Dear Mr. Mudholkar: the Site Under Investigation

Environmenta Engineering & Geotechnics, Inc. 149 Cross Street Winchester. Massachusetts 01890 {617) 721-1013 FAX 617 721 1001

September 16, 1991 Guilford Transportation Industries, Inc. Iron Horse Park North Billerica, MA. 01862-1688

RE: Laboratory Results MBTA Right of Way/ Perfection Auto Radiator Methuen, MA. EE&G Project No. 91.1016MA.

Dear Mr. Mudholkar:

In accordance with your request, Environmental Engineering & Geotechnics, Inc. (EE&G) has initiated preliminary investigations of the above referenced location. A preliminary site visit was conducted by EE&G personnel on July 19,1991.

This investigation was initiated based on a Notice of Responsibility/Request for Information issued by the Department of Environmental Protection dated January 25, 1991. Reference Appendix A. An October 11, 1989 letter prepared by Jet-Line Services, referenced subsurface contamination in the area of the drain discharge from the rear of the Perfection Auto Radiator facility. The letter contains information and manifests for the removal of contaminated soils in the area of the drain. This work was performed by Jet-Line for Perfection Auto Radiator. Refer to Appendix B for the Jet-Line Services letter. Perfection Auto/Methuen, Massachusetts Project No. 91.1016MA September 16, 1991 Page2 of 4

On July 29, 1991, EE&G personnel/Cleted sufcsoil samples onite slope in the area of Perfection Auto Radiator. Refer to Appendix C for sketch of approximate sample location. Soil samples were collected utilizing precleaned, dedicated stainless steel hand shovels. Samples were collected in 500 ml glass jars with TeflonTM lined lids for total petroleum hydrocarbon (TPH) analysis in accordance with Environmental Protection Agency (EPA) Method 418.1. Samples collected for volatile organic compound (VOC's) analysis in accordance with EPA Method 8240 were collected in 40 ml glass vials with Teflont m septa. All samples were labeled in the field, placed in coolers, chilled to 4* Celsius and shipped overnight mail to Groundwater Analytical Services of Buzzards Bay, Massachusetts for analysis.

Surface soil sample SS-1 was collected in the discharge area of a drain outfall exiting the foundation of Perfection Auto Radiator. It should be noted that a clear, sweet. smelling liquid was dripingfromthedran pipe at the time of the sample collection visit on July 29, 1991. Unfortunately there was not enough liquids being discharged to collect the required sample volume for laboratory analysis. Surface soil sample SS-1 had the sweet smelling odor characteristic of sgly.ents. Surface sample SS-2 was collected approximately 20 feet down the slope from SS-1. Surface sample SS-3 was collected another 20 feet down the slope from SS-2 at the base of the railroad ballast. Both samples 55-2 and SS-3 had the same sweet smelling odor as observed in SS-1.

Soil samples were screened for total organic vapors (TOV's) in the field with a Photovac Microtip Tm' photoionization detector in accordance with the Headspace Methodology attached in Appendix D. The measured TOY headspace for soil sample SS-1 was 1,750 parts per million (ppm), SS-2 was 1,243 ppm and SS-3 was 951 ppm.

The analytical laboratory results detected concentrations of the VOC's acetone (630 parts per billion [ppb]), 2-butanone (trace), toluene (22 ppb) and xylenes (21 ppb) in the sample SS-1. A TPH concentration of 19,000 ppm was detected in the sample for SS-1. All VOC's were below the reporting limit (BRL) of the analytical equipment for the sample SS-2. The TPH sample SS-2 detected a concentration of 380 ppm. No VOC's were detected in the VOC sample SS-3. A TPH concentration of 930 ppm was detected in the sample SS-3. Refer to Appendix E for complete laboratory results. Perfection Auto/Methuen, Massachusetts Project No. 91.1016MA September 16, 1991 _9_ Page 3 of 4 M

Based on this preliminary soil sample data and the history of contamination at the Perfection Auto Radiator facility, the source of the release appears to be the drain pipe in the rear of the Perfection Auto Radiator property. Soil sample SS-1 collected in the area of the drain pipe discharge had the highest concentration of contaminants. The contaminant concentrations decreased in the soil samples (SS-2 and SS-3) collected further away from the drain discharge.

Other areas of concern observed during this sample collection visit included Al's Auto Repair property located at the intersection of Oakland and Railroad Streets. It appears that oily surface runoff from auto repair discharges onto the railroad right of way. Additionally, automotive debris and other miscellaneous debris appear to have been discarded onto the right of way property at this location. DuG ersonnel observed Al's Auto personnel discading auto pans, oilstained sands and other debris onto the right of way. Al's Auto Repair was cleaning and sweeping the service bays and parking areas of its operation at this time.

Based on the results of this limited preliminary investigation, it appears that an off-site release may be impacting the railroad right of way. EE eonends-that-test-borings-and-groun4wter monitoring wells be installed and additional soil and groundwater samples be collected for laboratory analysis to provide additional information and confirm these conclusions.

It should be noted that all surficial investigations are inherently limited in the sense that conclusions are drawn and recommendations developed based on limited research information collected at State and local agencies and a visual review of the site and the surrounding area. Confirmation of the environmental acceptability can only be determined by a subsurface investigative program and chemical analysis of the site's soil and groundwater.

EE&G's professional services have been performed in accordance with acceptable environmental and geotechnical practices. EE&G is not responsible for independent conclusions, opinions or recommendations made by others based on the information contained herein.

The recommendations and conclusions provided herein are based solely on the scope of work conducted and the availability of information at this time. EE&G's opinions are based on professional expertise and no guarantee is implied herein. Perfection Auto/Methuen, M assachusetts Project No. 91.1016MA September 16, 1991 Page 4 of 4 6

If there are any questions and/or comments pertaining to the above mentioned project, please do not hesitate to contact EE&G's office; (Contact person: Thomas Williamson, Jr., telephone: (617) 721-1013).

Sincerely, Environmental Engineerin

omas W1 iamson, Jr Project Manager / Environmen Engineer

TW/tw Attachments ATTACHMENTS ATTACHMENT A

DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) NOTICE OF RESPONSIBILITY January 25, 1991 t/ t)'m/m/W7&Cea ttse J{7ac

* &z, 0a&a -/uoetta orzo

Daniel S. Greenbaun O / Commissioner (617) 935-2160 - January 25, 1991

Guilford Transportatinn RE: IETHUEN_ - ERB-N89-0750 Tudustries, Inc. RJil.oadRight--of-ay c/o Boston & Maine Railroad Request for Information Tron Horme Park Pursuant to M.G... c21E North Rillorica, MA 01862 ad 310 CMR 40.000

Attpi3n: Vinay Mudholkar, Chief Engineer

Dear ;Mr. Mudho kar:

M May .10, 1.989, D-:partment personnel investigated reports concerning the ree.Inas of waste oil from Perfection Auto.RadiatQ.r._at 39 Oakland Avenue, , -N11thqasac1usetts which abuts Massachusetts Bay Transportation Authorily's (MBTA) railroad right-of-way. Because it appeared that the railroadii bed had heel excavated at one time with the excavated materia) lije., soil, railroad ties) placed along the embankment, soil samples were collected out side I lie spil) area on the embankment to obtain background total petroleum hydrncarion (TPH) levels. The levels ranged from 270 parts per million (ppm) to 2,949 ppm TPH.

Crosquently you were instructed to enter into a contract with a cleanip contractir, approved by the Department to (1) perform necessary analyses of th wast material and make arrangements for its treatment/disposal; (2) perform analysis of the soil/water /groundwater impacted by the release to determuit contaminait conditions at the site after the initial response to the incident; and (3) submit a report of their findings for review by the Onpar t meit.

Prtsunnt to the Departmnt 's authority to perform information-gathering activities and its authority to. investigate, sample and inspect records,. rnlitumizs, eqtipjment, practices or property under M.G.h. C.21E Sections 2, 4 and 8, you are directed to provide to the Department, within seven (7) days of the dat. of this letter, an incident report to include the following nfornation:

(1) a brjitf account of why, how and where such release occurred; and

I Original Printed on Recycled Paper Pago 2

(2) an esimate, to the best of your knowledge, of the quantity of -il/hazardous material released; and

( -a brief description of all emergency remedial actions that have been and/or will be taken relative to such release: p]ease include fit-d screen:i.ng data and/or analytical data (soil/groundwater) describ:ing contaminant conditions at the site; and

(flaThbnratory results of soil/water samples taken from the "cleaned up" envirnnmenta] media impacted by the release; and

(sI phnIoropies of all waste manifests for the oil/hazardous material released; and

a detailed description and a timetable of measures you plan to imp Inemnt to prevent future recurrence of such incidents.

- This information is required by the Department in order to ascert ain that elr:i. p is proreed ing consistently with Departmental guidelinirs and slandards. for cleanip art ivit:ies. C.L. c.217 Section 4. noreover, the coll ect ion of such information constitutes an assessment action under Sections four ane, 'ight of the statute comprised of information-gathering activities neded h0 bIttJer evalulate the ieed for further emergency response actions at this sijt of a releasr- of oil/hazardous material (see 0.1.. c.21. Section 1, - assessl. n :").

Dcprnding on the information generated by the above work, the Departnent may reqwire additional investigations, studies and response actions in coiforincine with 310 CPIR 40.000.- If you fail to take these actions or if you fail in per form these tasks.in accordance with the standards of the Departmnt, the Departmel. may perform response actions in your stead and recover its costs from you in accordance with the provisiods described above.

Yoi are hereby notified that failure to respond to this letter in a timely w

Fuirherinore, if you refuse to provide the Department with the inf.ormaltion requested above, it may be necessary to order its production under the authority cif Section six of c.21E or to seize them pursuant to the authorily of Section eight thereof. In addition, refusing to provide the informa I:ion requestled could subject you to civil administrative penalties pirsmaiel In M.G.L. Chapter 21A.

Ti flcpartMe-nt I willing to consider any reasonable and appropriately posed claim nf colfi denti.al.ity relating to the requested records ht cannot P. i Cugt'ai-t o'iagnne Michaud if you have any questions, regarding thbs at Ir .. d ref.r to c:s number FRB-N89-0750.

Very truly yours,

10anne Michaud (Ivirra)omental5nginer

CA(~

Chief, Emergency Response Branch

ARC/.S:/ .- ce: mr BRSC, .Div. -of -Response & Remediation, One Winter St., Boston, MA 02108 -W bpn Rol V-:' twn Fir De pactment "PTA, 30 Park Plaza, Boston, MA 02116, Attu: Andrew Warren, Oirector of RHal kltate Management

0 I

* 6 Gwnwwauac/uetk Xoe r Daniel S. Greenbaum .0/&/ Commissioner December 6, 1990

Guilford Transproatation RE:METHUEN - ERB-N89-0750 Industries, Inc. Railroad Right-of-Way Rail Division c/o Boston & Maine Railroad Iron Horse Park North Billerica, MA 01862 NOTICE OF RESPONSIBILITY REQUEST FOR TECHNICAL INFORMATION PURSUANT TO M.G.L. CHAPTER 21E and 310 CMR 40.000

Attention: Vinay Mudholkar, Chief Engineer

Dear Mr. Mudholkar:

On May 10, 1989, Department personnel investigated reports concerning the. release of waste oil from Perfection Auto Radiator at 39 Oakland Avenue, Methuen, Massachusetts which abuts Massachusetts Bay Transportation Authority's (MBTA) railroad right- of-way. Because it -appeared that the railroad bed had been excavated at one time with the excavated material (i.e., soil, railroad ties) placed along the embankment, soil samples were .collecte.d outside the spill - area on the embankment to obtain background total petroleum hydrocarbon (TPH) levels. The levels ranged from 270 parts per million (ppm) to 2,945 ppft TPH.

Such incident is governed by The Massachusetts Contingency Plan (MCP), 310 CMR 40.000 and Chapter 21E of the General Laws of Massachusetts (hereinafter "M.G.L. Chapter 21E") , the Massachusetts Oil and Hazardous Material Release Prevention and Response Act, which was enacted on March 24, 1983.

Chapter, 21E and the MCP identify as responsible parties the current owner or operator of a site at which there has been a release or threat of release of oil or a hazardous material; the past owner or operator of a site where a release of hazardous material has occurred; any person who directly or indirectly arranged for the transport, disposal, storage or treatment of hazardous materials to or at such a site; and any person who caused or is legally responsible for a release or a threat of release of oil or a hazardous material at such a site. Such parties are liable without regard to fault; the nature of this liability is joint and.several. (M.G.L. Chapter 21E, Section 5a).

Original Prined on Recycled Paper Page 2 This letter is to inform you in writing that:

(1) The Department has determined that a release of petroleum materials has occurred at the subject site.

(2) Information available to the Department indicates that you. as operator of the subject site, are a liable and "responsible" party pursuant to Section 5(a) of Chapter 21E.

(3) Additional information is needed to better evaluate the need for further emergency response action at this site. Please, refer to page 3 for the requested information.

(4) should you fail to implement those actions deemed necessary by this Office, the Department may, pursuant to M.G.L. Chapter 21E, take or arrange for any and all necessary actions at the site.. If public funds are expended under such conditions, Chapter 21E, Section- 11 stipulates that the Attorney General of the Commonwealth of Massachusetts may initiate legal action against the responsible party(s) to recover all costs incurred by the Department in the assessment, containment, and removal of any release or threat of release of oil or hazardous materials.

(5) The liability of responsible parties in (4) above includes:

a. Administrative costs incurred by the Department in handling this matter. b. Interest charges on the total liability at the statutory rate of 12% compounded annually;

c. Treble costing (i.e., three (3) times the total amount-of-response costs the Department i'ncurs); and

d. All damages for the injury, destruction or loss of natural resources due to the release.

This liability constitutes a debt to the Commonwealth. The debt, together with interest, creates a lien on all your property in 'the Commonwealth. Lien placement will increase your administrative cost liability. This liability will further increase if the Department is required to go to court to recover its costs. Administrative and legal costs for simple spill cases which reach this stage total at least $3,300.00. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Commonwealth may recover that debt or any part of it in an action against you. You may also be liable under M.G.L. C.21E Section 11 for up to $100,000 in fines or penalties for each violation of C.21E as well as for additional penalties or damages pursuant to other statutes or common law. Page 3

Your acceptance of responsibility for such release means that: (1) You' will' enter into a contract with a cleanup contractor, approved by the Department to (a) perform the spill cleanup as deemed necessary by the Department; (b) perform necessary analyses of the waste material and make arrangements for its appropriate treatment/disposal; and (c) perform analysis of the soil/water/groundwa-ter -impacted by the release to determine contaminant conditions at the site after the inital response to the incident; and (d) submit a report of, their findings for review by the Department. And (2) you will pay for all response costs incurred by the Department due to such release.

Pursuant to the Department's authority to perform information- gathering activities -and its authority to investigate, sample and inspect records, conditions, equipment, practices or property under M.G.L. c. 21E Sections 2, 4 and 8, you are directed to provide to the Department, within seven (7) days. of the date of this letter, an incident report to include the follwoing information:

(1) a brief account of why, how and where such release occurred; and

(2) a brief description of all emergency remedial actions that have been and/or will be taken relative to such release; please include field screening data and/or analytical data (soil/groundwater) describing contaminant conditions at the site; and

(3) an estimate, to the best of your knowledge, of the quantity of oil/hazardous material released; and

(4) photocopies of all waste manifests for the oil/hazardous material released; and

(5) laboratory-results of soil/water samples taken from the "cleaned up" environmental media impacted by the release.

(6) a detailed description and a timetable of measures you plan to implement to prevent future recurrence of such incidents.

You are hereby notified that failure to respond to this letter -in. a., timely manner, is a violation of 310 CNR 40.008 and the submission of false and inaccurate information is a violation of 310 CMR 40.009 and 40.011. Any such violations may subject you to legal action including criminal prosecution, court-imposed civil penalties, administrative orders and/or civil administrative penalties assessed by the Department pursuant to M.G.L. Chapter 21A. . 0

Page 4

It is to your advantage to respond to this request for information in an adequate and timely manner, demonstrating that you have acted appropriately in taking necessary response actions relative to this release of oil and/or-hazardous materials.

Depending on the information generated by the above work, the Department may require additional investigations, studies and response actions in conformance with 310 CMR 40.000. If you fail to take these actions or if you fail to perform these tasks in accordance with the standards of the Department, the Department may perform response actions in your stead and recover its costs from you in accordance with the provisions described above.

Your response to the requested information and any further questions regarding this matter should be directed to Joanne Michaud 'at the letterhead address or 935-2106 and refer to case number ERB-N89-0750.

Very try yours,

Joanne Michaud onmketal Engineer

Anthon . G arciariello Section Chief Emergency Response

RJC/JM/ram

cc: DEP/BWSC, Div. of Response & Remediation, 1 Winter St., Boston, MA 02108 DEP/BWSC, Div. of Fiscal Mgmt./Cost Recovery, 1 Winter St., Boston, MA 02108 Methuen Board of Health Methuen Fire Department MBTA, 10 Park Plaza, Boston, MA 02116, Attn: Andrew Warren Director of Real Estate Management

Enclosures: (1) List of DEP-Licensed Spill Cleanup Contractors (2) DEP Policy #WSC-89-004: Minimum Standards for Analytical Data for Remedial Response Actions APPENDIX B

JET-LINE SERVICES REPORT October 11, 1989 I -- IJ *Lin

October 11, 1989

Ms. Joanne Michaud The Commonwealth of Massachusetts Department of -Environmental Protection Northeast Region - Emergency Response Five Commonwealth Avenue Woburn. MA 01801 Re: Perfection Auto Radiator-Contaminated Soil Removal/Disposal 39 Oakland Avepue - Methuen. Massachusetts (31-32035) Dear Ms. Michaud:

Jet-Line Services, Inc. is pleased to submit this letter d attached documents on behalf of our -client re-lative to rthe Perfection Auto Radiator facility located at 39 Dakiand Av.o Methuen. Massachusetts (the Site). These documents are transmitted in response to our telephone conversation -of .September 19, .1989. Attached please find the Uniform Hazardous Waste -Manifest (U MAC665101) documenting the excavation, transportation an: i disposal of three (3) drums of petroleum contamin'ated .oil.s in% late August 1989. The soil was excavated from the visually contaminated area located on the Boston &. Maine Railroad property immediately surrounding the drain hole in the rear wa] - of the Perfection Auto Radiator facility (see attached £ite Sketch). The visually contaminated soil was hand excavated to a depth of approximately 2.5 feet in the approximate area otlined in the Site Sketch. Also attached are copies of the laboratory certificates of analysis for samples collected on July 21, August 113, and September 5, 1989. The July 21 sample was collected from the- visually contaminated soil prior to excavation and analyzecd foi. total petroleum hydrocarbons (TPHCs) and volatile organic compounds (VOCs). The TPHC concentration detected in. this sa:npze . was 453 mi-lligrans per kilogram (mg/kg). The VOCs detected n. this sample included tetrachloroethene. toluene. ethyLbenzenet xylenes, and the 1,2/1.4 dichlorbenzenes in concentrations o. 0.052, 0.167. 0.105, 0.659, 0.104, and 0.143 mg/kg. respectivv. It was decided that the TPHC analysis would be required for further characterization since the total VOCdt edit relatively low at J . 23 miz/kg. Ti TP[ initialoncent Lration. sample ofwere the August 18 soi.1 sample lWimn oxcavation of the visually contaminated sol.1 wnL L.21 agn. A third sample was collected from the area outside. the excavation/visually contaminated area on September 5. 1989 to

| JET-LINE SERVICES, INC. * 8 Progress Drive, Dover, New Harqpshire 03820 * (603) 749-5735 e FAX: (603) 749-9095 -. --- h

.Page Two Ms. Michaud October 11, 1989

determine the extent and/or -background contamination on the property. The TPHC concentration of this sample and a- laboratory I selected duplicate were 2,762iand 2,945. mg/kg,.respectively. The area of the Site has a long history of industrial use. The contaminated soil was excavated from a railroad bed area which may have a relatively high residual petrolemn contamination background. It is believed th t the background contamination should be determined prior to establishing cleanup goals for th:V area rather than utilizing pre-determined values.

It has been a pleasure providing this letter and the artached document,. to you. Please call if you have any quest'ion.

Very truly yours

Richard D. Mansfield Project Engineer

C. L.- Lambert.- Perfection Auto.Radiator

A\PMMLTl.RDM

* II I'* * I II III'j'i'I' ii' I

I, I

'II.

I9 NVIRONMENTAL QUALITY ENGINEERING ON OF SOLID AND HAZARDOUS WASTE One Winter Street Boston, Massachusetts 02108 S3/- &r ------I ,.4...r~rr 17.o irVinWr f I - 3Gna r rUS EPA 10 No. MenU i$ 2. Pogo I InIcinmuin in tinc hedc! rrCda *f Il .e C ~ --l O S1J ~ l~ ~ A. Stars Manliegt Docurnunt FWmbr m A r R I i 8. SuateuG n.1I0 ' e.e Ne4'.me', SEP.A910/

ID .~ ri; NSI1I6. VS EPA ID Number C.StateI Trans. ~Ai-I 1I 1031 -r I _____ 0.TrhAAseorie,'s Phone( (03-/449b(Ji -2 CompanyHme 8. US EPA 10 Number E. 5tato lians. 10 _ _ _ .. tod ih n 4Sit Add ass 10, USEPA ID Number I r I I| 1 j chem a. D el-Line of Lowell F. Transon~.s Phone I 1 St. G.St.t. FSi-y'a D Not Reaulred 263 Howard r~fl - - - Lowell, IM a 0 07i0i7 /7 H. F ity hone 5 12. Containers 13. 14. - Ii. us 00e DeCfiltton lIncluding proper$hipping Nameea,Haard C168. and/D N Type uer ty Unit Waste No 011 contaminated solids N.O.-S. Mass. Regulated (MA01) 0 0 3 D M P- M A 0 l

. Additional Descriptions for Ma I aI. Liatod Above fincivde phy iciO reto andhazard code.I K. Handling Cdes tor Waste Listad Above oil contaminated soil . ra e. mod. t b. 1 1 6 Speciel Handling Inatuctions and Additionsl inonnoation

-GENE RATOt's C6rnFICAION' I hereby declvaeitat the contmnts of tms conalgninent e fully and sctCwtety deatlibed jbov# by- 0oa 6PAlp1naeme n ae cluaiied, otXed. maraed. end labtaad, Ind are Ai I soi eicu Ia pFopt Condilian ort n VS1spAn by 0ighwIy accordinQ t0 a0plcAbieAhInaIUnstJ and notional evernMent regulaion:. Il I a alge quantity genreratr. I tattIfv ti I he" a proeamet ptace to readc the Volume Oeetoriitily o waste ganetamid to tns aigree I thv duismined tota b i 9.att Arb e and that i have elbetao tAit piueel h rna Nrod oI tia tment. storag at disposai curnly evelabe tome *ihln rnmimr 1 1%4 plesent and uItur tWhisat to h.:uman neat ins It e fnvuio'- menu OR.ifIema maueutity generaeo.I havematfngood leiurellrt tomIrrnu e my wastgeefatkon 1nsiG tst eI*t BaIes iitfOnemnmethod real t ava- lb 1 rmI i -d hit

N TVgnh$i C~zsi. '4@4 . .Month DoeYear . Trane~onar 1 Acknowo ledoient of Recol of Mate asla Ptrmd/T yned Nor Sign Month Day Year

P.Transnrt r2 A e onowlc pment of A8ce6 t of MaterialI .. 1. garer.- Month Der Year

9.DiscrepenCv yd Stng ifl Cnpace

20. Facility Owner or Operator: Certllication of recclpt of hazardous rneteroile coveted by this manIfoot eCept a noted In Item 11. Dotm

y nPAMtn' "n rigns N reme 8 No70( 50-2. i-86)P v i d r b are obsalert rIM 0 009 .22 (Rev. 0-86) Ptviouis oditiono -- ~ - 'di,> Ar: I I I.,,. I i .1') I' I

I ~ T-LINE TE OF ANALYSIS 'I CER r rFICA

II I

* Td: PERFECTION AUTO RAVIA TOR DATE REpoRTED. 7-21-89 Douc AUGusTus DATE RECEzVED: 8-3-39 Jos NUMBER: 31-32035 LAS NUMBER: 4277 ii. SAMPLE DESCRIPTION: Sort .

PARAMETER ANALYSIS DETECTION LIMIT M/4!NC

OIL & GREASE (TPHC), MG/KG 45..,-0 0,2 SN r

VOL A TIL ES - SEE ATTACHED EPA 2 It

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SUPER VISOR:

JET-LINE S VICES, INC * STREET LOWELL, NA 01852 (508) 937-7294 -

*2* * .. ' . F ..... I. ~1 'A; * I / *1 2~

,1~ VOLATILE ORGANIC ANALYSIS DATA ~' Hg*1 LAS SAMPLE ID: 4277 Il: OA FE 'RUN: 8-2'-39 CLIENT SAMPLE ID:. PERFECTION AUTO RADIATOR On U7TZ ON FACroR: 10.0 1~ DATE RECEIVED; 7-21-89 .IX : 501,L METHOD: LOCAT rON: DETECTION LINTT CAS N RD VAU tiG;/Kc 74-87-3 CHLOROMETHANE ND * 100 74-83-9 SROMoME THA NE NO 100 75-01-4 VINYL CHLORIDE ND 100 75-00-3 CHLOROETHANE ND 100 75-09-2 ftETHYLENE CHLORIoE ND 50 75-69-4 RICHL OROFL UOR OME THA NE ND -50- 75-35-4 1, 1-DCHLOROETHENE NO 50 75 -35-3 1, 1-DICHLOROETHANE NO . 50 156-60-5 - TRANS-1, 2-DiCHL OROE THENE ND 50

67-66-3 *CHLOROrORN ND 50 107-06-2 1,2-DzCHLOROErHANE ND 50 71-55-6 1, 1, I-TRCHLOROETHANE ND 50 56-23-5 CARSON TETRACHLORIDE ND 50 705-27-4 BROMOD ICHL OROME THA NE ND 50 79-34-5 1,1,2,2, -TETRACHLOROETHANENO 50 78-87-5 1,2-DICHLOROPROPANE ND 50 10061-02-6 TRANS-1,3-DICHLOROPROPENE NO 50

79-01-6 TRICHLOROETHENE - .. NO . 50 124-48-1 DIOROMOCHLOROMETHANE NO 50 79-00-5 *1.1,2-TRICHLOROETHANE ND 50 71-43-2 BENZENE ' NO 50 10061-01-5 cus-l/,S-DzcHLOROPROPENE NO 50 110-75-8 2-CHLOROETHYL VINYL ETHER ND 100 '75-25-2 BROMOFORM ND 50 127-18-4 TETRACHLOROE THENE.. 52 50 108-88-3 4TOLUENE : 16;7 50 108-90-7 CHLOROSENZEIIE ND 50 100-41-4 ETHYL BENZENE 105 50 TOTAL XYLENES 659 .50 .1,2 DICHLOROBENZENE 104 50 1,4 DICHLOROSENZENE 143 50

4. 363$-1B4 3 * -31-59 ,5: iP'M[ 36524-) I

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. i ill CER FIICA T E OF ANALYSIS TO:PeRrectroN Aura1'

TO: PERFECrxioN AUTo RADIA TOR DATE ?EPORTED: 8-29-89 DoUG AUGUSTU DAT C ECCIVED; 8-18-89 J09 N UM9ER: 31-32035 LA&rNU'MeER| 4401 SAMPLE DESCRIPTION;

CONTAMrNA TED SonL

PAPA ME TER - -ANALYSIS DE TECTION LIMI T NE THUD TOTAL SQLIDS. XH 78.0 SM 209A OM L& GREASE (TPHC). 4C/XG 1.216 1.0 SM 5053

a.,

SUPERVISOR.- L Jer-LINE ERVICES. INC. 263 HOWARD STREET * LOWELL, MA 01852 (508) 937-7294 'It. /4 I S / Ii 4/

I ~' JE T-LINE. CERTIFWCATE OF ANALYSIS

PERFECTION AUTO R DIA TOR DA TE REPOR TEt ; 9-8-89 I TO: DoUG AUGUSTUS. OA TE RECEx VE : 9-5-89 JOB NUMBER: 31-32035 LAs NVMtRZ: 4444

SAMPLE DESCRIPTION:

OIL CONTAMINA TED SOIL

PARAME TER ANAL YSIS DE EC TION L INI T . METHOD

TOTAL SoL os. Z 85 SN 2M0A (DUP) -- 0 OIL & GREASE (TPHC), MG/KG 2762 2945 SM 5038

I I 4

.1. SUPERVISOR:______

SET-LINE SEc CES N 263 HOWARD SREEr * LOWELL, mA 01852 (508) 937-7294 APPENDIX C

SAMPLE LOCATION DIAGRAM

APPENDIX D

SOIL HEADSPACE METHODOLOGY AIMBIENT AIR PHO TOIONIZA TION ANA L YSIS USING THE PHOTOVAC TIP H SUMMARY OFANALYTICAL METHOD

The air samples:were taken with a direct reading Photovac TIP 1/ photolonization detector. Continuous samplig of ambient air, at a rate of approximately 275 mi/min., is accomplished by a positive displacement pump. Detection occurs as the sample Is drawn through a high energy, ultraviolet Photoionization Detector (PID) to Ionize a small portion of the Introduced sample. The instrument is equipped with a lamp with an .onizing 'energy of 10.6 eV which will detect most organic compounds-with an Ionization potential of less than 10.6 eV. The process of ionization is initiated by the' adsorption of a high energy photon by a molecule of the sample vapor In the lonization chamber. If the molecule's ionization potential is equal to or less than the photon energy (hv), a positive ion and an electron is formed.

R+hv-->R++e-

Ion formation occurs in the.'eiectrical field between the collector electrode and the jet in the Ionization chamber of the detector. Ions and electrons that reach the electrodes contribute. to a small Ionization current that is measured wifh the electrometer of the instrument.

The .amount of lons that reach the electrode will be proportional to the concentration of the' Ionizable molecules within the linear range of the detector. The detector response is displayed on the digital readout with a range of 0-2000 ppm and a resolution of 0.1 parts per million. Using a 10.6 eV lamp, the range of detectable compounds encompasses a very large number of solvent materials and some important pollutant species including benzene, vinyl chloride, I trichloroethylene, m -xylene, acetone, 1,2-dichlorobenzene, methyl ethyl ketone and toluene.

Sampling environmental air can be accomplished with the Photovac TIP // by (1) headspace analysis of sample containers, or (2) analysis of ambient air near the target media. AMBIENT AIR PHO TOIONIZA TION ANAL YSIS 1 .9, 1.9 4; < USING THE PHOTO VAC TIP II SUMMARY OFSAMPLE PROCEDURE

2. CALIBRATE THE INSTRUMENT ACCORDING TO THE INSTRUCTIONS PROVIDED IN SECTION'4 OF THE TIP It USER'S MANUAL. RECORD CALIBRATION DATA AND BACKGROUND LEVELS IN THE SPACES PROVIDED ON THE PHOTOIONJZATION DETECTOR FIELD DATA SHEET.

2. SAMPLE JAR HEADSPACE ANALYSIS

A. FILL AN 8 OR 16-OUNCE GLASS JAR APPROXIMATELY ONE-HALF FULL WITH THE SOIL TO BE SCREENED, COVER WITH A DOUBLE ALUMINUM FOIL SEAL AND SCREW-ON CAP.

B. SAMPLES SHOULD BE SCREENED AT ROOM TEMPERATURE. IN COLD WEATHER, WARM SAMPLES TO APPROXIMATELY 70 DEGREES FAHRENHEIT USING YOUR AUTOMOBILE HEATER OR BY PLACING ON A WARM HOOD.

C, SHAKE SAMPLE JAR VIGOROUSLY FOR APPROXIMATELY 10 SECONDS TO RELEASE VOLATILE COMPOUNDS.

D. REMOVE CAP FROM JAR AND PUNCTURE A SMALL HOLE IN THE ALUMINUM FOIL. INSERT THE TEFLON PROBE INTO THE HOLE AND RECORD THE HIGHEST READING FROM THE LCD DISPLAY. .

E. ALLOW THE INSTRUMENT TO RETURN TO THE BACKGROUND READING. IF THIS TAKES TOO LONG, ALLOW THE INSTRUMENT TO RETURN TO A READING LESS THAN 10 AND RECORD THE READING. THIS READING IS THE NEW BACKGROUND LEVEL. ANALYZE THE NEXT - SAMPLE AND SUBTRACT THE NEW BACKGROUND LEVEL TO OBTAIN THE ACTUAL LEVEL OF TOTAL IONIZABLE COMPOUNDS.

3. tIN-SITL SOIL HEADSPACE. ANALYSIS ( I.e. PIT WALLS, BACKHOE BUCKETS,. ETC.)

A. . SCREEN SOILS WITH THE PHOTO[ONIZATION DETECTOR IMMEDIATELY AFTER THEY ARE EXPOSED. IN A TEST PIT OR TANK EXCAVATION, SCRAPE THE TOP FEW INCHES OF SOIL PRIOR TO SCREENING TO EXPOSE REPRESENTATIVE SOIL.

B. USING A STICK OR SIMILAR IMPLEMENT, POKE A HOLE 4 TO 6-INCHES DEEP IN THE SOIL TO BE SCREENED. REAM AND PACK THE HOLE USING A CIRCULAR MOTION.

C. , IMMEDIATELY INSERT THE PROBE 2 TO 3-INCHES INTO THE HOLE, TAKING CARE NOT TO ASPIRATE ANY SOIL.-

D. RECORD THE HIGHEST READING FROM THE LCD DISPLAY.

E. ALLOW THE INSTRUMENT TO RETURN TO THE BACKGROUND READING. IF THIS TAKES TOO LONG, ALLOW THE INSTRUMENT TO RETURN TO A READING LESS THAN 10 AND RECORD THE READING THIS READING IS THE NEW BACKGROUND LEVEL. ANALYZE THE NEXT SAMPLE AND SUBTRACT THE NEW BACKGROUND LEVEL TO OBTAIN THE ACTUAL LEVEL OF TOTAL IONIZABLE COMPOUNDS.

I -. APPENDIX E

LABORATORY RESULTS Groundwater Analytical. Inc. 228 Main Stfeed GROUNDWATER Buzzards Bay, MA 02532 ANALYTICAL Telephone (508) 759-4441 FAX (508) 759-4475

August 20, 1991

Mr. Thomas Williamson EE & G, Inc. 149 Cross Street Winchester, MA 01890 Dear Tom: Enclosed are the Volatile Organic Analyses performed for the Guilford Methuen project, number 91.1016MA, sampled on 07-30-91. This project was processed for Priority One Week turnaround. A brief description of the Quality Assurance/Quality Control procedures employed by Groundwater Analytical, and a statement of our state certifications are contained within the report. This letter authorizes the release of the analytical results and should be considered a part of this report. Should you have any questions concerning this report, please do not hesitate to contact me. Sincerely,

David L. Sanford- Vice President Laboratory Operations

DLS/mad Enclosures GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS) Field ID: SS-1 Lab ID: 1752-01 Project: Guilford Methuen/91.1016MA QC Batch: VMA-291 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 40ml VOA Vial/Cool Received: 07-31-91 Matrix: Soil Percent Moisture: 44 % Analyzed: 08-13-91 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane * BRL 5 Methylene Chloride BRL 5 Acetone 630 ** 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 1,1-Dichloroethane BRL 5 2-Butanone trace 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1 3-Dichloropropene BRL 5 Trichioroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1,1,2,2-Tetrachloroethane BRL 5 Toluene 22 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) 21 5 Dichlorobenzene (total) * BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS I ,2-Dichloroethane-d4 50 51 102 % 70 121 % Toluene-d8 50 58 116 % 81 117 % 4-Bromofluorobenzene 50 36 72 % * 74 121 %

*** Outside QC limits due to matrix interference. ** Concentration of Acetone is estimated. No dilution was used in order to achieve low detection limits for other parameters. BRL - Below Reporting Limit. * Non-target compound. "Trace" indicates probable presence below listed detection limit. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

Field ID: SS-1 Lab ID: 1750-01 Project: Guilford Methuen/91.1016MA QC Batch: OHS-120 Client: EE.& G Sampled: 07-30-91 Cont/Prsv: 500ml Glass/Cool Received: 07-31-91 Matrix: Soil Extracted: 08-06-91 Analyzed: 08-07-91

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 19,000 30

BRL - Below Reporting Limit. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER EPA METHOD 8240 ANALYTICAL Volatile Organics (GC/MS)

Field ID: SS-2 Lab ID: 1752-02 Project: Guilford Methuen/91.1016MA QC Batch: VMA-291 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 40ml VOA Vial/Cool Received: 07-31-91 Matrix: Soil Percent Moisture: 18 % Analyzed: 08-13-91 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane * BRL 5 Methylene Chloride BRL 5 Acetone BRL 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 1,1-Dichloroethane BRL 5 2-Butanone BRL 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1,3-Dichloropropene BRL 5 Trichloroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1,1,2,2-Tetrachloroethane BRL 5 Toluene BRL 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) BRL 5 Dichlorobenzene (total) * BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS 1, 2-Dichloroethane-d4 50 50 100 % 70 - 121 % Toluene-d8 50 53 106 % 81 - 117 % 4-Bromofluorobenzene 50 45 90 % 74 - 121 %

BRL a Below Reporting Limit. * Non-target compound. "Trace" indicates probable presence below listed detection limit. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

Field ID: SS-2 Lab ID: 1750-02 Project: Guilford Methuen/91.1016MA QC Batch: OHS- 120 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 500ml Glass/Cool Received: 07-31-91 Matrix: Soil Extracted: 08-06-91 Analyzed: 08-07-91

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 380 30

BRL - Below Reporting Limit. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUND WATER EPA METHOD 8240 ANALYTICAL Volatile Organics (GC/MS)

Field ID: SS-3 Lab ID: 1752-03 Project: Guilford Methuen/91.1016MA QC Batch: VMA-291 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 40ml VOA Vial/Cool Received: 01-31-91 Matrix: Soil Percent Moisture: 38 % Analyzed: 08-13-91 PARAMETER CONCENTRATION REPORTING LIMIT (uy/Kg) (ug/Ky) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane *BRL 5 Methylene Chloride BRL 5 Acetone BRL 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 1,1-Dichloroethane BRL 5 2-Butanone BRL 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1,3-Dichloropropene BRL 5 Trichloroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1,1 ,2,2-Tetrachloroethane BRL 5 Toluene BRL 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) BRL 5 Dichlorobenzene (total) *BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS

1,2-Dichloroethane-d4 50 50 100 % 70 - 121 % Toluene-d8 50 53 106 % 81 - 117 % 4-Bromofluorobenzene 50 42 84 % 74 - 121 %

SRI - Below Reporting Limit. * Non-target compound. 'Trace" indicates probable presence below listed detection limit. Calculations based on dry sample weight. Hethod References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). - GROUNDWATER ANALYTICAL EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

Field ID: SS-3 Lab ID: 1750-03 Project: Guilford Methuen/91.1016MA QC Batch: OHS-120 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 500ml Glass/Cool Received: 07-31-91 Matrix: Soil Extracted: 08-06-91 Analyzed: 08-07-91

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 930 30

BRL = Below Reporting Limit. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US. EPA SW-846, Third Edition (1986). .LN3I1O - NM3ra~ Bfl - IVNICDWO

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LU :30. 0 cc L: 'mm I?- I givo C 5 C tm' a. a. ,) I-. GROUNDWATER ANALYTICAL QUALITY ASSURANCE QA/QC Program Statement Groundwater Analytical conducts an active Quality Assurance pro gram to ensure the production of high quality, valid data. This program closely follows the guidance provided by Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans, US EPA QAMS-005 80 (1980), and Test Methods for Evaluating Solid Waste, US EPA SW-846, Third dition (1986). Quality Control protocols include Standard Operating Procedures (SOPS) developed for each analytical method. SOPs are derived from US EPA methodologies and other established references. Equipment and facility maintenance conform to Good Laboratory Practices (GLPs). Standards are prepared from commercially obtained reference materials of certified purity, and documented for traceability. Quality Assessment -protocols for most organic analyses include a minimum of one calibration standard, one method blank, one matrix spike, and one matrix spike duplicate for each sample batch. All samples, standards, blanks, and matrix spikes are spiked with internal standards and surrogate compounds. GC/MS systems are tuned to BFB ion abundance criteria daily, or for each 12 hour operating period, whichever is more frequent. Quality Assessment protocols for most inorganic analyses include a minimum of one calibration standard, one method blank, one sample duplicate, one matrix spike and one matrix spike duplicate for each sample batch. Standard curves are derived from one reagent blank and four concentration levels. Curve validity is verified by standard recoveries within plus or minus ten percent of the curve. Analytical Batches are used as the basic unit for Quality Assessment. An Analytical Batch is defined as twenty or fewer samples which are analyzed together with the same method sequence and the same lots of reagents and with the same manipulations common to each sample within the same time period or in continuous sequential time periods. Method Blanks are used to assess the level of contamination present in the analytical system. Method Blanks consist of reagent (analyte-free) water or sand. Method Blanks are taken through all the appropriate steps of an analytical method. A universal blank matrix does not exist for solid samples. Sample data is reported on a blank-corrected basis. Matrix Spike/Matrix Spike Duplicates are used to assess accuracy and precision. A Matrix Spike/Matrix Spike Duplicate consists of two replicate samples (or two reagent blanks if sample volumes are inadequate) spiked with a group of target compounds representative of the method analytes. Accuracy is defined as the degree of agreement of a measured value with the true or expected value. Percent Recoveries for the Matrix Spike are calculated to assess accuracy. Precision is defined as the degree of mutual agreement of independent measurements as the result of repeated application of the method. Relative Percent Differences, between the Matrix Spike and Matrix Spike Duplicate are calculated to assess precision. Surrogate Compounds are used to assess the effectiveness of the method in dealing with each sample matrix. Surrogate Compounds are organic compounds which are similar to organic analytes of interest in chemical behavior, but which are not normally found in environmental samples. Percent Recoveries are calculated for each Surrogate Compound. GROUNDWATER ANALYTICA L QUALITY ASSURANCE Matrix Spike Recovery and Matrix Spike Duplicate Study

Category: EPA Method 8240/Low Level Purging QC Batch: VMA-291 Matrix: Soil/Sediment/Solid Units: ug/Kg

ANALYTE SPIKED MEASURED ACCURACY PRECISION MS MSD AVG APR Limits RPD Limit 1,1 Dichloroethene 50 73 73 73 146 % 59-172 0 % 22 Trichloroethene 50 45 42 44 87 % 62-137 6 % 24 Benzene 50 57 57 57 114 % 66-142 0 % 21 Toluene 50 55 57 56 112 % 59-139 4 % 21 Chlorobenzene 50 55 57 56 112 % 60-133 4 % 21

Terms: MS = Matrix Spike; MSD = Matrix Spike Duplicate; AVG = Average; APR = Average Percent Recovery; RPD = Relative Percent Difference. Quality Control Limits are defined by the methodology, or alternatively based upon the historical average recovery plus or minus three standard deviation units. GROUNDWATER QUALITY ASSURANCE ANALYTICAL Method Blank

Category: EPA Method 8240/Low Level Purging QC Batch: VMA-291 Matrix: Soil/Sediment/Solid PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane *BRL 5 Methylene Chloride BRL 5 Acetone BRL 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 Tetrahydrofuran * BRL 50 1,1-Dichloroethane BRL 5 2-Butanone BRL 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 Methyl tertiary Butyl Ether *BRL 5 1,1,1-Trichloroethane BRL S Carbon Tetrachloride BRL 5 Vinyl Acetate BRL O Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1,3-Dichloropropene BRL 5 Trichloroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL S trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 5O Tetrachloroethene BRL 5 11 1,2,2-Tetrachloroethane BRL S Toluene BRL Chlorobenzene BRL S Ethyl benzene BRL 5 Styrene BRL 5 Xylene (total) BRL 5 Dichlorobenzene (total) *BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS

1,2-Dichloroethane-d4 50 48 96 % 70 - 121 % Toluene-dS 50 49 98 % 81 - 117 % 4-Bromofluorobenzene 50 50 100 % 74 - 121 %

BDL - Below Detection Limit. * Non-target compound. "Trace" indicates probable presence below listed detection limit. calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846,.Third Edition (1986). GROUNDWATER ANALY TICA L StQUALITY ASSURANCE State Certification

CONNECTICUT Certificate Number Department of Health Services PH-0586 Potable Water, Wastewater/Trade Waste, Sewage/Effluent, and Soil: Purgeable Halocarbons, Purgeable Aromatics, Pesticides, Phenols, Oil and Grease, Aluminum, Antimony, Arsenic, Beryllium, Cadmium, Chromium-T, Chromium-VI, Cobalt, Copper, Iron, Lead, Magnesium, Manganese, Mercury, Nickel, Potassium, Selenium, Silver, Sodium, Thallium, Tin, Vanadium, Zinc, Cyanide, TDS, Ammonia, TKN, Nitrate, Ortho-Phosphate, Alkalinity, Hardness, Chloride, Fluoride, pH, Conductivity

MAINE Certificate Number Department of Human Services N/A Reciprocal certification in accordance with Massachusetts certification for drinking water parameters.

MASSACHUSETTS Certificate Number Department of Environmental Protection MA103 Drinking Waters: Metals, Trihalomethanes, Volatile Org anics Nitrate, Nitrite, Fluoride, Corrosivity Series, Cyanide Other Matrices: Metals, Minerals, Nutrients, Volatile Halocarbons, Volatile Aromatics, Pesticides, Cyanide, Oil and Grease, Phenolics

NEW HAMPSHIRE Certificate Number Department of Environmental Services 202791-A/B Drinking Water: Trihalomethanes, Volatile Organics Wastewater: Volatile Organics, Pesticides, Oil and brease, Aluminum, Arsenic, Beryllium, Cadmium, Cobalt, Chromium, Copper, Iron Mercury, Manganese, Nickel, Lead, Selenium, Antimony, Silver, Thallium Molybdenum, Strontium, Vanadium, Calcium, Magnesium, Sodium, Potassium, pH,. Specific Conductance, TDS, Hardness, Alkalinity, Chloride, 'Fluoride, Ammonia, Nitrate, Orthophosphate, TKN, Phosphorus, Phenolics

RHODE ISLAND Certificate Number Department of Health N/A Recognition of Massachusetts certification. t 7 v.... I,

/ I I CAVATION V AREA I

OAKLAND AVE,

I. - SITE SKETCH LEGEND. PERFECTION AUTO RADIATOR 9 OAKLAND AVEL I () EXCAVAT 1INI METHUEN MA, 0 SAMPLING L.OCA I P0N U4 1 J&/tavme/la/ .fited&ae

46 .~nmnaACeXoeo Daniel S. Greenbaum O/c Commissioner December 6, 1990

Attention: Vinay Mudholkar, Chief Engineer

Dear Mr. Mudholkar:

On May 10, 1989, Department personnel investigated reports concerning the release of waste oil from Perfection Auto. Radiator at 39 Oakland Avenue, Methuen, Massachusetts which abuts Massachusetts Bay Transportation Authority's (MBTA) railroad right- of-way. Because it -appeared that the railroad bed had been excavated at one time with the excavated material (i.e., soil, railroad ties) placed along the embankment, soil samples were collecte.d outside the spill area on the embankment to obtain background total petroleum hydrocarbon (TPH) levels. The levels ranged from 270 parts per million (ppm) to 2,945 ppA TPH.

Chapter, 21E and. the MCP identify as responsible parties the cprrent owner or operator of a site at which there has been a release or threat of release of oil or a hazardous material; the past owner or operator of a site where a release of hazardous material has occurred; any person who directly or indirectly arranged for the transport, disposal, storage or treatment of hazardous materials to or at such a site; and any person who caused or is legally responsible for a release or a threat of release of oil or a hazardous material at such a site. Such parties are liable without regard to fault; the nature of this liability is joint and. several. (M.G.L. Chapter 21E, Section Sa).

Original Printed on Recycled Paper -V

RegionCase:e CLOSED PENDING Case No. -

*- ~ DEQE OIL AND HAZARDOUS AATERIAL SPILL/RELEASE INCIDENT NOTIFICATION AND INSPECTION REPORT AMENDED E i. RESPONSE: INITIAL FIELD TELEPHONE 0 FOLLOW-UP C 21E NOTIFICATION LJ . MUNICIPALITY; 14. INCIDENT 12T REPORTED: 3. ADDRESS: I Date / - Time AM/PM 5. INCIDENT OCCURRED: Date Time AM/PPM,V . PERSON WHO 1ST NOTIFIED DEQE: - H Name/Address 'JS1'0Mr I 1 (A0 M h ' ( Tel. # OIL OR HAZARDO S MATERIQL RELEASED: a. Name: < CAS!# b. Amount Reported: Actual: .. c. ,Oil/Not Oil Virgin/ ast N'on-PCB/PCB ppm Soil Contamination Y/N d. Source: vehicle fuel tank drum tanker truck boat railroad tank/enana above-ground tank I below-ground tank transformer pipe hose othe e. Samples Obtained: Yes (No> f. Drurms Retained: Yes No (if yes, specify where sent)

g. Release Type:' Leak Overfill Rupture Tank Removal Spill Dumping Qth, BRIEF DESCRIPTION OF INCIDENT:

A. '' V I .*/j Ir f ',l~t :

POTENTIALLY RESPONSIBLE PRRSON IDENTIFIED BY DEQE: -a. PRP notified Department Date: Time:

U. Name/Address ,7 jif.el .. x~~ ~g ',/~ # _____ I .Name/Address 'L...l'.i..ir/ft c < Tel #______c. PRP received Notice of Responsibility: Verbal: Date Time .. I Field: Date /I / Time ; Office: Date Time .. d. Responsibility accepted and proper actions taken by responsible person: (Yes; No e. Name of cleanup contractor hired by responsible person: REGIONAL RESPONSE ACTIONS: a. State-cleanup contractor: X/A Service Category: SC SSC SSI HM b. Contractor arrived on-scene: Date Time AM/PM

c. Further field response actions needed: ' No . (if yes, specify)

'd. Enforcement actions taken/recommended: Yes tNo (if yes, specify)

e. Cost recovery recommended: Yes Maybe INTRA-AGENCY NOTIFICATION/REFERRAL: a. Name(s) of DEQE employee(s) notified. b. Case referred within DEQE to: ._2:2x.. . 12. OTHER AGENCIES NOTIFIED BY DEQE OF SPILL/RELEASE INCIDENT:

Name: Date: Name: Date: ...... Contact: - Reort prepared by: Signatur Title

DISTRIBUTION: WHITE/REGIONAI. OFFICE YF1IlI. GN/flTON pi I/IrfA nrr .pit i .. A1r P -a W 1! *' ~ . C

THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING

. NOTICE OF RESPONSIBILITY PURSUANT TO M.G.L CHAPTER 21E

TO: 3:?,- .'4-74 -'~ ~ -/..I IR#: tj-/-

On { at / S ( m the Department of Environmental

*- Ouality Englnehring (Departnent) responded to a release/threat of release of oh/hazardous material at 1 .4 p. r 1w in ' rnj r 1M,-1 Massachusetts (the site).

Preliminary indications are that pursuant to section 5 of M.G. L Chapter 21 E _ _'_ is/are a party responsible for assessment, containment and removal actions necessitated by this incident. Massachusetts General Laws. Chapter 21E, places liability on responsible parties to: (1) pay for all response action costs associated with the incident and (2) compensate for any damage to natural resources resulting from the incident. U . You may assume responsibility for emergency response actions/costs by paying for all response costs incurred by the Department relative to this Incident and immediately performing the items checked off below: Hire a spill cleanup contractor acceptable to the Department to take all necessary emergency response as required by the Department. containment and/or removal) / [3Disposeactions (i.e.of the assessment, contaminated soil generated at the site In conformance with the Department's current policies for management of virgin petroleum-contaminated soils. Written approval must be obtained from the Department prior to removal of the soil. Collect Soiater samples bekr re andfater cleanup)fom the.impacted environmental media and submit oresultsf a certified.laboratp analysis'fdf /- ~/ FM. r - -.

Submit a report providing an accurate description of the incident, response actions taken relative thereto, and site conditions (including supporting documents) immediately, or upon receipt of analytical results. Other /. - - --

The above actions must be performed Immediately and/or completed no later than / r Depending on the Information/data generated by the above work, the Department'may require'additional remedial response actions. Vfyou tail to complete the response action(s) required by the Department within the required timeframe, the Department will take appropriate response actions and seek to recover all costs, charges and damages. By accepting responsibility for conducting the required response actions now you can:

I-

I I - - I-s I -- --...... - ~. Preliminary Indications are that pursuant to section 5 of M.G. L. Chapter 21E is/are a party responsible for assessment, containment and removal actions necessitated by this incident. Massachusetts General Laws, Chapter 21 E. places liability on responsible parties to: (1) pay for all response action costs associated with the incident and (2)compensate for any damage to natural resources resulting from the incident. You may assume responsibility for emergency response actions/costs by paying for all response costs incurred by the Department relative to this incident and immediately performing the items checked off below: Hire a spill cleanup contractor acceptable to the Department to take all necessary emergency response actions (i.e. assessment, containment and/or removal) as required by the Department. Dispose of the contaminated soil generated at the she in conformance with the Department's current policies for management of virgin petroleum-contamiqated soils. Written approval must be obtained from the Department prior to removal of the soil. Collect soit/yater samples before andafe rcleanup f om the. Impacted environmental media and submit results oTsa certified.laboratr analysli'f6r iF

Submit a report providing an accurate description of the incident, response actions taken relative thereto, and site conditions (including supponing documents) Immediately or upon receipt of analytical results.

0Other~.4(t. iWL ~.. :j.~

The above actions must be performed immediately and/or completed no later than ' Depending on the information/data generated by the above work, the Deparment'may require'additional remedial response actions. r. it you fail to complete the response action(s) required by the Department within the required timeframe, the Department will take appropriate response actions and seek to recover all costs, charges and damages. By accepting responsibility for conducting the required response actions now you can: - minimize administrative costs incurred by the Department in handling this matter (In spill. cases, administrative costs Incurred by the Department are at least $1,000.00): - avoid interest charges on the total liability at the statutory rate of 12% compounded annually; and

- avoid treble damages (I.e., 3 times the total amount of response costs the Department incurs).

This liability constitutes a debt to the Commonwealth. The debt, together with interest, creates a lien on all - your property Inthe Commonwealth. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Commonwealth may recover that debt or any part of it In an action against you. You may also be liable under M.G.L. C. 21 E, section 11 for up to $100,000 in tines or penalties for each violation of C. 21 E as well as for additional penalties or damages pursuant to other statutes or common law. The Department encourages potentially responsible parties to provide or arrange for response actions to minimize the Department's response action costs for which you may be liable. The Department's objective is to ensure public health and safety and to protect the environment. Only with your help can this goal be achieved. Please.submit the requested information and direct any questions regarding this matter to * j*. 1 U.'.41..at the I '!.l. . R gional office,. Massachusetts, telephone # () ) I-'Very truly yours,

Name and Title of DEOE Official

On -jat approximately ' / - 1, of the.above DEQE Office served upon

personally by certified mail a copy

of the above "Notice of Responsibility', Person on-scene agrees does not agree to take the rosponso actions deemed nocossary by the Dopartmonl.

Copy Distribution: Whito/Potontlial Rosponsiblo Party Yellow/Boston Pink/Rogion Golden Rod/Iigion [2J' (.Wuu DEP OHM SPILL/RELEASE INCIDENT REPORT ate: IlW12Z/ Region: Al --- Case: Closed ['Pending ER #: . RESPONSE: c Initial Office C Follup Office . . C Amended. Site # C Initial Field - Follow-up Field 0 21E Notification. . MUNICIPALITY: ALL 4. INCIDENT 1ST REPORTED:

L't" Date: / / Time: AM/PM . ADRESS: n nw..;(- A 5. INCIDENT OCCURRED: I.PERSON WHO 1ST NOTIFIED DEP: Date: / Time: AM/PM Name/Address: Tel. # OHM: a. Name: CAS#: b. AMOUNT: Reported: - Actual: c. Category #: .i/oOil Virgin/Waste sNon-PCB/PCB ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank drum tanker truck boat railroad tank/engine above-ground tank below-ground tank transformer pipe hose other f. RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill Dumping Other 8. DESCRIPTION OF INCIDENT:

POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP: a. PRP notified the Department Date: Time: AM/N b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date: / -Time: AM/PM RESPONSE ACTIONS: a. Responsibility accepted and proper action taken by responsible person: Yes No b. Name of cleanup contractor hired by responsible person c. State-cleanup contractor d. Service Category: SC SSC SSI HM ASB e. Contractor arrived on-scene: Date: . / Time: C. Further field response actions needed: Hes) No (specify) -

Sg. Noncompliance Issues: h. LUST: Federal Eligible Yes 11. INTRA-AGENCY NOTIFICATION/REFERRAL: a. DEP Staff Notified: ER Lead: b. Referral within DEP' to: (Name/Prograin/Prog. V) 2. OTHER AGENCIES NOTIFIED BY DEP 01 S PILL/IRI.EASE INCIDENT: 2 Name: Date: /-- Name: Dai:L.-- Cont~ac i/I acu/'lIPhne:. eport prepared by: ' ' hi Signaliiur 7

COPY DISTRIBUTION: WIlITIVREGlONALOFFICE YELLOW/OSTON PINK/GOILDENROD/REGIONAL.OFFICE v.ii*, DEP OHM SPILL/RELEASE INCIDENT REPORT Region: Case: C Closed 0 Pending ER #: ESPONSE: 0 Initial Office C Follow-up Office C Amended Site # C Initial Field El Follow-up Field C 21E Notification UNICIPALITY: 4. INCIDENT 1ST REPORTED: .)ADDRESS: Date: /L/L Time: AM/PM 5. INCIDENT OCCURRED: 6. PERSON WHO 1ST NOTIFIED DEP: Date: W/ L Time: AM/PM Name/Address: Tel. # 7. OHM: a. Name: CAS #: . AMOUNT: Reported: Actual: c. Category #: d. Oil/Not Oil Virgin/Waste Non-PCB/PCB ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank drum tanker truck boat railroad tank/engine above-ground tank below-ground tank transformer pipe hose other f. RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill Dumping Other DESCRIPTION OF INCIDENT:

J r .. I..

POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP: a. PR P notified the Department Date: / / Time: AM/PM b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date: Time 11 RESPONSE ACTIONS: a. ResoonshNiv ncceit:d .nd proper ac:ion taken by responsible person: Yes No

C TN T RAT.D..D..R. 'A R EL E. 'T:t'~C X:~!.S:C

_ N _ _ _ _ _ 5257.R\,T _ _ TE.3Y4-.'.O______R L-. -.?

.. ,.. A. - U DEP OHM SPILL/RELEASE INCIDENT REPORT ate: Region: / j Case: C Closed O'Pending ER #: -. -

RESPONSE: Initial Office ollod-up Office C Amended Site # 0 Initial Field [] Follow-up Field . 21E Notification .MUNICIPALITY: 4, INCIDENT 1ST REPORTED: . A q : .. /S Date: / Time: AM/PM 5. INCIDENT OCCURRED: .PERSON WHO 1ST NOTIFIED DEP: Date: / Time: AM/PM Name/Address: -Tel. i 17. OHM: a. Name: CAS#: b. AMOUNT: Reported: Actual: c. Category #: d. Oil/Not Oil Virgin/Waste Non-PCB/PCB ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank / drum tanker truck boat railroad tank/eine above-ground tank below-ground tank transformer pipe hose other f. RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill Dumping Other 8. DESCRIPTION OF INCIDENT:- - --

9. POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP a. PRP notified the Department Date: Time: \M/PMV b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date; /- L Time: AM/'N [0. RESPONSE ACTIONS: a. Responsibility accepted and proper action taken by responsible person: Yes No b. Name of cleanup contractor hired by responsible person c. State-cleanup contractor: i. Service Category: SC SSC SS1 AIA\f e. Contractor arrived on-scene:' Daic: / / Thne: ..... \ M ' i f. Further field respo:Te actions needed: i 2 No( UQ. Noncomupliane sus h. LUST: Fedenil El cible Yes No I3. INTRA-AGENCY N )TIFICATION'REFERRAL: ER I ed N a.DEP S12if NCMified

F, R I.' I: N N FIV - -I)ItN-IF- tI KIII t . . ... DEP OHM SPILL/RELEASE INCIDENT REPORT 3 Date: - /'' Region: _ t Case: C Closed 0 Pending ER #: 1. RESPONSE: 0 Initial Office El Follow-up Office C Amended Site # (2 Initial Field 0,Follow-up Field E 21E Notification 2. MUNICIPALITY: 4. INCIDENT 1ST REPORTED: 3. ADDRESS: Date: / Time: AM/PM 5. INCIDENT OCCURRED: 6. PERSON WHO 1ST NOTIFIED DEP: Date: ' I Time: AM/PM in Nam6/Address:. Tel. # 7.- OHM: a. Name: CAS#: b. AMOUNT: Reported: Actual: c. Category #: d. Oil/Not Oil Virgin/Waste Non-PCB/PCB ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank drum tanker truck boat railroad tank/engine above-ground tank below-ground tank transformer pipe hose other f: RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill' Dimping Other 8. DESCRIPTION OF INCIDENT: -

9. POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP: a. PRP notified the Department Date: Time: AM/PM b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date: / -Time: AM/PM 10. RESPONSE ACTIONS: a. Responsibility accepted and proper action taken by responsible person: Yes - No b. Name of cleanup contractor hired by responsible person c. State-cleanup contractor: d. Service Category: SC SSC SSI l1M ASI3

e. Contractor arrived on-scene: Date : 'Time: - A M/PM - f. Further field response actions needed: Yesi No (specify)

g. Noncompliance Issues: h. LUST: Federal Eligible Yes No 11. INTRA-AG ENCY NOTIFICATION/REFERRAL: a. DEP Staff Notified: ER Lead: b. Referral within DEP to: (Name/Progrim/Prog. #) 12. OTEl ER AGENCIES NOTIFIE) BY DEP OF SPILI./I .EASE INCIDNT: Name: Date: // Name:I Contact/Phone: Conetact/Phone: Report prepared by: 'i; r i ( Signature:

* COPY DIIS~fII UT(ON: w.'ilf13IYEr'/RfGONAL OFFVrj Yp *jU1w/q pv,: )1. ;',- -: , *;. : , . , THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING LAWRENCE EXPERIMENT STATION

SPECIAI ANALYSIS

CITY/TOWN METHUEN

COLLECTOR J. Michaud

3 1 RCE A 39 Oakland Avenue Bottom

SOURCE B 39 Oakland Avenue Right * ,ejl.4./' ,,,I} 7; '7...... IRCE C 39 Oakland Avenue Center 5/21/G'z: 3 IRCE D 39 Oakland Avengii Center - duplicate

;RCE E ifRCE. F A B C D E F or PLE NUMBER 004 005 006 duplicate

TE OF COLLECTION - 4/23/90 4-/23/90 4/23/90 4/23/90

fTE OF RECEIPT 4/23/90 4/23/90 4/23/90 4/23/90 - DATE ANALYZED 4/26- 4/26- 4/26- 4/26- DATE ANALYZED 5/18/90 5/18/90 5/18/90 5/18/90

tal petroleum drocarbons uq/q 1400 270 5000 6200

-21

' The samples.were analyzed according to Method 503D, "Extraction Method Sludge Samples" and 503E, "Hydrocarbons", Standard Methods, 16th '<.k Womatography/FID.985. p. 501. The presence of petroleum hydrocarbons was conirmeod b/C.: -. COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING DIVISION OF SOLID AND HAZARDOUS WASTE One Winter Street Boston, Massachusetts 02108 I'W rnt mlie rnttn dmi i fat use on eloieIt 2-pitch) typewuler.I UNIFOfM II1AZARDOUS . Genetetor US EPA ID No. Manilest .. 2. Pan I Inforatiotn in ith s r'dm s WASTE MANIFEST S VI I N I. AI I , I' .' :11 I j Ti c' isI o "i'eiby r" t1FInwit'EiwA imi nml Ma.ling Adlesi / A. State Manifesi onewtrt humber

8.StataGen.ID

CImeln'G4 Plpim . - -- . in.t.wotler Coiitivo~ni e 6. - - USEPA laDNumber . CStato lians. I0 f2 oet-LInL' ervices, Ic.. |fl A1 6 21 -1179 j C90 /In IGI -III trntmiorter 2 Conmpnny Nanto a. | US EPA 10 Number I I I I i i I I I f? I)ns-l ilwed ricilary Name end Site Adderss 10. US EPA ID Number tK'echrn - b/9/A Jet-Line of Lowell F. Transporter's Phono I " Z33 keward St. G.Stoie Faciity's u Nut equfl5 ediic H, Fncility's Phone 1 5 93/-/296 *LMintllsf..!.0110 ___ JJ I Al Ill hl 4 11 Z& 12. Ceit ineoa 13. 1. 11. USD0 D01 rritlion thwAung Piopeo ShippiingNamno. larnte Class. andIDNImtntber T of al . Vil Waste No No. Typo Ouantily WItVol U1l contaiswnated solids 1.O.S. fiass. PejuhZted (Ai01Q - tL P A 0l1

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OIIUEDENTIFICATION

Page 1 of 3

PROCEDURE

The procedure used for the identification of refined petroleum products is derived from the method "Gas Chromatography -of High Molecular Weight. Hydrocarbons with an Inorganic Salt Eutectic Column". (Anal. Chen., Vol. 50, No. 2, February 1978, 22.9).

A 2% solution in pentane of the oil sample is analyzed in a Perkin Elmer Gas Chromatoeraph 'equipped with a flame ionization -detector -and an SPB - 1 capillary column. The chromatogram obtained is compared with chromatograms of a 2% solution in pentane of reference oils. The references are the refinery fractions gasoline, kerosene, diesel oils, heating oils and wide-cut gas oil (lube oils).

Two chromatograms are run for. both the sample and the reference. oil. In the second run they are spiked with a standard solution of known 'saturated hydrocarbons ranging from .nine- to twenty-four carbon atoms. The petroleum hydrocarbons in the sample are tentatively identified by the overlapping of-- peaks with similar retention times and the corresponding oil is identified by comparison with the reference -oil. - (L

9e/sanfmen( / cn$w onmentat &?calig &nr/cneeein

aence afn obintenI,

87 tRAallacA.4 el .2 2atoence, atasacusee/s 0180.3

E 2) , 1

SAMPLE (S) ANALYSIS b/t L RESULTS

CITY/TOWN METHUEN

COLLECTOR J. Michaud COLLECTION DATE 4/23/90

RECEIVED _ 4/23/90 ANALYZED 4/26-5/18/90

1. SAMPLE NO. 004

SOURCE 39 Oakland Avenue Bottom

RESULT The sample seems to contain a wide-cut gas oil.

2. SAMPLE NO. 005-

SOURCE 39 Oakland Avenue Right

RESULT The sample seems to contain a wide-cut gas oil.

...... - . .. * . .,.. PAGE 3 OF 3 I - 3. SAMPLE NO. 006

- SOURCE 39 Oakland Avenue Center

RESULT The sample seems to contain a wide-cut gas oil.

I ,

* * i--,,-.. . ;* ~e Environmental Engineering & Geotechnics, Inc. 149 Cross Street Winchester, Massachusetts 01890 (617) 721-1013 FAX (617) 721-1007

October 7, 1992 Guilford Transportation Industries, Inc. Iron Horse Park * North Billerica, MA. 01862-1688 RE: Laboratory Results (Additional Sampling) MBTA Right-of-Way/ Perfection Auto Radiator Methuen, MA. EE&G Project No. 91.1016-2MA.

Dear Mr. Mudholkar:

In accordance with your request and the guidelines established by Joanne Fagan of the Massachusetts Department of Environniental Protection (DEP), Environmental Engineering & Geotechnics, Inc. (EE&G) has collected additional soil samples along the above referenced right-of- way. The sample collection points were approved by the DEP as depicted on a plan titled "Soil Test Locations" prepared by Paul E. Donahue Associates, Inc.

The site under investigation is a section of the MBTA right of way located in Methuen, Massachusetts. Specifically, the site is located northeast of the intersection of Oakland and Railroad Streets and abuts property occupied by Perfection Auto Radiator located at 39 Oakland Street. Approximately 350-feet of right-of-way was evaluated and extends from approximately 85-feet south of the Oakland Street overpass to approximately 265-feet north of the overpass. The right-of-way consists of a single track at this location. The rails are supported by wood ties and stone ballast. The right of way is abutted by Perfection Auto Radiator, Al's Auto Repair and residential properties to the west and by Forster Lumber and a Laidlaw School Bus terminal to the east at this location. The ground surface slopes steeply from properties to the east of Railroad Street (Perfection Auto Radiator and Al's Auto Repair) towards the right-of-way in a west to east direction, with a total relief of approximately 15-feet. Perfection Auto/Methuen, Massachusetts Project No. 91.1016-2MA October 7, 1991 L ~ Page2 of 4

This investigation was initiated based on a Notice of Responsibility/Request for Information issued by the DEP on January 25, 1991. An October 11, 1989 letter prepared by Jet-Line Services, referenced subsurface contamination in the area of the drain discharge from the rear of the Perfection Auto Radiator facility. The letter contains information and manifests for the removal of contaminated soils in the area of the drain. This work was performed by Jet-Line for Perfection Auto Radiator. Soils samples were previously collected at this location of the right-of-way by EE&G and summarized in a letter report prepared on September 16, 1991. Refer to Appendix A for a copy of this report.

On August 11, 1992, EE&G personnel collected additional soil samples along the western slope of the right-of-way. Refer to Appendix B, Soil Test Location Plan. Soil samples were collected at depths approximately 2.0-feet below the ground surface utilizing precleaned, dedicated stainless steel hand shovels. Samples were collected in 500 ml glass jars with TeflonTM lined lids for total petroleum hydrocarbon (TPH) and petroleum fingerprint analysis in accordance with EPA Method 418.1 and ASTM Method D3328-78, respectively. Samples collected for volatile organic compound analysis in accordance with EPA Method 8240 were collected in duplicate 40 ml. glass vials with TeflonTM septa. All samples were labeled in the field, placed in coolers, chilled to 4" Celsius and shipped via overnight mail to Groundwater Analytical Services of Buzzards Bay, Massachusetts for analysis.

Soil samples were screened in the field for total organic vapors (TOV's) utilizing a Photovac Microtip m photoionization detector in accordance with the Headspace Methodology attached in Appendix C. TOV concentrations for the samples collected on August 11, 1992 were all nondetectable.

The analytical laboratory results for the VOC sample TS-1 detected a concentration of total xylenes of 510 parts per billion (ppb). No other VOC's were detected in this sample. A concentration of 100 parts per million.(ppm) was detected in the TPH sample TS-1. The petroleum fingerprint analysis for sample TS-1 indicated a TPH concentration of 200 ppm. No VOC's were detected in the sample TS-2. A nondetectable concentration of TPH was reported for sample TS-2. The petroleum fingerprint analysis indicated a TPH concentration of 110 ppm.

Nondetectable concentrations of VOC's and TPH were reported for the sample TS-3. The petroleum fingerprint indicated a TPH concentration of 71 ppm. Nondetectable concentrations of VOC's and TPH were also reported for sample TS-4. The petroleum fingerprint indicated a TPH concentration of 55 ppm. Perfection Auco/Methuen, Massachusetts Project No. 91.1016-2MA October 7, 1991 Page 3 of 4

The VOC and TPH analysis for the sample TS-5 indicated nondetectable concentrations. The petroleum fingerprint indicated a TPH concentration of 20 ppm. Nondetectable concentrations of VOC's and TPH were reported for the sample TS-6. A concentration of 78 ppm was reported for the petroleum fingerprint analysis for sample TS-6.

The soil sample TS-7 indicated nondetectable concentrations of VOC's. This sample indicated a TPH concentration of 45 ppm and a petroleum fingerprint TPH concentration of 82 ppm. Refer to Appendix D for complete laboratory results.

The variations between the TPH and petroleum fingerprint analysis results are due to the different extraction techniques utilized in each method. The extraction process for TPH Method 418.1 'generally does not allow for coal tarsand l ating oils to be detected. However, the extraction process for the petroleum fingerprint analysis utilizes a gas chromatograph which can more readily detect coal tars and lubricating oils.

The DEP Policy # WSC-400-89 "Management Procedures for Excavated Soils Contaminated with Virgin Petroleum Oils" has established guidelines for the reuse of excavated soils on-site. This policy establishes two guidelines, one for low environmental impact areas and one for high environmental impact areas. Based on a limited investigation, this site is considered to be a low environmental impact location. Therefore, the guidelines for reuse of soils on-site are "...soils headspace is equal to or less than 100 ppm headspace volatiles or 300 ppm TPH." No headspace volatiles were detected in any of the soil samples collected at this site. The laboratory analytical results indicated TPH concentrations for all the soil samples to be below 300 ppm.

The source of the xylenes detected in soil sample TS-1 may be attributed to oily surface runoff from auto repairs at Al's Auto discharge onto the railroad right-of-way. Additionally, automotive debris and other miscellaneous debris appear to have been discarded onto the right-of-way property at this location. During the sample collection visit on July 29, 1991, EE&G personnel observed Al's Auto personnel discarding auto parts, oil stained sands and other debris onto the right-of-way. Al's Auto Repair was cleaning and sweeping the service bays and parking areas of its operation at this time.

Based on this round of soil sampling and laboratory analysis, it appears that the railroad right- of-way is not the source of the soil contamination encountered at the rear of the Perfection Auto Radiator property. It ippears that-an-off-site release may be impacting the railroad right-of-way. EE&G recommends that no further action be taken by the railroad at this location. Perfection Auto/Methuen. Massachusetts Project No. 91.1016-2MA d/ October 7, 1991 Page4 of 4

It should be noted that all surficial investigations are inherently limited in the sense that conclusions are drawn and recommendations developed based on limited research information collected at State and local agencies an d a visual review of the site and the surrounding area. Confirmation of the environmental acceptability can only be determined by a subsurface investigative program and chemical analysis of the site's soil and groundwater.

Sincerely, EnvironmentalEngineering & Geotechnics, Inc

Kenneth J.K.Smith { Vice President Technical Services Manager-N.E. Region

TW/KJKS/tw Attachments m

APPENDICES GED

APPENDIX A Environmental Engineering & Geotechnics, Inc. 149 Cross Street Winchester, Massachusetts 01890 (617) 721-1013 FAX (617) 721-1007

September 16, 1991 Guilford Transportation Industries, Inc. Iron Horse Park North Billerica, MA. 01862-1688 RE: Laboratory Results MBTA Right of Way/ Perfection Auto Radiator Methuen, MA. EE&G Project No. 91.1016MA.

Dear Mr. Mudholkar:

On July 29, 1991, EE&G personnel collected surface soil samples on the slope in the area of Perfection Auto Radiator. Refer to Appendix C for sketch of approximate sample location. Soil samples were collected utilizing precleaned, dedicated stainless steel hand shovels. Samples were collected in 500 ml glass jars with TeflonTm lined lids for total petroleum hydrocarbon (TPH) analysis in accordance with Environmental Protection Agency (EPA) Method 418.1. Samples collected for volatile organic compound (VOC's) analysis in accordance with EPA Method 8240 were collected in 40 ml glass vials with TeflonTm septa. All samples were labeled in the field, placed in coolers, chilled to 4o Celsius and shipped overnight mail to Groundwater Analytical Services of Buzzards Bay, Massachusetts for analysis.

Surface soil sample SS-1 was collected in the discharge area of a drain outfall exiting the foundation of Perfection Auto Radiator. It should be noted that a clear, sweet smelling liquid was dripping from the drain pipe at the time of the sample collection visit on July 29, 1991. Unfortunately there was not enough liquids being discharged to collect the required sample volume for laboratory analysis. Surface soil sample SS-1 had the sweet smelling odor characteristic of solvents. Surface sample SS-2 was collected approximately 20 feet down the slope 'from SS-1. Surface sample SS-3 was collected another 20 feet down the slope from SS-2 at the base of the railroad ballast. Both samples SS-2 and SS-3 had the same sweet smelling odor as observed in SS-1.

Soil samples were screened for total organic vapors (TOV's) in the field with a Photovac MicrotipTm photoionization detector in accordance with the Headspace Methodology attached in Appendix D. The measured TOV headspace for soil sample SS-1 was 1,750 parts per million (ppm), SS-2 was 1,243 ppm and SS-3 was 951 ppm.

The analytical laboratory results detected concentrations of the VOC's acetone (630 parts per billion [ppb]), 2-butanone (trace), toluene (22 ppb) and xylenes (21 ppb) in the sample SS-1. A TPH concentration of 19,000 ppm was detected in the sample for SS-1. All VOC's were below the reporting limit (BRL) of the analytical equipment for the sample SS-2. The TPH sample SS-2 detected a concentration of 380 ppm. No VOC's were detected in the VOC sample SS-3. A TPH concentration of 930 ppm was detected in the sample SS-3. Refer to Appendix E for complete laboratory results. Perfection Auto/Methuen. Massachusetts Project No. 91.1016MA September 16, 1991 Page 3 of 4M

Other areas of concern observed during this sample collection visit included Al's Auto Repair property located at the intersection of Oakland and Railroad Streets. It appears that oily surface runoff from auto repair discharges onto the railroad right of way. Additionally, automotive debris and other miscellaneous debris appear to have been discarded onto the right of way property at this location. During the sample collection visit on July 29, 1991, EE&G personnel observed Al's Auto personnel discarding auto parts, oil stained sands and other debris onto the right of way. Al's Auto Repair was cleaning and sweeping the service bays and parking areas of its operation at this time.

Based on the results of this limited preliminary investigation, it appears that an off-site release may be impacting the railroad right of way. EE&G recommends that test borings and groundwater monitoring wells be installed and additional soil and groundwater samples be collected for laboratory analysis to provide additional information and confirm these conclusions.

The recommendations and conclusions provided herein are based solely on the scope of work conducted and the availability of information at this time. EE&G's opinions are based on professional expertise and no guarantee is implied herein. Perfection Auto/Methuen, Massachusetts Project No. 91.1016MA September 16, 1991 Page4 of 4

Sincerely, Environmental Engineering & Geot chnics, Inc.

omas Williamson, Jr. Project Manager / Environmen Engineer

TW/tw

Attachments ATTACHMENTS ATTACHMENT A

DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) NOTICE OF RESPONSIBILITY January 25, 1991 §7i& 60omwwzwrea/4 Jc/ &&

'Ni .xafercfokann~o~ston, - jnreczeat Geyoa, - Y ,ernwnrwea/d,-en/, I 4Uain,, .Aasacase&o/&Ot Daniel 5. Creenbaum IConmmissioner (617) 935-2160 January 25, 1991

Guilford Transportatinn RE: METHUEN - ERB-N89-0750 1ndun rries , Inc. Railroad. Right-of -Way I - c/o Br ton 4 faine' Railroad Request for Information Tron Hnrnso Par Pursuant to M.G.. c21E north 1Rillerica. MA 01862 aise 310 R 40.000

A-t i irin: Vinay Mudholkar, I'T Chief Engineer Dear ir. Mudholkar:

On May 10, 1989, D.ipartment personnel investigated reports concerning the release of waste oi frow PerfectjigaAto.Radiqtr..at 39 Oakland Avenue, Nrthl.m1. marsachuspt.ts which abuta- Massachulsetts Day Transportation Authril!y's (MBTAY railroad right-of-way. Because it appeared that the railri be'd had been excavated at one time with the excavated material (.. I; soil, railroad ties) placed along the embankment, soil samples were collected nui side the spill area on the embankment to obtain background total petrol euim hydroc'arbou (TPK) levels. The levels ranged from 270 parts per million (ppm) I:C to 2,945 ppm TPH. floisequent.iy you were instructed to enter into a contract with a cleanup contractor, approved by the Department to (1) perform necessary analyses of the want. materia] and make arrangements for its treatment/disposal: (2) perform analysis of the soil/water /groundwater impacted by the release to determink- contaminant conditions at the site after the initial response to the Ii incident; and (3) submit a report of their findings for review by the Departtm.. t

I; Pursuant to the Department's authority to perform information-gathering activities and its authority to investigate, sample and inspect records, rnnditiomus; equipment, practices or property tinder N.G.L. C.21E Sections 2, 4 and 8, you are directed to provide to the Department, within seven (7) days of t the date of Lhis letter, an incident report to include the following information:

I; (1) a br~uf account of why, how and where such release occurred; and

Orlginal Prinied on Recycled Paper aln esfiiale, to the best of your knowledge, of the quantity of vil/hazardotu material released;' and

a brief description of all emergency remedial actions that have buen and/or will be taken relative to such release: pJease incltide field scr.ening data and/or analytical data (soil/groundwater) dtescrib:ing contaminant conditions at the site; and

I labratory results of soil/water samples taken from the "cleaned up" environmental media impacted by the release; and

(S phomntoopiets of all waste manifests for the oil/hazardous material relvased; arid

(V a derailed description and a timetable of measures you plan to implenent: to prevent future recurrence of such incidents.

- - --- Th: .information is required by the Department in order to ascertain thal: vlo:4ro.p is prored i.ng consistently with Departmental giuidelinifs and sIlandflank for.clearnrp art..ivit.:ler. G.!,. c.21? Section 4. Moreover, tho en]lect'an of such information constitutes ant assessment action under Sections four ain' ijight of the :tafute comprised of information-gathering activities nmid-rd tn b"4i0tt evaluate the need for further emergency response actions at this silt of a releasA .f oil/hazardous material (see 0.L. c.1F Section 1, -- "'assessIent":').

Depending on the information generated by the above work, the Department may refqrre additional investigations, studies and response actions in conforinarice with 110 CI4R 40.000.- If you fail to take these act-ions or if youi fail In n-rform these tasks.in accordance with the standards of the Departioril , the Departmen. may perform response actions in your st ead and recover il.. conl.s from you in accordance with the provisiods described above.

Voi are hurcehy notifiAd that failure to respond to this letter in a timely a:Irsnor, ix a violation o[ 310 CHR 40.008 and the submission of false and inneriurate information in a violation of 310 CuR 40.009 and 40.011. Any such violations may subject you to legal action including criminal proserutin, court-imposed civil penalties, administrative orders or civil admuinistrative penalties assessed by the Department.

Finrlherinore, if you refuse to provide the Department with the - in(ormalion requerted above, it may be necessary to order its production under the authroril y of .Se-tion six of c.2.E or to seize them pursuant to the authorily of Section eight thereof. In addition, refusing to provide the inforno;ifil requestled couldi subject you to civil administrative penalties pursuant lo N.G.. Chapter 21A.

Vic Thi'nartment in willing to consider any reasonable and appropriately posed claim of cranfidentiality relating to the requested records hut cannot S.:mj colrart Joanpe Hichaud if you have any questions, rigarding rhi ui:utig r .. d rei?(r to c:sen numbnr ERB-N89-0750.

Very truly yours,

96anne Hichaud SJ~iiroMental nginer

Anthony R. uarciariello Chief, Emergency Response Branch

ce: Dr.r. rSC, ijv. of Renpone & Remedi at on, One V. n ter St., Bs on, W 02108 - 4 01been 1B011 .- 'Iiien Fire hDopartmut MBTA, 30 Parlk Plaza, BWionn, HA 02116, Attn: Andrew Warren, Oirectnr of Ral. Esta'e Kanagement Page 2 This letter is to inform you in writing that:

(1) The Department has determined that a release of petroleum materials has occurred at the subject site.

(2) Information available- to the Department indicates that you as operator of the subject site, are a liable and "responsible" party pursuant to Section 5(a) -of Chapter 21E.

(3) Additional information is -needed to better evaluate the need for further emergency response action at this site. Please, refer to page 3 for the requested information.

(4) Should you fail to implement those actions deemed necessary by this Office, the Department may, pursuant to M.G.L. C hapter 21E, take or arrange for any and all necessary actions at the site. If public funds are expended under such conditions, Chapter 21E, Section 11 stipulates that the Attorney General of the Commonwealth of Massachusetts may initiate legal action against the responsible party(s) to recover all costs incurred by the Department in the assessment, containment, and removal of any release or threat of release of oil or hazardous materials.

(5) The liability of responsible parties in (4) above includes:

a. Administrative costs incurred by the Department in handling this matter. b. Interest charges on the total liability at the statutory rate of 12% compounded annually;

c. Treble costing (i.e., three (3) times the total amount- -of -response costs the Department incurs); and

d. All damages for the injury, destruction or loss of natural resources due to the release.

This liability constitutes a debt to the Commonwealth. The debt, together with interest, creates a lien on all your property in the Commonwea'ltih. Lien placement will increase your administrative cost liability. This liability will further increase if the Department is required to go to court to recover its costs. Administrative and legal costs for simple spill cases which reach' this stage total.at least $3,300.00. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Commonwealth may recover that debt or any part of it in an action against you. You may also be liable under M.G.L. C.21E Section 11 for up to $100,000 in fines or penalties for each violation of C.21E as well as for additional penalties or damages pursuant to other statutes or common law. - J

Page 3

Your acceptance of responsibility for such release means that: (1) You* will- enter into a contract with a cleanup contractor, approved by the Department to (a) perform the spill - cleanup as deemed necessary by the Department; (b) perform necessary analyses of the waste material and make arrangements for its appropriate treatment/disposal; and (c) perform analysis of the soil/water/ground-wa-ter- impacted by the release to determine contaminant conditions at the site after the inital response to the incident; and (d) submit a report of. their findings for review by the Department. And (2) you will pay for all response costs incurred by the Department due to such release.

Pursuant to the Department's authority to perform information- gathering activities -and its authority to investigate, sample and inspect records, conditions, equipment, practices or property under M.G.L. c. 21E Sections 2, 4 and 8, you are directed to provide to the Department, within seven (7) days of the date of this letter, an incident report to include the follwoing information:

(1) a brief account of why, how and where such release occurred; and

(3) an estimate, to the best of your knowledge, of the quantity of oil/hazardous material released; and

(4) photocopies of all waste manifests for the oil/hazardous material released; and

(5) laboratory results of soil/water samples taken from the "cleaned up" environmental media impacted by the release.

(6) a detailed description and a timetable of measures you plan to implement to prevent future recurrence of such incidents.,

You are hereby notified that failure to respond to this letter .An. a.. timely manner, is a violation of 310 CNR 40.008 and the submission of false and inaccurate information is a violation of 310 CMR 40.009 and 40.011. Any such violations may subject you to legal action including criminal prosecution, court-imposed civil penalties, administrative orders and/or civil administrative penalties assessed by the Department pursuant to M.G.L. Chapter 21A. /

Page 4

It is to your advantage to respond to this request for information in an .adequate and timely manner, demonstrating that you have acted appropriately in taking necessary response actions relative to this release of oil and/or-hazardous materials.

Depending on the information generated by the above work, the Department may require additional investigations, studies and response actions in conformance with 310 CMR 40.000. If you fail to take these actions or if -you fail to perform these tasks in accordance with the standards of the Department, the Department may perform response actions in your stead and recover its costs from you in accordance with the provisions described above.

Your response to the requested information and any further questions regarding this matter should be directed to Joanne Michaud at the letterhead address or 935-2106 and refer to case number ERB-N89-0750.

Very tr y yours,

Joanne Michaud gvonme tal Engineer

Anthon .G arciariello Section Chief Emergency Response

RJC/JM/ram cc: DEP/BWSC, Div. of Response & Remediation, 1 Winter St., Boston, MA 02108 DEP/BWSC, Div. of Fiscal Mgmt./Cost Recovery, 1 Winter St., Boston, MA 02108 Methuen Board of Health Methuen Fire Department MBTA, 10 Park Plaza, Boston, MA 02116, Attn: Andrew Warren Director of Real Estate Management

Enclosures: '(1) List of DEP-Licensed Spill Cleanup Contractors (2) DEP Policy #WSC-89-004: Minimum Standards for Analytical Data for Remedial Response Actions I I. I I I APPENDIX B

JET-LINE SERVICES REPORT October 11, 1989 I I U I I U I U I I

I 42

~ t

I - .. Fc - 1

October 11, 1989-

Ms. Joanne Michaud - The Commonwealth of Massachusetts Department of -Environmental Protection INort~heast Region - Emergency Res ponse Five Commonwealth Avenue Woburn. MA 01801

Re: Perfection Auto Radiator-Contaminated Soil Removal/Disposal 39 Oakland Avenue - Methuen, Massachusetts (31--32031 Dear Ms. Michaud:

Jet-Line Services., Inc. is pleased to submit this letter attached documents on behalf of our client re.-lative to tA- Perfection Auto Radiator facility located at 39 Oakiand Av Methuen, Massachusetts (the Site). These documents are tranemitted in response to our telephone conversation of September 19, .1989. Attached please fiid the Uniform Hazardous Waste -Mani fest- (U MAC665101) documenting the excavation, transportation and - disposal of three (3) drums of petroleum contaminated sois in late August 1989. The soil was excavated from the visually contaminated area located on the Boston & Maine Railroad property immediately surrounding the drain hole in the rear walj of the Perfection Auto Radiator facility (see attached Site Sketch). The visually contaminated soil was hand e:cavated to a depth of approximately 2.5 feet in the approximate area out lined in the Site Sketch.

Also attached are copies of the laboratory certificates of analysis for samples collected on July 21. August 18, and September 5. 1989. The July 21 sample was collected from thS - visually contaminated soil prior to excavation and analy.zed or total petroleum hydrocarbons (TPHCs) and volatile organic compounds (VCs). The TPHC concentration detected in. this 5amp- was 453 milligrams per kilogram (mg/kg). The VOCs detected in this sample included tetrachloroethene. toluene. ethyl ienzenc - xylenes, and the 1,2/1,4 dichlorbenzenes in concentrations o 0.052, 0.167. 0.105, 0.659, 0.104. and 0.143 mg/kg. respectivev. It was decided that the TPHC analysis, would be req:uired for further characterization since the total VOCs de'tCted in tir initial sample were. relatively low at .1.23 ma/kg. T1TP1C concen tra tion.- Of the1 Augu.St. 18i SOil SAmple1.l0u u o~ - excav tion of the visually cont-aminated ll wc ... z1t nw/i. third sample was collected from the area outside the excavation/visually contaminated area on September 5. 198!9 t

IJET-LINE SERVICES, INC. e 8 Progress Drive, Dover, New Haipshire 03820 e (603) 749-5735 e FAX: (603) 749-9095 Page Two Ms. Michaud October 11, 1989

determine the extent and/or -background contamination on the * property. The TPHC concentration of this sample and a- laboratory selected duplicate were 2,762 land 2,945. mg/kg,. respectively.

The area of the Site has a long history of industrial use. The contaminated soil was excavated from a railroad bed area which may have a relatively high res'idual petroleum contamination background. It is believed th t the background contamination should be determined prior. to establishing cleanup goals for t.h:1 area rather than utilizing pre-determined values.

It has been a pleasure providing this letter and the attached documents to you. Please call if you have any questior Very truly yours

Richard D. Mansfield Project Engineer

C. L. Lambert - Perfection Auto.Radiator

A\PMMLTI.RDM r '? ENVIRONMENTAL QUALITY ENGINEERING I I;. gON OF SOLID AND-HAZARDOUS WASTE One Winter Street Boston, Massachusetts 02108 /- . "j * ..*M a anm nrier I - 1, GenerUtorUS EPA 10 No. Maniest 2,Paga I Iinarmuintin in the hoadcre . ~lrxA.,fi,L -. .. I J ?.C.T. of I1 It rinot reqifro by FcdorI la.. _ _~ A.Stirs Mar.looecumnt Iunt *j e *1 - Ti 4

I o ame 6. USEPA IDNumber C.Stata Trent.L 1 ,Lfie Servicesj Inc. P4 jA 0i6 2j Ir I 1 a. US EPA 10 Number D.Trenaeorior'sPonol 0&3J92fJ Cpn 2 crnpeny Wine InJ~mr C. I ians. Il bito i 1. t Olfree nol 5Sl ddless 1, US EPA ID Nurnber hem - A7F .-d ne of Lowell F,Tranporter's Phone I I 263 Howard St. G.Sta.ceity'a 1 D Not Reaulre d Lowell, M l18i i041710i7i5 7314 H.uoacity*s Phon.< 508-937-72%96 )2.Containers 13. 4. U S DeOT OcripOt n cluding Prqer Shipping Nam*, Hazard C/eg, andssD, Nfi ber ~o j' Toal Unit Watyt No. i ~No. Tyos ouantity Wtivoi '011 contaminated solids N.0.S. - Mass. Regulated (MA01) 001 0 3 DMOj 12010 1A0

AdditionsiDescriptions for Materiala Listed Above (inclAdspilysicaird sate Snderardcode-1 K. HAndling Codes lor Weses, .ListedJ-- WAbove,JWL.L d _____Lj oil contaminated soil.

I. Special Hondling Inatructions and AdditIonsl information

5.OU&AAIOA5 CE CA l(CATION I tere by doclar, that the teninti of iniscortsignnent are fully and mccurItly denCbed above y DegParskOsrg name and wreclajiked. paeed. marsetdand lteta(. en; ro in ll especuIn proper condition 1DOV'nsori bymnoconfy eccoraing t applicable acoiuenal and natonal ggrernmans laguetgona. Im Ma totge gynIsty gmneral6er. i tnili i have r oogrm I Place to rle duC the volume and teitity at wese genura ed tOe the agt hve d e rm.nbd toss t e ar'-.Iy ODst ibra and nat I hove aatlid INA 1t1tigande method l twoaIlmeAt. storegs. or dispossl currently eveliabie to me *Pcntic mainimves ti presen and luitvre thes at to human ne amAno t In nven nt ORW Iam a imals usniity geneeRtnv.I have made a good leal ntojnhimite my wasts getheration an ra'te the 0s6 Welse neAtgsment met hit ILAu' it e to me arid that I

an Ypar . $i

1 5 Trentorter 1 Acknowledgement of geco Cf M bae

jRkoldghin fFacer~ of Mmmermtl oat Priied/TypedName -Month DowVaa I I Stmocreprtcvinadcetion SpiceI' i 1I1

a ..A

Facility Ownyr or Operator; Ceritliceion ofsocatpt f haciardog, rinsteoale coveiedby this manifest exceot oe noted In itm I H. Doi. Print rpedNerne r0 bjg sciaIa,/ e ~ortA Day Year

* tin 6100-22 (Royv. 0.861 PreyIouG editions era obsolete. r I I,..,

I'I

JET-LINE CER T.?FICATE OF ANALYSIS

I..

TO: PERFECTION AUTO RADIATOR DATE REPORTED: 7-21-89 DOUG AucusTUS DATE RECEIVEo: 8-3-09 Joe NUMBER: 3 1-32035 LAS NUMBER: 4277

SAMPLE DESCRIPrION:

SOIL

PARAME TER ANAL YSIS DETECTION LIMIT E. G

SNI 5 OIL & GREASE (TPHC), MG/KG 4 E O 0.2 ll

- VOLATILES SEE ATTACHEC EPA 22

SUPERVISOR:

JET-LINE S RVICES. INC 263 HOwARO STREET LOWELL, NA 01352 I(508) 937-7294 - 1'; up'

U. / OL.A TILE-ORANIC ANALYSIS DA-T A

LAS SAMPLE ID 4277 DA TE RUN; 3 -2-8 r CLIENT SAMPLE ID: PERFECTION AUTO RADIATOR DILU rON FACToR: 10.0 DATE RECEIVED .7-21-89 . X: SOIL ME THOD: LOCA TION: DETECTION LINIT CA s&B .VALUF 74 -87-3 CUL ORONETHA NF ND 100 74-83-9 VSROMMETHANE NO 75-01-4 VINYL -CHLORIDE ND 100 75-00-3 -CHLOROETHA NE ND DO 75-09-2 NMETHYLENE CHLORIDE ND 50 75-69-4 tRICHLOROFLUOROMcTHANE NO 50 75-35-4 I,1-DICHLOROETHENE ND 50 75-35.-.3 1,1-DICHLOROETHANE ND 50 156-60-5 TRANS-1,2-DrCHLOROETHENE ND 50 67-66-3 CHL ORoronM ND 50 107-06-2 1, 2-DICHL ORoE HA NE ND 50 71-55-6 1, 1, 1-TRICHLOROETHANE ND 50 56-23-5 CARSON TETRACHLORIDE ND 50 705-27-4 BRONO ICHL OROME THA NE ND 50 79-34-5 1, 1,2,2, -TE TRACHLOROE THANEND 50.- 73-87-5 1,2-DICHLOROPROPANE ND 50. 10061-02-6 TRANS-i,3-DICHLOROPROPENE NO 50

79-01-6 TRICHLOROETHENE . .. ND 50 124-48-1 DIGROMOCHL OR OME THANE NO 50 79-00-5 1,1,2-TRICHLOROETHANE ND 50 71-43-2 BENZENE - ND 50 10061-01-5 CIS-i1,3-DrcHL.OROPROPENE NO 50 110-75-8 2-CHLOROETHYL VINYL ETHER ND 100

75-25-2 BROMOFORM ND 50 127-18-4 ITTRACHLOROETHENE.. . 52 50 108-88-3 704LUENE - 16;7 50 108-90-7 CHLOROENZE'E ND 50 100-41-4 ETHYL BENZENE 105 50 TOTAL XYLENES 659 .50 .1,2 DICHLOROBENZENE 104 50 1,4 DICHLOROBENZENE 143 50

It *. / --- 9 I 5 17MW 36824-)

CERTIfCAr OF ANALYSIS I.

TO: PERFEcroN A ITO RADIATO DATE ?EPOR TED: 8-29-89 DoU Aucusru OA TE 8-18-89 - JO N UMBER: 31 -32035 s . LAs N UMB ER| 4401

SAMPLE DESCRIPTION I

CONTAMINATED SOuL PARAMETER 1 ANALYSIS DETECTION LIMIT ME TH6D

ToTAL SoLIDS, X 78.0 S 209A4 OEL & GREASE (TPHC), vc/KG 1,216 1.0 SM 5033

SUPCRVISOR.

Jer-LINE ERVICES. IN *4 263 HOWARD SrRcEr * LOWELL, MA 01852 (508) 937-7294 I I #rr I

- JatT-LINE. CERTIFicATE oF ANALYSIS

ITO: PERFECTION A UTO RADIATOR OATE REPORTE D: 9-8-89 DOUG AUGUSTU S , - OATE RECEV0: 9-5-89 JOS NUMER: 31-32035 LAS NUMBER: 4444

SAMPLE OESCRIPTION; -I

OrL CONTAMINATED SOrL

PARAMETER ANAL YSIS DE rEC TION LINIT METHOD

To rTAL Sams, X 85 SN 209A (DUP) QIL & GREASE (TPHC), MG/KG 2762 2945 1,0 511 5038

SUPERVISOR:

JEr-LINE SE'VICES, INC. * 263 HOWARO SREET * LOWELL, NA 01852 (508) 937-??94 I; 1 ~ $______

7j RESIDENTIAL: PROPERTY U I - . I V /4R r-i4 DRIVEWAY DRAIN I .PARKING AREA HOLE U 0< .7-21-89 cr r

0 z EXIST ING BUILD [NG 39 OAKL AND AVE. 0 m-

OAVI ANF A\1E .

SITE SKETCH LEGEND PERFECTION AUTO RADIATOR 1 39 OAKLAND AVE. 7) EXCAVATION 0/ METHUENIMA. ; SAMPLING LOCA

I -I Region Case: CLOSED PENDING Case N0. DEQE OIL AND HAZARDOUS MATERIAL SPILL/RELEASE INCIDENT NOTIFICATION AND INSPECTION REPORT . Sr AMENE ED ED . RESPONSE: INITIAL FIYLD TELEPHONE ii FOLLOW-UP 21E NC TIFICATION l . MUNICIPALITY: 4. INCIDENT 1 T REPORTED: .A DES' Dote - -. Time AM/PM -E5. INCIDENT OCCURRED: Date Time AM/ Ph", 6. PERSON WHO 1ST NOTIFIED DEQE: - m

Name/Address J-rt CSh Lb A'2h''; (t ij.fsi (,t r- Tel. # OIL OR HAZARDOVS MATERIXL RELEASED: a. Naie: CAS1# - b. Amount Reported: Actual: c. (Oil/Not Oil Virgin/Waste N'on-PCB/PCB ppm Soil Contamination YIN d. Source: vehicle fuel tank drum tanker truck boat railroad tank/enoin: above-ground tank 1 below-ground tank transformer . pipe hose otC e. Samples Obtained: Yes (No).- f. Drums Retained: Yes No. (if yes, specify where sent)

g. Release Type:' Leak Overfill Rupture Tank Removal Spill Dumping Oth-2r BRIEF DESCRIPTION OF INCIDENT: 0 I'll 4 -

POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEQE ' a. PRP notified Department Date: Time:

b. Name/Address I'c 1'kfll p, / I. ((7 CI..a '.V/ Te'a tt______Name/Address I,, 1 -I , Tel. # c. PRP received Notice of Responsibility: Verbal: Date Time - Field: Date E //I / N/ Time Office: Date Time d. Responsibility accepted and proper actions taken by responsible person: (Yesy No e. Name of cleanup contractor hired by responsible person: REGIONAL RESPONSE ACTIONS: a. State-cleanup contractor: A/ Service Category SC SSC SSI HM b. Contractor arrived on-scene: Date Time AM/PtA

c. Further field response actions needed: e No . (if yes, specify) --

d. Enforcement actions taken/recommended: Yes to (if yes, specify) -

.e... Cost recovery recommended: Yes .. Maybe - 11. INTRA-AGENCY NOTIFICATION/REFERRAL-

a. Name(s) of DEQE employee(s) notified: ...... _>_"

b. Case referred within DEQE to: ... !:. - B OTHER AGENCIES NOTIFIED BY DEQE OF SPILL/RELEASE INCIDENT. Name: D ae: Name: Date: Contact: Title by: Signature t YDISTRIRUTION:ory prep-red WHITE/REGIONA. OFFICF YF1fl)W/ROSTfN fit r- l i r;nrrr'. . - THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING

NOTICE OF RESPONSIBILITY PURSUANT TO M.G.L CHAPTER 21E

TO: <000 'At 1.' iR #: : - .1

Ont~ A'P I. fs;j: at4(HLh I On at. (p.m/na.the Department of Environmental Quality Enginedring (Department) responded to a release/threat of release of oil/hazardous material at S in a J Mi ,Massachusetts (the site). Preliminary indications are that pursuant to section 5 of M.G. L. Chapter 21 E is/are a party responsible for assessment, containment and removal actions necessitated by this incident. Massachusetts General Laws, Chapter 21 E, places liability on responsible parties to: (1) pay for all response action costs associated with the incident and (2) compensate for any damage to natural resources resulting * from the incident. You may assume responsibility for emergency response actions/costs by paying for all response costs Incurred by the Department relative to this incident and immediately performing the items checked off below: Hire a spill cleanup contractor acceptable io the Department to take all necessary emergency response I actions (i.e. assessment, containment and/or removal) as required by the Department. fl Dispose of the contaminated soil generated at the site in conformance with the Department's current policies for management of virgin petroleum-contaminated soils. Written approval must be obtained from the Deparignt prior to removal of the soil. Collect(soil/fater samples bet re andafte.r cleanup f(om the. impacted environmental media and submit results or~ a certified Iaborat analyis f7

Submit a report providing an accurate description of the incident, response actions taken relative thereto, and site, conditions (including supporting documents) Immediately or upon receipt of analytical results.

O Other-- 4I I A :v''' *'tf 7':/ H

The above actions must be performed immediately and/or completed no later than / - - Depending on the information/data generated by the above work, the Department'may require'additional remedial response actions. If you fail to complete the response action(s) required by the Department within the required timeframe, the Department will take appropriate response actions and seek to recover all costs, charges and damages. By accepting responsibilitydi11 for conducting the required response actions now you can: Preliminary Indications are that pursuant to section 5 of MG. L. Chapter 21E is/are a party responsible for assessment, containment and removal actions necessitated by this incident. Massachusetts General Laws, Chapter 21E, places liability on responsible parties to: (1) pay for all response action costs associated with the incident and (2) compensate for any damage to natural resources resulting from the Incident. - You may assume responsibility for emergency response actions/costs by paying for all response costs incurred by the Department relative to this Incident and immediately performing the items checked off below: Hire a spill cleanup contractor acceptable to the Department to take all necessary emergency response actions (i.e. assessment, containment and/or removal) as required by the Department. Dispose of the contaminated soil generated at the site In conformance with the Department's current policies for management of virgin petroleum.contamirated soils. Written approval must be obtained from the Department prior to removal of the soil. Collect soil/ydater samples before andatt a m the, Impacted environmental media and submit results li certified.laboratry analy5isf6

Other : v .:~. /-*~/*.

The above actions must be performed immediately and/or completed no later than' '' Depending on the information/data generated by the above work, the Department'may require'additional remedial response actions. Ifyou tail to complete the response action(s) required by the Department within the required timetrame, the Department will take appropriate response actions and seek to recover all costs, charges and damages. By accepting responsibility for conducting the required response actions now you can: -minimize administrative costs incurred by the Department in handling this matter (In spill cases, administrative costs Incurred by the Department are at least $1,000.00);

- avoid interest charges on the total liability at the statutory rate of 12% compounded annually: and

- avoid treble damages (i.e., 3 times the total amount of response costs the Department incurs).

This liability constitutes a debt to the Commonwealth. The debt, together with interest, creates a lien on all your property In the Commonweahh. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Commonwealth may recover that debt or any part of it in an action against you. You may also - be liable under M.G.L. C. 21 E, section 11 for up to $100,000 in fines or penalties for each violation of C. 21 E as well as for additional penalties or damages pursuant to other statutes or common law. The Department encourages potentially responsible parties to provide or arrange for response actions to minimize the Department's response action costs for which you may be liable. The Department's objective is to ensure public health and safety and to protect the environment. Only with your help can this goal be achieved. Please.submit the requested Information and direct any questions regarding this matter to

'lA, -tat the A/T->6 I Regional Ofice,2 ...... 4L.j...a asacuett, telephone # 191. ;.~~

V---ery truly yours,

"[,,Name and Title of DEQE Official

On at approximately I.

- >of the above DECE Office served upon

personally by certified mai - a copy

of the above "Notice of Rosponsibility'. Person on-scene agrees does not agree to take the response actions deemed necessary by the Department.

Copy Distribution: Whito/Potontial Responsible Party Yollow/Boston Pink/Rogion Goldon Rod/lingion

n - 4 DEP OHM SPILL/RELEASE INCIDENT REPORT late: ./ 9L.Z22 Region: AJ6Lo 'Case: C Closed -'Pending ER #: 1. RESPONSE: 0 Initial Office C Foljpw up Office . . Amended Site #. * Initial Field [B Follow-up Field C 21E Notification

. MUNICIPALITY: /l / ' 4. INCIDENT 1ST REPORTED: AM/PM . ADDRESS: y c. / .- Date: / / Time: 5. INCIDENT-OCCURRED: 6.. PERSON WHO 1ST NOTIFIED DEP: Date: L Time: AM/PM Name/Address: Tel. # . OHM: a. Name: CAS #: b. AMOUNT: Reported: Actual: c. Category #: a. Oil/Not Oil Virgin/Waste -Non PCB/PCB ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank drum tanker truck boat railroad tank/engine above-ground tank below-ground tank transformer pipe hose other f. RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill Dumping Other_ _ DESCRIPTION OF INCIDENT:

POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP: a. PRP notified the Department Date: / / Time: AM/PM b. Name/Address:- Tel. # Name/Address: Tel. t c. PRP received Notice of Responsibility: Verbal/Field/Office Date: / Time: AM/PM EO. RESPONSE ACTIONS: a. Responsibility accepted and proper action taken by responsible person: Yes No b. Name of cleanup contractor hired by responsible person * c. State-cleanup contractor: d. Service Category: SC SSC SSI HiEM ASB e. Contractor arrived on-scene: Date: Time: AM/PM f. Further field response actions needed: 'Ye) No (specify)

g. Noncompliance IssueS: h. LUST: Federal Eligible Yes 1. INTRA-AGENCY a. DEP Staff Notified: ER Lead: b. Refemtl within DElP to: (Name/Program/Prog. #t) 12. OTHER AGENCIES NOTIFIED BY DEP OF SPILL/RImFEASE INCIDENT: Name: Date: /./ Name: Die: - ..

*Contcl/hone Comet:i/ hlonew- teportpreparedby: Signature -

I COPY DISTRIBUTION: WIH1ITE/REGIONAL OFFICE - YELLOW/IOSTON PINK/GOlIDEN ROl/REGIONAL OFrtCF.RIv. Ir-Jii DEP OHM SPILL/RELEASE INCIDENT REPORT ate: ' / ' Region: Case: [] Closed C Pending ER #: 0 Initial Office C Follow-up Office 3 Amended Site # IRESPONSE: C Initial Field 0l Follow-up Field 0 21E Notification MUNICIPALI Y: 4. INCIDENT 1ST REPORTED: ADDRESS: ___d tDate: - Time: AM/PM 5. INCIDENT OCCURRED: IPERSON WHO 1ST NOTIFIED DEP: Date: L Time: AM/PM Name/Address: Tel. # OHM: a. Name: CAS#: b. AMOUNT: Reported: Actual: c. Category #: d. Oil/Not Oil Virgin/Waste Non-PCB/PC3 ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank drum [ tanker truck boat railroad tank/engine above-ground tank below-gropnd tank transformer pipe hose other f. RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill Dumping Other DESCRIPfION OF INCIDENT:

POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP: I.PHIP notified the Department Date: / / Time: A M/PNI b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date: Time A P t RESPONSEACTIONS: a. Resr'ons hitv necep ed1 nd nrM'r action taken by responsible person: Yes No

U \CTR D~BY DE OFSKLL REL CSTE-

.'. DEP OHM SPILL/RELEASE INCIDENT REPORT late-, /v Region: A1_> Case: 0 Closed 'ending ER #: / I 1. RESPONSE: 0 Initial Office OFollovJ-up Office C Amended Site # * Initial Fie)d [ Follow-up Field . 21 E Notification . MUNICIPALITY: 4. INCIDENT 1ST REPORTED: ADDRESS - Date: / Time: AM/PM 5. INCIDENT OCCURRED: 6. PERSON WHO 1ST NOTIFIED DEP: Date: / Time: A M/PM I Name/Address: Tel. # OHM: a. Name: CAS #: b. AMOUNT: Reported: Actual: c. Category #t: d. Oil/Not Oil Virgin/Waste Non-PCB/PCB ppm Soil Contamination YeN/No e. SOURCE: vehicle fuel tank drum tanker truck boat railroad Lank/cnuae above-ground tank below-ground tank transformer pipe hose other f. RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill Dumping Other 18. DESCRIPTION OF INCIDENT:. - - -

9. POTENTIALLY RESPONSIBLE PERSON IDENTiFIED BY DEP: a. PRP notified the Department Date: / / Time: A M/I\ b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date: / Time: A%2% I10. RESPONSE ACTIONS: a. Responsibility accepted and proper action taken by responsible person: Yes No b. Name of cleanup contractor hired by responsible person * c. State-cleanup cotractor:- d. Service Category: SC SSC SSI ! .V c. Contractor arrived on-seene: Datc: / / Time: . \ f. Further tield response actions needed: .5-s No Lspecify

g.Noncompliance Isane- h. LUST: Federal Eliible Yes No * 1. INTRA-AGENCY NOTIFJCATION' REFERRAL: *a. DEP S2ff Notified: ER Ie

N mj :I) \1n ---- DEP OHM SPILL/RELEASE INCIDENT REPORT Date: Region: Case: 0 Closed E Pending ER # -:- 1. RESPONSE: C Initial Office . Follpw-up Office Amended Site # * Initial Field , Follow-up Field C] 21E Notification

2. MUNICIPALITY: III -.? - 4. INCIDENT 1ST REPORTED: Time: AM/PM * 3 . AlDRES Date: / 5. INCIDENT OCCURRED: 6. PERSON WHO IST NOTIFIED DEP: Date: / / Time: AIM/PM Name/Address:. Tel. # 'i.OH M: a. Name: CAS#: b. AMOUNT: Reported: Actual: c. Category #: d. Oil/Not Oil Virgin/Waste Non-PCB/PCB ppm Soil Contamination Yes/No e. SOURCE: vehicle fuel tank drum tanker truck boat railroad tank/engine above-ground tank below-ground tank transformer pipe hose other f; RELEASE TYPE: Leak Overfill Rupture Tank Removal Spill' Dumping Other 8. DESCRIPTION OF INCIDENT: -

9. POTENTIALLY RESPONSIBLE PERSON IDENTIFIED BY DEP: a. PRP notified the Department Date: Time: AM/PM b. Name/Address: Tel. # Name/Address: Tel. # c. PRP received Notice of Responsibility: Verbal/Field/Office Date: - Time: A.M/PM 0. RESPONSE ACTIONS: a, Responsibility accepted and proper action taken by responsible person: Yes - No b. Name of cleanup contractor hired by responsible person c. State-cleanup contractor: d. Service Category: SC SSC SS1 I-i ASB e. Contractor arrived on-scene: Date: Time: AM/PM f. Further field response actions needed: *Yes.or No (specify)

g. Noncompliance Issues: .h.LUST: Federal Eligible Yes No 1. INTRA-AGENCY NOTIFICATION/REFERRA L: a. DEP Staff Notified: ER Lead: b. Referral within DEP to: (Name/Program/Prog. #) 12. OTIIER AGENCIES NOTIFEI) BY DE1P OF SP11 .itIElASEINCIDENT:

Name: Date: / Name: -- .he: Contact/Phone: Contact/Phone: Report prepared by: I( /Ui { '1 .' Signature: --

COPY ISTRIBUTION: Wi/r EGJONAL Ovuli l.4'J)W/HOWX: PIN. ' o': Po':-: I THE COMMONWEALTH- OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING LAWRENCE EXPERIMENT STATION I

SPECIAL ANALYSIS

CITY/TOWN METHUEN

COLLECTOR J. Michaud

IR CE A 3'9 Oa kland Avenue Bottom jJRCE B 39 Oakland Avenue Right // - a RCE C 39 Oakland Avenue Center

IRCE D 39 Oakland Avenite Cente( - duplicate

OURCE E

*JRCE F A B C D E F -Ur- uPLE NUMBER 004 005 006 duplicate

DATE OF COLLECTION 4/23/90 4/23/90 4/23/90 4/23/90

ITE OF RECEIPT 4/23/90 4/23/90 4/23/90 4/23/90 - TE ANALYZED 4/26- 4/26- 4/26- 4/26- 5/18/90 5/18/90 5/18/90 5/18/90

tal petroleum drocarbons. ug/q 1400 270 5000 6200

I . .

The samples.were analyzed according to Method 503D, "Extraction NethoK or Sludge Samples" and 503E, "Hydrocarbons", Standard Methods, 16th : . 5. S0p.1, . The presence of- petroleum hydrocarbons was contirmed b, C omatography/FID. N

COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING DIVISION OF SOLID AND HAZARDOUS WASTE One Winter Street Boston, Massachusetts 02108

. poe frtr nr ed icruseonelito 112-pitchitypewiiier.I UNIFOflM HAZARDOUS 1.- Genat'or USEPA 10 No. Manilest . 2. Page I lnlolsson0 r r l r s'r i iis WAS I E MANIFEST | . ' || - I | I I 1 it 60 of l issol cf'sd.rci by rdi'rmmlv. 0 :inesn's Nattri' Mne mid Mailing Ardiltens I- %t- ') .a A. Slate Mani est Docunm Nkrrrr ts E10 1 . * j ,iA.1I, x9 I. Nul 65101 - 0. State Gen. ID -. A 4 Grriesaii's Phroner . wJ-._- J t . I ,rore 1:I ComriarnName 6. - US EPA I0DNumber CStato Trans. IDf2 9 Jet-LiPe'_Sprvices, Inc. 1Ir1i/0I i 61 2 ii7i 1819 0 1 I 'I P11.1/ 1 . 4 I I r1irrislO 2 ComtinvName 8. USEPA tO Number S ansponer-sPhine1 1r II 1 II I I I] I i 1i SI ~asIt l'dis D l]qianrd FfnCIbly Namie and Site A ddicss . to. US EPA ID Number I CK-ech - /8/A Jct-Line of Lowel F. Tansportes Pt'-,o I I r I.- ;613 HiewArd St. G.Stale Facilty's Not Required L.. P.I AliII li 41 71 () It I iZI 31 It. Fnciiliy's Phone I 58493/-Z96 12. Cont iners 13, a 1, 1. 1)S 001 D0.se.rilinr l1rlr:rsbwsig /',oprc Shippitg Nanie, imated Class, end ID Nuribel T o1al UnI Waste No No. Typo ouarntity WI.Vo 01 conLainated solids :Lo.s. Ilass. Pegulated (A010 -p II A I 11*

I I C.-

C A:

-- I dt 111L11J21__1JMLI r. I I II I hI ii J Addill Desciorrlinns Ie Ma ierins tied Above (nclud ephysicai srate andlazatd code.J K. Handling Codes lor Wasics tistlrdAtove

F IIuzoilcoutaninaed-s$o1l m _K -C

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S tGv(7 cL- I l.ssie A sw i s eci p h Manral [

i2 ric: krnw lpdt rc i t MAcrils - .It

lantrr typed Na e i s u- i i A j hv - f A f

-! ~, F ~-~--'-.-~-*-- I9. Dmnc:IaImnc y Jsrlicalirs Space N7 I~r it.t. (t",. U'2i 0 't~Wflnlri.b'Z5.t.'l '.t t'.A~i J:~sir'iC~. Pie 'fi'i'ri;r;rJ. it ':.r~rs x'.r*

.5..bC~.,

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Eautnence I x6 1e.imenI Yalion

£7 YAallacd &Aee, .ffawsence, dAlassac/usett O?843

OIL IDENTF~(CATION

Page 1 of 3

PROCEDURE

The procedure used for the identification of refined I petroleum products is derived from the method "Gas Chromatography of High Molecular Weight Hydrocarbons with an Inorganic Salt Eutectic Column". (Anal. Chem., Vol. 50, No. 2, February 1978, 327).

A 2% solution in pentane of the oil sample is analyzed in a Perkin Elmer Gas Chromatograph 'equipped with a flame ionization - -detector -- and an SPB - 1 capillary column. The chromatogram obtained is compared with * chromatograms of a 2% solution in pentane of reference oils. The references are the refinery fractions gasoline, kerosene, diesel oils, heating oils and wide-cut gas oil (lube oils).

Two chromatograms are run for both the sample and the reference oil. In the second run they are spiked with a standard solution of known 'saturated hydrocarbons I ranging from nine' to twenty-four carbon atoms. The * petroleum hydrocarbons in the sample are tentatively identified by the overlapping of-- peaks -with similar retention times and the corresponding oil is identified by comparison with the reference -oil. - gietatinrzen1 1 fvtfmfl( ?a/ n/ie~n

PA l:ULI jj

j~1 -1 1 (.. SAMPLE (S) ANALYSIS i/al h' ~ RESULT S Io CITY/TOWN MEl'HUEN

COLLEC TOR J. Michaud COLLECTION DATE 4/23/90

RECEIV ED 4/23/90 ANALYZED 4/26-5/18/90

I SAMPLE NO. 004

URCE 39 Oakland Avenue Bottom

RESURE S U LT The sample seems to contain a wide-cut gas oil.

2. SAMPLE NO. 005~

SOURCE 39 Oakland Avenue ~Right

RESULT The sample seems to contain a wide-cut gas oil. 7'U I. . PAGE OF 3 I.. 3. SAMPLE NO. 006 - SOURCE - 39 Oakland Avenue Center U N. RESULT . The sample seems to contain -a wide-cut gas oil.

* .. APPENDIX C

SAMPLE LOCATION DIAGRAM .J..

"ci 0 U I I CAKWL A D I "3 $43 I I U ~ i -

tt-~... I v I'

I g

I --I. I I I' C I'

1 '~, APPENDIX D

SOIL HEADSPACE METHODOLOGY APPENDIX E

LABORATORY RESULTS Groundwater Analytical. inc. 228 Main Street GROUNDWATER Buzzards Bay, MA 02532 ANALYTICAL Telephone (508) 759-4441 FAX (508) 759-4475

August 20, 1991

David L. Sanfordv Vice President Laboratory Operations

DLS/mad Enclosures GROUNDWATER EPA METHOD 8240 ANALYTICAL Volatile Organics (GC/MS) Field ID: SS-1 Lab ID: 1752-01 Project: Guilford Methuen/91.1016MA QC Batch: VMA-291 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 40ml VOA Vial/Cool Received: 07-31-91 Matrix: Soil Percent Moisture: 44 % Analyzed: 08-13-91 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane * BRL 5 Methylene Chloride BRL 5 Acetone 630 ** 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 1,1-Dichloroethane BRL 5 2-Butanone trace 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 -Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1 3-Dichloropropene BRL 5 Trichioroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1,1,2,2-Tetrachloroethane BRL 5 Toluene 22 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) 21 5 Dichlorobenzene (total) * BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 so 51 102 % 70 - 121 % Toluene-d8 50 58 116 % 81 - 117 % 4-Bromofluorobenzene 50 36 72 % 74 - 121 %

*** Outside QC limits due to matrix interference. " Concentration of Acetone is estimated. No dilution was used in order to achieve low detection limits for other parameters. BRL - Below Reporting Limit. * Non-target compound. "Trace" indicates probable presence below listed detection limit. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

Field ID: SS-1 Lab ID: 1750-01 Project: Guilford Methuen/91.1016MA QC Batch: OHS- 120 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 500ml Glass/Cool Received: 07-31-91 Matrix: Soil Extracted: 08-06-91 Analyzed: 08-07-91

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 19,000 30

BRL = Below Reporting Limit. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER EPA METHOD 8240 ANALYTICAL Volatile Organics (GC/MS)

Field ID: SS-2 Lab ID: 1752-02 Project: Guilford Methuen/91.1016MA QC Batch: VMA-291 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 40ml VOA Vial/Cool Received: 07-31-91 Matrix: Soil Percent Moisture: 18 % Analyzed: 08-13-91 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane * BRL 5 Methylene Chloride BRL 5 Acetone BRL 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 1,1-Dichloroethane BRL 5 2-Butanone BRL 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1,3-Dichloropropene BRL 5 Trichloroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1,1,2,2-Tetrachloroethane BRL 5 Toluene BRL 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) BRL 5 Dichlorobenzene (total) * BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 50 50 100 % 70 - 121 % Toluene-d8 50 53 106 % 81 - 117 % 4-Bromofluorobenzene 50 45 90 % 74 - 121 %

BRL - Below Reporting Limit. * Non-target compound. "Trace" indicates probable presence below listed detection limit. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 380 30

BRL - Below Reporting Limit. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER VoaieEPA MET HOD 8240 ANALYTICAL Volatile Organics (GC/MS)

Field ID: SS-3 Lab ID: 1752-03 Project: Guilford Methuen/91.1016MA QC Batch: VMA-291 Client: EE & G Sampled: 07-30-91 Cont/Prsv: 40ml VOA Vial/Cool Received: 07-31-91 Matrix: Soil Percent Moisture: 38 % Analyzed: 08-13-91 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane * BRL 5 Methylene Chloride BRL 5 Acetone BRL 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 1,1-Dichloroethane BRL 5 2-Butanone BRL 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1,3-Dichloropropene BRL 5 Trichloroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1,1,2,2-Tetrachloroethane BRL 5 Toluene BRL 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) BRL 5 Dichlorobenzene (total) * BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 50 50 100 % 70 - 121 % Toluene-d8 50 53 106 % 81 - 117 % 4-Bromofluorobenzene 50 42 84 % 74 - 121 %

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg)

Total Petroleum Hydrocarbons 930 30

8RL - Below Reporting Limit. Method Reference: Method 418.1 (Spectrophotometric, infrared) - Petroleum Hydrocarbons, Total Recoverable. Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). J GROUNDWATER QUALITY ASSURANCE ANALYTICAL Method Blank

Category: EPA Method 8240/Low Level Purging QC Batch: VMA-291 Matrix: Soil/Sediment/Solid PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 10 Bromomethane .BRL 10 Vinyl Chloride BRL 10 Chloroethane BRL 10 Trichlorofluoromethane * BRL 5 Methylene Chloride BRL 5 Acetone BRL 50 Carbon Disulfide BRL 5 1,1-Dichloroethene BRL 5 Tetrahydrofuran * BRL 50 1,1-Dichloroethane BRL 5 2-Butanone BRL 50 1,2-Dichloroethene (total) BRL 5 Chloroform BRL 5 1,2-Dichloroethane BRL 5 Methyl tertiary Butyl Ether * BRL 5 1,1,1-Trichloroethane BRL 5 Carbon Tetrachloride BRL 5 Vinyl Acetate BRL 50 Bromodichloromethane BRL 5 1,2-Dichloropropane BRL 5 cis-1,3-Dichloropropene BRL 5 Trichloroethene BRL 5 Dibromochloromethane BRL 5 1,1,2-Trichloroethane BRL 5 Benzene BRL 5 trans-1,3-Dichloropropene BRL 5 2-Chloroethylvinylether BRL 10 Bromoform BRL 5 4-Methyl-2-Pentanone BRL 50 2-Hexanone BRL 50 Tetrachloroethene BRL 5 1 1,2,2-Tetrachloroethane BRL 5 Toluene BRL 5 Chlorobenzene BRL 5 Ethylbenzene BRL 5 Styrene BRL 5 Xylene (total) BRL 5 Dichlorobenzene (total) * BRL 5 QC SURROGATE COMPOUNDS SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 50 48 96 % 70 - 121 % Toluene-d8 50 -49 98 % 81 - 117 % 4-Bromofluorobenzene 50 50 100 % 74 - 121 %

BOL - Below Detection Limit. * Non-target compound. "Trace" indicates probable presence below listed detection limit. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Low-level Purging Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846,.Third Edition (1986). GROUNDWATER ANA LY TICAL QUALITY ASSURANCE Matrix Spike Recovery and Matrix Spike Duplicate Study

Category: EPA Method 8240/Low Level Purging QC Batch: VMA-291 Matrix: Soil/Sediment/Solid Units: ug/Kg

Terms: MS = Matrix Spike; NSD = Matrix Spike Duplicate; AVG = Average; APR = Average Percent Recovery; RPD = Relative Percent Difference. Quality Control Limits are defined by the methodology, or alternatively based upon the historical average recovery plus or minus three standard deviation units. IN3no - mol-taA GY1 - IVNIENWO

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I------I- :3-m '0 C, cc '3 23V O a .. EZ z e:'7i 4 uJ a 9a } LU cc It \ei a:iL L I IIIIIJ- 'S z z I\ Ci0 0~ N 5- z U C 3ivo Cr U: IL 0.. - Ii~~ 6 & - I - - I - d - I k 6 - I - a - a - I --- I - I - I -' GROUNDWATER ANALYTICAL QUALITY ASSURANCE QA/QC Program Statement Groundwater Analytical conducts an active Quality Assurance program to ensure the production of high quality, valid data. This program closely follows the guidance provided by Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans, US EPA QAMS-005 80 (1980), and Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). Operating Procedures (SOPs) 2ualitydeveloped Controlfor eachprotocols analytical include method. Standard SOPs are derived from US EPA methodologies and other established references. Equipment and facility maintenance conform to Good Laboratory Practices (GLPs). Standards are prepared from commercially obtained reference materials of certified purity, and documented for traceability. Quality Assessment protocols for most organic analyses include a minimum of one calibration standard, one method blank, one matrix spike, and one matrix spike duplicate for each sample batch. All samples, standards, blanks, and matrix spikes are spiked with internal standards and surrogate compounds. GC/MS systems are tuned to BFB ion abundance criteria daily, or for each 12 hour operating period, whichever is more frequent. Quality Assessment protocols for most inorganic analyses include a minimum of one calibration standard, one method blank, one sample duplicate, one matrix spike and one matrix spike duplicate for each sample batch. Standard curves are derived from one reagent blank and four concentration levels. Curve validity is verified by standard recoveries within plus or minus ten percent of the curve. Analytical Batches are used as the basic unit for Quality Assessment. An Analytical Batch is defined as twenty or fewer samples which are analyzed together with the same-method sequence and the same lots of reagents and with the same manipulations common to each sample within the same time period or in continuous sequential time periods. Method Blanks are used to assess the level of contamination present in the analytical system. Method Blanks consist of reagent (analyte-free) water or sand. Method Blanks are taken through all the appropriate steps of an analytical method. A universal blank matrix does not exist for solid samples. Sample data is reported on a blank-corrected basis. Matrix Spike/Matrix Spike Duplicates are used to assess accuracy and precision. A Matrix Spike/Matrix Spike Duplicate consists of two replicate samples (or two reagent blanks if sample volumes are inadequate) spiked with a group of target compounds representative of the method analytes. Accuracy is defined as the degree of agreement of a measured value with the true or expected value. Percent Recoveries for the Matrix Spike are calculated to assess accuracy. Precision is defined as the degree of mutual agreement of independent measurements as the result of repeated application of the method. Relative Percent Differences between the Matrix Spike and Matrix Spike Duplicate are calculated to assess precision. Surrogate Compounds are used to assess the effectiveness of the method in dealing with each sample matrix. Surrogate Compounds are organic compounds which are similar to organic analytes of interest in chemical behavior, but which are not normally found in environmental samples. Percent Recoveries are calculated for each Surrogate Compound. GROUNDWATER ANALYTICAL QUALITY ASSURANCE State Certification

CONNECTICUT Certificate Number Department of Health Services PH-0586 Potable Water, Wastewater/Trade Waste, Sewage/Effluent, and Soil: Purgeable Halocarbons, Purgeable Aromatics, Pesticides, Phenols, Oil and -Grease, Aluminum, Antimony, Arsenic, Beryllium, Cadmium, Chromium-T, Chromium-VI, Cobalt, Copper, Iron, Lead, Magnesium, Manganese, Mercury, Nickel, Potassium, Selenium, Silver, Sodium, Thallium, Tin, Vanadium, Zinc, Cyanide, TDS, Ammonia, TKN, Nitrate, Ortho-Phosphate, Alkalinity, Hardness, Chloride, Fluoride, pH, Conductivity

MAINE Certificate Number Department of Human Services N/A Reciprocal certification in accordance with Massachusetts certification for drinking water parameters.

MASSACHUSETTS Certificate Number Department of Environmental Protection MA103 Drinking Waters: Metals, Trihalomethanes, Volatile Organics Nitrate, Nitrite, Fluoride, Corrosivity Series, Cyanide Other Matrices: Metals, Minerals, Nutrients, Volatile Halocarbons, Volatile Aromatics, Pesticides, Cyanide, Oil and Grease, Phenolics

NEW HAMPSHIRE Certificate Number Department of Environmental Services 202791-A/B Drinking Water: Trihalomethanes, Volatile Organics Wastewater: Volatile Organics, Pesticides, Oil and Grease, -Aluminum, Arsenic, Beryllium, Cadmium, Cobalt, Chromium, Copper, Iron, Mercury, Manganese, Nickel, Lead, Selenium, Antimony, Silver, Thallium Molybdenum, Strontium, Vanadium, Calcium, Magnesium, Sodium, Potassium, pH, Specific Conductance, TDS, Hardness, Alkalinity, Chloride, Fluoride, Ammonia, Nitrate, Orthophosphate, TKN, Phosphorus, Phenolics

RHODE ISLAND Certificate Number Department of Health N/A Recognition of Massachusetts certification. M)

APPENDIX B m

APPENDIX C ATTACHMENT I

JAR HEADSPACE ANALYTICAL SCREENING PROCEDURE

The following are recommended procedures for conducting analytical screening of gasolinE-contaminated soils utilizing a portable Photoionization detector (PID) or Flame Ionization Detector (FID):

(1) Half-fill two clean glass jars with-the sample to be analyzed. Quickly cover each open top with one or two sheets of clean aluminum foil and subsequently apply screw caps to tightly seal the jars. Sixteen ounce (16 oz.) (approx. 500 ml) soil or "mason" type jars are preferred; jars less than 8 oz. (approx. 250 ml) total capacity may to be used.

(2) Allow headspace development for at least 10 minutes. Vigorously shake Jars for 15 seconds both at the beginning and end of the -headspace development period. Where ambient temperatures-are below 32 F (0 C), headspace development should be within a heated vehicle or building.

(3) Subsequently to headspace development, remove screw lid/expose foil seal. Quickly puncture foil seal with instrument sampling probe, to a point about one-half of the headspace depth. Exercise care to avoid uptake of water droplets or soil particulates.

As an alternative, syringe withdrawal of a headspace sample with subsequent injection to instrument probe, or septum-fitted inlet is acceptable contingent upon verification of methodology accuracy using a test gas standard.

(4) Following probe insertion through foil seal and/or sample injection to the probe, record highest meter response as the.jar headspace concentration. Using foil seal/probe insertion method, maximum response should occur between 2 and 5 seconds. Erratic meter response may occur at high organic vapor concentrations or conditions of elevated headspace moisture, in which case headspace data should be discounted.

(5) The headspace screening data from both jar samples should be recorded and compared; generally, replicate values should be consistent to plus or minus.20%.

(6) PID and FID field instruments shall be operated and calibrated to yield "total organic vapors" in ppm (v/v) as benzene. PID instruments must be operated with a 10.0 eV (+/-) lamp source. Operation, maintenance, and calibration shall be performed in accordance with the manufacturer's specifications. For jar headspace analysis, instrument calibration shall be checked/adjusted no less than once every 10 analyses, or daily, whichever is greater.

(7) Instrumentation with digital (LED/LCD) displays may not be able to discern maximum headspace response unless equipped with a "maximum hold" feature or strip- chart recorder.

Deviations, departures and/or additions to the above procedures will be considered on a case-by-case basis by the DEP on-scene coordinator or project manager. In such cases, compelling technical justification must be presented and documented by the methodology proponent..

C APPENDIX D Groundwater Analytical, Inc, GROUNDWATGROUN ER WATER228 Main ""*"Street Buzzards Bay, MA 02532 ANALYTICAL Telephone (508) 759-4441 FAX (508) 759-4475

August 26, 1992

Mr. Thomas Williamson, Jr. EE & G, Inc. 149 Cross Street Winchester, MA 01890 Dear Tom: Enclosed are the Volatile Organic, Total Petroleum Hydrocarbons and Hydrocarbon Fingerprint Analyses performed for the Guilford-Methuen project, number 91.1016-2, sampled on 08-11-92. This project was processed for Standard Two Week turnaround. A brief description of the Quality Assurance/Quality Control procedures employed by Groundwater Analytical, and a statement of our state certifications are contained within the report. This letter authorizes the release of the analytical results and should be considered a part of this report. Should you have any questions concerning this report, please do not hesitate to contact me. Sincerely,

David L. Sanfor Vice President Laboratory Operations

DLnscac Enclosures- GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS- 1 Lab ID: 3578-01 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 7 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichlorop ropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichioroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1,1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xylene (total) 510 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,700 113 % 70 121 % Toluene-d8 5,000 5,000 100 % 81 117 % 4-Bromofluorobenzene 5,000 5,300 105 % 74 121 %

BRL = Below Reporting Limit. * Non-target compound. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Methanol Extraction Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

Field ID: TS-1 Lab ID: 3578-01 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0227-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 7 % Extracted: 08-14-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 100 31

BRL - Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric. Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction. Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS- I Lab ID: 3578-01 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0216-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 7 % Extracted: 08-12-92 Analyzed: 08-19-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match.

Ouantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 200 10

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.73 0.91 125 % 60 - 140 %

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method References: Method D3328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Lab ID: 3578-01 HYDROCARBONS LABORATORY

100.0(

BO.O(

60.0(

40.0(

20.0(

0.0(

0.00 20.00 40.00 60.00 80.00 Retention time In minutes GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS-2 Lab ID: 3578-02 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 16 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichloropropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichioroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1,1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xylene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,700 113 % 70 121 % Toluene-d8 5,000 5,100 101 % 81 117 % 4-Bromofluorobenzene 5,000 5,300 106 % 74 121 %

Field ID: TS-2 Lab ID: 3578-02 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0227-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 16 % Extracted: 08-14-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg)

Total Petroleum Hydrocarbons BRL 33

BRL - Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction. Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS-2 Lab ID: 3578-02 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0216-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 16 % Extracted: 08-12-92 Analyzed: 08-14-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match.

Quantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 110 11

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.78 0.96 123 % 60 - 140 %

Lab [0: 3578-02 HYDROCARBONS LABORATORY

0.00 20.00 40.00 60.00 80.00 100,00 Retention time In minutes GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS-3 Lab ID: 3578-03 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 15 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg)

Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichloropropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichioroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1,1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xylene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,600 113 % 70 121 % Toluene-d8 5,000 5,000 100 % 81 117 % 4-Bromofluorobenzene 5,000 5,200 103 % 74 121 %

Field ID: TS-3 Lab ID: 3578-03 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0227-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 15 % Extracted: 08-14-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 33

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SV-846, Third Edition (1986). GROUND WATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS-3 Lab ID: 3578-03 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0216-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 15 % Extracted: 08-12-92 Analyzed: 08-14-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match.

Quantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 71 11

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.81 0.92 113 % 60 - 140 %

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method References: Method D3328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICA L ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Lab 1D: 3578-03 HYDROCARBONS LABORATORY

100.00--

80.00--

40.0(

20.0(

O.0

0.00 20.00 40.00 60.00 80.00 100.00 Retention time In minutes GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS-4 Lab ID: 3578-04 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 15 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 I,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichloropropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichioroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1 ,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1,1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xy ene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,700 114 % 70 - 121 % Toluene-d8 5,000 5,000 99 % 81 - 117 % 4-Bromofluorobenzene 5,000 5,300 106 % 74 - 121 %

BRL - Below Reporting Limit. * Non-target compound. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Methanol Extraction Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANA LYTICA L EPA METHOD 418.1 (Modified) Total Petroleum Hydrocarbons (IR)

Field ID: TS-4 Lab ID: 3578-04 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0227-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500m1 Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 15 % Extracted: 08-14-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 33

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD 03328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Lab 10: 3578-04 HYDROCARBONS LABORATORY

0.00 20.00 40.00 60.00 80.00 100.00 Retention time in minutes GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS-4 Lab ID: 3578-04 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0216-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 5 % Extracted: 08-12-92 Analyzed: 08-19-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match.

Quantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 55 10

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.67 0.63 94 % 60 - 140 %

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method References: Method 03328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Saxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS-5 Lab ID: 3578-05 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 6 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichlorop ropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichioroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1, 1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xylene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,600 112 % 70 121 % Toluene-d8 5,000 5,000 100 % 81 117 % 4-Bromofluorobenzene 5,000 5,300 106 % 74 121 %

Field ID: TS-5 Lab ID: 3578-05 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0228-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 6 % Extracted: 08-17-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg)

Total Petroleum Hydrocarbons BRL 31

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS-5 Lab ID: 3578-05 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0217-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 6 % Extracted: 08-13-92 Analyzed: 08-19-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match.

Quantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 20 10

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.69 0.79 115 % 60 - 140 %

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method References: Method 03328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Lab ID: 3578-05 HYDROCARBONS LABORATORY

100

0.00 20.00 40.00 60.00 BO.00 100.00 Retention time In minutes GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS-6 Lab ID: 3578-06 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 10 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chl oropethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichloropropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichloroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1,1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xy ene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,700 114 % 70 121 % Toluene-d8 5,000 5,000 101 % 81 117 % 4-Bromofluorobenzene 5,000 5,300 106 % 74 121 %

Field ID: TS-6 Lab ID: 3578-06 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0228-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 10 % Extracted: 08-17-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 32

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD 03328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS-6 Lab ID: 3578-06 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0217-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 10 % Extracted: 08-12-92 Analyzed: 08-20-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match.

Quantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 78 11

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.76 0.88 116 % 60 - 140 %

BRL Below Reporting Limit. Calculations based on dry sample weight. Method References: Method D3328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US, EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Lab 10: 3578-06 HYDROCARBONS LABORATORY

0.00 20.00 40.00 60.00 80.00 100.00 Retention time in minutes GROUNDWATER ANALYTICAL EPA METHOD 8240 Volatile Organics (GC/MS)

Field ID: TS-7 Lab ID: 3578-07 Project: Guilford-Metheun/91.1016-2 Batch ID: VM2-0230-E Client: EE & G Sampled: 08-11-92 Cont/Prsv: 40ml VOA Vial/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 7 % Analyzed: 08-19-92 PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg)

Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 1,1,1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichlorop ropane BRL 500 cis-1 3-Dichloropropene BRL 500 Trichioroethene BRL 500 Dibromochloromethane BRL 500 I,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 I , 1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xylene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS 1,2-Dichloroethane-d4 5,000 5,600 113 % 70 121 % Toluene-d8 5,000 5,000 100 % 81 117 % 4-Bromofluorobenzene 5,000 5,300 105 % 74 121 %

Field ID: TS-7 Lab ID: 3578-07 Project: Guilford-Methuen/91.1016-2 Batch ID: HI-0228-X Client: EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 7 % Extracted: 08-17-92 Analyzed: 08-18-92

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 45 31

BRL = Below Reporting Limit. Calculations based an dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, - Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Lab ID: 3578-07 HYDROCARBONS LABORATORY

0.00 20.00 40.00 60.00 80.00 100.00 Retention time In minutes IN3113 - M0113RA SY1 - 1VNIVIUO

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0 391V/M 0 8209YdE3 U Ecy o 3S1AUM 0 0809/009 0 Z091109 Vd3 'S. P 0 B9±W/m 0 08:09 0l 809 Vcfl 0 01es093 109 Y4H3 w a- C 0 0 rt 0 a U PU n C?' C,, LQ mz 'A IA F 0 wU x £ tO cn ~0 0 0 (5 ON o 2 - LLjm i 0 0-0 0

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0 :3 -o OSVd -M 0 C C CL S N U CL E I C SSV2 1II-+ N a 4 WA VO_ K4 t4-it '.5 N Cot -- ~ (N C H~wn1I ccsm " aN * N ca IflL0S U -4-4 CL It 0 a2 DI

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D 0 I, r L Ac mi -- - - - E. wI II S a- atLva '-A co a- 1 I i ' GROUNDWATER ANALYTICAL ASTM METHOD D3328-78 (Modified) Hydrocarbon Fingerprinting (GC/FID)

Field ID: TS-7 Lab ID: 3578-07 Project: Guilford-Methuen/91.1016-2 Batch ID: HF-0217-X Client: .EE & G Sampled: 08-11-92 Cont/Prsv: 500ml Glass/Cool Received: 08-11-92 Matrix: Soil Percent Moisture: 7 % Extracted: 08-13-92 Analyzed: 08-20-92

Qualitative Identification This sample has GC/FID characteristics that are similiar to a mixture of Coal Tar and Lubricating Oil. All samples in this project match; however, resolved Leaf Hydrocarbons are present in this sample, but not in the other samples.

Ouantification

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons 82 v 10

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.72 0.79 110 % 60 - 140 %

v m Analyte result corrected for the presence of leaf hydrocarbons. BRL = Below Reporting Limit. Calculations based on dry sample weight. Method References: Method D3328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846. Third Edition (1986). GROUNDWATER ANALYTICAL QUALITY ASSURANCE QA/QC Program Statement Groundwater Analytical conducts an active Quality Assurance program to ensure the production of high quality, valid data. This program closely follows the guidance provided by Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans, US EPA QAMS-005/80 (1980), and Test fMethods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). Quality Control protocols include Standard Operating Procedures (SOPs) developed for each analytical method. SOPs are derived from US EPA methodologies and other established references. Equipment and facility maintenance conform to Good Laboratory Practices (GLPs). Standards are prepared from commercially obtained reference materials of certified purity, and documented for traceability.

Quality Assessment protocols for most organic analyses include a minimum of one calibration standard, one method blank, one laboratory control sample, and one matrix spike/duplicate pair for each sample batch. All samples, standards, blanks, laboratory control samples and matrix spikes are spiked with internal standards and surrogate compounds. GC/MS systems are tuned to BFB ion abundance criteria daily, or for each 12 hour operating period, whichever is more frequent.

Quality Assessment protocols for most inorganic analyses include a minimum of one calibration standard, one method blank, one sample duplicate, one laboratory control sample, and one matrix spike/duplicate pair for each sample batch. Standard curves are derived from one reagent blank and four concentration levels. Curve validity is verified by standard recoveries within plus or minus ten percent of the curve. Batches are used as the basic unit for Quality Assessment. A Batch is defined as twenty or fewer samples which are analyzed together with the same method sequence and the same lots of reagents and with the same manipulations common to each sample within the same time period or in continuous sequential time periods.

Method Blanks are used to assess the level of contamination present in the analytical system. Method Blanks consist of reagent water or purified soil. Method Blanks are taken through all the appropriate steps of an analytical method. Sample data reported is not corrected for blank contamination. Laboratory Control Samples are used to assess the accuracy of the analytical method. A Laboratory Control Sample consists of reagent water or purified soil spiked with a group of target compounds representative of the method analytes. Accuracy is defined as the degree of agreement of a measured value with the true or expected value. Percent Recoveries for the Laboratory Control Sample are calculated to assess accuracy.

Surrogate Compounds are used to assess the effectiveness of the method in dealing with each sample matrix. Surrogate Compounds are organic compounds which are similar to organic analytes of interest in chemical behavior, but which are not normally found in environmental samples. Percent Recoveries are calculated for each Surrogate Compound. GROUNDWATER ANALYTICAL QUALITY ASSURANCE Laboratory Control Sample Recovery

Category: EPA Method 8240/Methanol Extraction Batch ID: VM2-0230-ELS Matrix: Soil Units: ug/Kg Laboratory Control Samnle SPIKE SPIKED PERCENT QC ANALYTE ADDED RESULT RECOVERY LIMITS 1,1 Dichloroethene 5,000 4,100 82 % 59-172 Benzene 5,000 4,900 97 % 66-142 Trichloroethene 5,000 5,100 102 % 62-137 Toluene 5,000 4,900 98 % 59-139 Chlorobenzene 5,000 4,900 99 % 60-133

All Calculations performed prior to rounding. Quality Control Limits are defined by the methodology, or alternatively based upon the historical average recovery plus or minus three standard deviation units. GROUNDWATER ANALYTICAL QUALITY ASSURANCE Method Blank

Category: EPA Method 8240/Methanol Extraction Batch ID: VM-0230-EBI Matrix: Soil PARAMETER CONCENTRATION REPORTING LIMIT (ug/Kg) (ug/Kg) Chloromethane BRL 1,000 Bromomethane BRL 1,000 Vinyl Chloride BRL 1,000 Chloroethane BRL 1,000 Trichlorofluoromethane * BRL 500 Methylene Chloride BRL 500 Acetone BRL 5,000 Carbon Disulfide BRL 500 1,1-Dichloroethene BRL 500 1,1-Dichloroethane BRL 500 2-Butanone BRL 5,000 1,2-Dichloroethene (total) BRL 500 Chloroform BRL 500 1,2-Dichloroethane BRL 500 Methyl tertiary Butyl Ether * BRL 500 1,1, 1-Trichloroethane BRL 500 Carbon Tetrachloride BRL 500 Vinyl Acetate BRL 5,000 Bromodichloromethane BRL 500 1,2-Dichloropropane BRL 500 cis-1,3-Dichloropropene BRL 500 Trichloroethene BRL 500 Dibromochloromethane BRL 500 1,1,2-Trichloroethane BRL 500 Benzene BRL 500 trans-1,3-Dichloropropene BRL 500 2-Chloroethylvinylether BRL 1,000 1,2-Dibromoethane * BRL 500 Bromoform BRL 500 4-Methyl-2-Pentanone BRL 5,000 2-Hexanone BRL 5,000 Tetrachloroethene BRL 500 1,1,2,2-Tetrachloroethane BRL 500 Toluene BRL 500 Chlorobenzene BRL 500 Ethylbenzene BRL 500 Styrene BRL 500 Xylene (total) BRL 500 Dichlorobenzene (total) * BRL 500 QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS

1,2-Dichloroethane-d4 5,000 57 114 % 70 - 121 % Toluene-d8 5,000 50 101 % 81 - 117 % 4-Bromofluorobenzene 5,000 53 106 % 74 - 121 %

BRL = Below Reporting Limit. * Non-target compound. Calculations based on dry sample weight. Method References: Method 8240 - GC/MS for Volatile Organics and Method 5030 - Methanol Extraction Procedure, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL QUALITY ASSURANCE Laboratory Control Sample Recovery

Category: EPA Method 418.1 (Modified) Batch ID: HI-0227-XLS Matrix: Soil Units: mg/Kg Laboratory Control Sample SPIKE SPIKED PERCENT QC ANALYTE ADDED RESULT RECOVERY LIMITS Fuel Oil No. 2 440 440 102 % 80-120

All Calculations performed prior to rounding. Quality Control Limits are defined by the methodology, or alternatively based upon the historical average recovery plus or minus three standard deviation units. / GROUNDWATER ANALYTICAL QUALITY ASSURANCE U Method Blank

Category: EPA Method 418.1 (Modified) Batch ID: HI-0227-XB1 Matrix: Soil

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 30

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GRSUNDWATER ANALYTICAL QUALITY ASSURANCE Laboratory Control Sample Recovery

Category: EPA Method 418.1 (Modified) Batch ID: HI-0228-XLS Matrix: Soil Units: mg/Kg Laboratory Control Samole SPIKE SPIKED PERCENT QC ANALYTE ADDED RESULT RECOVERY LIMITS Fuel Oil No. 2 440 450 103 % 80-120

Category: EPA Method 418.1 (Modified) Batch ID: HI-0228-XB1 Matrix: Soil

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 30

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method Reference: Method 418.1 (Spectrophotometric, Infrared) - Petroleum Hydrocarbons, Total Recoverable, Methods for Chemical Analysis of Water and Wastes, US EPA EPA-600/4-79-020, Revised (1983). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL QUALITY ASSURANCE Laboratory Control Sample Recovery

Category: ASTM Method D3328-78 (Modified) Batch ID: HF-0216-XLS Matrix: Soil Units: mg/Kg Laboratory Control Sample SPIKE SPIKED PERCENT QC ANALYTE ADDED RESULT RECOVERY LIMITS Fuel Oil No. 2 61 61 101 % 60-140

All calculations performed prior to rounding. Quality Control Limits are defined by the methodology, or alternatively based upon the historical average recovery plus or minus three standard deviation units. GROUNDWATER ANALYTICAL QUALITY ASSURANCE Method Blank

Category: ASTM Method D3328-78 (Modified) Batch ID: HF-0216-XB1 Matrix: Soil

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 10

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.71 0.65 91 % 60 - 140 %

BRL = Below Reporting Limit. Calculations based on dry sample weight. Method References: Method D3328-78 (Modified) - Comparison of Waterborne Petroleum Oils by Gas Chromatography, Volume 11.02 Water, American Society for Testing and Materials, Reapproved (1982). Adapted for solids by Method 3540 (Modified) - Soxhlet Extraction, Test Methods for Evaluating Solid Waste, US EPA SW-846, Third Edition (1986). GROUNDWATER ANALYTICAL QUALITY ASSURANCE Laboratory Control Sample Recovery

Category: ASTM Method 03328-78 (Modified) Batch ID: HF-0217-XLS Matrix: Soil Units: mg/Kg Laboratory Control Sample SPIKE SPIKED PERCENT QC ANALYTE ADDED RESULT RECOVERY LIMITS Fuel Oil No. 2 61 67 110 % 60-140

Category: ASTM Method D3328-78 (Modified) Batch ID: HF-0217-XB1 Matrix: Soil

PARAMETER CONCENTRATION REPORTING LIMIT (mg/Kg) (mg/Kg) Total Petroleum Hydrocarbons BRL 10

QC SURROGATE COMPOUND SPIKED MEASURED RECOVERY QC LIMITS o-Terphenyl 0.71 0.60 84 % 60 - 140 %

CONNECTICUT Certificate Number Department of Health Services PH-0586

Potable Water, Wastewater/Trade Waste, Sewage/Effluent, and Soil: Purgeable Halocarbons, Purgeable Aromatics, Pesticides, Phenols, Oil and Grease, Aluminum, Antimony, Arsenic, Beryllium, Cadmium, Chromium-T, Chromium-VI, Cobalt, Copper, [ron, Lead, Magnesium, Manganese, Mercury, Nickel, Potassium, Selenium, Silver, Sodium, Thallium, Tin, Vanadium, Zinc, Cyanide, TOS, Ammonia, TKN, Nitrate, Ortho-Phosphate, Alkalinity, Hardness, Chloride, Fluoride, pH, Conductivity MAINE Certificate Number Department of Human Services N/A

Reciprocal certification in accordance with Massachusetts certification for drinking water parameters. MASSACHUSETTS Certificate Number Department of Environmental Protection MA103

Potable Water: Antimony, Arsenic, Barium, Beryllium, Cadmium, Chromium, Copper, Lead, Mercury, Nickel, Selenium, Silver, Thallium, Nitrate-N, Nitrite-N, Fluoride, Cyanide, Calcium, Total Alkalinity, Total Dissolved Solids, pH, Langelier Index, Trihalomethanes, Volatile Organic Compounds, 1,2-Dibromoethane, 1,2-Dibromo-3-chloropropane. Non-Potable Water: Aluminum, Antimony, Arsenic, Beryllium, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Mercury, Molybdenum, Nickel, Selenium, Silver, Strontium, Thallium, Titanium, Vanadium, Zinc, pH, Specific Conductivity, Total Dissolved Solids, Total Hardness, Calcium, Magnesium, Sodium, Potassium, Total Alkalinity, Chloride, Fluoride, Amnonia-N, Nitrate-N, Kjeldahl-N, Orthophosphate, Total Cyanide, Oil and Grease, Total Phenolics, Volatile Halocarbons, Volatile Aromatics, Chlordane, Aldrin, Dieldrin, DDD, DDE, DOT, Heptachlor, Heptachlor Epoxide, Polychlorinated Biphenyls (Water), Polychlorinated Biphenyls (Oil). MICHIGAN Certificate Number Department of Public Health N/A

Drinking Water: Antimony, Arsenic, Barium, Beryllium, Cadmium, Chromium, Copper, Cyanide, Fluoride, Lead, Mercury, Nickel, Nitrate, Nitrite, Selenium, Silver, Sodium, Sulfate, Thallium, Total Trihalomethanes, Regulated and Unregulated Volatile Organic Chemicals. NEW HAMPSHIRE Certificate Number Department of Environmental Services 202791-A/B

Drinking Water: Lead, Selenium, Silver, Thallium, Trihalomethanes, Volatile Organics, Antimony, Arsenic, Barium, Beryllium, Cadmium, Chromium, Copper, Mercury, Nickel, Fluoride, Total Filterable Residue, Calcium, Alkalinity, pH, Corrosivity, Total Cyanide, Vinyl Chloride, DBCP and EDB. Wastewater: Arsenic, Beryllium, Cadmium, Cobalt, Copper, Iron, Mercury, Manganese, Nickel, Lead, Selenium, Zinc, Antimony, Silver, Thallium, Molybdenum, Strontium, pH, Total Hardness, Calcium, Sodium, Potassium, Total Alkalinity, Chloride, Fluoride, Nitrate-N, TKN, Orthophospates, Total Phenolics, Oil & Grease, PCBs in Oil, Pesticides, Volatile Organics, Titanium, Total Cyanide, PCBs in Water.

RHODE ISLAND Certificate Number Department of Health N/A

Recognition of Massachusetts certification. ptw. as s..ra -c 0 pit) il too?

Sqtu 16.1991 OSMod Ttu flfw tion Industries. Inc. In= I knW~ tdar fikrIcae. MA. 01862-1688 iK La boriory Results SBTA Right of Way/ Onecton Auto Radiator Mhburn, MA. E aC project No. 91.1016MA. Der Mt- MtWholka:

In accordance with your request, Environmental Engineering & Geotechnics, Inc. (EE&G) a inojuted preliminary investigations of the above referenced location. A preliminary site visit was CodWed by E&G personnel on July 19,1991.

Th ste under investigation is a section of the MBTA right of way located in Methuen, Maacwhusctu. Specifically, the site is located northeast of the intersection of Oakland and Railroad Smste and abuts propeny occupied by Perfection Auto Radiator located at 39 Oakland Street The ngh of way consists of a single track at this location. The rails are supported by wood ties and usan ballast. The right of way is abutted by Perfection Auto Radiator, Al's Auto Repair, Forster tamfr. Laidlaw School Bus terminal and several residential properties at this location. The ground wfacc Sopes steeply from Perfection Auto Radiator towards the right of way in a west to cast dir010', whith a total relief of approximately 15 feet.

has invesuigation was initiated based on a Notice of Responsibility/Request for Information aued by the Department of Environmental Protection dated January 25, 1991. Reference Appendix A- Au (T sobcr ItI 1989 letter prepared by Jet-Line Services, referenced subsurface contamination Wa aeW of the drain discharge from the rear of the Perfection Auto Radiator facility. The letter cwasf iftaOrpon and manifests for the removal of contaminated soils in the area of the drain. Ts eLx* wais Lperformed by Jet-Line for Perfection Auto Radiator. Refer to Appendix B for the perfection Aut/Methn. Massachusetts Project No. 91.1016MA Septenber 16, 1991 Page3 of 4-

Based on this preliminary soil sample data and the history of contamination at the Perfection Auto Radiator facility, the source of the release appears to be' the drain pipe in the rear of the Perfection Auto Radiator property. Soil sample SS-1 collected in the area of the drain pipe discharge had the highest concentration of contaminants. The contaminant concentrations decreased in the soil samples (SS-2 and SS-3) collected further away from the drain discharge.

Other areas of concern observed during this sample collection visit included Al's Auto Repair property located at the intersection of Oakland and Railroad Streets. It appears that oily surface runoff from auto repair discharges onto the railroad right of way. Additionally, automotive debris and other miscellaneous debris appear to have been discarded onto the right of way property at this location. During the sample collection visit on July 29, 1991, EE&G personnel observed A's Auto personnel discarding auto parts, oil stained sands and other debris onto the right of way. Al's Auto Repair was cleaning and sweeping the service bays and parking areas of its operation at this time.

on the slope in the area of On July 29. 1991. EE&G personnel collected surface soil samples of approximate sample location. Soil perfection Auto Radiator. Refer to Appendix C for sketch steel hand shovels. Samples were aMpics were collected utilizing precleaned, dedicated stainless (TPH) collected in 500 ml glass jars with Teflons" lined lids for total petroleum hydrocarbon Samples analysis in accordance with Environmental Protection Agency (EPA) Method 418.1. Method 8240 collected for volatile organic co'ipound (VOC's) analysis in accordance with EPA were collected in 40 ml glass vials with Teflon"' septa. All samples were labeled in the field, placed in coolers. chilled to 4* Celsius and shipped overnight mail to Groundwater Analytical Services of Duuards Bay. Massachusetts for analysis.

Surface soil sample SS-1 was collected in the discharge area of a drain outfall exiting the foundation of Perfection Auto Radiator. It should be noted that a clear, sweet smelling liquid was dripping from the drain pipe at the time of the sample collection visit on July 29, 1991. Unfonunatcly there was not enough liquids being discharged to collect the required sample volume for laboratory analysis. Surface soil sample SS-1 had the sweet smelling odor characteristic of solvents. Surface sample SS-2 was collected approximately 20 feet down the slope from SS-1. Surface sample SS-3 was collected another 20 feet down the slope from SS-2 at the base of the railroad ballast. Both samples SS-2 and SS-3 had the same sweet smelling odor as observed in SS-I.

Soil samples were screened for total organic vapors (TOV's) in the field with a Photovac Microtip"' photoionization detector in accordance with the Headspace Methodology attached in Appendix D. The measured TOV headspace for soil sample SS-1 was 1,750 parts per million (ppm). SS-2 was 1,243 ppm and SS-3 was 951 ppm.

'The analytical laboratory results detected concentrations of the VOC's acetone (630 parts per billion tppbf), 2-butanone (trace), toluene (22 ppb) and xylenes (21 ppb) in the sample SS-1. A TPII concentration of 19,000 ppm was detected in the sample for SS-1. All VOC's were below the reporting limit (BRL) of the analytical equipment for the sample SS-2. The TPH sample SS-2 detected a concentration of 380 ppm. No VOC's were detected in the VOC sample SS-3. A TPH cncentrin of 930 ppm was detected in the sample SS-3. Refer to Appendix E for complete laboratory results. .A..MhwD. Masachuseus -u Na.91.I06MA s -1m6e.A1991

if ther ae any questions and/or comments pertaining to the above mentioned poject, please do not hesitate to contact EE&G's office; (Contact person: Thomas Williamson, Jr., telephone: (617) 721-1013).

Sincerely, EnrironmentalEngineering- & Geog chnics, Inc.

onus Williamson, Jr. Project Manager / Environm Engineer

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?s,/ October 11, 1989 -

Ms. Joanne Michaud The Commonwealth of Massachusetts Department of -Environmental Protection Northeast Region - Emergency Response Five Commonwealth Avenue Woburn. MA 01801

Re: Perfection Auto Radiator-Contaminated Soil Removal/Disponi 39 Oakland Avepue - Methuen, Massachusetts (31-32031)

Dear Ms. Michaud:

Jet-Line Services, Inc. is pleased to submit this letteir -r-: attached documents on behalf of our client relative to rA Perfection Auto Radiator .,facility located at 39 Oakland Av.-- i .: Methuen, Massachusetts (the Site). These documents are transmitted in response to our telephone conversation of September 19, .1989. Attached please finad the Uniform Hazardous Waste -Manifest. (# MAC665101) documenting the excavation, transportation and.--- disposal of three (3) drums of petroleum contamin'ated spoils in.E late August 1989. The Boil was excavated from the visually . contaminated area located on the Boston & Maine Railroad property immediately surrounding the drain hole in the rear wal of the Perfection Auto Radiator facility (see attached Site Sketch). The visually contaminated soil was hand excavated to a depth of approximately 2.5 feet in the approximate area outlin:d in the Site Sketch. Also attached are copies of the laboratory certificates of analysis for pamples collected on July 21. August 18. and September 5. 1989. The July 21 sample was collected from tie - visually contaminated soil prior to excavation and analyzed for total petroleum hydrocarbons (TPHCs) and volatile organic compounds (VOCs). The TPHC concentration detected in. this samp*e was 453 milligrams per kilogram (mg/kg). The VOCs detected in this sample included tetrachloroethene, toluene. ethyl bnzen-. xylenes, and the 1,2/1.4 dichlorbenzenes in concentrations of 0.052. 0.167. 0.105, 0.659, 0.104. and 0.143 mg/kg. respective iv. It was decided that the TPHC analysis. would be required for further characterization since the total VOCa dctecrecd in h-. initial sample were relatively low at 1.23 mg/kg. Th TiIC concentr-atint.on. of the August 18 soil sample collicted Yil inom. ' OXcavation of the visually contaminated so L. wnt$ *...2. imv/T- third sample was collected from the area outside the excavation/visually contaminated area on September 5. 1989 to-

IET-LINE SERVICES, INC. e 8 Progress Drive, Dover, Neiw Hanpshire 03820 e (603) 749-5735 e FAX: (603) 749-9095 I T

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-Page Two Ms. Michaud October 11, 1989 i.~~4 -~1

determine the extent and/or -background contamination on the property. The TPHC concentrat ion of this sample and a- laboratory: selected duplicate were 2,762 land 2,945. mg/kg,. respectively.

The area of the Site has a long history of industrial use. The contaminated soil was excavatea from a railroad bed area which may have a relatively high residual petroleum contamination background. It is believed thpt the background contamination should be determined prior to establishing cleanup goals for rh M area rather than utilizing pre-determined values.

It has been a pleasure providing this letter and the attachjed documents to you. Please call if you have any questicn. Very truly yours

N.a

Richard D. Mansfield Project Engineer

C. L. Lambert- Perfection Auto. Radiator A\PMMLTI.RDM

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I I I, I I. ii I: I JET-LINE CERTIFICATE OFt NAL YSIS

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TO: PERFECTION AUT0 RADIA TOR DATE REPORTED: 7-21 -89 DOUG AUGUSTUS DATE RECEIVED: 8-3-89 I? JOB NUMBER: 31-32035 LAS NUMBER: 4277

SAMPLE DESCRIPTION: SOIL

PARAME TER ANALYSIS DETECTION LIMIT ME ;HC

OIL & GREASE (TPHC), MG/KG 45.0 0.2 S 5

- VOLATILES - SEE ATTACHED EPA '2.

I'.

SUPERvrsoRn 263 HOwARD STREET JET-LINE s RVICtS, INC .* LOWEL L, MA 01852 - (508) 937-7294 ;..-- . / / / I: I, I, I.

-V. / VOLATILE ORG ANALYSIS DA-TA - / LAS SAMPLE ID: -4277 DA TE 'RUN: 8- -S CLIENT SAMPLE ID:. PERFECTION AUTO RADIATOR OiLUTION FACTOR: 10.0 DATE RECEIVED: 7-2!-89 'A rIX: SOIL METHOD: LOCA TION: DETECTION LINIT CAS NUMER COMPOUND VA F IK 74-87-3 CHLOROME THANE ND 100 74-83-9 ' ROMOME THANE ND 100 .75-01-4 , VINYL -CHL ORIDE ND 100 75-00-3 -CHLOROETHANE ND 100 75-09-2 11E TrH YLENE CHL oRJ IOE ND 50 75-69-4 1RICHLOROFLUOROMETHANE NO 50

75-35-4 1,1-DrCH LOROETHENE ND 50 75 -35-3 1, 1-DICHLOROETHANE NO 50 156-60-5 TRA NS-1, 2-DICHL OROc THENE NO 50 67-66-3 .CHLORoORM ND 50 107-06-2 172-DICHL OROE THA NE ND 50 71-55-6 1, 1. I-TRICHLOROETHANE ND 50 56-23-5 CARBON TETRACHLORIDE ND 50

705-27-4 *BRoMooCHLOROME THA NE ND 50 79-34-5 1, 1,2,2. -TE TRACHLOROE THANEND 50. 78-87-5 .1, 2-DICHLOROPROPANE ND 10061-02-6 TRANS-1,3-DICHLOROPROPENE ND 50

79-01-6 TRICHLOROETHENE . .NO . 50 124-48-1 DIBROMOCHLOROMETHANE .NO 50 79-00-5 1.1,2-TRICHLOROETHANE ND 50 71-43-2 BENZENE . ND 50 10061-01-5 Cs-1,3-DCHLOROPROPENE NO - 50 110-75-8 2-CHLORoETHYL VINYL ErHER ND 100 75-25-2 BROMoFORM ND 50 127-18-4 TerRA Cm. oRoe THENE.. . 52 50 108-88-3 'ToLuENE -- 16 7 50 108-90-7 CHLOROSENZEHE NO 50 100-41-4 ETHYL BENZENE 10 50 TOTAL .XYLCNEs 6545 50 .1,2 DICHLORoBENZENE 1049p 50 1.4 DICHLOROSNZEN 143, 50

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I I OF ANALYSIS Ii ii .9 TO: PrRFECrION AUTO RADIATORa DATE REPoRTED: 8-29-89 --. DOUe Auousrus. CA rE RECErVED: 8-18-89 ' JOe NUMBER: 31-32035 LAS NUMBER: 4401

-A. SAMPLE DESCRIPTION:

CONTAMINA TED Sont PARAMETER - ANALYSIS DE TEC TION LII T ME THCD ToTAL SOL ios. X 78.0 SH 269A

OIL & GREASE (TPHC). kG/KG 1,216 1.0 SM 5033

SUPeRVISOR. 4 JJ

JEr-LINE ERVICES, INC. * 263 HoWARD STREET LOWELL, IMA 01052 *

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I I '-T-LINE.. CERTIFICATE OF ANALYSIS e .

TO: PERFECTION Auro RAQIA OOR DATE REPORTEZD: 9-8-89 Douc AuGusTus DATE RECEIVE 9-5-89 Joe NuMeER: 31-32035 LAS NUMER : 4444

SAMPLE DESCRIPTION: I-

OIL CONTAMINA TED SOIL

PARAMETER ANAL YSIS OETECTION LIMIT METHOD

TorAL Sotos, % 85 SM 209A (DUP) Oa & GREASE (TPHC), MG/KG 2762 2945 1.0 SH 5038

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4. SUPERVISOR

JET~rLINE VCs N, 265 AR R ET* LoweL, NA .01852 'I KNOW ALL MEN BY THESE PRESENTS

This Indenture, dated this 24th day of December, 1976,

by and between ROBERT W. MESERVE and BENJAMIN H. LACY, as they

are Trustees of the Property of Boston and Maine Corporation,

Debtor, and,not individually, (see In the Matter of Boston and

Maine Corporation, Debtor, United States District Court for the

District of Massachusetts, Docket No. 70-250-M) with offices at

150 Causeway Street, Boston, Suffolk County, Massachusetts, 02114,

hereinafter called the "Trustees", (which expression shall include

their successors and assigns where the context so requires or

admits) and tihe MASSACHUSETTS BAY TRANSPORTATION AUTHORITY, a

body politic and corporate and a political subdivision of the

Comonwealth of Massachusetts, established under the provisions

of Massachusetts General Laws, Chapter 161A, as amended, and having

an usual place of business at 45 figh Street in Boston, Suffolk

County, Massachusetts, 02110, hereinafter called the "Authority",

(which expression shall include its successors and assigns where

the context so requires or admits).

WITNESSETH that the Trustees, in consideration of Thirty

Six Million Five Hundred Forty Nine Thousand and no/l00 Dollars

($36,549,000.00), paid to them by the Authority, receipt whereof

is hereby acknowledged, the said Trustees hereby grant to the

Authority all of the said Trustecs' right, title and interest

(sufficient to permit the Authority to operate a passenger and

freight rail service over the rail line rights of way and. the

Boston Engine Terminal Area, as hereinafter described), in and

to the Trustees Railroad rights of way and other lands thereon and including all track, signals, bridges, buildings, shops, towers and other improvements affixed thereto, and all rights and easements appurtenant thereto, all of the aforesaid property hereby conveyed is described in the plans entitled: LAND IN MASSACHU-

SETTS Robert W. Meserve and Benjamin H. Lacy, Trustees of the

Property of Boston and Maine Corporation to the Massachusetts

Bay-Transportation Authority Scale: 1" = 100' Date: Dec. 1,

1975", Sheets 1 through 309, and noted as follows:

ESSEX COUNTY - NORTH - Recorded December 10, 1976, 16 sheets as Plan 7531 of 1976

VS 7.4 Maps SLl(r), 2, SL3, 4 VS 2 Maps 16, 17, 18, 19, 20(R), 21, 22(R), SL23, SL24, 25, 26, 27

ESSEX COUNTY - SOUTH - Recorded December 10, 1976, 87 sheets in Plan Book 141, Plan 20

VS 2 Maps 28, 29, 30, SL31, 32, 33, 34 VS 3 Maps 6, 7, SL8, SL9(R), SLl0(R), SLll, 12, 13, 14(R) SL15, SL16(R), SL17, 18, 19, 20, 21(R), 22, 23, 24, 25, SL26, 27, 28, 29, 30, 31, '32, 33, 34, SL35(R), 36, 37, 38, 39

VS 7.3 Maps 3, 4, 5, 6, 7, 8, 9, 10(R), 11, 12, 13, 14, 15 VS 7.12 Maps SLI, SL2, 3, 4, 5, 6 VS 7.13 Maps l(R), 2, 3, 4, 5, 6, 7(R), 8, 9, 10, 11, 12, 13, 14, 15, 16, 17 VS 13.7 Maps 4, 5, 6, 7, 8 VS 7.7 Maps 6, 7, 8(R), 9, 10

MIDDLESEX COUNTY - NORTH - Recorded December 6, 1976, 33 sheets in Book 123, Pages 74 through 106.

VS 2 Naps 15, 16 VS 13.1 Maps 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, SL23, SL24 is .L3.3 Maps 6, 7, 8 VS 13.6 Maps 1, 2, 3, 4 VS 15 Maps SL1, 2(R), 3, 4, 5, 6, 7, 8, 9 VS 7.18 Maps SLl

MIDDLESEX COUNTY - SOUTH - Recorded December 3, 1976, 141 sheets in Book 442, Sections A, B & C. (50 sheets to a section.) vs 1 Maps SLi, SL2, SL3a, SL5 VS 3 Maps SLl, SL2 VS 12 Maps SLl, SL2, SL2a, SL3 VS 35 Maps SL2, SL3 VS 5 Maps 1, A-1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, SL24, 25, 26 VS 13.1 Maps SLI, 2, 3(R), 4, 5, 6(R), 7, 8, 9(R), 10, 11 VS 13.2 Maps 1, 2(R), 3, 3a, 4(R), 5, 6(R), 7, 8,. SL9, 10, 11, 12, 13 VS 36.3 Maps 1, 2, 3, 8, 9(R), 10, 11, 12, 13 VS 13.4 Maps SLi, SL2(R) VS 13.5 Maps 1, 2, SL3 VS 7.7 Maps SLI, 2(R), 3(R), 4 5 VS 7.3 Maps 1 & Al(R), 2, 3 VS 36.1 Maps SLl, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40 VS 36.4 Maps 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15

SUFFOLK COUNTY - Recorded December 2, 1976 - 17 sheets in Book 8913 - End. vs 1 Maps SL1, SL2, SL2a, SL3a vs 3 Maps SL2, SL3, SL4(R), 5, 6 Li%):t, ,J

VS 7.7 - Maps 5, 6 VS 7.8 Maps 1, 2 VS 12 Maps SLl, SL2a VS 35 Maps SLl, SL2

WORCESTER COUNTY - NORTH - Recorded December 6, 1976, 10 sheets in Plan Book 212, Plans 4 - 8.

VS 36.1 Maps 40, 41, 42, 43, 44, 45, 46, SL47, 48, SL49

WORCESTER COUNTY - SOUTH - Recorded December 6, 1976, 5 sheets in Plan Book 432, Plan 57 (Sheets 1 - 5).

VS 5 Maps 26, 27, 28, 29, 30

but excepting therefrom the following five (5) bridges which are

identified by B&M Bridge Number and situated in the location listed and shown on the following plans:

1. B&M Bridge C3.43, located in Cambridge, Middlesex County, and shown on plan marked: "Plan of Land In Cambridge, Mass. Showing Bridge and Easement Granted to the Commonwealth of Mass. (D.P.W.) By Robert W. Meserve and Benjamin H. Lacy, As Trustees of the Property of Boston and Maine Corporation, Debtor Scale: 40' to the inch January 31, 1975 Office of the Vice Pres-Engineering Billerica, Mass.

2. B&M Bridge #4.15, located in Medford, Middlesex County, and shown on plan marked: "Plan of Land In Medford, Mass. Showing Bridge and Easement Granted to the Commonwealth of Mass. (D.P.W.) By Robert W. Meserve and Benjamin H. Lacy, as Trustees of the Property of Boston and Maine Corporation, Debtor Scale: 40' to the inch January 31, 1975 Office of the Vice Pres-Engineering Billerica, Mass.

3. B&M Bridge t7.39, located in Belmont, Middlesex County, and shown on plan marked: "Plan of Land In Belmont, Mass. Showing Bridge and Easement Granted to the Commonwealth of Mass. (D.P.W.) by Robert W. Meserve and Benjamin H. Lacy, as Trustees of the Property of Boston and Maine Corporation, Debtor Scale: 40' to the inch January 31, 1975 Office of the Vice Pres-Engineering Billerica, Mass. 4. B&M' .idge #9.17, located in W tham, Middlesex County, and shown on plan marked: "Plan of Land, In Waltham, Mass. Showing Bridge and Easement - Granted to the Commonwealth of Mass. (D.P.W.) by Robert W. Meserve and Benjamin H. Lacy, as Trustees of the Property of Boston and Maine Corporation, Debtor Scale: 40' to the inch January 31, 1975 Office of the Vice Pres-Engineering Billerica, Mass.

5. B&M Bridge #25.19, located in Lowell, Middlesex County, and shown on plan marked: "Plan of Land In Lowell, Mass. Showing Bridge and Easement Granted to the Commonwealth of Mass. (D.P.W.) by Robert W. Meserve and Benjamin H. Lacy, as Trustees of the Property of Boston and MHine Corporation, Debtor Scale: 40' to the inch January 31, 1975 Office of the Vice Pres-Engineering Billerica, Mass. to be recorded herewith and shown on Exhibit A(1 - 5) annexed hereto; said Grantors hereby reserve the right to convey said excluded bridges together with an easement for their location, maintenance and repair, as shcwn on said plans, to the Common- wealth of Massachusetts, Department of Public Works, on or before

December 31, 1981.

RESERVED FREIGHT EASEMENT

The Trustees hereby reserve unto themselves, their successors and assigns, the right and easement as are appropriate and necessary to the continuance of the Trustees' freight transportation business at present and reasonably foreseeable levels of traffic volume and activity and in the general manner in which it is now conducted; said reserved right and easement shall include reasonable access over the conveyed Real Estate to the easement areas without undue interference from the activities of the Author- ity. Concurrently, it is the general intention of the parties to this Instrument that the Authority, as the result of this conveyance, till own said Real Estate and, as owner, will have the right, subject to this reservation for freight purposes, to use, maintain and alter said properties as it sees fit and will-have the right to schCdul:e pnassenqer trains with priority over the Trustees' freight trains, provided said freight trains will move without undue interruption to freight service by the Authority and, further, the said Authority will exercise control over the use, condition, maintenance and operation of said property.

The-reserved freight easement, hereinabove referred to, shall also include the use of facilities in order to continue Trustees' freight service as set forth below:

(A) NON-LINE AREAS AND FACILITIES

1. Outside of the Boston Engine Terminal Area.

Outside of the Boston Engine Terminal Area, which

Area is shown on plan entitled: "Boston and Maine

Corporation Robert W. Meserve and Benjamin H.

Lacy, Trustees Scale: 1" = 200' Date:

December 1, 1975", said plan being marked Exhibit

"B", attached hereto and made a part hereof, the

Trustees shall retain the right and easement to continue

to use, and use in the future, all those areas of land

and buildings, And all of that equipment, excluding

passenger rolling stock, and all of the facilities other

than lines of railroad including, but not limited to

yards, freight buildings, public delivery facilities,

buildings now located in the Town of Billerica,

all shops and all servicing facilities situated outside

of said Boston Engine Terminal area.

(a) Provided, however, the Authority shall have

the right to make such use as it may desire of said

Non-Line Areas to the extent that such use by the

Authority does not materially interfere with the ( then current or then reasonably foreseeable use of.

such Non-Line Areas and Facilities by the Trustees

in conducting railroad freight operations; provided,

further, that in the event such use by the Authority

materially interferes with the Trustees' use of such

Non-Line Areas or Facilities, then the Trustees

shall be provided equivalent, substitute areas or

facilities for use by the Trustees, but without -

interruption of the Trustees' use of such Non-Line

Areas or Facilities and at no cost to said Trustees.

(b) Provided, further, that during such time as the

Non-Line Areas or Facilities are used exclusively

by the Trustees, said Trustees shall, at their own

expense, maintain and keep such non-line areas

and facilities in as good order and repair as they

are at the time of execution of this instrument,

reasonable wear and tear excepted. Provided,

further, at such time as such non-line areas and

facilities shall be used by the Authority in con-

junction with Trustees, the expenses relating to

the non-line areas and facilities shall be borne

jointly in accordance with their use as determined

initiAlly by that Agreement entitled: "OPERATING

AGREEMENT" by and between the Trustees and the

Authority, dated March 18, 1976, which OPERATING

AGREEMENT is attached hereto and made a part hereof,

and marked Exhibit "C", or as the same may be

amended or extended, and thereafter by any written

Agreement which shill be- entered into betWClen the

Trustees and: tho Authorit.. (c) Provided, further, the Trustees' right to continue to use, or to use in the future, "Non-

Line Areas or Facilities" and the Trustees' obligatior to maintain same, which obligation shall cease in the event that any of the following contingencies occur:

(I) A voluntary surrender of such use of "Non-Line Areas or Facilities" by the Trustees as evidenced by notice to that effect given to the Authority, or

(II) In the event the Authority shall

(i) have a bona fide Use for such "Non- Line Areas or Facilities" in connection with its rail or transit commuter service, or

(ii) have a bona.fide specific intention to sell or lease such "Non-Line Areas or Facilities", or

(iii)- have a bona fide specific intention to make improvements or repairs to such "Non-Line Areas or Facilities", which repairs the Trustees have, in writing, declined to make or which the Trustees fail to make after reasonable opportunity and after receipt of notice concerning said improvements or repairs provided that the Trustees are not then using, nor have any then reasonably foreseeable need to use, such "Non-Line Areas or Facilities".

In the event the Trustees do cease to use and maintain, as provided above, said Authority shall be entitled to a release of such rights, executed in recordable form, but said release shall be recorded only in the event of the conveyance or long-term lease of the "Non-Line Areas or Facilities" involved. In the event such conveyance or long-term- lease

does not occur, as intended by the Authority, or such

improvement or repair is not accomplished within six

(6) months after the Authority's notice of its

intention to make such improvement or repair has been

given to the Trustees, then the release shall be

returned to the Trustees and the Trustees' rights

shall return to the status quo prior to notice of

the Authority's intention.

(d) Trustees' right to continue to use machinery

which is included in the "Non-Line Areas and

Facilities" shall not include the right to move

said machinery without prior approval of the

Authority; provided, further, right to continue

to use said machinery shall impose no obligation

upon either the Authority or the Trustees to maintain,

repair or replace said machinery.

2. Non-Line Facilities Within the Boston EnFine Terminal Area.

Except as hereinafter provided, the right of the

Authority to use and control "Non-Line Areas and

Facilities" within the said Boston Engine Terminal

Area shall be exclusive and the right of the Trustees

to continue to use "Non-Line Areas and Facilities"

shall not extend to or include those lands, tracks,

buildings and facilities situated within the Boston

Engine Terminal Area, except in the following instance (a) The Trustees shall have the continuing right use, in conjunction with the Authority, both

through line and any necessary tracks which provid< any access thereto within the Boston Engine

Terminal Area, which through line tracks and access tracks are necessary to service facilities.

(b) The Trustees shall have the right to use, in conjunction with the Authority, sanding, fueling and minor locomotive repair facilities, as they currently exist or may be suitably replaced or altered, within the Boston Engine Terminal Area.

(c) Trustees shall have the right to use, in conjL tion with the Authority, the existing diesel house, storage facilities, wheel truing machine, drop pit, and associated facilities in the "Track 40 Area", all of which are included in the area of Joint Use within the Boston Engine Terminal Area, as defined in Exhibit "B", together with space for.a wrecker and snow plow, and the freight car repair facilities adjacent to said diesel house.

The Trustees' right to continue to use the existing diesel house, storage facilities, wheel truing machine, drop pit and associated facilities, as well as space for wrecker and snow plow and space adjacent to diesel house shall terminate upon the expiration of one year after receigft of written notice of such termination by the

Authority; provided, however, that no such notice of termination shall be effective if it is W .- 6 6

of two (2) years from the date hereof; provided,

further, no such termination by the Authority

shall give the Trustees any right to either

substitute facilities or to economic damages.

(d) The Trustees shall pay to the Authority

for such use as they may make of the facilities

described in sub-paragraph (b) and (c) above, a

sum equal to- their share of the maintenance costs

of such facilities as each party's use of such

facilities relates to the total use of such

facilities by the Trustees and the Authority. (B) PERIMETER LINES

The Trustees shall have the continuing right and easement to use, in the conduct of their freight services, the following lines hereinafter referred to as "perimeter lines", which termination shall include related trackage, freight service buildingE and signal facilities. Perimeter Lines are as follows:

WEST ROUTE MAIN LINE NEW HAMPSHIRE/MASSACHUSETTS BORDER (Val. Sec. 2, Map 34, Sta. 1921+14.73) TO LOWELL JUNCTION, MASSACHUSETTS (Val. Sec. 2, Map 17, Sta. 1037+00)

NEW HAMPSHIRE MAIN LINE BLEACHERY, MASSACHUSETTS (Val. Sec. 13.1, Map 23, Sta. 1299+00) TO NEW HAMPSHIRE/MASSACHUSETTS BORDER (Val. Sec. 15, Map 9, Sta. 1818+41.0)

FITCHBURG ROUTE MAIN LINE WILLOWS (AYER), MASSACHUSETTS (Val. Sec. 36.1, Map 33, Sta. 1778+38.2) TO FITCHBURG, MASSACHUSETTS (Val. Sec. 36.1, Map 49, Sta. 2619+12.44) Provided further, the Trustees' right and easement to continue to use the perimeter lines shall last as long as Trustees have either current use, or any then reasonably foreseeable use, for the perimeter lines and the Authority shall not have the right to terminate the Trustees' use therein either by providing substitute facilities or the payment of economic damages or for any other reason.

Provided, further, that when the Trustees have no current, nor then reasonably foreseeable use, the said Trustees shall execute a release of their rights in said perimeter lines, which release shall run to the Authority. In the event that the

Trustees and the Authority disagree as to what constitutes foreseeable use, as set forth aforesaid, then such dispute shall be resolved in accordance with the Section of this Instrument entitled:

"Arbitration".

Provided, further, that, since there is no rail passenger service conducted on the perimeter lines, with the exception of the New Hampshire Main Line between Lowell and Bleachery, Massa- chusetts, and, as long as the Authority does not conduct passenger rail service on or over a perimeter line, then all aspects of operation, maintenance and repair of said perimeter lines shall be in the exclusive control and at the expense of the Trustees.

Provided, further, the Authority shall have the right to use said perimeter lines at any time, but upon the terms and conditions as set forth under the clause entitled: "Jointly Used

Lines" hereinafter set forth, provided that such use by the Author- ity shall not interfere with the ability of freight trains operated by the Trustees to enter, pass through or work upon said porincter lines w.,ithout_ umaterial delay. - a - / (C) OTHER LIN..

All of the rail lines contained in the above described parcels, other than those described as "Perimeter Lines", shall

be hereinafter referred to as "Other Lines." This ter shall

include all related trackage, freight service buildings and signal

facilities, and the Trustees hereby reserve the continuing right

and easement to use the "Other Lines" in the conduct of their

freight service, subject, however, to the following provisions:

1. The following lines, comprising a portion of "Other

Lines" shall be used exclusively by the Trustees and which "Other

Lines" the Trustees specifically reserve unto themselves the.

right and easement to use'in the conduct of their railroad freight

service:

EASTERN ROUTE MAIN LINE IPSWICH TO STATE LINE

SAUGUS BRANCH EVERETT JCT. TO WEST LYNN

EAST BOSTON BRANCH ' REVERE TO EAST BOSTON

SALEM AND DANVERS BRANCH SALEM TO DANVERS WEST PEABODY TO SO. MIDDLETON

WESTERN ROUTE MAIN LINE WILMINGTON JCT. TO LOWELL JCT.

NEWBURYPORT BRANCH WAKEFIELD JCT. TO TOPSFIELD

M AND L BRANCH LAWRENCE TO STATE LINE

STONEHAM BRANCH MONTVALE TO STONEHA4

BILLERICA BRANCH NO. BILLERICA TO BILLERICA FITCHBURG ROUTE lb ±N LINE SOUTH ACTON TO WILLOWS(AYER)

FREIGHT CUT OFF SOMERVILLE JCT. TO HILL CROSSING

CENTPAL MASS. BRANCH CLEMATIS BROOK TO MARLBORO

BERLIN BRANCH GLEASON JCT. TO BERLIN

MAYNARD BRANCH SOUTH ACTON TO MAYNARD

GREENVILLE BRANCH AYER TO STATE LINE

WILMINGTON JUNCTION PPANCH WILMINGTON TO WILMINGTON JUNCTION

These lines shall be referred to as "Freight ,f,, Only Lines" unless said lines are converted to "Jointly Used C

Lines" by the Authority under its reserved right to determine from time to time, which of the line or lines used only for railroad freight purposes shall thenceforth, and until further notice from the Authority to the Trustees, be used for railroad freight purposes jointly with.the railroad or transit passenger service of the Authority, as if said lines had been originally described and categorized as "Jointly Used Lines". This right of the Author- ity shall, in each instance, be exercised only upon at least thirty

(30) days prior written notice, in writing, given by the Author- ity to the Trustees.

2. The following rail lines included in the.Real Estate shall be used jointly for both railroad freight service conducted by the Trustees and railroad or transit pAssenger services conducted by the Authority or on the Authority's behalf: EASTERN ROUTE MAIN LINE BOSTON TO IPSWICH

GLOUCESTER BRANCH BEVERLY JCT. TO ROCRPORT

NEW HA?.:P SHIRE ROUTE MAIM LINE BOSTON TO LOWELL

WOBURN BRANCH WINCHESTER TO WOBURN

FITCEBURG ROUTE MAIN LI?E BOSTON TO SO. ACTON

LEXINGTON BRANCH W. CAMBRIDGE TO BEDFORD

(D) CONTROL AND MAINTENANCE OF ON-LINE EASEMENT PROPERTIES

1. Freight Only Lines

Trustees shall have sole operating and maintenance control over all "Freight Only" rights of way and related on-line facilities, including but not limited to tracks, track materials, appurtenances, buildings, structures and railroad equipment as long, in each instance, as such rights of way are not being used in Authority's passenger operations. The Trustees will, at their cost and expense, maintain the same in proper and safe condition for the freight use to which they are put, in each instance, and repair, replace and renew the same when and as it appears tobe reasonably necessary and desirable to do so.

2. Jointly Used Lines

(a) Control.

Authority shall have the control over the use, scheduling of passenger trains and operation of "Jointly Used Lines" but may, from time to time, under agreement with the Trustees delegate the actual day to day operating control, dispatching and scheduling to Sellers. In the exercise oz its control over the Jointly Used Lines, Authority will make all reasonable efforts

to expedite the movement of freight trains, including expediting

repairs to lines and the reuaval of obstructions and scheduling

regular maintenance and repair programs at hours which will not

unreasonably interfere with such movement.

(b) Maintenance of Jointly Used Lines.

The party to whose standards a given line is being

maintained, as hereinbelow provided, shall herein be referred

to as the "Maintaining Party". The Authority shall be considered

to be the "Maintaining Party" of any Jointly Used Line being

maintained to Authority's standards notwithstanding the fact that

actual maintenance may be performed by Trustees under contract

with Authority.

The "Maintaining Party" shall perform the maintenance

work necessary or desirable to maintain the Jointly Used Lines

and related on-line facilities in a proper and safe condition

and repair, replace and renew the same when and as it appears

necessary and desirable to do so in order to maintain them in a proper and safe condition in accordance with applicable Federal

and state standards and regulations. Such maintenance shall be

in compliance with standards to be set from time to time by the

Authority as evidenced by a written notice given by the Authority

to the Trustees setting forth objective criteria including the

applicable F.R.A. standard, except that if the Trustees desire

to maintain a Jointly Used Line and related on-line facilities

in compliance with standards that are higher than those so set by the Authority, they may do so upon giving similar written no-

tice to the Authority and thereafter, until the giving of further notice which may be given by either party reestablishing the Author-

ity's standard as the governing standard of maintenance, such

line and related on-line facilities shall be maintained to Trus-

tees' standards. From the date hereof, and until further notice, the following lines shall be maintained to the Authority's standards: Eastern Route Main Line, Boston to Ipswich; Gloucester

Branch, Beverly Junction to Rockport;, New Hampshire Route Main

Line, Boston to Lowell; Woburn Branch, Winchester to Woburn; Fitch- burg Route Main Line, Boston to South Acton.

All maintenance costs and expenses relating to the

Jointly Used Lines shall be borne in the first instance by the

"Maintaining Party". The other party, hereinafter referred to as the "Contributing Party", shall pay to the Maintaining Party an amount determined according to the formula contained in subparagraph (d) below toward the maintenance costs and expenses borne by the Maintaining Party during such calendar year. Such payments shall be made, on account, quarterly, according to reasonable estimates and there shall be an adjustment annually, within 90 days following the close of each year.

The Maintaining Party shall expend, in each calendar year subsequent to the year 1976, in connection with the maintenance of all Jointly Used Lines, not less than the amount of the

Contributing Party's contribution to the maintenance costs and expenses relating to Jointly Used Lines for the prior year.

(d) Calculation of Contribution to Miaintenance Costs.

(i) Signals and Crossing Protection Devices.

To calculate the Contributing Party's obligation to contribute toward the costs of installing, taintaininq, repairing and .perating signals and gradt crossing Protection devices on Jointly Used Lines, the Trustees' average systenwide signalling and grade crossing protection cost per train mile on signalled Main Track Lines which are under the operating. and maintenance control of the Trustees will be calculated for each calendar year, using relevant ICC Accounts, as shown on Exhibit D annexed hereto. The average cost per train mile thus obtained shall be multiplied by the number of train miles run by or for the account of the contributing party in such year over Jointly

Used Lines.

(ii) Other Line Maintenance Expenses.

For all other line maintenance expenses (including, without limitation, the costs of installing, repairing and maintaining tracks, ties, ballast, embanknents, abutments, bridges and other right-of-way structures) on Jointly Used Lines, the

Trustees' average system-wide cost per gross ton mile on all Main

Track lines which are under the operating and maintenance control of the Trustees- will be calculated for each calendar year using relevant ICC Accounts maintained in accordance with the procedures existing at the date of this instrument, as shown on Exhibit E annexed hereto, and the share of such costs incurred with respect to Jointly Used Lines which shall be payable by the Contributing

Party will be equal to the number of gross ton miles run by or for the account of such party in that year over such Jointly Used

Lines multiplied by such average cost per gross ton mile. (E) OTHER PRt aIONS RELATING TO FREIG -ASE.IENT.

1. Rights of Parties to Make Alterations

In the event that the Authority shall alter or increase

(which terms shall not include termination or diminution of passenger se rvice) its use of Freight Only Lines, Jointly Used

Lines or Perimeter Lines and related facilities, to the extent that, or in such a manner that, Authority's use unduly interferes with the ability of the Trustees to provide freight service at present or reasonably foreseeable levels of volume and activity as presently conducted, Authority shall provide substi- itute or additional facilities (on the same right of way in the case of Perimeter Lines) adequate to permit such freight service. or, with respect to lines other than Perimeter Lines, pay damages as appropriate under the circumstances. In implementation and not in limitation of the foregoing sentence, it is further agreed that:

(a) The Authority shall, at all times, make available to the Trustees rail access to all of their present freight service locations, so long as, in each instance, there are shippers or receivers actively using, or reasonably in prospect to use, such locations.

(b) Authority shall not move any of Trustees' public delivery tracks unless it moves them (in compliance with all applicable laws and regulations) to new locations nearby their present locations, with substantially equivalent work space and high- way access, at no cost to Trustees. Any such new location shall be suitably connected with either the sane line as the original connection or a line approved by the Trustees, whose approval' shall not be unreasonably withheld. (c)' he Trustees, at their exponse, may install switches and sidings including any associated signalling to serve new loca-

tions. Such expense may include grade separation from rapid tran-

sit lies, if such separation is deemed necessary by the Authority.

All such installations shall be subject to the approval of the

Authority, whose approval shall not be unreasonably withheld.

(d) In the event of an alteration in the existing trackage or yard facilities desired or required by Authority,

Authority will provide, at no cost to Trustees, such substitute trackage or yard facilities as may be necessary to move freight trains between points now served by Trustees on alignments cap- able of elapsed times no greater than the average time in which

Sellers can, as of the date hereof, move freight trains between such points at speeds authorized, as of the date hereof, using equivalent motive power. In the event that operations of the

Authority require signalling on certain trackage or in certain yards more extensive than that presently existing, Authority shall equip such trackage, yard facilities and necessary freight rolling stock with all reasonably necessary signalling devices.

(e) Authority shall provide and maintain clearance and load carrying capacity on each Jointly Used Line or Perimeter

Line under the control of the Authority at least equal to the physical minimum existing thereon as of the date of this Agree- ment. In the event of any new construction performed or permitted by the Authority, there will be erected no structure nor will any invasion of the air space over such line be permitted which will in any way obstruct the operation of trains thereon with equipment or cargoes extending to a height above the top of the rail up to the .ninimum clearance on such ,ine existing on the

date of this Agreement; nor will Authority erect or permit to

be erected any obstruction within 8 feet 6 inches of the center-

line of straight track or within 8 feet 6 inches plus 1 inch for

each degree of curvature of curved track. The Authority shall

not install any new track nor relocate any existing track less

than 13 feet (not less than 14 feet wherever reasonably feasible)

centerline to centerline from any other track if either track is being used by the Trustees in their freight service. Where

existing track is being reconstructed or former trackage is being reinstalled, Authority shall have the option of reconstructing

or reinstalling such track to clearances and alignments no more restrictive than those existing as of March 18, 1976. For the

purposes hereof the minimum clearance on any line other than a

Perimeter Line existing as of March 18, 1976 shall be the actual minimum clearance, or 22 feet above the top of the rail, which-

ever is less, and on a Perimeter Line shall be 22 feet above the

rail.

(f) Trustees may, at their own expense, alter or improve any part of the Real Estate other than the areas of Authority's

exclusive use referred to in (A) 2., and provided for in CE) 2.; provided that such alteration does not detract from the value of the Real Estate or materially interfere with Authority's then current or then reasonably foreseeable use of the Real Estate.

The plans and specifications for each such alteration or improvement involving an expenditure of more than $100,000 shall be sub-

ject to Authority's written approval prior to the conmencement of construction.

The preceding sentence shall not have the effect of liniting the Trustees' duties to obtain prior approval of plans for switches and sidetracks pursuant to Section 1 (c) above.

2. Termination of Trustees' Right to Use

The Authority may give written notice to the Trus-

tees of its desire to use exclusively a line or lines of railroad

property other than Perimeter Lines. Upon receipt of such notice,

the Trustees shall immediately prepare and file all such applica-

tions for governmental approval as may then be necessary as a

prior condition to the Trustees' abandonment of service on such

line, diligently prosecute the same and, when such approval becomes

final, cease operation on such line or lines. Authority shall

reimburse Trustees for all reasonable expenses including attorneys'

fees incurred in connection with the obtaining of such approvals.

In the event that compliance with the obligations contained in

this subparagraph causes Trustees to discontinue service to a

revenue-producing customer or customers, Authority shall pay

to Trustees, no later than seven days prior to actual discontinu-

ance of service over any line so abandoned economic damages determined as follows:

(a) Determine Trustees' total railway operating

revenue from traffic originated by or destined to such customer or customers to whom service has been or will be discontinued

(including only Trustees' share of the total revenues derived.

from the movement) during the last full calendar year prior to the notice from the Authority with respect to the line serving

such customer called for by the first sentence of this subsection

2. (b) Determine the Trustees' avoidable costs.of

originating or terminating such movement by adding the following

elements as they relate to the subject traffic;

i. Costs relating to Trustees' use of line or a portion of a line to be terminated:

Maintenance of way (Trustees' share); Maintenance of equipment (Trustees' share); Transportation (Trustees' share); Car Hire or Car Cost (Trustees' share); Other costs, if applicable (Trustees' share);

ii. Costs relating to use of Trustees' lines

other than the line to be terminated:

Beyond line costs, according to "Fifty percent (50%) formula". (The formula multiplies the line's pro rata mileage (ratio of number of miles travelled on the line to total number of miles travelled on the system) by the gross revenue generated, subtracts the product (gross revenue credited to the line) from the total gross revenue, and takes 50 percent (50%) of the resulting sum as the beyond line cost).

In the event freight service is eliminated over a through

line by action of the Authority, in addition to the economic damages relating to the discontinuance of service to revenue-producing customers, the Authority will provide an alternate route with the clearances at least equal to those provided for in subparagraph (E) 1. (e) above, with load carrying capacity equal to those existing on the eliminated line, at no cost to Trustees and without interruption in Trustees' ability to render their through service efficiently. S923 46 Once freight service has been legally abandoned, pur-

suant to a final order or orders of the Interstate Commerce Com-

mission and any other Federal or State reg;ulctory bodies having,

at the time, jurisdiction over the matter of continuance of rail

freight service on such line, the easement hereby provided for

shall terminate with respect to such line and the Trustees shall

have no right to reinstate rail freight service thereon without

prior written approval of the Authority, regardless of whether

such abandonment was at the request of the Authority or whether

it was upon the Trustees' own motion.

3. Access.

With respect to the properties retained by the Trustees

lying between Somerville Avenue, Cambridge and the Real Estate

as shown on Exhibit "B", the Trustees shall have the right to

grant to-parties to whom they may convey or lease any of said

retained -properties, the right, in common with the Authority and

others, to use the existing Private Way defined on Exhibit "B"

for egress and ingress on foot or in vehicles.

Trustees shall by their deed retain an easement to

construct an access road up to four (4) lanes in width through

the area lying between Washington Street, Somerville and the High

Line, so-called, defined as the "Yard 8 Access" on Exhibit "B",

for the purpose of providing vehicular and pedestrian ingress

and egress between Yard 8 and said Washington Street. Said road

shall be constructed so as to provide grade separation from the

High Line until such time as Authority shall operate a rail con-

nection between the New Harrshire Route rain Line and the Fitch-

burg Route Main Line or any other route alternat ivc to the High

Line. At any time thereaftar ':rs t ecs shall h-cr the option to require the Authority to convey to the Trustees the whole or any part of that portion of the High Line, defined as the "High Line

Segmcnt: on Exhibit "B", without payment of additional consideration; and thereafter the said access road may be constructed at grade. The layout of the said access road shall not interfere with the functioning of Tower X or the Ne: Hampshire Route

Main Line, as then located or laid out, and shall be subject to the Authority's prior approval, which shall not be unreasonably withheld.

4. Right to Provide Freight Service to be Exclusive.

The Trustees' right to continue to provide freight service. as hereinabove provided shall be exclusive in that no other carrier shall have the right to provide freight service over and upon any of the lines to be conveyed hereunder, except as follows:

(a) To the extent that the Trustees have entered into joint operating agreements granting rights to operate over said lines to other carriers, the operation or operations of such other carriers, pursuant to such arrangements shall be treated as operations of the Trustees for all purposes hereunder. No such joint operating agreements with other carriers shall be entered into after the date hereof without the prior written approval - of the Authority (which shall not be unreasonably withheld) provided that no such approval of the Authority shall be necessary for runthrough agreements where trains are operated by the Trus- tees' crews.

(b) The Authority shall, after the date hereof, have the right to transport baggage and its o-:n matt*-rial over and on such lines and such transportation shall not be considered freight service.

(F) GENERAL PRINCIPAL OF COST ALLOCATION

It is the general intention of the parties hereto that, except as more specifically provided hereinabove or in the separate agreement entitled "Operating Agreement", dated March 18, 1976, (Exhibit "C") or any extension or amendment thereof, all direct costs and expenses resulting solely from or attributable solely to-freight operations will be borne solely by Trustees and all direct costs and expenses resulting from passenger operations will be borne solely by Authority. Overhead or joint expenses will be apportioned between the Trustees and

Authority on the basis of relative use of the facility or department in question. The use of a facility or department by any person claiming by, through or under either party hereto shall, for the purposes of cost allocation, be deemed to be such party's use. In the event of a fundamental change in the underlying concepts upon which provisions hereof relating to allocation of costs and expenses are premised (such as might be caused by inclusion of Trustees in Conrail, a federal or state consolidated facilities program or other government ownership of facilities) by which any specific provisions for the allocation of costs and expenses are rendered inequitable, such provisions shall, at the request of either Authority or Trustees, be renegotiated in good faith so as to provide for an equitable allocation under the changed conditions. S923 .19 ELECTRICAL AND WATER EASEMil1TS

A. ELECTRICAL EASEMENTS.

The Trustees hereby reserve to themselves, their suc-

cessors and assigns, the right and easement for the location

of electrical lines and equipment in that area of the Real Estate

defined on Exhibit F annexed hereto entitled: Trustees' Electrical

System - Boston Yards, December 31, 1975"; which reservation shall

include the right to flow electricity through said electrical

system to serve the Trustees' freight easement and for any other

use, now or in the future. Said reserved easement shall also

include right to install, inspect and maintain, repair, operate

or remove electrical lines and equipment within the said freight

easement area and the right to use said reserved area and electri-

cal system in conjunction with the sale of electricity by the

Trustees to other partis, including but not limited to the Author-

ity and to new customers, insofar as the Trustees lawfully may,

provided, however, the Trustees' exercise of such rights shall

not substantially interfere with the operations or the electrical needs of the Authority. Such sale of electricity by the Trustees to other parties shall be with the right to profit therefrom without any obligation of the Trustees, either to account to or to pay to the Authority, any portion of the revenues arising there-

from or any other consideration. All of the electrical lines and equipment located within said area as of the date hereof, and all such lines and equipment hereafter installed therein by the Trustees, shall be and remain the sole property of the

Trustees and the existence of this easenent shall in no way be considered as establishing either a joint facility or a joint enterprise with the Authority. The Trustees shall also have the

right to assign their reserved rights herein to either the Cambrid=

Electric Company or any other comparable public utility at any

time within ten (10) years from the date hereof.

Provided further, that with respect to the Boston En-

gine Terminal Area, defined on Exhibit "B", Trustees hereby re-

serve to themselves, their successors and assigns, the right and

easement to use and maintain the electrical lines and facilities

existing therein as of the date hereof, as long as such use and

maintenance does not interfere with Authority's operations or

use of the Real Estate, together with the right and easement to

install and maintain electrical service to Yard 8 and those prop-

erties retained by Trustees lying between Somerville Avenue and

the Real Estate all as defined on said Exhibit "B", provided,

however, that any such installation and maintenance shall not

substantially interfere with Authority's operations or use of

the Real Estate and, provided further, that such installation

and maintenance shall be subject to the prior approval of the

Authority, which shall not be unreasonably withheld.

In the event that Authority alters the electrical lines or facilities existing as of the date hereof within said Boston

Engine Terminal Area, the Trustees shall have the right to make an electrical connection at Trustees' cost to either a public utility or a source of the Authority, whichever shall be more economical for the Trustees, provided that such connection shall not substantially interfere with Authority's operations or use of the Real Estate. !h.mj dpv~i qPa

B. ELECTRICAL COVENANT.

The Trustees further covenant and agree with the

Authority that insofar as they lawfully may, Trustees shall supply

electricity to Authority at the appropriate Cambridge Electric

rate as long as Trustees retain the easenent reserved in Paragraph

A above.

C. WATER EASEMENT

The Trustees hereby reserve unto themselves, their

successors and assigns, the right and easement to take water

from the 12-inch main through an 8-inch connection at point "A"

and through a 12-inch connection at point "B" as shown on Exhibit

G annexed hereto entitled "Sellers' Water System - Boston Yards,

December 31, 1975"; which reserved easement shall include the reserved right to flow water through said connections to serve

the freight easement and for any other use, now or in the future, at not less than the rate currently maintained and without unreasonable.interruption of flowage at any time. Included in the reserved easement is the right to inspect and maintain, repair, operate, renew or remove the said connections and said line between points "A" and "C" in a manner which shall not substantially interfere with Authority's operations or use of the Real Estate.

The Trustees shall be solely responsible for the inspection, maintenance and repair of said line between points "A" and "C", and

Authority shall not be obligated to contribute to the cost thereof.

Subject to the terms in the final paragraph of this Section C, the Authority will be solely responsible for the inspection, maintenance and repair of the lines between point "C" and points

"D" and "E", but subject to the Trustees' obligations to contribute to the cost thereof as provided hereafte-r. S923 52 The quantity of water taken at point "A" will be esti-

mated and the quantity of water taken at point "B" will be and

shall be metered, except for water used for fire protection, but

if requested by the Authority, the Trustees shall install a water

meter at point "A", at the expense of the Authority (or, if de-

sired by the Trustees, they may install such meter at their own

expense) to give an accurate measure of the usage of water through

that connection.

The water line between points "D" and "F" as shown

on Exhibit G shall continue to be owned by the Trustees, provided,

however, the Trustees hereby reserve to themselves, their succes-

sors and assigns, the right to inspect, maintain and repair the

said line on the Real Estate to the extent that it is located

thereon. The Trustees shall be solely responsible for the inspec-

tion, maintenance and repair of said line but the Authority shall

be obligated to contribute to the cost thereof as provided below.

The Authority shall have the right, subject to the rights of the

Trustees and all those parties who have the right (claiming by,

through or under the Trustees or otherwise) to tale water from

the said line through the connections located between points "D"

and F", to receive water through the said line at point "D"

for any use, at not less than the rate currently maintained and

without unreasonable interruption of flowage at any time.

In each calendar year the Trustees shall be responsible

for so much of the cost of inspecting, maintaining and repairing

of all those portions of the water line shown on Exhibit G lying

between points "C" and "F" and "C" and "E" as shall be proportional S923 53 to the fraction of which the denominator is the total volume of

water passing through points "E" and "Y"' in said year and the

numerator is the sum of the volumes of water passing through the

connections at points "A" and "B", and through all connections

lying between points "D" and "F", during said year. The Author-

ity shall be responsible for the remainder of such cost, subject

to Trustees' duty to contribute thereto in accordance with Pro-

vision contained in Paragraph (A)2(d) of the Reserved Freight Easement.

Provided further, the Authority shall have the right

to discontinue the aforesaid reserved right of the Trustees to

take water at points "A" and "B" at any time upon not-less than

ninety (90) days' prior written notice, provided that in such .

event the Authority shall grant to the Trustees, without further consideration, upon written requesttherefor made to the Author- ity by the Trustees, such easement or other reasonable rights as may be necessary to enable the Trustees to install and maintain, at their expense, a water main and connections adequate to supply the Trustees' needs for water for its freight service as well as the needs of any customers of the Trustees who are then receiving water from the connections at points "A" and/or

"B", which easement arid connection shall be so located as to con- nect points "A" and "B" with either a public water line or a water line of the Authority, whichever shall be the most economical for the Trustees, provided that such connection shall not substantially interfere with the Authority's operations or use of the Real Estate. D. WATER COVENANTS

The Authority covenants and agrees, for-itself, its successors and assigns, to pay the public supplier for all of the water taken at points "E" and "F" as determined by the- meters located at said points. The Trustees covenant and agree to pay Authority for the estimated water taken at point "A" and for the metered water taken at point "B" and at all connections lying between points "D" and "F" at the prevailing water rates of the City of Somerville in existence from time to time.

LABOR PROTECTION.

The Authority covenants and agrees, for itself, its successors and assigns, to indemnify and exonerate the Trustees to the extent provided hereinbelow, against the cost of (and be responsible for) obligations, liability, or claims due to provisions of Trustees' labor agreements, including labor protective conditions of such agreements, or of labor protective conditions imposed by regulatory agencies or applicable laws. The

Authority's obligation to indemnify and exonerate shall arise when employees or positions are adversely affected as a result of changes in the passenger service (including termination thereof), passenger facilities, or both, or by reason of the future contracting out or other removal or termination of work previously, now, or hereafter performed by the Trustees' employees to the extent that such change, termination or contracting out is the result of an action taken by, or with the consent of, the Authority.

It is further understood and agreed that an action taken by the Authority may have effects remote from the initial position or pc .,ions affected by such at -un as a result of successive seniority displacements, and it is the intention of the parties hereto that the indemnification and exoneration herein provided shall extend to such more remote effects.

If the initiating action affects a position or positions solely engaged in the "Service", (as "service" is defined in the

Operating Agreement dated March 18, 1976, Exhibit "C", as amended and extended) the Authority will pay all such costs. If the initiating action affects a'position or positions engaged in both passenger service and freight service, the Authority will pay the cost to the extent that it is solely traceable to the action taken by, or with the consent of, the Authority. In the event that in any instance the applicability of the irnediately preceding sentence produces a result which is manifestly unfair to either party, the sharing of such termination cost will,be renegotiated in good faith so as to provide for an equitable allocation thereof.

It is further understood and agreed that the Trustees shall use their best efforts to mitigate liability to such employees and that the Authority shall be permitted to participate, within reason, in such efforts.

The Authority will pay to the Trustees such funds as may be required to satisfy Authority's obligation to indemnify and exonerate the Trustees hereunder, concurrently with the delivery of evidence of payment by the Trustees. Trustees agree to keep Authority currently informed, to the extent that the Trus- tees can reasonably do so, of all aspects of local and national labor negotiations which might reasonably be expected to expand or broaden the scope of the protective provisions (i.e., provisions relating to termination rights) of laEbor agreenents. S923 6 -DENT RESPONSIBILITY

In the event that the Trustees shall cease to conduct

passenger service for the account of the Authority, pursuant

to the Operating Agreement or a successor operating agreement,

the following terms and conditions shall immediately become effec-

tive with respect to events occurring after such cessation:

A. In the event that harm, damage or injury (including

death) is caused by the negligence or other act for which one

of the parties hereto is legally responsible without any contri-

butory negligence or legal responsibility on the part of the other

party hereto (except in circumstances described in C below) and

said harm, damage or injury (including death) occurs to the

property of, or in the custody of, one of the parties hereto, to

property used jointly by the parties, to the employees, passengers

or licensees of either party, to common agents or employees or to

third parties, the party which caused such harm, damage or injury

(including death) shall bear all of the cost, expense and liability

arising therefrom and shall save harmless the other party from and

against any loss, cost or expense connected therewith. (This Sec-

tion is not intended to confer any rights upon third parties.)

B. In the event that harm, damage or injury (including

death) is caused solely by an act or omission for which a third

party is legally responsible, to the property of, or in the

custody of, one of the parties hereto, or to the employees, pas-

sengers or licensees of one of the parties hereto, that party shall

assume all loss, cost and expense arising therefrom, without contri-

bution from the other party. (This Section is not intended to

relieve any third party from any liability.) S923 57

C. In the event that harm, damage or injury (including

death) is caused by the condition of jointly used lines, facili- ities or equipment to the property of, or in the custody- of, one

of the parties hereto, or to the employees, passengers or licen-

sees of one of the parties hereto, that party shall assume all

loss, cost and expense arising therefrom, without contribution

from the other party, except that damage to such jointly used

lines, fAcilities or equipment shall be repaired by the Maintain-

ing Party subject to contribution from the other party as provided

in Paragraph F (General Principles of Cost Allocation) SUPRA.

D. In the event that -harm, damage or injury (including death) is caused by an act or omission for which both of the parties hereto are legally responsible and such harm, damage or injury (including death) occurs to the property of, or in the custody of, one or both of the parties hereto, or to the employees, passengers or licensees of one or both of the parties, each party shall bear all of the costs, expenses and liability arising from such harm caused to its own property, to property in its custody or to its employees, passengers or licensees. Any other loss, cost or expense so caused, including expense of repairing jointly used lines, facilities or equipment shall be divided equally between the parties.

E. In the event that harm, damage or injury (including death) is caused by an act or omission for which at least one of the parties hereto is legally responsible but in circumstances where legal rL-..ponsibility cannot be att-i.buted to one party or

the other, nor to both parties jointly, because of lack of evi-

dence or a conflict in evidence which cannot be resolved, by liti-

gation or otherwise, and said harm, damage or injury (including

death) occurs to the property of, or in the custody of, one or

both of the parties hereto, or to the employees, passengers or

licensees of one or both of the parties, each party shall bear

all of the costs, expenses and liability arising from such harm

caused to its own property, to property in its custody or to its

employees, passengers or licensees. Any other loss, cost or ex-

pense so caused, including expense of repairing jointly used lines,

facilities or equipment, shall be divided equally between the

parties.

F. In the event of any derailment or other accident occur-

ring upon the Real Estate wherein cars, motive power or other

equipment of either party shall fall or encroach upon tracks,

bridges or other property being used by the other party so that

said property is blocked or normal operation thereover is impeded,

the party whose property has so fallen or encroached shall expe-

ditiously remove the same and cause all necessary repairs to be

made and all tracks and appurtenances restored, at its expense,

as may be required for the continued operation of the other party's railroad activities.

Both parties agree to cooperate with each other to ex-

pedite the repair and removal of such cars, motive power and other

equipment and will make all reasonable efforts to restore the affected line or facility to service. 4 i ARBITRATION

A. Selection of Arbitrators.

If, at ainy time, a controversy shall arise which is

referable to arbitration according to subsection C of this Arbi-

tration Section, the parties hereto agree to engage forthwith

in good faith discussions attempting to resolve such controversy.

If the parties so agree, they may involve a disinterested person

experienced in railroad operations to render his objective advice

and opinions, which shall be advisory only and not binding unless

the parties agree in writing to be bound by his judgment in a

particular instance. In the event such good faith discussions

do not resolve such controversy within thirty (30) calendar days,

or such other time as the parties may agree in writing, the parties

shall submit such difference or dispute to disinterested arbitra-

tors, one of whom shall be appointed by the Trustees and the

other of whom shall be appointed by the Authority; and if the

two arbitrators so chosen cannot agree, they shall select a third

arbitrator, and their decision, or that of a majority of them,

shall be final and conclusive between the parties hereto, except

that if either party claims that the arbitrator's decision is

based upon an error of law, it may, within thirty (30) days after

receipt of such decision, institute an action at law to determine

such legal issue. In any such action at law, the parties shall

stipulate the facts to be as set forth by the arbitrators. In case

either of said parties shall fail or refuse to appoint an arbitrator

as aforesaid, for the period of thirty (30) calendar days after

written notice given by the other party to make such appointrent,. then and in th-c event the arbitrator appointed by the party not in default shall appoint a like competent and disinterested arbitrator for the defaulting party, and the said t-o arbitrators, so appointed, shall select a third arbitrator, and the three so chosen shall hear and decide such difference or dispute, and their decision, or that of a majority of them, shall be final and conclusive upon the parties hereto, except as above provided with respect to an error of law. In the event that the said arbitrators shall be unable to agree upon a third arbitrator within thirty (30) days after the appointment of the second arbitrator, such third arbitrator shall be appointed, upon the application of either party hereto, upon reasonable notice to the other party, by a Judge of the Superior Court for the Commonwealth of Massa- chusetts. Any application to such Judge as aforesaid shall be made and heard in the manner provided by law for the making and hearing of motions in said Court. If said Court declines to make such appointment, it shall be made by the President of the AssoL ciation of American Railroads. If any arbitrator shall decline or fail to act, the party or person by whom he was chosen or appointed, as the case may be, shall appoint another to act in his place.

B. Resolution.

During the pendency of such arbitration proceedings, the business, operations to be conducted, and physical plant to be used under this Agreement, to the extent that they are the subject matter of such controversy, shall continue to be transacted and used in the manner and form existing prior to the arising of such controversy, unless the arbitrators make a preliminary ruling to the contrary.

C. Matters Referable to Arbitration.

All controversies as to the construction of terms of this Agreement which are to survive the Closing Date and any prac- tical questions growing out of the application of the same to circumstances, except for claims for monetary damages in excess of $100,000, are referable to arbitration as provided in this

Arbitration section.

D. Cost of Arbitration.

Each party hereto shall bear the costs and expenses incurred by it in connection with such arbitration and both parties shall share equally the costs and expenses attributable to the services of the disinterested person or arbitrators.

- The Trustees and the Authority hereby covenant and agree that neither Robert W. Meserve nor Benjamin H. Lacy, nor any of their successors as Trustees of the Property of the Boston and Maine Corporation, Debtor, in the Proceedings for the Reorgani- zation of a Railroad, hereinabove referred to, shall be personally liable for the performance or non-performance of any of the Trus- tees' obligations hereunder, and that upon the transfer of the freight business and remaining assets of the Trustees to the Reor- ganized Debtor, or any other party, pursuant to a plan of reorgani- zation confirmed in said proceedings, or otherwise transferred the Authority and its successors and assigns, will thereafter look solely to such transferee and its successors and assigns for the performance of all of the Trustees' obligations hereunder. 4 t' -

Upon the said transfer of freight business and remain-

ing assets, whether to a successor Trustce or Trustees, to the

Reorganized Debtor, or to any other party or parties, all of the

rights and easements granted or reserved to the Trustees hereby

will inure to the benefit of any and all such transferees, whether

direct or remote, and their respective successors and assigns,

subject, in each instance, to the assumption by the transferee

of all obligations of the Trustees hereunder related to.the par-

ticular rights and easements transferred to such transferee.

Any voluntary transfer by the Trustees of the rights

and easements reserved or granted to the Trustees hereby to a

successor Trustee or Trustees, to the Reorganized Debtor or to

any other party that succeeds to substantially all of such rights

and easements, shall require as a condition thereof that the trans-

feree accept and assume all of the rights and obligations of the

Trustees as Operator under any operating contract between the

Trustees and the Authority then in effect.

This Indenture is executed in seven (7) counterparts

for the purpose of recording in seven (7) separate Registries

of Deeds where the real estate lies. Each counterpart contains

all of the provisions and attachments contained in this counter-

part. There is affixed to the counterpart to be recorded in Suf-

folk County Registry of Deeds Documentary Starps in the amount

of $83,331.72, and is available for inspection at that Registry.

The covenants contained in this Indenture are to be

binding upon the parties hereto and their successors and assigns

forever.

WIIEEPPS, on ?:cvrenhr 39, 1970', the said U. S. District

Court for th~e D)i::tric- W-r M.-;.'.~~1 I. 4 Docket No.: 70-250-N) authorized the said Trustees to convey this real estate to the Massachusetts Bay Transporation Authority, this conveyance is hereby made free from liens pursuant to said

Order.

TO HAVE AND TO HOLD the above described premises, with all the privileges and appurtenances thereto belonging to the said MASSACHUSETTS BAY TRANSPORTATION AUTHORITY, its successors and assigns, to their own use and behoof forever.

IN WITNESS WHEREOF the sa-id ROBERT U. MESERVE and

BENJAMIN H. LACY, as Trustees of the Property of Boston and. Mlaine

Corporation, Debtor, and not individually, have hereunto set their hands and seals, this 24th day of December, 1976.

ROBERT W. MESERVE and BENJAMIN H. LACY, as Trustees of the Property of Boston and Maine Corporation, Debtor

As Trustee and r t indiv'dually2

As Trnstee and not 7 i dually

COMM0ONWEALTH OF MASSACHUSETTS

Suffolk, ss Boston, ; :. c -i r ,1976

Then personally appeared the aboVe-named Robert W. Meserve, as Trustee of the Boston and Maine Corporation, Debtor, and acknowledged the foregoing instrument to be the free act and deed of said Trustee, before me

Notary Pub ic

My Comrmission expires: -- COMMONWEALTH OF MASSACHUSETTS K.1a

Suffolk, ss Boston, V:. - ~ 1976

Then personally appeared the above-named Benjamin H. Lacy, as Trustee of the Boston and Maine Corporation, Debtor, and acknowledged the foregoing instrument to be the free act and deed of said Trustee, before me

~1 -

( - -. - . * - r. ~9 Notary -Public -7 My commission expires: 6,

IN WITNESS WHEREOF the said MASSACHUSETTS BAY TRANS-

PORTATION AUTHORITY, by Robert R. Kiley, Chairman, has set its

hand and seal, this day of December, 1976.

MASSACHUSETTS BAY TRANSPORTATION APPROVED AS TO FORM: AUTHORITY

General Counsel

S C

COMMONWEALTH 07 MASSACHUSETTS

Suffolk, ss Boston, - a a .: 1976

Then personally appeared the above named Robert R. Kiley, as Chairman of the Massachusetts Bay Transportation Authority, and acknowledged the foregoing instrurent to be the free act and deed of said Chairman, before me

*1 / I y Notary ?4blic '4-, My Commission expires: ('"'';'-;: