1-13320_RAO A3-P C1-P Statement_2012-03-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 Revised: March 14, 2012 Prepared for:
Cutlery Building Assoc. c/o Alan Verson 56 Main Street Northampton, MA 01060 NEE Project No.02-2053-H
March 14, 2012 Mr. Michael Reed Massachusetts DEP 436 Dwight Street Springfield, Massachusetts 01103 RE: Revised Class A3 & Class C1 Response Action Outcome (RAO-P) Statements Former
Cutlery Raceway 320-360 Riverside Drive Northampton, Massachusetts RTN #1-13320 Dear Mr. Reed: New England Environmental Inc., (NEE) is pleased to submit this revised 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 original submittal dated February 8, 2011 was the subject of a DEP Audit (NOAF-NON
dated November 9, 2011) and which resulted in this revised submittal. 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 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 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 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 2.4 Annual LSP Site Inspection ...................................................................................................................................................................
8 2.5 Recent Sediment Sampling & Results ...................................................................................................................................................
9 3.0 REPRESENTATIVENESS EVALUATION & DATA USABILITY ASSESSMENT ............................................................... 10 3.1 Data Usability Assessment ......................................
............................................................................................................................ 10 3.1.1 Analytical Data Usability Assessment ............................
......................................................................................................... 10 3.1.2 Field Quality Control Data Usability Assessment ....................................
............................................................................... 11 3.1.3 Data Quality Objectives.......................................................................................
.................................................................... 11 3.2 Representativeness Evaluation .............................................................................................
............................................................... 11 3.2.2 Data Collection Approach .....................................................................................................
.................................................. 11 3.2.3 Field Screening Data ......................................................................................................................
......................................... 12 3.2.4 Selection of Sampling Locations and Depths .........................................................................................................
.................. 12 3.2.5 Number and Spatial Distribution of Sampling Locations ........................................................................................................
12 3.2.6 Temporal Distribution of Samples ...........................................................................................................................................
13 3.2.7 Critical Samples .......................................................................................................................................................................
13 3.2.8 Data Collection Evaluation .....................................................................................................................................................
13 3.2.9 Data Validation ........................................................................................................................................................................
13 3.2.10 Completeness ...........................................................................................................................................................................
14 3.3 Summary of REDUA ...........................................................................................................................................................................
14 4.0 EXTENT OF CONTAMINATION ................................................................................................................................................. 15 4.1
AOC-1 Parking Lots and River Bank .................................................................................................................................................. 15
4.2 Exposed Levee .....................................................................................................................................................................................
16 4.3 Conceptual Site Model .........................................................................................................................................................................
17 5.0 RISK CHARACTERIZATION ....................................................................................................................................................... 19
5.1.1 Metals .......................................................................................................................................................................................
19 5.1.2 PCBs .........................................................................................................................................................................................
19 5.1.3 Coal/Coal Ash ..........................................................................................................................................................................
19 5.1.4 Petroleum and VOCs ...............................................................................................................................................................
20 5.3 Identification of Soil and Groundwater Categories ..............................................................................................................................
21 5.3.1 Reportable Concentrations for Soil and Groundwater ............................................................................................................ 21 5.3.2 Method
1 Soil and Groundwater Cleanup Categories ............................................................................................................. 21 5.3.3 Applicability of Method
1 Risk Assessment .............................................................................................................................. 22 5.4 Method 3 Risk Characterization
.......................................................................................................................................................... 22 6.0 CLASS A3 RESPONSE ACTION
OUTCOME: AOC-1 ............................................................................................................... 23 6.1 Risk Assessment Conclusions for AOC-1 ...........................
................................................................................................................ 23 6.2 Activity & Use Limitation: AOC-1 ..............................................
....................................................................................................... 24 6.2.1 Permitted Activities and Uses Set Forth in the AUL Opinion ...........................
....................................................................... 24 6.2.2 Activities and Uses Inconsistent with the AUL Opinion ................................................................
.......................................... 25 6.2.3 Obligations and Conditions Set Forth in the AUL Opinion ...........................................................................................
.......... 25 6.3 RAO Statement Transmittal Form ......................................................................................................................................................
. 26 6.4 Public Involvement ...........................................................................................................................................................................
... 26 7.0 CLASS C1 RESPONSE ACTION OUTCOME: AOC-2 & AOC-3 ............................................................................................. 27 7.1 Risk Assessment Conclusions
for AOC-2 & AOC-3 ........................................................................................................................... 27 7.2.1 Permitted Activities and Uses Set
Forth in the AUL Opinion .................................................................................................. 27 7.2.2 Activities and Uses Inconsistent with the AUL Opinion
.......................................................................................................... 28 7.2.3 Obligations and Conditions Set Forth in the AUL Opinion ...........................
.......................................................................... 28 7.3 RAO Statement Transmittal Form ......................................................................................
................................................................. 29 7.4 Public Involvement ...........................................................................................................
................................................................... 29 8.0 CONCLUSIONS.................................................................................................................
............................................................... 30
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 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 3R 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 4-6R Confirmatory Soil Results CB-1 Excavation R = revised table Table 5-1R PP13 Metals in Levee Soil Table 5-2R PP13 Metals in Sediment Table 6-1R Maximum
and Minimum COC Concentrations – AOC-1 Table 6-2R Maximum and Minimum COC Concentrations – AOC-2 and AOC-3 PHOTOGRAPHS APPENDICES (only revised or new information is included herein,
see original submittal for remaining items) 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 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 (except at CB-12, see Section 4.1) 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.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 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. Sometime 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.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 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 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: 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;
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 4 Northampton, Massachusetts 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 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 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)
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 5 Northampton, Massachusetts 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 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 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 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.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 6 Northampton, Massachusetts 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. 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.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 7 Northampton, Massachusetts 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 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. 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
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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. 2.4 Annual LSP Site
Inspection On August 11, 2011, Lyons Witten, LSP and Karro Frost, PWS, both with NEE, visited the Site to assess vegetative growth, review the conditions and obligations of the AULs,
and inspect the Site for erosion. The grass seed and installed plants across the newly restored areas were in good good condition, and the geolifts were tight and secure. The previously
restored levee areas were in good condition with healthy plant and grass growth. The fences, signs, gate locks, and pavement were all in good condition. Two areas with mulch cover over
the orange plastic marker layer within AOC-1 had eroded to the extent that the orange marker layer was exposed. These areas were brought to the attention of the owner, and additional
mulch material was scheduled for installation. Lyons Witten re-inspected the Site on September 7, 2011 and found that additional mulch material had been added to the previously thin
areas. The obligations of the AULs have been met by these action.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 9 Northampton, Massachusetts 2.5 Recent
Sediment Sampling & Results On December 2, 2011, NEE collected three sediment samples from the shallow waters near the eastern shore of the Mill River. These were collected in the approximate
locations of DEP sediment samples SED-1, SED-2 and SED-3, and this round of samples was labeled DEP-SED-1, DEP-SED-2 and DEPSED-3 (Figure 3). The metals arsenic, cadmium, chromium, nickel,
lead, thallium, and zinc were detected in each of these new samples. The concentrations of nickel were in excess of the TEC Benchmarks, and the concentrations of thallium detected were
in excess of the S-1 soil standards (Table 5-2R). The detections of both metals were higher in the upstream DEP-SED-1/AOC-3 and DEP-SED-2/AOC-2 samples than in the downstream DEP-SED-3/AOC-1
sample. Laboratory reports are included in Appendix E and summarized with the other sediment samples in Table 5-2R.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 10 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 3R. 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 3R). 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 concentrations or in smaller areas of the Site can and will likely be treated
in the same manner as these
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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
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 3R). 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, and groundwater standards and/or screening criteria; 2. Define the horizontal and vertical extent of
OHM 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.
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
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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 3R). 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, 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. 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
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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. 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
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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-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. 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.
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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
4-6R 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 the UCL 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. Changes to several soil 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 4-6R). These concentrations were included in the calculated Exposure Point
Concentrations (EPCs) in the Method 3 Risk Characterization (Section 5.0). Since these results indicate metals concentrations in excess of Method 1 standards, an AUL and Method 3 Risk
Characterization (Section 5.0) are 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 16 Northampton, Massachusetts (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 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 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 5-1R 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 17 Northampton, Massachusetts 2005)
Table 3R), 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 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. Results of sediment sampling within the Mill River, summarized in Table 5-2R, indicate that the metals arsenic, chromium,
and lead exist within sediment upstream of the Site. The concentrations of arsenic and lead do not change significantly in the downstream samples adjacent to the site. Chromium levels
increase slightly adjacent to the site. The metals cadmium and nickel are present adjacent to the Site at concentrations above the TEC Benchmarks and S-1 soil standards, and these concentrations
decrease from AOC-3 and AOC-2 to AOC-1, pointing to the levee as a likely source of these metals. No metals concentrations were above the Imminent Hazard or UCL limits in Site sediment.
Concentrations of metals in sediment are evaluated in the Method 3 Risk Characterization (Section 5.0). 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 at the Site 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 18 Northampton, Massachusetts 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 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.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 19 Northampton, Massachusetts 5.0 RISK
CHARACTERIZATION 5.1 Contaminants of Concern (COCs) The soil COCs are EPH fractions, PCBs, and thirteen metals. The selected groundwater COCs were the metals chromium, copper, lead,
nickel, and zinc. No surface water or indoor air COCs were identified for the Site. The reasoning for these selections is as follows. 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 4-6R. Within the levee in AOC-3 the current distribution of metals is illustrated in Figure 5 /Table 5-1R 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 distribution
of metals in sediment is summarized in Table 5-2R. The maximum and minimum concentrations of each COC is listed in Table 6-1R for AOC-1, and Table 6-2R for AOC-2 and AOC-3. Repeated
speciation analyses of chromium indicates that high detections of 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 (Table 5-2R). 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 20 Northampton, Massachusetts 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 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, and are therefore not selected as COCs. 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 primarily derived from the coal
and/or coal ash and are therefore exempt. Sediment, surface water and groundwater samples have been analyzed for EPH. However, a few isolated samples had elevated EPH fractions characterized
by C19-C36 aliphatics, which is more consistent with a waste oil release. Therefore, EPH fractions were selected as soil COCs. The thirteen detected EPH PAHs were not selected as COCs
based on a comparison with background in “natural” soil. 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 21 Northampton, Massachusetts 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. 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 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive
NEE Project No. 02-2053 Page 22 Northampton, Massachusetts 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 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 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 (revised . The full risk characterization is 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.
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 23 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 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 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.
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 (revised 3//12), 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: For AOC-1, the Method 3 Risk Characterization concludes that a Condition of
No Significant Risk exists for construction workers in the Parking Lot and CB area, and recreational users in the floodplain riverbank area based on current and foreseeable future Site
uses. Construction worker exposure is considered to be protective of lesser-exposed utility workers and landscapers. Recreational exposure is considered to be protective of lesser-exposed
trespassers. Soil exposures to other human 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. Potentially significant exposures were not found to exist under current and foreseeable future Site conditions for aquatic receptors based on surface water
and groundwater data being below applicable criteria. For sediment, no exceedances of TECs were reported for metals in samples
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 24 Northampton, Massachusetts collected
along the shoreline and across transects of the Mill River, with one exception. Sediment concentrations for only nickel reported in the December 2011 samples DEP Sed-1, DEP Sed-2, and
DEP Sed-3, collected along the shoreline, exceeded the TEC. The nickel sediment concentrations were highest adjacent to the levee at AOC-3 (DEP Sed-1) and decreased in concentrations
to downstream sample adjacent to AOC-1 (DEP Sed-3). The sediment data, evaluated in total, indicates that potentially significant exposure to aquatic receptors in sediments, if any,
are likely to be limited to along the shoreline. Remedial actions, specifically levee and slope stabilization completed to reduce erosion, completed at the Site and to be maintained
as conditions of the RAO-Ps are aimed to minimize any further potential impacts of metals to Mill River shoreline sediments, particularly as conducted under the Class C-1 RAO 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. 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) was placed on
the portion of the Site identified as AOC-1 as shown on Figure 7 as part of the original submittal (recorded 2/11/11). Since AOC-1 incorporates portions of two different tax parcels
under different ownership, two AULs were 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 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.
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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, 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 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;
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 26 Northampton, Massachusetts 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 are not expected to stay or grow on top of the rock. In these 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 have been 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. 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 (original submittal).
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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 (revised 3//12), 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: 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. A Condition of No Substantial Hazard exists for the environment at AOC-2 and AOC-3. 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. Response actions to achieve a Condition of No Significant Risk and a permanent solution are not currently feasible for AOC-2 and AOC-3. 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 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)
were placed on the portions of the Site identified as AOC-2 and AOC-3 as shown on Figure 8 as part of the original submittal (recorded 2/11/11). 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 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 28 Northampton, Massachusetts 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 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
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 29 Northampton, Massachusetts 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 (original submittal).
Revised Class A3 & Class C1 RAO Statement RTN #1-13320 Former Cutlery Raceway March 14, 2012 320-360 Riverside Drive NEE Project No. 02-2053 Page 30 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 Activity and Use Limitation has been implemented. This portion of the Site is eligible for
a Class C1 RAO. 8.1 DEP Audit of RTN #1-13320 This revised 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) has been prepared on behalf of Cutlery Building Associates, a PRP. The original RAO submittal
dated February 8, 2011 was the subject of a DEP Audit (NOAF-NON dated November 9, 2011) which has resulted in this revised submittal. 8.2 RAO Statement Transmittal Form In accordance
with the NOAF-NON, a Post-Audit Completion Statement Transmittal Form (BWSC-111) has been completed for the Site on the eDEP system. 8.3 Public Involvement Public involvement activities
have been conducted in accordance with 310 CMR 40.1403(3)(i). 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 Revised Class A-3 & Class C1 RAO Statement. Copies of letters sent to
these offices are included in Appendix H.
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 samples were not 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 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-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 SB40422-01-03 MCP14 Metals 6010B, 7471A 12/2/2011 X X X X Y Y Y L Surrogate OK Confirmatory
Samples Sample ID or Series Site Characterization Data Qualifications, if Parameters EPA Method Date any Background Disposal Characterization
EPCs CAM Compliant MS/MSD AIR Risk Assessment Duplicate (F-Field, L=Lab) Former Cutlery Building Northampton, MA RTN1-13320 Table 3R-Data Summary Table LCS/LCSD SOIL GROUNDWATER SURFACE
WATER SEDIMENT New England Environmental, Inc. Table 3 -DataSummaryTable.xls /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 4-6R Table 4-6R 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 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 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 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 2 2 2 2 60 300 300 Chromium (III) 25000 1910 1830 4110 89.5 4090 940 345 75.7 1110 1130
4690 78.1 76.8 5760 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 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 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 20 20 20 20 NSL 7,000 Lead
220 216 505 753 128 1040 238 506 664 1260 329 4480 252 81.3 246 300 300 300 300 NSL 3,000 Antimony <31.7 BRL BRL BRL BRL BRL BRL BRL BRL 143 BRL 471 BRL BRL BRL 20 20 20 20 NSL 300 Selenium
BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 400 400 400 400 NSL 8,000 Thallium <31.7 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 79.4
773 333 418 129 597 58 103 65 447 281 657 109 101 411 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. 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 1.46 100 100 100 100
NSL 2,000 Arsenic 2.91 18.3 16.6 9.16 BRL BRL BRL BRL BRL BRL BRL BRL 76.6 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 0.779 100 100
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 2 2 2 2 60 300 Chromium (III) 34 2720 2590 274 2230 3060 3760 2740 107 3490 4560 1760
877 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 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 20 20 20 20 300 300 Nickel 185 115 89 38 2650 222 192 85.9 91.5 184 136 282 736 20 20 20 20 NSL 7,000 Lead 54.3 610 567 286 1560 1020 1190 915
176 312 475 429 432 300 300 300 300 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 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL 2.27 2.39 1.57 1.89
BRL BRL 2.42 3.49 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 79.8 105 464 66.4 574 506 781 351 173 315 247 162 117 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 RC S-1 Imminent Hazard Confirmatory Soil Samples RC S-1 New England Environmental,
Inc. PP13-CB 02-2053_Lab Table_Phase IV_soil-updated2012.xls
Table 5-1R Table 5-1R Laboratory Results -PP13 Metals in Levee 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
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 100 100 100 100 100 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 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 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 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 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 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 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 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 38.6 300 300 300 300 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 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 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 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 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
Soil Samples formerly labeled as Sediment: sand collected in floodplain RC S-1 New England Environmental, Inc. PP13-Levee 02-2053_Lab Table_Phase IV_soil-updated2012.xls
Table 5-2R Table 5-2R Laboratory Results -PP13 Metals in Sediment Former Cutlery Raceway Northampton, MA Upstream At Dam Below Dam Downstream Regulatory Standards Sample I.D.: Sample
Depth: Sed-1 Sed-2 Sed-3 SP16 0-1' DEP Sed-1 DEP Sed-1 Sed-5 Sed-6 DEP Sed-2 DEP Sed-2 DEP Sed-3 DEP Sed-3 Sed-4 Method 1 Standard UCLs (mg/kg) Sampling Date: 1/16/01 1/16/01 1/16/01
6/26/02 8/7/00 12/2/11 1/16/01 1/16/01 8/7/00 12/2/11 8/7/00 12/2/11 1/16/01 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) Silver BDL BDL BDL BDL BDL <1.62 BDL BDL BDL <1.51 BDL <1.40 BDL
NBL 100 100 100 100 NSL 2,000 Arsenic 4.53 BDL BDL BDL BDL <1.62 16 9.60 BDL <1.51 BDL <1.40 BDL 33 20 20 20 20 40 200 Barium na na na na na 18.5 na na na 21.9 na 15.5 na NBL 1000 1000
1000 1000 NSL 1 0,000 Beryllium na na na BDL 0.20 <0.541 na na BDL <0.505 BDL <0.465 na NBL 100 100 100 100 NSL 2000 Cadmium BDL BDL BDL BDL 5.50 0.563 6.02 BDL 0.30 0.651 0.28 0.489
BDL 5 2 2 2 2 60 300 Chromium (III) 10.50 5.42 5.26 6.84 23.70 40.8 67.20 71.70 51 82.4 18 43.5 12.0 110 110 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper na na na 34.7 48.0
na na na 90 na 60 na na 150 1,000 NSL NSL NSL NSL NSL Mercury BDL BDL BDL BDL BDL <0.0302 0.47 BDL 0.08 <0.0324 0.11 <0.0442 BDL 0.18 20 20 20 20 300 300 Nickel na na na 14 5.90 202
na na 88 216 25 74.2 na 49 20 20 20 20 NSL 7,000 Lead 13.20 9.92 8.52 14.9 10.0 16.8 66.50 57.30 18 25.6 16 23.2 12.2 130 300 300 300 300 NSL 3,000 Antimony na na na BDL BDL <5.41 na
na 2.40 <5.05 0.90 <4.65 na NBL 20 20 20 20 NSL 300 Selenium BDL BDL BDL BDL BDL <1.62 9.43 BDL BDL <1.51 BDL <1.40 BDL NBL 400 400 400 400 NSL 8,000 Vanadium na na na na na <3.25 na
na na <3.03 na <2.79 na NBL 600 600 600 600 NSL 1 0,000 Thallium na na na BDL BDL 12.1 na na BDL 15.2 BDL 10.0 na NBL 8 8 8 8 NSL 800 Zinc na na na 63.1 40.0 61.6 na na 53 64.7 144 58.8
na 460 2500 2500 2500 2500 NSL 10,000 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. 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. 9 -Shaded Rose -Exceeds TEC Benchmark (MassDEP, 2006) 10-NBL = No TEC Benchmark Listed AOC-3 AOC-2 AOC-1 Imminent Hazard TEC9 Benchmarks Under Stone Retaining
Wall -along Levee RC S-1 Interior Drainage Wetland Within Raceway Near MW-4 Near MW-3 New England Environmental, Inc. 3/8/2012 02-2053_Lab Table_Phase IV_soil-updated2012.xls /5-PP13-Sediment
Table 6-1R 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 0.90 <4.65 471 BDL 20 20 300 BDL BDL 8,000 80,000 Arsenic BDL BDL 76.6 BDL 20 20 200 BDL BDL 900
9,000 Beryllium BDL BDL 1.86 BDL 100 100 2000 BDL BDL 200 2,000 Cadmium 0.489 BDL 25 BDL 2 2 300 BDL BDL 4 50 Chromium 43.5 12.0 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 60 60 1,310 22.8 NSL NSL NSL BDL BDL NSL NSL Lead 23.2 12.2 1,100 37.20 300 300 3,000 BDL BDL 10 150 Nickel 74.2 25.0 2,650
11.0 20 20 7,000 20.9 BDL 200 2,000 Selenium BDL 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 10 BDL BDL BDL 8 8 800 BDL
BDL 3000 30,000 Zinc 144 59 5,020 50.9 2500 2500 10,000 3.8 BDL 900 50,000 Mercury 0.11 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 8 -Shaded Rose -Exceeds TEC
Benchmark (MassDEP, 2006) Sediment Soil Method 1 Standard Groundwater New England Environmental, Inc. 3/8/2012 02-2053_Lab Table-SOIL-SAs.xls /Table 7-Max-Min
Table 6-2R 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 0.20 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 82.4 5.26 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 34.7 41,900 5.3 NSL NSL NSL 11.7 BDL NSL NSL Lead 66.5 8.52 114,000 7.2 300 300
3,000 15.8 BDL 10 150 Nickel 216 5.90 111,000 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 15.2 BDL 19.3 BDL 8 8 800 BDL BDL 3000 30,000 Zinc 64.7 40.0 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 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 8 -Shaded Rose -Exceeds TEC Benchmark (MassDEP, 2006) Sediment Soil Method 1 Standard Groundwater New England Environmental, Inc. 3/8/2012 02-2053_Lab Table-SOIL-SAs.xls
/Table 7-Max-Min
APPENDIX A Terms & Conditions
LOCATION OF DATA RE: Revised RAO Statement Former Cutlery Raceway 320-360 Riverside Drive RTN: #1-13320 Northampton, MA NON-WE-11-3A073 The data for this Appendix did not change from
the original submittal, and can be found in the same numbered Appendix in that document.
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)
LOCATION OF DATA RE: Revised RAO Statement Former Cutlery Raceway 320-360 Riverside Drive RTN: #1-13320 Northampton, MA NON-WE-11-3A073 The data for this Appendix did not change from
the original submittal, and can be found in the same numbered Appendix in that document.
APPENDIX C Summary of Previous Submittals
LOCATION OF DATA RE: Revised RAO Statement Former Cutlery Raceway 320-360 Riverside Drive RTN: #1-13320 Northampton, MA NON-WE-11-3A073 The data for this Appendix did not change from
the original submittal, and can be found in the same numbered Appendix in that document.
APPENDIX D NEE Standard Operating Procedures
LOCATION OF DATA RE: Revised RAO Statement Former Cutlery Raceway 320-360 Riverside Drive RTN: #1-13320 Northampton, MA NON-WE-11-3A073 The data for this Appendix did not change from
the original submittal, and can be found in the same numbered Appendix in that document.
APPENDIX E Laboratory Analytical Reports & Groundwater Sampling Log
Report Date: 16-Dec-11 14:41 ü Final Report Re-Issued Report Revised Report SPECTRUM ANALYTICAL, INC. Featuring HANIBAL TECHNOLOGY Laboratory Report New England Environmental, Inc. 15
Research Drive Amherst, MA 01002 Attn: Lyons Witten Project: Project #: Cutlery -Northampton, MA 02-2053 Laboratory ID Client Sample ID Matrix Date Sampled Date Received SB40422-01 DEP-SED
1 Soil 02-Dec-11 14:30 06-Dec-11 13:25 SB40422-02 DEP-SED 2 Soil 02-Dec-11 14:40 06-Dec-11 13:25 SB40422-03 DEP-SED 3 Soil 02-Dec-11 14:50 06-Dec-11 13:25 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. 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 Authorized by: Nicole Leja Laboratory Director 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 8 pages of analytical data plus Chain of Custody document(s). When the Laboratory Report is indicated as revised, this report supersedes
any previously dated reports for the laboratory ID(s) referenced above. Where this report identifies subcontracted analyses, copies of the subcontractor's test report are available upon
request. This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. 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 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). Headquarters: 11 Almgren Drive & 830 Silver Street • Agawam, MA 01001 • 1-800-789-9115 • 413-789-9018 • Fax 413-789-4076 www.spectrum-analytical.com
Page 1 of 8
MassDEP Analytical Protocol Certification Form Laboratory Name: Spectrum Analytical, Inc. Project #: 02-2053 Project Location: Cutlery -Northampton, MA RTN: This form provides certifications
for the following data set: SB40422-01 through SB40422-03 Matrices: Soil CAM Protocol 8260 VOC CAM II A 7470/7471 Hg CAM III B MassDEP VPH CAM IV A 8081 Pesticides CAM V B 7196 Hex Cr
CAM VI B MassDEP APH CAM IX A 8270 SVOC CAM II B 7010 Metals CAM III C MassDEP EPH CAM IV B 8151 Herbicides CAM V C 8330 Explosives CAM VIII A TO-15 VOC CAM IX B 6010 Metals CAM III
A 6020 Metals CAM III D 8082 PCB CAM V A 9014 Total Cyanide/PAC CAM VI A 6860 Perchlorate ü CAM VIII B üAffirmative responses to questions A through F are required for "Presumptive Certainty"
status Were all samples received in a condition consistent with those described on the Chain of Custody, properly preserved (including temperature) in the field or laboratory, and prepared/analyzed
within method holding times? Were the analytical method(s) and all associated QC requirements specified in the selected CAM protocol(s) followed? Were all required corrective actions
and analytical response actions specified in the selected CAM protocol(s) implemented for all identified performance standard non-conformances? Does the laboratory report comply with
all the reporting requirements specified in CAM VII A, "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of Analytical Data"? a. VPH, EPH, and APH Methods
only: Was each method conducted without significant modification(s)? b. APH and TO-15 Methods only: Was the complete analyte list reported for each method? Were all applicable CAM protocol
QC and performance standard non-conformances identified and evaluated in a laboratory narrative (including all "No" responses to questions A through E)? Responses to questions G, H and
I below are required for "Presumptive Certainty" status Were the reporting limits at or below all CAM reporting limits specified in the selected CAM protocol(s)? Data User Note: Data
that achieve "Presumptive Certainty" status may not necessarily meet the data usability and representativeness requirements described in 310 CMR 40. 1056 (2)(k) and WSC-07-350. Were
all QC performance standards specified in the CAM protocol(s) achieved? Were results reported for the complete analyte list specified in the selected CAM protocol(s)? All negative responses
are addressed in a case narrative on the cover page of this report. 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. Nicole Leja Laboratory
Director Date: 12/16/2011 ABCDEFGHI Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No üüüüü ü üü Yes No 9012 Total Cyanide/PAC CAM VI A This laboratory report is not valid
without an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 2 of 8
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. If a Matrix Spike (MS), Matrix Spike Duplicate (MSD) or Duplicate (DUP) was not requested on the Chain of
Custody, method criteria may have been fulfilled with a source sample not of this Sample Delivery Group. 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. Regulatory limits may not be achieved if specific method method and/or technique was not requested on the Chain of Custody. According to WSC-CAM
5/2009 Rev.1, Table 11 A-1, recovery for some VOC analytes have been deemed potentially difficult. Although they may still be within the recommended recovery range, a range has been
set based on historical control limits. Some target analytes which are not listed as exceptions in the Summary of CAM Reporting Limits may exceed the recommended RL based on sample initial
volume or weight provided, % moisture content, or responsiveness of a particular analyte to purge and trap instrumentation. There is no relevant protocol-specific QC and/or performance
standards non-conformances to report. This laboratory report is not valid without an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 3 of 8
DEP-SED 1 Sample Identification Matrix 02-Dec-11 14:30 Collection Date/Time Received 06-Dec-11 Client Project # 02-2053 Soil SB40422-01 CAS No. Analyte(s) Result Flag Units *RDL MDL
Dilution Method Ref. Prepared Analyzed Analyst Batch Cert. Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver < 1.62 mg/kg dry 1.62 0.250 1 SW846 6010C 13-Dec-11 14-Dec-11
LR 1125909 7440-38-2 Arsenic < 1.62 mg/kg dry 1.62 0.261 1 " " " " " 7440-39-3 Barium 18.5 mg/kg dry 1.08 0.261 1 " " " " " 7440-41-7 Beryllium < 0.541 mg/kg dry 0.541 0.173 1 " " "
" " 7440-43-9 Cadmium 0.563 mg/kg dry 0.541 0.0597 1 " " " " " 7440-47-3 Chromium 40.8 mg/kg dry 1.08 0.394 1 " " " " " 7439-97-6 Mercury < 0.0302 mg/kg dry 0.0302 0.0062 1 SW846 7471B
" 13-Dec-11 RH 1125910 7440-02-0 Nickel 202 mg/kg dry 1.08 0.0745 1 SW846 6010C " 14-Dec-11 LR 1125909 7439-92-1 Lead 16.8 mg/kg dry 1.62 0.192 1 " " " " " 7440-36-0 Antimony < 5.41
mg/kg dry 5.41 0.238 1 " " " " " 7782-49-2 Selenium < 1.62 mg/kg dry 1.62 0.240 1 " " " " " 7440-28-0 Thallium < 3.25 mg/kg dry 3.25 0.267 1 " " " " " 7440-62-2 Vanadium 12.1 mg/kg dry
1.62 0.284 1 " " " " " 7440-66-6 Zinc 61.6 mg/kg dry 1.08 0.235 1 " " " " " General Chemistry Parameters % Solids 90.8 % 1 SM2540 G Mod. 07-Dec-11 07-Dec-11 DT 1125511 This laboratory
report is not valid without an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 4 of 8
DEP-SED 2 Sample Identification Matrix 02-Dec-11 14:40 Collection Date/Time Received 06-Dec-11 Client Project # 02-2053 Soil SB40422-02 CAS No. Analyte(s) Result Flag Units *RDL MDL
Dilution Method Ref. Prepared Analyzed Analyst Batch Cert. Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver < 1.51 mg/kg dry 1.51 0.233 1 SW846 6010C 13-Dec-11 14-Dec-11
LR 1125909 7440-38-2 Arsenic < 1.51 mg/kg dry 1.51 0.243 1 " " " " " 7440-39-3 Barium 21.9 mg/kg dry 1.01 0.244 1 " " " " " 7440-41-7 Beryllium < 0.505 mg/kg dry 0.505 0.162 1 " " "
" " 7440-43-9 Cadmium 0.651 mg/kg dry 0.505 0.0557 1 " " " " " 7440-47-3 Chromium 82.4 mg/kg dry 1.01 0.368 1 " " " " " 7439-97-6 Mercury < 0.0324 mg/kg dry 0.0324 0.0066 1 SW846 7471B
" 13-Dec-11 RH 1125910 7440-02-0 Nickel 216 mg/kg dry 1.01 0.0695 1 SW846 6010C " 14-Dec-11 LR 1125909 7439-92-1 Lead 25.6 mg/kg dry 1.51 0.180 1 " " " " " 7440-36-0 Antimony < 5.05
mg/kg dry 5.05 0.222 1 " " " " " 7782-49-2 Selenium < 1.51 mg/kg dry 1.51 0.224 1 " " " " " 7440-28-0 Thallium < 3.03 mg/kg dry 3.03 0.249 1 " " " " " 7440-62-2 Vanadium 15.2 mg/kg dry
1.51 0.265 1 " " " " " 7440-66-6 Zinc 64.7 mg/kg dry 1.01 0.219 1 " " " " " General Chemistry Parameters % Solids 89.8 % 1 SM2540 G Mod. 07-Dec-11 07-Dec-11 DT 1125511 This laboratory
report is not valid without an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 5 of 8
DEP-SED 3 Sample Identification Matrix 02-Dec-11 14:50 Collection Date/Time Received 06-Dec-11 Client Project # 02-2053 Soil SB40422-03 CAS No. Analyte(s) Result Flag Units *RDL MDL
Dilution Method Ref. Prepared Analyzed Analyst Batch Cert. Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver < 1.40 mg/kg dry 1.40 0.215 1 SW846 6010C 13-Dec-11 14-Dec-11
LR 1125909 7440-38-2 Arsenic < 1.40 mg/kg dry 1.40 0.224 1 " " " " " 7440-39-3 Barium 15.5 mg/kg dry 0.931 0.225 1 " " " " " 7440-41-7 Beryllium < 0.465 mg/kg dry 0.465 0.149 1 " " "
" " 7440-43-9 Cadmium 0.489 mg/kg dry 0.465 0.0514 1 " " " " " 7440-47-3 Chromium 43.5 mg/kg dry 0.931 0.339 1 " " " " " 7439-97-6 Mercury 0.0442 mg/kg dry 0.0302 0.0062 1 SW846 7471B
" 13-Dec-11 RH 1125910 7440-02-0 Nickel 74.2 mg/kg dry 0.931 0.0641 1 SW846 6010C " 14-Dec-11 LR 1125909 7439-92-1 Lead 23.2 mg/kg dry 1.40 0.166 1 " " " " " 7440-36-0 Antimony < 4.65
mg/kg dry 4.65 0.205 1 " " " " " 7782-49-2 Selenium < 1.40 mg/kg dry 1.40 0.206 1 " " " " " 7440-28-0 Thallium < 2.79 mg/kg dry 2.79 0.229 1 " " " " " 7440-62-2 Vanadium 10.0 mg/kg dry
1.40 0.244 1 " " " " " 7440-66-6 Zinc 58.8 mg/kg dry 0.931 0.202 1 " " " " " General Chemistry Parameters % Solids 90.9 % 1 SM2540 G Mod. 07-Dec-11 07-Dec-11 DT 1125511 This laboratory
report is not valid without an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 6 of 8
Total Metals by EPA 6000/7000 Series Methods -Quality Control Result Units Spike Level Source Result %REC %REC Limits RPD RPD Analyte(s) Flag *RDL Limit Batch 1125909 -SW846 3050B Blank
(1125909-BLK1) Prepared: 13-Dec-11 Analyzed: 14-Dec-11 Lead < 1.50 mg/kg wet 1.50 Zinc < 1.00 mg/kg wet 1.00 Vanadium < 1.50 mg/kg wet 1.50 Thallium < 3.00 mg/kg wet 3.00 Antimony <
5.00 mg/kg wet 5.00 Nickel < 1.00 mg/kg wet 1.00 Selenium < 1.50 mg/kg wet 1.50 Chromium < 1.00 mg/kg wet 1.00 Cadmium < 0.500 mg/kg wet 0.500 Beryllium < 0.500 mg/kg wet 0.500 Arsenic
< 1.50 mg/kg wet 1.50 Silver < 1.50 mg/kg wet 1.50 Barium < 1.00 mg/kg wet 1.00 Reference (1125909-SRM1) Prepared: 13-Dec-11 Analyzed: 14-Dec-11 Antimony 43.9 mg/kg wet 5.00 61.3 72
0-224.2 Thallium 118 mg/kg wet 3.00 118 100 75.3-124.2 Lead 66.0 mg/kg wet 1.50 70.0 94 77.4-122.6 Selenium 100 mg/kg wet 1.50 103 97 76.7-122.8 Zinc 152 mg/kg wet 1.00 141 109 78.5-121.4
Nickel 61.6 mg/kg wet 1.00 61.8 100 79.6-119.8 Vanadium 50.2 mg/kg wet 1.50 53.1 95 75.6-124 Beryllium 46.2 mg/kg wet 0.500 48.5 95 80.1-120 Silver 25.9 mg/kg wet 1.50 27.3 95 66.4-133.8
Arsenic 61.2 mg/kg wet 1.50 63.4 97 78-121.8 Cadmium 59.8 mg/kg wet 0.500 59.3 101 80.7-118.9 Chromium 46.3 mg/kg wet 1.00 49.0 94 76.7-123 Barium 156 mg/kg wet 1.00 161 97 79.7-120.2
Reference (1125909-SRM2) Prepared: 13-Dec-11 Analyzed: 14-Dec-11 Lead 58.6 mg/kg wet 1.50 69.3 85 77.4-122.6 Thallium 105 mg/kg wet 3.00 117 90 75.3-124.2 Vanadium 46.2 mg/kg wet 1.50
52.6 88 75.6-124 Selenium 92.6 mg/kg wet 1.50 102 91 76.7-122.8 Zinc 137 mg/kg wet 1.00 139 99 78.5-121.4 Antimony 37.3 mg/kg wet 5.00 60.7 61 0-224.2 Nickel 54.7 mg/kg wet 1.00 61.2
89 79.6-119.8 Beryllium 41.2 mg/kg wet 0.500 48.0 86 80.1-120 Chromium 40.8 mg/kg wet 1.00 48.5 84 76.7-123 Cadmium 53.2 mg/kg wet 0.500 58.6 91 80.7-118.9 Arsenic 55.6 mg/kg wet 1.50
62.7 89 78-121.8 Silver 23.0 mg/kg wet 1.50 27.0 85 66.4-133.8 Barium 141 mg/kg wet 1.00 160 89 79.7-120.2 Batch 1125910 -EPA200/SW7000 Series Blank (1125910-BLK1) Prepared & Analyzed:
13-Dec-11 Mercury < 0.0262 mg/kg wet 0.0262 Reference (1125910-SRM1) Prepared & Analyzed: 13-Dec-11 Mercury 3.68 mg/kg wet 0.300 3.81 97 71.7-128.3 This laboratory report is not valid
without an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 7 of 8
Notes and Definitions RPD Relative Percent Difference dry Sample results reported on a dry weight basis NR Not Reported 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, standards,
and samples prior to analysis. Percent recoveries are calculated for each surrogate. Continuing Calibration Verification: The calibration relationship established during the initial
calibration must be verified at periodic intervals. Concentrations, intervals, and criteria are method specific. Validated by: Nicole Leja This laboratory report is not valid without
an authorized signature on the cover page. 16-Dec-11 14:41 * Reportable Detection Limit Page 8 of 8
APPENDIX F Risk Assessment
EnvironmentalSafetyHealthGeotechnical O’Reilly, Talbot & Okun E N G I N E E R I N G 69 Milk Street [ A S S O C I A T E S ] Suite 218 Westborough, MA 01581 Tel 508 366 6409 Fax 508 366
9826 www.oto-env.com March 8, 2012 File No: 5028-02-03 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 10 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 15 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 16 2.4.1.2 Identification of Exposure Routes 17 2.4.1.3 Exposure Profile Summary 17 2.4.2 Development of Exposure Factors 17 2.4.3 Exposure
Point Concentrations (EPCs) 18 2.4.4 Calculation of Average Daily Doses 20 2.5 Risk Characterization 21 2.5.1 Non-Cancer Risk 22 2.5.2 Cancer Risk 22 2.5.3 Summary of Findings 23 2.6
Uncertainty Analysis 24 3.0 Characterization of Risk of Harm to Public Welfare 26 4.0 Characterization of Risk of Harm to Safety 27 5.0 Environmental Risk Characterization 27 5.1 Aquatic
Habitat Screening 29 5.2 Terrestrial Habitat Screening 31 6.0 Conclusions 31 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 34 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 -Cutlery Building TABLE 5-1R IRA Plan (NEE 6/2006) -Table 2 -Laboratory Results -PP13 Metals in Soil -Levee TABLE 5-2R Laboratory Results -PP13 Metals in Sediment 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 Exposure Assumptions and Equations for Recreational User -Incidental Ingestion
of and Dermal Contact with Soil TABLE 11 Groundwater Exposure Point Concentrations (EPCs) TABLE 12 Soil Exposure Point Concentrations (EPCs) TABLE 13 Calculation of Risk Estimates for
Construction Worker -Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates TABLE 14 Calculation of Risk Estimates for Recreational User -Incidental
Ingestion of and Dermal Contact with Soil TABLE 15 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 (the “Site”) 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, 2012).
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 3/8/12 5028-02-03 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 (the “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 3/8/12 5028-02-03 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 (Figure 3 of the RAO-P Report). 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 all areas of AOC-1, where heavy metals were identified
in excess of their respective Upper Concentration Limits (UCLs) in 2005, this material was excavated and moved to the existing soil stockpile within AOC-2. This includes several areas
under the Cutlery and VHI 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). These concentrations were included in the calculated Exposure Point Concentrations (EPCs) in this Method 3 Risk Characterizations (Section 2.4.3). Residual contamination
in this and other areas of AOC-1 is still present in soil. Those 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 Northampton Cutlery 3 3/8/12
5028-02-03 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 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 soil as specified in the AUL. These 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. The floodplain area of the riverbank is unpaved. 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 5-1R). 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-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 Northampton Cutlery 4 3/8/12 5028-02-03 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 stockpile accepting UCL 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 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. Sediment samples were
collected along shoreline in the Mill River in 2000, 2001, 2002, or December 2011, and in the interior drainage wetland within the raceway in 2001. These samples were analyzed for metals
(Table 5-2R). OTO collected samples from 3 to 4 along 3 transects across the Mill River in 2006 adjacent to AOCs -1, -2, and -3, and upstream (Table 2-4). These samples were analyzed
for EPH, PAHs, and metals. The concentrations of only cadmium or nickel in samples collected along the shoreline (DEP Sed-1, -2 and -3) exceeded the MassDEP Threshold Effects Concentrations
(TECs) in sediment. In addition, the concentrations of cadmium and nickel in one sample (Sed-5) within the raceway exceeded the TECs (Table 5-2R). 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. Northampton Cutlery 5 3/8/12 5028-02-03 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 analytical data used in the Method 3 Risk Characterization are presented in Tables 1 through 5 (NEE and OTO
data sets) from the NEE 2012 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). 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. Also AOC-1 includes the floodplain riverbank area of the Mill River. 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. No classes are taught at this facility. 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 Northampton Cutlery 6 3/8/12 5028-02-03 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 Identification 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. For AOC-1, except for the river bank and floodplain area, 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. The soils
on the river bank without erosion controls, and not fenced nor gated would be considered to be “accessible” for exposure. 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, excluding the river bank, 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 river bank area of AOC-1 may be accessed by recreational users of the Mill River. However, this area of the
bank is steep and there is no designated recreational area at this location. Therefore, frequency and intensity of exposure is considered to low. 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. Northampton Cutlery 7 3/8/12 5028-02-03 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-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. 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 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 MassGIS’s DEP Priority Resource Map data layers for Easthampton, MA Quadrangles, 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. Northampton Cutlery 8 3/8/12 5028-02-03 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 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. 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 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. The river is assumed to be the receptor of Site groundwater. The DEP’s BWSC Priority Resource Map of
the Easthampton Quadrangle (Figure 6 of the RAO-P Report) indicates there are estimated habitats of rare or endangered species along 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. Northampton Cutlery 9 3/8/12 5028-02-03 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 Flood Insurance Rate Map (FIRM) of Northampton, Massachusetts (Community Panel Number 250167 002 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 Mill River are located in Zone A7,
an area within the 100-year flood zone. Applicable Groundwater Categories 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 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. 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 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 Northampton Cutlery 10 3/8/12
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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 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 fractions were
detected in select samples at concentrations that were below 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 some of the EPH fractions are derived
from the coal and/or coal ash, and not Site-related activities. However, a few isolated samples had elevated EPH fractions characterized by C19-C36 aliphatics, which is more consistent
with a waste oil release. Therefore, EPH fractions were selected as soil COCs. 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 EPH fractions, 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 Northampton
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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 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 Sediment data collected in 2000, 2001, 2002, and 2011 are presented in Table 5-2R. The metals that were detected
in at least one sample collected from the river shoreline were barium, beryllium, cadmium, chromium, copper, mercury, nickel, lead, antimony, thallium, and zinc. Arsenic and selenium
were detected in only those samples collected from the interior drainage wetland with the raceway. 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. The metals detected in Site sediment samples were antimony, arsenic, beryllium, cadmium, chromium, copper, lead, nickel, and zinc. The metals antimony, barium,
cadmium, chromium, copper, lead, mercury, nickel, thallium, and zinc were detected in at least one Site transect samples at concentrations higher than in the upstream samples (OSS-41,
-42, and -43; and Upstream Sed-1). These metals are 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. 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. Northampton
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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 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 (EPA, 2012),
US US EPA's Health Effects Assessment Summary Tables (HEAST) (EPA, 1997a) and MassDEP documents (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). Northampton Cutlery 13 3/8/12 5028-02-03 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 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. 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). Northampton Cutlery 14 3/8/12
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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 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 (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). 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. Northampton Cutlery 15 3/8/12 5028-02-03 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 2.4.1 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 and recreational users
on the Mill River. Soil exposure 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 is based on an exposure duration of 6 months. Given the current development of the Site and size and shape of the parking lot, and the steepness of
the “CB”, as well as obligations and conditions set forth in the AUL opinion including erosion control material, the duration is considered to be conservative for Site-specific construction
activities. In addition, this 6 month duration of exposure for construction workers is considered to be protective of lesser-exposed receptors, such as the utility worker and authorized
remediation maintenance personnel. Soil exposure and risks were also quantitatively evaluated for recreational users on the Mill River that may access the floodplain area of the river
bank (Floodplain Riverbank soils). 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 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. Northampton Cutlery 16 3/8/12 5028-02-03 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 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 AOC-1 Recreational Use of Mill River (current/future)
Child to Adult Subchronic to Chronic Floodplain Riverbank Soil Incidental Ingestion Dermal Contact 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 are from the MassDEP’s Shortforms for Human Health Risk Assessment under the MCP (sf08cw) (MassDEP, 2008c). Northampton Cutlery 17 3/8/12 5028-02-03 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 Exposure assumptions and equations for estimating exposures for the recreational user scenario for the Floodplain
Riverbank soils are from the MassDEP Shortform for a park visitor (sf06ps). The park visitor shortform assumes a frequency of exposure for subchronic noncarcinogenic effects of 156 days/year
for a child of 1-2 years of age; for chronic noncarcinogenic effects of 90 days/year for a child of 1-8 years of age; and for carcinogenic effects of 90 days/year for a child to adult
of 1 to 31 years of age. Given the steepness of the floodplain riverbank area at AOC-1 and that there is no formal recreational in this area, the frequency of exposures are considered
to be conservative. It is noted that the MassDEP frequency of exposure for trespassers (sf06ts) (104 days for subchronic noncarcinogenic effects, and 60 days for chronic noncarcinogenic
and carcinogenic effects) is less than for the park visitor. Therefore, evaluation of exposure to the Floodplain Riverbank soils for park visitors is protective of similar exposures
to trespassers. 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 Table 10 -Recreational User -Incidental Ingestion and Dermal Contact 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 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 Northampton Cutlery 18 3/8/12 5028-02-03 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 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. 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 11. 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. AOC-1 Parking Lot -The EPCs for metals 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. The metals EPCs for the Parking Lot were developed as if the SA-1 through SA-5 excavation were a continuous area,
rather than actual discrete areas. The samples that were collected prior to the 2004 excavations and were located between the SA excavations were not included in the EPC. The metals
concentrations in these excluded samples were generally lower than average metals concentrations in the SA samples. For example, the Northampton Cutlery 19 3/8/12 5028-02-03 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 EPCs for lead in the SA samples was 305 mg/kg. The concentrations of lead in seven samples also collected from the
Parking Lot area (i.e., IHS-2, IHS-3, NEE-9, NEE-10, TP-9a, and TP-9c) ranged from 52 mg/kg to 249 mg/kg and these lower concentrations were not included in the EPCs for the Parking
Lot. Thereby, exclusion of these non-SA excavation samples resulted in EPCs that were biased high for the Parking Lot, and the EPCs used in the risk calculation represent a conservative
estimate of the average concentration. AOC-1 CB area -The EPCs for metals 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 inches bgs and are currently located
under the erosion control materials. As the CB excavation area represents a small portion of the bank area in AOC-1, the EPCs are area-weighted toward this portion of the bank. AOC-1
Floodplain Riverbank -The EPCs for metals were developed for those soil samples collected in the floodplain area of the Mill River and include soil samples CB-5, CB-11, CB-14, CB-16,
and CB-17 collected from a depth of 0 to 3 inches bgs. The EPCs for metals for AOC-1 were calculated based on the average of the detected concentrations in the three sample sets (Table
12). The EPCs for EPH fractions for AOC-1 were selected as the maximum detected concentrations (Table 6-1). These EPCs were used in the risk calculations for both the AOC-1 Parking Lot
and CB area. 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 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: 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 Northampton Cutlery 20 3/8/12 5028-02-03 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 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 13) and recreational users (Table 14). 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. 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 Northampton Cutlery 21 3/8/12 5028-02-03 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 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 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. The hazard indices are presented in Tables 13 and 14 and are summarized in Table 15. The total screening HIs for construction workers for AOC-1 Parking
Lot is equal to 1 and for AOC-1 CB Area exceeds 1. The total screening
HI for recreational users of the Floodplain Bank Area for subchronic effects is equal to 1, and for chronic effects is less than 1. The total screening HIs that were equal to or exceeded
1 were segregated by critical effect. For the AOC-1 Parking Lot and CB area soil exposure to the construction worker and the Floodplain Riverbank area soil exposure for recreational
users, the resultant segregated HIs do not exceed 1. Northampton Cutlery 22 3/8/12 5028-02-03 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 finding indicates a Condition of No Significant Risk for noncancer effects to construction workers and recreational
users. 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 13 and 14 and are summarized in Table 15. The ELCRs for construction workers and recreational users 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. 2. The segregated HIs and ELCR
for recreational users from soil exposure in AOC-1 Floodplain Riverbank area 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. Recreational user exposure to Site soil is considered to be protective of lesser-exposed receptors, such as trespassers. Northampton
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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 3. 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.
4. 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. 5. 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 and recreational users based on current and foreseeable future Site uses. Construction worker exposure is considered to be protective of
lesserexposed utility workers and landscapers. Recreational user exposure is considered to be protective of lesser-exposed trespassers. 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 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. A. Hazard Identification Northampton Cutlery 24 3/8/12 5028-02-03 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 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. 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 Northampton Cutlery 25 3/8/12 5028-02-03 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 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)). 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. Northampton Cutlery 26 3/8/12 5028-02-03 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 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 STAGE I ENVIRONMENTAL
SCREENING 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)]. 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. In Stage I, the objective is to identify and document conditions, which do not warrant a Stage II Risk Characterization,
either because of the absence of potentially significant exposure pathways or because environmental harm is readily apparent and, therefore, additional assessment would be redundant.
Northampton Cutlery 27 3/8/12 5028-02-03 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 a potentially significant exposure pathway is indicated by the available information, then a Stage II Environmental
Risk Characterization is required to characterize the risks posed by those exposures to demonstrate a Condition of No Significant Risk. If there are no complete exposure pathways, readily
apparent harm, or potentially significant exposures, no further action for assessing ecological risk is required. As specified in the MCP, evidence of current or potential future exposures
may include, but is not limited to: a. Current or past visual physical evidence of OHM from the Site in surface soil, surface water, sediment, or wetlands, such as sheens, non-aqueous
phase liquids, oil or tar; b. Records or other evidence of current or past environmental impacts, such as fish kills and abiotic conditions; c. Analytical data indicating the presence
of OHM attributable to the site in question in surface water and sediment (including wetlands), d. The potential for transport of OHM in groundwater or surface runoff to such receptors
as surface water or sediments (including wetlands) identified as environmental receptors, or e. The presence of OHM at the disposal site within two feet of ground surface and the potential
for such contamination to result in exposure to wildlife. If no current or potential future exposure is identified, then a Condition of “No Significant Risk of Harm” to the site biota
and habitats exists or has been achieved, and a Stage II Environmental Risk Characterization is not required. If any current or potential future exposure is identified, then for each
exposure, site conditions are evaluated to determine when significant environmental harm is “readily apparent”. According to the MCP, the following conditions represent “readily apparent
harm”: a. Visual evidence of stressed biota attributable to the release, such as fish kills or abiotic conditions, b. For surface water, OHM concentrations attributable to the site that
exceed Massachusetts Surface Water Quality Standards, which include USEPA National Ambient Water Quality Criteria (NAWQC), or c. For soil, visible presence of oil, tar, or other non-aqueous
phase hazardous material within three feet of the ground surface over an area equal to or greater than two acres. If a Condition of Readily Apparent Harm exists in any environmental
medium, then a Condition of “No Significant Risk of Harm” does not exist, and a Stage II Environmental Risk Characterization is not required to make that determination for that medium.
Northampton Cutlery 28 3/8/12 5028-02-03 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 each current and potential future exposure identified, a determination as to whether it could result in “potentially
significant exposure” is made. Any potential exposure identified must be considered a “potentially significant exposure” unless it can be ruled out as such using: a. For surface water,
USEPA National Ambient Water Quality Criteria (NAWQC) and Massachusetts Surface Water Standards, b. For sediment, environmental concentrations specifically adopted by the MassDEP as
screening criteria (MassDEP, 2002c), and c. For soil, site size, location, and/or landscape characteristics specifically adopted by MassDEP as screening criteria. If through the application
of these screening criteria, an environmental medium can be screened out as a source of “potentially significant exposures”, then a Stage II Environmental Risk Characterization is not
required for any exposure pathway for which that medium is the contaminated source. If current or potential future exposures to contaminants in any media are not ruled out in Stage I
screening, those exposures are considered to be “potentially significant exposures”. In this case, remediation and further assessment or a Stage II Environmental Risk Characterization
is required to determine whether a Condition of “No Significant Risk of Harm” exists to close out the site. In addition, MassDEP has issued Technical Updates for MCP environmental assessments
that discuss the ecological value of surface waters, area-based screening for sediment contamination, and sediment screening values (MassDEP, 2006a, 2006b, and 2006c). 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
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. Northampton Cutlery 29 3/8/12 5028-02-03 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 No sheen, non-aqueous phase liquids, oil or tar have been observed in the Mill River. There is no physical evidence
of environmental impacts, such as fish kills and abiotic conditions. Groundwater and Surface Water Data -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. As indicated on Table 11, 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 MassDEP 2008 Lowest Ecologically Based Criteria) in the surface water samples they collected from the Mill River (Table
2-3). In addition, dissolved lead was not detected in MW-4 in 2006 and 2008 (Table 10). Therefore, dissolved metals in Site groundwater do not appear to be migrating at and are not present
in surface water at concentrations that would have an adverse impact on aquatic receptors in the Mill River. Therefore, there is no “readily apparent harm” and no “potentially significant
exposure”. A Condition of No Significant Risk exists for the aquatic environment. Northampton Cutlery 30 3/8/12 5028-02-03 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 Sediment Data -Sediment samples were collected along the shoreline of the Mill River in 2000, 2001, 2002, or December
2011 and analyzed for metals (Table 5-2R). OTO collected 3 to 4 samples from 3 transects traversing the Mill River in 2006 adjacent to AOCs -1, -2, and -3, and upstream (Table 2-4).
These samples were analyzed for EPH, PAHs, and metals. These sediment data (Table 5-2R) were compared to MassDEP Threshold Effects Concentrations (TECs) (MassDEP, 2006c). This comparison
indicates that the historical concentrations in 2000 of cadmium in DEP Sed-1 (collected from under the stone retaining wall along the levee) in 2000, and nickel in DEP Sed-2 (collected
near MW-4) exceeded the TEC. These data were considered to be superseded by the December 2011 samples collected from DEP Sed-1, DEP Sed-2, and DEP Sed-3. The only exceedance of the TECs
in the December 2011 sediment data were for nickel in DEP Sed-1, DEP Sed-2, and DEP Sed-3 collected near MW-3 (Table 5-2R). The concentrations of nickel were highest adjacent to the
levee in AOC-3 (DEP Sed-1 at 202 mg/kg and DEP-2 at 216 mg/kg) and decreased downstream at DEP Sed-3 adjacent to AOC-1 (74.2 mg/kg). There were no exceedances of TECs in any of the transect
sediment samples (Table 2-4). 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. Surface soils (within two feet of the ground surface) within metals present
are located in the Floodplain Riverbank area of AOC-1. Other in AOC-2 and AOC-3 are impacted by metals. Soil exposure to terrestrial receptors could occur in soils in ACO-1, 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 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.
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: Northampton Cutlery 31 3/8/12 5028-02-03 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 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 within an ACEC nor is contaminant
transport from surface soil to an ACEC possible. However, 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 exists based on the MCP criteria in 310 CMR 40.0956(2). 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. 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 AOC-1, the Method 3 Risk Characterization
concludes that a Condition of No Significant Risk exists for construction workers in the Parking Lot and CB area, and recreational users in the Floodbank Riverbank area based on on current
and foreseeable future Site uses. Northampton Cutlery 32 3/8/12 5028-02-03 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 Construction worker exposure is considered to be protective of lesser-exposed utility workers and landscapers. Recreational
exposure is considered to be protective of lesserexposed trespassers. Soil exposures to other human 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. Potentially significant exposures were not found to exist under current and foreseeable
future Site conditions for aquatic receptors based on surface water and groundwater data being below applicable criteria. For sediment, no exceedances of TECs were reported for metals
in samples collected along the shoreline of, from transects adjacent to the Site across, and downstream of the Site in the Mill River, with one exception. Sediment concentrations for
only nickel reported in the December 2011 samples DEP Sed-1, DEP Sed-2, and DEP Sed-3, collected along the shoreline, exceeded the TEC. The nickel sediment concentrations were highest
adjacent to the levee at AOC-3 (DEP Sed-1) and decreased in concentrations to downstream sample adjacent to AOC-1 (DEP Sed-3). The sediment data, evaluated in total, indicates that potentially
significant exposure to aquatic receptors in sediments, if any, are likely to be limited to along the shoreline. Remedial actions, specifically levee and slope stabilization completed
to reduce erosion, completed at the Site and to be maintained as conditions of the RAO-Ps are aimed to minimize any further potential impacts of metals to Mill River shoreline sediments,
particularly as conducted under the Class C-1 RAO 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. 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. A Condition of No Substantial Hazard exists for the environment at AOC-2 and AOC-3. 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 33 3/8/12 5028-02-03 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
(MassDEP). 2003. Updated Petroleum Hydrocarbon Fraction Toxicity Values for the VPH/EPH Methodology. Final. November 2003. Massachusetts Department of Environmental Protection (MassDEP).
2005. Bureau of Waste Site Cleanup Master MCP Q&A 1993-2004. Northampton Cutlery 34 3/8/12 5028-02-03 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). 2006a. Technical Update -Ecological
Value of Surface Water Features. Interim Technical Update. January 2006. Massachusetts Department of Environmental Protection (MassDEP). 2006b. Technical Update -Area-Based Screening
for Sediment Contamination. Interim Technical Update. January 2006. Massachusetts Department of Environmental Protection (MassDEP). 2006c. Technical Update -Revised Sediment Screening
Values. Interim Technical Update. January 2006. 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 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). 2012. Class A-3 & Class C-1 Response Action
Outcome (RAO-P) Statements. Former Cutlery Raceway, 320-360 Riverside Drive, Northampton, Massachusetts. Release Tracking Number 1-13320. March 2012. 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). 2012. Integrated Risk Information System.
Office of Health and Environmental Assessment. On-line database. February 2012. Northampton Cutlery 35 3/8/12 5028-02-03 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 Northampton Cutlery 36 3/8/12 5028-02-03 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 3/8/12 5028-02-03 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 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 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 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 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 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 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 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 20 20 20 20 NSL 7,000 Lead 220
216 505 753 128 1040 238 506 664 1260 329 4480 252 81.3 246 300 300 300 300 NSL 3,000 Antimony <31.7 BRL BRL BRL BRL BRL BRL BRL BRL 143 BRL 471 BRL BRL BRL 20 20 20 20 NSL 300 Selenium
BDL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 400 400 400 400 NSL 8,000 Thallium <31.7 BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 79.4
773 333 418 129 597 58 103 65 447 281 657 109 101 411 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. 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. 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 4.07 5.32 1.76 1.43 BRL BRL 2.76 1.46 100 100 100
100 NSL 2,000 Arsenic 2.91 18.3 16.6 9.16 BRL BRL BRL BRL BRL BRL BRL BRL 76.6 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 0.779 100
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 2 2 2 2 60 300 Chromium (III) 34 2720 2590 274 2230 3060 3760 2740 107 3490 4560 1760
877 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 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 20 20 20 20 300 300 Nickel 185 115 89 38 2650 222 192 85.9 91.5 184 136 282 736 20 20 20 20 NSL 7,000 Lead 54.3 610 567 286 1560 1020 1190 915
176 312 475 429 432 300 300 300 300 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 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL 2.27 2.39 1.57 1.89
BRL BRL 2.42 3.49 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL 8 8 8 8 NSL 800 Zinc 79.8 105 464 66.4 574 506 781 351 173 315 247 162 117 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 RC S-1 Imminent Hazard Confirmatory Soil Samples Samples RC S-1 New England Environmental,
Inc. PP13-CB Table 4-6 PP13 CB
Table 5-1R Table 5-1R 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
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 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 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 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 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 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 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 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 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 38.6 300 300 300 300 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 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 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 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 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 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 RC S-1 IRA PLAN (NEE 06/2006) -Table 2 Soil Samples formerly labeled as Sediment: sand collected
in floodplain UCLs (mg/kg) UCLs (mg/kg) Imminent Hazard RC S-1 Imminent Hazard New England Environmental, Inc. PP13-Levee Table 5-1R PP13 Levee
Table 5-2R Table 5-2R Laboratory Results -PP13 Metals in Sediment Former Cutlery Raceway Northampton, MA Upstream At Dam Below Dam Downstream Regulatory Standards Sample I.D.: Sample
Depth: Sed-1 Sed-2 Sed-3 SP16 0-1' DEP Sed-1 DEP Sed-1 Sed-5 Sed-6 DEP Sed-2 DEP Sed-2 DEP Sed-3 DEP Sed-3 Sed-4 Method 1 Standard UCLs (mg/kg) Sampling Date: 1/16/01 1/16/01 1/16/01
6/26/02 8/7/00 12/2/11 1/16/01 1/16/01 8/7/00 12/2/11 8/7/00 12/2/11 1/16/01 S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg) Silver BDL BDL BDL BDL BDL <1.62 BDL BDL BDL <1.51 BDL <1.40 BDL
NBL 100 100 100 100 NSL 2,000 Arsenic 4.53 BDL BDL BDL BDL <1.62 16 9.60 BDL <1.51 BDL <1.40 BDL 33 20 20 20 20 40 200 Barium na na na na na 18.5 na na na 21.9 na 15.5 na NBL 1000 1000
1000 1000 NSL 1 0,000 Beryllium na na na BDL 0.20 <0.541 na na BDL <0.505 BDL <0.465 na NBL 100 100 100 100 NSL 2000 Cadmium BDL BDL BDL BDL 5.50 0.563 6.02 BDL 0.30 0.651 0.28 0.489
BDL 5 2 2 2 2 60 300 Chromium (III) 10.50 5.42 5.26 6.84 23.70 40.8 67.20 71.70 51 82.4 18 43.5 12.0 110 110 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper na na na 34.7 48.0
na na na 90 na 60 na na 150 1,000 NSL NSL NSL NSL NSL Mercury BDL BDL BDL BDL BDL <0.0302 0.47 BDL 0.08 <0.0324 0.11 <0.0442 BDL 0.18 20 20 20 20 300 300 Nickel na na na 14 5.90 202
na na 88 216 25 74.2 na 49 20 20 20 20 NSL 7,000 Lead 13.20 9.92 8.52 14.9 10.0 16.8 66.50 57.30 18 25.6 16 23.2 12.2 130 300 300 300 300 NSL 3,000 Antimony na na na BDL BDL <5.41 na
na 2.40 <5.05 0.90 <4.65 na NBL 20 20 20 20 NSL 300 Selenium BDL BDL BDL BDL BDL <1.62 9.43 BDL BDL <1.51 BDL <1.40 BDL NBL 400 400 400 400 NSL 8,000 Vanadium na na na na na <3.25 na
na na <3.03 na <2.79 na NBL 600 600 600 600 NSL 1 0,000 Thallium na na na BDL BDL 12.1 na na BDL 15.2 BDL 10.0 na NBL 8 8 8 8 NSL 800 Zinc na na na 63.1 40.0 61.6 na na 53 64.7 144 58.8
na 460 2500 2500 2500 2500 NSL 10,000 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. 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. 9 -Shaded Rose -Exceeds TEC Benchmark (MassDEP, 2006) Imminent Hazard TEC9 Benchmarks Under Stone Retaining Wall -along Levee RC S-1 Interior Drainage Wetland
Within Raceway Near MW-4 Near MW-3 New England Environmental, Inc. 5-PP13-Sediment Table 5-2R PP13 Sediment
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 Reference Weight Slope Factor Unit Risk Slope Factor of Study Information Compound name (mg/(kg*d))-1
(ug/m3)-1 (mg/(kg*d))-1 Evidence Extractable Petroleum Hydrocarbons C9-C18 Aliphatics none none none DEP08 NA C19-C36 Aliphatics none none none DEP08 NA C11-C22 Aromatics none none none
DEP08 NA 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: EPH = Extractable Petroleum Hydrocarbons mg/kg = milligrams per kilogram d = day ug = micrograms m3
= cubic meters RfD = Reference Dose RfC = Reference Concentration MassDEP = Massachusetts Department of Environmental Protection USEPA = United States Environmental Protection Agency
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, 2012. IRIS -Integrated Risk Information System.
February 2012. TOXval0212 2/29/2012
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) Reference Oral; Inhalation Oral; Inhalation Extractable Petroleum Hydrocarbons C9-C18 Aliphatics
1.0E-01 1.0E+00 DEP08 2.0E+02 6.0E+02 DEP08 Based on toxicity information for dearomatized C9-C17 aliphatic fractions Hepatic and hematological; Neurotoxicity C19-C36 Aliphatics 2.0E+00
6.0E+00 DEP08 NA NA DEP08 RfD based on eicosane as a reference compound Liver granuloma; NA C11-C22 Aromatics 3.0E-02 3.0E-01 DEP08 5.0E+01 5.0E+02 DEP08 RfD based on toxicity information
for pyrene; RfC based on aromatic mixtures Nephrotoxicity; Body weight reduction, hepatic, renal and developmental effects 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: EPH = Extractable Petroleum Hydrocarbons mg/kg = milligrams per kilogram d = day ug = micrograms m3 = cubic meters RfD = Reference
Dose RfC = Reference Concentration MassDEP = Massachusetts Department of Environmental Protection USEPA = United States Environmental Protection Agency 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, 2012. IRIS -Integrated Risk Information System. February 2012. TOXval0212
2/29/2012
Page 1 of 1 Ingestion Soil Dermal Soil Compound Name Carcinogen Non-Carcinogen Carcinogen Non-Carcinogen Extractable Petroleum Hydrocarbons C9-C18 Aliphatics NC 1 NC 0.5 C19-C36 Aliphatics
NC 1 NC 0.1 C11-C22 Aromatics NC 0.36 NC 0.1 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 2/29/2012
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 Exposure Assumptions and Equations for Recreational User -Incidental Ingestion of and Dermal Contact with Soil Park Visitor -Soil: Table PS-2 Vlookup Version v0808 Equations
to Calculate Cancer Risk for Visitor (Age 1-31 years) Parameter Value Units CSF OHM specific (mg/kg-day)-1 Cancer Risk from Ingestion LADD age/OHM specific mg/kg-day [OHM]soil OHM specific
mg/kg ELCRing = LADDing(1-31) * CSF IR(1-8) 100 mg/day IR(8-15) 50 mg/day LADDing (1-31) = LADDing (1-8) + LADDing (8-15) + LADDing (15-31) IR(15-31) 50 mg/day RAFc-ing OHM specific
dimensionless [OHM]soil * IRx * RAFc-ing * EFing * ED * EPx * C RAFc-derm OHM specific dimensionless BWx * APlifetime EFing,derm 0.247 event/day ED 1 day/event Cancer Risk from Dermal
Absorption EP(1-8) 7 years EP(8-15) 7 years ELCRderm= LADDderm * CSF EP(15-31) 16 years C 0.000001 kg/mg LADDderm (1-31) = LADDderm (1-8) + LADDderm (8-15) + LADDderm (15-31) BW(1-8)
17.0 kg BW(8-15) 39.9 kg [OHM]soil * SAx * RAFc-derm * SAFx * EFderm * ED * EPx * C BW(15-31) 58.7 kg kg BWx * APlifetime AP(lifetime) 70 years SA(1-8) 2431 cm2/day SA(8-15) 4427 cm2/day
SA(15-31) 5653 cm2/day SAF(1-8) 0.35 mg/cm2 SAF(8-15) 0.14 mg/cm2 SAF(15-31) 0.13 mg/cm2 LADDing (age group x) = LADDderm(age group x) = Page 1 of 4 sf06ps setup C Eq 2/29/2012
Table 10 (cont'd.) Exposure Assumptions and Equations for Recreational User -Incidental Ingestion of and Dermal Contact with Soil Park Visitor -Soil: Table PS-3 Vlookup Version v0808
Equations to Calculate Chronic Noncancer Risk for Visitor (Age 1-8 years) Chronic Noncancer Risk from Ingestion Parameter Value Units RfD OHM specific mg/kg-day ADDing ADD OHM specific
mg/kg-day RfD [OHM]soil OHM specific mg/kg IR 100 mg/day [OHM]soil * IR * RAFnc-ing * EFing * ED * EP * C RAFnc-ing OHM specific dimensionless BW * AP RAFnc-derm OHM specific dimensionless
EFing,derm 0.247 event/day Chronic Noncancer Risk from Dermal Absorption EFcyanide 1.00 event/day ED 1 day/event ADDing,derm EP 7 years RfD EPcyanide 1 day C 0.000001 kg/mg [OHM]soil
* SA * RAFnc-derm * SAF * EFderm * ED * EP * C BW 17.0 kg BW * AP AP 7 year APcyanide 1 day SA 2431 cm2/day SAF 0.35 mg/cm2 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. HQing = ADDing = ADDderm = HQderm = Page 2 of 4 sf06ps setup cNC Eq 2/29/2012
Table 10 (cont'd.) Exposure Assumptions and Equations for Recreational User -Incidental Ingestion of and Dermal Contact with Soil Park Visitor -Soil: Table PS-4 Vlookup Version v0808
Equations to Calculate Subchronic Noncancer Risk for Visitor (Age 1-2 years) Subchronic Noncancer Risk from Ingestion Parameter Value Units RfD OHM specific mg/kg-day ADDing ADD OHM
specific mg/kg-day RfDsubchronic [OHM]soil OHM specific mg/kg IR 100 mg/day [OHM]soil * IR * RAFnc-ing * EFing * ED * EP * C RAFnc-ing OHM specific dimensionless BW * AP RAFnc-derm OHM
specific dimensionless EFing,derm 0.428 event/day Subchronic Noncancer Risk from Dermal Absorption EFcyanide 1.00 event/day ED 1 day/event ADDderm EP 0.577 years RfDsubchronic EPcyanide
1 day C 0.000001 kg/mg [OHM]soil * SA * RAFnc-derm * SAF * EFderm * ED * EP * C BW 10.7 kg BW * AP AP 0.577 year APcyanide 1 day SA 1670 cm2/day SAF 0.35 mg/cm2 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. HQing = ADDing = ADDderm = HQderm = Page 3 of 4 sf06ps setup scNC Eq 2/29/2012
Table 10 (cont'd.) Exposure Assumptions and Equations for Recreational User -Incidental Ingestion of and Dermal Contact with Soil Park Visitor -Soil: Table PS-5 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) CSF -Cancer
Slope Factor chemical specific (mg/kg-day)-1 see Table PS-6 LADD -Lifetime Average Daily Dose chemical specific mg/kg-day Pathway specific HQ -Hazard Quotient chemical specific dimensionless
Pathway specific (ing =ingestion, derm=dermal) RfD -Reference Dose chemical specific mg/kg-day see Table PS-6 ADD -Average Daily Dose chemical specific mg/kg-day Pathway specific EPC
-Exposure Point Concentration chemical specific mg/kg IR(1-2) -Soil Ingestion Rate for age group 1-2 100 mg/day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Appendix
Table B-3. IR(1-8) -Soil Ingestion Rate for age group 1-8 100 mg/day Ibid IR(8-15) -Soil Ingestion Rate for age group 8-15 50 mg/day Ibid IR(15-31) -Soil Ingestion Rate for age group
15-31 50 mg/day Ibid RAFc -Relative Absorption Factor for Cancer Effects chemical specific dimensionless Adjusts estimated dose to conform to the revelant CSF. See Table PS-6 RAFNC -Relative
Absorption Factor for non-Cancer Effects chemical specific dimensionless Adjusts estimated dose to conform to the revelant RfD. See Table PS-6 EFsubchronic -Exposure Frequency for subchronic
exposure 0.428 event/day 3 events/week EFchronic,lifetime -Exposure Frequency for chronic or lifetime exposure 0.247 event/day 3 events/week, 30 weeks/year EFcyanide -Exposure Frequency
for cyanide exposure 1.00 event/day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Page 5-5. ED -Exposure Duration 1 day/event EP(1-2) -Exposure Period for age group
1-2 0.577 years 30 weeks EP(1-8) -Exposure Period for age group 1-8 7 years EP(8-15) -Exposure Period for age group 8-15 7 years EP(15-31) -Exposure Period for age group 15-31 16 years
EPcyanide -Exposure period for cyanide exposure 1 day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Page 5-5. BW(1-2) -Body Weight for age group 1-2 10.7 kg U.S. EPA.
1997. Exposure Factors Handbook. Table 7-7, females. BW(1-8) -Body Weight for age group 1-8 17.0 kg Ibid BW(8-15) -Body Weight for age group 8-15 39.9 kg Ibid BW(15-31) -Body Weight
for age group 15-31 58.7 kg Ibid APsubchronic -Averaging Period for subchronic noncancer 0.577 years 30 weeks APchronic -Averaging Period for chronic noncancer 7 years APlifetime -Averaging
Period for cancer/lifetime 70 years APcyanide -Averaging period for assessing cyanide exposure 1 day MADEP. 1995. Guidance for Disposal Site Risk Characterization. Page 5-5. SA(1-2)
-Surface Area for age group 1-2 1670 cm2/day 50th percentile of face (1/3 head), forearms, hands, lower legs, and feet for females. MADEP 1995 Guidance for Disposal Site Risk Characterization,
Appendix Table B-2. SA(1-8) -Surface Area for age group 1-8 2431 cm2 /day Ibid SA(8-15) -Surface Area for age group 8-15 4427 cm2 /day Ibid SA(15-31) -Surface Area for age group 15-31
5653 cm2 /day Ibid SAF(1-2) -Surface Adherence Factor for age group 1-2 0.35 mgsoil /cm2 All SAFs developed for ShortForm according to procedure outlined in MADEP Technical Update: SAF(1-8)
-Surface Adherence Factor for age group 1-8 0.35 mgsoil /cm2 Weighted Skin-Soil Adherence Factors, April 2002 SAF(8-15) -Surface Adherence Factor for age group 8-15 0.14 mgsoil /cm2
SAF(15-31) -Surface Adherence Factor for age group 15-31 0.13 mgsoil /cm2 Page 4 of 4 sf06ps setup Exp 2/29/2012
Table 11 -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 Response to DEP Comments Nov 2011\Method 3\GW
EPCsSheet1 (2)
Table 12 -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 4 Soil EPCs Parking Lot AOC-1 SA-1 to SA-5 Excav 2/29/2012
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 12 (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 4 Soil EPCs Parking Lot AOC-1 SA-1 to SA-5 Excav 2/29/2012
Table 12 (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-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 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 2.59 BRL 16.1 4.07 5.32 1.76 1.43 BRL 2.76 1.46 4.5 100 100 100
100 NSL 2,000 Arsenic 16.6 9.16 BRL BRL BRL BRL BRL BRL BRL 76.6 26 20 20 20 20 40 200 Beryllium 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 1.37 0.599 2.49 1.67 1.44 0.806 1.65 BRL 0.927 0.814 1.3 2 2 2 2 60 300 Chromium (III) 2590 274 2230 3060 3760 2740 3490 4560
1760 877 2413 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 124 45 1310 163 133 66.9 200 79.5 197 513 226 1,000 NSL NSL NSL NSL NSL Mercury 0.627 0.193 0.719 0.434 0.221 0.284
0.583 0.191 0.242 0.203 1.8 20 20 20 20 300 300 Nickel 89 38 2650 222 192 85.9 184 136 282 736 300 20 20 20 20 NSL 7,000 Lead 567 286 1560 1020 1190 915 312 475 429 432 832 300 300 300
300 NSL 3,000 Antimony 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 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 8 8 8 8 NSL 800 Zinc 464 66.4 574 506 781 351 315 247 162 117 361 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 4 Soil
EPCs AOC-1 CB Area PP13-CB 2/29/2012
Table 12 (cont'd.) Soil Exposure Point Concentrations for AOC-1 Floodplain Riverbank Area Former Cutlery Raceway, Northampton, MA RTN #1-13320 Regulatory Standards Sample I.D.: Sample
Depth: CB-5-SED 0-3" CB-11-SED 0-3" CB-14-SED 0-3" CB-16-SED 0-3" CB-17 0-3" EPCs 0-3" Method 1 Standard Sampling Date: 6/21/05 6/21/05 6/21/05 6/9/06 6/9/06 S-1/GW-1 S-1/GW-2 S-1/GW-3
Metals (mg/Kg) t,br t,br br Silver BRL 12.5 BRL BRL 2.69 7.6 100 100 100 100 NSL 2,000 Arsenic BRL BRL BRL 2.91 18.3 10.6 20 20 20 20 40 200 Beryllium BRL BRL 0.48 0.437 0.569 0.50 100
100 100 100 NSL 2000 Cadmium BRL BRL BRL 0.313 0.847 0.58 2 2 2 2 60 300 Chromium (III) 89.5 1130 76.8 34 2720 810 1000/30 1000/30 1000/30 1000/30 1000 10,000/2,000 Copper 142 315 83.9
162 138 168 1,000 NSL NSL NSL NSL NSL Mercury 0.368 6.22 BRL 0.304 0.198 1.77 20 20 20 20 300 300 Nickel 96.3 545 45.6 185 115 197 20 20 20 20 NSL 7,000 Lead 128 329 81.3 54.3 610 241
300 300 300 300 NSL 3,000 Antimony BRL BRL BRL BRL BRL BRL 20 20 20 20 NSL 300 Selenium BRL BRL BRL BRL BRL BRL BRL 400 400 400 400 NSL 8,000 Thallium BRL BRL BRL BRL BRL BRL 8 8 8 8
NSL 800 Zinc 129 281 101 79.8 105 139 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 DetEction 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) RC S-1 Imminent Hazard Page 4 of 4 Soil EPCs Floodplain
Table 13 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 Aliphatics C9 to C18 1.9E+02 2.3E-04 1.2E-03 6.1E-06 1.2E-05 1.4E-03 Aliphatics
C19 to C36 4.3E+03 8.8E-04 8.9E-04 2.3E-05 1.8E-03 Aromatics C11 to C22 6.8E+02 1.0E-03 2.8E-03 2.6E-05 5.1E-05 3.9E-03 Sheet: EPCs
TABLE 13 (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 2/29/2012
TABLE 13 (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 2/29/2012
Table 13 (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 4.5E+00 1.1E-03 2.8E-03 2.9E-05 1.2E-03
5.1E-03 Arsenic 2.6E+01 3.4E-07 1.0E-07 8.9E-09 3.0E-08 4.8E-07 1.1E-01 3.2E-02 2.8E-03 3.9E-01 5.3E-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
1.3E+00 6.2E-10 6.2E-10 3.2E-03 4.5E-03 8.3E-05 2.4E-03 1.0E-02 Chromium(III) 2.4E+03 2.0E-03 8.0E-8.0E-04 5.1E-05 3.0E-01 3.0E-01 Mercury 1.8E+00 7.4E-03 3.7E-03 1.9E-04 2.2E-04 1.2E-02
Nickel 3.0E+02 3.8E-08 3.8E-08 1.8E-02 6.5E-02 4.8E-04 1.1E-02 9.5E-02 Lead 8.3E+02 6.8E-01 8.3E-02 1.8E-02 3.1E-02 8.1E-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 3.6E+02 1.5E-03 3.0E-04 3.8E-05 9.6E-03 1.1E-02 Polychlorinated biphenyls (PCBs) ND Aliphatics C9 to C18 1.9E+02 2.3E-04
1.2E-03 6.1E-06 1.2E-05 1.4E-03 Aliphatics C19 to C36 4.3E+03 8.8E-04 8.9E-04 2.3E-05 1.8E-03 Aromatics C11 to C22 6.8E+02 1.0E-03 2.8E-03 2.6E-05 5.1E-05 3.9E-03 sf08cw AOC-1 CB Area
EPCs 2/29/2012
TABLE 13 (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 226 1 1.23E-06 2.8E-04 4.0E-02 6.9E-03 Subtotal = 6.9E-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 2/29/2012
TABLE 13 (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 226 0.10 1.22E-05 2.8E-04 4.0E-02 6.9E-03 Subtotal = 6.9E-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 2/29/2012
Table 14 Calculation of Risk Estimates for Recreational User -Incidental Ingestion of and Dermal Contact with Soil Park Visitor -Soil: Table PS-1 ShortForm Version 06-06 Exposure Point
Concentration (EPC) Vlookup Version v0808 Based on Visitor Ages 1-31 (Cancer), 1-8 (Chronic Noncancer), and 1-2 (Subchronic Noncancer) ELCR (all chemicals) = 5E-06 Chronic HI (all chemicals)
= 4E-01 **Do not insert or delete any rows** Subchronic HI (all chemicals) = 1E+00 Click on empty cell below and select OHM using arrow. Oil or EPC Hazardous Material (mg/kg) ELCRingestion
ELCRdermal ELCRtotal HQing HQderm HQtotal HQing HQderm HQtotal Silver 7.6E+00 2.2E-03 4.7E-03 6.9E-03 6.1E-03 8.9E-03 1.5E-02 Arsenic 1.1E+01 3.6E-06 1.1E-06 4.7E-06 5.1E-02 1.3E-02
6.4E-02 1.4E-01 2.5E-02 1.7E-01 Beryllium 5.0E-01 3.6E-04 9.3E-05 4.6E-04 4.0E-04 7.0E-05 4.7E-04 Cadmium 5.8E-01 1.7E-03 2.0E-03 3.7E-03 4.6E-03 3.8E-03 8.4E-03 Chromium(III) 8.1E+02
7.8E-04 2.7E-04 1.1E-03 2.2E-03 5.1E-04 2.7E-03 Mercury 1.8E+00 8.6E-03 3.6E-03 1.2E-02 2.4E-02 6.9E-03 3.0E-02 Nickel 2.0E+02 1.4E-02 4.3E-02 5.7E-02 3.9E-02 8.1E-02 1.2E-01 Lead 2.4E+02
2.3E-01 2.4E-02 2.6E-01 6.4E-01 4.5E-02 6.9E-01 Antimony ND Selenium ND Thallium ND Zinc 1.4E+02 6.7E-04 1.1E-04 7.9E-04 1.9E-03 2.2E-04 2.1E-03 Chronic Subchronic 1 of 1 Sheet: EPCs
Page 1 of 1 TABLE 15 SUMMARY OF HAZARD INDICES AND RISK ESTIMATES Receptor Hazard Index (HI) Excess Lifetime Site Area Exposure Pathway Subchronic Chronic 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 NC 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 Liver and Kidney (C9-18 Aliphatics, C19-C36 Aliphatics, C11-C22 Aromatics) 7E-03 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 NC 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 Liver and Kidney (C9-18 Aliphatics, C19-C36 Aliphatics,
C11-C22 Aromatics) 7E-03 Other (Beryllium, Cadmium, Chromium, Copper, Nickel, and Selenium) 4E-01 Recreational User AOC-1 Floodplain Riverbank Soil (0-3" bgs) Incidental Ingestion of
and Dermal Contact with Soil Total Screening HI: 1E+00* 4E-01 5E-06 Total Screening HI Segregated by Critical Effect: Skin (Silver and Arsenic) 2E-01 Central Nervous System (Lead and
Mercury) 7E-01 Blood (Antimony, Thallium, and Zinc) 2E-03 Other (Beryllium, Cadmium, Chromium, Copper, Nickel, and Selenium) 1E-01 MassDEP Risk Limits: 1E+00 1E-05 Notes: Bolded value
exceeds MassDEP risk limits. * Receptor conservatively evaluated is a child 1 to 2 years of age assumed to be exposed to soil for 156 days/year. NC -Not calculated, exposure period is
subchronic. RTN #1-13320 Former Cutlery Raceway, Northampton, MA risksum 2/29/2012
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 3/8/12 5028-02-03 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
LOCATION OF DATA RE: Revised RAO Statement Former Cutlery
Raceway 320-360 Riverside Drive RTN: #1-13320 Northampton, MA NON-WE-11-3A073 The data for this Appendix did not change from the original submittal, and can be found in the same numbered
Appendix in that document.
APPENDIX H Public Involvement Letters
March 14, 2012 Board of Health City of Northampton 210 Main Street Northampton, MA 01060 RE: Revised Class A-3 & Class C-1 RAO Statements Former Cutlery Raceway 320-360 Riverside Drive
Northampton, MA RTN: #1-13320 Dear Board of Health, In accordance with the requirements of the Massachusetts Contingency Plan (MCP), New England Environmental, Inc. is writing to notify
you, as the Chair of the Board of Health, that a Revised Class A-3 Response Action Outcome (RAO-P) Statement for the portion of the Site including the Cutlery on Lot #32 and a portion
of the Home Valley Improvement property on Lot #76 and a Revised Class C-1 RAO-P Statement for the undeveloped Lot #77 portion of the Site has been completed for the above-referenced
Site. All work was conducted in response to a Notice of Audit Findings/Notice of Non-compliance (NOAF-NON) issued by the MassDEP on November 9, 2011. The RAO Statements have been submitted
to the MassDEP Western Regional Office in Springfield, Massachusetts and to the Planning Department office for the City of Northampton. Copies of the report can be reviewed at these
offices. The RAO Statements are also available at the MassDEP’s web site: http://db.state.ma.us/dep/cleanup/sites/search.asp using the RTN above in the search function. The Revised RAO
Statements describe soil, sediment, and groundwater investigation activities at the Site as well as soil remediation and riverbank stabilization efforts. A revised Method 3 Risk Assessment
is included in the Revised RAO Statements. The Activity and Use Limitations (AULs) placed on the property in February 2011 remain in place and unchanged as a result of the revised reports.
Should you have questions regarding this matter, please do not hesitate to contact us at 413-256-0202. Sincerely, NEW ENGLAND ENVIRONMENTAL, INC. Wm. Lyons Witten, PG, LSP Alison Holmes
Division Manager/Hydrogeologist Project Geologist cc: Northampton: Mayor’s Office Planning Department – (Full Report) Robert Cummings, CFP Properties LLC, 320 Riverside Dr., Northampton,
MA 01060 (cc) Samuel Burton and Susan E. Rees, 320 Riverside Drive, Northampton, MA 01060 (cc) Nelson Shifflett, Firehouse Realty Corp., 114 Shelburne Falls Rd., Conway, MA 01341 (cc)
Alan Verson, Cutlery Building Associates, 56 Main Street, Northampton, MA 01060 (cc)
March 14, 2012 Mayor’s Office City of Northampton 210 Main Street Northampton, MA 01060 RE: Revised Class A-3 & Class C-1 RAO Statements Former Cutlery Raceway 320-360 Riverside Drive
Northampton, MA RTN: #1-13320 Dear Mayor’s Office, In accordance with the requirements of the Massachusetts Contingency Plan (MCP), New England Environmental, Inc. is writing to notify
you, as the Chair of the Board of Health, that a Revised Class A-3 Response Action Outcome (RAO-P) Statement for the portion of the Site including the Cutlery on Lot #32 and a portion
of the Home Valley Improvement property on Lot #76 and a Revised Class C-1 RAO-P Statement for the undeveloped Lot #77 portion of the Site has been completed for the above-referenced
Site. All work was conducted in response to a Notice of Audit Findings/Notice of Non-compliance (NOAF-NON) issued by the MassDEP on November 9, 2011. The RAO Statements have been submitted
to the MassDEP Western Regional Office in Springfield, Massachusetts and to the Planning Department office for the City of Northampton. Copies of the report can be reviewed at these
offices. The RAO Statements are also available at the MassDEP’s web site: http://db.state.ma.us/dep/cleanup/sites/search.asp using the RTN above in the search function. The Revised RAO
Statements describe soil, sediment, and groundwater investigation activities at the Site as well as soil remediation and riverbank stabilization efforts. A revised Method 3 Risk Assessment
is included in the Revised RAO Statements. The Activity and Use Limitations (AULs) placed on the property in February 2011 remain in place and unchanged as a result of the revised reports.
Should you have questions regarding this matter, please do not hesitate to contact us at 413-256-0202. Sincerely, NEW ENGLAND ENVIRONMENTAL, INC. Wm. Lyons Witten, PG, LSP Alison Holmes
Division Manager/Hydrogeologist Project Geologist cc: Northampton: Board of Health Planning Department – (Full Report) Robert Cummings, CFP Properties LLC, 320 Riverside Dr., Northampton,
MA 01060 (cc) Samuel Burton and Susan E. Rees, 320 Riverside Drive, Northampton, MA 01060 (cc) Nelson Shifflett, Firehouse Realty Corp., 114 Shelburne Falls Rd., Conway, MA 01341 (cc)
Alan Verson, Cutlery Building Associates, 56 Main Street, Northampton, MA 01060 (cc)
March 14, 2012 Planning Office City of Northampton 210 Main Street Northampton, MA 01060 RE: Revised Class A-3 & Class C-1 RAO Statements Former Cutlery Raceway 320-360 Riverside Drive
Northampton, MA RTN: #1-13320 Dear Planning Office, In accordance with the requirements of the Massachusetts Contingency Plan (MCP), New England Environmental, Inc. is writing to notify
you, as the Chair of the Board of Health, that a Revised Class A-3 Response Action Outcome (RAO-P) Statement for the portion of the Site including the Cutlery on Lot #32 and a portion
of the Home Valley Improvement property on Lot #76 and a Revised Class C-1 RAO-P Statement for the undeveloped Lot #77 portion of the Site has been completed for the above-referenced
Site. All work was conducted in response to a Notice of Audit Findings/Notice of Non-compliance (NOAF-NON) issued by the MassDEP on November 9, 2011. The RAO Statements have been submitted
to the MassDEP Western Regional Office in Springfield, Massachusetts and to the Planning Department office for the City of Northampton. Electronic copies of the original submittal and
the Revised RAO Statements are included on the attached CD for your files. The RAO Statements are also available at the MassDEP’s web site: http://db.state.ma.us/dep/cleanup/sites/search.asp
using the RTN above in the search function. The Revised RAO Statements describe soil, sediment, and groundwater investigation activities at the Site as well as soil remediation and riverbank
stabilization efforts. A revised Method 3 Risk Assessment is included in the Revised RAO Statements. The Activity and Use Limitations (AULs) placed on the property in February 2011 remain
in place and unchanged as a result of the revised reports. Should you have questions regarding this matter, please do not hesitate to contact us at 413-256-0202. Sincerely, New England
Environmental, Inc. Wm. Lyons Witten, PG, LSP Alison Holmes Division Manager/Hydrogeologist Project Geologist cc: Northampton: Mayor’s Office Board of Health Robert Cummings, CFP Properties
LLC, 320 Riverside Dr., Northampton, MA 01060 (cc) Samuel Burton and Susan E. Rees, 320 Riverside Drive, Northampton, MA 01060 (cc) Nelson Shifflett, Firehouse Realty Corp., 114 Shelburne
Falls Rd., Conway, MA 01341 (cc) Alan Verson, Cutlery Building Associates, 56 Main Street, Northampton, MA 01060 (cc)
New England Environmental Environmental Consulting 15 Research Drive Amherst MA 01002 (p) 413.658.2056 (f) 413. 256. 1092 www.neeinc.com