of soil is permitted within the AUL area provided the activities conform to the conditions outlined in Section 8 of this LSP Opinion (Obligations and Conditions); ii. Short-term (6 months or fewer) construction, emergency utility repair and/or other subsurface activities within the AUL area provided the activities conform to the conditions outlined in Section 8 of this LSP Opinion (Obligations and Conditions); iii. Monitoring, assessment or remediation of the Site by authorized personnel; iv. Activities and Uses which are not identified in this Opinion as being inconsistent with maintaining a condition of no substantial hazard; v. Such other activities or uses which, in the Opinion of an LSP, shall present no greater risk of harm to health, safety, public welfare, or the environment that the activities and uses set forth in this Paragraph; and, vi. Such other activities and uses not identified in Section 7 of this LSP Opinion as being Activities and Uses Inconsistent with the AUL. 7.2.2 Activities and Uses Inconsistent with the AUL Opinion Activities and uses which are inconsistent with the AUL Opinion, and which, if implemented at the portion of the Property restricted by the AUL, may result in a significant risk of harm to health, safety, public welfare, or the environment at the Site are as follows: i. Use of the AUL area for residential, commercial, industrial, agricultural, or recreational purposes; ii. Use of any portion of the AUL area soil for the growth or production of homegrown produce for human consumption; iii. Use of any portion of the of the AUL area for any reason other than maintenance of the erosion controls on the bank of the Mill River, maintenance of the existing sewer lines, or monitoring, assessment or remediation of the Site. 7.2.3 Obligations and Conditions Set Forth in the AUL Opinion The AUL Opinion provides that a condition of no substantial hazard to health, safety, public welfare, or the environment (such condition being defined in 310 CMR 40.0000) exists for any foreseeable period of Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 28 Northampton, Massachusetts time so long as any of the following obligations and conditions are maintained on the Property restricted by the AUL: i. The five-foot high chain link fences on the north, east, and south sides of the AUL area on Lot 77 shall be maintained in good condition; ii. Gates in the chain link fences shall remain locked at all times. The property owner(s) shall restrict access to the locked areas to authorized personnel who are familiar with the terms of this document; iii. Signs stating the fenced areas within the chain link fences are off limits (“No Trespassing”) shall be posted in visible locations along each section of fence, and shall be maintained in good condition; iv. Soil within the AUL area may not be moved to another area of the Property, or off the Site, without first being evaluated by an LSP who shall render an opinion, in accordance with 310 CMR 40.1080 et seq., as to whether the soil relocation will present a significant risk of harm to health, safety, public welfare, or the environment. v. Erosion controls have been installed on the bank of the Mill River above the stone retaining wall. This includes a layer of seeded and planted organic soil. In steeper areas, erosion control fabric or blanket was installed over the organic layer and pinned in place to assist in the establishment of planted materials. This material may be supplemented as necessary, or allowed to compost in place as the planted materials become established. Erosion of the steep bank above the stone retaining wall is not permitted and eroded areas will be repaired promptly; 7.3 RAO Statement Transmittal Form In accordance with 310 CMR 40.1000, a RAO Statement Transmittal Form (BWSC-104), has been completed for the Site on the eDEP system. A copy of the electronically signed form is included in Appendix B of paper copies of this report. 7.4 Public Involvement Public involvement activities have been conducted in accordance with 310 CMR 40.1403(3)(f). These activities included notification of the Chief Municipal Officer, the Board of Health, the Planning Department, the Department of Public Works, and the Conservation Commission in the City of Northampton of the availability of the Class C1 RAO Statement and the AUL. Copies of letters sent to these offices are included in Appendix H. Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 29 Northampton, Massachusetts 8.0 CONCLUSIONS The extent of the disposal of industrial waste materials, demolition debris, and common refuse in an unregulated landfill within and along the former raceway leading to the Cutlery Building has been identified. Soil that exceeded the UCL in AOC-1 was excavated and moved to the stockpile in AOC-2. For the Area AOC-1, a Permanent Solution has been achieved, the level of OHM in the environment has not been reduced to background and an Activity and Use Limitation has been implemented. The EPCs for identified OHM material at the disposal Site does not exceed any UCL in soil and groundwater, therefore this portion of the Site is eligible for a Class A3 RAO. For the portion of the Site labeled AOC-2 & AOC-3, a condition of No Substantial Hazard exists, response actions to achieve a permanent solution are not currently feasible, and an an Activity and Use Limitation has been implemented. This portion of the Site is eligible for a Class C1 RAO. FIGURES New England Environmental, Inc. Environmental Consulting Services 15 Research Drive Amherst, MA 01002 413-256-0202 413-256-1092 Fax Figure 1 Locus Map Former Cutlery Raceway 320-260 Riverside Drive Northampton, Massachusetts NEE File #02-2053 N 0.5 Mile Radius SITE USGS Easthampton, MA Quadrangle, 1990 0 0.25 0.5 SCALE IN MILES New England Environmental, Inc. Environmental Consulting Services 15 Research Drive Amherst, MA 01002 413-256-0202 Fax #413-256-1092 Figure 2 Aerial photograph Former Cutlery Raceway 320-260 Riverside Drive Northampton, Massachusetts NEE File #02-2053 N Former -Firehouse Approximate Area -Cutlery of Filled Raceway AOC-3 Former Dam Location Approximate Extent of Raceway Levee Approximate Extent of “Site” and Impacted Soils AOC-2 AOC-1 Surfical Soil Sample Location Approximate Extent of Fill in Raceway GZA Test Pit Location Stone Wall Existing Buildings Test Pit Locations TP-4 Explanation: Storm Drain Manhole Cover Monitoring Well /Soil Boring Sediment Sample Location SMH Sample Location SP-1 Approximate Location of the Mill River Paved areas outside of raceway NEE-22-2.5' Soil Stockpile Soil Excavated to Stockpile in AOC-2 Existing Surface Drainage Proposed Siltfence Location/Limit of Work Mulch Seed & Hay Areas with Orange Plastic Fence Layer Mulch Seed & Hay Areas Chain Link Fence AUL Area EPH, PCBs, Pesticides SVOCs, VOCs Sample Locations where additional analyses were completed other than Metals CB-CS-8 Confirmatory Samples x x RIVERSIDE LEXINGTON AVE. IHS-2 IHS-3 IHS-4 IHS-5 IHS-6 IHS-1 Approximate Extent of Raceway Fill Surfical Soil Sample Location Approximate Extent of Fill in Raceway GZA Test Pit Location GZA TP-1 GZA TP-2 GZA TP-3 GZA TP-4 GZA TP-5 GZA TP-6 Stone Wall TP-7a TP-7TP-6 TP-5 TP-9c TP-9b TP-9a TP-8 TP-11 TP-10b TP-10a TP-1 TP-2 TP-3 TP-4 Existing Buildings W W W W W W W W W W W W W W W W TP-14 TP-15 TP-13 TP-12 Test Pit Locations TP-4 Explanation: D D D D D D D D D D D G G G G G G G G G G G G G G G G s s s s s s s s s s s s s s s s S S S S S S S S S S S S S S S S S S S s s s s s s s House #337 House #347 Storm Drain S IHS-9 IHS-10 IHS-11 G G G G SMH SMH SMH s s s s s G G G G MW-4 MW-3 MW-1 MW-2SMW-2D D Monitoring Well /Soil Boring C&C Sed-4200' Downstream DEP Sediment Sample Sed-3(Approximate Location) (Huntley 1996)SB-4 (Huntley 1996)SB-3 x x x x GZA TP-9 DEP Sediment Sample Sed-2(Approximate Location) DEP Sediment Sample Sed-1(Approximate Location) C&C Sed-6 C&C Sed-5 C&C Sed-3 C&CSed-2 C&C Sed-1150' Upstream IH-L-8 IH-L-18 IH-L-15 IH-L-12 IH-L-10 IH-L-9 IH-L-2 210 205 Stone withMasonry Cap DEP-1 SMH 200 195 190Culvert SMH 200 Stone Retaining Wall 200 195 190 185 GZA TP-8 GZA TP-7 Approximate Limits of Former Raceway IHS-8 IHS-7 SP-3 10 feet SP-6 10 feet SP-7 6 feet SP-4 12 feet SP-1 5 feet SP-16 1 foot SP-15 4 feet SP-14 6 feet SP-13 5 feet SP-10 5.5 feet SP-9A5 feet SPMW-4 14 feet Wetland Area Wetland Area NORTH SP-5 8.5 feet SP-9B 6 feet Approximate Location of the Mill River Paved areas outside of raceway SP-2 Former "Firehouse" "Cutlery Building"(former Northampton Cutlery Mill) Sed-7 NEE-12.5'-3' NEE-32-3' NEE-22-2.5' NEE-42.5' NEE-54' GG G NEE-6' NEE-73' NEE-102-2.5' NEE-82-2.5' NEE-92-2.5' Tail Race -. Open ChannelConcrete Retaining Wall CL Fence Tail RaceCovered Channel x x x x MILL MILL RIVER RIVER EXISTINGPAVED PARKING LOT PAVED PARKING LOT PAVED PARKING LOT 6' CL Fence EXISTINGPAVED DRIVEWAY SA-7 SA-6SA-5 SA-4SA-3 SA-1 26' 36' SURFACE DRAINAGE CENTERLINE NORTH NORTH NORTH Existing Surface Drainage Proposed Siltfence Location/Limit of Work #320 Map 30A, Lot 32 3.48 Acres #340 Map 30A, Lot 76 20,000 SF #360 Map 30A, Lot 77 8.3+ Acres #360 Map 30A, Lot 77 8.3+ Acres 8' 15' CB-5-SED CB-11-SED CB-14-SED BLOWN COMPOST LOG AND WILLOW STAKES AT TOE OF SLOPE AND BANK TREATMENT AREA -340 L.F. PLASTIC ORANGE FENCING MARKER LAYER LAID ON SURFACE OF BANK AND COVERED IN MULCH, COMPOST, AND SEEDED. STEEP AREAS OF BANK COVERED WITH EROSION CONTROL BLANKET PRIOR TO SEED. CB-2 CB-3 CB-4 CB-7 CB-8 CB-1 CB-6 CB-10CB-9 CB-15 CB-12 CB-13 VALLEY HOME IMPROVEMENTNEW ADDITION UCL SOIL EXCAVATION AREA 4' HT. CHAIN LINK FENCE AT EDGE OF PAVEMENT (~350 L.F.) STORM WATER SEDIMENT TRAP WALL SMH MW-CR-2 RB-1 RB-2 MW-CR-3 RB-3 OSS-31 OSS-32 OSS-33 OSW-3 RB-4 RB-5 CR-4 CR-5 MW-CR-6 RB-6 RB-7 RB-8 CR-7 MW-CR-8 OSS-21 OSS-22 OSS-24 OSW-2 OSS-23 WP-1 WP-2 RB-9 RB-10 CR-9 OSS-11 OSS-12 OSS-14 OSW-1 OSS-13 TRANSECT 3 TRANSECT 2 MULCH, SEED AND HAY TOP OF BANK; EROSION CONTROL FABRIC ON STEEP BANK AS NEEDED. REBUILT STONE RETAINING WALL (~40-50 L.F.) SOIL STOCKPILE COVERED w/LOAM & SEED 5' HT. CHAIN LINK FENCE AT TOP OF SLOPE (~860 L.F.) 5' HT. CHAIN LINK FENCE AT TOP OF SLOPE (~860 L.F.) DRIVE CB-19 CB17 CB-18 CB-16 sed CB-1-2 BANK FULL BENCH NO TRESPASSING SIGNS IN TREES ON TOP OF WALL FACING RIVER NO TRASPASSING SIGNS ON TREES AT THE BOTTOM OF SLOPE FACING RIVER NO TRESPASSING SIGNS ON TREES AT TOP OF SLOPE FACING PARKING LOT. NO TRESPASSING SIGNS ON TREES AT BOTTOM OF SLOPE FACING RIVER NO TRESPASSING SIGNS ON TREES ON TOP OF WALL FACING RIVER CB-CS-3 CB-CS-2 CB-CS-1 CB-CS-6 CB-CS-5CB-CS-4 CB-CS-8 CB-CS-7 SOIL STOCKPILE COVERED w/LOAM & SEED 5-FOOT CL FENCE LOCATION WITH SWING GATE TRANSECT 1 AUL AREA #2 MULCH, SEED AND HAY TOP OF BANK; EROSION CONTROL FABRIC ON STEEP BANK AS NEEDED. MILL RIVER LE-3LE-1 LE-2 LE-4 LE-5 LE-6 LE-7 LE-8 LE-11 LE-10 LE-9 LE-12 LE-13 LE-14 LE-16 LE-17LE-18 LE-19 LE-20 LE-21LE-22 LE-23 LE-25 LE-26 LE-30LE-29LE-31 LE-27 B-2 LE-28 LE-32 LE-33 LE-34 B-3 LE-35 LE-36 LE-37 LE-38 B-4 LE-39 LE-41LE-40 LE-15 B-1 S6 S1+S2 S3+S4 S5 S6 S1+S2 S3+S4 S5 TPH VOCs EPH VPH EPH VPH PCBs PCBs PCBs IHS-14 IHS-12 IHS-13 IHS-15 IHS-16 PCBs PCBs PCBs PCBs PCBs EPH & VPH VOCs EPH & VPH VOCs EPH & VPH VOCs EPH & VPH VOCs EPH & VPH VOCs, COAL ASH PCBs, Pesticides SVOCs, VOCs EPH & VPH VOCs EPH EPH, PCBs, Pesticides SVOCs, VOCs PCBs, Pesticides SVOCs, VOCs COAL ASH COAL ASH Pesticides SVOCs, VOCs EPH PCBs EPH PCBs EPH PCBs EPHEPHEPH EPH EPH EPHEPH EPH EPH EPH EPH EPH EPH EPH EPH EPH EPH EPH COAL ASH 5' HT. CHAIN LINK FENCE AT TOP OF SLOPE (~860 L.F.) SA-2 S E N WB N W B E S E3 S2 W2 N3 W3S E Base2 N3 B S W2 N2 E2 B AUL AREA #1 E N S WB 1" = 40'-0" ENVIRONMENTAL CONSULTING SERVICES 9 RESEARCH DRIVE AMHERST, MA 01002 FAX: (413) 256 1092 WWW.NEEINC.COM TEL: (413) 256 0202 6/16/09 ALH 02-2053H WLW Prepared for: Prepared by: Date: Scale: Drawn by: Checked by: NEE File # DEP # NEW ENGLAND ENVIRONMENTAL, INC. REVISIONS DATE: BY: Figure-3 Cutlery Building Associates 56 Main Street Former Cutlery Raceway Northampton, Massachusetts 320-360 Riverside Drive Northampton, Massachusetts SITE PLAN -Sampling Locations SCALE 1"-40'-0" 3 SP-3 SITE PLAN Sampling Locations #1-13320 Surfical Soil Sample Location Approximate Extent of Fill in Raceway GZA Test Pit Location Stone Wall Existing Buildings Test Pit Locations TP-4 Explanation: Storm Drain Manhole Cover Monitoring Well /Soil Boring Sediment Sample Location SMH Sample Location SP-1 Approximate Location of the Mill River Paved areas outside of raceway NEE-22-2.5' Soil Stockpile Soil Excavated to Stockpile in AOC-2 Existing Surface Drainage Proposed Siltfence Location/Limit of Work Mulch Seed & Hay Areas with Orange Plastic Fence Layer Mulch Seed & Hay Areas x x Chain Link Fence AUL Area W W W W W W W W W G G G s s s s S S S S G G G G SMH MW-3 MW-1 DEP Sediment Sample Sed-3(Approximate Location) Former "Firehouse" "Cutlery Building"(former Northampton Cutlery Mill) GG G Tail Race -. Open ChannelConcrete Retaining Wall CL Fence Tail RaceCovered Channel x x x EXISTINGPAVED PARKING LOT PAVED PARKING LOT PAVED PARKING LOT EXISTINGPAVED DRIVEWAY SA-6SA-5 SA-4SA-3 SA-1 26' 36' NORTH #320 Map 30A, Lot 32 3.48 Acres #340 Map 30A, Lot 76 20,000 SF 8' 15' CB-5-SED CB-11-SED CB-14-SED CB-2 CB-3 CB-4 CB-7 CB-10CB-9 CB-15 CB-12 CB-13 VALLEY HOME IMPROVEMENTNEW ADDITION UCL SOIL EXCAVATION AREA CB-19 CB17 CB-18 CB-16 sed CB-1-2 CB-CS-3 CB-CS-2 CB-CS-1 CB-CS-6 CB-CS-5CB-CS-4 CB-CS-8 CB-CS-7 MILL RIVER SA-2 S E N WB N W B E S E3 S2 W2 N3 W3S E Base2 N3 B S W2 N2 E2 B E N S WB 1" = 30'-0" ENVIRONMENTAL CONSULTING SERVICES 9 RESEARCH DRIVE AMHERST, MA 01002 FAX: (413) 256 1092 WWW.NEEINC.COM TEL: (413) 256 0202 04-06-06 ALH 02-2053H WLW Prepared for: Prepared by: Date: Scale: Drawn by: Checked by: NEE File # DEP # NEW ENGLAND ENVIRONMENTAL, INC. REVISIONS DATE: BY: FIGURE-4 Cutlery Building Associates 56 Main Street Former Cutlery Raceway Northampton, Massachusetts SAMPLE LOCATION SITE PLAN FIGURE 4 320-360 Riverside Drive Northampton, Massachusetts SAMPLE LOCATION SITE PLAN -AOC-1 SCALE: 1"=30'-0" 4 FIGURE-4 06-16-2009 WLW Revised slope stabilization treatment. Added AUL Areas to AOC-1 12-27-07 WLW Riverside Drive MILL RIVER drain drainfence fence B-4 B-3 B-2 B-1 LE-9LE-8 LE-7 LE-6 LE-5LE-4 LE-3 LE-2 LE-1 LE-38 LE-37 LE-41 LE-40 LE-39 LE-36 LE-35 LE-34 LE-33 LE-31 LE-30 LE-32 LE-28 LE-27LE-26 LE-25 LE-23 LE-22 LE-21 LE-20 LE-19 LE-18 LE-17 LE-15 LE-16 LE-14LE-12 LE-13 LE-10LE-11 LE-24 Legend Levee Sampling Points Guardrail Stonewall Sewer Manhole Figure 5 -Levee Sampling Site Plan AOC-3 Former Cutlery Raceway Northampton, MA RTN# 1-13320 Scale 0 20 40 80 Feet 500 ft 1/2 Mile SITE Figure 3 Priority Resources Map New England Environmental, Inc. Environmental Consulting Services 15 Research Drive Amherst, MA 01002 413-256-0202 413-256-1092 Fax Figure 6 Priority Resource Map Former Cutlery Raceway 320-260 Riverside Drive Northampton, Massachusetts NEE File #02-2053 N Quad 38 (Easthampton) Priority Resources Map, 2009 Figure 7 Class A3 and Class C1 RAO Report, NEE 2/8/2011 Figure 8 Class A3 and Class C1 RAO Report, NEE 2/8/2011 PHOTOGRAPHS Class A3 & Class C1 RAO Report RTN #1-13320 Cutlery June 16, 2009 320-360 Riverside Drive Photo Page 1 Northampton, MA The tailrace sediment trap with water in it. New asphalt and 4-foot high CLF behind Cutlery Building. New asphalt parking lot in AOC-1. New asphalt parking lot and 4-foot high CLF near tailrace. New asphalt parking lot in AOC-1. New asphalt parking lot in AOC-1. Class A3 & Class C1 RAO Report RTN #1-13320 Cutlery June 16, 2009 320-360 Riverside Drive Photo Page 2 Northampton, MA Brown patch was repaired in Fall 2008 with addition of more blown-in compost. Orange marker layer is visible in small patch; center of photo. Area will be repaired. Grass on soil stockpile is healthy and no erosion is evident. Orange marker layer is visible in small patch; center of photo. Area will be repaired. Gap between bottom of fence and asphalt will be repaired by adding more fence material in the gap. Grass on top of the levee is healthy. Class A3 & Class C1 RAO Report RTN #1-13320 Cutlery June 16, 2009 320-360 Riverside Drive Photo Page 3 Northampton, MA Vegetation on levee bank above re-built stone retaining wall is in good condition. Grass on slope just north of well CR-3 is established. Well CR-2 on top of levee. Grass on slope near center of levee and well CR-3 is established. Slope just south of well CR-2 is too dry to support vegetation. Northeast corner of chain link fence along Riverside Drive. TABLES Table 1 -Groundwater Sample Laboratory Results Former Cutlery Raceway, Northampton MA RTN #1-13320 Sample ID: Date Collected MW-1 1/24/01 MW-1 6/8/01 MW-1 10/24/08 MW-3 1/24/01 MW-3 6/8/01 MW-3 10/24/08 MW-2S 1/24/01 MW-2S 6/8/01 MW-2S 10/24/08 MW-2D 1/24/01 MW-2D 6/8/01 MW-2D 10/24/08 MW-4 1/31/01 MW-4 6/8/01 MW-4 3/27/02 MW-4 3/24/03 MW-4 6/5/06 MW-4 10/24/08 Method 1 GW-2 Standard Method 1 GW-3 Standard UCL OTO EPH Aliphatics/Aromatics (ug/L) C9-C18 Aliphatics BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na 1,000 20,000 100,000 C19-C36 Aliphatics BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na NA 20,000 100,000 Aromatics BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na 50,000 30,000 100,000 EPH Target PAH Analytes (ug/L) All Analytes BDL BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na ------Soluble PP13 Metals (ug/L) 7/11/01 7/11/01 7/11/01 7/11/01 7/11/01 Antimony BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 8,000 80,000 Arsenic BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 900 9,000 Beryllium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 200 2,000 Cadmium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 4 50 Chromium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 2.6 BDL BDL BDL BDL BDL BDL BDL NA 600/300 3,000 Copper BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NSL NSL NSL Lead BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 10 150 Nickel BDL 20.9 9.5 BDL BDL BDL BDL 3.03 BDL BDL BDL BDL 333 735 468 4,180 174 84.2 NA 200 2,000 Selenium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 100 1000 Silver BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 7 1000 Thallium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 3000 30,000 Zinc BDL 3.78 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 26.7 18.5 22.2 67.1 123 BDL NA 900 50,000 Mercury BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 20 200 Notes: 1 Laboratory Analytical results compared to: 310 CMR 40.1600 & 310 CMR 40.0974(2). Avg. nickel conc in all monitoring wells 10/24/08 = 24 2 Red (& bold) = Exceeds Method 1 GW-3 Standard Avg. nickel conc in all monitoring wells over time = 344 3 Blue = Parameter detected above laboratory Method Detection Limit Avg nickel concnetration in MW-4 over time = 996 4 NSL=No Standard Listed 5 na = Not Analyzed for this parameter. 6 BDL = Below Detection Limit 7 Red (& bold) with yellow = Exceeds UCL Standard 8 Data from this sample are suspect and have been removed from further inclusion in the data set (see text). Class A3 RAO: AOC-1 Class C1 RAO: AOC-2 & AOC-3 Upgradient Downgradient Upgradient Downgradient New England Environmental, Inc. H:\PROJECTS\02-2053-H_Cutlery Raceway\5-Class A3 RAO-P\02-2053-Table 5-GWSheet1 (2) OTO Brownfields Investigation (June 2006) -Table 2 Groundwater Analytical Results Inorganic Analytes Former Cutlery Raceway Northampton, MA Concentrations in mg/l Well No.: CR-1 CR-2 CR-3 CR-6 CR-8 MW-4F* MW-4U* WP-1 WP-2 GW-3 Sample Date: 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 Standards UCLs VOCs by Method 8260B ND ND ND ND ND ----ND ND vary vary EPH Fractions C9-C18 Aliphatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 ----< 0.2 --20 100 C19-C36 Aliphatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 ----< 0.2 --20 100 C11-C22 Aromatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 ----< 0.2 --30 100 EPH Target PAHs ND ND ND ND ND ----ND --vary vary Metals Antimony < 0.030 < 0.030 < 0.030 < 0.030 < 0.030 < 0.024 < 0.15 < 0.030 < 0.030 8 80 Arsenic < 0.004 < 0.004 < 0.004 < 0.004 < 0.004 < 0.008 0.125 < 0.004 < 0.004 0.9 9 Beryllium < 0.002 < 0.002 < 0.002 < 0.002 < 0.002 < 0.004 0.0165 < 0.002 < 0.002 0.05 0.5 Cadmium < 0.0025 < 0.0025 < 0.0025 < 0.0025 < 0.0025 < 0.005 < 0.0125 < 0.0025 < 0.0025 0.004 0.05 Chromium (III) < 0.005 < 0.005 < 0.005 0.0431 < 0.005 < 0.010 1.81 < 0.005 0.0056 0.6 6 Copper < 0.005 < 0.005 < 0.005 0.0117 < 0.005 < 0.010 1.4 < 0.005 0.0103 NS NS Lead < 0.0075 < 0.0075 < 0.0075 0.0158 < 0.0075 < 0.015 0.286 < 0.0075 < 0.0075 0.01 0.15 Mercury < 0.0002 < 0.0002 < 0.0002 < 0.0002 < 0.0002 < 0.0002 0.00029 < 0.0002 < 0.0002 0.02 0.2 Nickel 0.0058 0.0636 0.0656 0.0432 < 0.005 0.174 3.67 < 0.005 0.0137 0.2 2 Selenium < 0.015 < 0.015 < 0.015 < 0.015 < 0.015 < 0.030 < 0.075 < 0.015 < 0.015 0.1 1 Silver < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.010 0.0272 < 0.005 < 0.005 0.007 1 Thallium < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.020 < 0.050 < 0.010 < 0.010 3 30 Zinc < 0.035 < 0.025 < 0.025 < 0.057 < 0.025 0.123 2.13 < 0.096 0.493 0.9 50 NOTES: 1. Concentrations in milligrams per liter (mg/l, or parts per million). "<" indicates not detected; value is quantitation limit. "--" = Not analyzed for this pa 2. MCP Method 1 groundwater standards from 310 CMR 40.0974(2). "UCLs" = Upper Concentration Limits, from 310 CMR 40.0996(7). 3. Values shown in bold exceed standards, underlined exceed UCLs. 4. "ND" = None of the target analytes were detected. "NA"=Not applicable. "NS"=No standard available. 5. "VOCs" = Volatile organic compounds. "EPH" = Extractable Petroleum Hydrocarbons. "PAHs"=Polycyclic aromatic hydrocarbons. * Groundwater from well MW-4 was analyzed on both a filtered (F) and unfiltered (U) basis. Table 2-1 AOC-3 AOC-2 New England Environmental, Inc. GW data.xls /gw (2) OTO Brownfields Investigation (June 2006) -Table 3 River Bank Soil Sample Analytical Results Former Cutlery Raceway Northampton, MA Concentrations in mg/kg Sample No.: RB-1 RB-2 RB-3 RB-4 RB-5 RB-6 RB-7 RB-8 RB-9 RB-10 MADEP Method 1 Standards Depth (inches.): 0-3 0-3 0-3 0-3 0-3 0-3 0-3 0-3 0-3 0-3 Ash Fill S-1 /S-1 /UCLs Date Collected: 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 Bkgrd. GW-2 GW-3 EPH Fractions C9-C18 Aliphatics < 44 < 40 < 46 < 32 < 36 < 37 < 62 < 40 < 32 < 43 NA 1,000 1,000 20,000 C19-C36 Aliphatics < 44 < 40 < 46 43.2 < 36 < 37 < 62 < 40 < 32 < 43 NA 2,500 2,500 20,000 C11-C22 Aromatics < 44 < 40 < 46 38.1 < 36 < 37 < 62 < 40 < 32 < 43 NA 800 800 10,000 EPH Target Analytes Naphthalene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 40 500 10,000 2-Methylnaphthalene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 500 500 10,000 Acenaphthylene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 100 100 10,000 Acenaphthene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 2 1,000 1,000 10,000 Fluorene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 2 1,000 1,000 10,000 Phenanthrene 0.222 0.289 0.301 0.165 < 0.18 < 0.19 0.332 < 0.20 < 0.16 < 0.22 20 1,000 100 10,000 Anthracene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 4 1,000 1,000 10,000 Fluoranthene 0.328 0.383 0.438 0.201 < 0.18 < 0.19 < 0.31 < 0.20 0.163 < 0.22 10 1,000 1,000 10,000 Pyrene 0.262 0.303 0.373 0.173 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 20 1,000 1,000 10,000 Benzo(a)anthracene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 9 7 7 3,000 Chrysene 0.308 0.345 0.292 0.184 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 7 7 7 400 Benzo(b)fluoranthene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 8 7 7 3,000 Benzo(k)fluoranthene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 4 70 70 10,000 Benzo(a)pyrene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 7 2 2 300 Indeno(1,2,3-cd)pyrene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 3 7 7 3,000 Dibenzo(a,h)anthracene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 0.7 0.7 300 Benzo(g,h,i)perylene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 3 1,000 1,000 10,000 Metals (Priority Pollutant 13) Antimony < 22 21.8 168 < 17 < 20 22.1 1,040 < 19.1 < 1.63 < 1.98 7 20 20 300 Arsenic 39.4 < 2.05 48.1 30.7 53.4 36.1 75.6 < 19.1 < 1.63 < 1.98 20 20 20 200 Beryllium 0.574 0.513 < 0.288 0.425 < 0.27 0.49 < 0.33 < 0.255 < 0.217 < 0.264 0.9 0.7 0.7 30 Cadmium 1.69 1.8 0.627 1.28 1.16 1.9 3.98 < 0.319 < 0.272 < 0.329 3 2 2 300 Chromium (III) 5,740 2,520 13,300 4,660 13,900 2,090 9,210 4,270 39.8 51 40 1,000 1,000 10,000 Copper 9,970 4,680 626 11,500 1,270 5,710 11,100 83.5 27.8 83.2 200 NS NS NS Lead 445 933 277 355 770 581 114,000 112 9.6 17.2 600 300 300 3,000 Mercury 0.188 0.0974 0.12 0.239 0.228 1.3 3.08 0.108 < 0.055 < 0.070 1 20 20 300 Nickel 20,900 7,460 907 26,100 3,010 12,700 25,300 215 40.2 165 30 20 20 7,000 Selenium < 22 < 10.3 < 22 < 17 < 20 < 10 < 25 < 1.91 < 1.63 < 1.98 1 400 400 8,000 Silver 5.02 1.98 3.17 35.7 1.91 1.83 17.9 < 1.27 < 1.09 < 1.32 5 100 100 2,000 Thallium 3.73 2.33 4.45 3.44 4.87 2.1 5.17 < 1.91 < 1.63 < 1.98 5 8 8 800 Zinc 79.8 54.5 37.3 147 134 55.4 653 55.9 25.3 35.9 300 2,500 2,500 10,000 NOTES: 1. Concentrations in mg/kg (parts per million) on a dry weight basis. "<" indicates not detected; value is sample-specific quantitation limit. 2. MCP Method 1 soil standards from 310 CMR 40.0975(6). Values shown in bold exceed Method 1 standards. Underlined values exceed UCLs. 3. "Ash Fill Bkgrd." =Background values from MADEP "Technical Update: Background Levels of Polycyclic Aromatic Hydrocarbons and Metals in Soil", May 23, 2002. Table 2-2 AOC-3 AOC-2 New England Environmental, Inc. soil data.xls /RB OTO Brownfields Investigation (June 2006) -Table 4 Surface Water Analytical Results Former Cutlery Raceway Northampton, MA Concentrations in mg/l Well No.: OSW-1 OSW-2 OSW-3 MADEP Sample Date: 5/23/06 5/23/06 5/23/06 SW Target Extractable Petroleum Hydrocarbons C9-C18 Aliphatics < 0.2 < 0.2 < 0.2 1.8 C19-C36 Aliphatics < 0.2 < 0.2 < 0.2 2.1 C11-C22 Aromatics < 0.2 < 0.2 < 0.2 0.005 EPH Target Polycyclic Aromatic Hydrocarbons Naphthalene < 0.006 < 0.006 < 0.006 0.072 2-Methylnaphthalene < 0.006 < 0.006 < 0.006 0.07 Acenaphthylene < 0.006 < 0.006 < 0.006 0.00014 Acenaphthene < 0.006 < 0.006 < 0.006 0.023 Fluorene < 0.006 < 0.006 < 0.006 0.00014 Phenanthrene < 0.006 < 0.006 < 0.006 0.038 Anthracene < 0.006 < 0.006 < 0.006 0.00013 Fluoranthene < 0.006 < 0.006 < 0.006 0.009 Pyrene < 0.006 < 0.006 < 0.006 0.000089 Benzo(a)anthracene < 0.006 < 0.006 < 0.006 0.001 Chrysene < 0.006 < 0.006 < 0.006 0.00007 Benzo(b)fluoranthene < 0.006 < 0.006 < 0.006 0.00042 Benzo(k)fluoranthene < 0.006 < 0.006 < 0.006 0.00014 Benzo(a)pyrene < 0.006 < 0.006 < 0.006 0.0005 Indeno(1,2,3-cd)pyrene < 0.006 < 0.006 < 0.006 0.00014 Dibenzo(a,h)anthracene < 0.006 < 0.006 < 0.006 0.00004 Benzo(g,h,i)perylene < 0.006 < 0.006 < 0.006 0.00002 Metals Antimony < 0.012 < 0.012 < 0.012 0.3 Arsenic < 0.004 < 0.004 < 0.004 0.036 Beryllium < 0.002 < 0.002 < 0.002 0.0073 Cadmium < 0.0025 < 0.0025 < 0.0025 0.000091 Chromium (III) < 0.005 0.0055 < 0.005 0.024 Copper < 0.0075 < 0.0075 < 0.0075 NS Lead < 0.0075 < 0.0075 < 0.0075 0.0005 Mercury < 0.0002 < 0.0002 < 0.0002 0.00077 Nickel < 0.005 < 0.005 < 0.005 0.0082 Selenium < 0.015 < 0.015 < 0.015 0.005 Silver < 0.005 < 0.005 < 0.005 0.00003 Thallium < 0.010 < 0.010 < 0.010 0.11 Zinc < 0.020 < 0.020 < 0.020 0.036 NOTES: 1. Concentrations in milligrams per liter (mg/l, or parts per million). 2. "<" indicates not detected; value is quantitation limit. 3. "MADEP SW Target" = the target value selected by MADEP to use in generation of GW-3 groundwater standards, based on published toxicity information for aquatic organisms in surface water. 4. "NS" = No standard available. Table 2-3 New England Environmental, Inc. SW data.xls /sw OTO Brownfields Investigation (June 2006) -Table 5 Sediment Analytical Results Former Cutlery Raceway Northampton, MA Concentrations in mg/kg Transect 1 (downstream) Transect 2 (side filled raceway) Transect 3 (side unfilled raceway) Transect 4 (upstream) Sample No.: OSS-11 OSS-12 OSS-13 OSS-14 OSS-21 OSS-22 OSS-23 OSS-24 OSS-31 OSS-32 OSS-33 OSS-41 OSS-42 OSS-43 Sediment Depth (inches): 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 Screening Date Collected: 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 Criteria Extractable Petroleum Hydrocarbons (EPH) C9-C18 Aliphatics < 37 < 35 < 34 < 36 < 37 < 34 < 34 < 38 < 35 < 32 < 34 < 34 < 33 < 31 ---C19-C36 Aliphatics < 37 < 35 < 34 < 36 < 37 < 34 < 34 < 38 < 35 < 32 < 34 < 34 < 33 < 31 ---C11-C22 Aromatics < 37 < 35 < 34 < 36 < 37 < 34 < 34 < 38 < 35 < 32 < 34 < 34 < 33 < 31 ---EPH Target Analytes Naphthalene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.180 2-Methylnaphthalene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Acenaphthylene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Acenaphthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Fluorene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.077 Phenanthrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 1.46 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.200 Anthracene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.48 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.057 Fluoranthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 1.58 < 0.17 < 0.19 0.206 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.420 Pyrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 1.14 < 0.17 < 0.19 0.186 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.200 Benzo(a)anthracene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.289 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.110 Chrysene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.378 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.170 Benzo(b)fluoranthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Benzo(k)fluoranthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.232 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Benzo(a)pyrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.232 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.150 Indeno(1,2,3-cd)pyrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Dibenzo(a,h)anthracene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.033 Benzo(g,h,i)perylene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Polychlorinated biphenyls (PCBs) < 0.033 ---------< 0.037 ---------< 0.035 ------< 0.037 ------0.060 Metals (Priority Pollutant 13) Antimony 6.98 < 1.72 < 1.84 < 1.82 < 1.93 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 < 1.76 ---Arsenic < 1.88 < 1.72 < 1.84 1.82 2.14 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 1.9 33 Beryllium 0.263 < 0.23 < 0.276 0.273 0.276 < 0.237 < 0.235 < 0.267 < 0.258 < 0.219 0.283 < 0.241 0.274 0.282 ---Cadmium < 0.31 0.436 < 0.306 < 0.303 < 0.321 < 0.296 < 0.294 < 0.334 < 0.322 < 0.274 < 0.307 < 0.302 < 0.286 < 0.294 5 Chromium (III) 15 6.36 7.93 13.1 11.9 3.51 5.64 11.2 9.58 6.96 13.3 8.32 5.18 5.09 110 Copper 66.9 122 28.8 38.7 58.2 22.6 36.4 38.1 53.5 29.4 50.7 16.9 28.6 26 150 Lead 43.1 18.3 14.6 12.3 17.3 8.32 12.5 14.6 15.6 12.6 15 6.19 9.6 11.1 130 Mercury < 0.064 < 0.061 < 0.061 < 0.062 < 0.066 < 0.059 < 0.062 < 0.068 < 0.065 < 0.058 < 0.064 < 0.064 < 0.058 < 0.061 0.18 Nickel 34.8 6.12 5.67 10.2 11.3 3.64 5.67 9.03 10.1 3.83 10.5 6.25 5.19 4.97 49 Selenium < 1.88 < 1.72 < 1.84 < 1.82 < 1.93 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 < 1.76 ---Silver < 1.25 < 1.15 < 1.23 < 1.21 < 1.29 < 1.18 < 1.18 < 1.34 < 1.29 < 1.10 < 1.23 < 1.21 < 1.14 < 1.18 ---Thallium < 1.88 < 1.72 < 1.84 < 1.82 < 1.93 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 < 1.76 ---Zinc 88.5 191 44 57.2 92.6 35.5 47.9 60.5 74.7 41.2 80.8 30.9 37.2 33.2 460 NOTES: 1. Concentrations in mg/kg (parts per million) on a dry weight basis. "<" indicates not detected; value is sample-specific quantitation limit. "---" indicates not tested or not available. 2. Criteria from "Revised Sediment Screening Values", MADEP/ORS Technical Update, January 2006. Values shown in bold exceed sediment screening criteria. Adjacent to AOC-1 Adjacent to AOC-2 Adjacent to AOC-3 Upstream of Dam Table 2-4 New England Environmental, Inc. sed data.xls /sed AA47470-73 VOCs 8260B 2/1/1996 X X N Y SVOCs 8270 2/1/1996 X X N Y RCRA 8 2/1/1996 X X N TPH 8100M 2/1/1996 X X N GZA-test pits RCRA 8 9/8/1989 X X N L Y 99B21740-41 Pb, Cr 3050/6010 9/30/1999 X X N EPH 98-1 9/30/1999 X X N Y VPH 98-1 9/30/1999 X X N Y preserved according to method 99B26220-230 Pb, Cr 3050/6010 11/15/1999 X X N Y L Y AB94804-11 5Metals 200.7, 245.1 6/30/2000 X X N AB94804-11 Chrom IV SM3500 6/30/2000 X X X N L2000257-1-257-4 PP13 6010B, 7470A 8/7/2000 X X N L Y PP13 6010B, 7470A 8/7/2000 X X X N L Y AC14674-81 PCBs 8082 10/24/2000 X X N PP13 200.7, 245.1 10/24/2000 X X N 5Metals 200.7, 245.1 10/24/2000 X X N Chrom IV SM3500 10/24/2000 X X N Reactivity 7.3 10/24/2000 X X N AC19199-204 VOCs 8260B 11/21/2000 X X N Y SVOCs 8270 11/21/2000 X X N Y TPH 8100M 11/21/2000 X X N 5 Metals 200.7, 245.1 11/21/2000 X X X N AC06587-599 EPH 98-1 9/11/2000 X X N Y VPH 97-12 9/11/2000 X X N Y PP13 200.7, 245.1 9/11/2000 X X N Total Cr, Pb 200.7 9/11/2000 X X N Chrom IV SM3500 9/11/2000 X X X N AC21840-42 PP13 200.7, 245.1 12/7/2000 X X N F Chrom IV SM3500 12/7/2000 X X X N F AC26893-898 RCRA 8 200.7, 245.1 1/16/2001 X X X N AC28035-42 EPH 98-1 1/24/2001 X X N Y PP13 200.7, 245.1 1/24/2001 X X N AC29021 PP13 200.7, 245.1 1/31/2001 X X N AC58756-60 PP13 200.7, 245.1 7/11/2001 X X N AD06317 PP13 200.7, 245.1 7/11/2001 X X N AD24303-330 PP13 200.7, 245.2 6/26/2002 X X X N F EPH 98-1 6/26/2002 X X X N F Y VPH 97-12 6/26/2002 X X X N Y VOCs 8260B 6/26/2002 X X X N Y PCBs 8082 6/26/2002 X X X N Y SVOCs 8270C 6/26/2002 X X X N Y cyanide SM4500 6/26/2002 X X X N pesticides 8081A 6/26/2002 X X X N Y TCLP 1311 6/26/2002 X X X N F 1-3 coal ash PLM, SEM, and EDX 6/26/2002 X X X N 4 coal ash PLM, SEM, and EDX 6/26/2002 X X X N AD75436 PP13 200.7, 245.1 3/24/2003 X X N AE01475-83 PP13 200.7, 245.1 7/23/2003 X X X N Chrom IV 3060A 7/23/2003 X X X N Barium 200.7 7/23/2003 X X X N TCLP 1311 7/23/2003 X X X N SA20413-01-26 PP13 6010B, 7471A 11/10/2004 X X X X Y Y Y L TCLP 1311 11/10/2004 X X X X Y Y Y L SA20717-01-06 PP13 6010B, 7471A 11/17/2004 X X X X Y Y Y L SA20899-01-04 PP13 6010B, 7471A 11/23/2004 X X X X Y Y Y L SA21752-01-03 PP13 6010B, 7471A 12/9/2004 X X X X Y Y Y L TCLP 1311 X X X X Y Y Y L SA27179-01-24 PP13 6010B, 7471A 4/28/2005 X X X X Y Y Y L SA27341-01-09 PP13 6010B, 7471A 5/2/2005 X X X X Y Y Y L PCBs 8082 X X X X Y Y Y L SA27698-01-08 PP13 6010B, 7471A 5/6/2005 X X X X Y Y Y L SA27699-01-04 PP13 6010B, 7471A 5/6/2005 X X X X Y Y Y L SA28476-01 PP13 6010B, 7471A 5/23/2005 X X X X Y Y Y L SA29922-01-15 PP13 6010B, 7471A 6/21/2005 X X X X Y Y Y F/L SA45382-01-04 EPH 3545A 5/15/2006 X X X X Y Y Y L Y PP13 6010B, 7471A X X X X Y Y Y L SA45448-01-19 EPH 3545A 5/23/2006 X X X X X X Y Y Y L Y PP13 6010B, 7471A X X X X X X Y Y Y L PCBs 8082 X X X X Y Y Y L SA46097-01-09 PP13 6010B, 7470A 6/5/2006 X X X X Y Y Y L Results for MW-4 were determined to be inconsistent EPH 3510C X X X X Y Y Y L Y VOCs 5030 X X X X Y Y Y L Y SA46224-01-10 EPH 3545A 6/7/2006 X X X X Y Y Y L Y PP13 6010B, 7471A X X X X Y Y Y L SA46194-01-05 PP13 6010B, 7470A 6/9/2006 X X Y Y Y L Y Total Cr 6010B X X X X X Y Y Y L Chrom IV 3060A X X X X X Y Y Y L Full TCLP 1311 X X X X X Y Y Y L Reactivity, cyanide, sulfide Ch. 7.3 X X X X X Y Y Y L SA51415-01-09 PP13 6010B, 7471A 9/21/2006 X X X X Y Y Y F/L SA86617-01-05 PP13 6010B, 7471A 10/27/2008 X X X X Y Y Y F/L Former Cutlery Building Northampton, MA RTN1-13320 Table 3-Data Summary Table LCS/LCSD SOIL GROUNDWATER SURFACE WATER SEDIMENT EPCs CAM Compliant MS/MSD AIR Risk Assessment Duplicate (F-Field, L=Lab Sample ID or Series Site Characterization Data Qualifications, if Parameters EPA Method Date any Background Disposal Characterization Surrogate OK Confirmatory Samples New England Environmental, Inc. DataSummaryTable /Sheet1 `` 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected NEE-8 2-2.5' 7/23/03 SA-1-N 2-3' 11/10/04 SA-1-E 2-3' 11/10/04 SA-1-S 2-3' 11/10/04 SA-1-W 2-3' 11/10/04 SA-1-Base 3.5' 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/04 Total Metals (mg/kg) Silver BDL BRL BRL 50.0 47.4 5.99 NSL 200 200 2,000 Arsenic 20.5 5.1 19.7 12.4 6.17 8.72 40 20 20 200 Beryllium BDL BRL BRL BRL BRL BRL NSL 200 200 2,000 Cadmium BDL 1.22 2.09 9.16 25.0 2.13 60 30 30 800 Chromium 7,170 1,120 5,400 1,830 2,550 2,200 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na na na na 200 200 200 2,000 Copper 253 53.0 116 142 258 131 NSL NSL NSL NSL Mercury BDL 0.329 BRL 0.338 3.38 0.265 300 30 30 300 Nickel 238 45.1 113 116 88.9 79.6 NSL 700 700 7,000 Lead 2,213 190 127 910 359 321 NSL 300 300 3,000 Antimony BDL BRL BRL BRL BRL BRL NSL 30 30 300 Selenium BDL BRL BRL BRL BRL BRL NSL 800 800 8,000 Thallium BDL BRL BRL BRL BRL BRL NSL 80 80 800 Zinc 214 85.7 63.1 5,020 203 95.6 NSL 5,000 5,000 10,000 Barium 139 na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na 5 TCLP Cr BDL na na na na na 5 TCLP Pb 3.20 na na na na na 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-1 IRA Plan (NEE 6/2006) -Table 1-SA-1 Confirmatory Soil Summary: SA-1 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-1 Excav `` 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-10b 4' 11/15/99 NEE-5 4' 7/23/03 SA-2-N 3-4.5' 11/10/04 SA-2-N2 3-4.5' 12/8/04 SA-2-E 3-4.5' 11/10/04 SA-2-E2 3-4.5' 12/9/04 SA-2-S 3-4.5' 11/10/04 SA-2-W 3-4.5' 11/10/04 SA-2-W2 3-4.5' 12/9/04 SA-2-Base 5' 11/10/04 Stabilized "Stockpile" 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/04 Excavated 11/10/04 Excavated 12/8/04 Excavated 12/9/04 Excavated 12/9/04 Total Metals (mg/kg) Silver na BDL BRL BRL BRL BRL BRL BRL BRL BRL na NSL 200 200 2,000 Arsenic na 16.7 16.3 12.5 34.9 BRL 8.0 26.6 BRL BRL na 40 20 20 200 Beryllium na BDL 1.11 BRL BRL 0.63 BRL BRL 0.658 BRL na NSL 200 200 2,000 Cadmium na BDL 2.53 2.42 4.44 0.99 1.59 3.86 1.46 1.06 na 60 30 30 800 Chromium 2020 10,040 2,510 4,050 18,700 73.0 4,560 15,500 127 958 na 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na BRL na na na na BRL na na 200 200 200 2,000 2,000 Copper na 163 271 515 180 24.4 60.5 173 72.9 39.2 na NSL NSL NSL NSL Mercury na BDL BRL 0.356 BRL BRL BRL BRL BRL BRL na 300 30 30 300 Nickel na 216 59.2 280.0 448 31.3 62.3 207 123 33.2 na NSL 700 700 7,000 Lead 799 356 15,400 390 401 98.9 585 877 938 132 na NSL 300 300 3,000 Antimony na BDL BRL 89.2 BRL 6.09 BRL BRL 10.0 BRL na NSL 30 30 300 Selenium na BDL BRL BRL BRL BRL BRL BRL BRL BRL na NSL 800 800 8,000 Thallium na BDL BRL BRL BRL BRL BRL BRL BRL BRL na NSL 80 80 800 Zinc na 303 450 236 237 54.5 62.8 90.1 155 50.9 na NSL 5,000 5,000 10,000 Barium na 77.9 na na na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na na na na na 5 TCLP Cr na 0.07 na na 0.0373 na na 0.0495 na na na 5 TCLP Pb na 2.67 167 BRL na na na na na na 0.0389 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-2 IRA Plan (NEE 6/2006) -Table 1-SA-2 Confirmatory Soil Summary: SA-2 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-2 Excav Table 4-3 Table 1-SA-3 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-9b 1.5'-2' 11/15/99 TP-9b 4' 11/15/99 SA-3-N 3-5' 11/10/04 SA-3-N2 3-5' 11/16/04 SA-3-N3 3-5' 11/23/04 SA-3-E 3-5' 11/10/04 SA-3-S 3-5' 11/10/04 SA-3-W 3-5' 11/10/04 SA-3-W2 3-5' 11/16/04 SA-3-W3 3-5' 11/23/04 SA-3-Base 5.5' 11/10/04 TP-9b 6'-7' 11/15/99 Stabilized "Stockpile" 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/03 Excavated 11/10/04 Excavated 11/16/04 Excavated 11/23/04 Excavated 11/16/04 Excavated 11/23/04 see note #9 below Total Metals (mg/kg) Silver na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 200 200 2,000 Arsenic na na 34.2 BRL BRL 6.37 16.4 34.0 BRL BRL 5.78 na na 40 20 20 200 Beryllium na na BRL BRL BRL BRL 1.86 BRL BRL 0.697 BRL na na NSL 200 200 2,000 Cadmium na na 7.12 2.92 BRL 0.93 2.92 3.4 2.6 0.675 1.69 na na 60 30 30 800 Chromium 3350 3810 24,900 9,650 1,130 3,090 4,510 12,100 8,720 430 2,320 38.4 na 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na na na na na na na na na na na 200 200 200 2,000 Copper na na 290 294 211 52.7 135 185 188 95.1 110 na na NSL NSL NSL NSL Mercury na na BRL 0.40 0.31 BRL 0.285 BRL BRL 0.225 0.987 na na 300 30 30 300 Nickel na na 292 146 41.1 54.5 125 198.0 167.0 28.4 78.9 na na NSL 700 700 7,000 Lead 346 719 256 914 119 355 359 1,350 675 1,100 277 35 na NSL 300 300 3,000 Antimony na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 30 30 300 Selenium na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 800 800 8,000 Thallium na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 80 80 800 Zinc na na 103 BRL 113 77.4 583 193 BRL 82.4 197.0 na na NSL 5,000 5,000 10,000 Barium na na na na na na na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na na na na na na na 5 TCLP Cr na 0.120 0.106 na na na na 0.0382 na na na na na 5 TCLP Pb na 11.7 0.0146 na na 2.02 0.0530 0.0862 na na 0.0490 na 0.0389 5 Notes: 1. Results in red (bold) exceed listed standard. Note #9. Shows the decrease in concentration with depth at this location. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-3 IRA Plan (NEE6/2006) -Table 1-SA-3 Confirmatory Soil Summary: SA-3 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-3 Excav `` 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-1 4'-5' 9/29/99 NEE-3 2-3' 7/23/03 SA-4-N 2-3' 11/10/04 SA-4-E 2-3' 11/10/04 SA-4-S 2-3' 11/10/04 SA-4-W 2-3' 11/10/04 SA-4-Base 4.5' 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/04 Excavated 11/10/04 Total Metals (mg/kg) Silver na BDL BRL BRL BRL BRL BRL NSL 200 200 2,000 Arsenic na BDL 7.44 25.4 16.5 BRL 19.9 40 20 20 200 Beryllium na BDL BRL BRL 0.449 0.45 0.60 NSL 200 200 2,000 Cadmium na BDL 1.45 1.22 BRL 1.11 1.32 60 30 30 800 Chromium 2,820 57,000 3,250 3,070 171 848 1,590 1000* 5000 5,000 10,000 Chromium, Hexavalent na BDL na na na na na 200 200 200 2,000 Copper na 1,540 70.6 106 31.8 35.6 57.7 NSL NSL NSL NSL Mercury na BDL 0.228 BRL BRL BRL BRL 300 30 30 300 Nickel na 5,206 58.6 52.7 11 43.8 45.4 NSL 700 700 7,000 Lead 936 142 88.7 192 45.6 45.6 216 NSL 300 300 3,000 Antimony na BDL BRL BRL BRL BRL BRL NSL NSL 30 30 300 Selenium na BDL BRL BRL BRL BRL BRL NSL 800 800 8,000 Thallium na BDL BRL BRL BRL BRL BRL NSL 80 80 800 Zinc na BDL 57.9 52.7 BRL 64.3 71.3 NSL 5,000 5,000 10,000 Barium na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na 5 TCLP Cr na BDL na na na na na 5 TCLP Pb na 0.21 na na na na na 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-4 IRA Plan (NEE 6/2006) -Table 1-SA-4 Confirmatory Soil Summary: SA-4 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-4 Excav Table 4-5 Table 1-SA-5 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-7 3' 11/15/99 NEE-2 2-2.5' 7/23/03 SA-5-N 2-3' 11/10/04 SA-5-N2 2-3' 11/16/04 SA-5-NE3 2-3' 11/23/04 SA-5-E 2-3' 11/10/04 SA-5-E2 2-3' 11/16/04 SA-5-E3 2-3' 11/23/04 SA-5-S 2-3' 11/10/04 SA-5-S2 2-3' 11/16/04 SA-5-W 2-3' 11/10/04 SA-5-W2 2-3' 11/16/04 SA-5-Base 3.5' 11/10/04 SA-5-Base2 4' 11/16/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/03 Excavated 11/10/04 Excavated 11/16/04 Excavated 11/23/04 Excavated 11/16/04 Excavated 11/23/04 Excavated 11/16/04 Excavated 11/16/04 Excavated 11/16/04 Total Metals (mg/kg) Silver na BDL BRL 16.2 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 200 200 2,000 Arsenic na 24.1 21.4 BRL BRL 66.6 BRL 6.9 26.4 BRL 5.85 BRL 37.2 BRL 40 20 20 200 Beryllium na BDL BRL BRL BRL 0.58 BRL 0.6 BRL BRL 0.44 BRL BRL BRL NSL 200 200 2,000 Cadmium na BDL 3.19 3.27 BRL 1.66 3.38 BRL 1.94 1.66 1.23 0.73 3.28 0.73 60 30 30 800 Chromium 2740 11,800 10,300 9,420 3,500 3,980 8,900 24.6 6,390 4,860 856 447 9,740 447 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na na na na na na na na na na na na 200 200 200 2,000 Copper na 212 322 400 67.7 78 179 22.8 128 BRL 43.8 BRL 191 BRL NSL NSL NSL NSL Mercury na 1.07 0.601 1.25 BRL BRL 4.67 BRL BRL BRL BRL BRL 7.0 BRL 300 30 30 300 Nickel na 285 248 317 97.7 61.7 171.0 13.2 116 82.5 34.5 18.5 199 18.5 NSL 700 700 7,000 Lead 1,350 1,990 433 301 151 103 1,490 149 1,250 254 380 32.7 692 32.7 NSL 300 300 3,000 Antimony na BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 30 30 300 Selenium na BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 800 800 8,000 Thallium na BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 80 80 800 Zinc na 288 190 BRL 102 131 BRL 144 69.6 BRL 50.5 BRL 159 BRL NSL 5,000 5,000 10,000 Barium na na na na na na na na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na na na na na na na na 5 TCLP Cr na BDL na na na na na na na na na na na na 5 TCLP Pb na 2.92 na na na na na na na na na na na na 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-5 IRA Plan (6/2006) -Table 1-SA-5 Confirmatory Soil Summary: SA-5 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-2 AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-5 Excav Table 4-6 Table 4-6 Laboratory Results -PP13 Metals in Soil Former Cutlery Building Northampton, MA Regulatory Standards Sample I.D.: Sample Depth: CB-1 0-3" CB-2 0-3" CB-3 0-3" CB-4 0-3" CB-5-SED 0-3" CB-6 0-3" CB-7 0-3" CB-8 0-3" CB-9 0-3" CB-10 0-3" CB-11-SED 0-3" CB-12 0-3" CB-13 0-3" CB-14-SED 0-3" CB-15 0-3" Method 1 Standard Sampling Date: 5/23/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Excavated Excavated Excavated Metals (mg/Kg) lt. g br dk g, bl dk g t,br dk g, br dk br, g r, br o, br br t,br dk g, mr dk br br lt g, br, dk g Silver BDL BRL BRL 3.01 BRL BRL BRL BRL BRL BRL 12.5 6.04 BRL BRL BRL NBL 100 100 100 100 NSL 2,000 Arsenic <31.7 10.5 BRL BRL BRL BRL BRL 32.5 BRL 32.7 BRL 10.9 BRL BRL BRL 9.79 20 20 20 20 40 200 Beryllium <4.22 1.23 BRL BRL BRL BRL BRL 0.761 0.55 0.757 BRL BRL BRL 0.48 BRL NBL 100 100 100 100 NSL 2000 Cadmium BDL 1.34 BRL 0.884 BRL 1.06 BRL BRL BRL 1.11 BRL 1.2 BRL BRL BRL 0.99 2 2 2 2 60 300 Chromium (III) 25000 1910 1830 4110 89.5 4090 940 345 75.7 1110 1130 4690 78.1 76.8 5760 43.4 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 269 298 112 241 142 176 58.7 452 43.1 213 315 333 59.4 83.9 106 31.6 1,000 NSL NSL NSL NSL NSL Mercury BDL 1.6 0.483 0.439 0.368 0.66 0.408 0.24 BRL 1.68 6.22 0.889 BRL BRL 21.9 0.18 20 20 20 20 300 300 Nickel 669 188 111 165 96.3 188 53.5 565 19.8 225 545 163 17.1 45.6 142 22.7 20 20 20 20 NSL 7,000 Lead 220 216 505 753 128 1040 238 506 664 1260 329 4480 252 81.3 246 35.8 300 300 300 300 NSL 3,000 Antimony <31.7 BRL BRL BRL BRL BRL BRL BRL BRL 143 BRL 471 BRL BRL BRL NBL 20 20 20 20 NSL 300 Selenium BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 400 400 400 400 NSL 8,000 Thallium <31.7 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 8 8 8 8 NSL 800 Zinc 79.4 773 333 418 129 597 58 103 65 447 281 657 109 101 411 121 2500 2500 2500 2500 NSL 10,000 Excavated Excavated Excavated Notes: Color Codes: 1. Results in red (bold) exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark Regulatory Standards Sample I.D.: Sample Depth: CB-16-SED 0-3" CB-17 0-3" CB-18 0-3" CB-19 0-3" CB-CS-1 0-3" CB-CS-2 0-3" CB-CS-3 0-3" CB-CS-4 0-3" CB-CS-5 0-3" DUP (CB-CS-5) CB-CS-6 0-3" CB-CS-7 0-3" CB-CS-8 0-3" Method 1 Standard Sampling Date: 6/9/06 6/9/06 6/9/06 6/9/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) Silver BRL 2.69 2.59 BRL 16.1 4.07 5.32 1.76 1.43 BRL BRL 2.76 1.46 NBL 100 100 100 100 NSL 2,000 Arsenic 2.91 18.3 16.6 9.16 BRL BRL BRL BRL BRL BRL BRL BRL 76.6 9.79 20 20 20 20 40 200 Beryllium 0.437 0.569 0.343 0.449 BRL 0.244 0.254 0.215 0.405 BRL BRL 0.514 0.779 NBL 100 100 100 100 NSL 2000 Cadmium 0.313 0.847 1.37 0.599 2.49 1.67 1.44 0.806 0.922 1.65 BRL 0.927 0.814 0.99 2 2 2 2 60 300 Chromium (III) 34 2720 2590 274 2230 3060 3760 2740 107 3490 4560 1760 877 43.4 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 162 138 124 45 1310 163 133 66.9 200 117 79.5 197 513 31.6 1,000 NSL NSL NSL NSL NSL Mercury 0.304 0.198 0.627 0.193 0.719 0.434 0.221 0.284 0.583 0.286 0.191 0.242 0.203 0.18 20 20 20 20 300 300 Nickel 185 115 89 38 2650 222 192 85.9 91.5 184 136 282 736 22.7 20 20 20 20 NSL 7,000 Lead 54.3 610 567 286 1560 1020 1190 915 176 312 475 429 432 35.8 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL 2.14 265 17.2 20.6 10.9 1.74 21 20.3 18.2 9.41 NBL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL 2.27 2.39 1.57 1.89 BRL BRL 2.42 3.49 NBL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 8 8 8 8 NSL 800 Zinc 79.8 105 464 66.4 574 506 781 351 173 315 247 162 117 121 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold) exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark IRA Completion (NEE 01/2008) -Table 1 UCLs (mg/kg) UCLs (mg/kg) Imminent Hazard TEC9 Benchmarks RC S-1 Imminent Hazard TEC9 Benchmarks Confirmatory Soil Samples RC S-1 New England Environmental, Inc. PP13-CB 02-2053_Lab Table_Phase IV_soil-updated09 Table 5 Table 2 Laboratory Results -PP13 Metals in Soil Former Cutlery Raceway Northampton, MA Regulatory Standards Sample I.D.: Sample Depth: LE-1 0-3" LE-2 0-3" LE-3 0-3" LE-4 0-3" LE-5 0-3" LE-6 0-3" LE-7 0-3" LE-8 0-3" LE-9 0-3" LE-10 0-3" LE-11 0-3" LE-12 0-3" LE-13 0-3" LE-14 0-3" LE-15 0-3" LE-16 0-3" LE-17 0-3" LE-18 0-3" LE-19 0-3" LE-20 0-3" LE-21 0-3" LE-22 0-3" LE-23 0-3" Method 1 Standard Sampling Date: 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) br,g,c dk.br,o,c lt.g,r/br lt.br,t "clean" y,g,br br,o dk.g t,br, grn hue p/r br br, grn hue c, ash, not ex lt.g r/br,y g dk.g, br t br, not ex br,c,ash br dk.br,c g g, sparkles Silver BRL 3.45 BRL BRL BRL 14.7 14.9 BRL BRL 2.47 6.75 BRL BRL BRL 4.21 BRL BRL 6.09 3.43 BRL BRL BRL BRL 100 100 100 100 NSL 2,000 Arsenic BRL 17.7 BRL 7.53 23 39.1 33.2 25.6 107 14.5 29.6 15.3 17.8 7.42 23.8 BRL BRL 21.4 17.8 13.9 13.1 6.44 BRL 20 20 20 20 40 200 Beryllium 0.522 BRL 0.471 0.499 0.645 BRL 0.682 0.674 2.05 0.577 0.668 1.06 0.453 0.484 0.603 BRL 0.598 BRL 0.912 0.541 0.795 0.528 0.463 100 100 100 100 NSL 2000 Cadmium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 2 2 2 2 60 300 Chromium (III) 1080 101 148 785 280 18.1 520 376 22.7 528 519 547 2070 30.3 723 9470 43 59 1270 1050 3690 1300 8050 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 117 11100 28.6 310 4610 431 21400 1150 141 19100 6410 1820 767 60.6 11800 359 43.6 12100 4970 3100 1670 859 2800 1,000 NSL NSL NSL NSL NSL Mercury BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 0.315 BRL BRL BRL BRL BRL 0.51 BRL BRL 20 20 20 20 300 300 Nickel 148 22800 97.5 566 9080 437 46300 1830 1040 35700 13000 3740 1600 812 23700 677 346 26500 7910 4950 2910 1650 5250 20 20 20 20 NSL 7,000 Lead 118 156 63.1 93.5 219 252 271 219 140 436 394 136 201 75.6 278 842 69.3 227 324 241 133 161 195 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 36.9 125 27.9 53.4 97.8 117 144 80.7 29.4 186 119 20 66.7 43.4 71.8 44.6 46.5 75.7 41.2 126 50.7 57.1 300 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold)exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark Sediment Samples: sand collected on the Beach Regulatory Standards Sample I.D.: Sample Depth: LE-25 0-3" LE-26 0-3" LE-27 0-3" LE-28 0-3" LE-29 0-3" LE-30 0-3" LE-31 0-3" LE-32 0-3" LE-33 0-3" LE-34 0-3" LE-35 0-3" LE-36 0-3" LE-37 0-3" LE-38 0-3" LE-39 0-3" LE-40 0-3" LE-24 0-3" B-1 0-3" B-2 0-3" B-3 0-3" B-4 0-3" Method 1 Standard Sampling Date: 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 4/28/05 5/6/05 5/6/05 5/6/05 5/6/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) dk.br,c r/o p/r dk.br, bl, g dk.g, bl t, br lt.g, sparkles bl, grn lt.br, t mr dk.br,g dk.br,bl grn,t bl br dk.br t,br lt.g, w lt.br,g,grn hue lt.br,g,grn hue t,grn Silver BRL BRL BRL 4.16 BRL BRL BRL BRL 3.77 5.14 7.98 11.4 BRL 11.1 BRL 8.32 BRL BRL BRL BRL BRL NBL 100 100 100 100 NSL 2,000 Arsenic 14.2 28.2 213 39.2 20.2 5.85 BRL 18.2 21.8 40.3 56.3 104 BRL 667 BRL 19.6 BRL BRL BRL BRL BRL 9.79 20 20 20 20 40 200 Beryllium 0.637 0.551 3.56 0.861 0.53 0.571 BRL BRL 0.557 BRL BRL BRL 0.434 1.17 0.487 BRL BRL BRL BRL 0.511 BRL NBL 100 100 100 100 NSL 2000 Cadmium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 0.99 2 2 2 2 60 300 Chromium (III) 759 36.1 99.8 166 1880 65.9 19.6 9340 45 54.1 2310 1450 32.2 1240 18.4 349 52.5 16.6 21.2 39.5 38.5 43.4 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 911 287 1490 2360 34000 160 32.4 1730 3500 5260 18800 31100 27.1 300 8.93 4290 87.7 65 98.7 90.8 159 31.6 1,000 NSL NSL NSL NSL NSL Mercury 0.22 0.23 BRL BRL BRL BRL BRL BRL BRL 0.243 0.665 0.227 BRL 1.23 BRL BRL BRL BRL BRL BRL BRL 0.18 20 20 20 20 300 300 Nickel 1460 1320 2580 4280 86100 452 74.4 4140 6500 9920 46100 75900 107 149 142 9100 56.6 89 162 21.6 317 22.7 20 20 20 20 NSL 7,000 Lead 164 264 452 537 130 80.6 25.9 155 128 157 147 184 24.5 1080 12.2 374 24.7 16.4 15 30.7 38.6 35.8 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL 13.3 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 771 BRL BRL BRL BRL BRL BRL BRL NBL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL 16.6 BRL BRL 21.4 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 8 8 8 8 NSL 800 Zinc 79 90.4 127 89.5 80.8 30.8 31.8 274 100 143 288 121 21.2 164 25.3 97.7 86.1 43.2 98.6 124 30.9 121 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold)exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark IRA PLAN (NEE 06/2006) -Table 2 UCLs (mg/kg) UCLs (mg/kg) Imminent Hazard RC S-1 Imminent Hazard TEC9 Benchmar ks RC S-1 New England Environmental, Inc. PP13-Levee 02-2053_Lab Table_Phase IV_soil-updated09 Table 6-1 AOC-1 Maximum and Minimum Concentrations of Detected Contaminants Former Cutlery Raceway, Northampton MA RTN #1-13320 Media Type: UCL in Soil Method 1 Standard UCL in GW Maximum Minimum Maximum Minimum S-1/GW-2 S-1/GW-3 Maximum Minimum GW-3 Units: mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg ug/L ug/L ug/L ug/L EPH Aliphatics & Aromatics C9-C18 Aliphatics BDL BDL 190 BDL 1,000 1,000 20,000 BDL BDL 50,000 100,000 C19-C36 Aliphatics BDL BDL 4,300 BDL 3,000 3,000 20,000 BDL BDL 50,000 100,000 C11 -C22 Aromatics BDL BDL 682 BDL 1,000 1,000 10,000 BDL BDL 5,000 100,000 EPH Target Analytes Napthalene BDL BDL BDL BDL 40 500 10,000 BDL BDL 20,000 100,000 2-Methylnapthalene BDL BDL 0.490 BDL 80 300 5,000 BDL BDL 20,000 100,000 Acenaphthylene BDL BDL BDL BDL 600 10 10,000 BDL BDL 40 100,000 Acenaphthene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 6,000 60,000 Fluorene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 40 400 Phenanthrene BDL BDL 2.000 BDL 500 500 10,000 BDL BDL 10,000 100,000 Anthracene BDL BDL 0.400 BDL 1,000 1,000 10,000 BDL BDL 30 600 Fluoranthrene BDL BDL 2.300 BDL 1,000 1,000 10,000 BDL BDL 200 2,000 Pyrene BDL BDL 1.900 BDL 1,000 1,000 10,000 BDL BDL 20 800 Benzo (a) anthracene BDL BDL 0.820 BDL 7 7 3,000 BDL BDL 1,000 10,000 Chrysene BDL BDL 0.824 BDL 70 70 10,000 BDL BDL 70 700 Benzo (b) fluoranthene BDL BDL 0.620 BDL 7 7 3,000 BDL BDL 400 4,000 Benzo (k) fluoranthene BDL BDL 0.480 BDL 70 70 10,000 BDL BDL 100 1,000 Benzo (a) pyrene BDL BDL 0.300 BDL 2 2 300 BDL BDL 500 5,000 Indeno (1,2,3,-cd) pyrene BDL BDL 0.600 BDL 7 7 3,000 BDL BDL 100 1,000 Dibenzo (a,h) anthracene BDL BDL BDL BDL 0.7 0.7 300 BDL BDL 40 400 Benzo (g,h,I,) perylene BDL BDL 0.300 BDL 1,000 1,000 10,000 BDL BDL 20 500 VPH Aliphatics & Aromatics C5-C8 Aliphatics na na BDL BDL 100 100 5,000 na na 50,000 100,000 C9-C12 Aliphatics na na 3.7 BDL 1,000 1,000 20,000 na na 50,000 100,000 C9 -C10 Aromatics na na 8.0 BDL 100 100 5,000 na na 50,000 100,000 VPH Target Analytes Napthalene na na 0.660 BDL 40 500 10,000 na na 20,000 100,000 Polychlorinated Biphenyls (mg/Kg) PCBs (total) na na BDL BDL 2 2 100 na na 10 100 Total Metals Antimony 6.98 BDL 471 BDL 20 20 300 BDL BDL 8,000 80,000 Arsenic 16.00 BDL 76.6 BDL 20 20 200 BDL BDL 900 9,000 Beryllium 0.26 BDL 1.86 BDL 100 100 2000 BDL BDL 200 2,000 Cadmium 6.02 BDL 25 BDL 2 2 300 BDL BDL 4 50 Chromium 71.70 5.26 5,760 24.60 1000 1000 10000 BDL BDL 600 6,000 Chromium, Hexavalent na na BDL BDL 30 30 2000 na na 300 3,000 Copper 122 29 1,310 22.8 NSL NSL NSL BDL BDL NSL NSL Lead 66.50 8.52 1,100 37.20 300 300 3,000 BDL BDL 10 150 Nickel 88 5.67 2,650 11.0 20 20 7,000 20.9 BDL 200 2,000 Selenium 9.43 BDL 3.49 BDL 400 400 8,000 BDL BDL 100 1000 Silver BDL BDL 50.00 BDL 100 100 2,000 BDL BDL 7 1000 Thallium BDL BDL BDL BDL 8 8 800 BDL BDL 3000 30,000 Zinc 191 40 5,020 50.9 2500 2500 10,000 3.8 BDL 900 50,000 Mercury 0.47 BDL 21.9 BDL 20 20 300 BDL BDL 20 200 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit 5. na = Not Analyzed for this parameter. 6. Results from soil sample IHS-13 not included because this material has been removed from the Site. 7. Red (bold & shaded orange) = Exceeds UCL Standard Sediment Soil Method 1 Standard Groundwater Table 6-2 AOC-2 & AOC-3 Maximum and Minimum Concentrations of Detected Contaminants Former Cutlery Raceway, Northampton MA RTN #1-13320 Media Type: UCL in Soil Method 1 Standard UCL in GW Maximum Minimum Maximum Minimum S-1/GW-2 S-1/GW-3 Maximum Minimum GW-3 Units: mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg ug/L ug/L ug/L ug/L EPH Aliphatics & Aromatics C9-C18 Aliphatics BDL BDL 500 BDL 1,000 1,000 20,000 BDL BDL 50,000 100,000 C19-C36 Aliphatics BDL BDL 8,300 BDL 3,000 3,000 20,000 BDL BDL 50,000 100,000 C11 -C22 Aromatics BDL BDL 1,200 BDL 1,000 1,000 10,000 BDL BDL 5,000 100,000 EPH Target Analytes Napthalene BDL BDL 0.66 BDL 40 500 10,000 BDL BDL 20,000 100,000 2-Methylnapthalene BDL BDL 0.490 BDL 80 300 5,000 BDL BDL 20,000 100,000 Acenaphthylene BDL BDL BDL BDL 600 10 10,000 BDL BDL 40 100,000 Acenaphthene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 6,000 60,000 Fluorene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 40 400 Phenanthrene 1.46 BDL 2 BDL 500 500 10,000 BDL BDL 10,000 100,000 Anthracene 0.48 BDL 0.4 BDL 1,000 1,000 10,000 BDL BDL 30 600 Fluoranthrene 1.58 BDL 2.3 BDL 1,000 1,000 10,000 BDL BDL 200 2,000 Pyrene 1.14 BDL 1.9 BDL 1,000 1,000 10,000 BDL BDL 20 800 Benzo (a) anthracene 0.289 BDL 0.82 BDL 7 7 3,000 BDL BDL 1,000 10,000 Chrysene 0.378 BDL 0.824 BDL 70 70 10,000 BDL BDL 70 700 Benzo (b) fluoranthene BDL BDL 0.62 BDL 7 7 3,000 BDL BDL 400 4,000 Benzo (k) fluoranthene 0.232 BDL 0.48 BDL 70 70 10,000 BDL BDL 100 1,000 Benzo (a) pyrene 0.232 BDL 0.3 BDL 2 2 300 BDL BDL 500 5,000 Indeno (1,2,3,-cd) pyrene BDL BDL 0.6 BDL 7 7 3,000 BDL BDL 100 1,000 Dibenzo (a,h) anthracene BDL BDL BDL BDL 0.7 0.7 300 BDL BDL 40 400 Benzo (g,h,I,) perylene BDL BDL 0.3 BDL 1,000 1,000 10,000 BDL BDL 20 500 VPH Aliphatics & Aromatics C5-C8 Aliphatics na na BDL BDL 100 100 5,000 na na 50,000 100,000 C9-C12 Aliphatics na na 3.7 BDL 1,000 1,000 20,000 na na 50,000 100,000 C9 -C10 Aromatics na na 8.0 BDL 100 100 5,000 na na 50,000 100,000 VPH Target Analytes Napthalene na na 0.660 BDL 40 500 10,000 na na 20,000 100,000 Polychlorinated Biphenyls (mg/Kg) PCBs (total) na na 250.2 BDL 2 2 100 na na 10 100 Total Metals Antimony 2.40 BDL 3,100 BDL 20 20 300 BDL BDL 8,000 80,000 Arsenic 16 BDL 327 BDL 20 20 200 BDL BDL 900 9,000 Beryllium 0.28 BDL 2.64 BDL 100 100 2000 BDL BDL 200 2,000 Cadmium 6.02 BDL 20.3 BDL 2 2 300 BDL BDL 4 50 Chromium 71.70 3.51 57,000 5.18 1000 1000 10000 43.1 BDL 600 6,000 Chromium, Hexavalent na na BDL BDL 30 30 2000 na na 300 3,000 Copper 90.0 22.6 41,900 5.3 NSL NSL NSL 11.7 BDL NSL NSL Lead 66.5 8.32 114,000 7.2 300 300 3,000 15.8 BDL 10 150 Nickel 88 3.64 111,000 13.1 20 20 7,000 735 BDL 200 2,000 Selenium 9.43 BDL BDL BDL 400 400 8,000 BDL BDL 100 1000 Silver BDL BDL 35.7 BDL 100 100 2,000 BDL BDL 7 1000 Thallium BDL BDL 19.3 BDL 8 8 800 BDL BDL 3000 30,000 Zinc 144.0 35.5 2,150 14.5 2500 2500 10,000 493 BDL 900 50,000 Mercury 0.47 BDL 3.08 BDL 20 20 300 BDL BDL 20 200 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit 5. na = Not Analyzed for this parameter. 6. Results from soil sample IHS-13 not included because this material has been removed from the Site. 7. Red (bold & shaded orange) = Exceeds UCL Standard Sediment Soil Method 1 Standard Groundwater APPENDIX A Terms & Conditions Mr. Alan Verson Phase IV and NOI Proposal March 10, 2004 Cutlery Raceway Page 10 of 11 Northampton, MA Attachment 1: TERMS & CONDITIONS These Terms and Conditions and the Proposal dated March 10, 2004 prepared and submitted by New England Environmental, Inc. (NEE) to Cutlery Building Associates (Client), constitute the “Agreement” between NEE and the Client. 1. Services and Reliance: The services rendered in our proposal will be performed for the sole use of the Client, client’s legal counsel(s), and client’s regulatory agencies for this environmental site assessment/remediation project. Any reuse or reliance on this work by third parties is prohibited and shall only be done with the prior written consent of NEE. 2. Standard of Care: Services performed by NEE under this agreement will be conducted in a manner consistent with that level of care and skill ordinarily exercised by members of the profession currently practicing in the same locality under similar conditions. No other representation expresses or implied, and no warrantee or guaranty is included or intended in this Agreement, or in any report, opinion, document, or otherwise. NEE is not responsible for the accuracy and veracity of information provided to us by outside parties with respect to the project Site and adjacent properties. 3. Termination: Client may terminate this Agreement without penalty upon seven (7) calendar days written notice to NEE, provided that Client shall be obligated pursuant to the terms hereof for all services performed and obligations incurred by NEE on Client’s behalf as of the effective date of termination. Such services shall include those rendered up to the date of termination, as well as those reasonable costs associated with the termination itself, such as demobilization. Prior to the final execution of this proposal, NEE reserves the right to take those measures necessary to evaluate the credit history of the client and subsequently, cancel or modify this proposal as deemed necessary. NEE reserves the right to stop work on all projects for a client in the event that one or more of the client’s accounts is in arrears in excess of 30 days. If NEE has stopped work on a project for this reason, we will not be held responsible for consequences, financial or otherwise associated with project delays or final completion thereof. NEE may terminate this Agreement upon seven (7) calendar days written notice to Client of non-payment of invoices within the thirty (30) day period described in article 6 of this Agreement. In the event of termination for non-payment of invoices Client will be responsible for all reasonable termination costs incurred by NEE. 4. Payment: Invoices for services will be submitted monthly. By the signing of this proposal, it is agreed and understood that payment will be made upon receipt of the invoice. It is further understood that any balances on this account remaining unpaid for a period of 30 days will incur a service charge of 1-1/2% per month (expressed as an annual percentage rate, the charge is 18%). It is further agreed that if said account is turned over for collection, reasonable attorney’s fees and costs of collection shall be added to the unpaid balances, whether or not legal action is instituted. The parties to this contract specifically agree that NEE has no obligation to release drawings or other documents until the final bill for services associated with the production of those documents has been paid. 5. Assignment: Neither party to this Agreement shall assign its duties and obligations hereunder without prior written consent of the other party, except that NEE may use the services of persons and entities not in its employ, when it is necessary or NEE deems appropriate. Such persons may include, but are not necessarily limited to: surveyors, specialty consultants or engineers, drilling contractors, and testing laboratories. 6. Governing Law; Severability: This Agreement shall be governed and enforceable in accordance with the laws of Massachusetts. Any element of this Agreement later held to violate a law or regulation shall be deemed void, and all remaining provisions shall continue in force. 7. Regulatory Compliance: Based upon the work under this Agreement, NEE may present opinions with respect to the environmental conditions of the Site. The actual determination of compliance of present or former operators of the Site with federal or state regulations can only be made by the appropriate regulatory agencies. 8. Right of Entry: Client shall provide to NEE, and its subcontractors, access to any Site necessary to perform the Scope of Work included hereunder. Client understands that certain tasks, such as field explorations, may cause damage. NEE shall be responsible for such damages to the extent caused by our negligent acts. 9. Underground Structures: If subsurface explorations are performed, NEE will contact the appropriate government or private agency which locates subsurface utilities. Client will provide NEE with all plans and other information in Client’s possession or control concerning Site Site underground structures. On Sites not owned by Client, NEE will request utility locations and other plans from the Site owner or other person(s) designated by the Client. Client/owner agrees to accept the Mr. Alan Verson Phase IV and NOI Proposal March 10, 2004 Cutlery Raceway Page 11 of 11 Northampton, MA risk of damage and loss associated with repair or restoration of any improvements not located on plans and/or identified in information provided to NEE. 10. Chemical Conditions: Chemical analyses may be performed for certain parameters during this assessment. However, additional chemical constituents not searched for during the study may be present in soil and/or groundwater at the Site. Chemical conditions reported by NEE reflect conditions only at the locations tested at the time of testing and within the limitations of the methods used. Such conditions can vary rapidly from area to area and from time to time. 11. Samples & Contaminated Media: Contaminated media generated as part of assessment or remedial activities are the sole responsibility of the Client. NEE can assist with the proper transportation and disposal of contaminated materials, at the Clients expense. NEE will pay for the transportation and disposal of contaminated materials only if expressly stated in our Scope of Services. Unless expressly requested in writing by the Client, NEE will not retain samples from the Site for longterm storage. Samples for laboratory analyses will be retained and stored for the interim period during transport to the laboratory. 12. Field Observation Services: NEE’s services will not include the direction or supervision of a contractor or subcontractor other than those contracted directly by NEE. Our services do not include responsibility for Health & Safety practices performed by others on the Site. 13. Ownership of Documents: All reports, boring logs, field data, field notes, photographs, laboratory test data, calculations, estimates, and other documents prepared by NEE as instruments of service shall remain the sole property of NEE. NEE shall retain such records for a minimum of three (3) years. At Client’s request, NEE will provide reasonable access or copies of such documents. Reproduction costs will be at the the Client’s expense. 14. Disclosure of Information: Client will inform NEE of all information in Client’s possession or control relevant to the performance of NEE’s services. This information includes, but is not limited to, all prior Site reports, Site plans or maps, waste disposal manifests, permits, and analytical data. Client will indemnify, defend, and hold NEE harmless of and from all loss or damage resulting from any claim that arises, in whole or in part, as a result of information Client fails to disclose to NEE. 15. Licensed Site Professional Services: In conducting certain environmental services, NEE employees may act in their capacity as Registered Licensed Site Professionals (LSPs), in accordance with the Massachusetts Contingency Plan (MCP). Opinions rendered by a LSP on this project are the product of Response Action Performance Standards (RAPS), the level of diligence reasonably necessary to obtain the quantity and quality of information adequate to assess a site and evaluate remedial action alternatives, to design and implement specific remedial actions to achieve a level of No Significant Risk for any foreseeable period of time, and where feasible, to reduce to the extent possible the level of oil and /or hazardous materials in the environment to background levels. Client acknowledges that in performing these services NEE, through its LSPs, is bound by state law to meet the requirements of the MCP. Client further acknowledges that NEE’s duty to comply with state law may in some instances conflict with Client interests; in these cases NEE will seek to comply with the law. LSP Opinions are not a guarantee of acceptance by a regulatory authority. The Massachusetts DEP may conduct a random or targeted compliance audit of response actions under the MCP at any disposal site, and in addition intends to audit all response actions which include Activity and Use Limitations (AULs). Client acknowledges that Client is responsible for all costs arising out of NEE’s actions to comply with DEP requests during an Audit, including NEE’s fees for time and materials used in preparing responses. These costs are not included in NEE’s current budget for this proposal, unless specifically mentioned. 16. Limitation of Professional Liability: The owner/client agrees to limit the liability of New England Environmental, Inc., to the owner/client and to all construction contractors and subcontractors on the project arising from New England Environmental, Inc.’s negligent acts, errors and omissions such that the total aggregate liability of New England Environmental, Inc. will not exceed the contract amount or $25,000, which ever is greater. APPENDIX B Wetland Certificates of Compliance Class A3 RAO Statement Transmittal Form (BWSC-104) AUL Transmittal Form (BWSC-113) Class C1 RAO Statement Transmittal Form (BWSC-104) AUL Transmittal Form (BWSC-113) AUL Transmittal Form (BWSC-113) APPENDIX C Summary of Previous Submittals Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 1 Northampton, Massachusetts Appendix C -Previously Published Investigations Environmental Site Evaluation, by GZA, 1989 The report documented lead and chromium contamination on the northerly portion of the Site (Lot 77, 360 Riverside Drive). GZA’s evaluation indicated that various debris and metal scraps were buried within the former mill raceway that ran north/south through the lot. Test pits performed to define the extent of the debris, indicated that the material was up to 7 feet thick with a width near the surface approximating the width of the flat portion of the land. The debris was determined to extend roughly 400 feet north into Lot 77. Laboratory analysis of the material sampled from test pit TP-1 indicated elevated levels of total lead and chromium and that the Toxicity Characteristic Leaching Procedure (TCLP) level of lead was 62 mg/L, which exceeded the 1989 (and current) federal standard of 5 mg/L used to identify a characteristically hazardous waste. GZA’s TP-1 is located within 20 feet of the former firehouse’s northern property boundary. Initial Site Investigation, by Almer Huntley, Jr. & Associates, 1996 In their investigations of the building, Huntley did not turn up any evidence of OHM release. No Volatile Organic Compounds or Petroleum Hydrocarbons were detected in the four samples collected. RCRA 8 metals were detected at concentrations below the reportable concentrations (RCs) and were determined by Huntley to not present a significant risk. The borings from which these samples were taken did not intercept the former raceway, and provide evidence that the waste debris does not extend to these locations. Level 1 ESA & Limited Subsurface Investigation Report, by C&C, October 1999 This report included the excavation of three test-pits to evaluate the potential presence of buried debris and lead and chromium contamination. Both debris and metals metals contamination in the soil were confirmed. The EPH laboratory results revealed concentrations that exceeded the RCS-1 standard of 200 mg/Kg. The concentrations of chromium and lead in TP-1 and TP-2 were also above the RCS-1 standards for these metals. Limited Subsurface Investigation, by C&C, February 2000 This report documents eight additional test pits that were conducted to determine the extent of the debris. It was determined that the debris appeared to be located within the confines of the former raceway, and was contaminated with both Extractable Petroleum Hydrocarbons (EPH) and the heavy metals lead (Pb) and chromium (Cr). Lead and chromium were detected in all twelve samples that were collected. It was also determined from this laboratory testing that the in-situ sediments beyond the extent of the debris fill did not contain reportable concentrations (RCs) of lead, chromium, or petroleum compounds. The release of petroleum compounds, lead and chromium to soil was reported to DEP on February 16, 2000. As part of their response, DEP issued a Notice of Responsibility (NOR) to both Mr. Elbaum and Cutlery Building Associates (RTN 1-13320), and requested that an Imminent Hazard Evaluation be conducted to determine if concentrations of lead and chromium in surface soil constituted an Imminent Hazard as defined by the MCP. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 2 Northampton, Massachusetts Imminent Hazard Evaluation, by C&C, October 2000 Eight surficial soil samples were collected from areas identified as being within the former raceway. The waste fill material was found below a four-inch organic layer. No fill material was observed directly on the surface at any of the sampling locations. Laboratory results from all eight samples confirmed the presence of lead and chromium in surficial soil. The DEP collected three sediment samples from the Mill River. On this date, the DEP also collected a surface soil sample from on top of the former raceway levee, approximately 300 feet south of the former dam that once diverted water into the raceway. The surface soil sampled was a mixture of black ash and cinder and a pink-tan fine sand. This material was found to contain arsenic in excess of the Imminent Hazard standards, and was the basis of DEP’s request to conduct a second Imminent Hazard Evaluation. Imminent Hazard Evaluation for Arsenic–IRA Plan & Status Report, by C&C, December 2000 Twelve shallow test pits were dug to 1 foot below ground in the vicinity of DEP-1. It was determined that a layer of pink-tan sand existed that was approximately 4 feet wide and 12 feet long and varied in thickness from 4 inches to less than 1/16th of an inch. Laboratory analysis of four samples taken from these test pits indicated that the pink-tan sand was the source of the Imminent Hazard concentrations of arsenic. All observed pink-tan sand was removed from the levee by shoveling the material into 55-gallon drums. Three drums of material were removed from the area surrounding DEP-1 on November 21, 2000, and on November 22, 2000, three additional drums of soil were removed from a location approximately 40 feet south of DEP-1 that was discovered during the initial removal process. This soil was removed from the Site under a Uniform hazardous Waste Manifest. With this IRA activity complete, the highest known concentrations of arsenic have been removed from the Site. Three shallow test pits located in the driveway of the Cutlery Building, just off the west edge of the northern section of the building, were also excavated. Waste fill was found in all three test pits, therefore indicating that the edge of the former raceway exists parallel to the west edge of the northern section of the building. The top of a stone wall that is visible approximately 20 feet west of the edge of the building is presumed to be the western edge of the raceway at this location. These observations are consistent with the depiction of the raceway on the Sanborn maps. A sample from each of the test pits was submitted for laboratory analysis of RCRA 8 metals, reactivity, cyanide, and polychlorinated biphenyls (PCBs). Concentrations of arsenic above the Imminent Hazard criteria and concentration of total chromium and lead exceeded the Method 1 cleanup standard. Additional driveway gravel was added to the parking as an Institutional Control to bring the depth of the waste fill to a depth greater than 12 inches, thereby relieving the arsenic Imminent Hazard condition in the parking lot. The owner has agreed to maintain the parking lot with adequate cover, until a more permanent solution is reached. Seventeen evenly spaced test holes were dug to a depth of 1 foot with a spade along the top the levee. Samples were collected and found concentrations of arsenic that exceeded Imminent Hazard criteria and elevated concentrations of total chromium. Location IH-L-18 was re-sampled to confirm the elevated chromium concentration and to test for the presence of hexavalent chromium. This result confirmed that hexavalent chromium has not been detected at the Site, and is therefore inferred to not exist. Because additional portions of the levee contain elevated, Imminent Hazard, concentrations of arsenic, a fence has been erected, along with warning signs, Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 3 Northampton, Massachusetts to discourage access to the site. The effort to achieve a final resolution to the Imminent Hazard condition is ongoing at this time. Phase I Initial Site Investigation Report, by C&C, February 2001 C&C supervised the excavation of four backhoe test pits that indicate the buried debris is concentrated in a strip, approximately 40 feet wide, which runs in a north/south direction parallel to the bank. The vertical extent of buried debris generally decreases moving towards the east/west limits of the strip, and is greatest near the center of the strip extending to approximately 6 to 8 feet below ground surface. Concentrations of EPH, Chromium, lead, antimony, arsenic and nickel were all detected above the Method 1 cleanup standards. Three additional samples were collected from the levee and were analyzed for Total PP13 Metals, and samples were also analyzed for hexavalent chromium. Arsenic, chromium thallium and nickel were reported above the cleanup standards and hexavalent chromium was not detected. Groundwater sampling of the five monitoring wells was conducted and indicated concentrations for both EPH and Soluble PP13 Metals were below the detection limit in all samples except MW-4 where nickel and zinc were detected. The groundwater laboratory results suggest that contamination from the raceway fill does leach to the groundwater in detectable concentrations at selected locations, but not at others. C&C collected four sediment samples from the Mill River and two sediment samples. DEP collected three sediment samples from the Mill River. The DEP samples were analyzed for the Soluble PP13 Metals, and C&C’s six samples were analyzed for the 8RCRA Metals. Various metals were detected in varying concentrations in the eight sediment samples, but all were below the Method 1 standards. The northern portion of the Site has been temporarily fenced off to prevent unauthorized access. A permanent fence installation is planned for the Spring of 2001. Upon completion of this fence installation, it is anticipated that the Site will no longer pose an Imminent Hazard, and re-classification of the Site will be considered. As part of the Tier Classification process, the Numerical Ranking System Scoresheet was completed in accordance with 310 CMR 40.1500(9) and the Site received a score of 362. As this value is between 350 and 450, the Site is classified as Tier IC. Phase II – Comprehensive Site Assessment (Phase II) & Phase III – Identification, Evaluation and Selection of Comprehensive Remedial Action Alternatives Report (Phase III), by NEE, October 2003 The content and location of the fill material, and materials deposited along the levee between the raceway and the Mill River are now known. This report documents the concentration of metals in Site groundwater, and the lack of significant concentrations of metals in river sediments. These materials comprise the known OHM at the Site, and therefore the nature and extent of contamination are known and described in this report. Fill material in the raceway was found to be approximately six feet deep for the length of the filled portion of the raceway and to extend to a width of around 30-40 feet. This filled area is roughly 300 feet long. In the southern portion closer to the former mill building, the filled area cross-section has a rounded bottom shape, and in the northern portions a more rectangular cross-sectional shape. The fill itself Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 4 Northampton, Massachusetts consists of building demolition debris (wood, electrical conduit, asphalt roofing, plaster), solid waste (shoes, glass, cans, and plastic), and industrial wastes (4” leather belts; colored sand; metal knife blanks; metals-, petroleum-, and to a far lesser degree PCB-impacted soil). Soil in the filled areas was found to contain contaminants and the sand below the fill was found to not contain contaminants at concentrations requiring additional action. On the levee, the upper one to three feet of soil along identified areas of the raised portion of the levee was found to contain elevated concentrations of metals, primarily in colored sands (red, pink, and green). The sand and gravel of natural appearance underlying these colored sands did not contain elevated concentrations of contaminants. Approximately half of the exposed levee length has experienced adverse impact from metals. In the area of the fill under the driveway behind the former Firehouse building, TCLP Pb levels above the land application standard were identified in one sample. Two samples analyzed for TCLP Pb collected in the levee reported concentrations below the land application standard therefore; the TCLP Pb is a small isolated problem in the fill material only. No areas of surface water runoff from the Site to the Mill River were observed, except at the extreme northern end of the property near the former raceway dam, and no contaminants were identified in soil in this location. Contaminants were detected in Mill River and wetland sediment samples but not at elevated concentrations, and similar low concentrations were detected in an upstream sample as in the samples adjacent to the Site and downstream of the raceway. Nickel was consistently detected at elevated concentrations in one on-site groundwater monitoring well, MW-4. Other contaminants found at the Site were not detected at elevated concentrations in this or the other three monitoring wells at the Site. Based upon the a comparison of the Site exposure point concentrations with the applicable Method 1 standards, the exposure point concentration for groundwater at MW-4 exceeds the GW-3 and Upper Concentration Limit (UCL) standards. MCP Phase IV Remedy Implementation Plan (RIP), by NEE, August 2004 The following remedial options were considered the best alternatives for the areas of concern (AOC) at the Site noted below. Each will require approval from appropriate state and local authorities, and each is considered reliable in the long-term for the Site. AOC-1: Excavate hot spots from under the parking lots and consolidate this material within AOC-2 (completed). Pave the parking lots and place an AUL on the new pavement areas for the residual metals-impacted soil. AOC-2: Consolidate the excavated soil from AOC-1 and AOC-3 in this area and either a) phytoremediate the metals, or b) stabilize the metals in place. AOC-3: Excavate hot spots and other impacted soil off the top of the levee and consolidate this material within AOC-2 (started). The goal in this area was to achieve Method 1 soil standards. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 5 Northampton, Massachusetts Phase IV – Interim Construction Report, by NEE, August 2, 2005 MCP Phase IV REVISED Remedy Implementation Plan, by NEE, September 2005 Problem with RIP: AOC-1: The recent discovery of metals-impacted soil on the bank of the Mill River behind the Cutlery and Firehouse buildings indicates that AOC-1 extends further to the west than previously thought. This means that simply paving the parking lot surface will not provide a sufficient barrier to isolate this soil. AOC-2: Phytoremediation does not appear to be a promising solution for this area of the Site. AOC-3: Removal of much of the material trapped by the dry-laid stone retaining wall will require partial dismantling of the wall, at least on a temporary basis, in order to remove the material. Alternate Remediation Plan: AOC-3: The metals-impacted soil will be excavated from atop the levee and from the river side of the levee, and stabilized and stockpiled at the base of the hill under Riverside Drive. The stone retaining wall will be lowered in areas where contaminants have gotten down behind the stones. In the central portion of the levee, the interior drainage wetland will be eliminated, and the drainage pipe that feeds it will be extended to discharge directly to the Mill River. In the southern portion of the levee, the stone retaining wall no longer exists in this portion of the Site, and neither does the interior drainage wetland. AOC-2: In the filled portion of the raceway north of the Firehouse property, the metals-impacted soil in the stockpile and in the raceway fill will be stabilized in place. Impacted soil that exists atop the levee and on the river side of the levee will be excavated, stabilized and stockpiled at the base of the hill under Riverside Drive. This new material and the current stockpile material will be reformed into a terrace at the base of the hill below Riverside Drive. AOC-1: West of the Cutlery Building and Firehouse metals-impacted soil along the bank leading down to the Mill River will be stabilized in place and an AUL will be extended from the parking lots down to the river’s edge. In all areas where exceedance of a UCL of any metal are identified, this material will be removed, and consolidated in the stockpile in AOC-2. It will then be stabilized with the stockpile and treated as noted above. West of the Cutlery Building where the bank is near vertical, metals-impacted soil along the steep bank leading down to the Mill River will be stabilized and formed into a soft constructed wall. Six to eight horizontal feet of the bank will be removed, the large boulders and debris removed, and the remaining soil stabilized. This newly stabilized material will then be returned to the bank inside a roll of tensar net and filter fabric. The wall will be built of a number of “lifts”, each containing a roll of net and filter fabric filled with stabilized soil. The exact height of each lift will be determined by a structural engineer who will sign off on final design drawings. The effect will be to create a wall of stacked soil burritos that are porous such that hydrostatic pressure does not build up behind the wall, and so that plant can grow in, on, and through the netting and fabric. Groundwater that passes through this stabilized soft wall will be filtered by the stabilized soil and combination of fabrics. Building a soft wall in this area will necessitate the removal of all vegetation prior to building the wall. The wall itself will be replanted with appropriate vegetation as the last step of construction. In areas that are less steep, the surface of the bank will be covered in a marker layer of landscape fabric that is laid down around the existing trees. The bank will then be sprayed with the stabilization treatment such that it can soak into the bank and stabilize the metals in place. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 6 Northampton, Massachusetts The landscape fabric/marker layer will then be covered in a minimum of one foot of cover material and loam, and then planted with materials designed to physically stabilize the bank against future erosion. This alternative solution leaves the contaminants in place at the Site, but in a stabilized form that will not be available to the environment. It will also place most of this material in a location farther from the Mill River (AOC-2 and AOC-3), or use it to protect the river from likely future degradation (AOC-1). To accomplish this goal, most of the large trees along the Mill River will need to be removed so that the metals-impacted soil can be effectively excavated. An interior drainage wetland, under local bylaw jurisdiction only, will cease to exist. The newly created set of terraces down from Riverside Drive to the newly widened Bank terrace will, in the end, be an improved area suitable for use as a public park. MCP IH Evaluation & IRA Closure Report, by NEE, September 2005 NEE identified one area in AOC-1 with silver grey soil similar to impacted soil found along the levee (AOC-3) in earlier sampling. A sample of this light grey silt was collected and found to contain, among several metals exceeding Method 1 standards, 25,000 mg/kg of chromium. This concentration is above the Imminent Hazard concentration of 200 mg/kg, and the Upper Concentration Limit (UCL) of 10,000 mg/kg for chromium (III). Since this surface soil sample was collected in an accessible area of AOC-1, an Imminent Hazard condition existed. This single result prompted additional sampling of the river bank behind the parking lots of the Cutlery and Firehouse buildings. Sample results indicated that 10 of the 12 soil samples collected exceed Method 1 standards for at least one metal, 9 of these exceed the IH concentration for chromium. There were no additional exceedances of UCL concentrations beyond the initial sample in this area. It is the expanded lateral extent of these soils that is of concern, and the presence of soil exceeding IH concentrations in a non-fenced area (AOC-1) that is the subject of this report. The DEP was notified of the IH condition on July 28, 2005 and an Immediate Response Action (IRA) was initiated. The bank down to the Mill River behind the Cutlery parking lot has been posted with “No Trespassing” signs, and several areas of orange construction fencing have been installed to deter entrance to this area. These IRA mitigating measures were completed on July 29, 2005. At a site visit on August 12, 2005, Mr. Ben Fish of the DEP agreed that the sign posting and fences were adequate mitigation measures for the steep bank. This river bank has been added to the areas of concern at the Site, expanding the total area of the Site. With the area “closed”, the Imminent Hazard has been alleviated, and the IRA can be closed. REVISED Remedy Implementation Plan, by NEE, May 2006 AOC-1: In all areas where exceedance of a UCL of any metal are identified, this material will be removed, and consolidated in the stockpile in AOC-2. It will then be treated with the stockpiled soil when that occurs in the future. West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River will be physically stabilized in place and an AUL will be extended from the parking lots down to the river’s edge. A chain-link fence will be erected along the west side of the parking lots in AOC-1 to restrict access to the bank. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 7 Northampton, Massachusetts The surface of the bank will be stripped of small brush and vegetation, and then covered in a marker layer of bright orange, plastic, construction-type fencing that is laid down around the existing trees. The marker layer will then be covered with four to six inches of cover material and loam, then covered with erosion control landscape fabric, and planted with materials designed to physically stabilize the bank against future erosion. A coconut bio-log will be installed at the toe of the slope within AOC-1 to anchor the fabric layers and reduce possible erosion by the Mill River of the lower portions of the new installations. West of the Cutlery Building where the bank is near-vertical, it is unrealistic to assume that even four to six inches of soil will stay on the bank. Some areas of this bank are boulders, and these do not need need to be covered with soil and planted. In the remaining areas, soil will be placed between the large rocks and covered with an erosion-control fabric to help hold it in place prior to being planted with materials designed to physically stabilize the bank against future erosion. At the base of established trees, the soil layer will be reduced to nothing so that the trees’ root systems and trunks are not suffocated. This alternative solution leaves most of the contaminants in place at the Site, but in a stabilized form that will not be available to the environment. It will also place the worst of this material in a location farther from the Mill River (stockpile within AOC-2), or use it to protect the river from likely future degradation (AOC-1). Under this alternative solution, the entire site will be subject to an Activity and Use Limitation (AUL; 310 CMR 40.1074). This will include the land area under the former raceway west to the edge of the Mill River, and from the mouth of the raceway south to the tail race. IRA Plan, by NEE, June 2006 Prior to initiating Phase IV remedial actions at the Site on the bank behind the Cutlery Building, it was necessary to amend the existing Notice of Intent (NOI) to include this portion of the river bank within the project work area. Initial discussions with the Northampton Conservation Commission indicated their agreement that cleaning up the bank of the Mill River was an appropriate course of action. Follow-up discussions indicated a resistance to approve the NOI since the scope of work involved adding additional contaminated soil to a soil stockpile that had been at the Site longer than 120 days. In addition, the City desired confirmation of the remediation plan from an MCP perspective. In an effort to work with the City, the Cutlery has found an off-site disposal facility that can accept this excavated soil from CB-1, and has opted to conduct the work under the IRA provisions of the MCP. In the Fall of 2004, the worst of the identified impacted soil within AOC-1 was excavated and either stabilized and consolidated, or simply consolidated in a stockpile, within AOC-2. Approximately 400 yds3 of soil from AOC-1 were stockpiled within AOC-2. Confirmatory soil sampling results from the excavation areas identified in the Phase IV RIP indicate that the objectives of this excavation were met; the areas are substantially cleaner than before the excavations. The soil in SA-3 that contained leachable lead was stabilized in place so that the lead would no longer leach. Confirmatory soil sampling indicates that the metals stabilization was successful. Now that excavation activities within the parking lots for the Cutlery Building and the Firehouse have achieved the remedial goals in these areas, the parking lots have been paved. The addition of a sediment trap within the tail race to improve stormwater quality is also complete. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 8 Northampton, Massachusetts In the Summer of 2005, metals-impacted soil was discovered on the bank of the Mill River behind the Cutlery and Firehouse buildings, west of the parking lots, indicating that AOC-1 extends further to the west than previously thought. This means that simply paving the parking lot surface will not provide a sufficient barrier to isolate this soil. The concentrations of chromium exceed Imminent Hazard (1,000 mg/kg) levels in 9 of the 15 samples collected in this area, and one of these (CB-1 at 25,000 mg/kg) exceeds the UCL for chromium (10,000mg/kg). The bank of the Mill River in this location is entirely composed of fill material including a large number of boulders and concrete slabs, and is currently held in place, in part, by the roots of many mature trees. The DEP was notified of the CB-1 Imminent Hazard (IH) condition on July 28, 28, 2005 and an Immediate Response Action (IRA) was initiated. NEE proposed the installation of “No Trespassing” signs as an appropriate mitigating measure under the IRA triggered by the IH condition. Mr. John Bourcier of the DEP agreed that sign posting was an appropriate measure, and the signs were installed the following day, July 29, 2005. In addition to the signs, NEE also installed several short lengths of orange construction fencing in the more accessible areas of the top portion of the bank as an additional deterrent. At a follow-up site visit on August 12, 2005, Mr. Ben Fish of the DEP agreed that the sign posting and fences were adequate mitigation measures for the steep bank. The IRA was closed on September 9, 2005. No other IRA activities have occurred for this condition. Alternative to RIP AOC-1: In all areas where exceedance of a UCL of any metal are identified, this material will be removed, and transported to the Turnkey Landfill in Rochester, NH. West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River will be physically stabilized in place and an AUL will be extended from the parking lots down to the river’s edge. A chain-link fence will be erected along the west side of the parking lots in AOC-1 to restrict access to the bank. The surface of the bank will be stripped of small brush and vegetation, and then covered in a marker layer of bright orange, plastic, construction-type fencing that is laid down around the existing trees. The marker layer will then be covered with four to six inches of cover material and loam, then covered with erosion control landscape fabric, and planted with materials designed to physically stabilize the bank against future erosion. A coconut bio-log will be installed at the toe of the slope within AOC-1 to anchor the fabric layers and reduce possible erosion by the Mill River of the lower portions of the new installations. West of the Cutlery Building where the bank is near-vertical, it is unrealistic to assume that even four to six inches of soil will stay on the bank. Some areas of this bank are boulders, and these do not need to be covered with soil and planted. In the remaining areas, soil will be placed between the large rocks and covered with an erosion-control fabric to help hold it in place prior to being planted with materials designed to physically stabilize the bank against future erosion. At the base of established trees, the soil layer will be reduced to nothing so that the trees’ root systems and trunks are not suffocated. Excavated UCL soil from AOC-1 will be transported to the Turnkey Landfill in Rochester, NH. Based upon the distribution of sampling locations and laboratory results (CB-1 to CB Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 9 Northampton, Massachusetts 15; Table 4), NEE estimates that less than 30 yd3 of soil exceeding UCL concentrations for chromium will require excavation, more likely 5-10 yd3. This alternative solution leaves most of the contaminants in place at the Site, but in a physically stabilized form that will not erode into the river. It will also remove the worst of the contaminants from the bank of the Mill River. Under this alternative solution, the entire site will be subject to an Activity and Use Limitation (AUL; 310 CMR 40.1074). This will include the land area under the former raceway west to the edge of the Mill River, and from the mouth of the raceway south to the tail race. Brownfields Investigation Report, by O’Reilly, Talbot & Okun (OTO), July 2006 OTO completed this report for the City of Northampton with the stated goals of filling existing gaps in the environmental data set and informing the City of current site conditions. This was conducted as part of the City’s evaluation of portions of the Site for possible future acquisition for recreational purposes, not for any specific MCP requirements. Tasks completed included: 1) Installation of five (5) groundwater monitoring wells spaced along the length of the Site; 2) Analysis of soils from borings to provide information on the vertical extent of impact; 3) Installation of two (2) hand-driven groundwater monitoring points along the river; 4) Riverbank soil and groundwater testing along the length of the parcel, including re-testing of the existing well MW-4; 5) Surface water and sediment testing in the abutting Mill River. Six soil samples were collected from below the limits of visible fill materials. EPH carbon fractions and target PAHs were not detected in these samples. Metals concentrations were below the S-1/GW-3 standards with the exception of nickel, which exceeded the standard in three of the six samples (CR-2, CR-5B) and CR-6). These samples were collected from depths of 10-14 feet b.g., suggesting that nickel may be leaching from raceway fill materials into underlying soil. Groundwater results indicate that no VOCs or EPH constituents were detected in Site groundwater. Metals were detected above GW-3 groundwater standards in samples from two wells (CR-6 and MW-4). Well CR-6 is located approximately 40 feet southeast of well MW-4 and is adjacent to or within raceway fill materials. The concentration of lead in CR-6 (158 ug/L) slightly exceeds the GW-3 standard (100 ug/L). OTO states this result may indicate the possibility of lead migrating from the Site into surface water at a concentration of concern for aquatic life. However, OTO did not detect lead in the surface water samples they collected from the Mill River. At MW-4, OTO noted that there was only a small amount of groundwater in the screened section of the well, and that the water collected had a high visual entrained sediment content. Two samples were submitted to the lab for analysis from this well, a filtered sample and an unfiltered sample. Metals analytical results for the filtered sample from MW-4 indicate no metals above GW-3 standards, while the unfiltered sample contained elevated concentrations of nickel, lead, chromium, silver and zinc. It was noted that the nickel concentration in the unfiltered sample (3,670 ug/L) was similar to earlier NEE March 2003 data from this well (4,180 ug/L). OTO concludes that well MW-4 is not optimally constructed, with very little screen intercepting the water table, and may not produce groundwater samples representative of conditions in this portion of the Site. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 10 Northampton, Massachusetts EPH and target PAHs were not detected in river bank soil samples at concentrations above S-1/GW-3 standards. Nickel was found in each of the ten samples above the S-1/GW-3 standard of 20 mg/kg. Eight of the 10 samples contained chromium above the S-1/GW-1 standard (200 mg/kg). Standards were also exceeded in some samples for antimony, arsenic, cadmium, and/or lead. Seven of the ten samples (RB-1 through RB-7) contained one or more metals above UCLs. OTO concludes that materials with high concentrations of metals are present adjacent to the river and have likely been sloughing into the rover for years. Three surface water samples (OSW-1 through OSW-3) were collected from the Mill River at locations upstream, sidestream, and downstream of the head race fill area. The samples were analyzed for EPH and PP13 metals and results do not indicate a significant impact to surface water from the discharging Site groundwater. EPH hydrocarbon fractions and PCBs were not detected in the 14 sediment samples collected. PAHs were detected in one sample above MADEP Sediment Screening Values (DEP. 2006) opposite the filled section of the raceway. Metals were not detected above the screening levels in any of the 14 sediment samples. The OTO report noted river bank soils were both potentially accessible and subject to erosion and transport into the Mill River. These situations were remedied by streambank stabilization activities, rebuilding portions of the retaining wall at the base of the levee, and the installation of a fence along the entire length of the Site between public areas (Riverside Drive and the Site parking lots) and the impacted soils (see the following three IRA Status Report summaries: October 2006, April 2007, and October 2007). OTO also noted the presence of the soil stockpile within AOC-2 which did not meet the requirements for remediation waste (MCP 310 CMR 40.0031). The stockpile was re-graded, covered with landscape fabric and loam, and was seeded in order to eliminate erosion (IRA Status Report, NEE October 2006). IRA Plan Amendment & Other Related Activities, by NEE August, 2006 The objective of the original IRA was to excavate soil that exceeds UCL concentrations for chromium within AOC-1 and to dispose of this soil off-site at an approved landfill. This amendment seeks to notify the DEP that under an agreement between the PRP, the City of Northampton Conservation Commission, and the DEP-BWSC-WERO, the soil excavated from AOC-1 under this IRA will now be added to the existing soil stockpile within AOC-2. The stockpile will in turn be lowered slightly, and spread out slightly to remove the high peaks and some of the steep side slopes. The stockpile will then be covered with a geotextile fabric, loam and seed. The plastic will not be replaced on top of this stockpile. Under the agreement, fabric, loam and seed was considered a better long-term cover material than plastic as it would not degrade in the sun and it would prevent contaminated soil from being blown by the wind. Percolation of precipitation was not considered a concern as the concentrations of metals in the soil have been demonstrated not to leach in excess of the EPA land treatment concentrations. With the exception of changing the cover material on the stockpile, these actions are similar to those included in the Revised Phase IV RIP submitted to the Department on September 15, 2005. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 11 Northampton, Massachusetts Additional chain link fence will be added to the road-side of the Site from the southerly chain link fence all the way to the northerly chain link fence; the entire length of AOC-2 and AOC-3. The orange plastic fencing will be moved to the river-side of the soil stockpile, after it has been loamed and seeded. This action will completely encircle the stockpile with fencing. The goal of this IRA Plan remains to remove the most highly contaminated soil from AOC-1 and then to stabilize, control and isolate the remaining concentrations of metals-impacted soil. Once this is complete, an Activity & Use Limitation will be placed on AOC-1, and NEE will file a Class A3 Partial Response Action Outcome (RAO-P) on this portion of the Site (the Cutlery Building and Firehouse lots). The remaining Remediation Waste from AOC-1 that is included in the soil stockpile located in AOC-2 will be managed as noted below and included in the Class C RAO for those portions of the Site. These actions are sufficient to allow partial closure of AOC-1 under 310 CMR 40.0030. Related Activities in AOC-2 & AOC-3 While not specifically included in the IRA, the following actions are also planned for AOC-3: The steep slopes along the levee that are not vegetated and are eroding will be covered with erosion control fabric and seeded with grass. The relatively flat top surface of the levee will be seeded and covered with straw. A short (40-50 foot) section of the toe of the slope will receive stone rip-rap to hold down the lower end of the erosion control fabric. This area is directly downstream from the downstream end of the stone retaining wall that exists along most of the toe of the slope along the levee, effectively making the stone retaining wall 40-50 feet longer. This new section of stone wall will be up to two feet high. The goal of lowering the soil stockpile, adding fencing along the entire length of Riverside Drive in AOC-2 & AOC-3, and stabilizing the levee bank from erosion is to get this portion of the Site in a condition where it is as stable, controlled and protected as is feasibly possible at this time in order to qualify for a Class C RAO. This Temporary Solution will allow additional time and research to determine the best long-term approach to remediation of the groundwater and soils, both in place and in the stockpile, in AOC-3. IRA Status Report, by NEE, October 2006 Soil Excavation On September 13, 2006, vegetation along the bank behind the Cutlery and Valley Home Improvement buildings and parking lots was cut and chipped in preparation for the remaining IRA tasks. On September 21, 2006, NEE supervised the excavation of soil exceeding UCL concentrations of chromium. Excavation was conducted by Duffy-Willard of Northampton, MA. Excavated soil was moved and added to the soil stockpile within AOC-2. In total, approximately 28 yds3 of soil were excavated from AOC-1 and added to the stockpile. Soil Sampling and Results Prior to initiating excavation activities on the bank of the Mill River in AOC-1, NEE collected the following soil samples for laboratory analysis: a) A duplicate sample of CB-1 (CB-1-2) was collected by NEE on June 6, 2006 and submitted to Spectrum Analytical of Agawam, MA for laboratory analysis of Full Toxicity Characteristic Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 12 Northampton, Massachusetts Leaching Procedure Scan (TCLP-VOCs, TCLP-SVOCs, TCLP-PCBs, TCLP-RCRA 8 metals) to ensure that the material proposed for excavation under this IRA Plan is considered “nonhazardous” under RCRA. Additional characterization analyses included Total and Hexavalent Chromium, flashpoint, pH, and reactivity. Laboratory results indicate that sample CB-1-2 contained 69,900 mg/Kg total chromium, no hexavalent chromium and 0.0523 mg/L chromium under the TCLP extraction. No other analytes were detected in the TCLP extraction. Flashpoint was >200, the pH 6.63, and reactivity was negative. Sample CB-1 contained 25,000 mg/Kg total chromium (Table 1). These analyses indicate that the material is not “hazardous” under RCRA, is the identified material in exceedance of UCL chromium concentrations, and is therefore suitable for addition to the existing soil stockpile within AOC-2 under the terms of this IRA. Copies of the laboratory report are included in Appendix C. b) Four additional surface soil samples were collected by NEE on June 6, 2006 from the bank of the Mill River north of CB-2 on the Firehouse lot for analysis of total metals. One sediment sample was collected from the Bank Full Bench (CB-16-sed), and three soil samples were collected from the embankment below the Valley Home Improvement parking lot (Figure 3). The samples were submitted to Spectrum Analytical of Agawam, MA for laboratory analysis of PP13 total metals to indicate if the work area needed to extend all the way to the north Firehouse property line (current location of the chain link fence). Currently the northern-most sample (CB-2) did not indicate a “clean margin” on the sampling area. Laboratory results indicate that sample CB-16-sed exceeds the TEC Benchmark values for copper, mercury, nickel, and lead, but does not exceed Method 1 standards for any of the PP13 metals (Table 1). Samples CB-17 and CB-18 each contain chromium above the imminent hazard concentration and below the UCL, and lead above the Method 1 standard. Sample CB-19 collected from the edge of the parking lot did not exceed a listed standard for any of the PP13 metals. These results are similar in nature to the other samples collected on this portion of the bank (except CB-1/CB-1-2), and indicate that the work area should extend all the way to the north Firehouse property line (current location of the chain link fence). Copies of the laboratory report are included in Appendix C. c) After soil excavation on September 21, 2006, NEE collected eight confirmatory soil samples from the excavation area, and one duplicate sample (of CB-CS-5). The samples were submitted to Spectrum Analytical for laboratory analysis of PP13 total metals. Laboratory results indicate that all samples contain concentrations of chromium below the UCL value (10,000 mg/Kg), confirming that the IRA excavation was successful. Laboratory results are summarized in Table 1 and indicate that 7 of the 9 confirmatory samples collected still contain chromium above the Method 1 (1,000 mg/kg) and Imminent Hazard (1,000 mg/kg) concentrations, but significantly below the UCL value of 10,000 mg/kg. These results represent an order of magnitude or greater decrease in the total chromium concentrations along the bank of the Mill River from the initial CB-1 (25,000 mg/kg) and CB-1-2 (69,900 mg/kg) concentrations. Copies of the laboratory report are included in Appendix C. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 13 Northampton, Massachusetts Soil Stockpile The excavated soil from AOC-1 was added to the soil stockpile within AOC-2 and this pile was re-graded to achieve a lower profile on the pile and change its cover material. The plastic cover on the stockpile was removed, and the pile re-graded to cover most of the east-west cross-section of the filled portion of the raceway near the original stockpile. The IRA Plan called for adding length to the stockpile as a means of reducing its height and then covering it with loam and seed. This proved to be highly impractical in the field as moving this volume of soil laterally along the pile was not possible without increasing the pile width. However, increasing the pile width eliminated the truck access along the western side of the stockpile. In the end, the pile was made almost twice as wide, compacted, and covered in geotextile fabric, loam, and seeded. Truck access to the northern portions of the Site is now over the seeded stockpile. The stockpile total height is between 3-4 feet and ramped to 0 at the north and south ends, its width 45-50 feet, and the total length increased slightly from 180 feet to approximately 230 feet. Two depressions in the stockpile provide access to City of Northampton sewer manholes. This stockpile has been covered in loam and seeded (see photographs). Added Fill Material & Imminent Hazard Evaluation “No Trespassing” signs were posted to mitigate the CB-1 UCL chromium IH situation in July 2005 as noted above. The signs are still present at the Site and NEE also installed several short lengths of orange construction fencing in the more accessible areas of the top portion of the bank as an additional deterrent at that time. The laboratory results from confirmatory soil sample CB-CS-8 indicate the presence of arsenic (76.6 mg/Kg) above the Imminent Hazard concentration of 40 mg/Kg. To alleviate this this situation, a foot of clean fill material was imported to this portion of the Site and placed on the top of the bank near the edge of the parking lot on top of this sampling location. The area was then covered with wood chips from the clearing operations. An Imminent Hazard situation no longer exists at this location for arsenic. Confirmatory soil sample results do indicate the presence of chromium in excess of the Imminent Hazard concentration of 1,000 mg/Kg. Since it has been demonstrated that Chromium IV does not exist at the Site, and a similar situation has existed along this bank since the initial CB soil sampling, and since the posting of signs has been deemed sufficient protection of the public at this location in the past, additional signs were added to this area (see Section 2.5 below) for the short term, and this was considered adequate until the chain link fence is installed. No other Site conditions have changed and no other new information has surfaced since the initial IH Evaluation & IRA IRA Plan for the CB-1 UCL soil situation. There is currently no known Imminent Hazard situation at the Site. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 14 Northampton, Massachusetts Retaining Wall Valley Home Improvement built a three-foot high concrete block retaining wall approximately six feet west of the edge of pavement at the northern-most portion of their parking lot. This wall was added to the plans in order to increase the paved area along this side of the parking lot to ease winter snow plowing and allow a place to pile plowed snow. With the addition of a chain link fence, snow can no longer be plowed over the bank and must remain on the pavement for the winter, or removed altogether. This design modification was approved by the Conservation Commission along with the NOI for the project. Soil that was excavated for the footing of this retaining wall was left on the bank below the wall. No soil was removed from the bank for this portion of the project. Design drawings for this wall are included in Appendix D. Sign Posting Additional “No Trespassing” signs were added to both the street and river sides of the Site. There are now six “Posted, No Trespassing” signs along the edge of pavement of the Cutlery and Valley Home Improvement parking lots, a total of 11 similar signs on the edge of Riverside Drive along AOC-2 and AOC-3, and three “Posted, No Trespassing” signs along the bottom edge of the levee facing the Mill River in AOC-3, with a final sign at the base of the CB-1 excavation facing the River in AOC-1. In all, 12 new signs were added to the Site in September 2006. IRA Status Report, by NEE, April 2007 Soil Excavation No soil excavation activities have occurred in the period from October 20, 2006 through April 20, 2007. Sign Posting Additional “No Trespassing” signs were added to both the street and river sides of the Site. There are now six “Posted, No Trespassing” signs along the edge of pavement of the Cutlery and Valley Home Improvement parking lots, a total of 11 similar signs on the edge of Riverside Drive along AOC-2 and AOC-3, and three “Posted, No Trespassing” signs along the bottom edge of the levee facing the Mill River in AOC-3, with a final sign at the base of the CB-1 excavation facing the River in AOC-1. In all, 12 new signs were added to the Site in September 2006. Update on the Status of Bank Stabilization, NEE, June 2007 Orange plastic fencing has now been installed as a marker layer on the bank surface to identify the former ground surface west of the parking lots in ACO-1. Spring flooding of the Mill River this Spring caused considerable erosion of the toe of the slope in AOC-1 and over-topped the silt fence, flattening it in many places. A flexible filter soc filled with seeded mulch was installed along the toe of the slope in this area of the Site as a replacement for the silt fence. Seeded mulch (EcoBlanketTM, see attached product specification sheets) was then sprayed in a layer 2-4 inches thick on the slope on top of the orange plastic fencing in AOC-1. Straw mat was stapled to to the top surface of the bank, on top of the EcoBlanketTM, in some of the steeper portions of the slope to further protect the slope from erosion. The attached photographs show various stages of this installation and the finished installation with sprouted seed. It is anticipated that some areas will require touch up before the summer is over, and this work is scheduled for August. The bank stabilization plan also called for planting of dormant willow stakes which is scheduled for November 2007. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 15 Northampton, Massachusetts Small areas at the edge of the existing parking lots and the land within the Valley Home Improvement storage fence still require paving. The necessary prep work for the paving was just completed with the bank stabilization and the paving is scheduled for this summer. Once the paving is complete, the chain link fence will be installed at the edge of the pavement and AOC-1 of the Site will be ready for an AUL and Class A-3 RAO-P. We anticipate that the bank stabilization NOI Certificate of Completion can be achieved once the willow stakes are installed, and that the IRA Completion Report can be prepared shortly thereafter. The AUL/RAO-P can then be finalized and submitted. We anticipate this will occur early in 2008. On the issue of the chain link fence, Cutlery Building Associates would greatly prefer to install a fourfoot high fence along the edge of the parking lot immediately behind the the buildings, including behind the old firehouse, with “No Trespassing/Restricted Area” signs. This would be in place of the five-foot fence outlined in the IRA Plan. They believe a higher fence will be unattractive and very adversely impact their property value, and is unnecessary as a means of restricting access by the public.. They believe a four-foot fence behind the buildings will be effective to deter people from climbing over the fence due to the proximity and active use of the buildings. A five-foot high chain link fence will still be installed along Riverside Drive as originally planned as this area is more accessible to the public. Primarily this is an issue of aesthetic impact of a five-foot fence, and the ability to rent space within the Cutlery Building. The fence will be very close to the buildings and the five-foot height will have a much more negative impact on the buildings than a four-foot height without any real additional protection of the public. They want to make this minor change to the IRA plans, along the parking lot only, but need assurance from the Department that such a fence will be accepted when this RTN/RAO-P is audited in the future. We would appreciate the Department’s written response to this request. Erosion had occurred in the sand under the new concrete wall of the sediment trap within the tailrace. The hole under the wall and the floor of the sediment trap were filled with a layer of pea-stone in early June to combat this erosion, and this solution appears to be holding up. The soil stockpile in AOC-2 has an ample crop of grass and no erosion is apparent on the sides of the stockpile. This stockpile is solid as evidenced by the lack of evident compaction or erosion when the levee area was accessed for bank stabilization work (see below). The inevitable tire tracks across the top of the stockpile were seeded with the same EcoBlanketTM mulch material once the levee work was complete, and we anticipate this will look as good as the rest of the stockpile within several weeks. The proposed stone retaining wall at the toe of the slope of the levee in AOC-3 is installed. An eroded, undercut area just above/behind this wall was filled with pea-stone to physically stabilize the bank and return the bank profile to its former slope. The entire levee bank was coated in a 2-4” layer of EcoBlanketTM, as was the top surface of the levee. The steepest sections of the levee bank were then covered with straw mat that was stapled to the ground surface in an effort to further combat erosion on the levee bank. The silt fence along the toe of the levee bank was left in place. Photographs of this area of the Site are also attached. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 16 Northampton, Massachusetts IRA Status Report, by NEE, October 2007 Soil Excavation No soil excavation activities have occurred in the period from April 20, 2007 through October 3, 2006. Sign Posting Additional “No Trespassing” signs were added to both the street and river sides of the Site in September 2006. There are now 18 “Posted, No Trespassing” signs around the Site: six along the edge of pavement of the Cutlery and Valley Home Improvement parking lots, a total of 11 similar signs on the edge of Riverside Drive along AOC-2 and AOC-3, and three “Posted, No Trespassing” signs along the bottom edge of the levee facing the Mill River in AOC-3, with a final sign at the base of the CB-1 excavation facing the River in AOC-1. Mill River Bank Stabilization in AOC-1 The remaining metals-impacted soil along the bank leading down to the Mill River in AOC-1 were physically stabilized in place. Orange plastic fencing has now been installed as a marker layer on the bank surface to identify the former ground surface west of the parking lots in ACO-1. Spring flooding of the Mill River this Spring caused considerable erosion of the toe of the slope in AOC-1 and over-topped the silt fence, flattening it in many places. A flexible filter soc filled with seeded mulch was installed along the toe of the slope in this area of the Site as a replacement for the silt fence. Seeded mulch (EcoBlanketTM) was then sprayed in a layer 2-4 inches thick on the slope on top of the orange plastic fencing in AOC-1. Straw mat was stapled to the top surface of the bank, on top of the EcoBlanketTM, in some of the steeper portions of the slope to further protect the slope from erosion. The attached photographs show various stages of this installation and the finished installation with sprouted seed. It is anticipated that some areas will require touch up this Fall, and this work is scheduled for October. The bank stabilization plan also called for planting of dormant willow stakes which is scheduled for November 2007. Mill River Bank Stabilization in AOC-2 and AOC-3 The proposed stone retaining wall at the toe of the slope of the levee in AOC-3 was installed. An eroded, undercut area just above/behind this wall was filled with pea-stone to physically stabilize the bank and return the bank profile to its former slope. The entire levee bank was coated in a 2-4” layer of EcoBlanketTM, as was the top surface of the levee. The steepest sections of the levee bank were then covered with straw mat that was stapled to the ground surface in an effort to further combat erosion on the levee bank. The silt fence along the toe of the levee bank was left in place. Photographs of this area of the Site are also attached. The soil stockpile in AOC-2 has an ample crop of grass and no erosion is apparent on the sides of the stockpile. This stockpile is solid as evidenced by the lack of evident compaction or erosion when when the levee area was accessed for bank stabilization work (see below). The inevitable tire tracks across the top of the stockpile were seeded with the same EcoBlanketTM mulch material once the levee work was complete, and this area recovered and looked as good as the rest of the stockpile within several weeks. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 17 Northampton, Massachusetts IRA Closure Report, by NEE, November 2007 Soil Excavation in AOC-1 In all areas where exceedance of a UCL of any metal was identified, this material was moved to the existing soil stockpile within AOC-2. The soil was excavated and moved by Duffy & Willard of Northampton, MA under the supervision of an NEE LSP on September 21, 2006. NEE estimates that 25 yd3 of soil exceeding UCL concentrations for chromium was excavated and moved to the soil stockpile. Confirmatory soil samples were collected at the end of excavation activities and the results indicated that the UCL contaminated soil had been removed from this location. These laboratory results were submitted with the October 20, 2006 IRA Status Report (see Table 1). Mill River Bank Stabilization in AOC-1 West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River was physically stabilized in place. The surface of the bank was stripped of small brush and vegetation, and then covered in a marker layer of bright orange, plastic, construction-type fencing that was laid down around the existing trees and large boulders. The marker layer was then covered with four to six inches of blown-in compost mulch and seed. In steep areas, this was then covered with erosion control landscape fabric. West of the Cutlery Building where the bank is nearvertical, it was unrealistic to assume that even four to six inches of soil would stay on the bank. Some areas of this bank are boulders, and these did not need to be covered with soil and planted. In the remaining areas, soil was placed between the large rocks and covered with an erosion-control fabric to help hold it in place prior to being planted. At the base of established trees, the soil layer was reduced to nothing so that the trees’ root systems and trunks were not suffocated. The bank was then planted with willow stakes to physically stabilize the bank against future erosion. A blown-compost bio-log was installed at the toe of the slope within AOC-1 to anchor the fabric layers and reduce possible erosion of the lower portions of the new installations by the Mill River. Photos of the installation sequence and completed bank treatment are attached. Fence Installation A chain-link fence was erected along the west side of the parking lots in AOC-1 to restrict access to the river bank. Cutlery Building Associates requested permission from the DEP to install a four-foot high fence along the edge of the parking lot immediately behind the buildings, including behind the old firehouse, with “No Trespassing/Restricted Area” signs. This was in place of the five-foot fence outlined in the IRA Plan. Cutlery Building Associates believed a higher fence would be unattractive and very adversely impact their property value, and was unnecessary as a means of restricting access by the public. They believed a four-foot fence behind the buildings would be effective to deter people from climbing over the fence due to the proximity and active use of the buildings. A five-foot high chain link fence was installed along Riverside Drive (AOC-2 and AOC-3) as originally planned as this area is more remote. The DEP responded favorably to this request, issuing an approval letter dated July 19, 2007 (Appendix A). Photos of the four-foot high and five-foot high fences are attached. Soil Stockpile in AOC-2 On September 21, 2006, the plastic that formerly covered the stockpile was removed, and the stockpile was re-graded to be wider and shorter. The length of the stockpile increased only slightly from 180 to 230 feet and the entire newly graded stockpile remained on top of the filled raceway within AOC-2. The Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 18 Northampton, Massachusetts stockpile was then covered in geo-textile fabric, several inches of loam, and was seeded and hayed. The fabric, loam and seed was considered a better long-term cover material than plastic as it would not degrade in the sun and it would prevent contaminated soil from being blown by the wind. Percolation of precipitation was not considered a concern as the concentrations of metals in the soil have been demonstrated not to leach in excess of the EPA land treatment concentrations. Due to the width of the stockpile, access to the northern portions of the Site (AOC-3) is now accomplished by traversing the length of the top of the stockpile. This includes authorized pedestrian and vehicular traffic. Photos of the completed stockpile installation are attached. A depression in the stockpile near the center and another near the north end provide access to City of Northampton sewer manholes. Sign Posting Additional five-foot high chain link fence was added to the road-side of the Site from the southerly chain link fence all the way to the northerly chain-link fence; the entire length of AOC-2 and AOC-3. Additional “No Trespassing” signs were attached to trees along both Riverside Drive and the shore line of the Mill River. These actions completely encircled the stockpile with signs and on three sides with chain-link fence. This IRA was initiated to abate an Imminent Hazard associated with chromium in soil in excess of UCL concentrations in AOC-1. This UCL soil has been moved to the soil stockpile in AOC-2, the stockpile has been covered with geo-textile fabric, loam and seed, and the stockpile has been fenced on three sides. The riverbank where the soil was excavated has been shown to no longer contain UCL concentrations of chromium (Table 1). The remaining soil on the riverbank is known to contain residual concentrations of chromium and other metals in excess of Method 1 clean-up criteria. These impacted soils have been isolated under an orange plastic fencing marker layer and behind a chain link fence. The riverbank was then physically stabilized using compost mulch, seed, erosion control fabric, and willow stakes. The non-paved areas of AOC-1 (the riverbank) have been further isolated with the installation of a fourfoot high chain link fence. This fence connects the existing chain link fence around the tailrace with the existing chain link fence on the north side of the paved parking area at the firehouse lot. This fence runs along the edge of the paved surface, separating the unpaved riverbank from the paved areas accessible to the general public. Since the UCL soil no longer exists in this area and the residual concentrations of metals are isolated, the Imminent Hazard situation no longer exists, and the IRA can be closed. The goal of this IRA was to remove the most highly contaminated soil from AOC-1 and then to stabilize, control and isolate isolate the remaining concentrations of metals-impacted soil. Now that this is complete, an Activity & Use Limitation will be placed on AOC-1, and NEE anticipates filing a Class A3 Partial Response Action Outcome (RAO-P) on this portion of the Site (the Cutlery Building and Firehouse lots). The remaining Remediation Waste from AOC-1 that is included in the soil stockpile located in AOC-2 will be included in and managed under the Class C RAO for those portions of the Site. These actions are sufficient to allow partial closure of AOC-1 under 310 CMR 40.0030. Cutlery Raceway Slope Stabilization, Wetland Restoration Monitoring Report, by NEE to Northampton Conservation Commission, November 16 2010. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 19 Northampton, Massachusetts New England Environmental, Inc. (NEE) was hired by Alan Verson (the applicant) to assess the bank stabilization work at 320-360 Riverside Drive in Northampton and assess vegetational cover as required by the Order of Conditions. This work was originally completed in 2007 by Northeast Environmental Solutions (NES) under a “revised remediation plan” submitted to the Commission in a letter dated May 29, 2007. A site visit to complete this assessment was done on November 11, 2010. An NEE wetland scientist had previously visited the site on July 28, 2010. Both of these site visits were conducted by Karro Frost, PWS. To describe the vegetation on the site, the work areas will be described individually below. These sections include (1) the northern section of the levee with the retaining walls between the raceway and the Mill River; (2) the soil stockpile area on the levee which has been loamed and seeded; (3) original slope stabilization work completed adjacent to the former firehouse and cutlery building and their associated parking area; and (4) 2010 repair work completed in two sections within (3). The primary wetland resource area impacted by the work is the 200 foot Riverfront Area associated with the Mill River. Most of the work also occurred within the 100 foot buffer zone to bank. Northern Section of the Levee and Stabilized Bank Material was removed from this area under the 2004 Order of Conditions, and portions of the stone walls were rebuilt. Photos 1 through 4 (Attachment A) illustrate this area during the July and November site visits. The work went around pre-existing trees without damaging them. This area is well vegetated with an unidentified grass and scattered clover and tree seedlings. Only a few of the willow stakes survived and have grown. The percent cover is 85% in November, 2010. This area meets the criteria in the Order of Conditions for 85% vegetative cover. There is a silt fence at the toe of the slope which should be removed. Soil Stockpile Area The soil stockpile was created under the 2004 Order of Conditions, and then regraded, and stabilized in place under an IRA Amendment dated August 2006. The IRA Amendment was the result of a joint agreement between the Applicant, the City of Northampton Conservation Commission, and the DEP-BWSC-WERO. Under the IRA Amendment, the stockpile was covered with orange fencing as a marker, then covered with loam and seeded. This area now is completely vegetated, with no open areas and a percent cover of 100%. The dominant vegetation includes New England Aster Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 20 Northampton, Massachusetts (Symphyotrichum novae-angliae), wild rye (Elymus spp.) and deertongue (Dichanthelium clandestinum). Photos 5 and 6 in Attachment A illustrate this area on July 28 and November 11, respectively. A variety of other plants were also observed in this area including Queen Anne’s lace (Daucus carota), raspberry and blackberry (Rubus spp.), fall panic grass (Panicum dichotomiflorum), wavy-leaved aster (Symphyotrichum undulatum), tall goldenrod (Solidago altissima), burdock (Arctium sp.), red oak seedlings (Quercus rubra), bird cherry seedlings (Prunus pensylvanica), and sugar maple seedlings (Acer saccharum). A few exotic species pre-existing on the site have also started to colonize this area, including autumn olive (Elaeagnus umbellatus), Japanese knotweed (Polygonum cuspidatum) and multiflora rose (Rosa multiflora). This area meets the the criteria in the Order of Conditions for 85% vegetative cover. Stabilized Slope Adjacent to Cutlery and Old Firehouse This area was stabilized under the 2004 Order of Conditions and the 2007 “revised remediation plan.” Work was done around pre-existing trees. This area includes very steep slopes. The canopy cover in this area is very dense and there is little light reaching the forest floor, preventing much growth in the herbaceous layer. This area has approximately 15% herbaceous cover, but 95% canopy cover. Portions of this area have slopes over 3:1, and the orange fencing is visible in sections on the slope. In addition, this area was minimally disturbed, with the primary activity covering the soil with orange fencing, which was then loamed and seeded. This area does not have any signs of erosion. Although the area does not meet the 85% herbaceous vegetation cover, it has 95% canopy cover. The area was minimally disturbed and shows no signs of erosion after three years. Smaller 2010 Repair Area -Upstream Immediately downstream of the above area is a small area of repair that was completed in spring, 2010. Unlike the above areas, this area was becoming undercut and was eroding. The total length of this repair is 30 linear feet. Repairs consisted of creating geo-lifts at the toe of the slope with brush layered between them, and soil covering the slope, seeded and covered with an erosion control blanket staked into place. Photos 8 through 10 in Attachment A illustrate this area. Appendix C -Class A3 & Class C1 RAO Report RTN #1-13320 Former Cutlery Raceway February 8, 2011 320-360 Riverside Drive NEE Project No. 02-2053 Page 21 Northampton, Massachusetts The vegetative cover of this area is approximately 20%. The vegetation is growing well and there is no further sign of erosion. Larger 2010 Repair Area – Downstream A second and larger area of bank repair was completed downstream and near the Cutlery Building. This area also was becoming undercut and the repairs were similar to the above. This area is 130 feet in length, and consists of biologs and geo-lifts at the toe of the slope with brush layering, and loam and seed were placed on the upper slope, which was then covered with an erosion control blanket. The grass has started to grow on the slope. Photos 11 and 12 illustrate this area. The herbaceous cover is approximately 50% and there has been no additional erosion. Canopy percent cover is 80%, with a total percent cover of approximately 90%. Summary Most of the site is well-vegetated, and the overall percent cover is 85% including the both canopy and herbaceous layers. The herbaceous layers in the 2010 repaired areas have not yet grown in to the density desired, however, they are expected to continue to expand and grow. The site was stable during both the July and November site visits conducted to assess the vegetation. An Activity & Use Limitation (AUL) will be placed on all of the areas described above as part of Site closure with DEP-BWSC. In part, the AUL will require the orange marker layers to be covered with loam and vegetation, the parking lot asphalt to remain in good condition, that any areas experiencing erosion be repaired in a manner to prevent future erosion, and that the fences and signs remain in good condition. The AUL will also require an Annual AUL Inspection Report be provided to DEP-BWSC. NEE suggests that the Conservation Commission also receives copies of these reports on an annual basis. If any areas have signs of erosion, these areas must be stabilized, which will include a new filing with the Conservation Commission. APPENDIX D NEE Standard Operating Procedures New England Environmental, Inc. Standard Protocols Jar Headspace Screening The following procedures will be used to screen soil samples for volatile organic compounds with a portable photoionization detector (PID) or a flame ionization detector (FID). 1. Half-fill a clean glass 8-ounce jar with the sample to be analyzed. Quickly cover the open top with a sheet of clean aluminum foil and apply the screw cap to tightly seal the jar. 2. Vigorously shake the jar for 10 seconds both at the beginning and end of the headspace development period. Allow the jar to stand 10 minutes for headspace development. When ambient temperatures are below 32F (0C), allow the samples to stand in a heated vehicle or building. 3. After the headspace development period, remove screw lid to expose the foil seal. Puncture the foil seal with an instrument sampling probe, to a point about one-half of the headspace depth. Do not allow water droplets or soil particulates to touch the instrument probe. 4. Observe the instrument response and record the highest meter response as the jar headspace concentration. The maximum response should occur from two to five seconds after the probe is inserted into the jar. The meter response may be erratic when the concentration of organic vapor is high or if there is excessive moisture in the sample. The experience and judgment of the instrument operator must be used to determine the validity of the headspace measurement. 5. Benzene or an equivalent compound will be used to calibrate the field screening instrument. Jar headspace sample results will be reported as “total organic vapors” in ppm (v/v). Instruments will be operated, maintained, and calibrated in accordance with the manufacturer's specifications. A calibration and maintenance log is kept at New England Environmental's office for each instrument. The daily calibration data are transcribed to the field log for each day that the instrument is used. Some samples may be collected and analyzed in duplicate to measure sample variability. Adapted from: from: Interim Remediation Waste Management Policy for Petroleum Contaminated Soils, MA-DEP #WSC-94-400. This document supersedes and references the earlier Management Procedures for Excavated Soils Contaminated with Virgin Petroleum Oils, MA-DEP #WSC 400-89. Last updated 9/16/02 New England Environmental, Inc. Standard Protocols Low-Flow Sampling of Monitoring Wells Discussion To obtain a representative sample of groundwater, particularly for metals analyses, low-flow sampling is the preferred method. Low-flow sampling is also preferred when trying to minimize the volume of purge water/remediation waste generated. For all sampling it must be understood that the water within the well casing and in close proximity to the well is generally not representative of the groundwater quality at that sampling site. Therefore, the well will be purged until it is sufficiently flushed of standing water and water from the aquifer is being drawn into the well. Refer to DEP Policy #WSC-310-91 to choose the appropriate method for purging and sampling a well and operate sampling equipment according to manufacturer's directions. Refer to EPA Low Stress (Low Flow) Purging And Sampling Procedure For The Collection Of Ground Water Samples From Monitoring Wells for a complete discussion of low-flow sampling methods and procedures. The following procedures have been adapted/distilled from the EPA protocol indicating the methods used by NEE. This procedure does not address the collection of samples from wells containing light or dense non-aqueous phase liquids (LNAPLs and DNAPLs). Procedures for Purging and Sampling 1. Using clean, non-contaminating equipment, determine and record in the field logbook the water level in the well to the nearest 0.01-foot. If a recording pressure transducer is used for this purpose, initialize the starting condition and measure the water level prior to starting the pump. 2. Sampling wells in order of increasing chemical concentrations (known or anticipated) is preferred. 3. Install Pump Lower pump, safety cable, tubing and/or electrical lines slowly (to minimize disturbance) into the well to the midpoint of the zone to be sampled. If possible keep the pump intake/tubing at least two feet above the bottom of the well, to minimize mobilization of particulates present in the bottom bottom of the well. Collection of turbid free water samples may be especially difficult if there is two feet or less of standing water in the well. 4. Purge Well 4a. Initial Low Stress Sampling Event Start the pump at its lowest speed setting and slowly increase the speed until discharge occurs. Check water level. Adjust pump speed until there is little or no water level drawdown (less than 0.3 feet). If the minimal drawdown that can be achieved exceeds 0.3 feet but remains stable, continue purging until indicator field parameters stabilize. Monitor and record water level and pumping rate every three to five minutes (or as appropriate) during purging. Record any pumping rate adjustments (both time and flow rate). Pumping rates should, as needed, be reduced to the minimum capabilities of the pump (for example, 0.1 -0.4 l/min) to ensure stabilization of indicator parameters. Adjustments are best made in the first fifteen minutes of New England Environmental, Inc. Standard Protocols pumping in order to help minimize purging time. During pump start-up, drawdown may exceed the 0.3 feet target and then "recover" as pump flow adjustments are made. Purge volume calculations should utilize stabilized drawdown value, not the initial drawdown. Do not allow the water level to fall to the intake level (if the static water level is above the well screen, avoid lowering the water level into the screen). The final purge volume must be greater than the stabilized drawdown volume plus the extraction tubing volume. Wells with low recharge rates may require the use of special pumps capable of attaining very low pumping rates (bladder, peristaltic), and/or the use of dedicated equipment. If the recharge rate of the well is lower than extraction rate capabilities of currently manufactured pumps and the well is essentially dewatered during purging, then the well should be sampled as soon as the water level has recovered sufficiently to collect the appropriate volume needed for all anticipated samples (ideally the intake should not be moved during this recovery period). Samples may then be collected even though the indicator field parameters have not stabilized. 4b. Subsequent Low Stress Sampling Events After synoptic water level measurement round, check intake depth and drawdown information from previous sampling event(s) for each well. Duplicate, to the extent practicable, the intake depth and extraction rate (use final pump dial setting information) from previous event(s). Perform purging operations as above. 5. Monitor Indicator Field Parameters During well purging, monitor indicator field parameters (turbidity, temperature, specific conductance, pH, Eh, DO) every three to five minutes (or less frequently, if appropriate). Note: during the early phase of purging emphasis should be put on minimizing and stabilizing pumping stress, and recording those adjustments. Purging is considered complete and sampling may begin when the above indicator field parameters have stabilized. Stabilization is considered to be achieved when three consecutive readings, taken at three (3) to five (5) minute intervals, are within the following limits: turbidity (10% for values greater than 1 NTU), DO (10%), specific conductance (3%), temperature (3%), pH (± 0.1 unit), ORP/Eh (± 10 millivolts). All measurements, except turbidity, must be obtained using a flow through-cell. Transparent flowthrough-cells are preferred, because they allow field personnel to watch for particulate build-up within the cell. This build-up may affect indicator field parameter values measured within the cell and may also cause an underestimation of turbidity values measured after the cell. If the cell needs to be cleaned during purging operations, continue pumping and disconnect cell for cleaning, then reconnect after cleaning and continue monitoring activities. The flow-through-cell must be designed in a way that prevents air bubble entrapment in the cell. When the pump is turned off or cycling on/off (when when using a bladder pump), water in the cell must not drain out. Monitoring probes must be submerged in water at all times. If two flow-through-cells are used in series, the one containing the dissolved oxygen probe should come first (this parameter is most susceptible to error if air leaks into the system). New England Environmental, Inc. Standard Protocols 6. Collect Water Samples Water samples for laboratory analyses must be collected before water has passed through the flowthrough-cell (use a by-pass assembly or disconnect cell to obtain sample). In order to compare analytical data for a given well over time, the same purging and sampling method should be used consistently at a given well. VOC samples should be collected first and directly into pre-preserved sample containers. Fill all sample containers by allowing the pump discharge to flow gently down the inside of the container with minimal turbulence. Add preservative, as required by analytical methods, to samples immediately after they are collected if the sample containers are not pre-preserved. If determination of filtered metal concentrations is a sampling objective, collect filtered water samples using the same low flow procedures. The use of an in-line filter is required, and the filter size (0.45 um is commonly used) should be based on the sampling objective. Pre-rinse the filter with approximately 25 -50 ml of ground water prior to sample collection. Preserve filtered water sample immediately. Note: filtered water samples are not an acceptable substitute for unfiltered samples when the monitoring objective is to obtain chemical concentrations of total mobile contaminants in ground water for human health risk calculations. Label each sample as collected. Samples requiring cooling (volatile organics, cyanide, etc.) will be placed into a cooler with ice or refrigerant for delivery to the laboratory. Metal samples after acidification to a pH less than 2 do not need to be cooled. 7. Label the sample bottle with an appropriate label and waterproof ink. Record the sample number, location, well purging information, the temperature, pH, specific conductivity, and deviations from protocol and relevant observations, such as colors, odors, or sheens, in the field logbook. Complete the chain of custody. Samples will be stored in a cooler until they are delivered to the laboratory. Adapted from: Low Stress (Low Flow) Purging And Sampling Procedure For The Collection Of Ground Water Samples From Monitoring Wells, US-EPA Region 1, July 30, 1996. Standard References for Monitoring Wells, The Massachusetts Department of Environmental Protection #WSC-310-91. New England Environmental, Inc. Standard Protocols Test Pit Excavation and Sampling Purpose Test pit and trenches are excavated with backhoe equipment to provide detailed visual examination of near surface soil, groundwater, and bedrock conditions. The advantages of test pits over soil borings are as follows: The near surface stratigraphy is exposed, making sample collection and recovery easier in addition to the logging of soils, water levels, and bedrock surface. Information is provided on the lateral and vertical extent of subsurface features. Site-specific safety issues (i.e., test pit stability, contamination potential, and impacts to groundwater) should be considered when designing a test pit program. Installation of monitoring wells in test pits is not recommended. Samples for volatile organic compounds should not be collected from test pit excavations. Procedures Mark the location of potential test pits to the nearest foot. Contact DIG-SAFE at (800) DIG-SAFE (888-344-7233), or Call-Before-You-Dig for properties in CT at (800) 922-4455, prior to any subsurface investigation. In addition, contact local utilities that may have underground services on or near the Site. At the direction of the geologist on-site, the backhoe operator will excavate the test pit in increments. At each increment, the geologist will inspect the test pit and decide whether to collect samples. Test pit excavations will cease if any of the following occurs: – Distinct changes in stratigraphy or materials – Odors – Groundwater or fluid phase contaminants – Drums or other potential waste containers – Utilities not previously identified New England Environmental, Inc. Standard Protocols Excavation will resume only at the direction of the geologist on Site. Unless otherwise specified and the site-specific Health and Safety Plan discusses appropriate procedures, no personnel will enter the test pit. In addition, all test pits will be backfilled on the day of excavation. In most cases, excavation materials will be used to fill the test pit. In the event that highly contaminated material is excavated and it is expected that it will be more cost-effective to remove the soil from the site rather than use it as backfill, excavated soils will be stockpiled on polypropylene and the excavation will be filled with clean soil. Field Log Information At a minimum, field logs for test pit excavation will include the following documentation: Plan and profile sketches of the test pit showing materials encountered, the depth of materials, and sample locations Sketch of the test pit and distance and direction from permanent, identifiable location marks A description of the material removed from the excavation A record of samples collected The presence or absence of water in the test pit and the depth encountered The presence or absence of bedrock in the test pit and the depth encountered Other readings, or measurements taken during excavation, including field screening reading Last updated 9/16/02 APPENDIX E Laboratory Analytical Reports & Groundwater Sampling Log GROUNDWATER SAMPLING LOG Sheet ___1__ of ___1__ DATE: JOB No: CLIENT: 9 Research Drive LOCATION: Amherst, MA 01002 SAMPLER (S): ALH (413) 256-0202 Phone SAMPLING EQUIPMENT: Bailer, peristaltic pump (413) 256-1092 Fax WEATHER CONDITIONS: PURGING EQUIPMENT: WELL I.D. REF. POINT (PVC,PROT. CASING, ETC.) TOTAL DEPTH OF WELL (Ft.) DEPTH TO WATER (Ft.) STANDING WATER HEIGHT (Ft.) * STATIC VOLUME (Gal.) VOLUME PURGED (Gal.) OBSERVED. ODORS Y/N PROD UCT THICK NESS (Ft.) TEMP oF SPECIFIC CONDUCT umho/cm @25 oC NOTES /Analyses MW-1 PVC 14.18 7.90 6.30 1.03 3.1 N -PP13 MW-2S PVC 17.22 5.20 12.00 1.96 5.9 N -PP13 MW-2D PVC 31.73 10.33 21.00 3.42 10.3 N -PP13 MW-3 PVC 23.33 15.98 1.10 0.18 0.5 N -PP13 MW-4 PVC 17.01 16.45 0.56 0.09 0.3 N -PP13 FIELD INSTRUMENTATION: MANUFACTURER /NEE IDENTIFICATION CALIBRATION: INSTRUMENT: MODEL: I.D. NUMBER: NOTES: (CHARACTERIZATION OF ODORS, PRODUCTS, ETC.) * STATIC VOLUME = (Vst) (Vst)=(0.163) x H for 2" PVC wells (Vst)=(0.0408) x D2 x H for all other wells WHERE: Vst = VOLUME (gallons) D = INSIDE WELL DIAMETER (inches) H = STANDING WATER HEIGHT (feet) beautiful 50s Bailer, peristaltic p 10/27/2008 02-2053 Alan Verson Northampton, MA New England Environmental, Inc. 02-2053_GWSamplingLog, 10-27-08 Laboratory Report Report Date: 30-Oct-08 16:39 Final Report Revised Report Re-Issued Report New England Environmental, Inc. 9 Research Drive Amherst, MA 01002 Attn: Lyons Witten ü SPECTRUM ANALYTICAL, INC. Featuring HANIBAL TECHNOLOGY Project: Project Cutlery -Northampton, MA 02-2053 Laboratory ID Client Sample ID Matrix Date Sampled Date Received SA86617-01 MW-1 Ground Water 27-Oct-08 11:30 28-Oct-08 17:16 SA86617-02 MW-2S Ground Water 27-Oct-08 12:30 28-Oct-08 17:16 SA86617-03 MW-2D Ground Water 27-Oct-08 13:30 28-Oct-08 17:16 SA86617-04 MW-3 Ground Water 27-Oct-08 14:30 28-Oct-08 17:16 SA86617-05 MW-4 Ground Water 27-Oct-08 15:30 28-Oct-08 17:16 I attest that the information contained within the report has been reviewed for accuracy and checked against the quality control requirements for each method. These results relate only to the sample(s) as received. All applicable NELAC requirements have been met. Spectrum Analytical holds certification in the State of Massachusetts for the analytes as indicated with an X in the "Cert." column within this report. Please note that the State of Massachusetts does not offer certification for all analytes. Please note that this report contains 12 pages of analytical data plus Chain of Custody document(s). This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. Massachusetts # M-MA138/MA1110 Connecticut # PH-0777 Florida # E87600/E87936 Maine # MA138 New Hampshire # 2538 New Jersey # MA011/MA012 New York # 11393/11840 Pennsylvania # 68-04426/68-02924 Rhode Island # 98 USDA # S-51435 Vermont # VT-11393 Authorized by: Hanibal C. Tayeh, Ph.D. President/Laboratory Director Spectrum Analytical, Inc. is a NELAC accredited laboratory organization and meets NELAC testing standards. Use of the NELAC logo however does not insure that Spectrum is currently accredited for the specific method or analyte indicated. Please refer to our "Quality" web page at www.spectrum-analytical.com for a full listing of our current certifications and and fields of accreditation. States in which Spectrum Analytical, Inc. holds NELAC certification are New York, New Hampshire, New Jersey and Florida. All analytical work for Volatile Organic and Air analysis are transferred to and conducted at our 830 Silver Street location (NY-11840, FL-E87936 and NJ-MA012). Technical Reviewer's Initial: Headquarters: 11 Almgren Drive & 830 Silver Street • Agawam, MA 01001 • 1-800-789-9115 • 413-789-9018 • FAX 413-789-4076 FL Division: 8180 Woodland Center Boulevard • Tampa, FL 33614 • 1-888-497-5270 • 813-888-9507 • FAX 800-480-6435 www.spectrum-analytical.com Page 1 of 12 CASE NARRATIVE: The samples were received 1.2 degrees Celsius, please refer to the Chain of Custody for details specific to temperature upon receipt. An infrared thermometer with a tolerance of +/-2.0 degrees Celsius was used immediately upon receipt of the samples. MADEP has published a list of analytical methods (CAM) which provides a series of recommended protocols for the acquisition, analysis and reporting of analytical data in support of MCP decisions. "Presumptive Certainty" can be established only for those methods published by the MADEP in the MCP CAM. The compounds and/or elements reported were specifically requested by the client on the Chain of Custody and in some cases may not include the full analyte list as defined in the method. According to WSC-CAM 5/2004 Rev.4, Table 11 A-1, recovery for some VOC analytes have been deemed potentially difficult. See below for any non-conformances and issues relating to quality control samples and/or sample analysis/matrix. SW846 6010B Laboratory Control Samples: 8102121-BS1 Analyte out of acceptance range in QC spike but no reportable concentration present in sample. Cadmium Selenium Thallium Zinc Analyte out of acceptance range. Nickel 8102121-BSD1 Analyte out of acceptance range in QC spike but no reportable concentration present in sample. Cadmium Zinc Duplicates: 8102121-DUP1 Source: SA86617-01 Analyses are not controlled on RPD values from sample concentrations that are less than 5 times the reporting level. The batch is accepted based upon the difference between the sample and duplicate is less than or equal to the reporting limit. Zinc * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 2 of 12 MW-1 Sample Identification Matrix 27-Oct-08 11:30 Collection Date/Time Received 28-Oct-08 Client Project # 02-2053 Ground Water SA86617-01 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Cert. Soluble Metals by EPA 200/6000 Series Methods Filtration Lab Filtered N/A 1 EPA 200.7/3005A 29-Oct-08 29-Oct-08 8102120 Soluble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/l 0.0050 1 SW846 6010B 29-Oct-08 29-Oct-08 8102121 7440-38-2 Arsenic BRL mg/l 0.0040 1 " " " " 7440-41-7 Beryllium BRL mg/l 0.0020 1 " " " " 7440-43-9 Cadmium BRL mg/l 0.0025 1 " " " " 7440-47-3 Chromium BRL mg/l 0.0050 1 " " " " 7440-50-8 Copper BRL mg/l 0.0050 1 " " " " 7440-02-0 Nickel 0.0095 mg/l 0.0050 1 " " " " 7439-92-1 Lead BRL mg/l 0.0075 1 " " " " 7440-36-0 Antimony BRL mg/l 0.0060 1 " " " " 7782-49-2 Selenium BRL mg/l 0.0150 1 " " " " 7440-28-0 Thallium BRL mg/l 0.0050 1 " " " " 7440-66-6 Zinc BRL mg/l 0.0445 1 " " " " Soluble Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL mg/l 0.00020 1 EPA 245.1/7470A 29-Oct-08 30-Oct-08 8102122 X * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 3 of 12 MW-2S Sample Identification Matrix 27-Oct-08 12:30 Collection Date/Time Received 28-Oct-08 Client Project # 02-2053 Ground Water SA86617-02 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Cert. Soluble Metals by EPA 200/6000 Series Methods Filtration Lab Filtered N/A 1 EPA 200.7/3005A 29-Oct-08 29-Oct-08 8102120 Soluble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/l 0.0050 1 SW846 6010B 29-Oct-08 29-Oct-08 8102121 7440-38-2 Arsenic BRL mg/l 0.0040 1 " " " " 7440-41-7 Beryllium BRL mg/l 0.0020 1 " " " " 7440-43-9 Cadmium BRL mg/l 0.0025 1 " " " " 7440-47-3 Chromium BRL mg/l 0.0050 1 " " " " 7440-50-8 Copper BRL mg/l 0.0050 1 " " " " 7440-02-0 Nickel BRL mg/l 0.0050 1 " " " " 7439-92-1 Lead BRL mg/l 0.0075 1 " " " " 7440-36-0 Antimony BRL mg/l 0.0060 1 " " " " 7782-49-2 Selenium BRL mg/l 0.0150 1 " " " " 7440-28-0 Thallium BRL mg/l 0.0050 1 " " " " 7440-66-6 Zinc BRL mg/l 0.0445 1 " " " " Soluble Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL mg/mg/l 0.00020 1 EPA 245.1/7470A 29-Oct-08 30-Oct-08 8102122 X * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 4 of 12 MW-2D Sample Identification Matrix 27-Oct-08 13:30 Collection Date/Time Received 28-Oct-08 Client Project # 02-2053 Ground Water SA86617-03 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Cert. Soluble Metals by EPA 200/6000 Series Methods Filtration Lab Filtered N/A 1 EPA 200.7/3005A 29-Oct-08 29-Oct-08 8102120 Soluble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/l 0.0050 1 SW846 6010B 29-Oct-08 29-Oct-08 8102121 7440-38-2 Arsenic BRL mg/l 0.0040 1 " " " " 7440-41-7 Beryllium BRL mg/l 0.0020 1 " " " " 7440-43-9 Cadmium BRL mg/l 0.0025 1 " " " " 7440-47-3 Chromium BRL mg/l 0.0050 1 " " " " 7440-50-8 Copper BRL mg/l 0.0050 1 " " " " 7440-02-0 Nickel BRL mg/l 0.0050 1 " " " " 7439-92-1 Lead BRL mg/l 0.0075 1 " " " " 7440-36-0 Antimony BRL mg/l 0.0060 1 " " " " 7782-49-2 Selenium BRL mg/l 0.0150 1 " " " " 7440-28-0 Thallium BRL mg/l 0.0050 1 " " " " 7440-66-6 Zinc BRL mg/l 0.0445 1 " " " " Soluble Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL mg/mg/l 0.00020 1 EPA 245.1/7470A 29-Oct-08 30-Oct-08 8102122 X * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 5 of 12 MW-3 Sample Identification Matrix 27-Oct-08 14:30 Collection Date/Time Received 28-Oct-08 Client Project # 02-2053 Ground Water SA86617-04 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Cert. Soluble Metals by EPA 200/6000 Series Methods Filtration Lab Filtered N/A 1 EPA 200.7/3005A 29-Oct-08 29-Oct-08 8102120 Soluble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/l 0.0050 1 SW846 6010B 29-Oct-08 29-Oct-08 8102121 7440-38-2 Arsenic BRL mg/l 0.0040 1 " " " " 7440-41-7 Beryllium BRL mg/l 0.0020 1 " " " " 7440-43-9 Cadmium BRL mg/l 0.0025 1 " " " " 7440-47-3 Chromium BRL mg/l 0.0050 1 " " " " 7440-50-8 Copper BRL mg/l 0.0050 1 " " " " 7440-02-0 Nickel BRL mg/l 0.0050 1 " " " " 7439-92-1 Lead BRL mg/l 0.0075 1 " " " " 7440-36-0 Antimony BRL mg/l 0.0060 1 " " " " 7782-49-2 Selenium BRL mg/l 0.0150 1 " " " " 7440-28-0 Thallium BRL mg/l 0.0050 1 " " " " 7440-66-6 Zinc BRL mg/l 0.0445 1 " " " " Soluble Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL mg/l 0.00020 1 EPA 245.1/7470A 29-Oct-08 30-Oct-08 8102122 X * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 6 of 12 MW-4 Sample Identification Matrix 27-Oct-08 15:30 Collection Date/Time Received 28-Oct-08 Client Project # 02-2053 Ground Water SA86617-05 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Cert. Soluble Metals by EPA 200/6000 Series Methods Filtration Lab Filtered N/A 1 EPA 200.7/3005A 29-Oct-08 29-Oct-08 8102120 Soluble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/l 0.0050 1 SW846 6010B 29-Oct-08 29-Oct-08 8102121 7440-38-2 Arsenic BRL mg/l 0.0040 1 " " " " 7440-41-7 Beryllium BRL mg/l 0.0020 1 " " " " 7440-43-9 Cadmium BRL mg/l 0.0025 1 " " " " 7440-47-3 Chromium BRL mg/l 0.0050 1 " " " " 7440-50-8 Copper BRL mg/l 0.0050 1 " " " " 7440-02-0 Nickel 0.0842 mg/l 0.0050 1 " " " " 7439-92-1 Lead BRL mg/l 0.0075 1 " " " " 7440-36-0 Antimony BRL mg/l 0.0060 1 " " " " 7782-49-2 Selenium BRL mg/l 0.0150 1 " " " " 7440-28-0 Thallium BRL mg/l 0.0050 1 " " " " 7440-66-6 Zinc BRL mg/l 0.0445 1 " " " " Soluble Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL mg/l 0.00020 1 EPA 245.1/7470A 29-Oct-08 30-Oct-08 8102122 X * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 7 of 12 Result Units Level Spike Result Source %REC %REC Limits RPD RPD Analyte(s) Flag Limit Soluble Metals by EPA 6000/7000 Series Methods -Quality Control *RDL Batch 8102121 -SW846 3005A Blank (8102121-BLK1) Prepared & Analyzed: 29-Oct-08 Zinc BRL mg/l 0.0445 Selenium BRL mg/l 0.0150 Lead BRL mg/l 0.0075 Antimony BRL mg/l 0.0060 Thallium BRL mg/l 0.0050 Nickel BRL mg/l 0.0050 Chromium BRL mg/l 0.0050 Silver BRL mg/l 0.0050 Cadmium BRL mg/l 0.0025 Copper BRL mg/l 0.0050 Arsenic BRL mg/l 0.0040 Beryllium BRL mg/l 0.0020 LCS (8102121-BS1) Prepared & Analyzed: 29-Oct-08 Nickel 1.44 QC1 mg/l 0.0050 1.25 116 85-115 Antimony 1.38 mg/l 0.0060 1.25 111 85-115 Zinc 1.48 QC2 mg/l 0.0445 1.25 119 85-115 Lead 1.43 mg/l 0.0075 1.25 114 85-115 Thallium 1.46 QC2 mg/l 0.0050 1.25 116 85-115 Selenium 1.46 QC2 mg/l 0.0150 1.25 117 85-115 Arsenic 1.40 mg/l 0.0040 1.25 112 85-115 Chromium 1.35 mg/l 0.0050 1.25 108 85-115 Copper 1.38 mg/l 0.0050 1.25 110 85-115 Cadmium 1.49 QC2 mg/l 0.0025 1.25 119 85-115 Silver 1.37 mg/l 0.0050 1.25 1.25 109 85-115 Beryllium 1.41 mg/l 0.0020 1.25 113 85-115 LCS Dup (8102121-BSD1) Prepared & Analyzed: 29-Oct-08 Thallium 1.42 mg/l 0.0050 1.25 114 85-115 2 20 Antimony 1.36 mg/l 0.0060 1.25 109 85-115 2 20 Lead 1.41 mg/l 0.0075 1.25 112 85-115 2 20 Nickel 1.42 mg/l 0.0050 1.25 114 85-115 2 20 Zinc 1.45 QC2 mg/l 0.0445 1.25 116 85-115 2 20 Selenium 1.44 mg/l 0.0150 1.25 115 85-115 2 20 Arsenic 1.37 mg/l 0.0040 1.25 110 85-115 2 20 Copper 1.36 mg/l 0.0050 1.25 109 85-115 2 20 Chromium 1.33 mg/l 0.0050 1.25 107 85-115 1 20 Beryllium 1.37 mg/l 0.0020 1.25 110 85-115 3 20 Cadmium 1.46 QC2 mg/l 0.0025 1.25 117 85-115 2 20 Silver 1.34 mg/l 0.0050 1.25 107 85-115 2 20 Duplicate (8102121-DUP1) Prepared & Analyzed: 29-Oct-08 Source: SA86617-01 Selenium BRL mg/l 0.0150 BRL 20 Zinc 0.0279 J,QR8 mg/l 0.0445 0.0197 34 20 Thallium BRL mg/l 0.0050 BRL 20 Lead BRL mg/l 0.0075 BRL 20 Antimony BRL mg/l 0.0060 BRL 20 Nickel 0.0100 mg/l 0.0050 0.0095 5 20 * Reportable Detection Limit BRL = Below Reporting Limit This laboratory laboratory report is not valid without an authorized signature on the cover page. Page 8 of 12 Result Units Level Spike Result Source %REC %REC Limits RPD RPD Analyte(s) Flag Limit Soluble Metals by EPA 6000/7000 Series Methods -Quality Control *RDL Batch 8102121 -SW846 3005A Duplicate (8102121-DUP1) Prepared & Analyzed: 29-Oct-08 Source: SA86617-01 Silver BRL mg/l 0.0050 BRL 20 Cadmium BRL mg/l 0.0025 BRL 20 Beryllium BRL mg/l 0.0020 BRL 20 Arsenic BRL mg/l 0.0040 BRL 20 Copper BRL mg/l 0.0050 BRL 20 Chromium BRL mg/l 0.0050 BRL 20 Matrix Spike (8102121-MS1) Prepared & Analyzed: 29-Oct-08 Source: SA86617-02 Nickel 1.40 mg/l 0.0050 1.25 BRL 112 75-125 Lead 1.38 mg/l 0.0075 1.25 BRL 110 75-125 Antimony 1.34 mg/l 0.0060 1.25 BRL 107 75-125 Thallium 1.39 mg/l 0.0050 1.25 BRL 111 75-125 Selenium 1.42 mg/l 0.0150 1.25 BRL 114 75-125 Zinc 1.46 mg/l 0.0445 1.25 0.0245 115 75-125 Chromium 1.36 mg/l 0.0050 1.25 BRL 108 75-125 Cadmium 1.44 mg/l 0.0025 1.25 BRL 115 75-125 Beryllium 1.39 mg/l 0.0020 1.25 BRL 111 75-125 Silver 1.36 mg/l 0.0050 1.25 BRL 109 75-125 Copper 1.38 mg/l 0.0050 1.25 BRL 111 75-125 Arsenic 1.39 mg/l 0.0040 1.25 BRL 111 75-125 Matrix Spike Dup (8102121-MSD1) Prepared & Analyzed: 29-Oct-08 Source: SA86617-02 Antimony 1.36 mg/l 0.0060 1.25 BRL 109 75-125 2 20 Thallium 1.41 mg/l 0.0050 1.25 BRL 113 75-125 1 20 Selenium 1.45 mg/l 0.0150 1.25 BRL 116 75-125 2 20 Nickel 1.41 mg/l 0.0050 1.25 BRL 113 75-125 1 20 Zinc 1.48 mg/l 0.0445 1.25 0.0245 116 75-125 1 20 Lead 1.39 mg/l 0.0075 1.25 BRL 111 75-125 1 20 Copper 1.40 mg/l 0.0050 1.25 BRL 112 75-125 2 20 Arsenic 1.40 mg/l 0.0040 1.25 BRL 112 75-125 1 20 Beryllium 1.39 mg/l 0.0020 1.25 BRL 111 75-125 0.3 20 Silver 1.38 mg/l 0.0050 1.25 BRL 111 75-125 2 20 Cadmium 1.46 mg/l 0.0025 1.25 BRL 117 75-125 2 20 Chromium 1.38 mg/l 0.0050 1.25 BRL 111 75-125 2 20 Post Spike (8102121-PS1) Prepared & Analyzed: 29-Oct-08 Source: SA86617-02 Zinc 1.48 mg/l 0.0445 1.25 0.0245 116 80-120 Antimony 1.31 mg/l 0.0060 1.25 BRL 105 80-120 Thallium 1.43 mg/l 0.0050 1.25 BRL 114 80-120 Lead 1.40 mg/l 0.0075 1.25 BRL 112 80-120 Nickel 1.42 mg/l 0.0050 1.25 BRL 113 80-120 Selenium 1.45 mg/l 0.0150 1.25 BRL 116 80-120 Arsenic 1.40 mg/l 0.0040 1.25 BRL 112 80-120 Beryllium 1.38 mg/l 0.0020 1.25 BRL 111 80-120 Cadmium 1.46 mg/l 0.0025 1.25 BRL 117 80-120 Chromium 1.37 mg/l 0.0050 1.25 BRL 110 80-120 Copper 1.39 mg/l 0.0050 1.25 BRL 112 80-120 Silver 1.37 mg/l 0.0050 1.25 BRL 110 80-120 * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 9 of 12 Result Units Level Spike Result Source %REC %REC Limits RPD RPD Analyte(s) Flag Limit Soluble Metals by EPA 200 Series Methods -Quality Control *RDL Batch 8102122 -EPA200/SW7000 Series Blank (8102122-BLK1) Prepared: 29-Oct-08 Analyzed: 30-Oct-08 Mercury BRL mg/l 0.00020 LCS (8102122-BS1) Prepared: 29-Oct-08 Analyzed: 30-Oct-08 Mercury 0.00446 mg/l 0.00020 0.00500 89 85-115 Duplicate (8102122-DUP1) Prepared: 29-Oct-08 Analyzed: 30-Oct-08Source: SA86617-01 Mercury BRL mg/l 0.00020 BRL 20 Matrix Spike (8102122-MS1) Prepared: 29-Oct-08 Analyzed: 30-Oct-08Source: SA86617-03 Mercury 0.00470 mg/l 0.00020 0.00500 BRL 94 75-125 Matrix Spike Dup (8102122-MSD1) Prepared: 29-Oct-08 Analyzed: 30-Oct-08Source: SA86617-03 Mercury 0.00482 mg/l 0.00020 0.00500 BRL 96 75-125 3 20 Post Spike (8102122-PS1) Prepared: 29-Oct-08 Analyzed: 30-Oct-08Source: SA86617-03 Mercury 0.00455 mg/l 0.00020 0.00500 BRL 91 85-115 * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 10 of 12 Notes and Definitions QC1 Analyte out of acceptance range. QC2 Analyte out of acceptance range in QC spike but no reportable concentration present in sample. Analyses are not controlled on RPD values from sample concentrations that are less than 5 times the reporting level. The batch is accepted based upon the difference between the sample and duplicate is less than or equal to the reporting limit. QR8 RPD Relative Percent Difference dry Sample results reported on a dry weight basis BRL Below Reporting Limit -Analyte NOT DETECTED at or above the reporting limit NR Not Reported J Detected but below the Reporting Limit; therefore, result is an estimated concentration (CLP J-Flag). A plus sign (+) in the Method Reference column indicates the method is not accredited by NELAC. Laboratory Control Sample (LCS): A known matrix spiked with compound(s) representative of the target analytes, which is used to document laboratory performance. Matrix Duplicate: An intra-laboratory split sample which is used to document the precision of a method in a given sample matrix. Matrix Spike: An aliquot of a sample spiked with a known concentration of target analyte(s). The spiking occurs prior to sample preparation and analysis. A matrix spike is used to document the bias of a method in a given sample matrix. Method Blank: An analyte-free matrix to which all reagents are added in the same volumes or proportions as used in sample processing. The method blank should be carried through the complete sample preparation and analytical procedure. The method blank is used to document contamination resulting from the analytical process. Method Detection Limit (MDL): The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is greater than zero and is determined from analysis of a sample in a given matrix type containing the analyte. Reportable Detection Limit (RDL): The lowest concentration that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. For many analytes the RDL analyte concentration is selected as the lowest non-zero standard in the calibration curve. While the RDL is approximately 5 to 10 times the MDL, the RDL for each sample takes into account the sample volume/weight, extract/digestate volume, cleanup procedures and, if applicable, dry weight correction. Sample RDLs are highly matrix-dependent. Surrogate: An organic compound which is similar to the target analyte(s) in chemical composition and behavior in the analytical process, but which is not normally found in environmental samples. These compounds are spiked into all blanks, standards, and samples prior to analysis. Percent recoveries are calculated for each surrogate. Validated by: Hanibal C. Tayeh, Ph.D. Nicole Leja * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 11 of 12 MADEP MCP ANALYTICAL METHOD REPORT CERTIFICATION FORM Sample matrices: MCP SW-846 Methods Used 8260B 8151A 8330 6010B 7470A/1A 8270C 8081A VPH 6020 9014M ² 8082 8021B EPH 7000S ³ 7196A MADEP RTN ¹: 1 List Release Tracking Number (RTN), if known 2 M -SW-846 Method 9014 or MADEP Physiologically Available Cyanide (PAC) Method 3 S -SW-846 Methods 7000 Series List individual method and analyte An affirmative response to questions A, B, C and D is required for "Presumptive Certainty" status Were all samples received by the laboratory in a condition consistent with that described on the Chain of Custody documentation for the data set? Were all QA/QC procedures required for the specified analytical method(s) included in this report followed, including the requirement to note and discuss in a narrative QC data that did not meet appropriate performance standards or guidelines? Does the data included in this report meet all the analytical requirements for "Presumptive Certainty", as described in Section 2.0 (a), (b), ((c) and (d) of the MADEP document CAM VII A, "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of Analytical Data"? ABC Yes Yes Yes No No No A response to questions E and F below is required for "Presumptive Certainty" status VPH and EPH methods only: Was the VPH or EPH method conducted without significant D modifications (see Section 11.3 of respective methods)? Were all analytical QC performance standards and recommendations for the specified methods achieved? Were results for all analyte-list compounds/elements for the specified method(s) reported? EF All negative responses are addressed in a case narrative on the cover page of this report. Yes No Yes No I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. Hanibal C. Tayeh, Ph.D. President/Laboratory Director Date: Yes No This form provides certifications for the following data set: 10/30/2008 Laboratory Name: Spectrum Analytical, Inc. -Agawam, MA Project Location: Cutlery -Northampton, MA Project #: 02-2053 üüü ü ü ü Ground Water SA86617-01 through SA86617-05 ü * Reportable Detection Limit BRL = Below Reporting Limit This laboratory report is not valid without an authorized signature on the cover page. Page 12 of 12 APPENDIX F Risk Assessment EnvironmentalSafetyHealthGeotechnical O’Reilly, Talbot & Okun E N G I N E E R I N G 19 West Main Street [ A S S O C I A T E S ] Suite 205 Westborough, MA 01581 Tel 508 366 6409 Fax 508 366 9826 www.oto-env.com August 31, 2009 File No: 5028-02-01 Prepared for: New England Environmental, Inc. 9 Research Drive Amherst, Massachusetts 01002 METHOD 3 RISK CHARACTERIZATION Former Cutlery Raceway 320-360 Riverside Drive Northampton, Massachusetts RTN 1-13320 Prepared by: O'Reilly, Talbot & Okun Associates, Inc. 19 West Main Street, Suite 205 Westborough, Massachusetts 01581 O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G TABLE OF CONTENTS Page 1.0 Introduction 1 1.1 Site History and Investigations 2 2.0 Human Health Risk Assessment 6 2.1 Current and Reasonably Foreseeable Future Site Use 6 2.1.1 Soil and Groundwater Categories 6 2.1.2 Background Concentrations 9 2.2 Hazard Identification 10 2.2.1 Identification of Constituents of Concern 10 2.2.2 Toxicity Profiles 12 2.2.3 Identification of Applicable or Suitably Analogous Standards 12 2.3 Dose-Response Assessment 13 2.3.1 Threshold (Non-carcinogenic) Effects 13 2.3.2 Non-threshold (Carcinogenic) Effects 14 2.3.3 Relative Absorption Factors 14 2.4 Exposure Assessment 15 2.4.1 Development of Exposure Profiles 15 2.4.1.1 Identification of Potential Human Receptors and Exposure Points 15 2.4.1.2 Identification of Exposure Routes 16 2.4.1.3 Exposure Profile Summary 16 2.4.2 Development of Exposure Factors 16 2.4.3 Exposure Point Concentrations (EPCs) 17 2.4.4 Calculation of Average Daily Doses 18 2.5 Risk Characterization 20 2.5.1 Non-Cancer Risk 20 2.5.2 Cancer Risk 21 2.5.3 Summary of Findings 21 2.6 Uncertainty Analysis 22 3.0 Characterization of Risk of Harm to Public Welfare 24 4.0 Characterization of Risk of Harm to Safety 25 5.0 Environmental Risk Characterization 25 5.1 Aquatic Habitat Screening 26 5.2 Terrestrial Habitat Screening 27 6.0 Conclusions 28 i O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G TABLE OF CONTENTS (cont’d.) Page REFERENCES 30 TABLES TABLE 1 Groundwater Sample Laboratory Results TABLE 2-1 OTO Brownfields Investigation (June 2006) -Table 2 -Groundwater Analytical Results TABLE 2-2 OTO Brownfields Investigation (June 2006) -Table 3 -River Bank Soil Sample Analytical Results TABLE 2-3 OTO Brownfields Investigation (June 2006) -Table 4 -Surface Water Analytical Results TABLE 2-4 OTO Brownfields Investigation (June 2006) -Table 5 -Sediment Analytical Results TABLE 3 Data Summary Table TABLE 4-1 IRA Plan (NEE 6/2006) -Table 1-SA-1 -Confirmatory Soil Summary: SA-1 Excavation TABLE 4-2 IRA Plan (NEE 6/2006) -Table 1-SA-2 -Confirmatory Soil Summary: SA-2 Excavation TABLE 4-3 IRA Plan (NEE 6/2006) -Table 1-SA-3 -Confirmatory Soil Summary: SA-3 Excavation TABLE 4-4 IRA Plan (NEE 6/2006) -Table 1-SA-4 -Confirmatory Soil Summary SA-4 Excavation TABLE 4-5 IRA Plan (NEE 6/2006) -Table 1-SA-5 -Confirmatory Soil Summary: SA-5 Excavation TABLE 4-6 IRA Completion (NEE 01/2008) -Table 1 -Laboratory Results -PP13 Metals in Soil TABLE 5 IRA Plan (NEE 6/2006) -Table 2 -Laboratory Results -PP13 Metals in Soil TABLE 6-1 AOC-1 Maximum and Minimum Concentrations of Detected Contaminants TABLE 6-2 AOC-2 & AOC-3 Maximum and Minimum Concentrations of Detected Contaminants TABLE 7 Toxicity Values for Site Compounds TABLE 8 Relative Absorption Factors (RAFs) TABLE 9 Exposure Assumptions and Equations for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates ii O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G TABLE OF CONTENTS (cont’d.) TABLE 10 Groundwater Exposure Point Concentrations (EPCs) TABLE 11 Soil Exposure Point Concentrations (EPCs) TABLE 12 Calculation of Risk Estimates for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates TABLE 13 Summary of Hazard Indices and Risk Estimates APPENDICES APPENDIX A Toxicity Profiles iii O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G 1.0 INTRODUCTION This Method 3 risk characterization has been prepared by O’Reilly, Talbot & Okun Associates, Inc. (OTO) to assess whether oil and/or hazardous material (OHM) at the Former Cutlery Raceway at 320-360 Riverside Drive in Northampton, Massachusetts poses a Condition of No Significant Risk or a Condition of No Substantial Hazard within the meaning of the Massachusetts Contingency Plan (MCP 310 CMR 40.0990 and 40.0956, respectively). Three methods for Risk Characterization under the MCP, which vary in detail and circumstances of use, have been developed to evaluate a disposal site, as described in 310 CMR 40.0941(3) and 40.0942. These three methods provide equivalent levels of protection to health, public welfare, and the environment. A Method 3 approach is considered applicable for this Site because Site-specific methodologies (e.g., exposure assumptions concerning Site use) have been used. As defined in 310 CMR 40.0990, a Method 3 Risk Characterization for the purposes of demonstrating a Condition of No Significant Risk evaluates the risks to human health, public welfare, safety, and the environment for all current and reasonably foreseeable future Site activities and uses. As defined in 310 CMR 40.0956, the focus of a Substantial Hazard Evaluation is on possible exposures to human and environmental receptors, considering the current use(s) of the disposal site and the surrounding environment and, where applicable, any Activity and Use Limitations (AULs) for the Site. The risk characterization has been completed in accordance with the MCP, 310 CMR 40.0900, and applicable Massachusetts Department of Environmental Protection (MassDEP) guidance (MassDEP, 1992 through 2008). Human health risks for the Site are assessed in Section 2.0 of this report. Risk of harm to public welfare, including comparisons to Upper Concentration Limits (UCLs), is presented in Section 3.0. Characterization of risk of harm to safety is described in Section 4.0. The environmental risk characterization can be found in Section 5.0. Section 6.0 presents conclusions regarding the overall significance of Site risk. The Method 3 is based on information and analytical data collected at the Site and provided to OTO by New England Environmental, Inc. (NEE) of Amherst, Massachusetts. This information and data are summarized in the NEE Class A-3 & Class C-1 Partial Response Action Outcome (RAO-P) Statements with accompanying AULs (NEE, 2009). The Class A-3 RAO-P pertains to the two southerly lots (firehouse and cutlery buildings); and the Class C-1 RAO-P pertains to the northern portion of the Site (raceway/levee). Additional information for the Method 3 Risk Characterization was also obtained from NEE’s MCP Phase II & Phase III Submittal (2003). Northampton Cutlery 1 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G OTO has not conducted independent testing or Site characterization activities, other than specifically stated, and has relied on the NEE supplied information to provide adequate characterization of the nature and extent of Site contamination, as defined in the MCP. 1.1 Site History and Investigations A detailed description of the Site history, investigations, and remediation is presented in the above-referenced reports. A summary, relevant to the RAO-Ps, is presented below. The Site is the former raceway that carried water from the Mill River to the former Northampton Cutlery mill building (Figure 3 of the RAO-P Report). A steep bank separates the former raceway from the east bank of the Mill River, approximately 15 feet below. The course of the former raceway follows a long, relatively flat strip of land approximately 40 to 60 feet wide. The strip extends in the north-south direction and is bordered on the east by Riverside Drive. A slight rise of 5 to 10 feet and a guardrail separate the flat strip of land from the road. The former raceway is not directly visible at most of the ground surface because it has been filled and is now covered in different portions by trees, shrubs, organic debris, and the Cutlery Building and Valley Home Improvement (VHI) parking lots. The course of the raceway has been determined by using historic maps and inspections of ground topography. The downstream end of the raceway abuts the back (western-most) portion of the Cutlery Building. Following its course upstream it then winds north through (under) the now paved parking lots of the Cutlery Building (Lot 32) and VHI (Lot 76) behind the former firehouse building, and then continues in the narrow strip of undeveloped land between Riverside Drive and the Mill River to the northern portion of Lot 77, where water entered the raceway at a former dam. The raceway was built in the mid-1800’s and carried water until the mid-1900’s. Some time in the 1940’s or 1950’s, the water from the raceway was no longer needed and it was drained. For the next 20 to 30 years, the southerly portion of the raceway, extending approximately 600 feet north from the Cutlery Building (400 feet into Lot 77) was used as a dumping site for household garbage, demolition debris, and industrial wastes. The levee that separates the raceway from the river has also been found to contain hazardous materials (metals). The levee becomes topographically prominent from approximately 600 ft to 880 ft north of the Cutlery Building, where the former raceway has not been filled. The MCP Disposal Site has been divided into three Areas of Concern (AOCs): AOC-1: This portion of the Site includes the northwestern portion of the southerly Cutlery Lot 32 and the western portion of the VHI Lot 76 as shown on Figures 3 and 5 of the RAO-P Report. Northampton Cutlery 2 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G This includes the paved parking lots behind the Cutlery building and the VHI building and the sloped bank down to the Mill River west of these parking lots. AOC-1 is the subject of the Class A-3 RAO-P. AOC-2 and AOC-3: These areas of the Site occupy the narrow strip of undeveloped land between Riverside Drive and the Mill River, from the northern VHI property line to the northern portion of Lot 77, where water entered the raceway at a former dam. AOC-2 includes the filled portion of the raceway, but does not include the bank of the Mill River west of this section. AOC-3 includes the entire exposed levee from the northerly end of AOC-2 north to the chain link fence at the north end of the Site. AOC-2 and AOC-3 are the subject of the Class C-1 RAO-P as response actions to achieve a Condition of No Significant Risk and a permanent solution are not currently feasible. Investigations by NEE and other previous consultants documented the character of the fill material (contains solid and industrial waste, and demolition debris), and the excavation and stabilization of these materials on Site. From 2005 to June 2009, NEE has conducted numerous Site visits to monitor the progress of bank stabilization, fence installations, sign posting, and sediment trap implementation. OTO conducted sampling at the Site in 2006 as part of a Brownfields Investigation for the City of Northampton. A summary of the data collected at the Site, which includes the Sample ID numbers, parameters analyzed, EPA Methods used, date of sampling, media sampled, use of the data within this investigation, and a summary of laboratory statistics related to the Data Usability Assessment is included in Table 3. In areas of AOC-1, where heavy metals were identified in excess of their respective Upper Concentration Limits (UCLs), this material was excavated in 2004 and 2006 and moved to the existing soil stockpile within AOC-2. This includes several areas under the Cutlery and VHI parking parking lots, and an area on the bank of the Mill River on the Cutlery property (“CB area”). Confirmatory soil samples from the five excavation areas and the CB excavation area indicated that the UCL contaminated soil had been removed from AOC-1 (Tables 4-1 through 4-6). Changes to several UCLs were incorporated in the 2006 MCP “Wave 2 Changes”. As a result, the soil sample CB-12 is now identified as containing lead (4,480 mg/kg) and antimony (471 mg/kg) at concentrations in excess of their respective UCLs (3,000 mg/kg and 400 mg/kg) (Table 4-6). Residual contamination in this and other areas of AOC-1 is still present in soil. The areas of the parking lot where residual contamination remains have been paved and this pavement will be maintained in good condition as an obligation and condition of the Class A-3 RAO – P and AUL. The remaining metals-impacted soil along the bank leading down to the Mill River (including CB-12) was physically stabilized in place to prevent any further erosion and these erosion controls will be maintained in good condition to restrict access to underlying Northampton Cutlery 3 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G soil as specified in the AUL. The unpaved areas within AOC-1 have been stabilized with erosion controls, fenced off with a chain link fence with signs, and this fence will be maintained in good condition as part of the AUL. Elevated concentrations of metals have been identified in surface and near-surface soils along the raceway. Elevated EPH and PCB concentrations have also been identified in the fill, but in isolated areas. North of the VHI property, near AOC-2, the river bank contains metals concentrations that are above the Method 1 S-1/GW-2/GW-3 standards, but below UCLs. At the area where the levee becomes topographically prominent and AOC-3 begins, the concentrations of metals (antimony, chromium, lead, and/or nickel) in river bank samples exceed the respective UCLs (OTO 2006 samples, Table 2-2). Elevated concentrations of metals have also been identified in surface and near-surface soils along the levee. In 2005, NEE attempted to excavate the metals impacted soil along the levee and consolidate this soil within the stockpile in AOC-2. This objective was not achieved, as the total volume and extent of metals impacted soil was under-estimated. The NEE Interim Construction Report (2005) details these efforts and reported that 38 of the 40 confirmatory soil samples collected after this excavation had concentrations of metals above Method 1 standards, and 28 of the samples have concentrations above UCLs (Table 5). Concentrations of metals are still present along the levee in AOC-3 (under the physical stabilization) and within portions of the stockpile in AOC-2. These impacted soils are readily identified in the field by their bright colors (red/pink and green), and test pit observations confirm that the impact from these soils does not typically extend to the natural-colored soil (tan and brown) below them. After the 2005 excavation effort along the levee, the project focus shifted from attempting remediation to physical stabilization toward the goal of Class C RAO-P. According to NEE, there have been no significant detections of elevated concentrations of metals within the un-filled portion of the raceway adjacent to the exposed levee. Sediment samples from the interior wetland in this area did contain concentrations of arsenic, cadmium, chromium, mercury, and lead above the MassDEP Sediment Threshold Effects Concentrations (TEC) Benchmarks, but below Method 1 soil standards. In AOC-3, the bank of the Mill River was stabilized using erosion control fabric and grass seed. One section of the stone rip-rap at the base of the bank was re-built in an effort to control erosion. These activities have stabilized this portion of the Site and dramatically reduced erosion. Bank stabilization was not required in AOC-2 as this portion of the Site is relatively flat, the bank is further from the Mill River, and is thickly wooded with mature trees. The filled portions of the raceway in AOC-2 were used as the location of a soil stockpile accepting UCL soil soil from AOC-1 and AOC-3. The fill in this area was similar in nature to the stockpile soil, in that it had been found to exceed UCL concentrations of several metals in multiple places, so placement of the stockpile in AOC-2 did not make this Northampton Cutlery 4 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G location worse. The stockpile was then graded in such a way as to reduce its height and was covered in geo-textile fabric and loam. The pile was then seeded with grass to prevent erosion. A five-foot high chain link fence was then installed at both ends of AOC-2 and AOC-3 and along the entire length of Riverside Drive in such a fashion as to isolate these areas from trespassers. Maintenance of the erosion controls and fencing, as well as restrictions to activities accessing impacted soils, are specified in the Class C-1 RAO-P and AUL for AOC-2 and AOC-3. Detections of metals of concern for the Site within river sediment are similar in concentrations in both upgradient and downgradient samples (Interim Construction Report (NEE, 2005)) and OTO transect samples in 2006 (Table 2-4). These data indicate that while the Site may have contributed metals to the river sediment, the Site is not a major contributor, or the sole contributor. Surface water samples (OSW-1 through -3) collected from the river by OTO in 2006 indicated that concentrations of the metals present at the Site were not present at significant concentrations within the river water at that time (Table 2-3). Groundwater samples were historically collected at the Site from 2001 to 2003; and most recently at the Site in 2006 by OTO and in 2008 by NEE. The groundwater laboratory results (Tables 1 and 2-1) suggest that nickel contamination from the raceway fill does leach to the groundwater in detectable concentrations in the last two rounds of sampling in MW-1 (AOC-1) and MW-4 filtered sample (AOC-2 and AOC-3). However, the concentrations were below the applicable MCP Method 1 GW-3 standard. The concentration of lead in CR-6 (AOC-2) (15.8 ug/L) slightly exceeded the MCP Method 1 GW-3 standard (10 ug/L). Arsenic, chromium, copper, and zinc were also detected in various monitoring wells at concentrations below the GW-3 standard. The objective of the Method 3 Risk Characterization is to determine if concentrations of OHM at the Site represent a Condition of No Significant Risk under current and foreseeable future Site Conditions for AOC-1; and a Condition of No Substantial Hazard for current uses for AOC-2 and AOC-3. The Method 3 Risk Characterizations have been completed under the assumption that the terms and conditions of the AULs are fully implemented. The analytical data used in the Method 3 Risk Characterization are presented in Tables 1 through 5 (NEE and OTO data sets) from the NEE 2009 RAO-P Report. NEE compiled that data from these two sets of tables into the maximum and minimum concentrations of detected contaminants in AOC-1 media (Table 6-1) and AOC-2 and AOC-3 media (Table 6-2). Northampton Cutlery 5 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G 2.0 HUMAN HEALTH RISK ASSESSMENT 2.1 Current and Reasonably Foreseeable Future Site Use The Site is a former water-powered industrial mill that manufactured cutlery tableware. The current use of AOC-1’s northern portion of the Cutlery Building, VHI office (former Firehouse Building), and associated parking lots is for various small businesses. In addition, a portion of AOC-1, the bank of the Mill River (CB Area), is unpaved and covered with erosion control materials and is separated from the Cutlery and VHI parking lots by a 4-foot high chain-link fence. There are no residential uses of AOC-1. One loft apartment is located in a western section of the Cutlery Building, but is not located within the Site boundaries. It is likely that the foreseeable future use will be similar. The AUL for AOC-1 allows for use of the northern portion of AOC-1 for multi-family residential and commercial activities; and short-term construction and utility/asphalt/erosion repair activities on AOC-1. AOC-2 and AOC-3 are not currently used for any purposes. A 5-foot chain link fence surrounds the north, east, and south sides of the AOC-2 and AOC-3 AUL area. The AUL for these AOCs restricts future use for residential, commercial, industrial, agricultural or recreational purposes. NEE has identified no schools, hospitals, nursing homes or other institutions located within 500 feet of the Site. A former school building is located approximately 400 feet southeast of the Site along Riverside Drive. This building is currently used for administrative and storage purposes only. The Site and surrounding properties are provided with municipal water. 2.1.1 Soil and Groundwater Categories Categories for soil and groundwater have been developed by the MassDEP to facilitate the characterization of risk at MCP sites. The identification of applicable groundwater and soil categories at the Site has been conducted in accordance with 310 CMR 40.0993(2). Soil Category Identification of of the applicable soil category requires an assessment of three factors identified in 40.0930 of the MCP. These are accessibility, frequency of use, and intensity of use. Each of these factors must be assessed for the current use scenario and for a reasonably foreseeable future use scenario. Northampton Cutlery 6 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G For AOC-1, soils with detected concentrations of OHM are located in paved areas and under buildings or at 0-3 feet in unpaved areas covered by AUL required/maintained erosion controls on the bank of the Mill River. A 4-foot chain link fence separates the paved areas from the river bank. As defined in the MCP, the soils at 0 to 15 feet in depth and under pavement are considered to be “potentially accessible” for exposure. The soils under buildings are considered to be “isolated”. The soils on the river bank with erosion controls, fenced, and gated would be considered to be “potentially accessible” with disturbance of the erosion control managed under the AUL. AOC-1, excluding the river bank, is currently used for business offices and associated parking. Therefore, Site worker frequency of use is considered to be high. Patrons and visitors to the businesses, which may include children and adults, is considered to occur on a low to high frequency. Intensity of use by these receptors at AOC-1 is considered low, since soils are paved or under erosion controls, and no intrusive activities into soil by these receptors are likely to occur. The AUL for AOC-1 restricts the use of the AUL area for single-family residence, school, daycare, nursery, playground, recreational areas, and/or other such activities or uses where a child is likely to be present and engage in high-intensity, direct contact activities. Routine maintenance of erosion controls and short-term (6 months or less) construction and utility work may occur at AOC-1 and is allowed under the AUL. The frequency of this activity is considered low and the intensity of use is considered high (i.e., short-term (6 months or less) excavation activities occurring at infrequent and irregular intervals). Landscapers would be expected to have a similar or lower frequency of use as utility workers. Given this set of circumstances, the applicable soil category for the impacted soils at AOC-1 under current and foreseeable future conditions are S-2 and S-3. For AOC-2 and AOC-3, impacted soils are located at the surface and near surface (0-3’) and deeper and unpaved and under erosion control materials. Therefore, these soils are considered to be “accessible” and “potentially accessible”, respectively. There is no current use of AOC-2 and AOC-3. The AUL for these AOCs restricts residential, commercial, industrial, agricultural or recreational purposes. The five-foot high chain link fence is located on the north, east, and south sides of the AUL area. The Mill River and a stone retaining wall are located on the western side of AOC-2 and AOC-3. Therefore, the frequency and intensity of use by Site workers, and the general public is low. Northampton Cutlery 7 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G Routine maintenance of erosion controls and short-term construction and utility work is allowed in the AUL for AOC-2 and AOC-3. However, these activities are not occurring under current use. The frequency of this activity is considered low and the intensity of use is considered high (i.e., short-term (6 months or less) excavation activities occurring at infrequent and irregular intervals). Given this set of circumstances, there is no current exposure to soils at AOC-2 and AOC-3; and the applicable soil category for the impacted soils under foreseeable future conditions is S-3. Groundwater Categories MassDEP has identified three groundwater exposure categories (GW-1, GW-2, and GW-3) under the MCP, each reflective of a type of risk that may be posed by OHM in groundwater. Different combinations of these criteria are applicable at sites depending upon the groundwater resource characteristics. GW-1 The GW-1 category is applicable to locations locations where groundwater is, or may in the future be, a drinking water source. The Site is serviced by municipal water. No private drinking water supplies were identified within 500 feet of the Site. According to the MassDEP BWSC Site Scoring Map, the Site is not located within any of the following features: 1. Interim Wellhead Protection Area (IWPA), 2. Mapped Potentially Productive Aquifer (PPA), 3. Approved Zone II of a Public Water Supply, 4. Zone A of a Class A Surface Water Body, or 5. An area designated by a municipality specifically for the protection of groundwater quality to ensure its availability for use as a source of potable water supply. According to NEE (2003 and 2009), there are no known water supplies within a one-half mile radius of the Site. Two public water supply wells are located adjacent to upstream tributaries of the Mill River at a distance between one-half mile and one mile. Both of these wells are upgradient of the Site. Therefore, the GW-1 category is not applicable to the Site. Northampton Cutlery 8 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G GW-2 The GW-2 category applies to locations where OHM may volatilize from the groundwater and migrate into an occupied structure. Wells with an average annual depth to groundwater of 15 feet or less bgs and located within 30 feet of a currently occupied or future planned building meet the criteria of GW-2. Observations in monitoring wells MW-1, -2S, -3, and -4, each installed to depths ranging from 15 to 20 feet, have revealed a thin aquifer perched on the glacial till. The saturated zone is estimated to be only 0.5 to 1.5 feet thick. Water level measurements in these four wells were approximately 8 feet (MW-2S), 9 feet (MW-1), 13 feet (MW-1), and 14.5 feet (MW-4). Occupied buildings are only present on AOC-1. Therefore, the GW-2 category applies in AOC-1, but not in AOC-2 and AOC-3. GW-3 The GW-3 category is intended to protect environmental receptors in surface water that may be exposed to OHM when groundwater discharges to surface water. For all MCP sites, the GW-3 groundwater category is applicable. The Mill River flows immediately adjacent to, and west of, the Site from north to south. The river is approximately 30 feet wide and approximately 2 to 3 feet deep in the center during the winter. Groundwater level measurements and contours indicate that Site groundwater flows westerly toward the Mill River. A second surface water body is a seasonal pool centered in the wetland in the non-filled portion of the raceway. This wetland is fed by the storm drain system along Riverside Drive, and has a steady base flow during the spring months. This base flow dries up in the fall as groundwater levels drop. There is no surface exit of water from this wetland as the water seeps into the ground, migrates under the levee, and enters the Mill River. Given this set of circumstances, the applicable groundwater categories for the Site are GW-2 and GW-3 for AOC-1; and GW-3 for AOC-2 and AOC-3. 2.1.2 Background Concentrations VPH, EPH, PCBs, and metals were were detected in upland and bank soils at the Site. Metals were detected in groundwater. The MassDEP has not formally established background concentrations for these constituents in soil and groundwater, with the exception of the EPH target analytes (polycyclic aromatic hydrocarbons (PAHs)) and metals in soil. Northampton Cutlery 9 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G Therefore, in this risk characterization, it is assumed that background concentrations for the detected constituents in soil and groundwater, with the exception of PAHs and metals in soil, are the respective method reporting limits. Thirteen PAHs were detected in at least one soil sample collected at the Site (Tables 6-1 and 6-2). The maximum concentrations of each of the detected PAHs were below the MassDEP background concentrations in “natural” soil (MassDEP, 2002a). Therefore, PAHs were not selected as COCs for soil. Thirteen metals (antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, and zinc) were detected in at least one soil sample. The detected concentration of each of these metals exceeded the MassDEP background concentrations in “natural” soil (MassDEP, 2002a). Therefore, each of the detected metals was selected as a COC for soil. 2.2 Hazard Identification 2.2.1 Identification of Constituents of Concern In accordance with MCP guidance (MassDEP, 1995), each detected compound should be considered a constituent of concern (COC), unless one of the following conditions is true: • The chemicals are present at a low frequency of detection and in low concentration; or • The chemicals are present at levels that are consistent with “background” concentrations for the area and there is no evidence that their presence is related to activities at the site; or • The chemicals are field or laboratory contaminants. Soil Soil analytical data collected at the Site are presented in Tables 2-2, 4-1 through 4-6, and 5. The detected compounds are listed on Tables 6-1 and 6-2 and include VPH and EPH carbon fractions and target analytes, PCBs, and metals. VPH carbon fractions and target analytes were detected at low frequency of detection and concentration and, therefore, are not selected as COCs. According to NEE, EPH compounds were detected in select samples at concentrations that were below Method Method 1 S-1/GW-2/GW-3 standards, except in a few isolated samples. Given the widespread distribution of coal and coal ash at this Site along the entire length of the levee, river bank, and within the raceway fill, it is NEE’s opinion that the EPH are derived from the coal and/or coal ash, and not Site-related activities. Northampton Cutlery 10 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G In addition, the thirteen detected EPH PAHs were not selected as COCs based on a comparison with background in “natural” soil (see Section 2.1.2). PCBs were detected at a low frequency, but at a elevated concentration in one sample (SP-15) from AOC-2 and AOC-3. Therefore, PCBs are selected as a COC. The thirteen detected metals were selected as COCs based on a comparison with background in “natural” soil (see Section 2.1.2). Therefore, the soil COCs are PCBs and thirteen metals. Groundwater The data from groundwater samples collected at the Site are presented in Tables 1 and 2-1. The data considered to be representative of current Site conditions are those collected in 2006 and 2008. The compounds detected in these samples and selected as groundwater COCs were the metals chromium, copper, lead, nickel, and zinc. Surface Water Surface water data collected in 2006 by OTO from the Mill River is presented in Table 2-3. The only analyte detected was chromium (+III) in sample OSW-2. The detected concentration of chromium was less than the MassDEP Lowest Ecologically Based Criteria (i.e., Surface Water Target). Therefore, chromium was not selected as a COC and there are no surface water COCs. Sediment The transect sediment data collected in 2006 by OTO from the Mill River is presented in Table 2-4. The 2006 transect data indicates that metals were detected in sediment samples collected adjacent to AOC-1, PAHs and metals adjacent to AOC-2 and AOC-3, and metals in the upstream transect samples. Seven metals were detected in Site sediment samples. The concentrations of six detected metals (excluding antimony) were similar to the concentrations detected in the upstream samples and/or below the available MassDEP Sediment Screening Values. Antimony was only detected in one sample (OSS-11 at 6.98 mg/kg). Therefore, metals are not selected as sediment COCs. PAHs were only detected in one midstream sample (OSS-22), and NEE states that PAHs may or may not have origins at the Site. However, these PAHs were not detected in the near bank sediment sample (OSS-21) and the adjacent river bank samples (RB-9 and RB-10). Therefore, PAHs are not selected as sediment COCs. Northampton Cutlery 11 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G 2.2.2 Toxicity Profiles Toxicity profiles describe the potential human health effects posed by the constituents of concern, when doses are high enough to elicit an effect. Toxicity profiles for the constituents of concern are included in Appendix A. 2.2.3 Identification of Applicable or Suitably Analogous Standards Applicable or suitably analogous standards are formally promulgated standards intended to protect human health and the environment from adverse effects of hazardous agents. Such standards are medium-specific. There are no applicable or suitably analogous soil standards available for Site COCs. In accordance with MassDEP policy, MCP Method 1 risk characterization standards are not considered to be applicable or suitably analogous standards for Method 3 Risk Characterization. Federal and state drinking water standards are not applicable or suitably analogous standards for this Site, because groundwater at the Site is not classified as GW-1. Massachusetts Drinking Water Standards and Guidelines, which are enforced by the Drinking Water Program, are comprised of the Massachusetts Maximum Contaminant Levels (MMCLs) (310 CMR 22.00 of the drinking water regulations) and the promulgated MCLs set by the United States Environmental Protection Agency (US EPA). The MMCLs apply to water that is delivered to any user of a public water system and are recommended for the evaluation of private residential contamination (MassDEP, 2007b). The MassDEP Office of Research and Standards (ORS) has also issued drinking water guidelines for the Site’s groundwater COCs (e.g., MTBE). However, these guidelines are not enforceable standards. Massachusetts Surface Water Quality Standards are applicable or suitably analogous standards to a site, if surface water is present and potentially impacted by a site. However, no surface water impacts have been identified at the subject Site. 2.3 Dose-Response Assessment Dose-response information describes the health effects observed in humans or animals associated with particular doses of a chemical. Based on the observed effect and target organ identified, a numerical value is developed to estimate the magnitude of the health effect associated with a dose. Dose-response values are derived differently for noncarcinogenic and carcinogenic effects, as discussed below. The primary sources of dose-response information for compounds detected at this Site were US EPA's on-line Integrated Risk Information System (IRIS) database, US EPA's Health Effects Assessment Summary Tables (HEAST) (EPA, 1997a) and MassDEP documents Northampton Cutlery 12 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G (MassDEP, 2008a). The toxicity values from these sources are encoded in MassDEP Method 3 Shortforms (MassDEP, 2008c). 2.3.1 Threshold (Non-carcinogenic) Effects For non-carcinogenic effects, there is believed to be a threshold level below which no adverse health effects will occur. Dose-response values for non-carcinogenic oral effects are referred to as Reference Doses (RfDs). For inhalation effects, these values are referred to as Reference Concentrations (RfCs). RfDs and RfCs represent a provisional estimate (with uncertainty spanning perhaps an order of magnitude) of the threshold dose that will not pose risk of an adverse health effect to sensitive humans. RfDs and RfCs are developed by applying uncertainty factors and modifying factors to the critical dose or concentration. This dose or concentration is usually either the Lowest-Observed-Adverse-Effect Level (LOAEL) or the No-Observed-Adverse-Effect Level (NOAEL) from toxicological studies, typically carried out on test animals. Uncertainty factors are used to account for interspecies variability, variation in sensitivity within the human population, differences in the route of administration among tests, and other variables that may lend uncertainty to the extrapolation of test data to environmental settings. Units for RfDs are mg/kg/day, representing a dose of chemical (in milligrams) per receptor body weight (in kilograms) per day. For inhalation exposures, the RfC value is expressed as a concentration in air in μg/m3 for continuous, 24 hour/day exposure. Oral RfDs and inhalation RfCs for the soil and groundwater COCs are summarized in Table 7. 2.3.2 Non-threshold (Carcinogenic) Effects In accordance with MCP guidance, it has been assumed that for carcinogenic effects there is no threshold level; that is, every non-zero exposure to a carcinogen is believed to be associated with some increased incremental risk. Dose-response values derived for carcinogenic compounds are Cancer Slope Factors (CSFs). CSFs are calculated as the largest linear slope of the dose-response curve, which is generally extrapolated from the low-dose end of the curve. CSFs are expressed in (mg/kg/day)-1, and assume that the received dose is averaged over a lifetime. Northampton Cutlery 13 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G EPA's weight-of-evidence cancer classifications for each of the COCs were compiled. These classifications indicate whether existing human and animal data are sufficient to confirm whether there is an association between exposure to the compound and the occurrence of cancer. Two COCs, arsenic and nickel (by inhalation), have a weight-of-evidence classification of Group A (i.e., Human Carcinogen -sufficient evidence in epidemiological studies to support causal association between exposure and cancer in humans). Beryllium and cadmium by inhalation have been given a weight-of-evidence classification of Group B1 (i.e., Probable Human Carcinogen). Lead and PCBs have been given a weight-of-evidence classification of B2 (i.e., Probable Human Carcinogen). The remaining detected compounds have been given a classification of D (i.e., Not Classifiable -inadequate or no human and animal evidence of carcinogenicity) or a classification is not available available (NA). Carcinogenic values for inhalation exposures, called unit risks, are calculated by dividing the slope factor by the body weight (70 kg) and multiplying by the air inhalation rate (20 m3/day) for risk associated with unit concentration in air. Multiplication by 10-3 is necessary to convert mg (milligrams) to μg (micrograms). Dose-response information for carcinogenic effects associated with soil and groundwater COCs are summarized in Table 7. 2.3.3 Relative Absorption Factors Relative absorption factors (RAFs) are used to account for the differences in absorption likely to occur between exposures under Site conditions and those that occurred under the experimental conditions that form the basis of the toxicity values. Absorption differences may result from matrix effects (e.g., doses absorbed from soil versus water) as well as from routes of administration (e.g., oral versus dermal exposure). RAFs adjust the calculated Site dose to make it comparable to the available toxicity information. RAFs used in this risk assessment are presented in Table 8 and were adopted from MassDEP (2008), when available. In the absence of compound-specific data for inhalation exposures, a default RAF of 1 was used. The RAFs from these sources are encoded in MassDEP Method 3 Shortforms (MassDEP, 2008c). Northampton Cutlery 14 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G 2.4 Exposure Assessment The objectives of the Exposure Assessment are to: 1. Qualitatively and quantitatively describe the settings and conditions under which human exposures to Site OHM may reasonably be expected to occur, and 2. Calculate doses of Site OHM that human receptors may receive. Achieving these goals entails the identification of receptors that may be on-Site, evaluation of exposure pathways, and the calculation of Exposure Point Concentrations (EPCs) to which receptors may be exposed. 2.4.1 Development of Exposure Profiles Exposure profiles provide a narrative description of how exposures may take place at the Site. The profiles identify factors related to potential exposures and estimate their magnitude. These factors include variables such as the receptors’ body weights, intake rates, frequency of exposure, and duration of exposure. Exposure profiles are provided for each receptor identified under current and foreseeable future uses of the Site and incorporating the terms of the AULs for AOCs -1, -2, and -3. 2.4.1.1 Identification of Potential Human Receptors and Exposure Points Exposure points represent the locations where human or ecological receptors may come into contact with OHM at a site. These locations may be either single discrete points or areas/zones of affected media. Under current and foreseeable future conditions of the Site and the implementation of the Class A-3 RAO-P AUL for AOC-1, there is no exposure potential to Site-impacted soil, groundwater, surface water, and sediments for residents, trespassers, recreational users, Site workers, and other Site users, except for limited soil exposure to construction/utility/erosion control maintenance workers. Soil exposures and risks were quantitatively evaluated for these workers as construction workers in the parking lot and river bank “CB” area of AOC-1. This evaluation of shortterm construction workers (exposure duration of 6 months) is considered to be protective protective of lesser-exposed receptors, such as the utility worker and authorized remediation maintenance personnel. There is no current exposure to impacted soil, groundwater, sediment, and surface water in AOC-2 and AOC-3 under the implementation of the Class C-1 RAO-P and AUL. The MCP (310 CMR 40.0956(1)(c)) indicates that a quantitative evaluation of human health risk Northampton Cutlery 15 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G is not required if there is no current exposure to OHM at the disposal Site. Therefore, no risks are calculated for AOC-2 and AOC-3, and a Condition of No Substantial Hazard exists for AOC-2 and AOC-3. Potable water is supplied to the Site by a municipal source and the Site does not lie within a current or potential drinking water supply area. Therefore, there is no current and foreseeable future direct exposure pathway to groundwater as drinking water. Since volatile compounds were not selected as COCs for groundwater or soil, vapor intrusion from groundwater (located at a depth of 15 feet or less) and from soil (within 6 horizontally and 10 feet vertically) was not evaluated. A potential complete exposure pathway for the existing AOC-1 Site buildings does not exist, therefore, further evaluation is not necessary. Groundwater from the Site may reach nearby surface waters and serve as an indirect exposure pathway for aquatic organisms. The potential environmental impact of groundwater discharging into surface water is evaluated for ecological receptors in Section 5.0 -Environmental Risk Characterization. 2.4.1.2 Identification of Exposure Routes The exposure route describes how a receptor may contact contaminants at a site. The exposure routes identified for quantitative analysis in this risk characterization were the inadvertent ingestion of constituents in soil and the dermal absorption of constituents from soils in contact with the skin, and inhalation of particulates by construction workers. 2.4.1.3 Exposure Profile Summary Exposure profile summaries bring together the different elements of the exposure profile to develop complete exposure pathways for each receptor. Receptor (exposure conditions) Age of Receptor Exposure Duration Exposure Medium Exposure Route Incidental Ingestion Dermal Contact Inhalation -GI AOC-1 Construction Worker (current/future) Adult Subchronic Soil Inhalation -Pulmonary 2.4.2 Development of Exposure Factors Exposure factors, also referred to as exposure assumptions, are numerical estimates of the magnitude and duration of exposures that receptors may have to Site OHM. Exposure assumptions and equations for estimating exposures for the construction worker scenarios Northampton Cutlery 16 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G are from the MassDEP’s Shortforms for Human Health Risk Assessment under the MCP (sf08cw) (MassDEP, 2008c). These exposure assumptions and equations for estimating exposures are presented in the following tables from the MassDEP Shortform: Table 9 -Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates 2.4.3 Exposure Point Concentrations Exposure Point Concentrations, or EPCs, are the concentrations of OHM in a medium representative of the concentrations a receptor may be exposed to over the course of an exposure. EPCs are calculated separately for each OHM and each medium. Groundwater EPCs are generally represented by detected concentrations in each individual monitoring well, while soil EPCs may represent an arithmetic average concentration within an impacted area or over the entire Site. The Site data were first evaluated to determine if a "hot spot" area(s) is (are) present. A hot spot is defined as a discrete area where concentrations of OHM or the thickness of nonaqueous phase liquid (NAPL) are substantially higher than those present in the surrounding area. A hot spot can be identified based on consideration of both the concentrations or thickness of an OHM within a contaminated area and the spatial pattern of that contamination. A discrete area where the average concentration within the area is greater than 10 but less than 100 times the average concentration in the immediate surrounding area is a hot spot, unless there is no evidence that the discrete area would be associated with greater exposure potential than the surrounding area. In all cases, a discrete area where the concentration of OHM is greater than 100 times the concentration in the surrounding area is considered a hot spot. In addition, a hot spot cannot be created as a result of a remedial action (MassDEP, 2005), such as soil excavation. Data from the affected areas of the Site were evaluated to identify potential "hot spots". NEE identified a hot spot for the PCBs in sample SP-15 located in AOC-3. The groundwater data presented in Section 2.2.1 of this report and in Tables 1 and 2-1 were evaluated for the development of groundwater EPCs. The soil data presented in Section 2.2.1 of this report and in Tables 4-1 through 4-6 and 5 were evaluated for the development of soil EPCs. Northampton Cutlery 17 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G Groundwater The groundwater EPCs were based on the analytical data from 2006 and 2008. Each of the monitoring wells was only sampled once, with the exception of MW-4. For the wells sampled once, the EPCs are the detected concentrations of the groundwater COCs. For MW-4, the EPCs are the average of the detected concentrations of the groundwater COCs. The groundwater EPCs are presented in Table 10. Soil The MCP (310 CMR 40.924(2)(b)(3)) specifies that for current and potential soil exposures, the following depths should be considered, with any applicable Site-specific information, when determining EPCs: 1. 0 to 3 feet for exposures associated with surficial activity; 2. 0 to 6 feet for exposures associated with utility installation and repair; 3. 0 to 15 feet for exposures associated with excavation scenarios and building construction. For the AOC-1 Parking Lot, the EPCs were developed based on the confirmatory soil data from the SA-1 through SA-5 excavations collected from 2 to 5 feet bgs. These areas previously were reported with concentrations of metals that exceeded the UCLs and represented the highest concentrations detected in the Parking Lot area (Tables 4-1 through 4-5). These areas were the subject of excavations in November and December 2004. For the AOC-1 CB area, the EPCs were developed based on the initial soil samples collected from the river bank in June 2005 and June 2006, and confirmatory soil samples collected in September 2006 from the CB excavation area (Table 4-6). These samples were collected from a depth of 0 to 3 feet bgs and are currently located under the erosion control materials. The EPCs for AOC-1 were calculated based on the average of the detected concentrations in the two sample sets (Table 11). There are no complete current exposure pathways for AOC-2 and AOC-3. Therefore, no EPCs were calculated for these areas. 2.4.4 Calculation of Average Daily Doses The average daily dose (ADD) is a quantitative estimate of of how much of each compound is taken into the receptor's body during exposure. The ADD is expressed as milligrams of OHM per kilograms of body weight per day. The general form of the dose equation is: Northampton Cutlery 18 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G ADD = (Total Amount of OHM Contacted) * (RAF) (Body Weight) * (Averaging Period) ADDs are calculated differently for assessment of carcinogenic and non-carcinogenic effects from ingestion and dermal contact exposures. For assessment of non-carcinogenic effects, the ADD is averaged over the exposure period. The resulting ADD is an estimate of dose experienced during the actual period of exposure. Averaging Periodnon-carcinogenic = Exposure Period For carcinogenic effects there is assumed to be no threshold level, and exposures are cumulative over a lifetime. The dose received is, therefore, averaged over a lifetime (70 years) instead of over just the exposure period. The resulting dose estimate is referred to as a lifetime average daily dose, or LADD. Averaging Periodcarcinogenic = Lifetime (70 years) For inhalation exposures, the average daily exposure (ADE) is a quantitative estimate of applied concentration of each compound for the receptor during exposure. The ADE is expressed as micrograms (μg) per cubic meter of air (m3) and is based on the exposure point concentration (EPC) and an adjustment for the amount of time the receptor spends in the area with contaminated air. The general form of the exposure equation is: ADE = EPC * Exposure Duration * Exposure Frequency * Exposure Period * Conversion Factors Averaging Period As with ADDs, ADEs are calculated differently for assessment of carcinogenic and noncarcinogenic effects. For assessment of non-carcinogenic effects, the ADE is averaged over the exposure period. The resulting ADE is an estimate of dose experienced during the actual period of exposure. Averaging Periodnon-carcinogenic = Exposure Period For carcinogenic effects there is assumed to be no threshold level, and exposures are cumulative over a lifetime. The exposure received is therefore averaged over a lifetime (70 years) instead of over just the exposure period. The resulting exposure estimate is referred to as a lifetime average daily exposure, or LADE. The ADDs and ADEs for soil exposures at AOC-1 are encoded in the MassDEP Shortforms for construction workers (Table 12). Copper is not included in the MassDEP Shortforms. Therefore, ADDs were calculated in separate spreadsheets using the MassDEP Shortform exposure assumptions and equations. There is no available inhalation reference concentration for copper. Therefore, no ADEs were calculated for copper. Northampton Cutlery 19 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G As previously stated, there are no complete exposure pathways under current use of AOC-2 and AOC-3, therefore, no ADDs and ADEs were calculated. 2.5 Risk Characterization Risk characterization is the final step in the risk assessment process. In this step, the results of the Hazard Assessment, Dose-Response Assessment, and Exposure Assessment are combined to yield quantitative estimates of incremental risk posed by potential exposures to environmental media at the Site. Separate estimates of potential cancer and non-cancer risk are made for each receptor and are discussed below. These estimates are compared to risk management criteria to establish whether a Condition of No Significant Risk is present. 2.5.1 Non-Cancer Risk The indicator used to describe the potential for non-carcinogenic health effects for an individual compound is the Hazard Quotient and the sum of the HQs is the Hazard Index (HI). For a given chemical, the HQ is the ratio of a receptor's exposure level (or dose) to the level of exposure considered to be safe. In this risk characterization, a safe level of exposure is represented by the RfD or RfC for each compound. An HQ that does not exceed 1 indicates the receptor's exposure to that compound is without risk of adverse health effect. Hazard Quotient = ADD/RfD or Hazard Quotient = ADE/RfC When the HQs for each of the compounds of concern at the Site are summed for each receptor, the result is a total Site Hazard Index. This total Site Hazard Index is referred to as a screening HI because it does not segregate different compounds of concern based on their mode of toxicological critical effect or target organ. This information on toxicological effect is presented with the corresponding toxicity values in Table 7. Thus, when used as an indicator of total Site non-carcinogenic risk, the screening HI is likely to overstate the actual level of non-carcinogenic risk. If the screening level HI is not greater than 1, this indicates indicates there is no significant noncarcinogenic health risk associated with Site exposures. If the screening level HI is greater than 1, this HI is segregated by critical effect or target organ. Northampton Cutlery 20 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G The hazard indices are presented in Tables 12 and are summarized in Table 13. The total screening HIs for construction workers for AOC-1 Parking Lot is equal to 1 and for AOC-1 CB Area exceeds 1. Therefore, the total screening HIs were segregated by critical effect. For the AOC-1 Parking Lot and CB area, the resultant segregated HIs do not exceed 1. This finding indicates a Condition of No Significant Risk for noncancer effects to construction workers. 2.5.2 Cancer Risk The potential for carcinogenic health effects is estimated as the Incremental Excess Lifetime Cancer Risk (ELCR). The ELCR represents the incremental probability of an exposed individual developing cancer over a lifetime as a result of exposure. For each chemical, the ELCR is the product of the Lifetime Average Daily Dose (LADD) or Lifetime Average Daily Exposure (LADE) and that compound's carcinogenic potency. The indicator of carcinogenic potency used in this risk characterization is the EPA Cancer Slope Factor (CSF) or Unit Risk. ELCR = LADD x CSF or ELCR = LADE x Unit Risk As in the case of non-cancer risk, the ELCRs for each of the different compounds and pathways are summed to produce a receptor-specific cumulative ELCR. This cumulative ELCR is compared to the risk management criterion of 1 x 10-5 (one in one hundred thousand). A cumulative ELCR that does not exceed 1 x 10-5 indicates that no significant carcinogenic risk is present due to OHM at the Site. A cumulative ELCR greater than 1 x 10-5 indicates a potential for significant cancer risk is present as defined by the MCP. The ELCRs are presented in Tables 12 and are summarized in Table 13. The ELCRs for construction workers for the Site do not exceed 1 x 10-5. This finding indicates a Condition of No Significant Risk for cancer effects to this receptor. 2.5.3 Summary of Findings 1. The segregated HIs and ELCRs for construction workers from soil exposure in AOC-1 are not greater than MassDEP’s risk management criteria of 1 and 1x10-5, indicating a Condition of No Significant Risk for non-cancer and cancer risks for this receptor. Construction worker exposure to Site soil is considered to be protective of lesser-exposed receptors, such as utility workers and landscapers. Northampton Cutlery 21 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G 2. Under the terms of the Class A-3 RAO-P and AUL for AOC-1, exposure pathways to soil for other receptors, including current Site workers, patrons and visitors, and future residents are not complete. There is no complete exposure pathway for groundwater. Indoor air impacts to the existing Site building are not likely based on the absence of volatile-impacted groundwater and soil. Sediment and surface water in the Mill River has not been identified to have been impacted by the Site and no regular recreational activities occur on the lower river bank of AOC-1. 3. There are no complete exposure pathways under the current use of AOC-2 and AOC-3. Therefore, a Condition of No Substantial Hazard exists for AOC-2 and AOC-3 and a Class C-1 RAO-P and AUL are applicable to these AOCs. 4. There are no exceedances of applicable or suitably analogous standards. Based on these findings, we conclude that a Condition of No Significant Risk for AOC-1 exists for construction workers based on current and foreseeable future Site uses. Construction worker exposure is considered to be protective of lesser-exposed utility workers and landscapers. Soil exposures to other receptors are controlled by the implementation of the AUL for the Class A-3 RAO-P, and there are no complete exposure pathways for AOC-1 groundwater, surface water, and sediment. For AOC-2 and AOC-3, there are no complete exposure pathways for soil, groundwater, surface water, and sediment under current Site uses. Therefore, a Condition of No Substantial Hazard exists for AOC-2 and AOC-3. A Class C-1 RAO-P is applicable to AOC-2 and AOC-3 as response actions to achieve a Condition of No Significant Risk and a permanent solution are not currently feasible. 2.6 Uncertainty Analysis The risk assessment process uses information from a variety of sources, such as analytical data from the Site investigation and toxicity data from published research. This information is combined with assumptions regarding regarding potential receptors and Site use. Uncertainties may be present in each of these assumptions, and may affect the outcome of the risk assessment. The risk assessment was developed to be a conservative estimate of potential adverse health effects. Its results should not be interpreted as definitive quantitative values. Uncertainties in the various portions of this risk assessment are discussed below. Northampton Cutlery 22 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G A. Hazard Identification The identification of constituents present in soil and groundwater and their distribution across the Site are dependent upon the sampling and analytical program conducted. Conservative assumptions were made in developing soil and groundwater EPCs that likely lead to overestimates of actual exposure point concentrations. EPCs were based on detected concentrations in samples collected from higher concentration areas. Sampling programs tend to focus on areas of higher concentration, resulting in a high-end estimate of the EPC. B. Exposure Assessment There is uncertainty associated with exposure assessment because the range of potential human activity is broad. Variability is associated with differences between individual receptors, such as body weight, skin surface area, and rates of soil or water ingestion. Conservative assumptions used in the MassDEP Shortforms in developing pathway exposure factors that are anticipated to err on the side of protection of health. C. Dose-Response Assessment Toxicity information for many of the chemicals detected at the Site is associated with varying degrees of uncertainty. Sources of uncertainty for toxicity values (EPA, 1989) may include: • Using dose-response information from effects observed at high doses to predict the adverse health effects that may occur following exposure to low levels expected from human contact with the agent in the environment; • Using dose-response information from short-term exposure to predict the effects of long-term exposures, and vice-versa; • Using dose-response information from animal studies to predict effects in humans; • Using dose-response information from homogeneous animal populations or healthy human populations to predict the effects likely to be observed in the general population consisting of individuals with a wide range of sensitivities. Most of the toxicity values used in this risk characterization are EPA-verified RfDs/RfCs and slope factors. These values, as presented in IRIS, are derived using a number of safety factors and are accompanied by a statement of confidence in the value itself, the critical study, and the overall data base for RfDs/RfCs, and the weight-of-evidence classifications for slope factors. Northampton Cutlery 23 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G MassDEP has derived toxicity values for VPH/EPH carbon fractions using a reference surrogate compound approach for these complex mixtures of hydrocarbons (MassDEP, 2003). The method involves segregating the petroleum hydrocarbons present in mixtures into broad chemical classes and further into subgroups or fractions based upon their size, and with consideration of comparative toxicity and structure activity relationships (SARs). For each subgroup of compounds, a reference compound was initially identified to represent the toxicity of all compounds in the range. The compound was usually chosen because its toxicity was relatively well characterized. For each reference compound, an EPA published value was identified or a value was identified based on available toxicity information. D. Risk Calculations The risk calculations were performed using a deterministic methodology as required under MCP guidance. In a deterministic methodology, a single value (point estimate) is used for exposure parameters and exposure point concentrations. The result is that a single risk value is calculated for each scenario and receptor of concern. However, the use of a mix of mid-range and conservative exposure assumptions is intended to produce realistic upper-end exposure estimates, which will be protective of public health and produce risk estimates that will be valid for comparison to MCP Cumulative Risk Limits (MassDEP, 1995). 3.0 CHARACTERIZATION OF RISK OF HARM TO PUBLIC WELFARE The MCP defines two purposes for conducting a characterization of risk to public welfare: (a) to identify and evaluate nuisance conditions that may be localized, and (b) to identify and evaluate significant community effects. The characterization of risk to public welfare considers effects that are or may result from the presence of residual contamination or the implementation of a proposed remedial alternative (310 CMR 40.0994). The characterization of the risk of harm to public welfare considers Site, receptor, and exposure information, as well as data collected pursuant to the response action(s) being performed. The characterization of risk of harm to public welfare also considers such factors as the existence of nuisance conditions, loss of active or passive property use(s), and any non-pecuniary effects not otherwise considered in the characterization of risk of harm to health, safety, and the environment, but which may accrue due to the degradation of public resources directly attributable to the release or threat of release of OHM or the remedial alternative (310 CMR 40.0994(2)). Northampton Cutlery 24 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G The risk of harm to public welfare is characterized by comparing the concentration of each OHM to the Upper Concentration Limits in Soil and Groundwater or UCLs [as defined in 310 CMR 40.0996]. In addition, a level of no significant risk of harm to public welfare exists or has been achieved, if no nuisance conditions, such as noxious odors, persist. The EPCs derived for groundwater (Table 10) and soil concentrations (Table 11) do not exceed the numerical UCLs. No non-aqueous phase liquid (NAPL) was detected at the Site. The Site has been shown to contain soil impacted by metals that are not likely to create an odor at close range. In addition, soils are located under pavements and erosion control materials. Based on Site-specific conditions, it is not likely that nuisance odor conditions would occur. Therefore, a Condition of No Risk of Harm to Public Welfare exists for AOC-1. 4.0 CHARACTERIZATION OF RISK OF HARM TO SAFETY The risk of harm to safety, as described in 310 CMR 40.0960, was evaluated for the Site. The Site does not exhibit the following safety-related characteristics: 1. There are no rusted or corroded drums or containers, open pits, lagoons, or other dangerous structures at the Site; 2. There is no threat of fire or explosion from the presence of explosive vapors resulting from the release of OHM at the Site; and 3. There are no containerized materials at the Site exhibiting the characteristics of corrosivity, reactivity, or flammability. Therefore, there is not a risk of harm to safety due to conditions at the Site. 5.0 ENVIRONMENTAL RISK CHARACTERIZATION In accordance with Section 40.0995 of the MCP, this section of the risk assessment evaluates possible ecological risks due to OHM in soil and groundwater at the Site. For the Site, a Stage I Environmental Risk Screening was conducted. The Stage I Screening steps are: 1. Identify complete Exposure Pathways [310 CMR 40.0995 (3)(a)], 2. Determine whether Readily Apparent Harm Exists [310 CMR 40.0995 (3)(b)], and 3. Establish if Potentially Significant Exposures Exist [310 CMR 40.0995 (3)(c)]. Northampton Cutlery 25 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G If there are no complete exposure pathways, readily apparent harm, or potentially significant exposures, no further action to assess ecological risk is required (MassDEP, 1996a). The Stage I screening for potential ecological receptors has been conducted separately for aquatic and terrestrial habitats. 5.1 Aquatic Habitat Screening Four criteria are identified in the MCP to assess whether exposure of environmental receptors is likely: 1. Evidence that OHM have come to be located in a surface water body or wetland, 2. Evidence that OHM have had an adverse impact on aquatic biota, 3. The presence of OHM in any Study Area media at concentrations associated in the scientific literature with adverse environmental impacts, and 4. The presence of environmental receptors within 500 feet of the Study Area and the potential for OHM to migrate to such receptors at a concentration which would exceed Ambient Water Quality Standards or Massachusetts Surface Water Quality Standards. The Mill River flows immediately adjacent to, and west of, the Site from north to south. Based on gauging measurements collected from monitoring wells at the Site by NEE, groundwater flow across the Site is in an inferred westerly direction toward the river. The potential for the existing groundwater conditions to impact these surface waters in the future was evaluated. The groundwater data for the Site indicate the presence of dissolved metals in Site monitoring wells. These constituents may be carried with groundwater flow and be potentially discharged to surface water with dilution of concentrations expected during transport and discharge. This migration pathway was evaluated by comparing groundwater concentrations to the MCP groundwater standards for the protection of environmental receptors, the GW-3 standards. The GW-3 standard incorporates a lowest ecologically based criterion (LOEC) and a simple groundwater/surface water dilution factor of 10 (Dsw) based on MassDEP experience writing groundwater and surface water discharge permits (MassDEP, 1995). However, this dilution factor is conservative and does not consider Site-specific conditions, such as soil type, volume of contaminated groundwater, groundwater flow direction, the actual dilution and attenuation that may occur during groundwater flow and discharge from the Site to a surface water. The GW-3 standards also incorporate in-groundwater dilution factors (Dgw) based on a chemical property (i.e., koc) of the COC to account for some of these factors. The values for the groundwater dilution factor are 2.5, 25, or 100. Northampton Cutlery 26 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G As indicated on Table 10, the groundwater sampling results from 2006 and 2008 indicate that the detected concentrations are below the GW-3 standard, with one exception. The concentration of lead in CR-6 (15.8 ug/L) slightly exceeds the GW-3 standard (10 ug/L). Well CR-6 is located approximately 40 feet southeast of well MW-4 and is adjacent to or within raceway fill materials. OTO in the Brownfields Investigation states this result may indicate the possibility of lead migrating from the Site into surface water at a concentration of concern for aquatic life. However, OTO did not detect lead or other metals at concentrations of concern (exceeding MADEP 2006 Sediment Screening Values) in the surface water samples they collected from the Mill River. In addition, dissolved lead was not detected in MW-4 in 2006 and 2008 (Table 10). Therefore, dissolved metals in groundwater do not appear to be migrating at concentrations that are above the GW-3 3 standards from the Site. Detections of metals of concern for the Site within river sediment are similar in concentrations in both upgradient and downgradient samples (Interim Construction Report (NEE, 2005)) and OTO transect samples in 2006 (Table 2-4). These data indicate that while the Site may have contributed metals to the river sediment, the Site is not a major contributor, or the sole contributor. These findings indicate a Condition of No Substantial Hazard for AOC-2 and AOC-3 exists under current conditions. A Condition of No Significant Risk of harm to the aquatic environment exists for AOC-1 groundwater currently and in the future. 5.2 Terrestrial Habitat Screening Natural vegetation on the northern portion of AOC-1 is limited due to the current development of the Site (buildings and parking lots), portions of AOC-1 riverbank area and AOC-2 and AOC-3 are covered by erosion control materials. Other surface soils in AOC-2 and AOC-3 are impacted by metals. Therefore, it is not likely that plants and and burrowing wildlife could currently directly contact this soil in AOC-1 and there is no complete exposure pathway for terrestrial receptors under current Site conditions. Soil exposure to terrestrial receptors could occur in soils in AOC-2 and AOC-3. For AOC-1, a further evaluation of the presence of potentially significant exposure pathways was completed. Since no soil screening criteria are available, the terrestrial habitat has been screened on the basis of its size. For the purposes of this screening, the size of undeveloped/open land at the Site determines the specific evaluation of terrestrial environments. Northampton Cutlery 27 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G MassDEP (1996a) states that for the purposes of the screening process, undeveloped/open land is characterized by the presence of native vegetation, and does not include landscaped residential and commercial parcels, landscaped parks, or golf courses. Based on this MassDEP definition, the open space on the Site is less than 2 acres in size. Therefore, no further action to characterize ecological risk is required for sites unless: 1. Contaminant transport from surface soil to an Area of Critical Environmental Concern (ACEC) is possible, or 2. State-listed threatened or endangered species, or other species of special concern are present. According to the MassDEP Site Scoring map, the Site is not: 1. Within an ACEC nor is contaminant transport from surface soil to an ACEC possible, or 2. The location of state-listed threatened or endangered species, or other species of special concern. For AOC-2 and AOC-3, a Condition of No Substantial Hazard Hazard exists based on the MCP criteria in 310 CMR 40.0956(2). Overall, there is currently a Condition of No Significant Hazard to the environment for AOC-2 and AOC-3, and a Condition of No Significant Risk for AOC-1 6.0 CONCLUSIONS In accordance with the Massachusetts Contingency Plan, 310 CMR 40.0990 and 40.0956, we have conducted a Method 3 Risk Characterization for a Condition of No Significant Risk for AOC-1 and a Condition of No Substantial Hazard for AOC-2 and AOC-3 for the MCP disposal Site located at the Former Cutlery Raceway at 320-360 Riverside Avenue in Northampton, Massachusetts. To assess whether reported concentrations of OHM represent a Condition of No Significant Risk for AOC-1 under current and future uses, this Method 3 risk characterization was completed. In accordance with the MCP, the Method 3 risk characterization included the following components: 1. Assessment of risks to human health, 2. Assessment of risks to public welfare, 3. Assessment of risk of harm to safety, and 4. Assessment of environmental risks. Northampton Cutlery 28 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G To assess whether reported concentrations of OHM represent a Condition of No Substantial Hazard for AOC-2 and AOC-3, this Method 3 risk characterization was completed. In accordance with the MCP, the Method 3 risk characterization included the following components: 1. Assessment of risks to human health, 2. Assessment of environmental risks. For human health, the Method 3 Risk Characterization concludes that a Condition of No Significant Risk for AOC-1 exists for construction workers based on current and foreseeable future Site uses. Construction worker exposure is considered to be protective of lesserexposed utility workers and landscapers. Soil exposures to other receptors are controlled by the implementation of the AUL for the Class A-3 RAO-P, and there are no complete exposure pathways for AOC-1 groundwater, surface water, and sediment. For AOC-2 and AOC-3, there are no complete exposure pathways for human receptors to soil, groundwater, surface water, and sediment under current Site uses. Therefore, a Condition of No Substantial Hazard exists for AOC-2 and AOC-3. There are no exceedances of applicable and suitably analogous standards. A Condition of No Significant Risk exists for public welfare and safety for AOC-1. Potentially significant exposures were not found to exist under current and foreseeable future Site conditions for aquatic and terrestrial ecological receptors for AOC-1. Overall, a Condition of No Significant Risk is concluded for AOC-1 and a Class A-3 RAO-P with an AUL is applicable. A Condition of No Substantial Hazard is concluded for AOC-2 and AOC-3 and a Class C-1 RAO-P with an AUL is applicable, as response actions to achieve a Condition of No Significant Risk and a permanent solution are not currently feasible for AOC-2 and AOC-3. Northampton Cutlery 29 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G REFERENCES Massachusetts Department of Environmental Protection (MassDEP). 1992. Documentation for the Risk Assessment Shortform Residential Scenario. Policy #WSC/ORS-142-92. October 1992. Massachusetts Department of Environmental Protection. (MassDEP). 1994. Background Documentation for the Development of the MCP Numerical Standards. April 1994. Massachusetts Department of Environmental Protection (MassDEP). 1995. Guidance for Disposal Site Risk Characterization -In Support of the Massachusetts Contingency Plan. July 1995. Massachusetts Department of Environmental Protection (MassDEP). 1996a. Guidance for Disposal Site Risk Characterization In Support of the Massachusetts Contingency Plan *** Chapter 9 *** Method 3 Environmental Risk Characterization. Bureau of Waste Site Cleanup and Office of Research and Standards. Interim Final Policy, BWSC/ORS-95-141. April 1996. Massachusetts Department of Environmental Protection (MassDEP). 1996b. Draft Commercial/Industrial Shortform Exposure Scenarios. December 1996. Massachusetts Department of Environmental Protection (MassDEP). 2002a. Background Levels of Polycyclic Aromatic Hydrocarbons and Metals in Soil. Technical Update. May 2002. Massachusetts Department of Environmental Protection (MassDEP). 2002b. Calculation of an Enhanced Soil Ingestion Rate. Technical Update. April 2002. Massachusetts Department of Environmental Protection (MassDEP). 2002c. Weighted Skin-Soil Adherence Factors. Technical Update. April 2002. Massachusetts Department of Environmental Protection (MassDEP). 2002d. Characterizing Risks Posed by Petroleum Contaminated Sites: Implementation of MADEP VPH/EPH Approach and Background/Support Documentation. Final Policy. October 31, 2002. Policy #WSC-02-411. Massachusetts Department of Environmental Protection (MA DEP). 2003. Updated Petroleum Hydrocarbon Fraction Toxicity Values for the VPH/EPH Methodology. Final. November 2003. Massachusetts Department of Environmental Protection Protection (MassDEP). 2005. Bureau of Waste Site Cleanup Master MCP Q&A 1993-2004. Northampton Cutlery 30 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G REFERENCES (Cont’d.) Massachusetts Department of Environmental Protection (MassDEP). 2008a. 310 CMR 40.0000, the Massachusetts Contingency Plan. Effective February 14, 2008. Including Spreadsheets for the Development of the MCP Risk-based Levels for Soil and Groundwater. Massachusetts Department of Environmental Protection (MassDEP). 2008b. Characterization of Risks Due to Inhalation of Particulates by Construction Workers. Technical Update. Revised July 2008. Massachusetts Department of Environmental Protection (MassDEP). 2008c. ShortForms for Human Health Risk Assessment under the MCP. Revised September 2008. New England Environmental, Inc (NEE). 2003. MCP Phase II & Phase III Submittal. Former Cutlery Raceway, 320-360 Riverside Drive, Northampton, Massachusetts. Release Tracking Number 1-13320. New England Environmental, Inc (NEE). 2009. Class A-3 & ClassC-1 Response Action Outcome (RAO-P) Statements. Former Cutlery Raceway, 320-360 Riverside Drive, Northampton, Massachusetts. Release Tracking Number 1-13320. United States Environmental Protection Agency (EPA). 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (Part A). Interim Final. EPA/540/1-89-002. December 1989. United States Environmental Protection Agency (EPA). 1997a. Health Effects Assessment Summary Tables, FY 1997 -Update. EPA 540/R-97-036. July 1997. United States Environmental Protection Agency (EPA). 1997b. Exposure Factors Handbook. Office of Research and Development, EPA/600/P-95/002Fa. August 1997. United States Environmental Protection Agency (EPA). 2009. Integrated Risk Information System. Office of Health and Environmental Assessment. On-line database. August 2009. Northampton Cutlery 31 8/31/09 5028-02-01 CutleryM3text O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G TABLES Northampton Cutlery 8/31/09 5028-02-01 CutleryM3text Table 1 -Groundwater Sample Laboratory Results Former Cutlery Raceway, Northampton MA RTN #1-13320 Sample ID: Date Collected MW-1 1/24/01 MW-1 6/8/01 MW-1 10/24/08 MW-3 1/24/01 MW-3 6/8/01 MW-3 10/24/08 MW-2S 1/24/01 MW-2S 6/8/01 MW-2S 10/24/08 MW-2D 1/24/01 MW-2D 6/8/01 MW-2D 10/24/08 MW-4 1/31/01 MW-4 6/8/01 MW-4 3/27/02 MW-4 3/24/03 MW-4 6/5/06 MW-4 10/24/08 Method 1 GW-2 Standard Method 1 GW-3 Standard UCL OTO EPH Aliphatics/Aromatics (ug/L) C9-C18 Aliphatics BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na 5,000 50,000 100,000 C19-C36 Aliphatics BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na NA 50,000 100,000 Aromatics BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na 50,000 5,000 100,000 EPH Target PAH Analytes (ug/L) All Analytes BDL BDL BDL na BDL BDL na BDL BDL na BDL BDL na na BDL na na na na ------Soluble PP13 Metals (ug/L) 7/11/01 7/11/01 7/11/01 7/11/01 7/11/01 Antimony BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 8,000 80,000 Arsenic BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 900 9,000 Beryllium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 200 2,000 Cadmium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 4 50 Chromium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 2.6 BDL BDL BDL BDL BDL BDL BDL NA 600/300 3,000 Copper BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NSL NSL NSL Lead BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 10 150 Nickel BDL 20.9 9.5 BDL BDL BDL BDL 3.03 BDL BDL BDL BDL 333 735 468 4,180 174 84.2 NA 200 2,000 Selenium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 100 1000 Silver BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 7 1000 Thallium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 3000 30,000 Zinc BDL 3.78 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 26.7 18.5 22.2 67.1 123 BDL NA 900 50,000 Mercury BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 20 200 Notes: 1 Laboratory Analytical results compared to: 310 CMR 40.1600 & 310 CMR 40.0974(2). Avg. nickel conc in all monitoring wells 10/24/08 = 24 2 Red (& bold) = Exceeds Method 1 GW-3 Standard Avg. nickel conc in all monitoring wells over time = 344 3 Blue = Parameter detected above laboratory Method Detection Limit Avg nickel concnetration in MW-4 over time = 996 4 NSL=No Standard Listed 5 na = Not Analyzed for this parameter. 6 BDL = Below Detection Limit 7 Red (& bold) with yellow = Exceeds UCL Standard 8 Data from this sample are suspect and have been removed from further inclusion in the data set (see text). Class A3 RAO: AOC-1 Class C1 RAO: AOC-2 & AOC-3 Upgradient Downgradient Upgradient Downgradient New England Environmental, Inc. C:\Data\Projects\5028-02-01 Cutlery\Method 3\02-2053-Table 1-GWSheet1 (2) Table 2-1 OTO Brownfields Investigations (June 2006) -Table 2 Groundwater Analytical Results Inorganic Analytes Former Cutlery Raceway Northampton, MA Concentrations in mg/l AOC-3 AOC-2 Well No.: CR-1 CR-2 CR-3 CR-6 CR-8 MW-4F* MW-4U* WP-1 WP-2 GW-3 Sample Date: 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 Standards UCLs VOCs by Method 8260B ND ND ND ND ND ----ND ND vary vary EPH Fractions C9-C18 Aliphatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 ----< 0.2 --50 100 C19-C36 Aliphatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 ----< 0.2 --50 100 C11-C22 Aromatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 ----< 0.2 --5 100 EPH Target PAHs ND ND ND ND ND ----ND --vary vary Metals Antimony < 0.030 < 0.030 < 0.030 < 0.030 < 0.030 < 0.024 < 0.15 < 0.030 < 0.030 8 80 Arsenic < 0.004 < 0.004 < 0.004 < 0.004 < 0.004 < 0.008 0.125 < 0.004 < 0.004 0.9 9 Beryllium < 0.002 < 0.002 < 0.002 < 0.002 < 0.002 < 0.004 0.0165 < 0.002 < 0.002 0.2 0.5 Cadmium < 0.0025 < 0.0025 < 0.0025 < 0.0025 < 0.0025 < 0.005 < 0.0125 < 0.0025 < 0.0025 0.004 0.05 Chromium (III) < 0.005 < 0.005 < 0.005 0.0431 < 0.005 < 0.010 1.81 < 0.005 0.0056 0.6 6 Copper < 0.005 < 0.005 < 0.005 0.0117 < 0.005 < 0.010 1.4 < 0.005 0.0103 NS NS Lead < 0.0075 < 0.0075 < 0.0075 0.0158 < 0.0075 < 0.015 0.286 < 0.0075 < 0.0075 0.01 0.15 Mercury < 0.0002 < 0.0002 < 0.0002 < 0.0002 < 0.0002 < 0.0002 0.00029 < 0.0002 < 0.0002 0.02 0.2 Nickel 0.0058 0.0636 0.0656 0.0432 < 0.005 0.174 3.67 < 0.005 0.0137 0.2 2 Selenium < 0.015 < 0.015 < 0.015 < 0.015 < 0.015 < 0.030 < 0.075 < 0.015 < 0.015 0.1 1 Silver < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.010 0.0272 < 0.005 < 0.005 0.007 1 Thallium < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.020 < 0.050 < 0.010 < 0.010 3 30 Zinc < 0.035 < 0.025 < 0.025 < 0.057 < 0.025 0.123 2.13 < 0.096 0.493 0.9 50 NOTES: 1. Concentrations in milligrams per liter (mg/l, or parts per million). "<" indicates not detected; value is quantitation limit. "--" = Not analyzed for this parameter. 2. MCP Method 1 groundwater standards from 310 CMR 40.0974(2). "UCLs" = Upper Concentration Limits, from 310 CMR 40.0996(7). 3. Values shown in bold exceed standards, underlined exceed UCLs. 4. "ND" = None of the target analytes were detected. "NA"=Not applicable. "NS"=No standard available. 5. "VOCs" = Volatile organic compounds. "EPH" = Extractable Petroleum Hydrocarbons. "PAHs"=Polycyclic aromatic hydrocarbons. * Groundwater from well MW-4 was analyzed on both a filtered (F) and unfiltered (U) basis. New England Environmental, Inc. Table 2-1 OTO GW data, gw Table 2-2 OTO Brownfields Investigation (June 2006) -Table 3 River Bank Soil Sample Analytical Results Former Cutlery Raceway Northampton, MA Concentrations in mg/kg AOC-3 AOC-2 Sample No.: RB-1 RB-2 RB-3 RB-4 RB-5 RB-6 RB-7 RB-8 RB-9 RB-10 MADEP Method 1 Standards Depth (inches.): 0-3 0-3 0-3 0-3 0-3 0-3 0-3 0-3 0-3 0-3 Ash Fill S-1 /S-1 /UCLs Date Collected: 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 6/7/06 Bkgrd. GW-2 GW-3 EPH Fractions C9-C18 Aliphatics < 44 < 40 < 46 < 32 < 36 < 37 < 62 < 40 < 32 < 43 NA 1,000 1,000 20,000 C19-C36 Aliphatics < 44 < 40 < 46 43.2 < 36 < 37 < 62 < 40 < 32 < 43 NA 3,000 3,000 20,000 C11-C22 Aromatics < 44 < 40 < 46 38.1 < 36 < 37 < 62 < 40 < 32 < 43 NA 1,000 1,000 10,000 EPH Target Analytes Naphthalene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 40 500 10,000 2-Methylnaphthalene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 80 300 5,000 Acenaphthylene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 600 10 10,000 Acenaphthene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 2 1,000 1,000 10,000 Fluorene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 2 1,000 1,000 10,000 Phenanthrene 0.222 0.289 0.301 0.165 < 0.18 < 0.19 0.332 < 0.20 < 0.16 < 0.22 20 500 500 10,000 Anthracene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 4 1,000 1,000 10,000 Fluoranthene 0.328 0.383 0.438 0.201 < 0.18 < 0.19 < 0.31 < 0.20 0.163 < 0.22 10 1,000 1,000 10,000 Pyrene 0.262 0.303 0.373 0.173 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 20 1,000 1,000 10,000 Benzo(a)anthracene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 9 7 7 3,000 Chrysene 0.308 0.345 0.292 0.184 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 7 70 70 10,000 Benzo(b)fluoranthene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 8 7 7 3,000 Benzo(k)fluoranthene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 4 70 70 70 10,000 Benzo(a)pyrene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 7 2 2 300 Indeno(1,2,3-cd)pyrene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 3 7 7 3,000 Dibenzo(a,h)anthracene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 1 0.7 0.7 300 Benzo(g,h,i)perylene < 0.22 < 0.20 < 0.23 < 0.16 < 0.18 < 0.19 < 0.31 < 0.20 < 0.16 < 0.22 3 1,000 1,000 10,000 Metals (Priority Pollutant 13) Antimony < 22 21.8 168 < 17 < 20 22.1 1,040 < 19.1 < 1.63 < 1.98 7 20 20 300 Arsenic 39.4 < 2.05 48.1 30.7 53.4 36.1 75.6 < 19.1 < 1.63 < 1.98 20 20 20 200 Beryllium 0.574 0.513 < 0.288 0.425 < 0.27 0.49 < 0.33 < 0.255 < 0.217 < 0.264 0.9 100 100 2,000 Cadmium 1.69 1.8 0.627 1.28 1.16 1.9 3.98 < 0.319 < 0.272 < 0.329 3 2 2 300 Chromium (III) 5,740 2,520 13,300 4,660 13,900 2,090 9,210 4,270 39.8 51 40 1,000 1,000 10,000 Copper 9,970 4,680 626 11,500 1,270 5,710 11,100 83.5 27.8 83.2 200 NS NS NS Lead 445 933 277 355 770 581 114,000 112 9.6 17.2 600 300 300 3,000 Mercury 0.188 0.0974 0.12 0.239 0.228 1.3 3.08 0.108 < 0.055 < 0.070 1 20 20 300 Nickel 20,900 7,460 907 26,100 3,010 12,700 25,300 215 40.2 165 30 20 20 7,000 Selenium < 22 < 10.3 < 22 < 17 < 20 < 10 < 25 < 1.91 < 1.63 < 1.98 1 400 400 8,000 Silver 5.02 1.98 3.17 35.7 1.91 1.83 17.9 < 1.27 < 1.09 < 1.32 5 100 100 2,000 Thallium 3.73 2.33 4.45 3.44 4.87 2.1 5.17 < 1.91 < 1.63 < 1.98 5 8 8 800 Zinc 79.8 54.5 37.3 147 134 55.4 653 55.9 25.3 35.9 300 2,500 2,500 10,000 NOTES: 1. Concentrations in mg/kg (parts per million) on a dry weight basis. "<" indicates not detected; value is sample-specific quantitation limit. 2. MCP Method 1 soil standards from 310 CMR 40.0975(6). Values shown in bold exceed Method 1 standards. Underlined values exceed UCLs. 3. "Ash Fill Bkgrd." =Background values from MADEP "Technical Update: Background Levels of Polycyclic Aromatic Hydrocarbons and Metals in Soil", May 23, 2002. New England Environmental, Inc. Table 2-2 OTO soil data, RB OTO Brownfields Investigation (June 2006) -Table 4 Surface Water Analytical Results Former Cutlery Raceway Northampton, MA Concentrations in mg/l Well No.: OSW-1 OSW-2 OSW-3 MADEP Sample Date: 5/23/06 5/23/06 5/23/06 SW Target Extractable Petroleum Hydrocarbons C9-C18 Aliphatics < 0.2 < 0.2 < 0.2 1.8 C19-C36 Aliphatics < 0.2 < 0.2 < 0.2 2.1 C11-C22 Aromatics < 0.2 < 0.2 < 0.2 0.005 EPH Target Polycyclic Aromatic Hydrocarbons Naphthalene < 0.006 < 0.006 < 0.006 0.072 2-Methylnaphthalene < 0.006 < 0.006 < 0.006 0.07 Acenaphthylene < 0.006 < 0.006 < 0.006 0.00014 Acenaphthene < 0.006 < 0.006 < 0.006 0.023 Fluorene < 0.006 < 0.006 < 0.006 0.00014 Phenanthrene < 0.006 < 0.006 < 0.006 0.038 Anthracene < 0.006 < 0.006 < 0.006 0.00013 Fluoranthene < 0.006 < 0.006 < 0.006 0.009 Pyrene < 0.006 < 0.006 < 0.006 0.000089 Benzo(a)anthracene < 0.006 < 0.006 < 0.006 0.001 Chrysene < 0.006 < 0.006 < 0.006 0.00007 Benzo(b)fluoranthene < 0.006 < 0.006 < 0.006 0.00042 Benzo(k)fluoranthene < 0.006 < 0.006 < 0.006 0.00014 Benzo(a)pyrene < 0.006 < 0.006 < 0.006 0.0005 Indeno(1,2,3-cd)pyrene < 0.006 < 0.006 < 0.006 0.00014 Dibenzo(a,h)anthracene < 0.006 < 0.006 < 0.006 0.00004 Benzo(g,h,i)perylene < 0.006 < 0.006 < 0.006 0.00002 Metals Antimony < 0.012 < 0.012 < 0.012 0.3 Arsenic < 0.004 < 0.004 < 0.004 0.036 Beryllium < 0.002 < 0.002 < 0.002 0.0073 Cadmium < 0.0025 < 0.0025 < 0.0025 0.000091 Chromium (III) < 0.005 0.0055 < 0.005 0.024 Copper < 0.0075 < 0.0075 < 0.0075 NS Lead < 0.0075 < 0.0075 < 0.0075 0.0005 Mercury < 0.0002 < 0.0002 < 0.0002 0.00077 Nickel < 0.005 < 0.005 < 0.005 0.0082 Selenium < 0.015 < 0.015 < 0.015 0.005 Silver < 0.005 < 0.005 < 0.005 0.00003 Thallium < 0.010 < 0.010 < 0.010 0.11 Zinc < 0.020 < 0.020 < 0.020 0.036 NOTES: 1. Concentrations in milligrams per liter (mg/l, or parts per million). 2. "<" indicates not detected; value is quantitation limit. 3. "MADEP SW Target" = the target value selected by MADEP to use in generation of GW-3 groundwater standards, based on published toxicity information for aquatic organisms in surface water. 4. "NS" = No standard available. Table 2-3 New England Environmental, Inc. SW data.xls /sw OTO Brownfields Investigation (June 2006) -Table 5 Sediment Analytical Results Former Cutlery Raceway Northampton, MA Concentrations in mg/kg Transect 1 (downstream) Transect 2 (side filled raceway) Transect 3 (side unfilled raceway) Transect 4 (upstream) Sample No.: OSS-11 OSS-12 OSS-13 OSS-14 OSS-21 OSS-22 OSS-23 OSS-24 OSS-31 OSS-32 OSS-33 OSS-41 OSS-42 OSS-43 Sediment Depth (inches): 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 0-2 Screening Date Collected: 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 5/23/06 Criteria Extractable Petroleum Hydrocarbons (EPH) C9-C18 Aliphatics < 37 < 35 < 34 < 36 < 37 < 34 < 34 < 38 < 35 < 32 < 34 < 34 < 33 < 31 ---C19-C36 Aliphatics < 37 < 35 < 34 < 36 < 37 < 34 < 34 < 38 < 35 < 32 < 34 < 34 < 33 < 31 ---C11-C22 Aromatics < 37 < 35 < 34 < 36 < 37 < 34 < 34 < 38 < 35 < 32 < 34 < 34 < 33 < 31 ---EPH Target Analytes Naphthalene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.180 2-Methylnaphthalene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Acenaphthylene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Acenaphthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Fluorene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.077 Phenanthrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 1.46 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.200 Anthracene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.48 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.057 Fluoranthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 1.58 < 0.17 < 0.19 0.206 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.420 Pyrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 1.14 < 0.17 < 0.19 0.186 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.200 Benzo(a)anthracene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.289 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.110 Chrysene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.378 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.170 Benzo(b)fluoranthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Benzo(k)fluoranthene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.232 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Benzo(a)pyrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 0.232 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.150 Indeno(1,2,3-cd)pyrene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Dibenzo(a,h)anthracene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 0.033 Benzo(g,h,i)perylene < 0.19 < 0.18 < 0.17 < 0.18 < 0.19 < 0.17 < 0.17 < 0.19 < 0.17 < 0.16 < 0.17 < 0.17 < 0.16 < 0.16 ---Polychlorinated biphenyls (PCBs) < 0.033 ---------< 0.037 ---------< 0.035 ------< 0.037 ------0.060 Metals (Priority Pollutant 13) Antimony 6.98 < 1.72 < 1.84 < 1.82 < 1.93 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 < 1.76 ---Arsenic < 1.88 < 1.72 < 1.84 1.82 2.14 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 1.9 33 Beryllium 0.263 < 0.23 < 0.276 0.273 0.276 < 0.237 < 0.235 < 0.267 < 0.258 < 0.219 0.283 < 0.241 0.274 0.282 ---Cadmium < 0.31 0.436 < 0.306 < 0.303 < 0.321 < 0.296 < 0.294 < 0.334 < 0.322 < 0.274 < 0.307 < 0.302 < 0.286 < 0.294 5 Chromium (III) 15 6.36 7.93 13.1 11.9 3.51 5.64 11.2 9.58 6.96 13.3 8.32 5.18 5.09 110 Copper 66.9 122 28.8 38.7 58.2 22.6 36.4 38.1 53.5 29.4 50.7 16.9 28.6 26 150 Lead 43.1 18.3 14.6 12.3 17.3 8.32 12.5 14.6 15.6 12.6 15 6.19 9.6 11.1 130 Mercury < 0.064 < 0.061 < 0.061 < 0.062 < 0.066 < 0.059 < 0.062 < 0.068 < 0.065 < 0.058 < 0.064 < 0.064 < 0.058 < 0.061 0.18 Nickel 34.8 6.12 5.67 10.2 11.3 3.64 5.67 9.03 10.1 3.83 10.5 6.25 5.19 4.97 49 Selenium < 1.88 < 1.72 < 1.84 < 1.82 < 1.93 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 < 1.76 ---Silver < 1.25 < 1.15 < 1.23 < 1.21 < 1.29 < 1.18 < 1.18 < 1.34 < 1.29 < 1.10 < 1.23 < 1.21 < 1.14 < 1.18 ---Thallium < 1.88 < 1.72 < 1.84 < 1.82 < 1.93 < 1.77 < 1.76 < 2.01 < 1.93 < 1.64 < 1.84 < 1.81 < 1.72 < 1.76 ---Zinc 88.5 191 44 57.2 92.6 35.5 47.9 60.5 74.7 41.2 80.8 30.9 37.2 33.2 460 NOTES: 1. Concentrations in mg/kg (parts per million) on a dry weight basis. "<" indicates not detected; value is sample-specific quantitation limit. "---" indicates not tested or not available. 2. Criteria from "Revised Sediment Screening Values", MADEP/ORS Technical Update, January 2006. Values shown in bold exceed sediment screening criteria. Adjacent to AOC-1 Adjacent to AOC-2 Adjacent to AOC-3 Upstream of Dam Table 2-4 New England Environmental, Inc. sed data.xls /sed AA47470-73 VOCs 8260B 2/1/1996 X X N Y SVOCs 8270 2/1/1996 X X N Y RCRA 8 2/1/1996 X X N TPH 8100M 2/1/1996 X X N GZA-test pits RCRA 8 9/8/1989 X X N L Y 99B21740-41 Pb, Cr 3050/6010 9/30/1999 X X N EPH 98-1 9/30/1999 X X N Y VPH 98-1 9/30/1999 X X N Y preserved according to method 99B26220-230 Pb, Cr 3050/6010 11/15/1999 X X N Y L Y AB94804-11 5Metals 200.7, 245.1 6/30/2000 X X N AB94804-11 Chrom IV SM3500 6/30/2000 X X X N L2000257-1-257-4 PP13 6010B, 7470A 8/7/2000 X X N L Y PP13 6010B, 7470A 8/7/2000 X X X N L Y AC14674-81 PCBs 8082 10/24/2000 X X N PP13 200.7, 245.1 10/24/2000 X X N 5Metals 200.7, 245.1 10/24/2000 X X N Chrom IV SM3500 10/24/2000 X X N Reactivity 7.3 10/24/2000 X X N AC19199-204 VOCs 8260B 11/21/2000 X X N Y SVOCs 8270 11/21/2000 X X N Y TPH 8100M 11/21/2000 X X N 5 Metals 200.7, 245.1 11/21/2000 X X X N AC06587-599 EPH 98-1 9/11/2000 X X N Y VPH 97-12 9/11/2000 X X N Y PP13 200.7, 245.1 9/11/2000 X X N Total Cr, Pb 200.7 9/11/2000 X X N Chrom IV SM3500 9/11/2000 X X X N AC21840-42 PP13 200.7, 245.1 12/7/2000 X X N F Chrom IV SM3500 12/7/2000 X X X N F AC26893-898 RCRA 8 200.7, 245.1 1/16/2001 X X X N AC28035-42 EPH 98-1 1/24/2001 X X N Y PP13 200.7, 245.1 1/24/2001 X X N AC29021 PP13 200.7, 245.1 1/31/2001 X X N AC58756-60 PP13 200.7, 245.1 7/11/2001 X X N AD06317 PP13 200.7, 245.1 7/11/2001 X X N AD24303-330 PP13 200.7, 245.2 6/26/2002 X X X N F EPH 98-1 6/26/2002 X X X N F Y VPH 97-12 6/26/2002 X X X N Y VOCs 8260B 6/26/2002 X X X N Y PCBs 8082 6/26/2002 X X X N Y SVOCs 8270C 6/26/2002 X X X N Y cyanide SM4500 6/26/2002 X X X N pesticides 8081A 6/26/2002 X X X N Y TCLP 1311 6/26/2002 X X X N F 1-3 coal ash PLM, SEM, and EDX 6/26/2002 X X X N 4 coal ash PLM, SEM, and EDX 6/26/2002 X X X N AD75436 PP13 200.7, 245.1 3/24/2003 X X N AE01475-83 PP13 200.7, 245.1 7/23/2003 X X X N Chrom IV 3060A 7/23/2003 X X X N Barium 200.7 7/23/2003 X X X N TCLP 1311 7/23/2003 X X X N SA20413-01-26 PP13 6010B, 7471A 11/10/2004 X X X X Y Y Y L TCLP 1311 11/10/2004 X X X X Y Y Y L SA20717-01-06 PP13 6010B, 7471A 11/17/2004 X X X X Y Y Y L SA20899-01-04 PP13 6010B, 7471A 11/23/2004 X X X X Y Y Y L SA21752-01-03 PP13 6010B, 7471A 12/9/2004 X X X X Y Y Y L TCLP 1311 X X X X Y Y Y L SA27179-01-24 PP13 6010B, 7471A 4/28/2005 X X X X Y Y Y L SA27341-01-09 PP13 6010B, 7471A 5/2/2005 X X X X Y Y Y L PCBs 8082 X X X X Y Y Y L SA27698-01-08 PP13 6010B, 7471A 5/6/2005 X X X X Y Y Y L SA27699-01-04 PP13 6010B, 7471A 5/6/2005 X X X X Y Y Y L SA28476-01 PP13 6010B, 7471A 5/23/2005 X X X X Y Y Y L SA29922-01-15 PP13 6010B, 7471A 6/21/2005 X X X X Y Y Y F/L SA45382-01-04 EPH 3545A 5/15/2006 X X X X Y Y Y L Y PP13 6010B, 7471A X X X X Y Y Y L SA45448-01-19 EPH 3545A 5/23/2006 X X X X X X Y Y Y L Y PP13 6010B, 7471A X X X X X X Y Y Y L PCBs 8082 X X X X Y Y Y L SA46097-01-09 PP13 6010B, 7470A 6/5/2006 X X X X Y Y Y L Results for MW-4 were determined to be inconsistent EPH 3510C X X X X Y Y Y L Y VOCs 5030 X X X X Y Y Y L Y SA46224-01-10 EPH 3545A 6/7/2006 X X X X Y Y Y L Y PP13 6010B, 7471A X X X X Y Y Y L SA46194-01-05 PP13 6010B, 7470A 6/9/2006 X X Y Y Y L Y Total Cr 6010B X X X X X Y Y Y L Chrom IV 3060A X X X X X Y Y Y L Full TCLP 1311 X X X X X Y Y Y L Reactivity, cyanide, sulfide Ch. 7.3 X X X X X Y Y Y L SA51415-01-09 PP13 6010B, 7471A 9/21/2006 X X X X Y Y Y F/L SA86617-01-05 PP13 6010B, 7471A 10/27/2008 X X X X Y Y Y F/L Former Cutlery Building Northampton, MA RTN1-13320 Table 3-Data Summary Table LCS/LCSD SOIL GROUNDWATER SURFACE WATER SEDIMENT EPCs CAM Compliant MS/MSD AIR Risk Assessment Duplicate (F-Field, L=Lab Sample ID or Series Site Characterization Data Qualifications, if Parameters EPA Method Date any Background Disposal Characterization Surrogate OK Confirmatory Samples New England Environmental, Inc. DataSummaryTable /Sheet1 `` 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected NEE-8 2-2.5' 7/23/03 SA-1-N 2-3' 11/10/04 SA-1-E 2-3' 11/10/04 SA-1-S 2-3' 11/10/04 SA-1-W 2-3' 11/10/04 SA-1-Base 3.5' 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/04 Total Metals (mg/kg) Silver BDL BRL BRL 50.0 47.4 5.99 NSL 200 200 2,000 Arsenic 20.5 5.1 19.7 12.4 6.17 8.72 40 20 20 200 Beryllium BDL BRL BRL BRL BRL BRL NSL 200 200 2,000 Cadmium BDL 1.22 2.09 9.16 25.0 2.13 60 30 30 800 Chromium 7,170 1,120 5,400 1,830 2,550 2,200 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na na na na 200 200 200 2,000 Copper 253 53.0 116 142 258 131 NSL NSL NSL NSL Mercury BDL 0.329 BRL 0.338 3.38 0.265 300 30 30 300 Nickel 238 45.1 113 116 88.9 79.6 NSL 700 700 7,000 Lead 2,213 190 127 910 359 321 NSL 300 300 3,000 Antimony BDL BRL BRL BRL BRL BRL NSL 30 30 300 Selenium BDL BRL BRL BRL BRL BRL NSL 800 800 8,000 Thallium BDL BRL BRL BRL BRL BRL NSL 80 80 800 Zinc 214 85.7 63.1 5,020 203 95.6 NSL 5,000 5,000 10,000 Barium 139 na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na 5 TCLP Cr BDL na na na na na 5 TCLP Pb 3.20 na na na na na 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-1 IRA Plan (NEE 6/2006) -Table 1-SA-1 Confirmatory Soil Summary: SA-1 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-1 Excav `` 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-10b 4' 11/15/99 NEE-5 4' 7/23/03 SA-2-N 3-4.5' 11/10/04 SA-2-N2 3-4.5' 12/8/04 SA-2-E 3-4.5' 11/10/04 SA-2-E2 3-4.5' 12/9/04 SA-2-S 3-4.5' 11/10/04 SA-2-W 3-4.5' 11/10/04 SA-2-W2 3-4.5' 12/9/04 SA-2-Base 5' 11/10/04 Stabilized "Stockpile" 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/04 Excavated 11/10/04 Excavated 12/8/04 Excavated 12/9/04 Excavated 12/9/04 Total Metals (mg/kg) Silver na BDL BRL BRL BRL BRL BRL BRL BRL BRL na NSL 200 200 2,000 Arsenic na 16.7 16.3 12.5 34.9 BRL 8.0 26.6 BRL BRL na 40 20 20 200 Beryllium na BDL 1.11 BRL BRL 0.63 BRL BRL 0.658 BRL na NSL 200 200 2,000 Cadmium na BDL 2.53 2.42 4.44 0.99 1.59 3.86 1.46 1.06 na 60 30 30 800 Chromium 2020 10,040 2,510 4,050 18,700 73.0 4,560 15,500 127 958 na 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na BRL na na na na BRL na na 200 200 200 2,000 2,000 Copper na 163 271 515 180 24.4 60.5 173 72.9 39.2 na NSL NSL NSL NSL Mercury na BDL BRL 0.356 BRL BRL BRL BRL BRL BRL na 300 30 30 300 Nickel na 216 59.2 280.0 448 31.3 62.3 207 123 33.2 na NSL 700 700 7,000 Lead 799 356 15,400 390 401 98.9 585 877 938 132 na NSL 300 300 3,000 Antimony na BDL BRL 89.2 BRL 6.09 BRL BRL 10.0 BRL na NSL 30 30 300 Selenium na BDL BRL BRL BRL BRL BRL BRL BRL BRL na NSL 800 800 8,000 Thallium na BDL BRL BRL BRL BRL BRL BRL BRL BRL na NSL 80 80 800 Zinc na 303 450 236 237 54.5 62.8 90.1 155 50.9 na NSL 5,000 5,000 10,000 Barium na 77.9 na na na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na na na na na 5 TCLP Cr na 0.07 na na 0.0373 na na 0.0495 na na na 5 TCLP Pb na 2.67 167 BRL na na na na na na 0.0389 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-2 IRA Plan (NEE 6/2006) -Table 1-SA-2 Confirmatory Soil Summary: SA-2 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-2 Excav Table 4-3 Table 1-SA-3 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-9b 1.5'-2' 11/15/99 TP-9b 4' 11/15/99 SA-3-N 3-5' 11/10/04 SA-3-N2 3-5' 11/16/04 SA-3-N3 3-5' 11/23/04 SA-3-E 3-5' 11/10/04 SA-3-S 3-5' 11/10/04 SA-3-W 3-5' 11/10/04 SA-3-W2 3-5' 11/16/04 SA-3-W3 3-5' 11/23/04 SA-3-Base 5.5' 11/10/04 TP-9b 6'-7' 11/15/99 Stabilized "Stockpile" 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/03 Excavated 11/10/04 Excavated 11/16/04 Excavated 11/23/04 Excavated 11/16/04 Excavated 11/23/04 see note #9 below Total Metals (mg/kg) Silver na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 200 200 2,000 Arsenic na na 34.2 BRL BRL 6.37 16.4 34.0 BRL BRL 5.78 na na 40 20 20 200 Beryllium na na BRL BRL BRL BRL 1.86 BRL BRL 0.697 BRL na na NSL 200 200 2,000 Cadmium na na 7.12 2.92 BRL 0.93 2.92 3.4 2.6 0.675 1.69 na na 60 30 30 800 Chromium 3350 3810 24,900 9,650 1,130 3,090 4,510 12,100 8,720 430 2,320 38.4 na 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na na na na na na na na na na na 200 200 200 2,000 Copper na na 290 294 211 52.7 135 185 188 95.1 110 na na NSL NSL NSL NSL Mercury na na BRL 0.40 0.31 BRL 0.285 BRL BRL 0.225 0.987 na na 300 30 30 300 Nickel na na 292 146 41.1 54.5 125 198.0 167.0 28.4 78.9 na na NSL 700 700 7,000 Lead 346 719 256 914 119 355 359 1,350 675 1,100 277 35 na NSL 300 300 3,000 Antimony na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 30 30 300 Selenium na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 800 800 8,000 Thallium na na BRL BRL BRL BRL BRL BRL BRL BRL BRL na na NSL 80 80 800 Zinc na na 103 BRL 113 77.4 583 193 BRL 82.4 197.0 na na NSL 5,000 5,000 10,000 Barium na na na na na na na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na na na na na na na 5 TCLP Cr na 0.120 0.106 na na na na 0.0382 na na na na na 5 TCLP Pb na 11.7 0.0146 na na 2.02 0.0530 0.0862 na na 0.0490 na 0.0389 5 Notes: 1. Results in red (bold) exceed listed standard. Note #9. Shows the decrease in concentration with depth at this location. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-3 IRA Plan (NEE6/2006) -Table 1-SA-3 Confirmatory Soil Summary: SA-3 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-3 Excav `` 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-1 4'-5' 9/29/99 NEE-3 2-3' 7/23/03 SA-4-N 2-3' 11/10/04 SA-4-E 2-3' 11/10/04 SA-4-S 2-3' 11/10/04 SA-4-W 2-3' 11/10/04 SA-4-Base 4.5' 11/10/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/04 Excavated 11/10/04 Total Metals (mg/kg) Silver na BDL BRL BRL BRL BRL BRL NSL 200 200 2,000 Arsenic na BDL 7.44 25.4 16.5 BRL 19.9 40 20 20 200 Beryllium na BDL BRL BRL 0.449 0.45 0.60 NSL 200 200 2,000 Cadmium na BDL 1.45 1.22 BRL 1.11 1.32 60 30 30 800 Chromium 2,820 57,000 3,250 3,070 171 848 1,590 1000* 5000 5,000 10,000 Chromium, Hexavalent na BDL na na na na na 200 200 200 2,000 Copper na 1,540 70.6 106 31.8 35.6 57.7 NSL NSL NSL NSL Mercury na BDL 0.228 BRL BRL BRL BRL 300 30 30 300 Nickel na 5,206 58.6 52.7 11 43.8 45.4 NSL 700 700 7,000 Lead 936 142 88.7 192 45.6 45.6 216 NSL 300 300 3,000 Antimony na BDL BRL BRL BRL BRL BRL NSL NSL 30 30 300 Selenium na BDL BRL BRL BRL BRL BRL NSL 800 800 8,000 Thallium na BDL BRL BRL BRL BRL BRL NSL 80 80 800 Zinc na BDL 57.9 52.7 BRL 64.3 71.3 NSL 5,000 5,000 10,000 Barium na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na 5 TCLP Cr na BDL na na na na na 5 TCLP Pb na 0.21 na na na na na 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-4 IRA Plan (NEE 6/2006) -Table 1-SA-4 Confirmatory Soil Summary: SA-4 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-4 Excav Table 4-5 Table 1-SA-5 2006 MCP Standards Regulatory Standards Sapmle ID: Depth (ft.) Date Collected TP-7 3' 11/15/99 NEE-2 2-2.5' 7/23/03 SA-5-N 2-3' 11/10/04 SA-5-N2 2-3' 11/16/04 SA-5-NE3 2-3' 11/23/04 SA-5-E 2-3' 11/10/04 SA-5-E2 2-3' 11/16/04 SA-5-E3 2-3' 11/23/04 SA-5-S 2-3' 11/10/04 SA-5-S2 2-3' 11/16/04 SA-5-W 2-3' 11/10/04 SA-5-W2 2-3' 11/16/04 SA-5-Base 3.5' 11/10/04 SA-5-Base2 4' 11/16/04 Imminent Hazard (mg/kg) Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) TCLP Land Disposal Criteria Excavated 11/10/03 Excavated 11/10/04 Excavated 11/16/04 Excavated 11/23/04 Excavated 11/16/04 Excavated 11/23/04 Excavated 11/16/04 Excavated 11/16/04 Excavated 11/16/04 Total Metals (mg/kg) Silver na BDL BRL 16.2 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 200 200 2,000 Arsenic na 24.1 21.4 BRL BRL 66.6 BRL 6.9 26.4 BRL 5.85 BRL 37.2 BRL 40 20 20 200 Beryllium na BDL BRL BRL BRL 0.58 BRL 0.6 BRL BRL 0.44 BRL BRL BRL NSL 200 200 2,000 Cadmium na BDL 3.19 3.27 BRL 1.66 3.38 BRL 1.94 1.66 1.23 0.73 3.28 0.73 60 30 30 800 Chromium 2740 11,800 10,300 9,420 3,500 3,980 8,900 24.6 6,390 4,860 856 447 9,740 447 1000* 5000 5,000 10,000 Chromium, Hexavalent na na na na na na na na na na na na na na 200 200 200 2,000 Copper na 212 322 400 67.7 78 179 22.8 128 BRL 43.8 BRL 191 BRL NSL NSL NSL NSL Mercury na 1.07 0.601 1.25 BRL BRL 4.67 BRL BRL BRL BRL BRL 7.0 BRL 300 30 30 300 Nickel na 285 248 317 97.7 61.7 171.0 13.2 116 82.5 34.5 18.5 199 18.5 NSL 700 700 7,000 Lead 1,350 1,990 433 301 151 103 1,490 149 1,250 254 380 32.7 692 32.7 NSL 300 300 3,000 Antimony na BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 30 30 300 Selenium na BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 800 800 8,000 Thallium na BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NSL 80 80 800 Zinc na 288 190 BRL 102 131 BRL 144 69.6 BRL 50.5 BRL 159 BRL NSL 5,000 5,000 10,000 Barium na na na na na na na na na na na na na na NSL 5,000 5,000 10,000 TCLP Metals (mg/L) TCLP As na na na na na na na na na na na na na na 5 TCLP Cr na BDL na na na na na na na na na na na na 5 TCLP Pb na 2.92 na na na na na na na na na na na na 5 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. Table 4-5 IRA Plan (6/2006) -Table 1-SA-5 Confirmatory Soil Summary: SA-5 Excavation Former Cutlery Raceway, Northampton, MA RTN #1-13320 Side-By-Side AOC-2 AOC-1 New England Environmental, Inc. 02-2053_Lab Table-SOIL-SAsSA-5 Excav Table 4-6 Table 4-6 Laboratory Results -PP13 Metals in Soil Former Cutlery Building Northampton, MA Regulatory Standards Sample I.D.: Sample Depth: CB-1 0-3" CB-2 0-3" CB-3 0-3" CB-4 0-3" CB-5-SED 0-3" CB-6 0-3" CB-7 0-3" CB-8 0-3" CB-9 0-3" CB-10 0-3" CB-11-SED 0-3" CB-12 0-3" CB-13 0-3" CB-14-SED 0-3" CB-15 0-3" Method 1 Standard Sampling Date: 5/23/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Excavated Excavated Excavated Metals (mg/Kg) lt. g br dk g, bl dk g t,br dk g, br dk br, g r, br o, br br t,br dk g, mr dk br br lt g, br, dk g Silver BDL BRL BRL 3.01 BRL BRL BRL BRL BRL BRL 12.5 6.04 BRL BRL BRL NBL 100 100 100 100 NSL 2,000 Arsenic <31.7 10.5 BRL BRL BRL BRL BRL 32.5 BRL 32.7 BRL 10.9 BRL BRL BRL 9.79 20 20 20 20 40 200 Beryllium <4.22 1.23 BRL BRL BRL BRL BRL 0.761 0.55 0.757 BRL BRL BRL 0.48 BRL NBL 100 100 100 100 NSL 2000 Cadmium BDL 1.34 BRL 0.884 BRL 1.06 BRL BRL BRL 1.11 BRL 1.2 BRL BRL BRL 0.99 2 2 2 2 60 300 Chromium (III) 25000 1910 1830 4110 89.5 4090 940 345 75.7 1110 1130 4690 78.1 76.8 5760 43.4 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 269 298 112 241 142 176 58.7 452 43.1 213 315 333 59.4 83.9 106 31.6 1,000 NSL NSL NSL NSL NSL Mercury BDL 1.6 0.483 0.439 0.368 0.66 0.408 0.24 BRL 1.68 6.22 0.889 BRL BRL 21.9 0.18 20 20 20 20 300 300 Nickel 669 188 111 165 96.3 188 53.5 565 19.8 225 545 163 17.1 45.6 142 22.7 20 20 20 20 NSL 7,000 Lead 220 216 505 753 128 1040 238 506 664 1260 329 4480 252 81.3 246 35.8 300 300 300 300 NSL 3,000 Antimony <31.7 BRL BRL BRL BRL BRL BRL BRL BRL 143 BRL 471 BRL BRL BRL NBL 20 20 20 20 NSL 300 Selenium BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 400 400 400 400 NSL 8,000 Thallium <31.7 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 8 8 8 8 NSL 800 Zinc 79.4 773 333 418 129 597 58 103 65 447 281 657 109 101 411 121 2500 2500 2500 2500 NSL 10,000 Excavated Excavated Excavated Notes: Color Codes: 1. Results in red (bold) exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark Regulatory Standards Sample I.D.: Sample Depth: CB-16-SED 0-3" CB-17 0-3" CB-18 0-3" CB-19 0-3" CB-CS-1 0-3" CB-CS-2 0-3" CB-CS-3 0-3" CB-CS-4 0-3" CB-CS-5 0-3" DUP (CB-CS-5) CB-CS-6 0-3" CB-CS-7 0-3" CB-CS-8 0-3" Method 1 Standard Sampling Date: 6/9/06 6/9/06 6/9/06 6/9/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) Silver BRL 2.69 2.59 BRL 16.1 4.07 5.32 1.76 1.43 BRL BRL 2.76 1.46 NBL 100 100 100 100 NSL 2,000 Arsenic 2.91 18.3 16.6 9.16 BRL BRL BRL BRL BRL BRL BRL BRL 76.6 9.79 20 20 20 20 40 200 Beryllium 0.437 0.569 0.343 0.449 BRL 0.244 0.254 0.215 0.405 BRL BRL 0.514 0.779 NBL 100 100 100 100 NSL 2000 Cadmium 0.313 0.847 1.37 0.599 2.49 1.67 1.44 0.806 0.922 1.65 BRL 0.927 0.814 0.99 2 2 2 2 60 300 Chromium (III) 34 2720 2590 274 2230 3060 3760 2740 107 3490 4560 1760 877 43.4 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 162 138 124 45 1310 163 133 66.9 200 117 79.5 197 513 31.6 1,000 NSL NSL NSL NSL NSL Mercury 0.304 0.198 0.627 0.193 0.719 0.434 0.221 0.284 0.583 0.286 0.191 0.242 0.203 0.18 20 20 20 20 300 300 Nickel 185 115 89 38 2650 222 192 85.9 91.5 184 136 282 736 22.7 20 20 20 20 NSL 7,000 Lead 54.3 610 567 286 1560 1020 1190 915 176 312 475 429 432 35.8 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL 2.14 265 17.2 20.6 10.9 1.74 21 20.3 18.2 9.41 NBL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL 2.27 2.39 1.57 1.89 BRL BRL 2.42 3.49 NBL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 8 8 8 8 NSL 800 Zinc 79.8 105 464 66.4 574 506 781 351 173 315 247 162 117 121 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold) exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark IRA Completion (NEE 01/2008) -Table 1 UCLs (mg/kg) UCLs (mg/kg) Imminent Hazard TEC9 Benchmarks RC S-1 Imminent Hazard TEC9 Benchmarks Confirmatory Soil Samples RC S-1 New England Environmental, Inc. PP13-CB 02-2053_Lab Table_Phase IV_soil-updated09 Table 5 Table 2 Laboratory Results -PP13 Metals in Soil Former Cutlery Raceway Northampton, MA Regulatory Standards Sample I.D.: Sample Depth: LE-1 0-3" LE-2 0-3" LE-3 0-3" LE-4 0-3" LE-5 0-3" LE-6 0-3" LE-7 0-3" LE-8 0-3" LE-9 0-3" LE-10 0-3" LE-11 0-3" LE-12 0-3" LE-13 0-3" LE-14 0-3" LE-15 0-3" LE-16 0-3" LE-17 0-3" LE-18 0-3" LE-19 0-3" LE-20 0-3" LE-21 0-3" LE-22 0-3" LE-23 0-3" Method 1 Standard Sampling Date: 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) br,g,c dk.br,o,c lt.g,r/br lt.br,t "clean" y,g,br br,o dk.g t,br, grn hue p/r br br, grn hue c, ash, not ex lt.g r/br,y g dk.g, br t br, not ex br,c,ash br dk.br,c g g, sparkles Silver BRL 3.45 BRL BRL BRL 14.7 14.9 BRL BRL 2.47 6.75 BRL BRL BRL 4.21 BRL BRL 6.09 3.43 BRL BRL BRL BRL 100 100 100 100 NSL 2,000 Arsenic BRL 17.7 BRL 7.53 23 39.1 33.2 25.6 107 14.5 29.6 15.3 17.8 7.42 23.8 BRL BRL 21.4 17.8 13.9 13.1 6.44 BRL 20 20 20 20 40 200 Beryllium 0.522 BRL 0.471 0.499 0.645 BRL 0.682 0.674 2.05 0.577 0.668 1.06 0.453 0.484 0.603 BRL 0.598 BRL 0.912 0.541 0.795 0.528 0.463 100 100 100 100 NSL 2000 Cadmium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 2 2 2 2 60 300 Chromium (III) 1080 101 148 785 280 18.1 520 376 22.7 528 519 547 2070 30.3 723 9470 43 59 1270 1050 3690 1300 8050 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 117 11100 28.6 310 4610 431 21400 1150 141 19100 6410 1820 767 60.6 11800 359 43.6 12100 4970 3100 1670 859 2800 1,000 NSL NSL NSL NSL NSL Mercury BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 0.315 BRL BRL BRL BRL BRL 0.51 BRL BRL 20 20 20 20 300 300 Nickel 148 22800 97.5 566 9080 437 46300 1830 1040 35700 13000 3740 1600 812 23700 677 346 26500 7910 4950 2910 1650 5250 20 20 20 20 NSL 7,000 Lead 118 156 63.1 93.5 219 252 271 219 140 436 394 136 201 75.6 278 842 69.3 227 324 241 133 161 195 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 36.9 125 27.9 53.4 97.8 117 144 80.7 29.4 186 119 20 66.7 43.4 71.8 44.6 46.5 75.7 41.2 126 50.7 57.1 300 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold)exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark Sediment Samples: sand collected on the Beach Regulatory Standards Sample I.D.: Sample Depth: LE-25 0-3" LE-26 0-3" LE-27 0-3" LE-28 0-3" LE-29 0-3" LE-30 0-3" LE-31 0-3" LE-32 0-3" LE-33 0-3" LE-34 0-3" LE-35 0-3" LE-36 0-3" LE-37 0-3" LE-38 0-3" LE-39 0-3" LE-40 0-3" LE-24 0-3" B-1 0-3" B-2 0-3" B-3 0-3" B-4 0-3" Method 1 Standard Sampling Date: 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 4/28/05 5/6/05 5/6/05 5/6/05 5/6/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) dk.br,c r/o p/r dk.br, bl, g dk.g, bl t, br lt.g, sparkles bl, grn lt.br, t mr dk.br,g dk.br,bl grn,t bl br dk.br t,br lt.g, w lt.br,g,grn hue lt.br,g,grn hue t,grn Silver BRL BRL BRL 4.16 BRL BRL BRL BRL 3.77 5.14 7.98 11.4 BRL 11.1 BRL 8.32 BRL BRL BRL BRL BRL NBL 100 100 100 100 NSL 2,000 Arsenic 14.2 28.2 213 39.2 20.2 5.85 BRL 18.2 21.8 40.3 56.3 104 BRL 667 BRL 19.6 BRL BRL BRL BRL BRL 9.79 20 20 20 20 40 200 Beryllium 0.637 0.551 3.56 0.861 0.53 0.571 BRL BRL 0.557 BRL BRL BRL 0.434 1.17 0.487 BRL BRL BRL BRL 0.511 BRL NBL 100 100 100 100 NSL 2000 Cadmium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 0.99 2 2 2 2 60 300 Chromium (III) 759 36.1 99.8 166 1880 65.9 19.6 9340 45 54.1 2310 1450 32.2 1240 18.4 349 52.5 16.6 21.2 39.5 38.5 43.4 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 911 287 1490 2360 34000 160 32.4 1730 3500 5260 18800 31100 27.1 300 8.93 4290 87.7 65 98.7 90.8 159 31.6 1,000 NSL NSL NSL NSL NSL Mercury 0.22 0.23 BRL BRL BRL BRL BRL BRL BRL 0.243 0.665 0.227 BRL 1.23 BRL BRL BRL BRL BRL BRL BRL 0.18 20 20 20 20 300 300 Nickel 1460 1320 2580 4280 86100 452 74.4 4140 6500 9920 46100 75900 107 149 142 9100 56.6 89 162 21.6 317 22.7 20 20 20 20 NSL 7,000 Lead 164 264 452 537 130 80.6 25.9 155 128 157 147 184 24.5 1080 12.2 374 24.7 16.4 15 30.7 38.6 35.8 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL 13.3 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 771 BRL BRL BRL BRL BRL BRL BRL NBL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL 16.6 BRL BRL 21.4 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 8 8 8 8 NSL 800 Zinc 79 90.4 127 89.5 80.8 30.8 31.8 274 100 143 288 121 21.2 164 25.3 97.7 86.1 43.2 98.6 124 30.9 121 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold)exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue= Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. 9 -Shaded Rose -Exceeds TEC Benchmark IRA PLAN (NEE 06/2006) -Table 2 UCLs (mg/kg) UCLs (mg/kg) Imminent Hazard RC S-1 Imminent Hazard TEC9 Benchmar ks RC S-1 New England Environmental, Inc. PP13-Levee 02-2053_Lab Table_Phase IV_soil-updated09 Table 6-1 AOC-1 Maximum and Minimum Concentrations of Detected Contaminants Former Cutlery Raceway, Northampton MA RTN #1-13320 Media Type: UCL in Soil Method 1 Standard UCL in GW Maximum Minimum Maximum Minimum S-1/GW-2 S-1/GW-3 Maximum Minimum GW-3 Units: mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg ug/L ug/L ug/L ug/L EPH Aliphatics & Aromatics C9-C18 Aliphatics BDL BDL 190 BDL 1,000 1,000 20,000 BDL BDL 50,000 100,000 C19-C36 Aliphatics BDL BDL 4,300 BDL 3,000 3,000 20,000 BDL BDL 50,000 100,000 C11 -C22 Aromatics BDL BDL 682 BDL 1,000 1,000 10,000 BDL BDL 5,000 100,000 EPH Target Analytes Napthalene BDL BDL BDL BDL 40 500 10,000 BDL BDL 20,000 100,000 2-Methylnapthalene BDL BDL 0.490 BDL 80 300 5,000 BDL BDL 20,000 100,000 Acenaphthylene BDL BDL BDL BDL 600 10 10,000 BDL BDL 40 100,000 Acenaphthene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 6,000 60,000 Fluorene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 40 400 Phenanthrene BDL BDL 2.000 BDL 500 500 10,000 BDL BDL 10,000 100,000 Anthracene BDL BDL 0.400 BDL 1,000 1,000 10,000 BDL BDL 30 600 Fluoranthrene BDL BDL 2.300 BDL 1,000 1,000 10,000 BDL BDL 200 2,000 Pyrene BDL BDL 1.900 BDL 1,000 1,000 10,000 BDL BDL 20 800 Benzo (a) anthracene BDL BDL 0.820 BDL 7 7 3,000 BDL BDL 1,000 10,000 Chrysene BDL BDL 0.824 BDL 70 70 10,000 BDL BDL 70 700 Benzo (b) fluoranthene BDL BDL 0.620 BDL 7 7 3,000 BDL BDL 400 4,000 Benzo (k) fluoranthene BDL BDL 0.480 BDL 70 70 10,000 BDL BDL 100 1,000 Benzo (a) pyrene BDL BDL 0.300 BDL 2 2 300 BDL BDL 500 5,000 Indeno (1,2,3,-cd) pyrene BDL BDL 0.600 BDL 7 7 3,000 BDL BDL 100 1,000 Dibenzo (a,h) anthracene BDL BDL BDL BDL 0.7 0.7 300 BDL BDL 40 400 Benzo (g,h,I,) perylene BDL BDL 0.300 BDL 1,000 1,000 10,000 BDL BDL 20 500 VPH Aliphatics & Aromatics C5-C8 Aliphatics na na BDL BDL 100 100 5,000 na na 50,000 100,000 C9-C12 Aliphatics na na 3.7 BDL 1,000 1,000 20,000 na na 50,000 100,000 C9 -C10 Aromatics na na 8.0 BDL 100 100 5,000 na na 50,000 100,000 VPH Target Analytes Napthalene na na 0.660 BDL 40 500 10,000 na na 20,000 100,000 Polychlorinated Biphenyls (mg/Kg) PCBs (total) na na BDL BDL 2 2 100 na na 10 100 Total Metals Antimony 6.98 BDL 471 BDL 20 20 300 BDL BDL 8,000 80,000 Arsenic 16.00 BDL 76.6 BDL 20 20 200 BDL BDL 900 9,000 Beryllium 0.26 BDL 1.86 BDL 100 100 2000 BDL BDL 200 2,000 Cadmium 6.02 BDL 25 BDL 2 2 300 BDL BDL 4 50 Chromium 71.70 5.26 5,760 24.60 1000 1000 10000 BDL BDL 600 6,000 Chromium, Hexavalent na na BDL BDL 30 30 2000 na na 300 3,000 Copper 122 29 1,310 22.8 NSL NSL NSL BDL BDL NSL NSL Lead 66.50 8.52 1,100 37.20 300 300 3,000 BDL BDL 10 150 Nickel 88 5.67 2,650 11.0 20 20 7,000 20.9 BDL 200 2,000 Selenium 9.43 BDL 3.49 BDL 400 400 8,000 BDL BDL 100 1000 Silver BDL BDL 50.00 BDL 100 100 2,000 BDL BDL 7 1000 Thallium BDL BDL BDL BDL 8 8 800 BDL BDL 3000 30,000 Zinc 191 40 5,020 50.9 2500 2500 10,000 3.8 BDL 900 50,000 Mercury 0.47 BDL 21.9 BDL 20 20 300 BDL BDL 20 200 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit 5. na = Not Analyzed for this parameter. 6. Results from soil sample IHS-13 not included because this material has been removed from the Site. 7. Red (bold & shaded orange) = Exceeds UCL Standard Sediment Soil Method 1 Standard Groundwater Table 6-2 AOC-2 & AOC-3 Maximum and Minimum Concentrations of Detected Contaminants Former Cutlery Raceway, Northampton MA RTN #1-13320 Media Type: UCL in Soil Method 1 Standard UCL in GW Maximum Minimum Maximum Minimum S-1/GW-2 S-1/GW-3 Maximum Minimum GW-3 Units: mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg ug/L ug/L ug/L ug/L EPH Aliphatics & Aromatics C9-C18 Aliphatics BDL BDL 500 BDL 1,000 1,000 20,000 BDL BDL 50,000 100,000 C19-C36 Aliphatics BDL BDL 8,300 BDL 3,000 3,000 20,000 BDL BDL 50,000 100,000 C11 -C22 Aromatics BDL BDL 1,200 BDL 1,000 1,000 10,000 BDL BDL 5,000 100,000 EPH Target Analytes Napthalene BDL BDL 0.66 BDL 40 500 10,000 BDL BDL 20,000 100,000 2-Methylnapthalene BDL BDL 0.490 BDL 80 300 5,000 BDL BDL 20,000 100,000 Acenaphthylene BDL BDL BDL BDL 600 10 10,000 BDL BDL 40 100,000 Acenaphthene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 6,000 60,000 Fluorene BDL BDL BDL BDL 1000 1000 10,000 BDL BDL 40 400 Phenanthrene 1.46 BDL 2 BDL 500 500 10,000 BDL BDL 10,000 100,000 Anthracene 0.48 BDL 0.4 BDL 1,000 1,000 10,000 BDL BDL 30 600 Fluoranthrene 1.58 BDL 2.3 BDL 1,000 1,000 10,000 BDL BDL 200 2,000 Pyrene 1.14 BDL 1.9 BDL 1,000 1,000 10,000 BDL BDL 20 800 Benzo (a) anthracene 0.289 BDL 0.82 BDL 7 7 3,000 BDL BDL 1,000 10,000 Chrysene 0.378 BDL 0.824 BDL 70 70 10,000 BDL BDL 70 700 Benzo (b) fluoranthene BDL BDL 0.62 BDL 7 7 3,000 BDL BDL 400 4,000 Benzo (k) fluoranthene 0.232 BDL 0.48 BDL 70 70 10,000 BDL BDL 100 1,000 Benzo (a) pyrene 0.232 BDL 0.3 BDL 2 2 300 BDL BDL 500 5,000 Indeno (1,2,3,-cd) pyrene BDL BDL 0.6 BDL 7 7 3,000 BDL BDL 100 1,000 Dibenzo (a,h) anthracene BDL BDL BDL BDL 0.7 0.7 300 BDL BDL 40 400 Benzo (g,h,I,) perylene BDL BDL 0.3 BDL 1,000 1,000 10,000 BDL BDL 20 500 VPH Aliphatics & Aromatics C5-C8 Aliphatics na na BDL BDL 100 100 5,000 na na 50,000 100,000 C9-C12 Aliphatics na na 3.7 BDL 1,000 1,000 20,000 na na 50,000 100,000 C9 -C10 Aromatics na na 8.0 BDL 100 100 5,000 na na 50,000 100,000 VPH Target Analytes Napthalene na na 0.660 BDL 40 500 10,000 na na 20,000 100,000 Polychlorinated Biphenyls (mg/Kg) PCBs (total) na na 250.2 BDL 2 2 100 na na 10 100 Total Metals Antimony 2.40 BDL 3,100 BDL 20 20 300 BDL BDL 8,000 80,000 Arsenic 16 BDL 327 BDL 20 20 200 BDL BDL 900 9,000 Beryllium 0.28 BDL 2.64 BDL 100 100 2000 BDL BDL 200 2,000 Cadmium 6.02 BDL 20.3 BDL 2 2 300 BDL BDL 4 50 Chromium 71.70 3.51 57,000 5.18 1000 1000 10000 43.1 BDL 600 6,000 Chromium, Hexavalent na na BDL BDL 30 30 2000 na na 300 3,000 Copper 90.0 22.6 41,900 5.3 NSL NSL NSL 11.7 BDL NSL NSL Lead 66.5 8.32 114,000 7.2 300 300 3,000 15.8 BDL 10 150 Nickel 88 3.64 111,000 13.1 20 20 7,000 735 BDL 200 2,000 Selenium 9.43 BDL BDL BDL 400 400 8,000 BDL BDL 100 1000 Silver BDL BDL 35.7 BDL 100 100 2,000 BDL BDL 7 1000 Thallium BDL BDL 19.3 BDL 8 8 800 BDL BDL 3000 30,000 Zinc 144.0 35.5 2,150 14.5 2500 2500 10,000 493 BDL 900 50,000 Mercury 0.47 BDL 3.08 BDL 20 20 300 BDL BDL 20 200 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit 5. na = Not Analyzed for this parameter. 6. Results from soil sample IHS-13 not included because this material has been removed from the Site. 7. Red (bold & shaded orange) = Exceeds UCL Standard Sediment Soil Method 1 Standard Groundwater Page 1 of 2 Table 7 Toxicity Values for Site Compounds Cancer Slope Factors Oral Inhalation Ref Weight Slope Factor Unit Risk Slope Factor of Study Information Compound name (mg/(kg*d))-1 (ug/m3)-1 (mg/(kg*d))-1 Evidence PCBs PCBs 2.0E+00 1.0E-04 2.0E+00 I B2 Rat dietary studies-liver tumors; Inhalation unit risk based on oral studies data Metals Antimony none none none I Arsenic 1.5E+00 4.0E-03 1.5E+01 I A Human occupational inhalation respiratory tumors Beryllium none 2.4E-03 8.4E+00 I B1(inh) Human occupational exposure resulting in lung cancer Cadmium none 1.8E-03 6.3E+00 I B1(inh) Lung tumors in human occupational studies Chromium (+III) none none none I D(+III) No human data; inadequate animal data Copper none none none I D No human data; inadequate animal data Lead none none none I B2 Renal tumors in rats and mice by diet and subcutaneous routes Mercury none none none I D No human data; inadequate animal data Nickel none 4.8E-04 1.7E+00 I A (inh) Lung and nasal tumors in nickel refinery workers Selenium none none none I D No human data; inadequate animal data Silver none none none I D Thallium (chloride) none none none I D No human data; inadequate animal data Zinc none none none I D Notes: NA -Not Available. 1 -Subchronic RfD and RfC assumed to be the same value as the Chronic RfD and RfC, unless presented otherwise in HEAST or MassDEP, 2008a R -Route-to-route extrapolation. References: DEP08 -MassDEP, 2008a. 310 CMR 40.0000, The Massachusetts Contingency Plan. MCP Numerical Standards Derivation. Workbook: MCP Toxicity. February 2008. Updated in MassDEP Shortforms, Vlookup Version v0808. H97 -USEPA, 1997a. Health Effects Assessment Summary Tables (HEAST). July 1997. (A) -Alternate. I -USEPA, 2009. IRIS -Integrated Risk Information System. August 2009. TOXval0809 8/3/2009 Page 2 of 2 Table 7 Toxicity Values for Site Compounds Reference Doses and Reference Concentrations Oral Inhalation Chronic Subchronic Chronic Subchronic RfD RfD 1 RfC RfC 1 Study Information Critical Effect or Target Organ Compound name (mg/(kg*d)) (mg/(kg*d)) Ref (ug/m3) (ug/m3) Ref Oral; Inhalation Oral; Inhalation PCBs PCBs 2.0E-05 5.0E-05 I, H97 2.0E-02 2.0E-02 DEP08 Monkey clinical and immunologic studies Ocular, nail, and blood effects Metals Antimony 4.0E-04 4.0E-04 I, H97 1.0E+01 1.0E+01 DEP08 Rat chronic oral study Longevity and blood Arsenic 3.0E-04 3.0E-04 I, H97 2.5E-03 2.5E-03 DEP08 Human oral exposure Skin keratosis and hyperpigmentation Beryllium 2.0E-03 5.0E-03 I, H97 2.0E-02 2.0E-02 I Dog dietary study; Occupational and community exposure studies Small intestine; Beryllium sensitization progressing to chronic beryllium disease Cadmium 1.0E-03 1.0E-03 I 2.0E-02 2.0E-02 DEP08 Chronic human oral exposure None observed Chromium (+III) 1.5E+00 1.5E+00 I 1.0E-01 3.0E-01 I Rat chronic feeding study; Rat subchronic study None observed; Respiratory effects Copper 4.0E-02 4.0E-02 H97 NA NA H97 Human single oral dose Gastrointestinal Lead 7.5E-04 7.5E-04 DEP08 1.0E+00 1.0E+00 DEP08 Back-calculated from drinking water action level Central nervous system; Central nervous system Mercury 1.0E-04 1.0E-04 I 3.0E-01 3.0E-01 I Human epidemiological study; human occup. inhalation exposure Nervous system; nervous system Nickel 2.0E-02 2.0E-02 I, H97 1.0E+00 1.0E+00 DEP08 Rat chronic oral study Decreased body and organ weights Selenium 5.0E-03 5.0E-03 I, H97 3.0E+00 3.0E+00 DEP08 Human epidemiological study Clinical selenosis Silver 5.0E-03 5.0E-03 I, H97 1.4E-01 1.4E-01 DEP08 Human oral study Skin discoloration Thallium (chloride) 8.0E-05 8.0E-04 I 1.4E-02 1.4E-02 DEP08 Rat subchronic oral study Blood chemistry Zinc 3.0E-01 3.0E-01 I, H97 1.4E+00 1.4E+00 DEP08 Human dietary supplement study Blood Notes: NA -Not Available. 1 -Subchronic RfD and RfC assumed to be the same value as the Chronic RfD and RfC, unless presented otherwise in HEAST or MassDEP, 2008a R -Route-to-route extrapolation. References: DEP08 -MassDEP, 2008a. 310 CMR 40.0000, The Massachusetts Contingency Plan. MCP Numerical Standards Derivation. Workbook: MCP Toxicity. February 2008. Updated in MassDEP Shortforms, Vlookup Version v0808. H97 -USEPA, 1997a. Health Effects Assessment Summary Tables (HEAST). July 1997. (A) -Alternate. I -USEPA, 2009. IRIS -Integrated Risk Information System. August 2009. TOXval0809 8/3/2009 Page 1 of 1 Ingestion Soil Dermal Soil Compound Name Carcinogen Non-Carcinogen Carcinogen Non-Carcinogen PCBs 0.85 0.85 0.16 0.16 Metals Antimony NC 1 NC 0.1 Arsenic 1 1 0.03 0.03 Beryllium NC 1 NC 0.03 Cadmium NC 1 NC 0.14 Chromium (III) NC 1 NC 0.04 Copper NC 1 NC 0.1 Lead NC 0.5 NC 0.006 Mercury NC 1 NC 0.05 Nickel NC 1 NC 0.35 Selenium NC 1 NC 0.002 Silver NC 1 NC 0.25 Thallium NC 1 NC 0.01 Zinc NC 1 NC 0.02 NC -Non-carcinogen MassDEP, 2008a. Table 8 Relative Absorption Factors (RAFs) RAF2008 8/3/2009 Table 9 Exposure Assumptions and Equations for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates Construction Worker -Soil: Table CW-2 Vlookup Version v0808 Equations to Calculate Cancer Risk for Construction Worker Cancer Risk from Ingestion Parameter Value Units CSF OHM-specific (mg/kg-day)-1 ELCRing = LADDing * CSForal LADD age/OHM-specific mg/kg-day EPC OHM-specific mg/kg IR 100 mg/day RAFc-ing OHM-specific dimensionless RAFc-derm OHM-specific dimensionless Cancer Risk from Dermal Absorption RAFc-inh OHM-specific dimensionless EF 0.714 event/day ELCRderm = LADDderm * CSForal EDing & derm 1 day/event EDinh 0.333 day/event EP 182 days C1 1.0E-06 kg/mg C2 1.0E-09 kg/μg Cancer Risk from Particulate Inhalation -Gastrointestinal Absorption C3 1440 min/days C4 1.0E-03 m3/L ELCRinh-GI = LADDinh-GI * CSForal BW 58.0 kg AP(lifetime) 25,550 days LADDinh-GI = VRwork 60 L/min AF 0.29 mg/cm2 SA 3473 cm2/day Cancer Risk from Particulate Inhalation -Pulmonary Absorption RCAFinh-gi 1.5 dimensionless RCAFinh 0.5 dimensionless ELCRinh = LADDinh* CSFinhalation PM10 60 μg/m3 LADDing = LADDderm = EPC * IR * RAFc-ing * EF * EDing * EP * C1 BW * APlifetime BW * APlifetime EPC * SA * AF * RAFc-derm * EF * EDderm * EP * C1 BW * APlifetime LADD = EPC * RCAFinh-gi * PM10 * VRwork * RAFc-ing * EF * EDinh * EP * C2 * C3 * C4 BW * APlifetime EPC * RCAFinh * PM10 * VRwork * RAFc-inh * EF * EDinh * EP * C2 * C3 * C4 Page 1 of 3 sf08cw set up C Eq 8/3/2009 Table 9 (cont'd.) Exposure Assumptions and Equations for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates Construction Worker -Soil: Table CW-3 Vlookup Version v0808 Equations to Calculate Noncancer Risk for Construction Worker Noncancer Risk from Ingestion Parameter Value Units RfD OHM-specific mg/kg-day ADDing ADD OHM-specific mg/kg-day RfDoral-subchronic EPC OHM-specific mg/kg IR 100 mg/day RAFnc-ing OHM-specific dimensionless RAFnc-derm OHM-specific dimensionless RAFnc-inh OHM-specific dimensionless Noncancer Risk from Dermal Absorption EF 0.714 event/day EFcyanide 1 event/day ADDderm EDing & derm 1 day/event RfDoral-subchronic EDinh 0.333 day/event EP 182 days EPcyanide 1.00 day C1 1.0E-06 kg/mg C2 1.0E-09 kg/μg Noncancer Risk from Particulate Inhalation -Gastrointestinal Absorption C3 1440 min/days C4 1.0E-03 m3/L ADDinh-GI BW 58.0 kg RfDoral-subchronic APnoncancer 182 days APcyanide 1 day VRwork 60 L/min AF 0.29 mg/cm2 SA 3473 cm2/day Noncancer Risk from Particulate Inhalation -Pulmonary Absorption RCAFinh-gi 1.5 dimensionless RCAFinh 0.5 dimensionless ADD PM10 60 μg/m3 RfDinhalation-subchronic HQing = ADDing = EPC * SA * AF * RAFnc-derm * EF * EDdermal* EP * C1 EPC * IR * RAFnc-ing * EF * EDing * EP * C1 BW * APnoncancer ADDdermal = BW * APnoncancer HQinh-GI = ADDinh-GI = HQderm = Cyanide can cause a significant health risk from a one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. EPCsoil * RCAFinh * PM10 * VRwork * RAFnc-inh * EF * EDinh * EP * C2 * C3 * C4 BW * APnoncancer BW * APnoncancer HQinh = ADDinh = EPC * RCAFinh-gi * PM10 * VRwork * RAFnc-ing * EF * EDinh * EP * C2 * C3 * C4 Page 2 of 3 sf08cw set up NC Eq 8/3/2009 Table 9 (cont'd.) Exposure Assumptions and Equations for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates Construction Worker -Soil: Table CW-4 Vlookup Version v0808 Definitions and Exposure Factors Parameter Value Units Notes ELCR -Excess Lifetime Cancer Risk chemical specific dimensionless Pathway specific (ing =ingestion, derm=dermal, inh=inhalation) HI -Hazard Index chemical specific dimensionless Pathway specific (ing =ingestion, derm=dermal, inh=inhalation) CSF -Cancer Slope Factor chemical specific (mg/kg-day)-1 see Table CW-5. RfD -Reference Dose chemical specific mg/kg-day see Table CW-5. LADD -Lifetime Average Daily Dose chemical specific mg/kg-day Pathway specific. See Table CW-2. ADD -Average Daily Dose chemical specific mg/kg-day Pathway specific. See Table CW-3. EPC -Exposure Point Concentration chemical specific μg/L see Table CW-1. IR -Soil Ingestion Rate 100 mg/day MADEP. 2002. Technical Update: Calculation of an Enhanced Soil Ingestion Rate. (http://www.mass.gov/dep/ors/orspubs.htm). RAFc -Relative Absorption Factor for Cancer Effects chemical specific dimensionless Pathway specific -see Table CW-5. RAFnc -Relative Absorption Factor for Noncancer Effects chemical specific dimensionless Pathway specific -see Table CW-5. EF -Exposure Frequency 0.714 event/day 5 events (days) /7 events (days) in a week; MADEP 1995 Guidance for Disposal Site Risk Characterization pg B-38. EFcyanide -Exposure Frequency for Cyanide Exposures 1.00 event/day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Page 5-5. EDing,derm -Exposure Duration for ingestion or dermal exposure 1 day/event EDinh -Exposure Duration for inhalation exposure 0.333 day/event Represents 8 hours /event. EP -Exposure Period 182 days 6 months; MADEP 1995 Guidance for Disposal Site Risk Characterization. EPcyanide -Exposure period for cyanide exposure 1 day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Page 5-5. BW -Body Weight 58.0 kg U.S. EPA. 1997. Exposure Factors Handbook. Table 7-7, Females, ages 18 -25. AP(lifetime) -Averaging Period for lifetime 25,550 days Represents 70 years AP(noncancer) -Averaging Period for noncancer 182 days 6 months; MADEP 1995 Guidance for Disposal Site Risk Characterization. APcyanide -Averaging period for assessing cyanide exposure 1 day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Page 5-5. AF -Adherence Factor 0.29 mg/cm2 MA DEP. 2002 Technical Update: Weighted Skin-Soil Adherence Factors. (http://www.mass.gov/dep/ors/orspubs.htm) VRwork -Ventilation Rate during work (heavy exertion) 60 L/min Table B-4 MADEP 1995 Guidance for Disposal Site Risk Characterization. SA -Surface Area 3473 cm2/day MADEP. 1995. Guidance for Disposal Site Risk Characterization. 50th percentile for females. Appendix Table B-2. RCAFinh-gi -Relative Concentration Adjustment Factor, gastrointestinal 1.5 dimensionless MADEP 2007. Characterization of Risks Due to Inhalation of Particulates by Construction Workers RCAFinh -Relative Concentration Adjustment Factor, inhalation 0.5 dimensionless MADEP 2002. Characterization of Risks Due to Inhalation of Particulates by Construction Workers PM10 -Concentration of PM10 60 μg/m3 MADEP 1995 Guidance for Disposal Site Risk Characterization pg B-11 Page 3 of 3 sf08cw set up Exp 8/3/2009 Table 10 -Groundwater Exposure Point Concentrations (EPCs) Former Cutlery Raceway, Northampton MA RTN #1-13320 Class A3 RAO: AOC-1 Class C1 RAO: AOC-2 & AOC-3 Sample ID: Date Collected MW-1 10/24/08 MW-3 10/24/08 MW-2S 10/24/08 MW-2D 10/24/08 MW-4 6/5/06 MW-4 10/24/08 MW-4 EPC CR-1 6/5/06 CR-2 6/5/06 CR-3 6/5/06 CR-6 6/5/06 CR-8 6/5/06 WP-1 6/5/06 WP-2 6/5/06 Method 1 GW-2 Standard Method 1 GW-3 Standard UCL OTO Soluble PP13 Metals (ug/L) Chromium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 43.1 BDL BDL 5.6 NA 600/300 3,000 Copper BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 11.7 BDL BDL 10.3 NSL NSL NSL Lead BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 15.8 BDL BDL BDL NA 10 150 Nickel 9.5 BDL BDL BDL 174 84.2 129 5.8 63.6 65.6 43.2 BDL BDL 13.7 NA 200 2,000 Zinc BDL BDL BDL BDL 123 BDL 123 BDL BDL BDL BDL BDL BDL 493 NA 900 50,000 C:\Data\Projects\5028-02-01 Cutlery\Method 3\GW EPCsSheet1 (2) Table 11 -Soil Exposure Point Concentrations (EPCs) for AOC-1 Parking Lots Former Cutlery Raceway, Northampton, MA RTN #1-13320 Sample ID: Depth (ft.) Date Collected SA-1-N 2-3' 11/10/04 SA-1-E 2-3' 11/10/04 SA-1-S 2-3' 11/10/04 SA-1-W 2-3' 11/10/04 SA-1-Base 3.5' 11/10/04 SA-2-N2 3-4.5' 12/8/04 SA-2-E2 3-4.5' 12/9/04 SA-2-S 3-4.5' 11/10/04 SA-2-W2 3-4.5' 12/9/04 SA-2-Base 5' 11/10/04 SA-3-N3 3-5' 11/23/04 SA-3-E 3-5' 11/10/04 SA-3-S 3-5' 11/10/04 SA-3-W3 3-5' 11/23/04 SA-3-Base 5.5' 11/10/04 Polychlorinated Biphenyls (mg/Kg) PCBs (total) na na na na na na na na na na na na na na na Total Metals (mg/kg) Silver BRL BRL 50.0 47.4 5.99 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL Arsenic 5.1 19.7 12.4 6.17 8.72 12.5 BRL 8.0 BRL BRL BRL 6.37 16.4 BRL 5.78 Beryllium BRL BRL BRL BRL BRL BRL 0.63 BRL 0.658 BRL BRL BRL 1.86 0.697 BRL Cadmium 1.22 2.09 9.16 25.0 2.13 2.42 0.99 1.59 1.46 1.06 BRL 0.93 2.92 0.675 1.69 Chromium 1,120 5,400 1,830 2,550 2,200 4,050 73.0 4,560 127 958 1,130 3,090 4,510 430 2,320 Copper 53.0 116 142 258 131 515 24.4 60.5 72.9 39.2 211 52.7 135 95.1 110 Mercury 0.329 BRL 0.338 3.38 0.265 0.356 BRL BRL BRL BRL 0.31 BRL 0.285 0.225 0.987 Nickel 45.1 113 116 88.9 79.6 280.0 31.3 62.3 123 33.2 41.1 54.5 125 28.4 78.9 Lead 190 127 910 359 321 390 98.9 585 938 132 119 355 359 1,100 277 Antimony BRL BRL BRL BRL BRL 89.2 6.09 BRL 10.0 BRL BRL BRL BRL BRL BRL Selenium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL Zinc 85.7 63.1 5,020 203 95.6 236 54.5 62.8 155 50.9 113 77.4 583 82.4 197.0 Notes: 1. Results in red (bold) exceed listed standard. 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard 3. Results in blue exceed method detection limit. 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) 4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) Page 1 of 3 Soil EPCs Parking Lot AOC-1 SA-1 to SA-5 Excav 8/28/2009 Sample ID: Depth (ft.) Date Collected Polychlorinated Biphenyls (mg/Kg) PCBs (total) Total Metals (mg/kg) Silver Arsenic Beryllium Cadmium Chromium Copper Mercury Nickel Lead Antimony Selenium Thallium Zinc Table 11 (cont'd) -Soil Exposure Point Concentrations (EPCs) for AOC-1 Parking Lots Former Cutlery Raceway, Northampton, MA RTN #1-13320 SA-4-N 2-3' 11/10/04 SA-4-E 2-3' 11/10/04 SA-4-S 2-3' 11/10/04 SA-4-W 2-3' 11/10/04 SA-4-Base 4.5' 11/10/04 SA-5-E3 2-3' 11/23/04 SA-5-S2 2-3' 11/16/04 SA-5-W2 2-3' 11/16/04 SA-5-Base2 4' 11/16/04 EPCs 2-5' Method 1 S-3 Soil & GW-2 (mg/kg) Method 1 S-3 Soil & GW-3 (mg/kg) UCLs (mg/kg) na na na na na na na na na na 3 3 100 BRL BRL BRL BRL BRL BRL BRL BRL BRL 34 200 200 2,000 7.44 25.4 16.5 BRL 19.9 6.9 BRL BRL BRL 12 20 20 200 BRL BRL 0.449 0.45 0.60 0.6 BRL BRL BRL 0.7 200 200 2,000 1.45 1.22 BRL 1.11 1.32 BRL 1.66 0.73 0.73 2.9 30 30 300 3,250 3,070 171 848 1,590 24.6 4,860 447 447 2,044 5,000 5,000 10,000 70.6 106 31.8 35.6 57.7 22.8 BRL BRL BRL 111 NSL NSL NSL 0.228 BRL BRL BRL BRL BRL BRL BRL BRL 0.7 30 30 300 58.6 52.7 11 43.8 45.4 13.2 82.5 18.5 18.5 69 700 700 7,000 88.7 192 45.6 45.6 216 149 254 32.7 32.7 305 300 300 3,000 BRL BRL BRL BRL BRL BRL BRL BRL BRL 35 30 30 300 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 800 800 8,000 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 80 80 800 57.9 52.7 BRL 64.3 71.3 144 BRL BRL BRL 373 5,000 5,000 10,000 Page 2 of 3 Soil EPCs Parking Lot AOC-1 SA-1 to SA-5 Excav 8/28/2009 Table 11 (cont'd.) Soil Exposure Point Concentrations for AOC-1 CB Area Former Cutlery Building Northampton, MA Regulatory Standards Sample I.D.: Sample Depth: CB-2 0-3" CB-3 0-3" CB-4 0-3" CB-7 0-3" CB-9 0-3" CB-10 0-3" CB-12 0-3" CB-13 0-3" CB-15 0-3" Method 1 Standard Sampling Date: 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) br dk g, bl dk g dk br, g o, br br dk g, mr dk br lt g, br, dk g Silver BRL BRL 3.01 BRL BRL BRL 6.04 BRL BRL 100 100 100 100 NSL 2,000 Arsenic 10.5 BRL BRL BRL BRL 32.7 10.9 BRL BRL 20 20 20 20 40 200 Beryllium 1.23 BRL BRL BRL 0.55 0.757 BRL BRL BRL 100 100 100 100 NSL 2000 Cadmium 1.34 BRL 0.884 BRL BRL 1.11 1.2 BRL BRL 2 2 2 2 60 300 Chromium (III) 1910 1830 4110 940 75.7 1110 4690 78.1 5760 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 298 112 241 58.7 43.1 213 333 59.4 106 1,000 NSL NSL NSL NSL NSL Mercury 1.6 0.483 0.439 0.408 BRL 1.68 0.889 BRL 21.9 20 20 20 20 300 300 Nickel 188 111 165 53.5 19.8 225 163 17.1 142 20 20 20 20 NSL 7,000 Lead 216 505 753 238 664 1260 4480 252 246 300 300 300 300 NSL 3,000 Antimony BRL BRL BRL BRL BRL 143 471 BRL BRL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL BRL BRL BRL BRL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 773 333 418 58 65 447 657 109 411 2500 2500 2500 2500 NSL 10,000 Confirmatory Soil Samples Regulatory Standards Sample I.D.: Sample Depth: CB-17 0-3" CB-18 0-3" CB-19 0-3" CB-CS-1 0-3" CB-CS-2 0-3" CB-CS-3 0-3" CB-CS-4 0-3" CB-CS-5 0-3" CB-CS-6 0-3" CB-CS-7 0-3" CB-CS-8 0-3" EPCs 0-3' Method 1 Standard Sampling Date: 6/9/06 6/9/06 6/9/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 9/21/06 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) Silver 2.69 2.59 BRL 16.1 4.07 5.32 1.76 1.43 BRL 2.76 1.46 4.3 100 100 100 100 NSL 2,000 Arsenic 18.3 16.6 9.16 BRL BRL BRL BRL BRL BRL BRL 76.6 25 20 20 20 20 40 200 Beryllium 0.569 0.343 0.449 BRL 0.244 0.254 0.215 0.405 BRL 0.514 0.779 0.5 100 100 100 100 NSL 2000 Cadmium 0.847 1.37 0.599 2.49 1.67 1.44 0.806 1.65 BRL 0.927 0.814 1.2 2 2 2 2 60 300 Chromium (III) 2720 2590 274 2230 3060 3760 2740 3490 4560 1760 877 2428 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 138 124 45 1310 163 133 66.9 200 79.5 197 513 222 1,000 NSL NSL NSL NSL NSL Mercury 0.198 0.627 0.193 0.719 0.434 0.221 0.284 0.583 0.191 0.242 0.203 1.7 20 20 20 20 300 300 Nickel 115 89 38 2650 222 192 85.9 184 136 282 736 291 20 20 20 20 NSL 7,000 Lead 610 567 286 1560 1020 1190 915 312 475 429 432 821 300 300 300 300 NSL 3,000 Antimony BRL BRL 2.14 265 17.2 20.6 10.9 21 20.3 18.2 9.41 91 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL 2.27 2.39 1.57 1.89 BRL 2.42 3.49 2.3 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 105 464 66.4 574 506 781 351 315 247 162 117 348 2500 2500 2500 2500 NSL 10,000 Notes: Color Codes: 1. Results in red (bold) exceed listed standard. br = brown p = pink t = tan 2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light 3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark 4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white 4. BRL = Below Reporting Limit o = orange grn = green 5. na = Not Analyzed for this parameter. 6. Shaded Orange = Exceeds Upper Concentration Limit (UCL) 7. Shaded Blue = Exceeds TCLP Land Application Standard 8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location. UCLs (mg/kg) UCLs (mg/kg) Imminent Hazard Imminent Hazard RC S-1 RC S-1 Page 3 of 3 Soil EPCs AOC-1 CB Area PP13-CB 8/28/2009 Table 12 Calculation of Risk Estimates for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates AOC-1 Parking Lot Soils (2-5') Construction Worker -Soil: Table CW-1 ShortForm Version 08-08 Exposure Point Concentration (EPC) and Risk Vlookup Version v0808 Based on Construction Worker 18-25 years of age ELCR (all chemicals) = 2E-07 **Do not insert or delete any rows** HI (all chemicals) = 1E+00 Click on empty cell below and select OHM using arrow. Oil or Hazardous EPC ELCR ELCR ELCR ELCR Subchronic Material (OHM) (mg/kg) ingestion dermal inhalation GI inhalation pulmonary ELCRtotal HQing HQderm HQinh-GI HQinh HQtotal Silver 3.4E+01 8.4E-03 2.1E-02 2.2E-04 9.0E-03 3.9E-02 Arsenic 1.2E+01 1.6E-07 4.8E-08 4.1E-09 1.4E-08 2.2E-07 4.9E-02 1.5E-02 1.3E-03 1.8E-01 2.4E-01 Beryllium 7.0E-01 4.5E-10 4.5E-10 1.7E-04 5.2E-05 4.5E-06 1.3E-03 1.5E-03 Cadmium 2.9E+00 1.4E-09 1.4E-09 7.1E-03 1.0E-02 1.9E-04 5.4E-03 2.3E-02 Chromium(III) 2.0E+03 1.7E-03 6.8E-04 4.3E-05 2.5E-01 2.6E-01 Mercury 7.0E-01 2.9E-03 1.4E-03 7.4E-05 8.7E-05 4.5E-03 Nickel 6.9E+01 8.8E-09 8.8E-09 4.2E-03 1.5E-02 1.1E-04 2.6E-03 2.2E-02 Lead 3.1E+02 2.5E-01 3.0E-02 6.5E-03 1.1E-02 3.0E-01 Antimony 3.5E+01 1.1E-01 1.1E-01 2.8E-03 1.3E-04 2.2E-01 Selenium ND Thallium ND Zinc 3.7E+02 1.5E-03 3.1E-04 4.0E-05 9.9E-03 1.2E-02 Polychlorinated biphenyls (PCBs) ND Sheet: EPCs TABLE 12 (cont'd.) CALCULATION OF RISK ESTIMATES FOR CONSTRUCTION WORKER -Incidental Ingestion of Soil Oral Ingestion Average Oral Hazard Contaminant x Relative x Exposure = Daily /Subchronic = Index EPCsoil Absorption Factor Dose RfD (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day) Metals Copper 111 1 1.23E-06 1.4E-04 4.0E-02 3.4E-03 Subtotal = 3.4E-03 CARCINOGENIC EFFECTS Oral Average Oral Contaminant x Relative x CWCIS = Daily x Cancer = ELCR EPCsoil Absorption Factor Dose Slope Factor (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day)-1 None AOC-1 Parking Lot Soils NONCARCINOGENIC EFFECTS cuwsorsk Cu Parking Lot Ingestion Soil 8/28/2009 TABLE 12 (cont'd.) CALCULATION OF RISK ESTIMATES FOR CONSTRUCTION WORKER Dermal Contact with Soil Dermal Dermal Average Oral Hazard Contaminant x Relative x Exposure = Daily /Subchronic = Index EPCsoil Absorption Factor Dose RfD (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day) Metals Copper 111 0.10 1.22E-05 1.4E-04 4.0E-02 3.4E-03 Subtotal = 3.4E-03 CARCINOGENIC EFFECTS Dermal Average Oral Contaminant x Relative x CWCDS = Daily x Cancer = ELCR EPCsoil Absorption Factor Dose Slope Factor (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day)-1 None AOC-1 Parking Lot Soils NONCARCINOGENIC EFFECTS cuwsorsk Cu Parking Lot Dermal Soil 8/28/2009 Table 12 (cont'd.) Calculation of Risk Estimates for Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates AOC-1 CB Area Soils (0-3') Construction Worker -Soil: Table CW-1 ShortForm Version 08-08 Exposure Point Concentration (EPC) and Risk Vlookup Version v0808 Based on Construction Worker 18-25 years of age ELCR (all chemicals) = 5E-07 **Do not insert or delete any rows** HI (all chemicals) = 2E+00 Click on empty cell below and select OHM using arrow. Oil or Hazardous EPC ELCR ELCR ELCR ELCR Subchronic Material (OHM) (mg/kg) ingestion dermal inhalation GI inhalation pulmonary ELCRtotal HQing HQderm HQinh-GI HQinh HQtotal Silver 4.3E+00 1.1E-03 2.7E-03 2.7E-05 1.1E-03 4.9E-03 Arsenic 2.5E+01 3.3E-07 9.9E-08 8.5E-09 2.9E-08 4.7E-07 1.0E-01 3.1E-02 2.7E-03 3.7E-01 5.1E-01 Beryllium 5.0E-01 3.2E-10 3.2E-10 1.2E-04 3.7E-05 3.2E-06 9.3E-04 1.1E-03 Cadmium 1.2E+00 5.7E-10 5.7E-10 3.0E-03 4.2E-03 7.7E-05 2.2E-03 9.4E-03 Chromium(III) 2.4E+03 2.0E-03 8.0E-8.0E-04 5.2E-05 3.0E-01 3.0E-01 Mercury 1.7E+00 7.0E-03 3.5E-03 1.8E-04 2.1E-04 1.1E-02 Nickel 2.9E+02 3.7E-08 3.7E-08 1.8E-02 6.3E-02 4.6E-04 1.1E-02 9.2E-02 Lead 8.2E+02 6.7E-01 8.1E-02 1.7E-02 3.1E-02 8.0E-01 Antimony 9.1E+01 2.8E-01 2.8E-01 7.3E-03 3.4E-04 5.7E-01 Selenium 2.3E+00 5.7E-04 1.1E-05 1.5E-05 2.9E-05 6.2E-04 Thallium ND Zinc 3.5E+02 1.4E-03 2.9E-04 3.7E-05 9.3E-03 1.1E-02 Polychlorinated biphenyls (PCBs) ND sf08cw AOC-1 CB Area EPCs 8/28/2009 TABLE 12 (cont'd.) CALCULATION OF RISK ESTIMATES FOR CONSTRUCTION WORKER -Incidental Ingestion of Soil Oral Ingestion Average Oral Hazard Contaminant x Relative x Exposure = Daily /Subchronic = Index EPCsoil Absorption Factor Dose RfD (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day) Metals Copper 222 1 1.23E-06 2.7E-04 4.0E-02 6.8E-03 Subtotal = 6.8E-03 CARCINOGENIC EFFECTS Oral Average Oral Contaminant x Relative x CWCIS = Daily x Cancer = ELCR EPCsoil Absorption Factor Dose Slope Factor (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day)-1 None AOC-1 CB Area NONCARCINOGENIC EFFECTS cuwsorsk Cu CB Area Ingestion Soil 8/28/2009 TABLE 12 (cont'd.) CALCULATION OF RISK ESTIMATES FOR CONSTRUCTION WORKER Dermal Contact with Soil Dermal Dermal Average Oral Hazard Contaminant x Relative x Exposure = Daily /Subchronic = Index EPCsoil Absorption Factor Dose RfD (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day) Metals Copper 222 0.10 1.22E-05 2.7E-04 4.0E-02 6.8E-03 Subtotal = 6.8E-03 CARCINOGENIC EFFECTS Dermal Average Oral Contaminant x Relative x CWCDS = Daily x Cancer = ELCR EPCsoil Absorption Factor Dose Slope Factor (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day)-1 None AOC-1 CB Area NONCARCINOGENIC EFFECTS cuwsorsk Cu CB Area Dermal Soil 8/28/2009 Page 1 of 1 TABLE 13 SUMMARY OF HAZARD INDICES AND RISK ESTIMATES Receptor Hazard Index (HI) Excess Lifetime Site Area Exposure Pathway Subchronic Cancer Risk Media (depth) (ELCR) CURRENT/FUTURE CONDITIONS Construction Worker AOC-1 Parking Lot Soil (2-5' bgs) Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Particulates Total Screening HI: 1E+00 2E-07 Total Screening HI Segregated by Critical Effect: Skin (Silver and Arsenic) 3E-01 Central Nervous System (Lead and Mercury) 3E-01 Blood (Antimony, Thallium, and Zinc) 2E-01 Other (Beryllium, Cadmium, Chromium, Copper, Nickel, and Selenium) 3E-01 Construction Worker AOC-1 CB Area Soil (0-3' bgs) Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Particulates Total Screening HI: 2E+00 5E-07 Total Screening HI Segregated by Critical Effect: Skin (Silver and Arsenic) 5E-01 Central Nervous System (Lead and Mercury) 8E-01 Blood (Antimony, Thallium, and Zinc) 6E-01 Other (Beryllium, Cadmium, Chromium, Copper, Nickel, and Selenium) 4E-01 MassDEP Risk Limits: 1E+00 1E-05 Notes: NC indicates no carcinogens detected. Bolded value exceeds MassDEP risk limits. RTN #1-13320 Former Cutlery Raceway, Northampton, MA risksum 8/28/2009 O’Reilly, Talbot & Okun [ A S S O C I A T E S ] E N G I N E E R I N G APPENDIX A TOXICITY PROFILES Northampton Cutlery 8/31/09 5028-02-01 CutleryM3text U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, Public Health Service Agency for Toxic Substances and Disease Registry Division of Toxicology ToxFAQsTM September 2002 This fact sheet answers the most frequently asked health questions (FAQs) about beryllium. For more information, call the ATSDR Information Center at 1-888-422-8737. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It is important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present. HIGHLIGHTS: People working or living near beryllium industries have the greatest potential for exposure to beryllium. Lung damage has been observed in people exposed to high levels of beryllium in the air. About 1-15% of all people occupationally-exposed to beryllium in air become sensitive to beryllium and may develop chronic beryllium disease (CBD), an irreversible and sometimes fatal scarring of the lungs. CBD may be completely asymptomatic or begin with coughing, chest pain, shortness of breath, weakness, and/or fatigue. Beryllium has been found in at least 535 of the 1,613 National Priorities List sites identified by the Environmental Protection Agency (EPA). What is beryllium? Beryllium is a hard, grayish metal naturally found in mineral rocks, coal, soil, and volcanic dust. Beryllium ore is mined, and the beryllium is purified for use in nuclear weapons and reactors, aircraft and space vehicle structures, instruments, xray machines, and mirrors. Beryllium oxide is used to make speciality ceramics for electrical and high-technology applications. Beryllium alloys are used in automobiles, computers, sports equipment (golf clubs), and dental bridges. What happens to beryllium when it enters the environment? ‘ Beryllium dust enters the air from burning coal and oil. This beryllium dust will eventually settle over the land and water. ‘ It enters water from erosion of rocks and soil, and from industrial waste. Some beryllium compounds will dissolve in water, but most stick to particles and settle to the bottom. ‘ Most beryllium in soil does not dissolve in water and remains bound to soil. ‘ Beryllium does not accumulate in the food chain. How might I be exposed to beryllium? ‘ The general population is normally exposed to low levels of beryllium in air, food, and water. ‘ People working in industries where beryllium is mined, processed, machined, or converted into metal, alloys, and other chemicals may be exposed to high levels of beryllium. People living near these industries may also be exposed to higher than normal levels of beryllium in air. ‘ People living near uncontrolled hazardous waste sites may be exposed to higher than normal levels of beryllium. How can beryllium affect my health? Beryllium can be harmful if you breathe it. The effects depend on how much you are exposed to, for how long, and individual susceptibility. If beryllium air levels are high enough (greater than 1000 ug/m3), an acute condition can result. This condition resembles pneumonia and is called acute beryllium disease Occupational and community air standards are effective in preventing acute lung damage. Some exposed workers (1-15%) become sensitive to beryllium. These individuals may develop an inflammatory reaction in the respiratory system. This condition is called chronic beryllium disease (CBD), and can occur years after exposure to higher than normal levels of beryllium (greater than 0.2 ug/m3). This disease can make you feel weak and tired, and can cause difficulty in breathing. It can also result in anorexia, weight loss, and may also lead to right side heart BERYLLIUM CAS #7440-41-7 Page 2 Federal Recycling Program Printed on Recycled Paper ToxFAQsTM Internet address is http://www.atsdr.cdc.gov/toxfaq.html Where can I get more information? For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology, 1600 Clifton Road NE, Mailstop F-32, Atlanta, GA 30333. Phone: 1-888-422-8737, FAX: 770-488-4178. ToxFAQs Internet address viaWWWis http://www.atsdr.cdc.gov/toxfaq.html. ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questions or concerns. enlargement and heart disease in advanced cases. Some people who are sensitized to beryllium may not have any symptoms. The general population is unlikely to develop chronic beryllium disease because ambient air levels of beryllium are normally very low (0.00003-0.0002 ug/m3). Swallowing beryllium has not been reported to cause effects in humans because very little beryllium is absorbed from the stomach and intestines. Ulcers have been seen in dogs ingesting beryllium in the diet. Beryllium contact with skin that has been scraped or cut may cause rashes or ulcers. How likely is beryllium to cause cancer? Long term exposure to beryllium can increase the risk of developing lung cancer in people. The Department of Health and Human Services (DHHS) and the International Agency for Research on Cancer (IARC) have determined that beryllium is a human carcinogen. The EPA has determined that beryllium is a probable human carcinogen. EPA has estimated that lifetime exposure to 0.04 ug/m3 beryllium can result in a one in a thousand chance of developing cancer. How can beryllium affect children? It is likely that the health effects seen in children exposed to beryllium will be similar to the effects seen in adults. We do not know whether children differ from adults in their susceptibility to beryllium. We do not know if exposure to beryllium will result in birth defects or other developmental effects in people. The studies on developmental effects in animals are not conclusive. How can families reduce the risk of exposure to beryllium? ‘ Individuals working at facilities that use beryllium should make sure that contaminated clothing and objects are not brought home. ‘ Children should avoid playing in soils near uncontrolled hazardous waste sites where beryllium may have been discarded. Is there a medical test to show whether I’ve been exposed to beryllium? Beryllium can be measured in samples from your blood, urine, skin, or lungs. These tests are rarely done because they are not reliable measures of your exposure over time. Also, these tests do not show if you have become sensitized to beryllium. Another test, the beryllium lymphocyte proliferation test (BeLPT), can help your doctor decide if you are sensitized to beryllium. This test is only done in a few specialized laboratories, but doctors familiar with the test can collect blood samples and send them for testing by overnight carrier. The BeLPT is most often done for people who work with beryllium. It is also useful for separating chronic beryllium disease from diagnoses that resemble it (for example, sarcoidosis). Depending on your exposure history, clinical findings, and test results, your doctor may also recommend additional specialized testing. Has the federal government made recommendations to protect human health? The EPA restricts the amount of beryllium that industries may release into the air to 0.01 ug/m3, averaged over a 30-day period. The Occupational Safety and Health Administration (OSHA) sets a limit of 2 ug/m3 for an 8-hour work shift measured as a personal sample. References Agency for Toxic Substances and Disease Registry (ATSDR). 2002. Toxicological Profile for Beryllium Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. CAS #7440-41-7 BERYLLIUM U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, Public Health Service Agency for Toxic Substances and Disease Registry Division of Toxicology ToxFAQsTM September 2003 This fact sheet answers the most frequently asked health questions (FAQs) about selenium. For more information, call the ATSDR Information Center at 1-888-422-8737. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It is important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present. HIGHLIGHTS: People may be exposed to low levels of selenium daily through food and water. Selenium is a trace mineral needed in small amounts for good health, but exposure to much higher levels can result in neurological effects and brittle hair and deformed nails. Occupational inhalation exposure to selenium vapors may cause dizziness, fatigue, irritation of mucous membranes, and respiratory effects. This substance has been found in at least 508 of the 1,636 National Priorities List sites identified by the Environmental Protection Agency (EPA). What is selenium? Selenium is a naturally occurring mineral element that is distributed widely in nature in most rocks and soils. In its pure form, it exists as metallic gray to black hexagonal crystals, but in nature it is usually combined with sulfide or with silver, copper, lead, and nickel minerals. Most processed selenium is used in the electronics industry, but it is also used: as a nutritional supplement; in the glass industry; as a component of pigments in plastics, paints, enamels, inks, and rubber; in the preparation of pharmaceuticals; as a nutritional feed additive for poultry and livestock; in pesticide formulations; in rubber production; as an ingredient in antidandruff shampoos; and as a constituent of fungicides. Radioactive selenium is used in diagnostic medicine. What happens to selenium when it enters the environment? ‘ Selenium occurs naturally in the environment and can be released by both natural and manufacturing processes. ‘ Selenium dust can enter the air from burning coal and oil. This selenium dust will eventually settle over the land and water. ‘ It also enters water from rocks and soil, and from agricultural and industrial waste. Some selenium compounds will dissolve in water, and some will settle to the bottom as particles. ‘ Insoluble forms of selenium will remain in soil, but soluble forms are very mobile and may enter surface water from soils. ‘ Selenium may accumulate up the food chain. How might I be exposed to selenium? ‘ The general population is exposed to very low levels of selenium in air, food, and water. The majority of the daily intake comes from food. ‘ People working in or living near industries where selenium is produced, processed, or converted into commercial products may be exposed to higher levels of selenium in the air. ‘ People living in the vicinity of hazardous waste sites or coal burning plants may also be exposed to higher levels of selenium. How can selenium affect my health? Selenium has both beneficial and harmful effects. Low doses of selenium are needed to maintain good health. However, exposure to high levels can cause adverse health effects. Short-term oral exposure to high concentrations of selenium may cause nausea, vomiting, and diarrhea. Chronic oral exposure to high concentrations of selenium compounds can produce a disease called selenosis. The major signs of selenosis are hair loss, nail brittleness, and neurological abnormalities (such as numbness and other odd sensations CAS # 7782-49-2 SELENIUM Page 2 Federal Recycling Program Printed on Recycled Paper ToxFAQsTM Internet address is http://www.atsdr.cdc.gov/toxfaq.html Where can I get more information? For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology, 1600 Clifton Road NE, Mailstop F-32, Atlanta, GA 30333. Phone: 1-888-422-8737, FAX: 770-488-4178. ToxFAQs Internet address via WWW is http://www.atsdr.cdc.gov/toxfaq.html. ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questions or concerns. in the extremities). Brief exposures to high levels of elemental selenium or selenium dioxide in air can result in respiratory tract irritation, bronchitis, difficulty breathing, and stomach pains. Longerterm exposure to either of these air-borne forms can cause respiratory irritation, bronchial spasms, and coughing. Levels of these forms of selenium that would be necessary to produce such effects are normally not seen outside of the workplace. Animal studies have shown that very high amounts of selenium can affect sperm production and the female reproductive cycle. We do not know if similar effects would occur in humans. How likely is selenium to cause cancer? Studies of laboratory animals and people show that most selenium compounds probably do not cause cancer. In fact, studies in humans suggest that lower-than-normal selenium levels in the diet might increase the risk of cancer. The International Agency for Research on Cancer (IARC) has determined that selenium and selenium compounds are not classifiable as to their carcinogenicity to humans. The EPA has determined that one specific form of selenium, selenium sulfide, is a probable human carcinogen. Selenium sulfide is not present in foods and is a very different chemical from the organic and inorganic selenium compounds found in foods and in the environment. How can selenium affect children? It is likely that the health effects seen in children exposed to selenium will be similar to the effects seen in adults. However, one study found that children may be less susceptible to the health effects of selenium than adults. Selenium compounds have not been shown to cause birth defects in humans or in other mammals. How can families reduce the risk of exposure to selenium? ‘ Certain dietary supplements and shampoos contain selenium; these should be used according to the manufacturer’s directions. ‘ Children living near waste sites that contain selenium or coal burning plants should be encouraged to wash their hands before eating and to avoid putting their unwashed hands in their mouths. Is there a medical test to show whether I’ve been exposed to selenium? Low levels of selenium are normally found in body tissues and urine. Blood and urine tests for selenium are most useful for people who have recently been exposed to high levels. Toenail clippings can be used to determine longerterm exposure. These tests are not usually available at your doctor’s office, but your doctor can send the samples to a laboratory that can perform the tests. None of these tests, however, can predict whether you will experience any health effects. Has the federal government made recommendations to protect human health? The EPA restricts the amount of selenium allowed in public water supplies to 50 parts total selenium per billion parts of water (50 ppb). The Occupational Safety and Health Administration (OSHA) sets a limit of 0.2 mg selenium/m3 of workroom air for an 8-hour work shift. ATSDR and the EPA have determined that 5 micrograms of selenium per kilogram of body weight taken daily would not be expected to cause any adverse health effects over a lifetime of such intake. References Agency for Toxic Substances and Disease Registry (ATSDR). 2003. Toxicological Profile for Selenium (Update) Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. SELENIUM CAS # 7782-49-2 APPENDIX G Activity & Use Limitations Hampshire County Current datetime: 2/15/2011 2:01:30 PM DETAILS REPORT **Note: Report is Sorted in Ascending Order by Office, Recorded Date, Document Number Doc# Document Type Town Book/Page File Date Consideration 3254 NOTICE FLORENCE 10475/118 02/11/2011 Street Street Name Description 320-360 RIVERSIDE DR Grantors Grantees Street Property Description FIREHOUSE REALTY CORP NOTICE OF ACTIVITY & USE LIMITATION RIVERSIDE DR References Book/Pg Description Recorded year 10475/118 NOTICE 2001 References Certificate Hampshire County Current datetime: 2/15/2011 2:01:31 PM DETAILS REPORT **Note: Report is Sorted in Ascending Order by Office, Recorded Date, Document Number Doc# Document Type Town Book/Page File Date Consideration 3255 NOTICE FLORENCE 10475/133 02/11/2011 Street Street Name Description 320 RIVERSIDE DR Grantors Grantees Street Property Description CFP PROPERTIES LLC , CUTLERY BUILDING ASSOCIATES , BURTON SAM, REES SUSAN E, CUTLERY BUILDING CONDOMINIUM TRUST , VERSON ALAN TR, VERSON ALAN GENERAL PARTNER NOTICE OF ACTIVITY & USE LIMITATION RIVERSIDE DR References Book/Pg Description Recorded year 10475/133 NOTICE 1987 References Certificate Hampshire County Current datetime: 2/15/2011 2:01:32 PM DETAILS REPORT **Note: Report is Sorted in Ascending Order by Office, Recorded Date, Document Number Doc# Document Type Town Book/Page File Date Consideration 3256 NOTICE FLORENCE 10475/141 02/11/2011 Street Street Name Description 320-360 RIVERSIDE DR Grantors Grantees Street Property Description CUTLERY BUILDING ASSOCIATES , VERSON ALAN GENERAL PARTNER NOTICE OF ACTIVITY & USE LIMITATION RIVERSIDE DR References Book/Pg Description Recorded year 10475/141 NOTICE 1984 References Certificate Three (3) legal ads; one each for the three (3) AULs at the Former Cutlery RTN #1-13320. See bottom of page. AUL-1 AUL-2 AUL-3 APPENDIX H Public Involvement Letters END OF REPORT