February 25, 2011 Page 1 of 12 MEMORANDUM TO

MEMORANDUM TO: Windham Regional Commission Attn. Susan McMahon, Associate Director FROM: Alan Liptak, CPG, KAS, Inc. DATE: February 25, 2011 RE: Phase I Environmental Site Assessment Update Mill Street Turnaround, Bellows Falls, Vermont KAS, Inc. of Williston, Vermont (KAS) conducted a Phase I Environmental Site Assessment (ESA) update of a portion of land and premises at 20-24 Mill Street in Bellows Falls, Vermont (herein referred to as “the property” or “Mill Street Turnaround property”; see Attachment 1, Site Location Map1 and Attachment 2, Site Map2). This assessment was conducted for the Windham Regional Commission (WRC) of Brattleboro, Vermont, herein referred to as client. The owner of record of the property as of the date of this report is the Bellows Falls Historical Society (BFHS), herein referred to as owner. The user of this assessment, e.g., the entity deriving Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Bona Fide Prospective Purchaser (BFPP) exclusion, is the Bellows Falls Village Corporation. At the request of the WRC, KAS conducted necessary tasks to update a previous ASTM E 1527-05 Phase I ESA for the referenced property. 3 KAS reviewed the previous Phase I ESA report and has updated the following aspects of it: Owner and user interviews Database report Site visit Additional historical and technical reviews Conclusions presented herein are not materially different than those presented in the referenced Phase I ESA report. 1 USGS, 1985. 2 DiBernardo Associates, 2009. 3 Nobis Engineering, February 2010. February 25, 2011 Page 1 of 12 General Description The property is a proposed 0.5 acre parcel that will be created via subdivision concurrent with a pending ownership transaction. The property is presently the southern tip of an 8+/- acre parcel owned by the BFHS. As of February 2011 there were no structures on the property. The property was in general use for vehicle parking and storage of a steel rolloff container; these uses are believed to be associated with the Bellows Falls Wastewater Treatment Facility (WWTF). Mill Street crosses the property from north to south, and there is a Green Mountain Power (GMP) utility line crossing the property parallel to Mill Street. A village stormwater easement also crosses the property, and stormwater is conveyed via culvert to a stone lined ditch that leads to the Connecticut River. A site location map4 and a site map5 are included as Attachments 1 and 2, respectively. Owner and User Interviews KAS interviewed Mr. Stewart Read, Treasurer of the Bellows Falls Historical Society (BFHS; “owner”), on February 22, 2011 in person in Bellows Falls. An interview form is included in Attachment 3. Mr. Read stated the following: • The BFHS is the current property owner. A pending transaction will subdivide and transfer the 0.5 acre property to the Bellows Falls Village corporation. • There is a notice to the Town of Rockingham land records filed at V. 315, Page 428, date of recording October 21, 2008, regarding on site contamination.6 There is a utility easement for overhead electrical lines and the village holds a stormwater easement for buried piping and lined ditch for conveyance of stormwater. • The property is part of an equal swap of land with the Bellows Falls Village Corporation. No purchase price has been negotiated and no reduction in purchase price for real or perceived contamination has been made. • The past uses of the property include unimproved riverfront land until the 1920’s when the New England Power Plant construction took place. Mr. Read does not believe that the bulk of the 4 USGS, 1985. 5 DiBernardo Associates, 2009. 6 Nobis, 2010, Appendix E. February 25, 2011 Page 2 of 12 demolished mill buildings were disposed of on site; he believes that most of these buildings were sold off and hauled away. • Mr. Read is not aware of use of specific chemicals on the property except for the possible use of herbicides in the utility corridor. • The property is known to be contaminated with PAH, dioxin, VOCs and metals. No environmental cleanups are known to have taken place. KAS contacted Mr. Rob Wheeler, operator of the Bellows Falls WWTF and a representative of the document user, on February 22, 2011, via telephone. Mr. Wheeler referred KAS to an interview conducted within the context of the prior Phase I ESA report, and stated that there have been no changes to conclusions from then and that no hazardous materials or petroleum products have been used, stored or disposed of on the turnaround property. Database report KAS contracted with Environmental FirstSearch Technology Corporation to perform a review of state and federal regulatory records during this Phase I ESA update. A copy of the FirstSearch Search Report is included in Attachment 4. A summary of the pertinent data contained in the First Search report is presented below. Property The property is currently part of the BFHS property which is included in the First Search list of properties, variously identified the former White Mountain Paper Company, the Penta and TLR properties, in the following categories: Federal and State Brownfields; CERCLA NFRAP (No Further Remedial Action Proposed); leaking UST site (inactive); and, active state hazardous site. Generally, historic paper making operations including USTs have resulted in soil and groundwater contamination that has been investigated and is in the process of being mitigated. Other Sites The Bellows Falls Wastewater Treatment Facility (WWTF) property, which is adjacent to the Turnaround property to the south, is included in the First Search list of properties in the following categories: RCRA Generator; reported spill site; registered underground storage tank (UST) property; and, active state hazardous site. The WWTF listings February 25, 2011 Page 3 of 12 pertain to generation of small quantities of hazardous waste, a chlorine spill which was adequately contained, three, 2,000-gallon registered active USTs, and detection of dioxin in soils during a headworks construction project. Properties to the west, including Riverview Apartments on Westminster Street, New England Telephone on Henry Street, Meatland on Westminster Street, Fleming Oil Shell on Westminster Street and the Rockingham Public Library, are included in the First Search list of properties in the following categories: Registered UST and leaking UST sites; State and Federal Brownfields; and, RCRA generator. Given the preponderance of sites in the vicinity many of which are potentially upgradient with respect to the probable direction of groundwater flow, there is some potential for an environmental impact to the property based on available data. Site Reconnaissance On February 22, 2011, Alan Liptak of KAS conducted a site reconnaissance to inspect the property for indications of environmental risks or hazardous conditions. A completed site inspection checklist is included in Attachment 5. KAS was accompanied by Stewart Read of the Bellows Falls Historical Society during the site reconnaissance. Photographs of the property are included in Attachment 6. The property was covered in 1-2 feet of snow at the time of the reconnaissance making direct observation of the ground surface not possible except where plowed. The property was being used for vehicle parking, and for storage of a 30 cubic yard rolloff container typical of those used for trash. The utility lines and poles were observed to run north to south across the property, parallel to Mill Street. A stormwater culvert and drainage ditch were observed oriented in a northwest-southeast orientation crossing the property. No evidence of the use, storage, or disposal of petroleum products or hazardous materials was noted on the property. No tanks, drums, pits, ponds or lagoons were noted aside from the aforementioned stormwater drainage system. There were no buildings or other structures noted. February 25, 2011 Page 4 of 12 In comparing the on site observations made in February 2011 with the photographs presented in the previous Phase I ESA for the Turnaround property, there is no suggestion that recent environmental conditions have developed since those photographs were taken which would alter the findings presented in that document. Historical Research KAS performed additional historical research pertaining to the property. Documents were obtained from the Bellows Falls Historical Society, the Vermont Law Library in Montpelier, the University of New Hampshire on line collections program, and the Sanborn map collection. Copies of available documents are included in Attachment 7. Historic Drawings and Photographs KAS reviewed historic drawings and photographs depicting the property from 1855, 1886, 1926-1927, 1940, 1953, 1962, 1999 and 2009. A birds eye view drawing of the property and surroundings from June 1855 depicts the property as a sand marsh along the western bank of the Connecticut River. Property development to the north included industrial facilities. The village was located to the west. 7 An 1886 drawing of the property and surroundings shows the property as a sand marsh with brush growth and general flood plain characteristics. 8 A ground photograph from late 1926 or early 1927 depicts the construction of the dam raceway and construction of a large mound of blasted soil and rock in the location of the adjacent Poet’s Seat. 9 Background development is residential and there appears to be industrial development in the foreground. An aerial photograph taken from the cover of the 1940 town report depicts the property as a wooded parcel between the railroad tracks and the adjacent mound. Little surrounding development is noted. 10 7 L.H. Bradford & Sons, 1855. 8 L.R. Burleigh, 1886. 9 BFHS, 1926. 10 Town of Rockingham, 1940. February 25, 2011 Page 5 of 12 An aerial photograph taken in 1953 is similar to the 1940 photograph.11 An aerial photograph taken in 1962 depicts the property similar to the 1940 and 1953 photographs. 12 Mill Street is visible in this photograph.

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