Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup o n L
ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM "lt Trd;k-r0 Numtl." L lilL Pursuant to 310 CMR 40.1056 & 40.1070 - 40 1064 (Sutbpartl 16
A. DISPOSAL SIrE LOCATION:
. Disosis Sie Name Ralph Shuster Metals, Inc
2 Stree! Address 44 Forest Street ._...._......
3. cwto Attleborough_ _ 4 ZIP Cooe 70
5 Check here if a Tier Classinicabon Submittal nas been provided to DEP for this disposal ste a. Tier1A F] b Trer t B c Tier IC d Tier2
6 If a Tier I Permit nas been issued. povide Permit Number
B. THIS FORM IS BEING USED TO:-check on i
1 Submit a crtified copy of aNodce of Activity and Use Llnitatiron pursuant to 310 CMR 40 1074
2 Submit an Evaluation of Changes in Land Uses/Actvitis and/or Site Conditions after a Reaponse Action Outcome Statement has bee n filed paersuiant L 310 CMR 40 1080
3 Submit a certified copy of an Amended Notice of Acitity and Le Limitation. pursuant to 310 CMR 40 1081
4 Submit a certified copy of a Parltal Tenination of a Notice of Actiity and Use Limitation. porsuam to 30 CMR 401013(3~
5. Subma a certihed copy of a Termination of a Notce of ActMity and Use Limitation, pLrsuarit to 310 CMR 40 1034) id) 6 Submit a cerdhed copy o a Grant of Enronmental Restriction pursuan o 310 CMR 40 1071
7. Submit a certified copy ofan Amendment of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1081[3j
i. Submit a cerlified copy 0 a Partial Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40 103C3(2M
Li 9 Submi a certified copy of a Release of a Grant of Environrnental Restricton, pursuant to 310 CMR 40 10E3!(1 c)
1G Submit a certified copy af a Confirmatory Activity a We Umitatio, pursuant to 310 CMR 40 108514)
11. Provide Additional RTNs:
a Check here if this AUL Submittal covers additional Release Tracking Numbers (RT Ns
0 Provide the additional Release Tracking Number~s) ] covered by this AUL Submittai El -
(All sections of this transmittal form must be filled out unless othierwise noted above. BWSCII3A Is required for all submittals listed abiove)
L67203 Page 1 of 4 U Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup Relese__Nb ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM ReleaseTracking u Pursuant to 310 CMR 40,1056 & 40.1070 -40.1084 (Subpart J)
C. AUL INFORMATION: 1. Document (per Section B) Recording and/or Registration information:
a. Name of Registry of Deeds and/or Land Registration Office: Bristol County
b. Book and Page Number and/or Document Number: Book 1124. Page 98
c. Date of recording and/or registration: 09/02/2008 mm/dd/yyyy 2. Is the address of the property subject to AUL different from the disposal site address listed above? 0 a. No F1 b. Yes If yes, then fill out address section below.
3. Street Address:
4. City/Town: 5. ZIP Code:
D. PERSON SUBMITTING AUL TRANSMITAL FORM:
1. Check all that apply: n a. change in contact name E] b. change of address nde ing respon e actions 2. Name of Organization. Ralph Shuster Metals, Inc.
3. Contact First Name: David 4. Last Name: Malkin
5. Street: 909 Main Street 6.Title: President
7. City/Town: Providence 8. State: RI 9. ZIP Code: 02904-0000
10. Telephone: (401) 277-0300 11. Ext.: 12. FAX:
13. Is the person described in this section the owner of the property?
0 a. Yes [] b. No , if checked then Section G must be filled out by at least one owner.
c. Check here if providing names and addresses of any additional owners in an attachment.
E. RELATIONSHIP TO DISPOSAL SITE OF PERSON SUBMITTING AUL TRANSMITTAL FORM: (check one)
1. RP or PRP Z a. Owner [] b. Operator E] c. Generator El d. Transporter
[ e. OtherRPorPRP Specify: -
1 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2)
3. Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s. 5(j))
[ 4. Any Other Person Submitting AUL Specify:
Revised: 06/27/2003 Page 2 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site C/eanup BWSC113 ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM Release Tracking Number (Subpart J) k J Pursuant to 310 CMR 40.1056 & 40.1070 - 40.1084 F.REQUIRED ATTACHMENT AND SUBMITTALS:
1. Check here to certify that notice of the proposed Activity and Use Limitation (AUL) was given to all record-interest holders, if any, in accordance with 310 CMR 40.1074(1)(e), via certified mail.
a. Check here if there were no record interest holders. b. Date of certified mailing: mm/dd/yyyy c. Check here to certify that names and addresses of all record holders notified is attached.
2. Check here to certify that within 30 days of recording and/or registering the AUL, including amending, releasing or terminating the AUL, a copy of the AUL was/will be provided to the Chief Municipal Officer, the Board of Health, the Zoning Official, and the Building Code Enforcement Official in the community(ies) where the the property subject to such Activity and Use Limitation is located.
3. Check here to certify that within 30 days of recording and/or registering the AUL. including amending, releasing or terminating the AUL, a Legal Notice was/will be published in a newspaper with circulation in the community(ies) where the property subject to the AUL is located.
4. Check here to certify that within 7 days of publishing a Legal Notice in a newspaper with circulation in the community(ies) where the property subject to the AUL is located, a copy of the notice was/will be submitted to DEP.
5. Check here to certify that within 30 days of recording and/or registering the AUL, including amending, releasing or terminating the AUL, a certified copy of the AUL, including the LSP Opininon containing the material facts, data, and other information, will be submitted to DEP.
Aid. Send information provided on this form is incorrect, e.g. Site Address/Location o corrections6. Check here to the if any DEP non-updatable Regional Office.
7. If an Evaluation of Changes In Land Uses/Activities and/or Site Conditions after a Response Action Outcome L Statement is being submitted, check here to certify that the LSP Opinion containing the material facts, data, and other information is attached.
0. CERTIFICATION OF OWNER OF PROPERTY, IF NOT PERSON SUBMITTING AUL TRANSMITTAL FORM:
1.1,1, attest under the pains and penalties of perjury that I am the owner of said property(ies), subject to the AUL
2. 3. Date: Signature mm/dd/yyyy
4. Name of Organization:
5. Contact First Name: 6. Last Name:
7. Street: 8. Title:
9. City/Town: 10. State: 11. ZIP Code:
12. Telephone: 13. Ext.: 14. FAX: aeo RIse:0/720 Revised: 06/27/2003 Page 3 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC113 Number ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM Release Tracking Pursuant to 310 CMR 40.1056 & 40.1070 - 40.1084 (Subpart J)
K. CERIFICATION OF PERSON MAKING SUBMITTAL:
1. I, L).lI'f 4 1 k - , attest underthe pains and penalties of perjury (i) that Ihave personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. lithe person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.
Pursuant to 310 CMR 40.1074 (1)(f), I also hereby certify under penalties of perjury, that either I (if person submitting the AUL Transmittal Form is the property owner), or
2. Name of Property Owner am/is identified on the Notice of AUL as the owner of the property subject to the AUL, owned such property on the date that the AUL was recorded and /or registered
3. By- 2/ 4. Title: R d &5 - Signature
5. For i/gZ 5tY4 t - Ae54 t/s5 gi.. 6. Date: I, (Name of person or entity recorded in Seption D) mm/dd/yyyy
[] 7. Check here if the address of the person providing certification is different from address recorded in Section D.
8. Street:
9. City/Town: 10. State: - 11. ZIPCode:
12. Telephone: 13. Ext.: 14. FAX:
YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE. Date Stamp (DEP USE ONLY:)
h i Page 4 of 4 Revised:Revised: 06/27/200306/27/2003 Page 4 of 4 - - Burea WS Ll Massachusetts Department of Environmental Protection 1>21 ~Bureau of Waste Site Cleanup B SI3 ACTIVITY & USE LIMITATION (AUL) OPINION FORM Release Tracking Number Pursuant to 310 CMR 40.1056 & 40.1070 - 40.1084 (Subpart J) 16211
A. DISPOSAL SITE LOCATION:
1. Disposal Site Name: Ralph Shuster Metals, Inc.
2. Street Address: 44 Forest Street
3. Cityrrown: Attleborough 4. ZIP Code: 02703-0000
B. THIS FORM IS BEING USED TO: (check one)
H 1. Provide the LSP Opinion for a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1074. 2. Provide the LSP Opinion for an Evaluation of Changes in Land Uses/Activities and/or Site Conditions after a Response El Action Outcome Statement, pursuant to 310 CMR 40.1080. Include BWSC113A as an attachment to BWSC113. Section A and C do not need to be completed.
2 3. Provide the LSP Opinion for an Amended Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1081(4).
and Use Limitation, pursuant to 310 CMR the LSP Opinion for a Partial Termination of a Notice of Activity 40.1083(3)4. Provide . w 5. Provide the LSP Opinion for a Termination of a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1083(1)(d).
[ 6. Provide the LSP Opinion for a Grant of Environmental Restriction, pursuant to 310 CMR 40.1071.
E] 7. Provide the LSP Opinion for an Amendment of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1081(3).
H 8. Provide the LSP Opinion for a Partial Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1083(2),
9. Provide the LSP Opinion for a Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1083(1)(c).
10. Provide the LSP Opinion for a Confirmatory Activity and Use Limitation, pursuant to 310 CMR 40.1085(4).
(Unless otherwise noted above, all sections of this form (BWSCI I 3A) must be completely filled out, printed, stamped, signed with black ink and attached as an exhibit to the AUL Document to be recorded and/or registered with the Registry of Deeds and/or Land Registration Office.)
C. AUL INFORMATION: 1. Is the address of the property subject to AUL different from the disposal site address listed above?
1 a. No LI b. Yes If yes, then fill out address section below.
2. Street Address:
3. City/Town: 4. ZIP Code:
Revised: 06/27/2003 Page 1 of 2 Protection Number Bureau of Waste Site Cleanup BWSC1I13ATracking Environmental Release of FORM Department (AUL) OPINION Massachusetts& USE LIMITATION fl ACTIVITY
D.k LSP SIGNATURE PursuantAND STAMP: to 310 CMR 40.1056 & 40.1070 - 40.1084 (Subpart J) - 18211 I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief, > if Section B indicates that a Notice of Actvity and Use Limitation is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1074; > if Section B indicates that an Evaluation of Changes in Land Uses/Activitiesand/or Site Conditions after a Response Action Outcome Statement is being submitted, this evaluation was developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1080;
> if Section B indicates that an Amended Notice of Activity and Use Limitation or Amendment to a Grant of Envirnmental Restriction is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.GL. c. 21E and 310CMR 40.0000 and (ii) complies with 40.1081;
> if Section B indicates that a Termination or a Partial Termination of a Notice of Activity and Use Limitation, or a Release or Partial Release of a Grant of Environmental Restriction is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1083:
> if Section B indicates that a Grant of Environmental Restriction is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1071;
> if Section B indicates that a Confirmatory Activity and Use Limitation is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1085(4);
I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.
1. LSP #: 7770
2. First Name: Kurt 3. Last Name: Klages
4. Telephone:4.Teepon:(413) /A5. 78 2622 5.Et___Ext.: - 6. FAX:A:(413) 787-2646
7. Signature: 8. Date: 76f mm/dd/yyyy 9. LSP Stamp:
KLAGES No. 777
sIT E PO'r
Revised: 06/27/2003 Page 2 of 2 I Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC111 $7 rAUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT-16 1 ...... Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K)
A. DISPOSAL SITE LOCATION:
1. Disposal Site Name: Ralph Shuster Metals, Inc.
2. Street Address: 44 Forest Street
3. City/Town: Attleborough 4. ZIPCode: 02703-0000
7 5. Check here if a Tier Classification Submittal has been provided to DEP for this disposal site. 5 a. Tier 1A [ b. TierB c. Tier1C g] d. Tier 2
6. If a Tier I Permit has been issued, provide Permit Number:
B. THIS FORM IS BEING USED TO: (check one)
1. Submit an Audit Follow-Up Plan (Section C is not required). 2. Submit a Modified or Revised Audit Follow-Up Plan (Section C is not required).
2 3. Submit a Post-Audit Completion Statement 4. Provide Additional RTNs:
l a. Check here if this Audit Submittal covers additional Release Tracking Numbers (RTNs). b. Provide the additional Release Tracking Number(s) covered by this Audit Submittal. L 1 L:J
(All sections of this transmittal form must be filled out unless otherwise noted above)
C. POST-AUDIT RESPONSE ACTIONS SUMMAR
1. Notice of Audit Finding Date Issued: 12/21/2008 mm/dd/yyyy 2. Documentation (check all that apply): a. Provided Technical Justification, or Supporting or Clarifying Information Relating to Previous Response Actions w b. Performed Additional Risk Assessment c. Modified Disposal Site Boundary
3. Field Work (check all that apply): [ a. Sampled Previously Assessed Media (check all that apply): 7 Soil [Z GW' [1] SW [] Sediment [ Air Waste Material b. Sampled New Media Not Previously Assessed (check all that apply): Z Soil Z GW ] SW [] Sediment [ Air Waste Material
c. Performed Remediation Describe: Capping of entire site w/ Engineered Barrier (See RAO) I I Revised: 06/27/2003 Page 1 of 4 Bureau of Waste Site CleanupBW C1
Massachusetts Department of Environmental Protection Release Tracking Number &AUDIT POST- FOLLOW-UP AUDIT COMPLETION PLAN TRANSMITTAL STATEMENT FORM - 16211 Li__ Pursuant to 310 CMR40.1160 - 40.1170 (Subpart K)
C. POST-AUDIT RESPONSE ACTIONS SUMMARY: (cont) 4. Outcome (Check all that apply and submit appropriate transmittal form(s)):
a. Implemented or Amended Activity and Use Limitation
I b. Modified Risk Assessment Method c. Revised Response Action Outcome (RAO) Class r d. Revised Tier Classification
L e. Revised or Modified Phase Work
f. Retracted RAO Statement
g. Other
D. LSP SIGNATURE AND STAMP:
I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR 4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief, > if Section 8 of this form indicates that an Audit Follow-up Plan, or a Modified or Revised Audit Follow-up Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40,0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal;
> if Section B of this form indicates that a Post-Audit Completion Statement is being submitted, the Post-Audit response action(s) that is (are) the subject of this submittal as required to correct either violations and/or deficiencies identified by DEP in a Notice of Audit Finding pursuant to 310 CMR 40.1140 (i) has (have) been developed, implemented and completed in accordance with the applicable provisions of M.G.L. c.21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c.21E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, approvals, orAudit Follow-up Plans pursuant to 310 CMR 40.1160 as identified in this submittal. Development, implementation and completion of the Post-Audit response action(s) have corrected the violations and/or deficiencies identified by DEP in the Notice of Audit Finding. This Statement does not (1) apply to actions or other aspects of the site that were not reviewed in the audit, (2) preclude future audits of past, current, or future actions at the site, (3) in any way constitute a release from any liability, obligation, action or penalty under M, G.L. c.21E, 310 CMR 40.0000, or any other law, regulation, or requirement, or (4) limit the Department's authority to take or arrange, or to require any Responsible Party or Potentially Responsible Party to perform, any response action authorized by M.G.L. c.21 E, which the Department deems necessary to protect health, safety, public welfare or the environment.
Page 2 of 4 Revised: 06/27/200306/27/2003 Page 2 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC111
AUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT - 16211 Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K)
D. LSP SIGNATURE AND STAMP: (cont.) Iam aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.
1. LSP#: 7770
2. First Name: Kurt 3. Last Name: Klages
4. Telephone: (413 78826225 . (413) 76a-2646
7. Signature:
8. Date: 9. LSP Stamp: mmn/6d/yyyfyKR
FLAS NOAMT
E. PERSON RESPONDING TO AUDIT: 1. Check all that apply: 0 a. change in contact name L b. ch ange of address nde aing response actions
2.Name ofOrganization: Ralph Shuster Metals, Inc.
3. Contact -irst Name: David 4. Last Name: Malkin
5. Street: 909 Main Street 6.Title: President
02904-0000 7. City/Tow n: Providence 8 Se RI 9. ZIP Code:
10. Teleph ne: (401) 277-0300 11. Ext.: - 12. FAX: I F. RELATIONSHIP TO SITE OF PERSON RESPONDING TO AUDIT:
1. RPor PRP V] a. Owner [1 b. Operator LI c. Generator [ d. Transporter
F e. OtherRPorPRP Specify: ] 2.Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2)
3. Agency or Public Utility on a Right of Way (as defined by M.G.L c. 21 E, s. 5())
4. Any Other Person Responding to Audit Specify Relationship:
Revised: 06/27/2003 Page 3 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSCIII
AUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT BEfguz- Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K)
G. REQUIRED ATTACHMENT AND SUBMITTALS: 1. Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. Ifthe box is checked, you MUST attach a statement identifying the applicable provisions thereof. F- o- - -oo
2. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached.
H. CERTIFICATION OF PERSON RESPONDING TO AUDrr:
1. I, A- ,Iattest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompahying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.
2. By: 3. Title Signature
4. For. 6 h t e /_5 f 5. Date: gf6 4 905 (Name of person or entity recorded in Section E) mm/dd/yyyy
6. Check here if the address of the person providing certification is different from address recorded in Section E.
7. Street:
8. City/Town: 9. State: - 10. ZIP Code:
11. Telephone: 12. Ext.: 13. FAX:
YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENAIED FOR MISSING A REQUIRED DEADUNE.
Date Stamp (DEP USE ONLY:)
Revised: 06/27/2003 Page 4 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104
RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number Pursuant to 310 CMR 40.1000 (Subpart J) R - 16211 For sites with multiple RTNs, enter the Primary RTN above. A. SITE LOCATION:
1. Site Name/Location Aid: Ralph Shuster MetalsInc.
2. Street Address: 44 Forest Street Attleborough 02703-0000 3. City/Town: 4. ZIP Code:
5. Check here if a Tier Classification Submittal has been provided to DEP for this disposal site. la.Tier IA [] b. Tier lB E c. Tier iC K] d. Tier il
6. If a Tier I Permit has been issued, provide Permit Number:
B. THIS FORM IS BEING USED TO: (check all that apply) 1. List Submittal Date of RAO Statement (if previously submitted): 01/06/2006 mm/dd/yyyy 2. Submit a Response Action Outcome (RAO) Statement
F a.Check here if this RAO Statement covers additional Release Tracking Numbers (RTNs). RTNs that have been previously linked to a Tier Classified Primary RTN do not need to be listed here. b. Provide additional Release Tracking Number(s) covered by this RAO Statement.
3. Submit a Revised Response Action Outcome Statement
a. Check here if this Revised RAO Statement covers additional Release Tracking Numbers (RTNs), not listed on the RAO Statement or previously submitted Revised RAO Statements. RTNs that have been previously linked to a Tier Classified Primary RTN do not need to be listed here.
b. Provide additional Release Tracking Number(s) covered by this RAO Statement. 4. Submit a Response Action Outcome Partial (RAO-P) Statement Check above box, if any Response Actions remain to be taken to address conditions associated with this disposal site having the Primary RTN listed in the header section of this transmittal form. This RAO Statement wilt record only an RAO-Partial Statement for that RTN. A final RAO Statement will need to be submitted that references all RAO-Partial Statements and, if applicable, covers any remaining conditions not covered by the RAO-Partial Statements. Also, specify if you are an Eligible Person or Tenant pursuant to M.G.L. c. 21E s.2, and have no further obligation to conduct response actions on the remaining portion(s) of the disposal site: Sa. Eligible Person flb. Eligible Tenant
[ 5. Submit an optional Phase I Completion Statement supporting an RAO Statement 6. Submit a Periodic Review Opinion evaluating the status of a Temporary Solution for a Class C-I RAO Statement, as specified in 310 CMR 40.1051 (Section F is optional)
7. Submit a Retraction of a previously submitted Response Action Outcome Statement (Sections E & F are not required)
(All sections of this transmittal form must be filled out unless otherwise noted above)
Revised: 02/28/2006 Page 1 of 7 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104
RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number Pursuant to 310 CMR 40.1000 (Subpart J)
C. DESCRIPTION OF RESPONSE ACTIONS: (check all that apply; for volumes, list cumulative amounts)
S1. Assessment and/or Monitoring Only [] 2. Temporary Covers or Caps F] 3. Deployment of Absorbent or Containment Materials LI 4. Treatment of Water Supplies 5. Structure Venting System ] 6. Engineered Barrier 7. Product or NAPL Recovery 8. Fencing and Sign Posting E] 9. Groundwater Treatment Systems 10. Soil Vapor Extraction 11. Bioremediation 12. Air Sparging 13. Monitored Natural Attenuation 14. In-situ Chemical Oxidation
15. Removal of Contaminated Soils a. Re-use, Recycling or Treatment I i. On Site Estimated volume in cubic yards
F- ii.Off Site Estimated volume in cubic yards
iia. Facility Name: - Town: State:
iib. Facility Name: Town: State:
iii. Describe: b. Landfill
L1 i.Cover Estimated volume in cubic yards
Facility Name: Town: State:
F]ii. Disposal Estimated volume in cubic yards
Facility Name: Town: State:
16. Removal of Drums, Tanks or Containers: a. Describe Quantity and Amount:
b. Facility Name: Town: State:
c. Facility Name: Town: - State:
33 17, Removal of Other Contaminated Media:
a. Specify Type and Volume:
b. Facility Name: Town: State:
c. Facility Name: Town: State:
Revised: 02/28/2006 Page 2 of 7 MassaChusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104
RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number
Pursuant to 310 CMR 40.1000 (Subpart J) R - IF62I1
C. DESCRIPTION OF RESPONSE ACTIONS (cont): (check all that apply; for volumes, list cumulative amounts) U 18. Other Response Actions:
Describe
C] 19. Use of innovative Technologies:
Describe
D. SITE USE: 1. Are the response actions that are the subject of this submittal associated with the redevelopment, reuse or the major expansion of the current use of property(ies) impacted by the presence of oil and/or hazardous materials?
U a. Yes R] b. No Fl c. Don't know 2. Is the property a vacant or under-utilized commercial or industrial property ("a brownfield property")?
U a. Yes K] b. No [I c. Don't know 3. Will funds from a state or federal brownfield incentive program be used on one or more of the property(ies) within the disposal site? U a. Yes b. No c. Don't know If Yes, identify program(s):
4. Has a Covenant Not to Sue been obtained or sought? Sa. Yes K] b. No R c. Don't know 5. Check all applicable categories that apply to the person making this submittal: a. Redevelopment Agency or Authority E] b. Commmunity Development Corporation r] c. Economic Development and Industrical Corporation d. Private Developer L e. Fiduciary f, Secured Lender U g. Municipality h. Potential Buyer (non-owner) N i. Other, describe: Corporation
This data will be used by MassDEP for information purposes only, and does not represent or create any legal commitment obligation or liability on the part of the party or person providing this data to MassDEP. E. RESPONSE ACTiON OUTCOME CLASS: Specify the Class of Response Action Outcome that applies to the disposal site, or site of the Threat of Release. Select ONLYone Class.
1. Class A-1 RAO: Specify one of the following: M a. Contamination has been reduced to background levels. b. A Threat of Release has been eliminated.
to or approaching background levels is Class A-2 RAO: You MUST provide justification that reducing contamination L infeasible.2.
3. Class A-3 RAO: You MUST provide an implemented Activity and Use Limitation (AUL) and justification that reducing contamination to or approaching background levels is infeasible.
4. Class A-4 RAO: You MUST provide an implemented AUL, justification that reducing contamination to or approaching U background levels is infeasible, and justification that reducing contamination to less than Upper Concentration Limits (UCLs) 15 feet below ground surface or below an Engineered Barrier is infeasible. If the Permanent Solution relies upon an Engineered Barrier, you must provide or have previously provided a Phase Ill Remedial Action Plan that justifies the selection of the Engineered Barrier.
Revised: 02/28/2006 Page 3 of 7 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSCi 04
RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number Pursuant to 310 CMR 40.1000 (Subpart J)
E. RESPONSE ACTION OUTCOME CLASS (cont):
E 5. Class B-1 RAO: Specify one of the following: U a. Contamination is consistent with background levels fl b. Contamination is NOT consistent with background levels. F- 6. Class B-2 RAO: You MUST provide an implemented AUL.
contamination to less than You MUST provide an implemented AUL and justification that reducing C I Upper7. Class Concentration B-3 RAO: Limits (UCLs) 15 feet below ground surface is infeasable. 8. Class C-1 RAO: You must submit a plan as specified at 310 CMR 40.0861(2)(h). Indicate type of ongoing response actions. la. Active Remedial System b. Active Remedial Monitoring Program L c. None RAO Text) d. Other Specify. Monitoring via Sampling (See
9. Class C-2 RAO: You must hold a valid Tier I Permit or Tier 11Classification to continue response actions toward a Permanent Solution.
F. RESPONSE ACTION OUTCOME INFORMATION: 1. Specify the Risk Characterization Method(s) used to achieve the RAO described above: a. Method 1 [ b. Method 2 c. Method 3 d. Method Not Applicable-Contamination reduced to or consistent with background, or Threat of Release abated
2. Specify all Soil Category(ies) applicable. More than one Soil Category may apply at a Site. Be sure to check off all APPUCABLE categories: n a. S-1/GW-1 L d. S-2/GW-1 [] g. S-3/GW-1 I b. S-1/GW-2 E e. S-2/GW-2 E h. S-3/GW-2
c. S-1/GW-3 r] f. S-2/GW-3 E i. S-3/GW-3
3. Specify all Groundwater Category(ies) impacted. A site may impact more than one Groundwater Category. Be sure to check off all IMPACTED categories: l a. GW-1 b. GW-2 K c. GW-3 [ d. No Groundwater Impacted
4. Specify remediation conducted: a. Check here if soil remediation was conducted. b, Check here if groundwater remediation was conducted.
5. Specify whether the analytical data used to support the Response Action Outcome was generated pursuant to the Department's Compendium of Analytical Methods (CAM) and 310 CMR 40.1056:
a. CAM used to support all analytical data. b. CAM used to support some of the analytical data,
c. CAM not used.
6. Check here to certify that the Class A, B or C Response Action Outcome includes a Data Usability Assessment and Data Representativeness Evaluation pursuant to 310 CMR 40.1056. 5.62 7. Estimate the number of acres this RAO Statement applies to:
Revised: 02/28/2006 Page 4of?7 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104
RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number
Pursuant to 310 CMR 40.1000 (Subpart J) - 6211
G. LSP SIGNATURE AND STAMP: I1attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal, In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief,
> if Section B indicates that either an RAO Statement, Phase I Completion Statement and/or Periodic Review Opinion is being provided, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L c. 21 E and 310 CMR 40.0000, and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal.
I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.
1. LSP #: 7770 Kurt Klages 2. First Name: ______3. Last Name: 508-853-5027 Same 4. Telephone: n /. t. 6. FAX:
7. Sionature:
8. Date: 9 LSP Stamp:
H. PERSON MAKING SUBMIrTAL: [ c change in the person 1. Check all that apply: El a. change in contact name 5 b.change of address undertaking response actions 2. Name of Organization: Ralph Shuster Metals, Inc.
David Malkin 3. Contact First Name: 4, Last Name:
5 St 909 North Main Street 6. Title: President
RI 9 02904 7. City/Town: Providence 8. State 9. ZP Code:
10. Telephone: 401-277-0300 11. Ext. -___ _ 12. FAX ______
Page 5of7 Revised: 02/28/200602/2812006 Page 5 of 7 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 L7 RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number
Pursuant to 310 CMR 40.1000 (Subpart J) - i i
1. RELATIONSHIP TO RELEASE OR THREAT OF RELEASE OF PERSON MAKING SUBMrrTAL:
1. RP or PRP [] a. Owner [] b. Operator c. Generator JJ d. Transporter
El e. Other RP or PRP Specify:
Q 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L c. 21 E, s. 2)
Ej 3, Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21 E, s. 5(j))
4. Any Other Person Making Submittal Specify Relationship:
J. REQUIRED ATrACHMENT AND SUBMIfTALS:
1. Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof- ACOP 2. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of an RAO Statement that relies on the public way/rail right-of-way exemption from the requirements of an AUL.
3. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of a RAO Statement with instructions on how to obtain a full copy of the report.
4. Check here to certify that documentation is attached specifying the location of the Site, or the location and boundaries of the Disposal Site subject to this RAO Statement. If submitting an RAO Statement for a PORTION of a Disposal Site, you must document the location and boundaries for both the portion subject to this submittal and, to the extent defined, the entire Disposal Site.
5. Check here to certify that, pursuant to 310 CMR 40.1406, notice was provided to the owner(s) of each property within the g disposal site boundaries, or notice was not required because the disposal site boundaries are limited to property owned by the party conducting response actions. (check all that apply)
l a. Notice was provided prior to, or concurrent with the submittal of a Phase 11Completion Statement to the Department. C] b. Notice was provided prior to, or concurrent with the submittal of this RAO Statement to the Department.
9 c. Notice not required. d. Total number of property owners notified, if applicable:
6. Check here if required to submit one or more AULs. You must submit an AUL Transmittal Form (BWSC1 13) and a copy of each implemented AUL related to this RAO Statement. Specify the type of AUL(s) below: (required for Class A-3, A-4, 8-2, B-3 RAO Statements)
a. Notice of Activity and Use Limitation b. Number of Notices submitted:
n c. Grant of Environmental Restriction d. Number of Grants submitted:
E] 7. If an RAO Compliance Fee is required for any of the RTNs listed on this transmittal formn,check here to certify that an RAO Compliance Fee was submitted to DEP, P. 0. Box 4062, Boston, MA 02211.
8. Check here if any non-updatable information provided on this form is incorrect, e.g. Site Address/Location Aid. Send corrections to the DEP Regional Office.
] 9. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached.
Revised: 02/28/2006 Page 6 of 7 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104
RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number Pursuant to 310 CMR 40.1000 (Subpart J) F~I/2(
K. CERTIFICATION OF PERSON MAKING SUBMlTTAL: 1.1, t 1A -' i k -'1 , attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. l/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.
. BSY 3. Iitie: Signature
4. For: fl-1A 54 , fh, /-I ,,1' ' 1' C' 5. Date: /2001 ( ame of person or entity recorded in Section H) mm/dd/yyyy
El 6. Check here if the address of the person providing certification is different from address recorded in Section H.
7. Street:
8. City/Town: 9. State: 10. ZIP Code:
111. Telephone: 12. Ext.: _ 13. FAX:
YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IFYOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLNE.
Date Stamp (DEP USE ONLY:)
Page 7 of 7 Revised: 02/28/20 06 Revised: 02/28/2006 Page 7 of 7 RESPONSE ACTION OUTCOME STATEMENT 44 Forest Street Attleborough, MA RTN 4-16211
Project No. 1484 PROJECT NO. 1484
Potentially Responsible Party & Owner: Ralph Shuster Metals, Inc. 909 Main Street Providence, RI 02904 Contact: Mr. David Malkin, President Phone: 401-521-4477
September 2008
Prepared By:
Western Mass Environmental, LLC 93 Wayside Avenue West Springfield, MA 01089 Phone: 413-788-2622 Fax: 413-787-2646
880 Washington Street Rear Attleboro, MA 02703 Phone: 508-761-5978 Fax: 508-761-5928
Website: www.westernmassenv.com Table of Contents 1.0 INTRODUCTION...... 1 2.0 HISTORY...... 1 3.0 IMMEDIATE RESPONSE ACTIONS ...... 2.....2 4.0 DISPOSAL SITE CHARACTERIZATION ...... 4...... 4 4.1 Disposal Site Definition and Site Activity and Use [Current and Foreseeable]...... 4...... 4 4.2 Contaminants of Concern .....- ...... 5.....5 4.3 Soil and Groundwater Categorization...... -...... 6.....6 4.4 Exposure Pathways and Exposure Point Determination...... 6 4.5 Quality Assurance / Quality Control...... 7.....7 5.0 RISK CHARACTERIZATION ...... _ ...... 7 5.1 Method 3 Risk Characterization - Soil, Groundwater, Sediment, Surface Water, & Soil Gas/Vapor migration...... 7 5.3 Feasibility Study/Remedial Action Alternatives ...... 7 5.4 Periodic Evaluation and Monitoring Plan ...... 7 6.0 CONCLUSIONS...... 8
List of Tables Table 1 - Soil Analytical Results Table 2 - Groundwater Analytical Results Table 3 - Sediment Analytical Results Table 4 - Surface Water Analytical Results
List of Figures Figure 1 - Site Locus Figure 2 - Site Plan
List of Appendices APPENDIX A - Transmittal Forms APPENDIX B - Copy of Former RAO/Phase Il/Phase Ill Package (Text/Figure/Tables) APPENDIX C - Administrative Consent Order APPENDIX D - AUL Package APPENDIX E - Method 3 Risk Characterization APPENDIX F - Laboratory Reports APPENDIX G - Public Notification APPENDIX H - Geotextile Fabric Specifications Response Action Outcome (RAO) Statement Report 1.0 INTRODUCTION The purpose of this submittal is to supply the Massachusetts Department of Environmental Protection (MADEP) with a Response Action Outcome (RAO) Statement report package for the site located at 44 Forest Street in Attleborough, MA. This package has been prepared by Western Mass Environmental (WME) on behalf of the potentially responsible party (PRP), Ralph Shuster Metals, Inc. (RSM), to finalize the site's compliance with the Massachusetts Contingency Plan (MCP), 310 CMR 40.0000. This package has been provided as an attachment to an original RAO Transmittal Form, BWSC-104. A copy of the RAO Transmittal Form is included in Appendix A. A RAO Statement report, Phase I Comprehensive Site Assessment, and Phase Ill Remedial Action Alternatives report package were submitted for the site in January 2006. A copy of this report package that includes the text, tables and maps is included in Appendix B. In 2007, an audit was conducted-by the MADEP and found deficiencies within the previously submitted reports and as such an Administration Consent Order (ACOP-SE-07-3A-005) dated May 1, 2008 was issued. A copy of this document is included in Appendix C. WME has completed this report package in accordance with Item 8(A) of the ACOP. Basically the ACOP required that additional sampling be conducted to define the northern edge of the roadway and that modifications be completed to the activity and use limitation (AUL) filing. The following RAO report outlines this additional assessment and conclusions. Based on this assessment the entire site, with exception of the roadway, was capped with soil and a marker layer and the roadway was capped with soil and asphalt. This RAO package concludes that the disposal site located outside the wetland has achieved a permanent solution with no significant risk to public health welfare or the environment, so long as there is an AUL in place. Additionally, this RAO package concludes that the wetland area presents a condition of no substantial hazard but does not present a condition of no significant risk, and therefore, this RAO concludes that a temporary solution has been achieved at the site. A copy of the AUL Opinion and applicable forms including proof of filing and appropriate notification are included in Appendix D, a copy of the Method 3 Risk Characterization including the substantial hazard evaluation and environmental screening is included in Appendix E, copies of all laboratory documentation from June 2005 through March 25, 2008 are included in Appendix F, and copies of public notification applicable to this RAO are included in Appendix G. A tare sheet from the local paper for the publication notice for the AUL will be submitted within 30 days of submittal of the filing of the AUL. Refer to Figure 1, the Site Locus, for the regional location of the site, and Figure 2, the Site Plan, for the approximate disposal site boundaries and other pertinent site features. All actions conducted by WME at the site were covered by WMEs site specific Health and Safety plan. The plan is on file at WME and available for review upon request.
2.0 HISTORY The former RAO package text is included in Appendix B and includes details on the release history and should be reviewed for content. In April 2001, a MADEP representative noted a sheen on the surface water of the wetland abutting the roadway. As a result of this sheen the MADEP issued Release Tracking Number 4-16211. An Immediate Response Action (IRA) Plan, Phase I Initial Site Investigation, Tier Classification and IRA Completion statement were submitted for the site by Kaegael Environmental, Inc. (KEI) between September 2001 and April 2002. The site was tier classified as a Tier 1I Disposal site. In October 2003 a Method 3 Risk Characterization was submitted by Eco- Solutions, in April 2005 sediment and soil samples were collected by Aquatronics Industries, Inc. (AI) and in June 2005 through December 2005, Jacques Whitford (JW) submitted several Regulatory Compliance Timeline Letters. A summary of these documents and there findings are discussed in the previous RAO package.
WESTERN MASS ENVIRONMENTAL@ 2008, Project 1484 1 As previously stated in January 2006 an RAO package was submitted for the site. In 2007 the MADEP conducted an audit of the site and found that the roadway was not paved as was a stipulation within the filed AUL. Due to the Attleborough Assessors office not providing an abutters list, approval from the Conservation Commission could not be granted to conduct the work at the site, and this is why the roadway was not paved. However, in addition to the lack of the roadway being paved the MADEP determined that the northern boundary of the roadway was not adequately defined. Based primarily on these two major issues along with other minor deficiencies the MADEP issued an Administration Consent Order (ACOP-SE-07-3A-005) dated May 1, 2008. This required that RSM re-assess the northern boundary and re-submit an RAO and amended AUL by September 2, 2008, or re-open the site by retracting the RAO and submitting a Tier 11 Extension, Phase Il Scope of Work, an AUL termination and a post audit statement.
3.0 IMMEDIATE RESPONSE ACTIONS A summary of assessment conducted prior to January 2006 was included in the previous RAO Package and should be reviewed for context. However, a brief summary of actions previously conducted at the site are presented below: KEI completed an assessment including the installation of two monitoring wells (KE-1 & KE-2), sampling of shallow and deep soils, sampling of groundwater from the newly installed wells and existing Texas Instrument well (SHU-2S), sediment samples (SS-1 through SS-14), and surface water samples (SW-E and SW-W). The results indicated that metals and total petroleum hydrocarbons were present in soil in excess of applicable Method 1 Soil Standards; sediment samples exhibited concentrations of metals and petroleum constituents above background levels; and surface water had concentrations of metals above typical background. Refer to Table 1, Soil Analytical Results, Table 2, Groundwater Analytical Results, Table 3, Sediment Analytical Results, and Table 4, Surface Water Analytical Results, for concentrations. In April 2005 RSM contracted Al to conduct soil and sediment samples from the site. The results indicated no overt evidence of impacts. However, sampling was not overseen by an LSP as these samples were collected while RSM was attempting to contract with a new LSP. In June 2005 RSM contracted with JW. JW conducted several rounds of sediment and surface water sampling. Additionally, one sample of groundwater and one sample of soil were also collected to confirm the lack of any detections in groundwater and the presence of PCBs. The soil sample results indicated that low levels of PCBs and high levels of total metals were present in excess of applicable Method 1 Soil standards, and concentrations of metals and petroleum constituents were present above background in sediment and surface water. In an attempt to define the northern extent of the roadway on December 19, 2007, WME oversaw the completion of 17 test pits extending from the wetland roadway out into the yard proper. Test pits were completed based on distance from the roadway and if metals fragments were noted within the soil. All test pits were completed to 3 feet deep as no observations of metal was noted past this depth, in the area of the test pits. Two other areas, the first being the roadway is known to have metal fragments to a depth of approximately 7 feet below grade and the second area located along the northern property boundary is known to also have been filled to a depth of approximately 7 feet below grade with metal fragments. Depth of impacts in these two areas are estimated from existing natural grade of the wetland in the first case and to ground surface between the former railroad spur and existing rail road line. During the completion of the test pits visual and olfactory observations were made of soil conditions. Based on these observations no overt evidence of petroleum type impacts were noted. Soil samples (ID's: "TP-1" through "TP-17") were packaged, sealed, labeled, preserved, and transported under Chain of Custody documentation to Spectrum Analytical, Inc. in Agawam, MA (Spectrum) for analyses. Select soil samples were analyzed for one or all of the following; total chromium, extractable petroleum hydrocarbons (EPH), polychlorinated biphenyl's (PCB), polynuclear aromatic hydrocarbons (PAH) and RCRA 8 metals. Refer to Table 1, Soil Analytical Results, for test
WESTERN MASS ENVIRONMENTAL @ 2008, Project 1484 2 pit observations and results. As chromium was the highest concentration of metals detected in previous soil sampling, and since the source of impacts to the site is historic use of the site for metals segregation and re-sale, WME was of the opinion and confirmed this opinion through conversation with the MADEP that chromium would be a good marker compound to determine extent of impacts and possible concentration gradient across the site. Therefore, most samples were analyzed for chromium, while select samples were analyzed for additional parameters, based primarily on there being located at the perimeter of the yard. Based on this assessment metal fragments appeared to extent to the approximate center of yard. The test pit results indicated that concentrations of EPH were not defined by the presence of metal fragments and are likely present as a result of historic use of the site for stockpiling and segregating metals, laden with cutting oils. Based on the sporadic presence of EPH impacts, WME determined that additional assessment was required, specifically the installation of a monitoring well in the vicinity of the soil samples with the highest EPH concentrations (TP-15, TP-16 and TP-17) and the completion of additional soil borings to delineate the eastern and western extent of impacts. WME returned to the site on February 5, 2008, to oversee New England Geotech install a monitoring well to assess the potential for petroleum and metal contaminants leaching from soil to groundwater. One 1-inch monitoring well was completed to 15 feet below grade with 14 feet of screened interval. As petroleum type impacts were the primary reason for the installation of this monitoring well (i.e. previous groundwater sampling has indicated limited if any impacts to groundwater) WME screened the soil with a photoionization detector (PID) calibrated with isobutylene span gas standard "as benzene" and utilizing the MADEPs "jar headspace" screening procedure. Based on this screening and on visual and olfactory indications, no metal fragments were noted during completion of the boring, no petroleum odors were noted and no PID readings were detected. On February 14, 2008, WME returned to the site to collect a groundwater sample from the newly installed monitoring well (MW-1) and to complete additional soil borings at the extent of the eastern property boundary and at the entrance to the facility yard. No samples were collected to the north since metal fragments were noted to the property boundary which abuts the railroad tracks, beyond which is landscaped grassy areas owned by TI. The soil borings were completed to approximately 2 feet below grade, and no evidence of metal fragments or petroleum odors were noted. The groundwater sample (ID: "MW-1") was analyzed for EPH and RCRA 8 metals and the six soil samples (ID's: "SS-1" through "SS-6") were analyzed for EPH and chromium. Soil samples were collected from 1 to 3 feet below grade and no metal fragments were noted within the samples. The results indicated that no overt evidence of impacts in either the soil or groundwater samples. The only concentrations of note were detected in the soil sample collected from the entrance to the facility yard (SS-6), which had concentrations of EPH, although they were below applicable Method 1 Soil Standards. WME is of the opinion that since no visual or olfactory evidence was noted that the detected EPH concentrations are likely from vehicular traffic over this area, which is the only access to the yard. Refer to the Tables I and 2, Soil Analytical Results, and Groundwater Analytical Results, respectively, for results and applicable standards. Refer to Figure 2, Site Plan, for sample locations and other pertinent site features. After communication with representatives of the MADEP Audit Division, WME returned to the site on March 25, 2008 to collected soil samples from the northern boundary of the site. As the railroad tracks abut the site, soil samples could not be collected from this area, due to safety concerns associated with active rail traffic and structural integrity of the tracks, therefore, WME with approval from the MADEP collected samples from just over the rail road tracks, on the TI property. The samples (ID's: "SS-7" through "SS-9") were analyzed for total chromium as a target compound. The samples were collected from 1 to 3 feet below grade and no metal fragments were noted within the samples. In summary no concentrations in excess of applicable Method 1 Soil Standards was noted in the soil samples. In summary, concentrations seem to be sporadic and spread throughout and encompass the facility yard and roadway. Therefore, WME is of the opinion that placing an activity and use limitation (AUL) over the entire yard within borings SS-1 through SS-9 and to the northern property boundary would be
WESTERN MASS ENVIRONMENTAL 0 2008, Project 1484 3 the most cost effective and logical approach to the problem. The AUL boundary to the south through the wetland will remain approximately the same. This conclusion was relayed to the MADEP Audit Division and capping of the roadway and yard was determined to be a viable option, in addition to placement of the AUL. This approach was relayed to the MADEP, specifically in e-mail correspondence of April 17, 2008, and through numerous telephone correspondence. The plan as outlined to the MADEP was as follows: 1) clearing of vegetation from the roadway and portions of the roadway embankment through the wetland that is not extremely healthy (e.g. areas with exceedingly heavy vegetation will only be trimmed back to allow grading and placement of cap on roadway); 2) Material to be chipped and spread or removed from the AUL area; 3) Removal of debris gross debris from the wetland and disposal; 4) Fencing of the wetland along Eddy Street (8' fence) and at the interior property boundary entrance (6' fence); 5) Capping and grading of the roadway with 3 to 6" of compactable underlayment; 6) Asphalt the roadway with a 1.5 to 2" binder coarse; 7) Spreading of loam, placing jute fabric and seeding the sides of the roadway; 8) Capping the entire AUL area outside the roadway with a marker layer of brightly colored (Lime Green) geotextile fabric that is manufactured with recycled plastic material. A copy of the fabric specifications for the GN100 fabric is included in Appendix H; and, 9) Capping the entire AUL area outside the roadway with a minimum 3" layer of compactable fill. The fill to be utilized is a recycled concrete mixture that is 1.5" minus. Approval to proceed with the project was granted by RSM on July 7, 2008. WME immediately submitted notice to the Conservation Commission (ConCom) that actions outlined under the Notice of Intent dated May 14, 2007. Sepe Tree Service was contracted directly by RSM and began work on the project following notice to the ConCom; however, it was not until July 28, 2008, that the site was partially prepared for capping to begin. Between July 28, and August 21, 2008, WME was present at the site to cap the roadway and yard. Due to the grade of the site, most areas have significantly greater than 3" of cover over the marker layer and surface. The asphalt was placed on the roadway on August 29, 2008. Six roll-offs of debris was removed from the site, however, this debris included wood (e.g. fence, pallets, tree branches, etc.), scrap metal that was not associated with the release (e.g. loose rail tracks from the former spur, former excavator shovels from the former operations, etc.), and garbage (e.g. construction debris, appliances from the wetland, furniture, etc.) and is not considered a waste material associated with the disposal site. Therefore, waste slips were not included with this RAO, however, they are on file and available for review at WME. 4.0 DISPOSAL SITE CHARACTERIZATION 4.1 Disposal Site Definition and Site Activity and Use [Current and Foreseeable] The disposal site is located at 44 Forest Street in Attleborough, MA, and is bordered Eddy Street to the south, residential and commercial properties to the west, the New York & Hartford Rail to the north and undeveloped wooded areas to the east. The disposal site is situated primarily on Lot 181, with a very small portion encroaching on Lot 182G. Both lots are owned by RSM. The area is primarily mixed use industrial/commercial with some residential. No structures are located on the disposal site. While determining the disposal site boundaries some assumptions were made and include the following: 1) Due to the size of the property and the known source being historical use of the property for scrap metal staging and resale, visual observations of metal and/or rust were utilized to assist in the delineation of impacts. As such and due to the high concentrations of chromium present in soil samples collected from the roadway, WME utilized chromium as the indicator compound for the presence of impacts. This was discussed and approved by the MADEP;
WESTERN MASS ENVIRONMENTAL © 2008, Project 1484 4 2) While many areas of the disposal site appeared clean, the historic use of the site for staging of metals would require a substantially larger sampling effort. Therefore, in an effort to minimize costs associated with sampling and since anticipated use is not expected to change, RSM and WME with discussion with the MADEP, made the decision to sample the area outside the facility yard and just place the AUL over the entire area and include the entire yard, as well as the roadway and wetlands as part of the disposal site. WME was of the opinion that this was the most conservative approach, in addition to being a cost reducing measure when considering sampling volumes that would be required. 3) Two major areas of impacts were detected, which included the roadway and the area between the former rail road spur and the active railroad line property. The depth of impacts from these areas was assumed to be to the former existing grade, or approximately 7 feet below grade of these areas. This assumption appears valid based on the grade of undisturbed land in the vicinity of these areas; 4) While many sediment concentrations did not exceed the background, as determined by the sediment sample collected from the outfall of Eddy Street (Sed-21), all sediment concentrations in excess of MADEP Consensus Based Threshold Effect Concentrations (TEC) are being included as part of the disposal site; 5) Surface water concentrations are assumed to extend throughout the wetland which they were collected from, either the eastern or western wetland and likely do not commingle. There is a drainage line connecting the two wetlands, however the line only several feet below the top of the roadway grade; therefore, only during extreme flood events would water from the eastern and western wetland mix. The specific disposal site boundaries are comprised of the roadway (measuring approximately 400 feet by 30 feet at the widest point and encompassing an area 0.5 acres, and to a depth of approximately 7 feet below surface grade of the roadway); the eastern wetland (measuring approximately 325 feet by 200 feet and encompassing an area 1.5 acres), the western wetland (measuring approximately 250 feet by 100 feet and encompassing an area 0.57 acres); and lastly the former facility storage yard (measuring approximately 665 feet by 200 feet and encompassing an approximate area of 3.05 acres with the deepest portion located along the northern property boundary at 7 feet below grade). The determination of the disposal site was based on visual observations, sampling of soil, sediment, surface water and groundwater, done by completing test pitting and geoprobe investigations at the site. According to RSM personnel there are no plans to change the use of the property and the placement of the AUL would assist in minimizing any future risk associated with development of the site. Information collected from the Attleborough, Massachusetts USGS Topographic Map, via the MASGIS Website, indicates the site is located at Universal Transverse Mercator (UTM) Coordinates 4646206 Northing by 311694 Easting. Figure 1 indicates the location of the disposal site and Figure 2 Illustrates the disposal site boundaries and other pertinent site features. The site is not located in an area of priority habitats of rare species, or habitats of rare wildlife and certified vernal pools, or protected open space. The site does have the aforementioned wetland on-site and the nearest named water body is Coopers Pond and associated wetland located approximately 0.5 miles east of the site. 4.2 Contaminants of Concern In accordance with MADEP Publication No. WSC-401-91, the most recent version of the MCP, and the Implementation of MADEP VPH/EPH Approach, on known historical use of the site, and on the analytes detected as part of this investigation, Contaminants of Concern (COC) with respect to soil, sediment, surface water and groundwater include EPH, PAHs, PCBs and metals. Soil: Concentrations detected in soils during assessment include EPH chain lengths, PCBs, silver, arsenic, barium, cadmium, chromium, mercury, lead, selenium, naphthalene, acenaphthylene, phenanthrene, anthracene, fluoranthene, - pyrene, benzo(a)anthracene,
WESTERN MASS ENVIRONMENTAL @ 2008, Project 1484 5 chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene, benzo(g,hi)perylene, and dibenzo(a,h)anthracene. The only compounds detected above applicable Method 1 S-1 Soil Standards include EPH C19-C36 Aliphatics, EPH C11-C22 Aromatics, PCBs, benzo(a)pyrene, chromium, cadmium, arsenic and lead. As a conservative estimate all detected compounds are being considered COC. Refer to Table 1, Soil Analytical Results, for results and applicable standards. Groundwater: Based on groundwater sampling only barium has been detected above laboratory method detection limits but was well below the applicable Method 1 GW-2/3 Groundwater standard. Therefore, COCs relate only to this compound. Refer to Table 2, Groundwater Analytical Results, for concentrations and applicable standards. Sediment: Based on sediment samples collected at the site, remaining concentrations include EPH Chainlengths, PAHs, metals, and PCBs. Therefore, COCs relate to these compounds. Surface Water: Based on surface water samples collected at the site, remaining concentrations include metals. Therefore, COCs relate only to metals. 4.3 Soil and Groundwater Categorization Site soil can be categorized based on accessibility and on the frequency and intensity of use for children and adults. At the current time, soil from portions of the disposal site could typically be classified accessible soil (i.e., 0-3 feet unpaved). Assuming unrestricted development, with stipulations as outlined in the AUL, both adults and children might be present at a high frequency and intensity, thus, site soil could be categorized as S-1. Although refer to the Method 3 Risk Characterization for a more detailed determination of standards specific to this site. With respect to site groundwater, according to Massachusetts Geographic Information System data; Massachusetts Surface Water Quality Standard documentation; site reconnaissance; a review of the site conditions; and other sources: * Based on the lack of any Current or Potential Drinking Water Source Areas within the vicinity of the site, the site is not subject to GW-1 standards; * As the depth to groundwater is less than 15 feet below grade and since the disposal site is within 30 feet of an occupied building or structure, the site is subject to GW-2 standards; * As is the case for all disposal sites, groundwater at the disposal site is a potential source of discharge to surface water bodies and, therefore, is subject to GW-3 standards. 4.4 Exposure Pathways and Exposure Point Determination Pursuant to Section 310 CMR 40.0924 - 40.0926, an evaluation of the contaminant conditions was conducted to define potential exposure points, exposure pathways, and exposure point concentrations (EPCs). In addition, the potential for the existence of critical exposure pathways (CEPs) was evaluated. Exposure pathways are defined, without limitation, as ingestion, inhalation, and/or dermal absorption of impacted media. CEPs are defined as those routes by which oil and/or hazardous material(s) released at the disposal site are transported, or are likely to be transported, to human receptors via vapor phase emissions into a living or work space of a pre-school, daycare, school, or occupied residential dwelling; or ingestion, dermal absorption or inhalation of measurable concentrations of oil and/or hazardous materials from drinking water supply wells located at and servicing a pre-school, daycare, school, or occupied residential dwelling. Refer to the Appendix E, the Method 3 Risk Characterization for potential EPCs and CEPs and associated risk.
WESTERN MASS ENVIRONMENTAL © 2008, Project 1454 6 4.5 Quality Assurance / Quality Control Guidance WSC-02-320 (CAM) was utilized in the collection and analyses of the soil samples collected from the site by WME in 2007 and 2008. Due to the samples collected previous by other parties being done prior to the publication of Guidance WSC-02-320, those samples were not collected in accordance with that guidance. An overview of quality assurance and control for the samples collected by WME indicate that while some deficiencies were present, overall in the opinion of WME they were not of sufficient severity to negate the use of the samples for risk purposes. Copies of all laboratory reports available to WME are included in Appendix F.
5.0 RISK CHARACTERIZATION 5.1 Method 3 Risk Characterization - Soil, Groundwater, Sediment, Surface Water, & Soil Gas/Vapor migration Pursuant to 310 CMR 40.0950 through 40.0990, a Method 3 Risk Characterization is applicable to demonstrate a condition of no substantial hazard evaluates the risk to human health, public welfare, safety, and the environment for all current site activities and uses, and to demonstrate a condition of no significant risk evaluates the risks to human health, public welfare, safety and the environment for all current and reasonable foreseeable future site activities and uses. Refer to the Appendix E, the Method 3 Risk Characterization for the complete risk characterization. The Method 3 Risk Characterization concluded the following: 1) A Condition of No Significant Risk to public welfare and safety exists at the site; 2) A Condition of No Substantial Hazard to human health exists at the site; 3) A Condition of No Significant Risk exists for trespassers at the site; 4) A Condition of No Significant Risk does not exist for construction workers and future on-site residents at the site, therefore, an AUL is necessary to maintain a Condition of No Significant Risk under specific current and foreseeable future site activities and uses; 5) The AUL is required to restrict direct contact exposure to soil and under such conditions as outlined in the AUL, a Condition of No Significant Risk exists for the site; and, 6) A Condition of No Significant Risk to the environment does not exist due to the potential harm to the wetlands, however, a Condition of No Substantial Hazard to the wetlands environment exists. 5.3 Feasibility Study/Remedial Action Alternatives The feasibility of remediation at this site to reduce levels over the entire site to a condition of No Significant Risk to health, public welfare, safety and the environment was completed as part of the Phase Ill Remedial Action Alternatives (Phase Ill) submitted for the site in January 2006. The text and tables from that report are included in Appendix B. As conditions that prohibit permanent site closure remain (i.e. impacts associated with the wetland) the conclusions of the Phase IllI still apply. In summary the Phase Ill concluded that monitored natural attenuation is the best solution at the site. 5.4 Periodic Evaluation and Monitoring Plan As concentrations were detected in sediment and surface water and since an AUL and engineered barrier will be placed at the site, it is the opinion of WME that continued minimal monitoring in the form of surface water and sediment sampling is required to maintain a condition of no substantial hazard. Therefore, three surface water locations (SW-1, SW-4 and SW-5) and sediment locations (Sed-15, Sed-20, and Sed-21) will be sampled for metals, PAHs and EPH Chainlenghts at the third and fifth year following submittal of the RAO. The results will
WESTERN MASS ENVIRONMENTAL 0 2008, Project 1484 7 be outlined in the Periodic Evaluation for submittal in September 2013. This report will determine if a permanent solution can be achieved.
6.0 CONCLUSIONS Pursuant to 310 CMR 40.1050 a Class C RAO can be utilized at sites where a Temporary Solution has been achieved and after submittal of Phase Il and Phase IlI reports.. Criteria in support of the Class C RAO are as follows: * The source of contamination has been eliminated or controlled through the placement of the AUL and engineered barrier, which has mitigated direct contact exposure; " A Phase Il and IlIl were submitted in January 2006; * A periodic monitoring plan to attempt to achieve a permanent solution is outlined in Section 5.4 and option where discussed in the Phase IlIl report; and, * A condition of no substantial hazard exists at the site as outlined in the Method 3 Risk Characterization. The placement of the AUL was to support a condition of no significant risk. While the concentrations in the wetland will not allow a permanent solution, due to levels detected within the wetland, future monitoring, and potential minimal excavation may allow for a permanent solution at the site. The AUL was not filed for the wetland area and does support a condition of no significant risk for the portion of the disposal site on which it was placed, once a permament solution can be achieved at for the site. Therefore, future Class A RAOs will not require an amendment to the AUL filing. Details on the risk associated with different areas of the site and from different media are outlined in the Method 3 Risk Characterization included as Appendix E. Copies of public notification letters to the City of Attleborough officials, as required pursuant to 310 CMR 1403(3)(e)(f) and 40.1403(7)(a), is provided in Appendix G. In addition, the tare sheet from the publication of the AUL notice will be submitted to the MADEP following its publication.
WESTERN MASS ENVIRONMENTAL Q2008, Project 1484 8 TABLES
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II- o U 0. .: es=E 4' r S. 00(X0 esec ~ re c -; fA-R1.Ke3~ ~-a g5 0 ZZC SI .6326i L2 F, I %24I-r U . _o FIGURES WESTERN MASS ENVIRONMENTAL a 2008, Project 1484 APPENDIX I 11 STIC '~- !. ~ ~ ATU~J~ I A j 7a~4 7 k WESTERN MASS ENVIRONMENTAL AI _ AI SITE LOCUS 44 FOREST STREET ATTLEBOROUGH, MA A A 1I ArmaAc zzzzzzzzzzzzz z z w 1Visual (Metals or No Metals A A A 0 "as A wQWDC i4 to ito 6 )9, 1 wM- ch Sile A 0 Z8-- Zq Z4 21 2q Zr1 -4 - -1 -4 24 -- Z- f 24 21 22 2 24adomium aru AI pOmgOZZZZZZZ=8 'zzpzZzzzZZAmn AA P~ ~ ~z oK) azz~ ;Z~ ZCa iu'm AA 00 98 Alaphthalene ~ Cr~ Acenaphthylene C, AAO ( c henanthrene 0n ii a~Anthracene -4 H -4 -4-4A C -1 -4 - 3 zzz~z~a- -4- -4-4 -- 1 -- 1--I luenoanthre e AA 1.39 ~~ 22 ~ ndenoe,,-dprn 00 Ziphatis 9-1 Ar0 ha a A A A A 0 ienzoaanhrene 00 OODOe (n ~C~N)Z~A (~~~*4**** hrysene ytn 11C2 -4 - ZZP z 4 zt- z z z z Bnzoa~athrceI zz ZZ ZZ Z2 ZNalben h b0 oZ :pj Z-Z Z ZZAZZZ Pz -ua Ct -Fk- ca 8li' 2 z -4 9 yP z -4 PA _ - A 8 6 T z -4 Z z 1111 -4 -4 Z -Zq Z AA 2-4 2 pAApAp.p!opOAA -4 at4pp a t AP Po" A aAAAAA.AAAMAAAt6 ' -4 A64A44P S64AAA6 A I . a a .3 z -- I CA A !A A 2 A A4 4AA -4 AaAsAAoAoaAAA co4t~a M -UC. ('wCP DCI P 9:: -4 Coaa~~ooooAAA 2-4 m Mis LnEnI 2 0 PP6~Ase o AA 0 Cit 2-4 F, "3 '.3 5? BA --- I § .4 IL Eg 1. j U e m .4 z .4 a H I. LBI~. 0> 0 .4 I. S 0 .4 0 .4 Alt B': 0 0 ( -. I 0 A' a C / 'C A I I N I . I I E a s o ~ c I drij -- : C) " - c-) 5 APPENDIX A Transmittal Forms WESTERN MASS ENVIRONMENTAL @2008, Project No. 1484 APPENDIX Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC1 13 ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM Release Tracking Number Pursuant to 310 CMR 40.1056 & 40,1070 - 40.1084 (Subpart J) - A. DISPOSAL SITE LOCATION: 1. Disposal Site Name: Ralph Shuster Metals, Inc. V~'ENEU \! 2. Street Address: 44 Forest Street ~'V1~ 2 ~' 3. City/Town: Attleborough 4. ziP Cod ' g 5. Check here if a Tier Classification Submittal has been provided to DEPfor-this disposal site 7 a. Tier 1A [ b. Tier 18 [ c. Tier 1C 7 d. Tier 2 6. If a Tier I Permit has been issued, provide Permit Number: B. THIS FORM IS BEING USED TO: (check one) [ 1. Submit a certified copy of a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1074. 2. Submit an Evaluation of Changes In Land Uses/Activities and/or Site Conditions after a Response Action Outcome Statement has been filed pursuant to 310 CMR 40.1080. 3. Submit a certified copy of an Amended Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1081 4. Submit a certified copy of a Partial Termination of a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1083(3). H 5. Submit a certified copy of a Termination of a Notice of Activity and Use Limitation, pursuant to 310 CMR 40,1063(1)(d H 6. Submit a certified copy of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1071. . Li 7. Submit a certified copy of an Amendment of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1081(3). 3 8. Submit a certified copy of a Partial Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1083(2) 9. Submit a certified copy of a Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1083(1)(c). 3 10. Submit a certified copy of a Confirmatory Activity and Use Limitation, pursuant to 310 CMR 40.1085(4). 11. Provide Additional RTNs: [ a. Check here if this AUL Submittal covers additional Release Tracking Numbers (RTNs). b. Provide the additional Release Tracking Number(s) covered by this AUL Submittal. (All sections of this transmittal form must be filled out unless otherwise noted above. BWSC1 I 3A is required for all submittals listed above) aWI Page 1 of 4 Revised: 06/27/200306/27/2003 Page 1 of 4 Protection Bureau of Waste Site Cleanupof Environmental BW SC 113 Massachusetts Department L Number ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM Release Tracking Pursuant to 310 CMR 40.1056 & 40.1070 - 40 1084 (Subpart J) - 12 C. AUL INFORMATION: 1. Document (per Section B) Recording and/or Registration Information: a. Name of Registry of Deeds and/or Land Registration Office: Bristol County b. Book and Page Number and/or Document Number: Book 1124, Page 98 c. Date of recording and/or registration: 09/02/2008 mm/dd/yyyy 2. Is the address of the property subject to AUL different from the disposal site address listed above? a. No f b. Yes If yes, then fill out address section below. 3. Street Address: 4, City/Town: 5. ZIP Code: D. PERSON SUBMfrTING AUL TRANSMITTAL FORM: 1. Check all that apply: El a. change in contact name f b. change of address El cnde ang i spoe actions 2. Name of Organization: Ralph Shuster Metals, Inc. 3. Contact First Name: David 4. Last Name: Malkin 5. Street: 909 Main Street 6.Title: President 7. Cityrrown: Providence 8. State: RI 9. ZIP Code: 02904-0000 10, Telephone: (401) 277-0300 11. Ext.: 12. FAX: 13. Is the person described in this section the owner of the property? W a. Yes El b. No , if checked then Section G must be filled out by at least one owner, El c. Check here if providing names and addresses of any additional owners in an attachment. E. RELATIONSHIP TO DISPOSAL SITE OF PERSON SUBMITTING AUL TRANSMITTAL FORM: (check one) 1. RP or PRP Z a. Owner El b. Operator [: c. Generator d. Transporter El e. OtherRPorPRP Specify: - 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.GL c. 21E, s. 2) 3. Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s. 5()) 4. Any Other Person Submitting AUL Specify: Revised: 06/27/2003 Page 2 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSCI113 911ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM Release Tracking Number (Subpart J) Pursuant to 310 CMR 401056 & 40.1070 -40.1084 F. REQUIRED ATTACKMENT AND SUBMITTALS: 1. Check here to certify that notice of the proposed Activity and Use Limitation (AUL) was given to all record-interest holders, if any, in accordance with 310 CMR 40.1074(1)(e), via certified mail. [] a. Check here if there were no record interest holders. b. Date of certified mailing: mm/dd/yyyy c. Check here to certify that names and addresses of all record holders notified is attached. 2. Check here to certify that within 30 days of recording and/or registering the AUL, including amending, releasing or terminating the AUL, a copy of the AUL was/will be provided to the Chief Municipal Officer, the Board of Health, the Zoning Official, and the Building Code Enforcement Official in the community(ies) where the the property subject to such Activity and Use Limitation is located. 3. Check here to certify that within 30 days of recording and/or registering the AUL, including amending, releasing or 6 terminating the AUL, a Legal Notice was/will be published in a newspaper with circulation in the community(ies) where the property subject to the AUL is located. 4. Check here to certify that within 7 days of publishing a Legal Notice in a newspaper with circulation in the community(les) where the property subject to the AUL is located, a copy of the notice was/will be submitted to DEP. 5. Check here to certify that within 30 days of recording and/or registering the AUL, including amending, releasing or terminating the AUL, a certified copy of the AUL, including the LSP Opininon containing the material facts, data, and other information, will be submitted to DEP. 6. Check here if any non-updatable information provided on this form is incorrect, e.g. Site Address/Location Aid. Send corrections to the DEP Regional Office. 7. If an Evaluation of Changes in Land Uses/Activities and/or Site Conditions after a Response Action Outcome Statement is being submitted, check here to certify that the LSP Opinion containing the material facts, data, and other information is attached. G. CERT1FICATION OF OWNER OF PROPERTY, IF NOT PERSON SUBMrMiNG AUL TRANSNMTTAL FORM: 1. 1, , attest under the pains and penalties of perjury that I am th e owner of said property(ies), subject to the AUL 2. 3. Date: Signature mm/dd/yyyy 4. Name of Organization: 5. Contact First Name: 6. Last Name: 7. Street: 8. Title: 9. City/Town: 10. State: 11. ZIP Code: 12. Telephone: 13. Ext: 14. FAX; RI se:0 1 72 0 a e3o Revised: 06/27/2003 Page 3 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC113 ACTIVITY & USE LIMITATION (AUL) TRANSMITTAL FORM Release Tracking Number Pursuant to 310 CMR 40.1056 & 40.1070 -40.1084 (Subpart J) Fl- TI H. CERTIFICATION OF PERSON MAKING SUBMITTAL: TAA 9 I I~r 1.11 LfIA "\ , attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. l/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information. Pursuant to 310 CMR 40.1074 (1)(f), I also hereby certify under penalties of perjury, that either I(if person submitting the AUL Transmittal Form is the property owner), or 2. Name of Property Owner am/is identified on the Notice of AUL as the owner of the property subject to the AUL, owned such property on the date that the AUL was recorded and /or registered 4. Title: P FA e& 9-r Signature I I 25 5. For X > 5 C fftI -, 6. Date: (Name of person or entity recorded in section D) mm/dd/yyyy 7. Check here if the address of the person providing certification is different from address recorded in Section D. 8. Street: 9. City/Town: 10. State: - 11. ZIP Code: 12. Telephone: 13. Ext.: - 14. FAX: YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCONPLETE. IF YOU SUBT AN NCOMPLETE FORM, YOU MAY BE PENALIED FOR MISSING A REQUIRED DEADUNE. Date Stamp (DEP USE ONLY:) SN Revised: 06/27/2003 Page 4 of 4 fl Massachusetts Department of Environmental Protection I ] Bureau of Waste Site Cl'eanup BWSCII13A ACTIVITY & USE LIMITATION (AUL) OPINION FORM Release Tracking Number Pursuant to 310 CMR 40.1056 & 40.1070 - 40.1084 (Subpart J) - 16211 A. DISPOSAL SWE LOCATION: Inc. 1. Disposal Site Name: Ralph Shuster Metals, 2. Street Address: 44 Forest Street 3. Cityrrown: Attleborough 4. ZIP Code: 02703-0000 B. THIS FORM IS BEING USED TO: (check one) FJ 1. Provide the LSP Opinion for a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1074. 2. Provide the LSP Opinion for an Evaluation of Changes In Land Uses/Activitiles and/or Site Conditions after a Response Action Outcome Statement, pursuant to 310 CMR 40.1080. Include BWSC1I3A as an attachment to BWSC113. Section A and C do not need to be completed. S3. Provide the LSP Opinion for an Amended Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1081(4). 4. Provide the LSP Opinion for a Partial Termination of a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1083(3) - 5. Provide the LSP Opinion for a Termination of a Notice of Activity and Use Limitation, pursuant to 310 CMR 40.1083(1)(d). 6. Provide the LSP Opinion for a Grant of Environmental Restriction, pursuant to 310 CMR 40.1071. 0 7.Provide the LSP Opinion for an Amendment of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1081(3). 8. Provide the LSP Opinion for a Partial Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1083(2). 9. Provide the LSP Opinion for a Release of a Grant of Environmental Restriction, pursuant to 310 CMR 40.1083(1)(c), 10. Provide the LSP Opinion for a Confirmatory Activity and Use Limitation, pursuant to 310 CMR 40.1085(4). (Unless otherwise noted above, all sections of this form (BWSC'1I3A) must be completely filled out, printed, stamped, signed with black ink and attached as an exhibit to the AUL Document to be recorded and/or registered with the Registry of Deeds and/or Land Registration Office.) C. AUL INFORMATION: 1. Is the address of the property subject to AUL different from the disposal site address listed above? 7 a. No f1 b. Yes Ifyes, then fill out address section below. 2. Street Address: 3. City/Town: 4. ZIP Code. Revised: 06/27/2003 Page 1 of 2 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC113A ACTIVITY & USE LIMITATION (AUL) OPINION FORM Release Tracking Number - 16211 k J Pursuant to 310 CMR 40.1056 & 40.1070 - 40.1084 (Subpart J) D. LSP SIGNATURE AND STAMP: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief, > if Section B indicates that a Notice of Activity and Use Limitation is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1074; > if Section B indicates that an Evaluation of Changes in Land Uses/Activites and/or Site Conditions after a Response Action Outcome Statement is being submitted, this evaluation was developed in accordance with the applicable provisions of MG.L. c. 21E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1080; > if Section B indicates that an Amended Notice of Activity and Use Limitationor Amendment to a Grant of Environmental Restriction is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (ii) complies with 40.1081; > if Section B indicates that a Termination or a Partial Termination of a Notice ofActivity and Use Limitation,or a Release or Partial Release of a Grant of Environmental Restriction is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the a pplicable provisions of M.G.L, c. 21E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1083; > if Section S indicates that a Grant of Environmental Restriction is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (ii) complies with 310 CMR 40.1071; > if Section B indicates that a ConfirmatoryActivity and Use Limitation is being registered and/or recorded, the Activity and Use Limitation that is the subject of this submittal (i) is being provided in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (ii) complies with 310 GMR 40.1085(4); I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete. 1, LSP #: 7770 2. First Name: Kurt 3. Last Name: Klages 4.Telephone: (413) 782622 5, Ext: 6. FAX: (413) 787-2646 7. Signature: 8. Date: 9. LSP Stamp: y tm d/M Revised: 06/27/2003 Page 2 of 2 Revised: 06/27/2003 Page 2 of 2 Bureau of Waste Site Cleanup BWSC111 AUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT - 16211 Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K) A. DISPOSAL SITE LOCATION: 1. Disposal Site Name: Ralph Shuster Metals, Inc. 2. Street Address: 44 Forest Street 3. Cityrrown: Attleborough 4. ZIP Code: 02703-0000 L 5. Check here if a Tier Classification Submittal has been provided to DEP for this disposal site. I a. Tier 1A [] b. Tier 1B [] c. Tier IC Z d. Tier 2 6. If a Tier I Permit has been issued, provide Permit Number: B. THIS FORM IS BEING USED TO; (check one) 1. Submit an Audit Follow-Up Plan (Section C is not required). 2. Submit a Modified or Revised Audit Follow-Up Plan (Section C is not required). 3. Submit a Post-Audit Completion Statement 4, Provide Additional RTNs: LI a. Check here if this Audit Submittal covers additional Release Tracking Numbers (RTNs). b. Provide the additional Release Tracking Number(s) covered by this Audit Submittal. W L- (All sections of this transmittal form must be filled out unless otherwise noted above) C. POST-AUDIT RESPONSE ACTIONS SUMMARY: 1. Notice of Audit Finding Date Issued: 12/21/2008 mm/dd/yyyy 2. Documentation (check all that apply): a. Provided Technical Justification, or Supporting or Clarifying Information Relating to Previous Response Actions b. Performed Additional Risk Assessment c. Modified Disposal Site Boundary 3. Field Work (check all that apply): a. Sampled Previously Assessed Media (check all that apply): [ Soil [Z GW [] SW fl Sediment E] Air Waste Material b. Sampled New Media Not Previously Assessed (check all that apply): Z Soil [ GW fl SW E] Sediment E] Air E] Waste Material c. Performed Remediation Describe: Capping of entire site w/ Engineered Barrier (See RAO) Revised: 06/27/2003 Page 1 of 4 Massachusetts Department of Environmental Protection BWSC111 LL71 Bureau of Waste Site Cleanup AUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT-16 1 Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K) C. POST-AUDIT RESPONSE ACTIONS SUMMARY: (cont) 4. Outcome (Check all that apply and submit appropriate transmittal form(s)): a. Implemented or Amended Activity and Use Limitation b. Modified Risk Assessment Method c. Revised Response Action Outcome (RAO) Class d. Revised Tier Classification a. Revised or Modified Phase Work f. Retracted RAO Statement g. Other D. LSP SIGNATURE AND STAMP: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR 4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief, > if Section B of this fonn indicates that an Audit Follow-up Plan, or a Modified or Revised Audit Follow-up Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (iii) oomplies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal; > if Section B of this form indicates that a Post-Audit Completion Statement is being submitted, the Post-Audit response action(s) that is (are) the subject of this submittal as required to correct either violations and/or deficiencies identified by DEP in a Notice of Audit Finding pursuant to 310 CMR 40.1140 (i) has (have) been developed, implemented and completed in accordance with the applicable provisions of M.G.L. c.21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c.21 E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, approvals, or Audit Follow-up Plans pursuant to 310 CMR 40.1160 as identified in this submittal. Development, implementation and completion of the Post-Audit response action(s) have corrected the violations and/or deficiencies identified by DEP in the Notice of Audit Finding. This Statement does not (1) apply to actions or other aspects of the site that were not reviewed in the audit, (2) preclude future audits of past, current, or future actions at the site, (3) in any way constitute a release from any liability, obligation, action or penalty under M. G.L. c.21E, 310 CMR 40.0000, or any other law, regulation, or requirement, or (4) limit the Department's authority to take or arrange, or to require any Responsible Party or Potentially Responsible Party to perform, any response action authorized by M.G.L. c.21E, which the Department deems necessary to protect health, safety, public welfare or the environment. Page 2 of 4 Revised: 06/27/2003 Page 2 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC111 AUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT -[ 121 Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K) D. LSP SIGNATURE AND STAMP: (cont I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete. 1. LSP#: 7770 2. First Name: Kurt 3. Last Name: KageS 4. Telephone: (413 88-2622. 5.AI 640 7. Signature: 8. Date 9. LSP Stamp: rnnv~~yi( KURT 4 E. PERSON RESPONDING TO AUDrr: 1. Check all that apply: 1 a. change in contact name b. change of address L Iundertakingc. change in response the person actions 2. Name of Organization: Ralph Shuster Metals, Inc. 3. Contact First Name: David 4. .ast Name: Malkin 5. Street: 909 Main Street 6. Title: Pres~ient 7. City/Town: ProvidenCe 8. State: RI 9. ZIP Code: 02904-0000 10. Telephone: (401) 277-0300 11. Ext. 12. FAX: F. RELATIONSHIP TO SITE OF PERSON RESPONDING TO AUDIT: I 1.RP or PRP 7] a. Owner [] b. Operator [] c. Generator I d. Transporter LI e,OtherRPorPRP Specify: J 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2) 3. Agency or Public Utility on a Right of Way (as defined by M.G.L. c, 21 E, s. 5(j)) L 4.Any Other Person Responding to Audit Specify Relationship: Revised: 06/27/2003 Page 3 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC111 AUDIT FOLLOW-UP PLAN TRANSMITTAL FORM Release Tracking Number & POST- AUDIT COMPLETION STATEMENT M-jf/ J Pursuant to 310 CMR 40.1160 - 40.1170 (Subpart K) G. REQUIRED ATTACHMENT AND SUBMITTALS: 1. Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) 1 and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof. A e P- 5(- yA 0rc2 E 2. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached. H. CERTIFICATION OF PERSON RESPONDING TO AUDIT: 1. i, V - / A ,attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompahying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information. 2. By (7 3A Titfe: Signature 4. For 5. Date: (Name of person or entity recorded in Section E) mm/dd/yyyy D 6. Check here if the address of the person providing certification is different from address recorded in Section E. 7. Street 8. City/Town: 9. State: 10. ZIP Code: 11. Telephone: 12. Ext.: - 13. FAX: YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IFYOU SUBMIT AN INCOMPLETE FORK YOU MAY BE PENALIZED FOR MISGING A REQUIRED DEADUNE. Date Stamp (DEP USE ONLY:) 0 N J Reie:0/7203Pg o Revised: 06/27/2003 Page 4 of 4 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 Release Tracking Number RESPONSE ACTION OUTCOME (RAO) STATEMENT - 7 1 Pursuant to 310 CMR 40.1000 (Subpart J) [ - 1211 For sites with multiple RTNs, enter the Primary RTN above. A. SITE LOCATION: 1. Site Name/Location Aid: Ralph Shuster Metals,lnc. 2. Street Address: 44 Forest Street 3. Cityfown: Attleboraugh 4. ZIP Code: 02703-0000 0 5. Check here if a Tier Classification Submittal has been provide d to DEP for this e si E a. Tier IA F1 b, Tier IB LI c. Tier IC d. Tier il 6. Ifa Tier I Permit has been issued, provide Permit Number: Vn B. THIS FORM IS BEING USED TO: (check all that apply) 1. List Submittal Date of RAO Statement (if previously submitted): 01/0612006 m/d y SOUTHEAST F --- L 2. Submit a Response Action Outcome (RAO) Staten ent a. Check here if this RAO Statement covers additi onal Release Tracking Numbers (RTNs). RTNs that have been previously linked to a Tier Classified Primary RTN do not need to be listed here. b. Provide additional Release Tracking Number(,s) covered by this RAO Statement. D:1-W Y 3. Submit a Revised Response Action Outcome Stat ement a. Check here if this Revised RAO Statement cov ers additional Release Tracking Numbers (RTNs), not listed on the Fl RAO Statement or previously submitted Revised RAG Statements. RTNs that have been previously linked to a Tier Classified Primary RTN do not need to be listed here, b. Provide additional Release Tracking Number( s) covered by this RAO Statement. FH-ZZ H-LY 4. Submit a Response Action Outcome Partial (RAO *P) Statement Check above box, if any Response Actions remain to be taken to address conditions associated with this disposal site having the Primary RTN listed in the header section of this transmittal form. This RAO Statement will record only an RAO-Partial Statement for that RTN. A final RAO Statement will need to be submitted that references all RAO-Partial Statements and, if applicable, covers any remaining conditions not covered by the RAO-Partial Statements. Also, specify if you are an Eligible Person or Tenant pursuant to M.G.L. c. 21 E s.2, and have no further obligation to conduct response actions on the remaining portion( ,) of the disposal site: LI a. Eligible Person [U b. Eligible Tena nt 5. Submit an optional Phase I Completion Statement supporting an RAO Statement 6. Submit a Periodic Review Opinion evaluating thet status of a Temporary Solution for a Class C-1 RAO Statement, as specified in 310 CMR 40.1051 (Section F is optional) U 7. Submit a Retraction of a previously submitted Res ponse Action Outcome Statement (Sections E & F are not required) (All sections of this transmittal form, nust be filled out unless otherwise noted above) Page 1 of 7 Revised: 02/28/200602128/2008 Page 1 of 7 Masschuettf Eniromenal Deprtmnt Potetio Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 Release Tracking Number RESPONSE ACTION OUTCOME (RAO) STATEMENT - 16211 J) Pursuant to 310 CMR 40.1000 (Subpart C. DESCRIPTION OF RESPONSE ACTIONS: (check all that apply; for volumes, list cumulative amounts) S 1. Assessment and/or Monitoring Only 2. Temporary Covers or Caps S 3. Deployment of Absortbent or Containment Materials 4. Treatment of Water Supplies S 5, Structure Venting System 6. Engineered Barrier 77. Product or NAPL Recovery j 8. Fencing and Sign Posting B 9. Groundwater Treatment Systems Q 10. Soil Vapor Extraction I 11. Bioremediation U 12. Air Sparging 13. Monitored Natural Attenuation H 14. In-situ Chemical Oxidation L 15. Removal of Contaminated Soils L a.Re-use, Recycling or Treatment i. On Site Estimated volume in cubic yards L ii.Off Site Estimated volume in cubic yards iia. Facility Name: Town: State: iib. Facility Name: Town: State: iii. Describe b. Landfill F i. Cover Estimated volume In cubic yards Facility Name: Town: State: n ii. Disposal Estimated volume in cubic yards Facility Name: Town: State: 16. Removal of Drums, Tanks or Containers: a. Describe Quantity and Amount: i b. Facility Name: Town: State: c. Facility Name: Town: State: 0l 17. Removal of Other Contaminated Media: a. Specify Type and Volume: b. Facility Name: Town: State: c. Facility Name: Town: State: Page 2 of 7 Revised: 02/281200602/28/206 Page 2 of 7 Massachusetts Department of Environmental Protection Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number 4 - 16211 Pursuant to 310 CMR 40.1000 (Subpart J) C. DESCRIPTION OF RESPONSE ACTIONS (cont): (check all that apply; for volumes, list cumulative amounts) f 18. Other Response Actions: Describe: 19. Use of Innovative Technologies: Describe: D.SITE USE: 1. Are the response actions that are the subject of this submittal associated with the redevelopment, reuse or the major expansion of the current use of property(ies) impacted by the presence of oil and/or hazardous materials? n a. Yes g b. No n c. Don't know 2. Is the property a vacant or under-utilized commercial or industrial property ("a brownfield property")? n a. Yes K b. No n c. Don't know 3. Will funds from a state or federal brownfield incentive program be used on one or more of the property(ies) within the disposal site? * a. Yes J b. No f c. Don't know If Yes, identify program(s): 4. Has a Covenant Not to Sue been obtained or sought? R a. Yes K] b. No ID c. Don't know 5. Check all applicable categories that apply to the person making this submittal: fl a. Redevelopment Agency or Authority E] b. Commmunity Development Corporation 0 c. Economic Development and Industrical Corporation E d.Private Developer [j e. Fiduciary [I f. Secured Lender 0 g. Municipality o h.Potential Buyer (non-owner) NJ i. Other, describe: Corporation This data will be used by MassDEP for information purposes only, and does not represent or create any legal commitment, obligation or liability on the part of the party or person providing this data to MassDEP. E,. RESPONSE ACTION OUTCOME CLASS: Specify the Class of Response Action Outcome that applies to the disposal site, or site of the Threat of Reiease. Select ONLY one Class. 1.. Class A-1 RAO: Specify one of the following: F a. Contamination has been reduced to background levels, b. A Threat of Release has been eliminated. 2. Class A-2 RAO: You MUST provide justification that reducing contamination to or approaching background levels is infeasible. 3. Class A-3 RAO: You MUST provide an implemented Activity and Use Limitation (AUL) and justification that reducing contamination to or approaching background levels is infeasible. 4. Class A-4 RAO: You MUST provide an implemented AUL, justification that reducing contamination to or approaching background levels is infeasible, and justification that reducing contamination to less than Upper Concentration Limits (UCLs) 15 feet below ground surface or below an Engineered Barrier is infeasible. If the Permanent Solution relies upon an Engineered Barrier, you must provide or have previously provided a Phase IlII Remedial Action Plan that justifies the selection of the Engineered Barrier. Page 3 of 7 I Revised: 02/28/2006 Page 3 of 7 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number Pursuant to 310 CMR 40.1000 (Subpart J) E. RESPONSE ACTION OUTCOME CLASS (cont): 5. Class B-1 RAO: Specify one of the following: a. Contamination is consistent with background levels M b. Contamination is NOT consistent with background levels. 6. Class B-2 RAO: You MUST provide an implemented AUL. S7. Class B-3 RAO: You MUST provide an implemented AUL and justification that reducing contamination to less than l Upper Concentration Limits (UCLs) 15 feet below ground surface is infeasable. 8. Class C-I RAO: You must submit a plan as specified at 310 CMR 40.0861(2)(h). Indicate type of ongoing response actions. a. Active Remedial System b. Active Remedial Monitoring Program c. None RAO Text) X d. Other Spefy: Monitoring via Sampling (See 9. Class C-2 RAO: You must hold a valid Tier I Permit or Tier il Classification to continue response actions toward a Permanent Solution. F. RESPONSE ACTION OUTCOME INFORMATION: 1. Specify the Risk Characterization Method(s) used to achieve the RAO described above: E a. Method 1 [] b. Method 2 ] c. Method 3 * d.Method Not Applicable-Contamination reduced to or consistent with background, or Threat of Release abated 2. Specify all Soil Category(ies) applicable. More than one Soil Category may apply at a Site. Be sure to check off all APPLICABLE categories: a. S-1/GW-1 E] d, S-2/GW-1 E g. S-3/GW-1 b. S-I/GW-2 e. S-2/GW-2 l h. S-3/GW-2 c. S-:/GW-3 El f. S-2/GW-3 E i. S-3/GW-3 3. Specify all Groundwater Category(ies) impacted. A site may impact more than one Groundwater Category. Be sure to check off all IMPACTED categories: E a. GW-1 b. GW-2 Z c. GW-3 E] d. No Groundwater Impacted 4. Specify remediation conducted: El a. Check here if soil remediation was conducted. C] b. Check here if groundwater remediation was conducted. 5. Specify whether the analytical data used to support the Response Action Outcome was generated pursuant to the Department's Compendium of Analytical Methods (CAM) and 310 CMR 40.1056: E a. CAM used to support all analytical data. g] b. CAM used to support some of the analytical data, E c. CAM not used. 6. Check here to certify that the Class A, B or C Response Action Outcome includes a Data Usability Assessment and Data Representativeness Evaluation pursuant to 310 CMR 40.1056. 7. Estimate the number of acres this RAO Statement applies to: Revised: 02/28/2006 Page 4 of 7 Massachusetts Department of Environmental Protection Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number R 6211 Pursuant to 310 CMR 40.1000 (Subpart J) G. LSP SIGNATURE AND STAMP: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief, > if Section 8 indicates that either an RAO Statement, Phase I Completion Statement and/or Periodic Review Opinion is being provided, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal. I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete. 1. LSP#: 7770 Kurt Klages 2. First Name: 3. Last Name: 508-853-5027 Same 4. Telephone: 5. Ext.:- 6. FAX: 7. Signature: 8. Date: 9. LSP Stamp: H. PERSON MAKING SUBMITTAL: in the person 1. Check all that apply: 0 a. change in contact name [ b. change of address Iundertakingc. change response actions 2. Name of Organization Ralph Shuster Metals, Inc. Malkin 3. Contact First Name: David 4. Last Name: 5. street: 909 North Main Street 6. Title: President 7. City/Town: ProvidenCe 8. State: RI 9. ZIP Code: 02904 0. Telephone: I0 401-277-0300 11.1Et:______Ext.: 1.FX12. FAX: Page Sot 7 Revised: 02/28/200602/28/2006 Page 5 of 7 Massachusetts Department of Environmental Protection Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 RESPONSE ACTION OUTCOME (RAO) STATEMENT Release Tracking Number Pursuant to 310 CMR 40.1000 (Subpart J) 9- 16211 I I. RELATIONSHIP TO RELEASE OR THREAT OF RELEASE OF PERSON MAKING SUBMITTAL: 1. RP or PRP [] a. Owner [ b. Operator K c. Generator E] d. Transporter Q e. Other RP or PRP Specify: 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2) 3. Agency or Public Utility on a Right of Way (as defined by M.G.L. 0.21 E, s. 5(j)) E 4. Any Other Person Making Submittal Specify Relationship: J. REQUIRED ATTACHMENT AND SUBMITTALS: 1. Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof. ACOP 2. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of an RAO Statement that relies on the public way/rail right-of-way exemption from the requirements of an AUL. 3. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of a RAO Statement with instructions on how to obtain a full copy of the report. 0 4. Check here to certify that documentation is attached specifying the location of the Site, or the location and boundaries of the Disposal Site subject to this RAO Statement. If submitting an RAO Statement for a PORTION of a Disposal Site, you must document the location and boundaries for both the portion subject to this submittal and, to the extent defined, the entire Disposal Site. 5. Check here to certify that, pursuant to 310 CMR 40.1406, notice was provided to the owner(s) of each property within the disposal site boundaries, or notice was not required because the disposal site boundaries are limited to property owned by the party conducting response actions. (check all that apply) a. Notice was provided prior to, or concurrent with the submittal of a Phase i Completion Statement to the Department. b. Notice was provided prior to, or concurrent with the submittal of this RAO Statement to the Department. c. Notice not required. d. Total number of property owners notified, if applicable: 6. Check here if required to submit one or more AULs. You must submit an AUL Transmittal Form (BWSC113) and a 1 copy of each implemented AUL related to this RAO Statement. Specify the type of AUL(s) below: (required for Class A-3, A-4, 8-2, B-3 RAO Statements) a. Notice of Activity and Use Limitation b. Number of Notices submitted: c. Grant of Environmental Restriction d. Number of Grants submitted: 7. If an RAO Compliance Fee is required for any of the RTNs listed on this transmittal form, check here to certify that an RAO Compliance Fee was submitted to DEP, P. 0. Box 4062, Boston, MA 02211. 8. Check here if any non-updatable information provided on this form is incorrect, e.g. Site Address/Location Aid. Send corrections to the DEP Regional Office. 9. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached. Revised: 02/28/2006 page 6 of 7___ Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC104 Release Tracking Number RESPONSE ACTION OUTCOME (RAO) STATEMENT Pursuant to 310 CMR 40.1000 (Subpart J) EI- /2 /1 K CERTIFICATION OF PERSON MAKING SUBMT TAL: 1.1, 2) O --t a- , attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. 1/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information. 2. By AV 3. Title: Signature 4. For ______5. Date: fame of person or entity recorded in Section H) mm/dd/y I] 6.Check here if the address of the person providing certification is different from address recorded in Section H. 7. Street: 8. City/Town: 9. State: 10. ZIP Code: 11. Telephone: 12. Ext.: -- 13 FAX: YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM YOU MAY BE PENALIED FOR MISSING A REQUIRED DEADLINE. I Date Stamp (DEP USE ONLY:) 0 Page 7 of 7 Revised: 02/28/200602/26/2006 Page 7 of 7 APPENDIX B Copy of Former RAO/Phase l/Phase III WESTERN MASS ENVIRONMENTAL © 2008, Project 1484 APPENDIX Response Action Outcome (RAO) Statement Report, Phase I CSA, Phase Ill Remedial Action Alternatives 44 Forest Street Atfleboro, MA RTN 4-16211 PROJECT NO. 1000400. Response Action Outcome (RAO) Statement, Phase I Comprehensive Site Assessment, & Phase Ill Remedial Action Alternatives Potentially Responsible Party: Ralph Shuster Metals, Inc. 909 Main Street Providence, RI 02904 Contact: Mr. David Malkin, President Ph: (401) 521-4477 January 6, 2006 Jacques Whitford 24 Albion Road, Suite 220 Lincoln, RI 02865 Phone: (401) 312-8005 Fax: (401) 312-8010 www.jacqueswhitford.com urt E. K es, S r. Projct M ager Vincent L. Jac ~ spE Area Manager Table of Contents RAO, PHASE |1 CSA, PHASE IlI RAA 1.0 INTRO DUCTIO N ...... 1 2.0 PROPERTY DESCRIPTION & SURROUNDING RECEPTORS ...... 1 3.0 RELEASE HISTO RY...... 2 4.0 COMPLETED ASSESSMENT ACTIONS...... 2 5.0 CONCEPTUAL CONTAMINANT MODEL ...... 4 6.0 MANAGEMENT OF REMEDIATION WASTE ...... 5 7.0 REMEDIAL ACTION ALTERNATIVES...... 6 7.1 INITIAL SCREENING METHOD ...... 6 7.1.1 No A dditional Action ...... 6 7.1.2 N atural Attenuation...... 7 7.1.3 In-Situ T reatm ent...... 7 7.1.4 Groundw ater ...... 9 7.1.5 S urface W ater ...... 9 7.2 SUMMARY OF SCREENING EVALUATION RESULTS...... 9 8.0 REMEDIAL ACTION PLAN ...... 9 8.1 JUSTIFICATION FOR SELECTION OF REMEDIAL ALTERNATIVES ...... 9 8.2 PERMANENCY/ANTICIPATED PERMANENCY OF SELECTIONS...... 10 8.3 FEASIBILITY OF RESTORATION TO BACKGROUND...... 10 8.4 IMPLEMENTATION SCHEDULE...... 10 9.0 DISPOSAL SITE DEFINITION AND SITE ACTIVITY AND USE [CURRENT AND FORESEEABLE]...... 10 9.1 SOIL AND GROUNDWATER CHARACTERIZATION...... 11 9.2 CONTAMINANTS OF CONCERN ...... 11 9.3 EXPOSURE POINT CONCENTRATION...... 13 10.0 METHOD I RISK CHARACTERIZATION - SOIL & GROUNDWATER...... 14 10.1 FEASIBILITY ASSESSMENT - SOIL...... 15 10.2 RISK TO SAFETY EVALUATION...... 15 11.0 CLASS C RESPONSE ACTION OUTCOME STATEMENT ...... 16 12.0 PERIODIC EVALUATION AND MONITORING PLAN ...... 17 13.0 FIN DING S ...... 17 14.0 CERTIFICATIO N...... 18 List of Tables Table 1 - Soil Analytical Results Table 2 - Groundwater Analytical Results Table 3 - Sediment Analytical Results Table 4 - Surface Water Analytical Results Table 5 - Initial Screening Matrix Table 6 - Exposure Point Concentrations List of Figures Figure 1 - Site Locus Figure 2 - Site Plan List of Appendices - APPENDIX Transmittal Forms ...... A APPENDIX Original Certified AUL and Opinion...... B APPENDIX Phase I Initial Site Investigation...... C APPENDIX Method 3 Stage I Environmental Screening ...... 0 APPENDIX Substantial Hazard Evaluation for Human Health to Sediment and Surface W ater ...... E - APPENDIX Laboratory Reports...... F APPENDIX Public Notification...... G RAO, PHASE 11 CSA, PHASE Il RAA 1.0 INTRODUCTION - The purpose of this submittal is to supply the Massachusetts Department of Environmental Protection (MADEP) with a Response Action Outcome (RAO) Statement Report Package for the site located at 44 Forest Street in Attleboro, Massachusetts. This package has been prepared by - Jacques Whitford Co., Inc. (Jacques Whitford) on behalf of the potentially responsible party (PRP), Ralph Shuster Metals, Inc. (RSM), to demonstrate that a temporary solution, as defined by the Massachusetts Contingency Plan (MCP - Section 310 CMR 40.1050), has been achieved at the site. Information required for a RAO Report, as specified in Section 310 CMR 40.1056, Phase Il Comprehensive Site Assessment (Phase II) as specified in Section 310 CMR 40.0830, and Phase Ill Identification, Evaluation, and Selection of Comprehensive Remedial Action Alternatives (Phase II) as specified in Section 310 CMR 40.0850 are contained in this document as a whole. Throughout this report, the property or subject property will be utilized when referring to the entire area encompassing Plat Map 61, Lot 181, while "site" or "disposal site" will refer to the area where contamination has been detected. This RAO report is based upon the results of a Phase I Initial Site Investigation (Phase 1), dated April 2002; on Phase 11Comprehensive Site Assessment, conducted in June and July 2005; on a Method 3 Stage I Environmental Screening, dated October 2005; on a Method 3 No Substantial Hazard Evaluation for Human Health Exposures to Sediment and Surface Water, dated December 20, 2005, and on an Activity and Use Limitation (AUL) Opinion filed on December 28, 2005. Copies of the Bureau of Waste Site Cleanup (BWSC) Transmittal forms for a RAO, Phase lI, Phase ll[ and AUL Submittal are provided in Appendix A; a copy of the AUL Opinion and applicable forms including proof of filing and appropriate notification are included in Appendix B; a copy of the Phase I completed by other parties is included in Appendix C; a copy of the Method 3 Stage I Environmental Screening is included in Appendix D; a copy of Method 3 - No Substantial Hazard Evaluation for Human Health Exposures to Sediment and Surface Water is included in Appendix E; copies of laboratory documentation is included in Appendix F; and copies of the public notification applicable to the submittal of the RAO package is included in Appendix G. - The original transmittal forms are provided as a separate attachment to this report. A tare sheet from the local paper indicating filing of the AUL, as well as other applicable notification documentation will be submitted within 30 days of filing the AUL, in a separate submittal. Refer to Figure 1 for the regional location of the site. - 2.0 PROPERTY DESCRIPTION & SURROUNDING RECEPTORS The property which contains the disposal site is owned by RSM and is located at 44 Forest Street in -- Attleboro, Massachusetts. It should be noted that RSM owns parcels listed at the Attleboro Assessors Office at Plat Map 61, Lots 169, 181, 182D, 182G, 170, and 170A, listed under addresses 40 and 44 Forest Street. In addition, the previous Phase I indicated the site to be located at 40 Forest Street and abutters. However, the disposal site is situated solely on the property identified on Plat Map 61 as Lot 181, listed in the Attleboro Assessors Office as 44 Forest Street. The 10 acre subject property is industrially zoned. The site has no building structures, but has an access roadway leading from Eddy Street across a wetland and ending at the RSM facility parking lot. The access roadway enters the wetland on the north side of Eddy Street, approximately 75 feet from the corner of Forest Street. The area is located in an area of town zoned for "Industrial Use". However, residentially zoned properties are located within close Jacqins Whitfid © 2006 PROJECT No. 1000400 January 2006 1 proximity to the site. The wetland is ungraded and is overgrown with wetland flora; the only visible topographic relief within the wetland is the roadway. The wetland and roadway is currently fenced with access from Eddy Street. According to the Phase 1,the property at 40 Forest Street has historically been utilized for industrial purposes. Also according to the Phase 1, since the mid 1950's, the property has been utilized by RSM for the collection, separation and shipping of scrap metals. However, the exact date of RSMs property occupation and use could not be confirmed. According to representatives of RSM, the metals included ferrous and non-ferrous types, such as nickel, aluminum and copper, and the site was not utilized for the refining or cleaning of the metals, just for the collection and separation. Based on the current use of the site, as a wetland, it is likely that the site, Lot 181, has never been developed. Based on information derived from site reconnaissance, the USGS Quadrangle, the MADEP MCP/21 E NRS Site Map, and other sources, the only known wetlands, vernal pools, ponds, lakes, streams, rivers, or reservoirs potentially within 500 feet of the Disposal Site is the site wetland, parts of which are considered a portion of the disposal site. The wetland associated with the site appears to be located near several wetland areas, associated with Coopers Pond to the east, Bungay River to the north and west and significant wetlands to the south that according to the MCP/21 E NRS Site Map appear to be connected. These wetlands have several unnamed brooks that feed Thrasher Brook, which feeds into the Ten Mile River. According to the Massachusetts Surface Water Quality Standards, the Disposal Site is located within the Ten Mile River Basin. This area is designated as a Class B waterway, designated as a habitat for fish, other aquatic life, wildlife, and for primary and secondary contact recreation. Where designated, the area is suitable as a source of public water supply, with appropriate treatment. 3.0 RELEASE HISTORY According to information contained within the Phase I, on April 17, 2001, a MADEP representative observed an oil sheen on the surface of the wetland, located within the boundaries of Lot 181. On May 18, 2001, the MADEP determined that the release (i.e. noted sheen on surface water) was, or may have been, a disposal site as defined in the MCP, 310 CMR 40.0000. Therefore, the MADEP issued RSM a Notice of Responsibility (NOR), as a potentially responsible party pursuant to M.G.L. c. 21E, 310 CMR 40.0000, referencing Release Tracking Number (RTN) 4-16211. A copy of the NOR is included in Appendix B, as part of the Phase 1. As indicated in the NOR, general response action requirements included the need for filing an Immediate Response Action (IRA) Plan, IRA Completion Statement and/or Response Action Outcome (RAO) Statement report and the need for employing or engaging a Licensed Site Professional (LSP) to manage, supervise, or actually perform necessary response actions. The NOR specifies that a plan for IRA assessment should be completed and forwarded for approval. 4.0 COMPLETED ASSESSMENT ACTIONS The following is a listing and summary of the existing environmental data compiled for the disposal site from May 2001 to the present. All of these documents have previously been submitted to the MADEP. Jcque ldtford @ 2006 PROJECT No. 1000400 January 2006 2 * September 2001 - IRA Plan - Kaegael Environmental, Inc. " April 2002 - IRA Completion - Kaegael Environmental, Inc. . April 2002 - Phase I Initial Site Investigation and Tier Classification * October 2003 - Method 3 Risk Characterization - Eco-Solutions * April 2005 - Sediment and Soil Sample Collection - Aquatronics Industries, Inc. e June 24, 2005 - Regulatory Timeline Letter - Jacques Whitford * September 27, November 14, and December 16, 2005 - Regulatory Compliance Timeline Letters - Jacques Whitford e December 30, 2005 - Activity and Use Limitation (AUL) - Jacques Whitford Historical Summary The IRA Plan included the assessment of soil, groundwater, surface water and sediment and was submitted to the MADEP for approval. Kaegael Environmental, Inc. (KEI) oversaw the installation of two monitoring wells (KE-1 and KE-2), and collected soil samples from each boring from 0 to 3 feet below surface grade (bsg) in borings KE-1 and KE-2, from 6 to 8 feet bsg and 15 to 16 feet bsg in KE-1 and from 4 to 6 feet bsg and 13 to 15 feet bsg in KE-2. Soil samples were analyzed for one or more of the following: extractable petroleum hydrocarbons (EPH) with polynuclear aromatic hydrocarbons (PAHs), volatile organic compounds (VOCs), total petroleum hydrocarbons (TPH) and/or polychlorinated biphenyls (PCBs). Groundwater samples were collected from the newly installed monitoring wells KE-1 and 2, and from existing monitoring well (SHU2s), which is present at the site due to an investigation completed for the neighboring Texas Instruments facility. Groundwater samples were analyzed for EPH with PAHs and RCRA 8 metals. Sediment samples were collected from both sides of the roadway (SS-1 through SS-14), and surface water samples were collected from both sides of the roadway, SW-E collected from the east side of the roadway, and SW-W collected from the west side of the roadway. The results of this investigation were compiled in the Phase I and IRA Completion report package completed for the site. Soil results indicated no concentrations in excess of applicable Method 1 Soil Standards. However, the shallow soil sample collected from borings KE-1 and KE-2 were composited into one soil sample. That sample had levels of PCBs close to the Method 1 Soil Standard. Groundwater results indicated no evidence of groundwater impacts exceeding applicable Method 1 Groundwater Standards. Sediment results were compared to the Method 1 Soil Standards, for comparison purposes only, which had exceedences of select metals. In addition, surface water results were also compared to Method 1 Groundwater Concentrations, for comparison purposes only, which had exceedences of select metals. All analytical results of past and present sampling have been tabulated in Tables 1, 2, 3 and 4, Soil, Groundwater, Sediment, and Surface Water results, respectively. The numerical ranking system (NRS) scoresheet completed for the site as part of the Tier Classification concluded that the site was a Tier II Site. The Method 3 Environmental Risk Characterization completed in October 2003, by Eco-Solutions compared the sediment results collected up to that date with appropriate threshold effect levels for sediment and surface water. The Method 3 Environmental Risk Characterization concluded that for aquatic receptors in the wetlands, there are complete exposure pathways associated with the oil and/or hazardous material (OHM) from the site (along the west side of the access road) and attributed to "local conditions" (adjacent to the former auto body shop/Crown Limousine and outfall pipe). These potential exposures may represent "readily apparent harm" for surface water and "potentially significant exposures" for surface water and sediment. Therefore, a condition of No Significant Risk of Harm to the environment does not exist. However based on the criteria outlined in the MCP 310 CMR 40.0956, a condition of No Substantial Hazard exists for the Site. It should be noted that the environmental characterization concludes that the western portion of the wetland is the primary area of harm to environmental media. Jacques Whtfod © 2006 PROJECT No. 1000400 January 2006 3 - In April 2005, RSM contracted Aquatronics, Inc. to collect sediment and soil samples from the site. Two soil samples (Roadbed-East and Roadbed-West) were collected from the roadway and analyzed for PAHs and two sediment samples (Roadbed-East and Roadbed-West) were collected from either side of the road and analyzed for RCRA 8 Metals by Total Characterization Leachate Parameters (TCLP). The results indicated no PAH concentrations within soil above the laboratory method detection limits, and only lead was detected above laboratory detection limits (0.46 mg/I) in the sediment sample collected from the east side of the roadway. It should be noted that the nomenclature utilized by Aquatronics, Inc. is incorrect and the sample IDs are reversed due to an incorrect assumption of east and west (Figure 2). In June 2005, Jacques Whitford was contracted by RSM to conduct assessment actions and act as LSP for the site. As such, Jacques Whitford submitted a letter to the MADEP outlining a new timeline. In September 2005, Jacques Whitford determined that the placement of an AUL would allow for the - "temporary" closure of the site with an RAO Class C. As such, Jacques Whitford requested that RSM contract a surveyor to complete the appropriate plans for the delineation of the AUL. In addition, Jacques Whitford submitted an additional letter to the MADEP indicating that the timeline in the previous June letter would not be sufficient. As the surveyor could not complete the survey by the November 15, 2005.deadline agreed upon, Jacques Whitford submitted a second timeline letter on November 14, 2005, indicating that the AUL would be filed and the RAO would be submitted prior to December 15,2005. The survey plan was received by Jacques Whitford on December 14,2005, and the RAO and AUL with applicable plan was submitted for review. As the plan was only received one day prior to the December 15, 2005 deadline, Jacques Whitford submitted an additional timeline letter outlining the delay and indicating that the RAO would be submitted by January 6, 2006. The AUL was filed with the Bristol County Registry of Deeds on December 30, 2005. A copy of the AUL package, as it was received from the Bristol County Registry of Deeds is included within Appendix B. The original will be submitted under separate cover with appropriate public notification documentation. 5.0 CONCEPTUAL CONTAMINANT MODEL The release at this site was detected by a sheen on surface water. At no time during Jacques Whiff ord's visits to the site has a sheen been noted on surface water. Through investigation, it was determined that the most likely cause of the sheen was the construction material of the roadway and the presence of a neighboring autobody repair facility, which has since been converted to a limousine rental facility. A recent visit to the site by Jacques Whitford personnel has found dumping in the wetland from the neighboring limousine rental facility, in the form of gasoline cans, fluorescent bulbs, tires, empty metal drums, etc. RSM has asked the neighbor to cleanup the dumped material. While RSM does not claim that this dumping is the sole source of the release, it - is mentioned here since the highest concentrations detected within the wetland are on the west side of the roadway directly behind the limousine facility and closest to the dumping. In addition, the presence of old gasoline containers may have influenced the concentrations of petroleum hydrocarbons in the western portion of the wetland. The roadway was constructed utilizing soil and scrap metal from the RSM facility operations. The scrap metal within the roadway has likely leached cutting oils and metals to the wetland, as evidenced by the detection of metals, PCBs and EPH chainlengths in wetland sediment and soil samples collected from the roadway. The wetland sediment and surface water samples were utilized to complete a Substantial Hazard Evaluation for human health and a Method 3 Stage I Environmental Screening for environmental media to determine human health and environmental risk from wetland surface water and sediment. The results of sediment and surface water indicate that a Substantial Hazard to human health does not exist from wetland sediment or surface water, and a Substantial Hazard does not exist to environmental media. Jacqus Whitford 2006 PROJECT No. 1000400 January 2006 4 As concentrations of soil beneath the roadway exceed applicable Method 1 Risk Characterization Soil Standards but do not exceed upper concentration limits (UCLs) as outlined in 310 CMR 40.0996(7), in the opinion of Jacques Whitford, soil beneath the roadway does pose a risk to human health. To minimize this risk from roadway soil, RSM has placed an AUL on the roadway. In addition, RSM will be capping the roadway with asphalt within one year, however, while capping of the roadway will minimize risk through minimizing direct contact to roadway soils it is Jacques Whitford's opinion that the AUL, along with the current use and anticipated use over the next 5 years of the property, is sufficient to obtain a condition of "no substantial hazard" at the site. In addition, the capping of the roadway should limit migration of rainwater over and/or through the soils, thereby limiting the transport of contaminants to the wetland, and, allowing natural attenuation of contaminants from wetland sediment and surface water. Jacques Whitford is aware that most metals will not attenuate over time, however, the PAHs and EPH concentrations are likely to decrease with time. It is Jacques Whitford's opinion that the decease of these contaminants of concern may allow for the closure of the site in 5 years, either with a Method 3 Risk Characterization and/or excavation of limited amounts of sediment that contain metals. I I 6.0 MANAGEMENT OF REMEDIATION WASTE No remediation waste has been generated at the disposal site. Jianssufs W1hitford@2006 PROJECT No. 1000400 January 2006 5 7.0 REMEDIAL ACTION ALTERNATIVES This section includes Jacques Whitford's identification, evaluation and selection of comprehensive remedial response alternatives. This section was prepared in accordance with the requirements for a Phase Ill, as specified in the MCP. This report provides recommendations for Remedial Action Alternatives (RAAs), which include measures that are expected to reduce the concentrations of oil and/or hazardous material at the site to levels, which will pose no significant risk. The recommended RAAs are expected to represent a Permanent Solution, as defined in the MCP. However, the conclusion of this RAA indicates that a temporary solution is necessary at this time. Potentially applicable soil, groundwater, sediment, and surface water remedial alternatives were selected and subjected to an initial screening process to eliminate those which, upon a cursory examination, were determined to be unsuitable for application on this particular project. Potentially applicable and available remedial technologies were identified and evaluated based upon past remediation experience, a literature review, and the US EPA/US Air Force publication entitled "Remediation Technologies Screening Matrix and Reference Guide," (USEPA Publication No. 542F95002, October, 1994), referred to hereafter as the Screening Matrix Guide. Acceptable RAAs are those alternatives, which are reasonably likely to achieve a permanent or temporary solution, given the nature of contaminants present at the site, the media contaminated and site-specific characteristics. 7.1 Initial Screening Method An Initial Screening Matrix was constructed to aid in the evaluation of the individual remedial alternatives for impacted media and is included as Table 5. Jacques Whitford developed the table based on the EPA Screening Matrix Guide with modifications to fit the needs and intents of the Phase Ill evaluation. All of the alternatives considered in this evaluation are applicable for remediation of petroleum constituents (EPH and PAHs) and inorganics (metals). RAAs are listed in rows beneath the Alternative heading, with the initial screening information summarized in the row beside the alternative name. Factors including overall relative costs, effectiveness, reliability, and timeliness were evaluated on a "Better/Average/Worse" rating system to indicate how the alternatives compare on a relative scale. Some categories were not applicable to certain alternatives. The effectiveness criteria were used to indicate the degree and extent to which the alternative could reasonably be expected to reduce contaminant concentrations at the site. Reliability was used to indicate how well the alternative typically fares in field implementation and the relative difficulty in implementation and operation of the alternative or technology. The timeliness criteria were used to evaluate the relative speed with which the technology could be expected to achieve the desired remedial goals. Benefits and risks related to each alternative, and other comments, are stated briefly in individual columns. The outcome of the initial screening is summarized by the column indicating whether the alternative was accepted for further consideration or rejected on the basis of the initial screening. The final column indicates the basis for rejection of the alternative using the codes shown in the top row of the Matrix. The following is a summary of the initial screening method completed as part of this Phase Ill. 7.1.1 No Additional Action The No Additional Action alternative was rejected since it does not reduce the potential risks to human health, safety, and public welfare, and the environment. Jaquues WhitfWd @2006 PROJECT No. 1000400 January 2006 6 7.1.2 Natural Attenuation Natural attenuation is a reduction in the concentration of contaminants through natural processes including biodegradation, volatilization, dilution, adsorption and chemical reactions with other materials. Natural attenuation is proven to decrease volatile and semi-volatile organic compounds. This makes natural attenuation and monitoring a valid and non-invasive RAA, for the decrease of PAHs and EPH Chainlengths over time. Some monitoring would likely be required to confirm that the concentrations were attenuating and to determine when the desired clean-up level had been reached. Verification of on-going natural attenuation in the soil may require periodic advancement of soil borings and/or the collection of periodic soil vapor samples. This method has proven to be a cost effective medium to longer-term treatment technology. Research and field studies have proven this method to be effective at a variety of sites, and it is anticipated that the biomass that exists in the wetland will supply native microbes to naturally attenuate the remaining PAHs and EPH fractions. Therefore, this alternative was retained in this evaluation. 7.1.3 In-Situ Treatment In-situ treatments such as solidification, pneumatic fracturing, vitrification, soil washing and - chemical reduction/oxidation were reviewed to determine there viability in obtaining a condition of no significant risk. Solidification/Stabilization Solidification/Stabilization is an in-situ soil remediation technology in which contaminants are physically bound or enclosed within a stabilization mass, or chemical reactions are induced between the stabilizing agent and contaminants to reduce mobility. This technology is most applicable to inorganics (i.e. metals) and has limited applicability to PAHs and EPH Chainlengths. Since mobility is not the issue with regard to soil or sediment impacts and since PAH and EPH Chainlengths exist in excess of target remedial levels at this site, this remedial technology was ~ determined to be unacceptable to reach a condition of no significant risk. Pneumatic Fracturing - Pneumatic Fracturing is initiated by the injection of pressurized air into the subsurface to crack or create pathways. These cracks or pathways allow for the use of other remedial alternatives to migrate to the impacted media. This remedial alternative is typically utilized with chemical - reduction/oxidation, soil vapor extraction, soil washing, etc. This remedial technology has the potential to allow contaminant migration via the newly opened pathways, and is limited to certain soil types, such as glacial till, vadose zone clays, tight lucustrine sediments, etc. The use of this technology in and of itself is not viable. In addition, as the groundwater is not believed to have been impacted from this release, the use of fracturing could create a risk to impact the groundwater, therefore, this remedial technology was determined to be unacceptable to reach a condition of no significant risk. Vitrification Vitrification is an in-situ method where extrudes are utilized to heat subsurface soils to a glass or - crystalline structure, thereby not allowing migration. Some limiting factors include use soley in the vadose zone, the controlling of off-gasing and the extreme energy use. As the site soil and sediment does not pose a significant migration issue, and since such technology is extremely - costly, this remedial technology was determined to be unacceptable to reach a condition of no significant risk. JwaqueWhitfM@ 20 06 PROJECT No. 1000400 January2006 7 Soil Washing * Soil Washing is the use of water, typically with a leaching agent, such as a surfactant or chelating agent to help remove organics or metals. Soil washing is extremely effective in sands and gravels where permeability allows significant volumes of washing agent to flow over theimpacted media. As the site is surrounded by and part of which is a wetland, with highly organic rich fine particles, this remedial technology was determined to be unacceptable to reach a condition of no significant - risk. Chemical Reduction/Oxidation - Chemical Reduction/Oxidation chemically converts the hazardous contaminants to non-hazardous compounds. The most common chemical agents are, ozone, hydrogen peroxide, permanganate, activated persulfate, etc. Most of the commonly utilized chemicals require an environment where the current conditions are not extremely reducing, or an extremely high volume of the agent is needed to remediate the contaminant. Since the sediment at the site is present in a highly reducing environment (i.e. anaerobic), this remedial technology would require an extremely high volume of chemical to either further reduce the environment (i.e. make more anaerobic) or change the environment to an aerobic condition to remediate the contaminants, if it was even possible to achieve. Additionally, a highly reactive oxidant or reducer in.a wetland environment is extremely dangerous and would most certainly destroy the existing wetland. As such, it was determined to be an unacceptable remedial technology to reach a condition of no significant risk. Excavation and Treatment - Excavation and treatment is a process where contaminated material is removed and transported to permitted off-site treatment and/or disposal facilities. The media that is transported off-site can be treated in a variety of ways, including thermal treatment, biopiles, and asphalt batch recycling. Excavation and off-site disposal is applicable to a virtually unlimited range of contaminant groups, and the media is replaced with clean fill. The excavated soil may also be treated on-site by bringing in equipment capable of on-site soil recycling or low temperature thermal desorption. - Factors that may limit the applicability and effectiveness of this process at the site include: the generation of vapors from the petroleum constituents in the soils, high risks of exposure to the general public and workers from the exposed contaminated soil, emissions from machine - operations, and contaminants can potentially migrate from soil piles via rainfall runoff to surface water, leachate into ground water or volatilization to the atmosphere. Additionally, a large portion of the impacted media is sediment, which would require drying, prior to transport or treatment, and the destruction of the wetland would be required. While excavation alone is not considered a viable remedial alternative, it may in the future pose an option for the removal of highly impacted sediment. - Activity and Use Limitation (AUL) and/or Method 3 Risk Characterization An AUL is the placement of a restriction on the property deed to limit use of the entire property or a portion of the property. A Method 3 Risk Characterization is the determination of human and environmental risk associated with the specific job site. An AUL is an effective means of limiting property use and risk associated with impacted media at a site, it is cost effective as only documentation is required and together with a Method 3 Risk Characterization, can greatly reduce the levels to which impacted media is required to be remediated, while obtaining a condition of no significant risk. To further reduce risk, an AUL can include the placement of an engineered barrier such as concrete or asphalt. At the site, an AUL was determined to be a viable option for reducing risk posed by the impacted soil beneath the roadway. However, levels within sediment and surface water did not allow for obtaining a condition of no significant risk and an engineered barrier was not a viable option for sediment and surface water. Therefore, an AUL and/or Method 3 Risk - ECharacterization alone could not obtain a condition of no significant risk. Jacues MWird C 2006 PROJECT No. 1000400 January 2006 8 7.1.4 Groundwater Since concentrations in groundwater were below the Method 1 GW-2/3 groundwater standards determined to be applicable, remedial alternatives were not required for this media. 7.1.5 Surface Water As the remediation of site soil and sediment would reduce surface water impacts, it is the opinion of Jacques Whitford that remedial alternatives do not need to be addressed for this media. With the remediation of sediment and soil, the surface water will in turn be remediated. 7.2 Summary of Screening Evaluation Results An evaluation of remedial technologies was conducted to determine which remedial alternative might be feasible to reduce soil, sediment and surface water contaminant concentrations at the site. Based on the concentrations of contaminants present in soil, sediment and surface water at the site, the complete lack of viable remedial alternative for both PAHs, EPH Chainlengths and metals within a wetland environment and the documented successful implementation of natural attenuation with PAHs and EPH Chainlengths at other sites, this method is recommended for use at the site to reduce contaminant concentrations to levels at which they will pose no significant risk. However, this method alone will not remediate the site to a condition of no significant risk, as natural attenuation will not work on metals. Therefore, the placement of an AUL on the roadway will minimize risk to roadway soils, creating a condition of no significant risk from that media, and the placement or an engineered barrier in the form of asphalt cover will reduce migration of rainwater through soils, thereby reducing soil washing into the wetland. In addition, the cleanup, via removal of all dumped material by the neighbor, will likely further reduce impacts to the wetland. It is Jacques Whitford's opinion that a condition of no substantial hazard will exist with the placement of the AUL and completion of applicable risk characterizations. Re-sampling of the wetland sediment and surface water in five years will determine if additional remedial actions, likely in the form of limited excavation of wetland sediments is required. Since these selected technologies are a proven technology for the remediation of petroleum contamination as documented in numerous publications, a detailed evaluation of the technologies is not required, as exempted under 310 CMR 40.0857 (2). However, the screening criteria in the Initial Screening Matrix considers the detailed evaluation criteria specified in 310 CMR 40.0000. 8.0 REMEDIAL ACTION PLAN 8.1 Justification for Selection of Remedial Alternatives The remedial alternative selected for soil/sediment and surface water includes monitored natural attenuation to remediate petroleum contamination from the sediment and surface water at the site to below applicable standards. Jacques Whitford and RSM understands that metals will not naturally attenuate, however, the decrease in PAHs and EPH Chainlengths will either assist in the determination of no significant risk utilizing a Method 3 Risk Characterization and an AUL on the roadway or may require limited excavation of wetland sediment. It is anticipated that the naturally occurring bioculture in the wetlands will assist the natural attenuation process. This selected technology has been demonstrated to successfully remediate petroleum contamination (i.e. select PAHs and EPH Chainlengths) as documented by numerous publications, including those by the A USEPA. It is Jacques Whitford's opinion that this technology is justified. JaCqUS WdhtfWd @2006 PROJECT No. 1000400 January 2006 9 8.2 Permanency/Anticipated Permanency of Selections Based on the reported reductions in petroleum contamination (i.e. select PAHs and EPH __ Chainlengths) using this technology, Jaques Whitford is of the opinion that soil/sediment and thereby surface water concentrations can be effectively reduced to below applicable Method 1 and/or site specific Method 3 Standards and achieve a level of no significant risk. However, to allow for the natural attenuation process to work a temporary solution will be required at this site. 8.3 Feasibility of Restoration to Background The selected RAA has been documented through studies and in literature to reduce concentrations of petroleum hydrocarbons (i.e. select PAHs and EPH Chainlengths) in soil/sediment and thereby surface water at numerous sites. An evaluation of the selected RAA's capacity to reduce concentrations of contaminants present at the site to background, considering site-specific conditions, will be evaluated as part of future response actions. At a minimum, the soils/sediments will be remediated such that hydrocarbon concentrations (i.e. select PAHs and EPH Chainlengths) are reduced to levels, which represent No Significant Risk to public health, safety, welfare, or the environment. This technology is technologically feasible in relation to the costs/benefits. 8.4 Implementation Schedule It is proposed that the implementation of monitored natural attenuation be performed under a five- year plan. The placement of the AUL on the roadway on December 30, 2005, followed by the construction of the engineered barrier within one year, followed by the natural degradation of the petroleum constituents (i.e. select PAHs and EPH Chainlengths) for the next four years. At five years, the site will be reevaluated and likely additional sediment and surface water samples will be collected. Pending the additional sampling, a permanent solution can be obtained if a condition of no significant risk is determined to exist to humans and the environment. If some areas of the wetlands are determined to not allow a condition of no significant risk, some limited areas may require excavation, likely in areas where metals have been detected, as the remedial alternative assumes natural attenuation will remediate the petroleum contaminants (i.e. select PAHs and EPH Chainlengths). 9.0 DISPOSAL SITE DEFINITION AND SITE ACTIVITY AND USE [CURRENT AND FORESEEABLE] The disposal site is located at 44 Forest Street inAttleboro, Massachusetts. As no structures are located on the site, the RSM facility address for mailing purposes is 40 Forest Street, Attleboro, Massachusetts. For the purposes of this RAO, some assumptions were made on the determination of the RAO disposal site boundaries. These assumptions include the following: * While many sediment concentrations did not exceed the background, as determined by the collection of sediment sample SED-21, collected at the discharge from Eddy Street, all sediment concentrations in excess of MADEP Consensus Based Threshold Effect Concentrations (TEC) are being included as part of the disposal site; * Concentrations in soil do not extend beyond the roadway (i.e. source) or wetland, as contaminant migration from the sediments to soil outside the disposal site boundaries are unlikely due to a lack of a migration pathway and the highly absorbent nature of sediments to organic molecules; and Jacque Wutford © 2006 PROJECT No. 1000400 January 2006 10 - . Surface water concentrations are assumed to extent throughout the wetland which they were collected from, either the eastern wetland or western wetland, but do not commingle. The specific disposal site boundaries are comprised of the roadway (measuring approximately 400 feet by 30 feet wide at its widest point, and to a depth of no greater than 7 feet), the eastern wetland (measuring approximately 352 feet long by 200 feet wide) and lastly the western portion of the wetland (measuring approximately 250 feet by 100 feet). These disposal site boundaries were determined based on the assessment of surface water, soil, and sediment, specifically the background sediment sample collected at the outfall from Eddy Street, and on the completion of the Method 3 Stage I Screening, which indicated the risk to the environment exists on the western portion of the roadway. Additionally, the vertical thickness of the roadway (7') was determined from the elevation change from top of roadway to the wetland and assumed the natural elevation was wetland grade. According to RSM personnel, there are no plans to revise the current use of the . property/disposal site. In addition, the Federal Wetland Protection Act and the State of Massachusetts 310 CMR 10.00 prohibits any significant changes of use. Information collected from the Attleboro, Massachusetts USGS Topographical Map indicates that the disposal site is -- approximately located at UTM Coordinates 4646206m N, 3 11694 m E. Figure 2 illustrates the RAO disposal site boundaries and other pertinent site features. - 9.1 Soil and Groundwater Characterization Site soil can be categorized based on accessibility, and on the frequency and intensity of use for children and adults. Impacted soil at the site (roadway) is classified as accessible soil (i.e., 0 to 3' unpaved). Since the disposal site is owned by and abuts an industrial facility and on the difficult accessibility isssues (i.e. - heavy wetland vegetation and fencing), adults only are likely to be present within the general vicinity of the disposal site. Adults may be present at the site at a high frequency * (employees, visitors, and/or trespassers), and at a low intensity (activities which do not have the potential to disturb the soil). Thus, site soil is categorized as S-2. Site groundwater is categorized based on the criteria established at 310 CMR 40.0932. Based on a review of Attleboro records, the Massachusetts Geographic Information System data map, and site reconnaissance; -- The disposal site is not subject to GW-1 standards since it is not located in, or in close proximity to, an area defined as a Current or Potential Drinking Water Source Area; * Since the average annual depth to groundwater at the site may be 15 feet or less, the disposal site is subject to GW-2 standards, since portions of the site are located within 30 feet of an existing occupied building or structure and, therefore, is a potential source of vapors to indoor air; and, 0 As is the case for all disposal sites, groundwater at the disposal site is a potential source of discharge to surface water bodies and, therefore, is subject to GW-3 standards. - 9.2 Contaminants of Concern As part of the RAO and previously completed Phase i, contaminants of concern (COC's) were identified. All chemicals detected at a site are considered contaminants of concern, unless there is a specific, justifiable rationale for not including the contaminant in the site evaluation. Compounds were eliminated from the list of study compounds if they were: 1) detected at concentrations at or below background concentrations identified by DEP or by site-specific data; 2) potential laboratory contaminants; or 3) detected infrequently at low concentrations with respect to the detection limit, and not associated with former or current site activities. Jacques Wtfoni © 2006 PROJECT No. 1000400 January 2006 11 Based on MADEP's publications "Policy for the Investigation, Assessment, and Remediation of Petroleum Releases, Interim Site Investigation Protocol Document," DEP Publication # WSC-401 - 91 (MADEP, 1991 a) and "Characterizing Risks Posed by Petroleum Contaminated Sites: Implementation of MADEP VPH/EPH Approach," Final Policy, October 31, 2002, and on the analytes detected as part of this investigation, COCs with respect to site soil, sediment, surface water and groundwater conditions include: " EPH carbon fractional ranges: all EPH fractional ranges CO-Ce aliphatics, Ci-C aliphatics, C11-C22 aromatics were detected and are listed as target parameters under the MADEP VPH/EPH policy for cutting oils. As no PID readings were detected and no visual or olfactory indications of oils were noted during Jacques Whitford's investigation, VHP and other volatile organic compounds (VOC) were determined to not be necessary analyses; * PAHs: PAHs are listed as target analytes under the MADEP VPH/EPH policy for cutting oils, * Metals: As the roadway is made up of metal shavings and soil, it was deemed necessary to analyze for RCRA 8 Metals; and, * PCBs: As a roadway sample had concentrations of PCBs detected, it was Jacques Whitford's opinion that PCBs should be tested for in soil and sediment samples. Soil: Based on the March 7, 2002 and June 14, 2005 sampling events, some target parameters remain above applicable Method 1 S-2 soil standards. Concentrations of arsenic and PCBs were detected above Method 1 S-2 Soil Standards. As a conservative approach, all detected compounds that do not have refutable recent analytical data, or are shown to not be present as a result of RTN 4- 16211 are being considered potential COCs. In addition, as the roadway is known to have been constructed utilizing scrap metal mixed with soil, Jacques Whitford has made the conservative assumption that all soil beneath the roadway (i.e. part of the AUL area) is at these elevated concentrations. Therefore, the entire area located beneath the roadway to a depth of approximately 7 feet below roadway grade are considered as exposure point concentrations (EPC). The thickness of the roadway was based on a survey completed as part of the AUL, and indicates an arbitrary elevation of 100 feet at the top of the road and an elevation of approximately 93 feet down the embankment at the start of the wetland. Refer to Table 1, Soil Analytical Results, for detected contaminants of concern, or Table 6, Exposure Point Concentrations. Soil background concentrations for target parameters associated with RTN 4-16211 were assumed to be less than the analytical detection limits, as presented in the laboratory reports. Groundwater: Based on the March 28, 2002 and June 14, 2005 sampling events, only barium exists in groundwater at concentrations well below applicable Method 1 GW-2 and GW-3 Standards. Therefore, only barium in well SHU-1 S and KE-1 is considered as an EPC, and only barium is considered as a COC in groundwater. Refer to Table 2, Groundwater Sample Results, for detected contaminants of concern, or Table 6, Exposure Point Concentrations. Groundwater background concentrations for target parameters associated with RTN 4-16211 were assumed to be less than the analytical detection limits, as presented in the laboratory reports. Sediment/Surface Water: Based on the sediment samples collected on March 7, 2002, June 13, 2005 and July 7, 2005, from areas within the wetland and from along the sides of the roadway, remaining EPH chain lengths, PAHs, Metals, and PCBs are present at the site. Based on the surface water samples collected on March 28, 2002 and June 13, 2005, from areas within the wetland, concentrations of metals remain within surface water at the site. To determine if the sediment and surface water concentrations that exist at the site are a threat to the environment a Method 3 Stage 1 Environmental Screening was conducted for the site. The Method 3 Stage I Screening concluded that for aquatic receptors in the wetlands, there are complete exposure pathways associated with the oil and/or hazardous material from the site (along the west side of the roadway) and attributed to local conditions (adjacent to former auto body shop / limousine and JaqUSSW hf @ ©2006 PROJECT No. 1000400 January 2006 12 discharge from Eddy Street). These potential exposures may represent readily apparent harm for surface water and potentially significant exposures for surface water and sediment. Therefore, a condition of no significant risk to the environment does not exist. .However, based on the criteria outlined in the MCP 310 CMR 40.0956, a condition of No Substantial Hazard exists for the site. A copy of the Method 3 Stage I Environmental Screening is included in Appendix D. To determine ifsediment and surface water posed a substantial hazard to human health, a Substantial Hazard Evaluation was conducted. The cumulative HI for noncancer risks for sediment and surface water exposure is 0.8. The cumulative ELCR for cancer risks for sediment and surface water exposure is I E-06. These cumulative risks are less than the cumulative receptors risk limits specified in 310 CMR 40.0993(6) for a Substantial Hazard Evaluation of an HI of 1 and an ELCR of 1 E-05. Therefore, a condition of No Substantial Hazard exists for human health exposure to sediments and surface water in the wetlands surrounding the site's access road. A copy of the Substantial Hazard Evaluation for Human Health Exposure to Sediments and Surface Water is included in Appendix E. - 9.3 Exposure Point Concentration Pursuant to Section 310 CMR 40.0924 - 40.0926, an evaluation of the contaminant conditions was conducted to define potential exposure points, exposure pathways, and EPCs. In addition, the potential for the existence of critical exposure pathways (CEPs) was evaluated. Exposure pathways are defined, without limitation, as ingestion, inhalation, and/or dermal absorption of impacted media. CEPs are defined as those routes by which oil and/or hazardous material(s) released at the disposal site are transported, or are likely to be transported, to human receptors via vapor phase emissions into a living or work space of a pre-school, daycare, school, or occupied residential dwelling; or ingestion, dermal absorption or inhalation of measurable concentrations of oil and/or hazardous materials from - adrinking water supply wells located at and servicing a pre-school, daycare, school, or occupied residential dwelling. Based on the site conditions, there were contaminants of concern detected in excess of applicable standards, consensus based TEC, and Lowest Ecologically Based Criteria (LEBC). Refer to the Method 3 Stage I Environmental Risk Characterization provided in Appendix D, and Substantial Hazard Evaluation for Human Health Exposure to Sediments and Surface Water provided in Appendix E. Based on the current and future nature of the defined disposal site and the placement of the AUL, the only potential routes of exposure would relate to activities that would disturb sediment and surface water in the wetland. Since soil is being capped and an AUL placed, exposure to soil will be - limited by the deed restriction and by the use of a soil management plan and health and safety plan when and if any activities will be conducted that will disturb soil beneath the roadway. Otherwise, a direct route of exposure is not present towards residents, employees, and/or trespassers. No schools are located in the immediate area, however, residentially zoned properties are located in the vicinity of the site. It should also be noted that the roadway does not contain any utilities, therefore, no emergency situations would warrant immediate access to soils within the AUL area. - Soil: The exposure point for soils is defined as the horizontal and vertical distribution of the contaminant in soil, in combination with the soil category determined to be applicable. As a conservative estimate, the highest concentrations detected in soil beneath the roadway are being considered the EPCs. As an AUL has been filed for the roadway, Jacques Whitford has made the assumption that all soils beneath the roadway are at the highest detected concentration. Based on the placement of the AUL and the current and anticipated future (5 years) use, it is Jacques Whitford's opinion that CEPs do not exit with relation to soil. Refer to Table 6, Exposure Point Concentrations, for EPCs in soil. JacqUSM Whfid @ 2006 PROJECT No. 1000400 January 2006 13 Jacques Whitford did not utilize any of the data collected by Aquatronics, Inc. for the completion of the risk characterization and determination of EPCs or CEPs due to the following: 1) elevated PAH detection limits; 2) collection by other parties; 3) suspect nature of the collection techniques; and, 4) lack of faith in sample results due to incorrect labeling. However, the results are presented on the soil and sediment tables (Table 1 and 3). Groundwater: The exposure point for groundwater is defined as the horizontal and vertical distribution of the contaminant in groundwater, in combination with the groundwater category(ies) determined to be applicable. As a conservative estimate, the highest concentrations detected in groundwater from each well will be considered as EPCs. Therefore, the concentration of barium from wells KE-1, KE-2 and SHU-2s, at 12.2, 700, and 600 mg/I, respectively, will be considered exposure points. As all concentrations are below applicable Method 1 GW-2/GW-3 Groundwater Standards, the highest concentration, indicative of worst case is presented in Table 6, Exposure Point Concentrations. As - concentrations are all below applicable standards, it is Jacques Whitford's opinion that no CEPs exist with regard to groundwater at the site. Sediment/Surface Water: The exposure points for sediments and surface water are defined as the horizontal and vertical distribution of the contaminants, in combination with the TECs and lowest ecological based criteria (LEBCs) determined to be applicable. Based on the Method 3 Stage I Environmental Screening there is potential CEPs from sediment and surface water to the environment. - Sediment and surface water concentrations need to be readdressed in future sampling events. Greater detail on sediment and surface water EPCs and CEPs are discussed in the Method 3 Stage I Environmental Screening. The Method 3 Stage 1 Environmental Screening concluded that No -- Substantial Hazard exists at the site towards environmental media. A copy of the Method 3 Stage I Environmental Screening is included in Appendix D. Based on a Substantial Hazard Evaluation for Human Health Exposures to sediment and surface water, the cumulative HI for noncancer risks for sediment and surface water exposure is 0.8. The cumulative ELCR for cancer risks for sediment and surface water exposure is 1E-06. These cumulative risks are less than the cumulative receptors risk limits specified in 310 CMR 40.0993(6) - for a Substantial Hazard Evaluation of an HI of 1 and an ELCR of 1E-05. Therefore, a condition of No Substantial Hazard exists for human health exposure to sediments and surface water in the wetlands surrounding the site's access road. Refer to the Substantial Hazard Evaluation for Human - Health Exposures to sediment and surface included in Appendix E. 10.0 METHOD 1 RISK CHARACTERIZATION - SOIL & GROUNDWATER Pursuant to 310 CMR 40.0970 through 40.0979, if oil or hazardous material at the disposal site is - limited to soil and/or groundwater, then a Method 1 Risk Characterization may be used. In addition, Guidance For Disposal Site Risk Characterization, Interim Final Policy #WSC/ORS-95-141, a Method 1 and Method 3 Risk Characterization may be utilized when the contamination is not limited to soil and - groundwater. In this case, a Method 1 Risk Characterization will be utilized to demonstrate that contaminants of concern within soil and groundwater at the site do not pose a risk to health, public welfare, and the environment. A Method 3 Stage I Environmental Screening was utilized to determine risk from sediment and surface water to the environment (Appendix D), and a Substantial Hazard Evaluation for Human Health Exposure was utilized to determine risk from sediment and surface water to human health (Appendix E). - As noted, contaminants of concern were identified in site soil and groundwater. Refer to Table 6 for concentrations. Method 1 is appropriate and was selected since allowable limits for the remaining contaminants of concern have been predetermined by the MADEP and listed at 310 CMR -- 40.975(6)(a). According to 310 CMR 40.0973(7), a condition of No Significant Risk of harm to Jacueas Wiford @2006 PROJECT No. 1000400 January 2006 14 health, safety, public welfare and the environment exists if no exposure point concentration is greater than the applicable category standard identified at 310 CMR 40.0974 and/or 40.0975. As * indicated in the exposure point information previously presented, remaining levels of the - groundwater contaminants of concern are not greater than the "GW-2 and GW-3 Groundwater' Standards. Concentrations of soil exceed applicable "S-2 Soil" Standards but are below the UCLs as outlined at 310 CMR 40.0996(7). Based on the remaining concentrations in soil a condition of _ "no significant risk" can not be obtained, however, with the placement of an AUL, a condition of no substantial hazard is achieved, thereby, allowing the temporary closure of the site. - 10.1 Feasibility Assessment - Soil The feasibility of further reducing the remaining contaminants of concern in soil to non-detectable levels can be dependent upon both a technological evaluation, and a cost-benefit analysis. According to 310 CMR 40.0860(5)(a), if existing technology or reasonable modifications of technology cannot remediate the disposal site to the extent necessary to attain levels that approach or achieve background, the remedial action shall not be considered technologically feasible. -- According to 310 CMR 40.0860(4)(b) and (6)(a), if the incremental cost of conducting the remedial action is substantial and disproportionate to the incremental benefit of risk reduction, environmental restoration, and monetary and non-pecuniary values, then the benefits of implementing the - remedial action to achieve a Permanent Solution and to reduce the concentrations of the constituents in question in the environment at the disposal site to levels which achieve or approach background are not considered feasible. As part of the AUL, Jacques Whitford has included capping the roadway with asphalt to mitigate migration of rainwater through the impacted soil to minimize contaminant migration. The placement of asphalt on the roadway would have minimal effect on the neighboring wetland, and in Jacques - Whitford's opinion is the most feasible alternative to minimize exposure to site soil. With respect to the levels in soil, in order to attempt to approach or achieve background concentrations (assuming that background concentrations are analogous to non-detectable concentrations) the roadway through the wetland would have to be removed. In this particular case, however, the disposal site is situated within the wetland. The removal or remediation of soil is restricted by the wetland and would present logistical difficulties, and be impossible to carry out - without destroying a large area of the wetland. Any remedial action (excavation, chemical or biological treatment) would adversely affect the wetland, by destroying the native floura and fauna. Currently the wetland appears healthy with no adverse signs of impact from the roadway. Aside from the technological aspects, financial costs would have been associated with conducting remedial actions at the site. These costs would have been incurred through obtaining wetland permits, the excavation of the roadway soil, the transport and disposal of soil, the re-sampling and - re-testing of the area, the restoration of the wetland to its previous condition, the purchase and placement of chemical or biological additives, the continued monitoring of the wetland as required by the wetland regulations following the rebuilding of a wetland. Since the identified levels can be mitigated with the placement of an AUL, and since the wetland is currently healthy and future use is anticipated to remain the same (i.e. a wetland) and as it is supported by current wetland regulations, potential risk reduction does not justify the technological effort or financial costs of remediation at this time. 10.2 Risk to Safety Evaluation Risk of harm to safety was characterized in accordance with 310 CMR 40.0960. In the opinion of Jacques Whitford, based on current and potential future site use, conditions at this disposal site do not pose a threat of physical harm or bodily injury to humans. Therefore, a condition of no JacqueSWItfor"d@2 0 0 6 PROJECT No. 1000400 January2006 15 significant risk of harm to safety exists at the site with respect to the potential source(s) of soil and groundwater contamination, with respect to RTN 4-16211. 11.0 CLASS C RESPONSE ACTION OUTCOME STATEMENT Pursuant to 310 CMR 40.1050, a Class C Response Action Outcome (RAO) can be utilized at sites where a Temporary Solution has been achieved and after the submittal of the Phase II and Phase IlIl reports. The criteria in support of the Class C RAO are summarized below. 1. The source of contamination, which is likely to result in an increase in the concentration of the contamination in an environmental medium, has been eliminated or controlled, with respect to the release relating to RTN 4-16211. In this case, an AUL will minimize exposure to roadway soils and the placement of an engineered barrier in the form of an asphalt cap will minimize migration of contaminants from the roadway soils. It should be clear that the placement of the asphalt cap is not necessary to obtain a condition of no substantial hazards but is necessary to assist in the natural attenuation of petroleum contaminants (i.e. select PAHs and EPH Chainlengths) in soil, sediment and thereby surface water. The concentrations of soil from the roadway currently exceed applicable Method 1 Soil Standards, while none of the concentrations exceed the Upper Concentration Limits. The placement of an AUL creates a condition of no substantial hazard from roadway soils to human health and the environment. Based on sediment and surface water sampling and the completion of a Method 3 Stage I Environmental Screening, concentrations in sediment and surface water pose a risk to the environment, but not a substantial hazard. In addition, a substantial hazard evaluation was completed to determine risk to human health from sediment and surface water concentrations. The results indicated that no substantial hazard exists from the concentrations of sediment and surface to human health. 2. An evaluation of the site conditions was conducted to evaluate a Condition of No Substantial Hazard. Substantial Hazard, as defined in the MCP, means a hazard, which would pose a significant risk of harm to health, safety, public welfare, or the environment if present for several years. In the opinion of Jacques Whitford and taking into account the Method 3 Stage I Environmental Screening, the Substantial Hazard Evaluation to Human Health from Sediment and Surface Water and the Method 1 Risk Characterization, there are no hazards at the site that would pose a Substantial Hazard. This is justified by the opinions presented in the following paragraphs; As part of the Method 3 Stage I Environmental Screening, Substantial Hazard Evaluation to Human Health from Sediment and Surface Water and Method 1 Risk Characterization, potential exposure point pathways, were evaluated. Based on the current nature of the property/Disposal Site, the only potential routes of exposure would relate to maintenance work on the roadway portion of the RAO disposal site boundary, at a depth of just below the roadway surface to an estimated depth of approximately 7 feet. Exposure to human health from wetland sediment and surface water were also evaluated and no exposure currently exists that would cause a substantial hazard. Therefore, a direct route of exposure that would cause a substantial hazard is not present towards employees, visitors, and/or trespassers. There is potential for exposure to aquatic wildlife and vegetation; however, no stressed vegetation, no sheens or non-aqueous phase liquids (relating to RTN 4- 16211) and no observations (i.e. noticeable fish, amphibian, etc. kills) of dead aquatic organisms has been observed in the area of the disposal site. Therefore, even though potential exposures exist, no current exposures have been identified. Jaees Widtford @C2006 PROJECT No. 1000400 January 2006 16 The completion of the Method 3 Stage I Environmental Screening concluded that for aquatic and terrestrial receptors and for complete exposure pathways, potential exposures may cause "readily apparent harm" and may represent "potentially significant exposures". These exposures are the main reason for a temporary and not permanent site closure, since the AUL removes exposure to roadway soils. 3. The remedial alternative selected in the Phase Ill for soil, sediment, and surface water was monitored natural attenuation, placement of an AUL, and future re-assessment and possible excavation of sediment in areas of high metals concentration, to remediate petroleum contamination and metals at the site to below applicable standards and/or benchmarks, and to reduce exposure (i.e. AUL), therefore achieving a level of No Significant Risk, as defined in the MCP. It is anticipated that the naturally occurring bioculture in the wetlands will assist the natural attenuation process of PAHs and EPH Chainlengths. This selected technology has been demonstrated to successfully remediate petroleum contamination (i.e. PAHs and EPH Chainlengths) as documented by numerous publications, including those by the USEPA. The Natural Attenuation Remedial Alternative was also determined to be technologically feasible in rglation to the costs/benefits. This chosen Remedial Alternative currently provides for a Temporary Solution, and it is anticipated that in time, will provide a Permanent Solution. 12.0 PERIODIC EVALUATION AND MONITORING PLAN - As concentrations were detected in sediment and surface water and since an AUL and engineered barrier will be placed at the site, it is the opinion of Jacques Whitford that continued minimal monitoring, in the form of surface water sampling in the areas previously determined to be impacted - a is required to maintain a condition of "no significant risk". Therefore, Jacques Whitford will sample three surface water locations (SW-1, SW-4 and SW-5) for Metals, PAHs and EPH Chainlengths, at the third year (March 2008), and fourth year (March 2009). - This data will be provided in the Periodic Evaluation at the fifth year (December 2010). In addition, select sediment samples will also be collected at the fifth year to determined existing PAH, EPH Chainlengths and Metals concentrations, to determine if a permanent solution can be achieved. -- Pending the data evaluation, and in accordance with the Phase Ill, select sediment areas may be excavation, to reduce risk and achieve a permanent solution. However, this excavation will not be completed until December 2010, following the evaluation of the data collected. A schedule for future assessment or excavation will be presented within the Periodic Evaluation. 13.0 FINDINGS Pursuant to 310 CMR 40.1036, it is the opinion of Jacques Whitford that a Class C RAO applies to Disposal Site because: e A Phase il Comprehensive Site Assessment has been completed; 0 A Phase IlI Remedial Action Plan has been completed; - * Substantial Hazards at the site do not currently exist and/or have been controlled; and . A Temporary Solution has been achieved Jacqua Wtftrd@200 6 PROJECT No. 1000400 January 2006 17 Appendix G provides copies of the public notification letter. Additionally, the RAO area is depicted in Figure 2. Jacques Whitford has completed this Class C RAO Statement Report, Phase II and Phase il on the site located at 44 Forest Street in Attleboro, MA for RTN 4-16211. It is Jacques Whitford's opinion that at this time, a Temporary Solution has been achieved and that the site does not pose a substantial hazard to public safety, human health welfare, or the environment. 14.0 CERTIFICATION Jacques Whitford Company, Inc. and its LSP of Record express no guarantee or warrantee regarding the opinion of the LSP of Record. Jacques Whitford Company, Inc., its parent, and its LSP of Record for the project are not liable for the opinion rendered by the Jacques Whitford LSP of Record or for the actions that result in or follow from opinion of the Jacques Whitford LSP. It is hereby affirmed that the assessment described herein has been conducted in accordance with relevant and referenced environmental regulations, prudent and generally accepted environmental engineering practices, and applicable professional standards of care were followed, and that the reference information, data, and attached documents are true, accurate and complete to the best of Jacques Whiff ord's knowledge. All conclusions and recommendations provided herein are based solely on the scope of work conducted and the availability of information at this time. Any additional information, which becomes available concerning the Disposal Site or the abutting properties, should be provided to Jacques Whitford so that the conclusions and recommendations may be modified accordingly. JaCqMes @hffd©2006 PROJECT No. 1000400 January 2006 18 TABLES Jacques Whitford @2006 PROJECT No. 1000400 January 2006 APPENDIX C- 0 0 0 a 0 0 O.0 - I- 88-N 88888O88 N 1000 m IN00U" 8N do8 So o (9 888 888 CNN N N a00 00080000 C) 0 000 0 820 6 0 oo coo 0m 0 C.(9C.C N 10 N IN, 000N (0 N 0000 N C)0 0 0 00 0 o0o; 0 -s .) m (9 080 C') 000 0 0) 0 N 0n0 oOOOOOOOONOONOOOOo a8 0 0 40 r.-NiC OOI N 00 N OOOO 0 0009 0 0 0 a00 co V V V VV V V VV VV VV V VV V 0 U0 0 ------0 V VVV VV VVVVVVv VVV C - II- ~Iz Iz dc6 66&6c6 ;66 ci C56 i - IZ- !i-I-I-f - *l0 73 I~~g4 N N NNN9 N N N N N C- 0)0v)-)v0It )0It 0ItIt0v 0 v70q0) ) mC.N) m t . 6tf 6 666 V6 7 vv VWF???5!6d66ootvvoo U) c W to0 ) *0 M0 PM 00 ii *0 U') N in I N I-- 0 N aD -04 V v c; 0 0 ; C) 0) 1 a) 0) 00 0 0 0 N v)0V V) ) 0) 0) 0) 0) 0)0 0) V)) to z ao V 0 A i ~0 z V) ) N iiIi INP P- NNN-NN N N N NN N N MNDC o m m o azf t; mlas k;0 a or ra S -S E E esc-- 'cc CDme c 2 . I , idI = O0 Z, Em z Ll Orr Cncfll00al JC 000 Uk mffmmoa r s sozar2 M ,- earl -Yam-I Eel (n 0 0 P oooooo0000 0000 0 0 0 0 0 000 30 00000000000 00 0 0 0 coO 0 -0 8-04O Ce8O & (1) IN C"l w'C C 0c0 ni 0 0c cu 0 0een0 CCl 00U)oo L6 C6 C C6 R C6 C < . C C oC C6C 40zo 0 '4 c ) SS O q ;Oq oo66oooo6o66ooo6o6o6o vo o d66r gv Sv v v v v CN cc lJ Se zzz zzzzzzzzzzzzzzzzzv v v v v v v v v v v v v v v v v v vVrV0V'VN 0 .i4'U - a 000 N mN N 000v v v N N NN N N N C4 IU)0 ovV0 v (Do VV V v v E6 I I- v v v 0, COO C CM C Nl C M C CMCM N CMlC-4 N NCM CM CM 04C LO ~ 0 )Lf Q:> L 0 60666666666666666 vU) 0 5 UOv) CM V VV V V VV VVV VV V V CD v% V v 000 oNN .. Q a z , CD >,) 0 ) a) -c -,O - C4 C a,3 c a 1 .c ao WCUo a 000 W4,- -- ,c S aSm co~-6w 6-6 co E 0 (D 0 a) E E ~co = 0) 2 a a mdcc mfal 0) 0 LLL -3. Cd- C 0 a d) CL a e 'Cd, 3 H o5 a, - I- Cc cd C moo z § s8 C.C.,8§ 6 1 6 2 2zr f mom z f V f z N N v Nvi NNNN * 2 N -is F- C' IR 0 2 dC NOW0 6 0 NWi ~* 2 1 N ~; I 7 T 7 Ii'-' I11111pill.11 I jl I i-I ~ I liii' I 'I'D II11141 11 A ahl , ~-'------'liii I I a I~. U - S .3 tI C, 't~t - S Ii U it I ii it a, Ii ~iicu-n. x -- - 0 Loo m < m -- a = e e 0 e e E2 *1 0 o 20 e - o o ..o Q 0 0 0 0 0 0 * o0 0) o0 0 0 0 0 - Co a a5 o a ~2 2 p E 0 0 0 o 0 0 0 0 a . E = 2 2 C= 2 2x 2 MA 3 a CF 's (t 0 Lu c LLw 0 a3 1 ~a ~ ~ 6 :coi~ e l4 C p IS C.! 0 0 t - 8 . C C4 Zz Z Z Z Z ~c~~Z S N 8m 88§88 N es C4 N N N ; rNNc N (14N (rN N N* ( 'to N a C'2 N CL 040 wDOW 00000oo0 zzzzzzzzzzzzzzzzzSa r- 8 - Oit8l-88 g 2 0.OxI aZI aZZ.Z0 0 S. c o N U.8 E 6. oD 00,0 000 C ef Ei .08 ~ (N 2 W.,n a ii I " m jmlii rn0 M U 0 aiw CL)0 Jacques Whitford @ 2006 PROJECT No. 1000400 January 2006 APPENDIX SOURCE: USGS TOPOGRAPHIC MAP 1981 Jacques Whitford Company, Inc. n E QA mu SITE LOCATION MAP ''ATTLEOR4 QUAD FOREST STREET ATTLEBORO, MA LEBCrYcUSETT 004 e L SHUSTER METALS,INC. 6 Ch L ja IZ7 ese C')) 0 APPENDIX C Administrative Consent Order WESTERN MASS ENVIRONMENTAL@ 2008, Project 1484 APPENDIX AUG-28-2009 11:01 From:CRANE 979440e700 To: 14137872646 P. 2/8 ARTMENT OF tNVLtfLUrSMJz A SOuT HEABT REGIONAL OFFICE 20 RI VERSIDE DRIVE, LAKEVILLE, MA 02347 508-946-2700 DEVAL L. VATRTCK AN A. BOWLW Govemor Secretary TIM OyrY P. MURRAY LAUEIE BURT .Autennt Govrnor Commiraur May 1,2008 Ralph Shuster Metals Inc, RE' ATrLEBOROBWSC/AP David Malkin, President 909 *th Main S 40 Fei-SEt Providence, Rhode I land 02904 RTN 4-16211 AMENMNT OF ADM ITRATIV COMEM ORDERWITHPENALT ACor-SE-074A-005.. Amend #1 Dear Mr. Malkin: The Dcp t of tnvironmental Protection, Bureau of Waste Site Cleaup (the Department), has cncloed two ( ) copies of the Anndmnt of Administradve Consent Order with Penalty (the Consent Order) for the above reftrenocd disposal site. The Depatment requess that both copies of the Consent be slgnbd and retumed to the Department by HU 15. 200. The Consent Orders should be sent tol letterheada ddress and directed to the attention ofKathryn Carvalho. The May 1 , 2008 dkM'is an Interim Deadline pursuant tW 310 CMR 40.0167 and has been cstablished by the fbr the turuination of settlemnat discusfins regarding this matter. The Depanment's decii to establ ish one or ore Interim Deadlines in accardance with 310 CMR 400167 is not subject to M. .L c.30A arany othe law governing adjudicatory proceedings. In the event that the C0 nscnt Order ianot apopriatcly signed mid rettrned to the-Department by the May 1S, ~2008" ldno, 'th4 Departrment reserves the right to keenie the fill extent of its legal authority to obtain 11 compfar nce with al applionble roquirements ineludlrg. but not limited to, criminal prosecution, civil abtion Inolu ding court-iposed civil penalties, and Civil Administative Pnaltics issued by the Departient. Prompt re ution of ti ds matter isbeneficial to both you and the Department and is consistent with the Depmnns environu Inaland mforemnat oals, and limt. resources which would otheawise be expended on o litigation of the issues. The Department suggests that you review its Enforermnt Response Guidance ("ERG") I br additioial information regarding potential enforcement actiont which you rmybo subject if thOCo anuet Order ti not signed and rturned be the above tefutenced date. The Deparunent's regd tione and guidance document an available on the Department's wcb site at www-malssuv/ep. ml.Wnn..n.Robnefm7. u.ie... ..hb.....at fr...cal b.st M.OAA Comw..u.twa 5us.'4S7.'rOn ors on wwnoWn wsW: har*wwwmanagasp 1 * Psad aniaa d Pupur s I AUG-28-2008 11:01 From:CRANE 9794409700 To:14137872646 P.3/9 Sent By: DM Realty, Inc; 401 633 6039; Mey.9-0^ 10:56AM; Pe 2 Attleboro-14WSC/AP N.4-162i1 ACP # ACOP4ESO A-005 - ArmAd #1 Page 2 If you have any ustions regsrding this Ietr or the Consent Order, please contact Kathryn Crvtho at (508) 946-2742. All future communication regarding this matter must refcrecc Releas TrAcking Number (RTN): 4-1 II. Sincaely, A 'Ygra M/KC/rr zon %r UM62I t om born dt. Onfl~U~zv NI2Iqa,~s CERTSFIED MAIL# 7006 3450 0002 '414 2446 ec: DEP-SERO ATflJ: Re Tobin, Regional Conel D Enatry, LAra McLaughifm- C&E mrrrr 1o Ie AUG-28-2008 11:01 From:CRANE 978448700 To:14137872646 P. 4/8 sent By: DOM Realty, Inc; 401 633 6039; My--CP 10:56AM; Page 8 COMMONWEALTH OF MASSACHUSETTS E CUTIVE OFFICE OF ENViRONMENTAL AFFAIRS DE ARTMENT OF ENV[RONMENTAL PROTECTION In the matter of: ) Ralph Shuster Metal4, Inc. ) 909 Nonh Main Stret ) Providence, Rhode l4and 02904 ) File No.: ACOP-SE-07.3A-005 - Amend #1 FErN# 0414148 AMENDMF4 OF ADMINISTRATIVE CONSENT ORDER WITH PENALTY The Department of Environmental Protection ("Depanet" or "MassDEP") and the Respondent agree tn amend and theCfelowing changes Into the AdiIelative Consent Order with Penalty ACOP-SE-073A-005, 1. Spction Il paragraph 8, subpart C, that originally stated V. Respokdent shall perform the following actions: A) If additional asessment performed at the Site indicates that conditions netessary to support an RAO have been achieved, then the Respondent shall sut mit the rollowing documentation to MasaDEP by Jbne 12008: 1) A revised RAO. The RAO shall be prepared in full accordance with all requirements listed in 310 CMR 40,1000 and shall contain, at a minimunm, itrevised risk characterization that incorporates both historic and current data collected (tom the site, taking into consideration the additional assessment data collected within the access road to document the concentrations of contamlnants present in the soils and more adie el to define the disposal site boundaries, a) Ir'the revised RAO relics on Lbe implementation of an At T., then a registry crftied Q py of .a,At Amendmnn, prepartd in full accordance wIth 310 CMR 40.1081, shall also be submitted to MaasDEP. The AUL Amendment shall not intlude reference to baMers not yet in place at the time the AUL is tuoorded and shplt correctly state whethcr the AUL isnecessary to maintain a condition of NSR or NSH b) However, if the revised RAO does not rely on the Implemeontation of an ALTL then a Registry crtified copy of the AUL termination, prepared in full accordance with 310 CMR 40,1083(t)(a), shall also be submitted to MasSDEP; and, RUG-28-20 0 9 11:01 From:CRANE 9784408700q P. Sent By: DSM Realty, no; 401 033 6039; May-qP tQ;S7AUP 4 In the MnoRrof, Rph Sht4r Meals, Attebor Msachuea ACO P Amendment # AM~ -SE4N.3A-005-Amend # 1 Page 2 2) The above referenced revised documents shall be prepared In fUll accordance with the provisions of the MCP and be accompanied by a Post-Audit Completion Statement. Transmittal Form BWSC-l I I B) IN t0 event that the Respondent submits to MasaDEP the revised documents discissed above by Jn is 20083 then the Respondent need not continue with the i Dsponw actions set forth below. C) Nov ver, if additonal assessment performed at the Site indicates that con4itions necessary to, support an RAO have not been achieved, then the Regondent shall submit the following documentation to MossDEP by JmL -i) A statement of retraction for the Class C RAO Statement received by the Departnent on January 11, 2006; A .T* 1 Extemion Submittal prepard! Nil accordance with the provisions of 310 CMR 40.0560(7) and adnuilly thereafter umil a time at which a Response Action Outcome Statement, prepared In full accordance with 310 MR.40, 1000, is submitted for the site; 3) A Phase 1 Sc6pa of Work, prepared in full accordance with the provision of 310 CMR 40.0834(2); '4) A registry certified copy of the AUL termination, prepared in full accordane with 310 CMR 40.1083(1)(e); and 5) A Post Audit Completion Statement, Transmittal Form BWSC-1 II. D) By A4ggan 4..2M, Respondent shall submit to Mas]DEP a Supplemental Ph se IUComprehensive Site Assessment Report (a Phase 11 Report) including a Ask charecterizaton for the Site, prepared in fUll accordance with the visions of 310 CMR 40.0830 and 310 CMR 40.0900, respectively. If the P Report indicates that more Comprehnsive Response Actions are needed to achieve a Response Action Outcome C'RAO' at the Site, the pondent shall also submit to the MassDE? a Phase III Remedial Action PI ("Phase 111"), prtparcd in full accordance with the provisions of 310 C 40.00. The Phase 111 Report shall evaluate the feasibility of reaching a Permanet. Solution, as defined by dhe MCP, for the Sits. E) By Eqankgogg g2Oif the Phase III Report. referenced in paragraph 8,D. above, demonstrates that the .meets the requirements for a Class C RAO, the Respondent shall submit tois MasPDP a Claus C RAO, pursuant to the provisions of 310 CMR 40.1050 and 310 CMR 40.1056. If the Phase III R port referenced In paragraph S.D. above indicates that it is feasible to reach a Permanent Solution at tho Site, then by Anszusi 29 the Respondent a 1i submit to the MasaDEP a Phase TV Remedy Implementation Plan (' base 1V"r), preped in full accordance with the provisions of 310 CMR 40.0t70. F) or befo Agstl 1. 2010, if a Phase IV Report, referenced in paragraph SIE. above, has been submitted to MasiDEP by August 1, 2009. the RUG- 20-200 11:01 From:CRRNE 9784408700 To: 14137872646 P. 6/9 10:57AM; Page 5/e 401 633 039; May.9- sent By: 0814 Realty, Inc; In tha Matter of' Ralph uster Metals, Attleboro Massachusetta ACOP Amendment # A OP-SE-074A405-Amnd #01 Page 3 R spondent shall achieve arid maintain Phase V Remedy Operation Status ("ihase V") at the Site in accordance with the provisions of 310 CMR 4 .0890. If sufficient 4locumcntation is provided to MassDEP which supports a Licensed Site Professional, conclusion that a Condition of No Significant Risk has been achieved at the Site and Response Action Outcorne' etment is provided to the Department prior to attaining enedy Operation Status ut e Site in pecordance with paragraphi B.C through 8.F above, the Ruspondent is not required to implement any further Conprehensie Response Actions at the Site, pursuant to 310 CMR 40.0560(3) and Section II1 of is Consent Order. Is hreby emdend so: p Respondent shall perform the following actions: /7 A) If tdditionl assessment performed at the Site indicates that conditions ne saary to support an RAO have been achieved, then the Respondent shall 17 # sulit the following documentation to MassDEP by Scntqepbet- 24200: X____ 1) A revised RAO; The RAO shall be prepared in full accordance with all requirements listed in 310 CMR 40.1000 and shall contain, at a minimum, a revised risk characterization that incorporates both historic and current data collected from the site, taking into consideration the additional assessment data collected within the access road to documenl the concentrations of contaminants present in the soils and more adeqLttelyto define the disposal site boundaries. a) If the revised RAO relies on the implementation of an AUL, then a rgistry certified copy of an AUL Amcndment, prepared in full accordance with 310 CMR 40.1081, shall also be submitted to MassDEP, The AUL Arnendmeno1Jall not incfudo reference to barrier not yet in- place aLlhe time the AUL Is recorded and shall correctly state whether the AULs niiecessary to maintain a condition ofNSR or NSI). b) Howevtr, If the revised RAO does not rely on the implementation of an AUL. then a Registry certified copy of the AUL termination, prepared in full accordance with 310 CMR 40.1083(l)(a), shall also be submitted to MassDEP; and, The above referenced revised documents shall be prepared in full accordance with the provisions of the MCP and be accompanied by a Post-Audit Completion Statement. Transmittal Form BWSC-l III B) In tI* event that the Respondent. sibm its to MassDEP the revised documents dissed above by e2 . then the Respondent need not /I cont ue with the response actiond set forth below. 1 .nmr aft RaInh qh tor Metals. Attflehno Mmuaschusetts. AUG-28-2008 11:02 From: CRRNE 9T:13 F' -440700To:141378726467 8 8 9 F.7/8 ACOP Amendment # ACOP-SED7A&-005-Amend #1 Page 4 C) HoNcvr, additional asessment performed at the Site indicates that 9 co ditions necessary to support an RAO have not been achieved, then the Re pondent shall submit the following documentation to MasaDEP by Sentemberl. 200 I) A statement of retraction for the Class C RAO Statoment received by the Department-on January 11, 2006; 2) A Tier 11 Extension Submittal prepared in full accordance with the provisions of 310 CMR 40.0560(l) and annually thereafter until a time at which a Response Action Outcome Statement, prepared In f1l accordance with 310 CMR 40.1000, is submitted for the site; 3) A Phaso 1 Scope of Work, prepared in Ml accordance with the provision of 310 CM 48.0834(2); 4) A rgisty ertified copy of the AUL termination, prepared in full coiance with 310 CMR 40.1083(1)(Metnd 5) A Post Audit Completion Statement, Tradsmrital Form BWSC-1 11. D) By December 4, 28 Respondent shall submit to MassDEP a Supplomental Ph we 11 Comprehensive Site Assessment Report (a Phase 11 Report) including a isk characterization for the Site, prepared in Mi accordance with the prvsions of 310 CMR 40.0830 and 310 CMR 40.0900, respectively. If the Ph e 1 Report Indicotes that more Comprehensive Response Actions are ne dad to achieve a Response Action Outcome ("RAO") at the Site, the pondent shall also submit to the MassDEP a Phase UT Remedial Action P n("Phase 111"), prepared in full accordance with the provisions of 310 CMR 40.0850. The Phase 111 Report shall evaluate the feasibility of reaching a Nrmanent Solution, as defined by the MCP, for the Sito. B) By Fifra 3, 209:1i the Phase IM Report, referenced in paragraph 8D. abqve, demonstrates that the Site meets the requirements for a Class C RAO, t Respondent shall submit totte MasaDEP a Class C RAO, pursuant to the k pr visions or 310 CMR 4pd 310 CMR 40.1056, If the Phase 1U Rrt refernced in paragrap sb. above indicates that it is feasible to reach a Permnont Solution at the Site, then by Novembe9he Respondent V shll subit to the MassDEP a Phase IV Remedy Impleientttion Plan ("Phase IV), prepared in tUll accordance with the provisions of 310 CMR 40j0870. F) O or before Novenber ., 2010, if a Phase IV Report, referenced in agrph 8.B. above, has been submitted to MassDEP by August 1, 2009, Lhe ndent shall achieve and maintain Phase V Remedy Operation Status (" hase V') at the Site in accordance with the provisions of 310 CMR 0890. If sufficient cumentation is ptovided to MassDEP which supports a Licensed Site ProfessionaP4 conclusion that a Condition of No Significant Riak has been achieved at the Site and 4 Response Action Outcome Statement is provided to the Department prior to attaining cedy Operation Status at the Site in accordance with paragraphs 8.C AUG-28-2008 11:02 From:CRRNE 97R441P700 T o:14137872646 .E/ Sent By: DOM Aealty, Inc; 401 633 6039; May-9-0' 0O:5B8Au; Page 8/ inthe Matter or Kalph s unter Metals, Attleboro Msnachueus ACOP Amendmnt # AC0P-SB-053 A-05-Anind #1 Fage 5 through 8,F above, the Respondent i"not required to implement any further Comprehensile Response Actions at the Site, pursuant to 310 CMR 40.0560(3) and Section III of hi Consent Order, 2. The undersigned ccrtify that they are aily authorized to enter into the terms and conditions of this Consent Order and to legally bind the party on whose behalf they are signing this Conscnt Order. 3. This Consent rder Amendment shall become effective on the date that it Is exccuted by MassDEP. 4, The Deprlme't reprsents that the Regional Director has the authority to Issue the Order on behalf oftt Departnment. 5. 'Tho remnin rovision of thi Or,. specifically Sceqign IL which addresses t terms fnd conitiond fmo nflhgStipulated penlties, are stilt id.lSre. Consented To: Ralph Shuster Meta 4 Inc. By: I David Mukin, Pr ident Ralph Shuster Me ale, Inc. 909 North Main S rect, Providence, Rhode island 02904 Federal Employer Idendfication No.: 042141488 Date: Issued By: DEPARTMENT 01 ENVTRONMENTAL PROTECTION By;I David Johnston Acting Regional director DceFlment of En ronmul P'rotactin 20 AkVenide Drivr = ' - Lakeville, Massacpusetts 02347 Date- APPENDIX D AUL Package WESTERN MASS ENVIRONMENTAL @ 2008, Project 1484 APPENDIX - Bk: 17663 Pg: 1 Page: 1 of 16 Doc: AMD 09/02/2008 12:36 PM A Vru cOWY By Aes rnD Form 1082B FIRST AMENDMENT TO NOTICE OF ACTIVITY AND USE LIMITATION M.G.L. c. 21E, §6 and 310 CMR 40.0000 Disposal Site Name: 44 Forest Street, Attleboro, MA DEP Release Tracking No.: 4-16211 WHEREAS, a Notice of Activity and Use Limitation has been recorded with the Bristol County Registry of Deeds in Book 15517, Page 73 (said Notice of Activity and Use Limitation and any amendments thereto are collectively referred to herein as "Notice"); WHEREAS, said Notice sets forth limitations on use and activities, conditions and obligations affecting a certain parcel of land situated in Attleboro, Bristol County, Massachusetts with the building as and improvements thereon, said land being more particularly bounded and described in Exhibit A attached hereto and made a part hereof ("the Property"). Said limitations on use and activities are consistent with the terms of an Activity and Use Limitation Opinion ("AUL Opinion") dated December 27, 2005, signed and sealed by Kurt E. Klages, holder of a valid license issued by the Board of Registration of Waste Site Cleanup Professionals, pursuant to Massachusetts General Laws Chapter 21A, Sections 19-19J (the holder being referred to as "LSP") attached to the Notice of Activity and Use Limitation as Exhibit C and made a part thereof, in order eliminate a substantial hazard (such conditions and terms being defined in 310 CMR 40.0000); WHEREAS, only a portion of the Property ("Portion of the Property") is subject to the Notice. The Portion of the Property, consisting of vacant land and a paved roadway, is more particularly bounded and described in Exhibit A-1, attached hereto and made a part hereof The portion of the Property is shown on a survey plan recorded in the Bristol County Registry of Deeds in Book i/% 7 at Page / Attached as Exhibit B is a sketch plan showing the boundaries of the Portion of the Property in relation to the boundaries of the Property; and WHEREAS, the undersigned LSP, in accordance with M.G.L. c. 21E and the MCP, has issued and signed an AUL Opinion, dated August 28, 2008, filed with DEP at its Southeastern Regional Office under Release Tracking No. 4-16211, and attached hereto as Exhibit C and made a part hereof Said AUL Opinion explains that the implementation of the following proposed changes in Site Activities and Uses at the Portion of the Property will maintain a condition of No Significant Risk at the Portion of the Property, and that no additional response actions are necessary on the Portion of the Property; NOW THEREFORE, in accordance with M.G.L. c. 21E and the MCP, the undersigned David Malkin, as President of Ralph Shuster Metals, Inc., of Attleboro, Bristol County, Massachusetts being the owner ("Owner") of the Property pursuant to a deed recorded with the Bristol County Registry of Deeds in Book 1124, at Page 98, hereby amends said Notice as follows: Paragraph 1, Permitted Activities and Uses, is amended to read as follows: (i) Maintenance of the paved areas to limit exposure to underlying soils, such that underlying soils are not readily accessible; (ii) Maintenance of the unpaved areas to limit exposure to underlying soils, such that soils underlying the fabric cover placed under three inches of clean soil in all unpaved areas of the portion of the property subject to the AUL are not readily accessible; (iii) Underground utility and/or construction activities including, but not limited to, excavation (including emergency repair of underground utility lines), which are likely to disturb metal and petroleum impacted soil beneath the marker layer (fabric) or asphalt, provided that such activities are conducted in accordance with: 1) subparagraphs (i) and (ii) of the section below of this AUL Opinion entitled, "Obligations and Conditions"; 2), the soil management procedures of the MCP cited at 310 CMR 40.0030; and 3) and all applicable worker health and safety practices pursuant to 310 CMR 40.0018; (iv) Activities and uses that are not identified in this Opinion as being inconsistent with maintaining a condition of No Significant Risk; and (v) Such other activities and uses which, in the Opinion of a Licensed Site Professional (LSP), shall present no greater risk of harm to health, safety, public welfare, or the environment than the activities and uses set forth in this Paragraph. Paragraph 2, Activities and Uses Inconsistent with AUL Opinion, is amended to read as follows: (i) Any use of or activities on the portion of the property subject to the AUL that are likely to disturb contaminated soil, unless such uses and/or activities are covered under an appropriate Soil Management Plan and health and safety is covered by an on-site Health and Safety Plan in accordance with Obligations and Conditions (i) and (ii) of this AUL Opinion; (ii) Any development of the portion of the property subject to the AUL such that future residents, tenants, construction workers, or other users of the property would come into direct contact with contaminated soils; (iii) The cultivation of crops for human consumption either through commercial or residential use; (iv) Any activity on the portion of the property subject to the AUL including, but not limited to, excavation, that is likely to disturb contaminated soil located beneath the marker layer or pavement associated with underground utility and/or construction work, without prior development and implementation of a Soil Management Plan and a Health and Safety Plan in accordance with Obligations and Conditions (i) and (ii) of this AUL Opinion; (v) Any activity on the portion of the property subject to the AUL which is likely to disturb contaminated soil located beneath the marker layer and pavement for a period of time greater than three months, unless such activity is first evaluated by an LSP who renders an Opinion stating that such activity is consistent with maintaining a condition of No Significant Risk and that such activity is conducted in accordance with Obligations and Conditions (i) and (ii) of this AUL Opinion; and (vi) Relocation of contaminated soil located beneath the marker layer and pavement on the portion of the property subject to the AUL, unless such relocation is first evaluated by an LSP who renders an Opinion stating that such relocation is consistent with maintaining a condition of No Significant Risk. Paragraph 3, Obligations and Conditions, is amended to read as follows: (i) A Soil Management Plan must be prepared by an LSP prior to the commencement of any activity on the portion of the property subject to the AUL which is likely to disturb contaminated soil located beneath the pavement and/or marker layer. The Soil Management Plan should describe appropriate soil management, characterization, storage, transport and disposal procedures in accordance with the provisions of the MCP cited at 310 CMR 40.0030 et seq. Workers who may come in contact with the contaminated soil should be appropriately trained on the requirements of the Plan, and the Plan must remain available on-site throughout the course of the project; (ii) A Health and Safety Plan must be prepared and implemented prior to the commencement of any activity which may result in the disturbance of contaminated soil located beneath the marker layer and pavement on the portion of the property subject to the AUL. The Health and Safety Plan should be prepared by a qualified individual appropriately trained in worker health and safety procedures and requirements. The Plan should specify the type of personal protection, engineering controls, and environmental monitoring necessary to prevent worker and other potential receptor exposures to contaminated soil through ingestion, dermal contact, and/or inhalation (e.g. dust created during excavation activities). Workers who may come in contact with the contaminated soil should be appropriately trained on the requirements of the Plan, and the Plan must remain available on-site throughout the course of the project; and (iii) The contaminated soil located beneath pavement and the marker layer on the portion of the property subject to the AUL must remain at depth and may not be relocated, unless such activity is first evaluated by an LSP who renders an Opinion which states that such activity poses no greater risk of harm to health, safety, public welfare, or the environment and ensures that a condition of No Significant Risk is maintained. Paragraph 4, Proposed Changes in Activities and Uses, is amended to read as follows: Any proposed changes in activities and uses at the Portion of the Property which may result in higher levels of exposure to oil and/or hazardous material than currently exist shall be evaluated by an LSP who shall render an Opinion, in accordance with 310 CMR 40.1080 et seq., as to whether the proposed changes will present a significant risk of harm to health, safety, public welfare or the environment. Any and all requirements set forth in the Opinion to meet the objective of this Notice shall be satisfied before any such activity or use is commenced. In all other respects the provisions of said Notice remain unchanged. Owner authorizes and consents to the filing and recordation of this First Amendment to Notice of Activity and Use Limitation, said First Amendment to become effective when executed under seal by the undersigned LSP and recorded with the appropriate Registry of Deeds. Owner certifies that there are no record interest-holders on the Property requiring notification of this First Amendment to Notice of Activity and Use Limitation. David Malkin, President of Ralph Shuster Metals, Inc., is authorized to sign this document on behalf of Ralph Shuster Metals, Inc., as documented in the attached Exhibit D. WITNESS the execution hereof under seal this 2gday of August, 2008. Ralph Shuster Metals, Inc. By: David Malkin, President COMMONWEALTH OF MASSACHUSETTS Bristol, ss August 't, 2008 On this .11 day of August , 2008, before me, the undersigned notary public, personally appeared David Malkin, proved to me through satisfactory evidence of identification, which were 4ynume, to be the person whose name is signed on the preceding or attacfied documeht, add acknowledged to me that he signed it voluntarily for its stated purpose as President of Ralph Shuster Metals, Inc. The undersigned LSP hereby certifies that he executed the AUL Opinion dated August 28, 2008 , filed with DEP at its Southeastern Regional Office under Release Tracking No. 4-16211, attached hereto as Exhibit C and made a part hereof, and that, in his Opinion, this First Amendment to Notice of Activity and Use Limitation is consistent therewith. Date: ffkurt E. Klapes / [ LSP SEAL ] OF MASSACHUSETTS Bristol, ss August 30,2008 On this W day of August , 2008, before me, the undersigned notary public, personally appeared Kurt E. Klages, pyoved to me through satisfactory evidence of identification, which were fl104otd4 wltn , to be the person whose name is signed on the preceding or attached document, and acknowledged to me that he signed it voluntarily for its stated purpose as LSP for Ralph Shuster Metals, Inc., Owner of the Property. NotaryPublic: My Commission Expires:/4 (official seal of notary) Upon recording, return to: David Malkin, Pres. Ralph Shuster Metals, Inc. 909 North Main Street Providence, RI 02904 ExM4) A EXIBIT A-I Area of AUL A.P. 61 Lo 181 44 Forest Street, Attleboro, MA; MassDEP RTN: 4-16211 That certain lot or parcel of land designated as the area of the Activity and Use Limitation located on the northerly side of Eddy Street, southerly side of The New York, New Haven and Hartford Railroad (Taunton Branch), City of Attleboro, State of Massachusetts, being further described as follows. Beginning at a point set on the northerly line of said Eddy Street set at the southeasterly corner of land now or formerly Ernest J. Boucher and the southwesterly corner of land now or formerly Ralph Shuster Metals, Inc., said point also being the southwesterly corner of the AUL area. Thence running N 1159'30"E, bounded westerly by said Boucher land, a distance of one hundred thirty five and forty three hundredths (135.43) feet to a point for a corner; Thence turning and running N 78'02'47" W, bounded southerly by said Boucher land, a distance of twelve and ninety six hundredths (12.96) feet to a point for a corner; Thence turning and running N 30*49'11 " W a distance of one hundred ten and eighty six hundredths (110.86) feet to a point for a corner; Thence turning and running N 17o10'22" W, a distance of sixty five and twenty seven hundredths (65.27) feet to a point for a corner; Thence turning and running N 12*33'09" W, a distance of sixty two and seventy hundredths (62.70) feet to-a point and the beginning of a curve to the left; Thence turning an interior angle to chord of 244o44'33" and running westerly along said curve having a radius of 39.8 feet an arc distance of 54.9 feet to a point of reverse curve to the right; Thence turning an interior angle to chord of 132' 14'12" and running westerly to northerly along said curve having a radius of 23.5 feet an arc distance of 54.8 feet to a point of reverse curve to the left; Thence turning an interior angle to chord of 192'38'41" and running westerly along said curve having a radius of 9.4', an arc distance of 25.6 feet to a point of reverse curve to the right; Thence turning an interior angle to chord of 240*06'35" and running westerly along said curve having a radius of 83.6 feet, an are distance of 90.6 feet to a point of curvature; Thence turning an interior angle to chord of 124* 35' 53" and running northwesterly along said curve having a radius of 95.1 feet, an arc distance of 65.4 feet to a point for a corner; Thence turning and running N 280 25' 04" W, a distance of twenty seven and twenty two hundredth (27.22) feet to a point for a corner; Thence turning and running N 450 44' 30" E, a distance of one hundred thirty nine and ninety one hundredth (139.91) feet to a point for a corner; Thence turning and running S 890 29' 07" W, a distance of eighty three and thirty four hundredth (83.34) feet to a point for a corner; Thence turning and running N 00' 24' 28" W, a distance of one hundred and twenty five and forty seven hundredth (125.47) feet to a point for a corner; Thence turning and running N 850 56' 33"E, a distance of ninety nine and twenty hundredth (99.20) feet to a point for a corner; Thence turning and running N 890 43' 31" E, a distance of five hundred sixty nine and seventy three hundredth (569.73) feet to a point for a corner; Thence turning and running S 35* 36' 22" E, a distance of sixty one and sixty six hundredth (61.66) feet to a point for a corner; Thence turning and running S 56* 50' 34" W, a distance of eighty three and seventy three hundredth (83.73) feet to a point for a corner; Thence turning and running S 500 38' 27" W, a distance of fifty seven and fifty six hundredth (57.56) feet to a point for a corner; Thence turning and running S 570 21' 39" W, a distance of fifty six and sixty two hundredth (56.62) feet to a point for a corner; Thence turning and running S 75' 03' 53" W, a distance of seventy eight and thirty five hundredth (78.35) feet to a point for a corner; Thence turning and running S 12" 50' 27" W, a distance of seventy two and ninety six hundredth (72.96) feet to a point and beginning of a curvature to the right; Thence turning an interior angle to chord of 85' 54' 05" and running westerly along said curve a radius of 138.5 feet, an arc distance of 168.61 feet to a point for a reverse curve to the left; Thence turning an interior angle of 187* 16' 53" and running westerly along said curve a radius of 49.62 feet an arc distance of 65.2 feet to a point of curvature to the left; Thence turning an interior angle to chord of 2580 05' 57" and running southeasterly along said curve, a radius of 45.9 feet, and arc distance of 86.1 feet to a point of curvature to the left; Thence turning a interior angle from chord of 2510 47' 58" and running S 50' 14' 25" E a distance of 19.91 feet to a point of curvature to the left; Thence turning an interior angle to chord of 1350 44' 36" and running southerly along said curve, a radius of 38.9 feet an arc distance of 43.68 feet to a point; Thence turning and interior angle from chord of 1670 56' 01" and running S 04* 45' 51" W a distance of 29.44 feet to a point for an angle; Thence running S 230 09' 15" E a distance of one hundred thirty eight and eighty three hundredth (138.83) feet to a point for a corner; Thence running S 31* 26' 36" E a distance of seventy seven and sixty two hundredth (77.62) feet to a point for a comer; Thence running S 15* 44' 44" E a distance of sixty one and ten hundredth (61.10) feet to a point for a corner; Thence running S 070 26' 32" W a distance of forty three and eighty four hundredth (43.84) feet to a point for a corner; Thence running S 040 08' 01" E a distance of fourteen and seventy seven hundredth (14.77) feet to a point for a corner; Thence running S 09' 54' 31" W a distance of fifty six and sixty two hundredth (56.62) feet to the said northerly line of Eddy Street; Thence running N 780 10' 33" W along said northerly line of Eddy street a distance of forty four and thirty two hundredth (44.32) feet to a point and place of beginning. EA46I B Ii ii 19I q -E ,Ja;d I1~ a-~ Iiji!ijill,~ II. I: 8/28/08 EXHIBIT C ACTIVITY AND USE LIMITATION OPINION In accordance with the requirements of 310 CMR 40.1074, this Activity and Use Limitation (AUL) Opinion has been prepared for a portion of a parcel of land owned by the Ralph Shuster Metals, Inc., located at 40 Forest Street in Attleborough, Bristol County, Massachusetts. The subject 10-acre property is an industrially zoned property identified on the Attleborough tax assessors Plat Map 61, as Lot 181. The portion of the property subject to the AUL is paved or capped with no buildings or other improvements thereon. Site History Ralph Shuster Metals, Inc. (RSM) historically utilized the property at 40 Forest Street for the collection, separation and shipping of scrap metals. According to representatives of RSM the metals included non-ferrous and ferrous types, such as nickel, aluminum, copper, stainless steel, and iron. The site was utilized for the collection and separation of the metals, but not for their cleaning or refining. In May 2001, the Massachusetts Department of Environmental Protection (MassDEP) visited the site and issued a release tracking number (RTN 4-16211) for a petroleum-like sheen on wetland surface water. The sheen was noted adjacent to a roadway through the wetland. This roadway was reportedly constructed in the 1950s and apparently was constructed of soil and metal shavings from the RSM operations. The likely source of the sheen was rainwater run-off from the roadway and through the roadway soils. The environmental assessment actions determined that polychlorinated biphenyls (PCBs), extractable petroleum hydrocarbons (EPH), arsenic, chromium, cadmium and lead exceed applicable Method 1 S-1 risk-based soil standards as set forth in the Massachusetts Contingency Plan (MCP) in shallow soils varying from surface grade to an estimated 8 feet below grade as determined by excavation and grade changes of the roadway and other areas of the site. Additionally, polynuclear aromatic hydrocarbons (PAHs), PCBs, chromium, cadmium, mercury and lead in wetland sediments exceed Threshold Effect Concentrations (TECs) as determined in the Method 3 Stage I Environmental Screening also completed at the site. Based on assessment completed on groundwater from monitoring wells at the site, groundwater was not found to be impacted, and all concentrations were below the Method 1 GW-213 Groundwater Standards as a result of the release. The Method 3 Risk Characterization that incorporates the Method 3 Stage I Environmental Screening concluded that no substantial hazard exists for the site, and a Method 3 Risk Characterization completed for the site concluded that a condition of no significant risk exists for the roadway and areas outside the wetland with the implementation of the AUL. The roadway and areas outside the wetland are associated with this AUL and, with the placement of the AUL, present a condition of no significant risk. The portion of the property subject to the AUL is depicted in the sketch plan included in Exhibit B. The property outside of the AUL but within the RAO disposal site boundaries includes both areas of no significant risk and no substantial hazard. Reason for Activity and Use Limitation A Method 3 Risk Characterization was conducted to evaluate the risk posed by contamination remaining in soil, sediment and surface water at the site. Based on remaining concentrations in soil at the site, the Risk Characterization determined that an AUL is necessary to meet a condition of No Significant Risk on a portion of the property by limiting unrestricted human exposure to the soil by providing notice of the existence of contamination to future holders of an interest(s) in the subject property and to place conditions on site use. Permitted Activities and Uses (i) Maintenance of the paved areas to limit exposure to underlying soils, such that underlying soils are not readily accessible; (ii) Maintenance of the unpaved areas to limit exposure to underlying soils, such that soils underlying the fabric cover placed under three inches of clean soil in all unpaved areas of the portion of the property subject to the AUL are not readily accessible; (iii) Underground utility and/or construction activities including, but not limited to, excavation (including emergency repair of underground utility lines), which are likely to disturb metal and petroleum impacted soil beneath the marker layer (fabric) or asphalt, provided that such activities are conducted in accordance with: 1) subparagraphs (i) and (ii) of the section below of this AUL Opinion entitled, "Obligations and Conditions"; 2), the soil management procedures of the MCP cited at 310 CMR 40.0030; and 3) and all applicable worker health and safety practices pursuant to 310 CMR 40.0018; (iv) Activities and uses that are not identified in this Opinion as being inconsistent with maintaining a condition of No Significant Risk; and (v) Such other activities and uses which, in the Opinion of a Licensed Site Professional (LSP), shall present no greater risk of harm to health, safety, public welfare, or the environment than the activities and uses set forth in this Paragraph. Activities and Uses Inconsistent with AUL Opinion (i) Any use of or activities on the portion of the property subject to the AUL that are likely to disturb contaminated soil, unless such uses and/or activities are covered under an appropriate Soil Management Plan and health and safety is covered by an on-site Health and Safety Plan in accordance with Obligations and Conditions (i) and (ii) of this AUL Opinion; (ii) Any development of the portion of the property subject to the AUL such that future residents, tenants, construction workers, or other users of the property would come into direct contact with contaminated soils; (iii) The cultivation of crops for human consumption either through commercial or residential use; (iv) Any activity on the portion of the property subject to the AUL including, but not limited to, excavation, that is likely to disturb contaminated soil located beneath the marker layer or pavement associated with underground utility and/or construction work, without prior development and implementation of a Soil Management Plan and a Heath and Safety Plan in accordance with Obligations and Conditions (i) and (ii) of this AUL Opinion; (v) Any activity on the portion of the property subject to the AUL which is likely to disturb contaminated soil located beneath the marker layer and pavement for a period of time greater than three months, unless such activity is first evaluated by an LSP who renders an Opinion stating that such activity is consistent with maintaining a condition of No Significant Risk and that such activity is conducted in accordance with Obligations and Conditions (i) and (ii) of this AUL Opinion; and (vi) Relocation of contaminated soil located beneath the marker layer and pavement on the portion of the property subject to the AUL, unless such relocation is first evaluated by an LSP who renders an Opinion stating that such relocation is consistent with maintaining a condition of No Significant Risk. Obligations and Conditions (i) A Soil Management Plan must be prepared by an LSP prior to the commencement of any activity on the portion of the property subject to the AUL which is likely to disturb contaminated soil located beneath the pavement and/or marker layer. The Soil Management Plan should describe appropriate soil management, characterization, storage, transport and disposal procedures in accordance with the provisions of the MCP cited at 310 CMR 40.0030 et seq. Workers who may come in contact with the contaminated soil should be appropriately trained on the requirements of the Plan, and the Plan must remain available on-site throughout the course of the project; (ii) A Health and Safety Plan must be prepared and implemented prior to the commencement of any activity which may result in the disturbance of contaminated soil located beneath the marker layer and pavement on the portion of the property subject to the AUL. The Health and Safety Plan should be prepared by a qualified individual appropriately trained in worker health and safety procedures and requirements. The Plan should specify the type of personal protection, engineering controls, and environmental monitoring necessary to prevent worker and other potential receptor exposures to contaminated soil through ingestion, dermal contact, and/or inhalation (e.g. dust created during excavation activities). Workers who may come in contact with the contaminated soil should be appropriately trained on the requirements of the Plan, and the Plan must remain available on-site throughout the course of the project; and (iii) The contaminated soil located beneath pavement and the marker layer on the portion of the property subject to the AUL must remain at depth and may not be relocated, unless such activity is first evaluated by an LSP who renders an Opinion which states that such activity poses no greater risk of harm to health, safety, public welfare, or the environment and ensures that a condition of No Significant Risk is maintained. LS P: DATE: 1170 CLERK'S CERTIFICATE I, Helen Kosubinsky, DO HEREBY CERTIFY; That I am the Clerk of Ralph Shuster Metals, Inc, a Massachusetts Corporation having a principal place of business at 40 Forest Street, Attleboro, Massachusetts ("Corporation") and that at a meeting of the Board of Directors of the Corporation duly called and held at the office of the Corporation at 40 Forest Street, Attleboro, Massachusetts on the 7t day of January, 2008, all the directors being present and voting at all times, the following resolution was unanimously adopted: VOTED; That the President, Treasurer or Clerk be, and any one of them is, hereby authorized and directed in the name and on behalf of the Corporation to purchase real or personal property for the Corporation in his or her discretion; to sell, mortgage or lease any and all real estate owned or which may hereafter be owned by the Corporation, as any one of them shall deem expedient and proper in carrying out the business of the Corporation, and in connection therewith to sign in the name and on behalf of the Corporation, seal with the corporate seal, acknowledge and deliver any mortgages, deeds, promissory notes, and other instruments of every nature, which may be necessary or proper in carrying on the business of the Corporation, and to do any and all acts necessary and proper for imposing restrictive covenants and agreements on any property now or hereafter owned by said Corporation. This vote shall remain in full force and effect until revoked by a vote of the Board of Directors. I DO FURTHER CERTIFY that the above vote has not been altered, amended, rescinded or repealed. I DO FURTHER CERTIFY that the Corporation is a duly organized corporation; that the foregoing vote is in accordance with the charter and by-laws of the Corporation; that David Malkin is the duly elected and qualified President of the Corporation, and that I am the duly elected and qualified Clerk of the Corporation. Dated this 2 2 "Aday of August, 2008. ATTEST: A true copy Helen Kosubinsky, Clerk APPENDIX E Method 3 Risk Characterization WESTERN MASS ENVIRONMENTAL @2008, Project 1484 APPENDIX EnvironmentalSafetyHealthGeotechnical O'Reilly, Talbot & Okun EN]EEa G 19 W. Main Street [ A S S 0 C I A T E S I Suite 205 Westborough, MA 01581 Tel 508 366 6409 Fax 508 366 9826 www.oto-env.com August 28, 2008 File No: 5075-09-01 Prepared for Western Massachusetts Environmental 93 Wayside Avenue West Springfield, Massachusetts 01089 METHOD 3 RISK CHARACTERIZATION 40 Forest Street Attleborough, Massachusetts RTN 4-16211 Prepared by: O'Reilly, Talbot & Okun Associates, Inc. 19 West Main Street, Suite 205 Westborough, Massachusetts 01581 T O'Reilly, Talbot & Okun 4 ENINERNG --4 [ A S S 0 C A T E 5 TABLE OF CONTENTS Page 1.0 Introduction 1 1.1 Site History and Investigations 2 2.0 Human Health Risk Assessment 5 2.1 Current and Reasonably Foreseeable Future Site Use 5 2.1.1 Soil and Groundwater Categories 5 2.1.2 Background Concentrations 7 2.2 Hazard Identification 7 2.2.1 Identification of Constituents of Concern 7 2.2.2 Toxicity Profiles 8 2.2.3 Identification of Applicable or Suitably Analogous Standards 8 2.3 Dose-Response Assessment 8 2.3.1 Threshold (Non-carcinogenic) Effects 9 2.3.2 Non-threshold (Carcinogenic) Effects 9 2.3.3 Relative Absorption Factors 10 2.4 Exposure Assessment 10 2.4.1 Development of Exposure Profiles 11 2.4.1.1 Identification of Potential Human Receptors and Exposure Points 11 2.4.1.2 Identification of Exposure Routes 12 2.4.1.3 Exposure Profile Summary 13 2.4.2 Development of Exposure Factors 14 2.4.3 Exposure Point Concentrations (EPCs) 14 2.4.4 Calculation of Average Daily Doses 16 2.5 Human Health Risk Characterization 18 2.5.1 Non-Cancer Risk 18 2.5.2 Cancer Risk 19 2.5.3 Summary of Findings 20 2.6 Uncertainty Analysis 21 3.0 Characterization of Risk of Harm to Public Welfare 22 4.0 Characterization of Risk of Harm to Safety 24 5.0 Environmental Risk Characterization 24 5.1 Site Environmental Setting 25 5.2 Aquatic Habitat Screening 25 5.3 Terrestrial Habitat Screening 28 6.0 Conclusions 29 1T 01-* O'Reilly, Talbot & Okun *4 ENIEEsG A 5 5 0 C 1 A T E S ]. TABLE OF CONTENTS (Cont'd.) Page REFERENCES 31 TABLES TABLE 1 Soil Analytical Results TABLE 2 Groundwater Sample Results TABLE 3 Sediment Sample Results TABLE 4 Surface Water Analytical Results TABLE 5 Toxicity Values for Site Compounds TABLE 6 Relative Absorption Factors (RAFs) TABLE 7 Exposure Assumptions and Equations for Construction Worker - Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates TABLE 8 Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Soil TABLE 9 Exposure Assumptions and Equations for Resident - Incidental Ingestion of and Dermal Contact with Soil, and Ingestion of Homegrown Produce TABLE 10 Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Sediment TABLE 11 Exposure Assumptions and Equations for Trespasser - Dermal Contact with Surface Water TABLE 12 Soil Exposure Point Concentrations (EPCs) TABLE 13 Calculation of Risk Estimates for Construction Worker - Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates TABLE 14 Calculation of Risk Estimates for Trespasser - Incidental Ingestion of and Dermal Contact with Soil TABLE 15 Calculation of Risk Estimates for Resident - Incidental Ingestion of and Dermal Contact with Soil, and Ingestion of Homegrown Produce TABLE 16 Calculation of Average Daily Doses and Risk Estimates for Trespasser - Incidental Ingestion of and Dermal Contact with Sediment TABLE 17 Calculation of Average Daily Doses and Risk Estimates for Trespasser - Dermal Contact with Surface Water TABLE 18 Summary of Hazard Indices and Risk Estimates TABLE 19 Comparison of Sediment Exposure Point Concentrations (EPCs) to MassDEP Threshold Effects Concentrations (TECs) TABLE 20 Comparison of Surface Water Exposure Point Concentrations (EPCs) to Lowest Ecologically-based Criteria (LOECs) APPENDICES APPENDIX A Toxicity Profiles it O'Reilly , Talbot & Okun +44 0 -* [ A S S O C I A T E S 1.0 INTRODUCTION This Method 3 risk characterization has been prepared by O'Reilly, Talbot & Okun Associates, Inc. (OTO) to assess whether oil and/or hazardous material (OHM) present at 40 Forest Street in Attleborough, Massachusetts poses Conditions of No Substantial Hazard and No Significant Risk within the meaning of the Massachusetts Contingency Plan (MCP 310 CMR 40.0950 and 40.0990). The MCP disposal site (the "Site") is located on a portion of the 40 Forest Street property that encompass the 3.62 acre Activity and Use Limitation (AUL) area, which includes an access road and surrounding wetlands. The access road originates at Eddy Street, travels through a wetland area, and ends at Ralph Shuster Metals (RSM) facility parking lot and yard. Three methods for Risk Characterization under the MCP, which vary in detail and circumstances of use, have been developed to evaluate a disposal site, as described in 310 CMR 40.0941(3) and 40.0942. These three methods provide equivalent levels of protection to human health, public welfare, and the environment. A Method 3 approach is considered applicable for the Site because Site-specific methodologies (e.g., exposure assumptions concerning Site use) have been used. As defined in 310 CMR 40.0950, a Method 3 Risk Characterization to demonstrate a Condition of No Substantial Hazard evaluates the risks to human health, public welfare, safety, and the environment for all current site activities and uses. As defined in 310 CMR 40.0990, a Method 3 Risk Characterization to demonstrate a Condition of No Significant Risk evaluates the risks to human health, public welfare, safety, and the environment for all current and reasonably foreseeable future site activities and uses. This risk characterization has been completed in accordance with the MCP, 310 CMR 40.0900, and applicable Massachusetts Department of Environmental Protection (MassDEP) guidance (MassDEP, 1992 through 2008). Human health risks for the Site are assessed in Section 2.0 of this report. Risk of harm to public welfare, including comparisons to Upper Concentration Limits (UCLs), is presented in Section 3.0. Characterization of risk of harm to safety is described in Section 4.0. The environmental risk characterization can be found in Section 5.0. Section 6.0 presents conclusions regarding the overall significance of Site risk. This Method 3 risk characterization is based on information and analytical data collected at the Site and provided to OTO by Western Massachusetts Environmental (WME). OTO has not conducted independent testing or Site characterization activities and assumes that the WME supplied information provides adequate characterization of the nature and extent of Site contamination, as defined in the MCP. 40 Forest Street, Attleborough 1 8/28/2008 5075-09-01 AttleboroM3text T O'Reilly Talbot & Okun S 0 -+ L A S S O C I A T E S 1.1 Site History and Investigations A detailed description of the Site history and investigations is presented in the WME reports. A summary is presented below. The disposal Site boundaries encompass the 3.62 acre Activity and Use Limitation (AUL) area, which includes an access road and surrounding wetlands. The access road was reportedly constructed in the 1950's and was approved by the Attleborough Conservation Committee in the 1970's. The access road was constructed using soil and scrap metal from the RSM facility operations. In 2001, an oil sheen was observed on the surface water within the wetland. MassDEP issued a Notice of Responsibility (NOR) to RSM and required that Immediate Response Actions (IRA) be conducted. An assessment only IRA was performed. In 2002, a Phase I/Tier Classification was completed by Kaegael Environmental. As part of the Phase I, soil, groundwater, sediment, and surface water samples were collected (Tables I through 4). The soil data collected from the access road indicated the presence of polychlorinated biphenyls (PCBs), extractable petroleum hydrocarbons (EPH), polycyclic aromatic hydrocarbons (PAHs), and RCRA 8 metals. PCBs, arsenic, chromium, and lead were detected at concentrations above the MCP Method 1 S-1/GW-2/GW-3 standards applicable in 2002 (Table 1). The groundwater samples from three monitoring wells in 2002 were analyzed for EPH, PAHs, and RCRA 8 metals. Only barium was detected in the wells and at concentrations below the MCP Method I GW-2 and GW-3 standards applicable in 2002 (Table 2). Sediment samples collected in 2002 indicated the presence of EPH and PAHs (Table 3). Surface water samples collected in 2002 indicated the presence of metals (Table 4). In 2003, a Stage I Environmental Screening was conducted by Eco-Solutions using the 2002 analytical data. The report concluded that there was a Risk of Harm to the Environment. Specifically, the Stage I identified risk of harm to aquatic invertebrates in the western portion of the wetland, and to wildlife that may come in contact to scrap metal turnings on the access road. In 2005, Jacques Whitford completed additional sampling of soil, groundwater, sediment, and surface water (Tables 1 through 4). Concentrations of PCBs, arsenic, chromium, and lead in a soil sample from the access road exceeded the MCP Method 1 S-1/GW-2/GW-3 standards applicable in 2005 (Table 1). Barium was detected in groundwater at a concentration below the MCP Method 1 GW-2 and GW-3 standards applicable in 2005 (Table 2). EPH, PAHs, metals, and PCBs were detected in sediments (Table 3). Metals were detected in surface water (Table 4). 40 Forest Street, Attleborough 2 8/28/2008 5075-09-01 AttleboroM3text ENIERN O'Reilly , Talbot & Okun +-- [A S S 0 C I A T E S Jacques Whitford made two important observations during the 2005 Site visits and sampling. The first one was that significant debris was present adjacent to the property formerly occupied by an auto repair shop and currently occupied by Crown Limousine. The debris was located on the western and eastern sides of the access road and at the southern end of the wetlands. The debris was in the general vicinity of samples KE1, SS-6, SW-1, SS-10, and SED-15 on the western side of the access road, and SS-23 on the eastern side of the access road. The second significant observation made by Jacques Whitford was that an outfall pipe enters the southeastern wetlands from Eddy Street. Therefore, Jacques Whitford collected a sediment sample from this location (SS-21) to characterize materials that may be discharging into the wetlands from this source. In December 2005, OTO completed a Method 3 Stage I Environmental Screening (Section 5). The Stage I concluded that a Condition of No Significant Risk of Harm to the Environment does not exist. However, a Condition of No Substantial Hazard did exist. The Stage I recommended a Class C RAO, with an Activity and Use Limitation (AUL) that includes placement and maintenance of pavement on the access road. The objectives for the pavement on the road are to mitigate surface runoff that may further impact the wetlands, and to prevent direct contact exposure to terrestrial receptors. In January 2006, a Phase II CSA/Phase III RAP/Class C RAO was submitted to MassDEP. On December 19, 2007, WME oversaw the completion of 17 test pits extending from the wetland roadway out into the RSM yard proper. Test pits were completed based on distance from the roadway and if metals fragments were noted within the soil. All test pits were completed to 3 feet deep, as no observations of metals were noted past this depth in the areas test pitted. Select soil samples were analyzed for total chromium, EPH, PCBs, PAHs, and RCRA 8 metals (Table 1). Select chromium samples were analyzed in an attempt to determine a concentration gradient from the roadway, and other analyses were completed to determine the extent of impacts. Based on this assessment, WME concluded that metal fragments appeared to extend to the approximate center of the yard. However, additional areas of apparent metal fragments were noted on the far side of the railroad spurs and extended to the existing operating railroad tracks, beyond which is the Texas Instruments (TI) property. The test pit results indicated that concentrations of EPH were not defined by the presence of metal fragments and are likely present as a result of historic use of the Site for stockpiling and segregating metals, laden with cutting oils. Based on the sporadic presence of EPH impacts, WME determined that additional assessment was required, specifically the installation of a monitoring well in the vicinity of the soil samples with the highest EPH concentrations (TP-15, TP-16, and TP-17) and the completion of additional soil borings to delineate the eastern and western extent of impacts. 40 Forest Street, Attleborough 3 8/28/2008 5075-09-01 AttleboroM3text T1 O'Reilly , Talbot & Okun 4 CNIERN [ A S S 0 C I A T E S ] WME returned to the Site on February 5, 2008, to oversee New England Geotech install a monitoring well to assess the potential for petroleum and metal contaminants leaching from soil to groundwater. One 1-inch monitoring well was completed to 15 feet below grade with 14 feet of screened interval. On February 14, 2008, WME returned to the Site to collect a groundwater sample from the newly installed monitoring well (MW-1) and to complete additional soil borings at the extent of the eastern property boundary and at the entrance to the facility yard. No samples were collected to the north, since metal fragments were noted to extend to the active railroad tracks, beyond which is landscaped grassy areas owned by TI. The soil borings were completed to approximately 2 feet below grade, and no evidence of metal fragments or petroleum odors were noted. The groundwater sample (ID: "MW-I") was analyzed for EPH and RCRA 8 metals and the six soil samples (ID's: "SS-1" through "SS-6") were analyzed for EPH and chromium. The results indicated that no overt evidence of impacts was noted in either the soil or groundwater samples. The only concentrations of note were detected in the soil sample collected from the entrance to the facility yard (SS-6), which had detected concentrations of EPH, although they were below applicable soil standards. WME is of the opinion that since no visual or olfactory evidence was noted that the detected EPH concentrations are likely from vehicular traffic over this area, which is the only access to the yard. In summary, concentrations seem to be sporadic and spread throughout the facility yard. Therefore, WME is of the opinion that placing an activity and use limitation (AUL) over the entire yard within borings SS-1 through SS-6 and to the northern property boundary would be the most cost effective and logical approach to the problem. The AUL boundary to the south through the wetland will remain approximately the same. Since the northern boundary of the property abuts an active rail line and is visibly impacted with metal fragments, WME is of the opinion that continued sampling of known metal fragments would not yield any significantly different data than samples collected from the roadway, since the source would be the same. In March 2008, WME collected three additional soil samples (SS-7, -8 and, -9). These samples were collected north of the railroad tracks on the TI property. The samples were analyzed for chromium and the detected concentrations were below MCP Method 1 S- 1/GW-2/GW-3 standards (Table 1). In 2008, a portion of the access road originating on Eddy Street and extending to the entrance of the RSM yard was paved. The remainder of the RSM yard, extending to the live railroad tracks and extending from SS-6 to SS-1 through SS-5, but not encompassing the wetlands, was covered with a marker fabric (recycled green 4 mil) and a minimum of 3 inches of soil. 40 Forest Street, Attleborough 4 8/28/2008 5075-09-01 AttleboroM3text T O'Reilly Talbot & Okun ENGNEIG 0-+ [ A S S 0 C I A T E S] The objective of the Method 3 Risk Characterization is to determine whether concentrations of OHM at the Site represent a Condition of No Significant Risk under current and foreseeable future Site conditions. The soil, groundwater, sediment, and surface water data used in the risk characterization are presented in Tables 1, 2, 3, and 4, respectively. 2.0 HUMAN HEALTH RISK ASSESSMENT 2.1 Current and Reasonably Foreseeable Future Site Use The disposal Site boundaries encompass the 3.62 acre Activity and Use Limitation (AUL) area, including the access road, and surrounding wetlands. The subject property is industrially zoned. The portion of the property subject to the AUL is paved or capped with no buildings or other improvements. The foreseeable future use of the Site is expected to be the same as the current use. 2.1.1 Soil and Groundwater Categories Categories for soil and groundwater have been developed by the MassDEP to facilitate the characterization of risk at MCP sites. The identification of applicable groundwater and soil categories at the Site has been conducted in accordance with 310 CMR 40.0993(2). Soil Category Identification of the applicable soil category requires an assessment of three factors identified in Section 40.0930 of the MCP. These are accessibility, frequency of use, and intensity of use. Each of these factors must be assessed for the current use scenario and for a reasonably foreseeable future use scenario. Soils with detected concentrations of constituents are located at depths ranging from 0 to 15-16 feet below ground surface (bgs) in paved, capped, or unpaved areas. As defined in the MCP, soils located from 0 to 3 feet in unpaved areas are considered to be "accessible" for exposure. Soils located from 0 to 3 feet in paved or capped areas and 3 to 15 feet in unpaved areas are considered to be "potentially accessible". Based upon this current use of the Site, frequency of use by the general public, as adult and children residents and trespassers, is considered to be low. Intensity of use by these receptors is considered to be low. Construction and utility work may occur at the Site in the future. There are no plans for construction and no utilities are currently located at the Site. The frequency of this activity is considered low, and the intensity of use is considered high (i.e., short-term excavation activities occurring at infrequent and irregular intervals). 40 Forest Street, Attleborough 5 8/28/2008 5075-09-01 AtdeboroM3text T O'Reilly , Talbot & Okun 0NIERN [ A S S 0 C I A T E S ] Given this set of circumstances, the applicable soil categories for the impacted soils at the Site are S-2 and S-3 under current and foreseeable future conditions. The S-1 category has been assumed for unlimited future Site use (e.g., residential) in order to evaluate the need for an Activity and Use Limitation (AUL). Groundwater Categories MassDEP has identified three groundwater exposure categories (GW-1, GW-2, and GW-3) under the MCP, each reflective of a type of risk that may be posed by OHM in groundwater. Different combinations of these criteria are applicable at sites depending upon the groundwater resource characteristics. OW-1 The GW-1 category is applicable to locations where groundwater is, or may in the future be, a drinking water source. The Site is serviced by municipal water. No private drinking water wells are located within 500 feet of the Site. According to the MassDEP Bureau of Waste Site Cleanup (BWSC) Geographic Information System (GIS) Priority Resource Map, the Site is not located within any of the following features: 1. Potentially Productive Aquifer (PPA), 2. Interim Wellhead Protection Area (IWPA), 3. Approved Zone II of a Public Water Supply, 4. Zone A of a Class A Surface Water Body, and 5. An area designated by a municipality specifically for the protection of groundwater quality to ensure its availability for use as a source of potable water supply. Therefore, the GW-1 groundwater category is not applicable to the Site. GW-2 The GW-2 category applies to locations where OHM may volatilize from the groundwater and migrate into an occupied structure. Groundwater with an average annual depth of 15 feet or less bgs and located within 30 feet of a currently occupied or future planned building meets the criteria of GW-2. The depth to groundwater at the Site is less than 15 feet bgs. However, no occupied buildings exist or are planned within 30 feet of the groundwater monitoring wells. Therefore, the GW-2 category is not applicable. 40 Forest Street, Attleborough 6 8/28/2008 5075-09-01 AttleboroM3text ENIEIG O'Reilly, Talbot & Okun 4 0.-}+ L A S S 0 C I A T E S GW-3 The GW-3 category is intended to protect environmental receptors in surface water that may be exposed to OHM when groundwater from an MCP site discharges to surface water. For all MCP sites, the GW-3 groundwater category is applicable. The wetlands that surround the access road are part of the disposal Site. Given this set of circumstances, the applicable groundwater category for the Site is GW-3. 2.1.2 Background Concentrations EPH, PAHs, metals, and PCBs are detected in soil and sediments. Barium is detected in groundwater. Metals are detected in surface water. The MassDEP has not formally established background concentrations for these constituents in these media, except for PAHs and metals in soil. Therefore, in this risk characterization, it is assumed that background concentrations for these constituents, except PAHs and metals in soil, are the respective method reporting limits. Fourteen PAHs are detected in the soil samples (fable 1). The detected concentrations of seven PAHs (benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene, and benzo(g,h,i)perylene) are above the MassDEP background concentrations in "natural" soil (MassDEP, 2002a). Therefore, PAHs as a group are selected as constituents of concern (COCs) and are carried through the risk characterization. The RCRA 8 metals were detected in at least one soil sample. The maximum concentrations of arsenic, cadmium, chromium, lead, mercury, and silver are above the MassDEP background concentrations in "natural" soil (MassDEP, 2002a). Therefore, these metals are selected as COCs and carried through the risk characterization. 2.2 Hazard Identification 2.2.1 Identification of Constituents of Concern Soil The soil data collected at the Site in 2002, 2005, 2007, and 2008 are presented in Table 1. EPH, fourteen PAHs, PCBs, and six metals (see Section 2.1.2) are the COCs for soil. Groundwater The groundwater data collected at the Site in 2002 and 2005 are presented in Table 2. Barium, the only detected analyte, is the groundwater COC. 40 Forest Street, Attleborough 7 8/28/2008 5075-09-01 AttleboroM3text I O'Reilly Talbot & Okun 0-4 [ A S S 0 C I A T E S Sediment The sediment data collected at the Site in 2002 and 2005 are presented in Table 3. The detected analytes EPH, PAHs, PCBs, and seven metals (arsenic, barium, cadmium, chromium, mercury, lead, and silver) are the COCs for sediment. Surface Water The metals detected in surface water, silver, barium, cadmium, chromium, lead, and selenium are the COCs. 2.2.2 Toxicity Profiles Toxicity profiles describe the potential human health effects posed by the constituents of concern, when doses are high enough to elicit an effect. Toxicity profiles for the constituents of concern are included in Appendix A. 2.2.3 Identification of Applicable or Suitably Analogous Standards Applicable or suitably analogous standards are formally promulgated standards intended to protect human health and the environment from adverse effects of hazardous agents. Such standards are media-specific. There are no applicable or suitably analogous soil standards available for Site COCs. In accordance with MassDEP policy, MCP Method 1 risk characterization standards are not considered to be applicable or suitably analogous standards for Method 3 risk assessments. Federal and state drinking water standards are not applicable or suitably analogous standards for this Site, because groundwater at the Site is not classified as GW-1. Massachusetts Surface Water Quality Standards are applicable or suitably analogous standards for this Site, because surface water is present on the Site and potential Site-related analytes are detected in surface water. 2.3 Dose-Response Assessment Dose-response information describes the health effects observed in humans or animals associated with particular doses of a chemical. Based on the observed effect and target organ identified, a numerical value is developed to estimate the magnitude of the health effect associated with a dose. Dose-response values are derived differently for non- carcinogenic and carcinogenic effects, as discussed below. 40 Forest Street, Attleborough 8 8/28/2008 5075-09-01 AttleboroM3text I O'Reilly , Talbot & Okun -4 [ A S S o C I A T E S ] The sources of dose-response information for compounds detected at this Site were US EPA's on-line Integrated Risk Information System (IRIS) database (EPA, 2008), US EPA's Health Effects Assessment Summary Tables (HEAST) (EPA, 1997a) and MassDEP documents (MassDEP, 2008a). 2.3.1 Threshold (Non-carcinogenic) Effects For non-carcinogenic effects, there is believed to be a threshold level below which no adverse health effects will occur. Dose-response values for non-carcinogenic oral effects are referred to as Reference Doses (RfDs). For inhalation effects, these values are referred to as Reference Concentrations (RfCs). RfDs and RfCs represent EPA's provisional estimate of the threshold dose that will not pose risk of an adverse health effect to sensitive humans. RfDs and RfCs are developed by applying uncertainty factors and modifying factors to the critical dose or concentration. This dose or concentration is usually either the Lowest- Observed-Adverse-Effect Level (LOAEL) or the No-Observed-Adverse-Effect Level (NOAEL) from toxicological studies, typically carried out on test animals. Uncertainty factors are used to account for interspecies variability, variation in sensitivity within the human population, differences in the route of administration among tests, and other variables that may lend uncertainty to the extrapolation of test data to environmental settings. Units for RfDs are mg/kg/day, representing a dose of chemical (in milligrams) per receptor body weight (in kilograms) per day. For inhalation exposures, the RfC value is expressed as a concentration in air in ig/m 3 for continuous, 24 hour/day exposure. Oral RfDs and inhalation RfCs for the soil and groundwater COCs are summarized in Table 5. 2.3.2 Non-threshold (Carcinogenic) Effects In accordance with MCP guidance, it has been assumed that for carcinogenic effects there is no threshold level; that is, every non-zero exposure to a carcinogen is believed to be associated with some increased incremental risk. Dose-response values derived for carcinogenic compounds are Cancer Slope Factors (CSFs). CSFs are calculated as the largest linear slope of the dose-response curve, which is generally extrapolated from the low-dose end of the curve. CSFs are expressed in (mg/kg/day)-', and assume that the received dose is averaged over a lifetime. EPA's weight-of-evidence cancer classifications for each of the COCs were compiled. These classifications indicate whether existing human and animal data are sufficient to confirm whether there is an association between exposure to the compound and the occurrence of cancer. 40 Forest Street, Attleborough 9 8/28/2008 5075-09-01 AttleboroM3text ST O'Reilly , Talbot & Okun +_ [ A 5 S 0 C I A T E 5 ] Arsenic has a weight-of-evidence classification of Group A (i.e., Human Carcinogen - sufficient evidence in epidemiological studies to support causal association between exposure and cancer in humans). Carcinogenic PAHs, cadmium (inhalation only), and lead have a classification of Group B1/B2 (i.e., Probable Human Carcinogen). The COC naphthalene has been given a weight-of-evidence classification of C (i.e., Possible Human Carcinogen - inadequate or lack of human data and limited evidence of carcinogenicity in animals). The remaining detected compounds have been given a classification of D (i.e., Not Classifiable - inadequate or no human and animal evidence of carcinogenicity) or a classification is not available (NA). Carcinogenic values for inhalation exposures, called unit risks, are calculated by dividing the slope factor by the body weight (70 kg) and multiplying by the air inhalation rate (20 m3 ) for risk associated with unit concentration in air. Multiplication by 10-3 is necessary to convert mg (milligrams) to sg (micrograms). Dose-response information for carcinogenic effects associated with Site soil and groundwater COCs is summarized in Table 5. 2.3.3 Relative Absorption Factors Relative absorption factors (RAFs) are used to account for the differences in absorption likely to occur between exposures under Site conditions and those that occurred under the experimental conditions that form the basis of the toxicity values. Absorption differences may result from matrix effects (e.g., doses absorbed from soil versus water) as well as from routes of administration (e.g., oral versus dermal exposure). RAFs adjust the calculated Site dose to make it comparable to the available toxicity information. RAFs used in this risk assessment are presented in Table 6 and were adopted from MassDEP (2008), when available. In the absence of compound-specific data for inhalation exposures, a default RAF of 1 was used. 2.4 Exposure Assessment The objectives of the Exposure Assessment are to: 1. Qualitatively and quantitatively describe the settings and conditions under which human exposures to Site OHM may reasonably be expected to occur, and 2. Calculate doses of Site OHM that human receptors may receive. Achieving these goals entails the identification of receptors that may be on-Site, evaluation of exposure pathways, and the calculation of Exposure Point Concentrations (EPCs) to which receptors may be exposed. 40 Forest Street, Attleborough 10 8/28/2008 5075-09-01 AttleboroM3text O'Reilly Talbot & Okun ENCEEIG 0.-+ [ A S S D C I A T E S] 2.4.1 Development of Exposure Profiles Exposure profiles provide a narrative description of how exposures may take place at the Site. The profiles identify factors related to potential exposures and estimate their magnitude. These factors include variables such as the receptors' body weights, intake rates, frequency of exposure, and duration of exposure. Exposure profiles are provided for each receptor identified under current and foreseeable future uses of the Site, including unrestricted residential use of the Site in order to evaluate the need for an AUL under the MCP. 2.4.1.1 Identification of Potential Human Receptors and Exposure Points Exposure points represent the locations where human or ecological receptors may come into contact with OHM at a site. These locations may be either single discrete points or areas/zones of affected media. Potential human receptors were identified based on the current and foreseeable future use of the Site. Under current conditions, there is the limited potential for exposure to "accessible" soils in unpaved areas and sediment/surface water in the wetlands, as no regular work and recreational activities occur in this part of the Site. In addition, "potentially accessible" soils located under pavement or a cap are not currently an exposure point. The potential future exposure to soils, and sediments/surface water could change if Site use and conditions are changed or if the pavement or cap is removed. Direct contact exposures to soil have been evaluated for construction workers, trespassers, and future on-Site residents. Direct contact exposures to sediment/surface water have been evaluated for trespasser. Potential exposures by construction workers to Site soils are considered to be protective of potential soil exposure to lesser-exposed utility workers, landscapers, and Site workers. Therefore, risks to these lesser-exposed receptors are not quantitatively evaluated. Vapor intrusion from groundwater (located at a depth of 15 feet or less) and from soil (within 6 horizontally and 10 feet vertically) into a Site building is not a complete exposure pathway. There is no existing or planned building within these distances from impacted groundwater and soil. In addition, volatile organic compounds are not constituents of concern for these media. 40 Forest Street, Attleborough 11 8/28/2008 5075-09-01 AttleboroM3text T O'Reilly , Talbot & Okun S [ A 5 5 0 C I A T E 5 ] 1 Groundwater from the Site may reach nearby surface waters and serve as an indirect exposure pathway for aquatic organisms. The potential environmental impact of groundwater discharging into surface water is evaluated for ecological receptors in Section 5.0 - Environmental Risk Characterization. 2.4.1.2 Identification of Exposure Routes The exposure route describes how a receptor may contact contaminants at a site. The exposure routes identified for quantitative analysis in this risk characterization are: " Incidental ingestion of and dermal contact with soil, and inhalation of airborne particulates by construction workers; * Incidental ingestion of and dermal contact with soil by trespassers; * Incidental ingestion of and dermal contact with soil, and ingestion of homegrown produce by future residents; e Incidental ingestion of and dermal contact with sediments by trespassers; and e Dermal contact with surface water by trespassers. Other exposure routes that were considered for quantitative analysis in the evaluation of current and unlimited future use, but determined not to be complete or not to contribute significantly to overall risk, were: * Incidental ingestion of and dermal contact with soil by Site workers, utility workers, and landscapers; * Inhalation of fugitive dust by residents and workers; * Inhalation of volatile compounds released from soils into outdoor air by construction/utility workers; and * Dermal contact with groundwater/surface water and inhalation of volatiles released from groundwater/surface water in a trench by construction/utility workers. Site worker, utility worker, and landscaper exposure to impacted soils may occur if the Site use in the future is changed. Future soil exposures to these receptors were not quantitatively evaluated, as construction worker direct contact exposure to Site soil is evaluated and considered to be protective of these lesser-exposed receptors. Construction worker direct contact exposure to soil would be of a higher frequency and/or duration of exposure than for these other receptors. Inhalation of fugitive dusts by residents and workers was not quantitatively evaluated. Inhalation of fugitive dusts is evaluated for construction workers. Under the condition that the impacted soils are excavated in the future, it is likely that the construction workers would be the maximum exposed individuals, and potential risks to residents and utility workers would be lower. 40 Forest Street, Attleborough 12 8/28/2008 5075-09-01 AttleboroM3text EIi22 O'Reilly, Talbot & Okun +_ 4 P-+ [ A S S 0 C I A T E S I The COCs for soils at the Site do not include volatile compounds. Therefore, inhalation of volatile compounds released from soils into outdoor air by construction/utility workers is not a complete exposure pathway. Pathways for the construction/utility workers that involve groundwater/surface water exposures, including dermal contact with and inhalation of volatiles in ambient air released from groundwater/surface water in a trench, were not evaluated quantitatively. Subsurface excavation for utility work is typically to a depth of 6 feet, while construction work may occur to a depth of 15 feet. It is possible that construction/utility work could occur at or below the water table and in surface water. For construction/utility excavations in water, dermal absorption of volatiles and in contact with the skin, and inhalation of volatiles by construction/utility workers are not considered to be significant exposure pathways. The COCs for soils at the Site do not include volatile compounds. In addition, direct contact with groundwater would generally be experienced only occasionally by laborers regarding dewatering, an activity that would result in short-term exposure (MassDEP, 1996b). It is not considered standard procedure for workers to enter an excavation containing water. It is assumed that Occupational Safety and Health Administration (OSHA) regulations and standard health and safety procedures, regarding sloping of trench excavations, water in trenches, and atmospheres in trenches, would be followed. 2.4.1.3 Exposure Profile Summary Exposure profile summaries bring together the different elements of the exposure profile to develop complete exposure pathways for each receptor. RECEPTOR TYPE OF AGE OF EXPOSURE EXPOSURE EXPOSURE RECEPTOR MEDIA PATHWAY Construction Subchronic Adult Soil Incidental Ingestion Worker Dermal Contact Inhalation of Airborne Particulates Trespasser Chronic Youth Soil Incidental Ingestion Dermal Contact Sediment Incidental Ingestion Dermal Contact Surface Water Dermal Contact Future Chronic Youth Soil Incidental Ingestion On-Site Dermal Contact Resident Ingestion of Homegrown Produce 40 Forest Street, Attleborough 13 8/28/2008 5075-09-01 AttleboroM3text ENIEEIG O'Reilly , Talbot & Okun 4 -- y [ A S S 0 C I A T E S ] 2.4.2 Development of Exposure Factors Exposure factors, also referred to as exposure assumptions, are numerical estimates of the magnitude and duration of exposure that receptors may have to Site OHM. For construction workers, trespassers, and residents exposure to soil, the MassDEP Shortformsfor Human Health Risk Assessment under the MCP (sV6rs) (MassDEP, 2007) were used for exposure assumptions and equations. For trespasser exposure to sediment and surface water, exposure assumptions were selected to be consistent with MassDEP parameters for the receptor (e.g., age and body weight). Site-specific assumptions were selected for frequency and duration of exposure based on accessibility and condition of the wetlands (e.g., not used for formal recreation). These exposure assumptions and equations for estimating exposures are presented in: * Table 7 - Construction Workers - Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates * Table 8 - Trespasser - Incidental Ingestion of and Dermal Contact with Soil * Table 9 - Resident - Incidental Ingestion of and Dermal Contact with Soil, and Ingestion of Homegrown Produce * Table 10 - Trespasser - Incidental Ingestion of and Dermal Contact with Sediment * Table 11 - Trespasser - Dermal Contact with Surface Water 2.4.3 Exposure Point Concentrations Exposure Point Concentrations, or EPCs, are the concentrations of OHM in a medium representative of the concentration a receptor may be exposed to over the course of an exposure. EPCs are calculated separately for each OHM and each medium. The soil, groundwater, sediment, and surface water data presented in Section 2.2.1 of this report and in Tables 1, 2, 3, and 4, respectively, were evaluated for the development of EPCs. Groundwater EPCs are generally represented by detected concentrations in each individual well, while soil EPCs may represent an arithmetic average concentration within an affected area or over the entire Site. The Site data were first evaluated to determine if a "hot spot" area(s) is (are) present. Hot Spots A hot spot is defined as a discrete area where concentrations of OHM or the thickness of NAPL are substantially higher than those present in the surrounding area. A hot spot can be identified based on consideration of both the concentrations or thickness of an OHM within a contaminated area and the spatial pattern of that contamination. 40 Forest Street, Attleborough 14 8/28/2008 5075-09-01 AttleboroM3text it O'Reilly , Talbot & Okun 4- 0-- [ A s S 0 C I A T E S ] A discrete area where the average concentration within the area is greater than 10 but less than 100 times the average concentration in the immediate surrounding area is a hot spot, unless there is no evidence that the discrete area would be associated with greater exposure potential than the surrounding area. In all cases, a discrete area where the concentration of OHM is greater than 100 times the concentration in the surrounding area is considered a hot spot. In addition, a hot spot cannot be created as a result of a remedial action (MassDEP, 2005), such as soil excavation. Data from the affected areas of the Site were evaluated to identify potential "hot spots". No hot spots were identified. Soil The MCP (310 CMR 40.924(2)(b)(3)) specifies that for current and potential soil exposures, the following depths should be considered, with any applicable Site-specific information, when determining EPCs: 1. 0 to 3 feet for exposures associated with surficial activity; 2. 0 to 6 feet for exposures associated with utility installation and repair; 3. 0 to 15 feet for exposures associated with excavation scenarios and building construction. In this Method 3 Risk Characterization, three sets of soil EPCs were developed for human health risk characterization and for comparison to upper concentration limits (UCLs) in the Public Welfare Risk Characterization (Section 3.0). The EPCs were developed for the Site using soil sample data collected in 2002, 2005, 2007, and 2008. The first set of soil EPCs are developed for soil with metal fragments present. These soils are currently covered with pavement or cap (marker fabric and soil). The soil samples in this data set are KE1, KE2, and TP-1 through TP-10, and TP-12 through TP-14. The EPCs are developed as the average of the detected concentrations. The second set of soil EPCs are developed for soil with no metal fragments present in soil and currently covered with pavement or cap (marker fabric and soil). The soil samples in this data set are TP-11, -15, -16, and -17. The EPCs are developed as the average of the detected concentrations. The third set of soil EPCs are developed for soils that are unpaved and uncapped. The soil samples in this data set are SS-1 through SS-9, and MW-1. The EPCs are the maximum detected concentrations. Soil EPCs are presented in Table 12. Risks from soil exposure for the three sets of soil EPCs were calculated for construction workers, trespassers, and future residents. 40 Forest Street, Attleborough 15 8/28/2008 5075-09-01 AttleboroM3text I O'Reilly Talbot & Okun 4-- S--k [ A ss D C I A T E S I Groundwater The groundwater EPCs used to evaluate potential impacts to aquatic receptors (Section 5.0) are the detected concentrations of COCs (Table 2). Sediment The sediment EPCs used to evaluate direct contact exposures to sediment and potential impacts to aquatic receptors (Section 5.0) are the detected concentrations of COCs (Table 3). Surface Water The groundwater EPCs used to evaluate potential impacts to aquatic receptors (Section 5.0) are the detected concentrations of COCs (Table 2). The surface water EPCs used to evaluate potential impacts to aquatic receptors (Section 5.0) are the detected concentrations of COCs (Table 4). 2.4.4 Calculation of Average Daily Doses The average daily dose (ADD) is a quantitative estimate of how much of each compound is taken into the receptor's body during exposure. The ADD is expressed as milligrams of OHM per kilograms of body weight per day. The general form of the dose equation is: ADD = (Total Amount of OHM Contacted) * (RAF) (Body Weight) * (Averaging Period) ADDs are calculated differently for assessment of carcinogenic and non-carcinogenic effects from ingestion and dermal contact exposures. For assessment of non-carcinogenic effects, the ADD is averaged over the exposure period. The resulting ADD is an estimate of dose experienced during the actual period of exposure. Averaging Periodnon-caranogeic = Exposure Period For carcinogenic effects there is assumed to be no threshold level, and exposures are cumulative over a lifetime. The dose received is, therefore, averaged over a lifetime (70 years) instead of over just the exposure period. The resulting dose estimate is referred to as a lifetime average daily dose, or LADD. Averaging Periodcarinogeic = Lifetime (70 years) 40 Forest Street, Attleborough 16 8/28/2008 5075-09-01 AttleboroM3text O'Reilly , Talbot & Okun +- ENIEEa Gb -k [ A S S O C I A T E S ] The average daily exposure (ADE) is a quantitative estimate of applied concentration of each compound for the receptor during exposure. The ADE is expressed as micrograms (jg) per cubic meter of air (n 3) and is based on the exposure point concentration (EPC) and an adjustment for the amount of time the receptor spends in the area with contaminated air. The general form of the exposure equation is: ADE = EPC * Exposure Duration * Exposure Frequency * Exposure Period * Conversion Factors Averaging Period As with ADDs, ADEs are calculated differently for assessment of carcinogenic and non- carcinogenic effects. For assessment of non-carcinogenic effects, the ADE is averaged over the exposure period. The resulting ADE is an estimate of dose experienced during the actual period of exposure. Averaging Periodnon-cacinosenic = Exposure Period For carcinogenic effects there is assumed to be no threshold level, and exposures are cumulative over a lifetime. The exposure received is therefore averaged over a lifetime (70 years) instead of over just the exposure period. The resulting exposure estimate is referred to as a lifetime average daily exposure, or LADE. 1. Incidental Ingestion Doses for Soil The derivations of ADDs for the incidental ingestion route are encoded into the calculation of risk estimates in the MassDEP shortforms for construction workers (Table 13), trespassers (Table 14), and future residents (Table 15). Incidental ingestion is assumed to occur due to hand-to-mouth activity. 2. Dermal Contact Doses for Soil The calculations of estimated dermal contact route ADDs are encoded into the calculation of risk estimates in the MassDEP shortforms for construction workers (Table 13), trespassers (Table 14), and future residents (Table 15). Estimates of OHM contacted were calculated based on compound concentrations, the amount of skin exposed, and the amount of soil adhering to the skin. The ADD equation assumes that the exposed skin is coated with soil once per event/day. 3. Inhalation of Airborne Particulates The calculation of ADEs for inhalation of airborne particulates for construction workers are encoded into the calculation of risk estimates in the MassDEP shortforms (Table 13). 40 Forest Street, Attleborough 17 8/28/2008 5075-09-01 AttleboroM3text O'Reilly, Talbot & Okun4- ENIE RING 0-- [A S S 0 C I A T E S ] 4. Ingestion of Homegrown Produce The calculations of ADDs for the ingestion of homegrown produce for residents are encoded into the calculation of risk estimates in the MassDEP shortform (Table 15). 5. Incidental Ingestion Doses for Sediment The derivations of ADDs for the incidental ingestion for sediment by trespassers are presented in Table 16. 6. Dermal Contact Doses for Sediment The calculations of estimated dermal contact route ADDs for sediment by trespassers are presented in Table 16. 7. Dermal Contact Doses for Surface Water The calculations of estimated dermal contact route ADDs for surface water by trespassers are presented in Table 17. 2.5 Human Health Risk Characterization Risk characterization is the final step in the risk assessment process. In this step, the results of the Hazard Assessment, Dose-Response Assessment, and Exposure Assessment are combined to yield quantitative estimates of incremental risk posed by potential exposures to environmental media at the Site. Separate estimates of potential cancer and non-cancer risk are made for each receptor and are discussed below. These estimates are compared to risk management criteria to establish whether a Condition of No Significant Risk is present. 2.5.1 Non-Cancer Risk The indicator used to describe the potential for non-carcinogenic health effects is the Hazard Index (HI). For a given chemical, the HI is the ratio of a receptor's exposure level (or dose) to the level of exposure considered to be safe. In this risk characterization, a safe level of exposure is represented by the RfD or RfC for each compound. An HI that does not exceed 1 indicates the receptor's exposure to that compound is without risk of adverse health effect. Hazard Index = ADD/RfD or Hazard Index = ADE/RfC 40 Forest Street, Attleborough 18 8/28/2008 5075-09-01 AttleboroM3text I O'Reilly, Talbot & Okun --- t A S S 0 C I A T E 5 ] When the Hazard Indices for each of the compounds of concern at the Site are summed for each receptor, the result is a total Site Hazard Index. This total Site Hazard Index is referred to as a screening HI because it does not segregate different compounds of concern based on their mode of toxicological activity. Thus, when used as an indicator of total Site non- carcinogenic risk, the screening HI is likely to overstate the actual level of non-carcinogenic risk. If the screening level HI is not greater than 1, this indicates there is no significant non- carcinogenic health risk associated with Site exposures. If the screening level HI is greater than 1, this HI is segregated by toxicity endpoint. The hazard indices are presented in Tables 13 through 17 and are summarized in Table 18. This summary indicates that under current and foreseeable future use of the Site, the HIs do not exceed 1, indicating that a Condition of No Significant Risk exists for these receptors, with three exceptions. The HI for construction workers for soils that contain metals fragments and are paved or capped exceeds 1. In addition, the HIs for future residents for soils that contain metals and do not contain metals that are paved or capped exceed 1. These findings indicate that a Condition of No Significant Risk for non-cancer effects does not exist for these receptors and Site conditions. 2.5.2 Cancer Risk The potential for carcinogenic health effects is estimated as the Incremental Excess Lifetime Cancer Risk (ELCR). The ELCR represents the incremental probability of an exposed individual developing cancer over a lifetime as a result of exposure. For each chemical, the ELCR is the product of the Lifetime Average Daily Dose (LADD) or Lifetime Average Daily Exposure (LADE) and that compound's carcinogenic potency. The indicator of carcinogenic potency used in this risk characterization is the EPA Cancer Slope Factor (CSF) or Unit Risk. ELCR LADD x CSF or ELCR LADE x Unit Risk As in the case of non-cancer risk, the ELCRs for each of the different compounds and pathways are summed to produce a receptor-specific cumulative ELCR. This cumulative ELCR is compared to the risk management criterion of 1 x 10-5 (one in one hundred thousand). A cumulative ELCR that does not exceed 1 x 10-5 indicates that no significant carcinogenic risk is present due to OHM at the Site. A cumulative ELCR greater than 1 x 10-5 indicates a potential for significant cancer risk is present as defined by the MCP. The ELCRs are presented in Tables 13 through 17 and are summarized in Table 18. The ELCRs for construction workers, trespassers, and future residents are less than 1 x 10-5 indicating that a Condition of No Significant Risk exists for these receptors, with two exceptions. 40 Forest Street, Attleborough 19 8/28/2008 5075-09-01 AttleboroM3text ENIE NG O'Reilly Talbot & Okun M.-- I A $ $ 0 C I A T E $ ] The ELCRs for future residents for soils with or without metals present in paved or capped soils exceed 1 x 10- indicating that a Condition of No Significant Risk does not exist for this receptor and Site conditions. 2.5.3 Summary of Findings 1. The cumulative hazard index values and ELCRs for construction workers from soil exposures are not greater than the MassDEP's risk management criteria of 1 and 1 x 10-5, respectively, indicating a Condition of No Significant Risk for non- cancer and cancer risks for this receptor, with one exception. The hazard index value for soils with metals present that are paved or capped exceed 1, indicating that a Condition of No Significant Risk for noncancer risks for construction workers in this area of the Site does not exist. 2. The cumulative hazard index values and ELCRs for trespassers from soil, sediment, and surface water exposures are not greater than the MassDEP's risk management criteria of 1 and 1 x 10-5, respectively, indicating a Condition of No Significant Risk for non-cancer and cancer risks for this receptor. 3. The cumulative hazard index values and ELCRs for future on-Site residents from soil exposures that are currently are not paved/capped are not greater than the MassDEP's risk management criteria of 1 and 1 x 10-s, respectively, indicating a Condition of No Significant Risk for non-cancer and cancer risks for this receptor. However, the hazard index value and ELCR for soils with metals present or no metals present that are paved or capped exceed 1 and 1 x 10-5, respectively, indicating that a Condition of No Significant Risk for noncancer and cancer risks for future residents in these areas of the Site does not exist. 4. Vapor intrusion from soil and groundwater is not considered to be a complete, significant exposure pathway under current and future Site conditions. No buildings are currently located or planned for the Site. Volatile compounds are not COCs for groundwater and soil. 5. There are no current direct, complete exposure pathways related to groundwater. 6. There are no exceedances of applicable or suitably analogous standards. A Condition of No Substantial Hazard for human health exists at the Site based on current activities and uses. A Condition of No Significat Risk exists for trespassers on the Site. However, A Condition of No Significant Risk does not exist for construction workers and future on-Site residents. Therefore, an AUL is required to achieve and maintain a Condition of No Significant Risk under current and foreseeable future activites and uses. An AUL is required to restrict activities in the AUL area, such that direct contact exposure to soil is controlled. For construction worker, excavation is permitted in the AUL area with the implementation of a Health and Safety Plan and Soil Management Plan. 40 Forest Street, Attleborough 20 8/28/2008 5075-09-01 AttleboroM3text NGNERIG O'Reilly Talbot & Okun +- P_4+ I A S S 0 C I A T E S ] For future on-Site residents, an AUL is required to ensure that the soil in the AUL area is not accessible for direct contact soil exposure. Under these requiremets of the AUL, a Condition of No Significant Risk exists for the Site. 2.6 Uncertainty Analysis The risk assessment process uses information from a variety of sources, such as analytical data from the Site investigation and toxicity data from published research. This information is combined with assumptions regarding potential receptors and Site use. Uncertainties may be present in each of these assumptions, and may affect the outcome of the risk assessment. The risk assessment was developed to be a conservative estimate of potential adverse health effects. Its results should not be interpreted as definitive quantitative values. Uncertainties in the various portions of this risk assessment are discussed below. A. Hazard Identification The identification of constituents present in soil and groundwater and their distribution across the Site are dependent upon the sampling and analytical program conducted. Conservative assumptions were made in developing EPCs that likely lead to overestimates of actual exposure point concentrations. EPCs were based on detected concentrations in samples collected from higher concentration areas. Sampling programs tend to focus on areas of higher concentration, resulting in a high-end estimate of the EPC. B. Exposure Assessment There is uncertainty associated with exposure assessment because the range of potential human activity is broad. Variability is associated with differences between individual receptors, such as body weight, skin surface area, and rates of soil or water ingestion. Conservative assumptions that are consistent with those recommended by MassDEP risk guidance documents have been used in developing pathway exposure factors that are anticipated to err on the side of protection of health. C. Dose-Response Assessment Toxicity information for many of the chemicals detected at the Site is associated with varying degrees of uncertainty. Sources of uncertainty for toxicity values (EPA, 1989) may include: " Using dose-response information from effects observed at high doses to predict the adverse health effects that may occur following exposure to low levels expected from human contact with the agent in the environment; e Using dose-response information from short-term exposure to predict the effects of long-term exposures, and vice-versa; * Using dose-response information from animal studies to predict effects in humans; 40 Forest Street, Attleborough 21 8/28/2008 5075-09-01 AttleboroM3text ENTEE]G O'Reilly, Talbot & Okun -4-- [ASS 0 CI AT ES] * Using dose-response information from homogeneous animal populations or healthy human populations to predict the effects likely to be observed in the general population consisting of individuals with a wide range of sensitivities. Most of the toxicity values used in this risk characterization are EPA-verified RfDs/RfCs and slope factors. These values, as presented in IRIS, are derived using a number of safety factors and are accompanied by a statement of confidence in the value itself, the critical study, and the overall data base for RfDs/RfCs, and the weight-of-evidence classifications for slope factors. MassDEP has derived toxicity values for VPH carbon fractions using a reference surrogate compound approach for these complex mixtures of hydrocarbons (MassDEP, 2003). The method involves segregating the petroleum hydrocarbons present in mixtures into broad chemical classes and further into subgroups or fractions based upon their size, and with consideration of comparative toxicity and structure activity relationships (SARs). For each subgroup of compounds, a reference compound was initially identified to represent the toxicity of all compounds in the range. The compound was usually chosen because its toxicity was relatively well characterized. For each reference compound, an EPA published value was identified or a value was identified based on available toxicity information. D. Risk Calculations The risk calculations were performed using a deterministic methodology as provided for under MCP guidance. In a deterministic methodology, a single value (point estimate) is used for exposure parameters and exposure point concentrations. The result is that a single risk value is calculated for each scenario and receptor of concern. However, the use of a mix of mid-range and conservative exposure assumptions is intended to produce realistic upper-end exposure estimates, which will be protective of public health and produce risk estimates that will be valid for comparison to MCP Cumulative Risk Limits (MassDEP, 1995). 3.0 CHARACTERIZATION OF RISK OF HARM TO PUBLIC WELFARE The MCP defines two purposes for conducting a characterization of risk to public welfare: (a) to identify and evaluate nuisance conditions that may be localized, and (b) to identify and evaluate significant community effects. The characterization of risk to public welfare considers effects that are or may result from the presence of residual contamination or the implementation of a proposed remedial alternative (310 CMR 40.0994). The characterization of the risk of harm to public welfare considers Site, receptor, and exposure information, as well as data collected pursuant to the response action(s) being performed. 40 Forest Street, Attleborough 22 8/28/2008 5075-09-01 AttleboroM3text ENIEEIGT O'Reilly, Talbot & Okun N-+ [ A S S 0 C I A T E S ] The characterization of risk of harm to public welfare also considers such factors as the existence of nuisance conditions, loss of active or passive property use(s), and any non- pecuniary effects not otherwise considered in the characterization of risk of harm to health, safety, and the environment, but which may accrue due to the degradation of public resources directly attributable to the release or threat of release of OHM or the remedial alternative (310 CMR 40.0994(2)). The risk of harm to public welfare is characterized by comparing the Site-wide EPCS of OHM to the Upper Concentration Limits in Soil and Groundwater or UCLs [as defined in 310 CMR 40.0996]. In addition, a level of No Significant Risk of harm to public welfare exists or has been achieved, if no nuisance conditions, such as noxious odors, persist. The EPCs derived for soil (Table 12) and groundwater concentrations (Table 2) do not exceed the numerical UCLs. Non-aqueous phase liquid (NAPL) has not been observed in Site monitoring wells.. The Site has been shown to contain soils impacted by constituents that may possess an odor at close range. The impacted soils at the Site are located at depths of 0 to 16 feet in paved, capped, or unpaved areas. Intermittent odors may occur if affected soils at the surface. For petroleum-contaminated sites, MassDEP guidance (MassDEP, 2002d) has suggested rules of thumb for determining when an odor condition would generally not be considered a nuisance condition. The rules of thumb that would be applicable to potential intermittent odors are: 1. Odors observed in the subsurface during excavation or boring advancement would generally not be considered a nuisance condition, as long as such odors are not detectable in ambient or indoor air, and as long as there are no plans to excavate or disturb such areas. 2. Odors observed in the breathing zone of the ambient air, or indoor air of an impacted structure, would generally not be considered a nuisance condition, if such odors do not persist for more than 3 months. 3. Odors observed in the breathing zone of the ambient air would generally not be considered a nuisance condition if they are discernable less than 10 days a year. 4. Odors observed in the ambient air or indoor air of an affected structure would generally not be considered a nuisance condition if the occupants of such a structure do not believe such odors significantly affect or degrade their quality of life. Potential odors are not believed to pose a significant risk to public welfare based on these rules of thumb being met and the infrequent occurrence and low potential for exposure at the Site. Therefore, there is No Significant Risk to public welfare for soils or groundwater at the Site under current and foreseeable future conditions. 40 Forest Street, Attleborough 23 8/28/2008 5075-09-01 AtdeboroM3text EE O'Reilly , Talbot & Okun [ A S S 0 C I A T E S ] 4.0 CHARACTERIZATION OF RISK OF HARM TO SAFETY The risk of harm to safety, as described in 310 CMR 40.0960, was evaluated for the Site. The Site exhibits the following safety-related characteristics: 1. There are no rusted or corroded drums or containers, open pits, lagoons, or other dangerous structures at the Site; 2. There is no threat of fire or explosion from the presence of explosive vapors resulting from the release of OHM at the Site; and 3. There are no containerized materials at the Site exhibiting the characteristics of corrosivity, reactivity, or flammability. The areas of the Site with metal fragments present at the surface have been paved or capped. Therefore, there is not a risk of harm to safety due to conditions at the Site. 5.0 ENVIRONMENTAL RISK CHARACTERIZATION OTO completed a Method 3 Stage I Environmental Screening for the Site in December 2005. Subsequent to the completion of the 2005 report, no additional analytical sediment and surface data was collected. The results of the 2005 Stage I are presented in the subsequent section. Remedial actions completed at the Site since this 2005 report that relate to environmental exposures and risks are discussed below. In accordance with Section 40.0995 of the MCP, this section of the risk assessment evaluates possible ecological risks due to OHM in soils, groundwater, sediment, and surface water at the Site. For the Site, a Stage I Environmental Risk Screening was conducted. The Stage I Screening steps are: 1. Identify complete Exposure Pathways [310 CMR 40.0995 (3)(a)], 2. Determine whether Readily Apparent Harm Exists [310 CMR 40.0995 (3)(b)], and 3. Establish if Potentially Significant Exposures Exist [310 CMR 40.0995 (3)(c)]. If there are complete exposure pathways, then for each complete exposure, Site conditions are evaluated to determine when significant environmental harm is "readily apparent" and if the potential exposure is significant. If there are no complete exposure pathways, no further action to assess readily apparent harm or potentially significant exposures is required (MassDEP, 1996a). The Stage I screening for potential ecological receptors has been conducted separately for aquatic and terrestrial habitats. 40 Forest Street, Attleborough 24 8/28/2008 5075-09-01 AttleboroM3text O'Reilly, Talbot & Okun 4 ENGNEIG 10-+ L A 5 5 0 C I A T E S ] 5.1 Site Environmental Setting The Site property is relatively flat with wetlands to the east and the Bungay River to the northwest. The access road extends through the wetlands, and the wetlands that surround the access road are part of the disposal Site. The wetland is a red maple (Acer rubra) swamp, but on the east side of the access road is a small emergent marsh that is dominated by reeds (Phragmites australis The marsh has been created within the red maple swamp as the result of the hydrologic constriction caused by the access road. 5.2 Aquatic Habitat Screening Complete Exposure Pathways - Four criteria are identified in the MCP (310 CMR 40 .0995(3)(a)(1)) to assess whether there is evidence of current or potential future exposures to aquatic environmental receptors: a. Evidence that OHM have come to be located in a surface water body or wetland, b. Evidence that OHM have had an adverse impact on aquatic biota, c. The presence of OHM in a surface water body or wetland as indicated by analytical data, and d. The potential for transport of OHM in groundwater or surface runoff to aquatic receptors. As defined in the MCP, there is evidence of current or potential future exposures based on the following findings. a. There is visible physical evidence of OHM at the Site. The materials (i.e., metal shavings) used to construct the access road were visible at the surface prior to the paving or capping of the road in 2008. In addition, significant debris has also been observed by Jacques Whitford associated with the former auto repair shop/current Crown Limousine on the west and east sides of access road; beginning at Eddy Street and extending north. In April 2001, a MassDEP employee observed the presence of an oil sheen on surface water and determined that the source of the release was from a continuous or intermittent release of oil from the property. In 2003, Eco-Solutions noted a sheen present on the water's surface along the west side of the access road (SS-4 and SS-5). However, the sheen appeared to be a methanogenic natural sheen. b. Based on observations made by WME, Jacques Whitford and Eco-Solutions, there is no physical evidence of environmental impacts, such as fish kills and abiotic conditions. 40 Forest Street, Attleborough 25 8/28/2008 5075-09-01 AttleboroM3text T O'Reilly Talbot & Okun 4- ENERN [ A S S 0 C I A T E 5 ] c. Sediment and surface water exposure point concentrations (EPCs) (Tables 19 and 20, respectively) have been derived based on their locations adjacent to the access road (east and west), adjacent to other potential sources (outfall pipe and former auto repair/Crown Limousine), and in the inner wetlands (east and west). A comparison of the concentrations of the detected analytes in these subareas was conducted to determine if the presence of OHM in sediment and surface water are attributable to the Site. If the source concentrations cannot be discerned from other concentrations, this could indicate that "local conditions" are present. The MassDEP defines local conditions as levels of OHM present consistently and uniformly throughout the surface water body, or throughout a larger section of the river that contains the area potentially affected by contamination at or from the Site. If concentrations of an OHM are consistent with local conditions, exposure to contaminants from the Site may not be discernible, and thus incremental risk may not be quantifiable (MassDEP, 1996a). Sediment - A review of the sediment EPCs (Table 19) indicates that the highest concentrations of EPH in historical samples (2002) were detected in locations directly adjacent to the access road (SS-5 and SS-2). In the recent (2005) data, EPH concentrations were highest adjacent to the outfall pipe (SS-21), and possibly adjacent to the west side of the access road (SED-17 and SED-18: EPH not detected at detection limits of 187 and 170 mg/kg, respectively). PAHs were not detected or were detected at low concentrations in samples collected from the east side of the access road and inner wetlands. The PAH concentrations were highest in the sediment samples collected from adjacent to the former auto body shop/Crown Limousine (SED-16 & SED-15), the outfall pipe (SS-21), and the west side of the access road (SS-4, SS-5, and SS-22). The concentrations of heavy metals (arsenic, cadmium, chromium, mercury, and lead) were highest in sediment samples collected from adjacent to the former auto body shop/Crown Limousine (SED-16 & SED-15), and the west side of the access road (SED-17, SED-18, and SS-22). PCBs were analyzed for in two samples: SS-22 (adjacent to the west side of the access road) and SS-23 (adjacent to the east side of the access road). The concentrations of PCBs in SS-22 (1.71 mg/kg) are approximately 10 times higher than the concentrations of PCBs in SS-23 (0.175 mg/kg). These sediment data indicate that OHM are present in sediment at the Site. However, there is a clear pattern that shows concentrations are the highest directly adjacent to the former auto repair/Crown Limousine, to the west side of the access road, and the outfall pipe. 40 Forest Street, Attleborough 26 8/28/2008 5075-09-01 AtdeboroM3text EN R O'Reilly Talbot & Okun [ A S S O C I A T E S The concentrations of the same OHM are generally lower or not detected in samples collected from adjacent to the east side of the access road, and the inner wetlands to the east and west of the access road. This indicates that surface runoff from the access road, and other source areas, are contributing to the localized presence of OHM. Readily Apparent Harm - There is a potential for "readily apparent harm" to the aquatic environment associated with materials at the Site based on the presence of metals in surface water. a. There is no visual evidence of stressed biota attributable to the release, such as fish kills or abiotic conditions. b. The concentrations of several metals (silver, cadmium, chromium, and lead) in surface water samples SW-1 (adjacent to the former auto repair shop/Crown Limousine) and SW-5 (inner wetlands east of the access road) exceed the MassDEP Lowest Ecologically Based Criteria (LOEC), which include USEPA National Ambient Water Quality Criteria (NAWQC) (Table 20). However, the concentrations of each of these metals in SW-1 were greater than in SW-5. In addition, the concentrations of lead in SW-4 (adjacent to the east side of the access road), SW-2 (inner wetlands west of the access road), and SW- 3 (adjacent to the west side of the access road) exceed the MassDEP LOEC. This indicates that metals in surface water may be attributable to the runoff from the access road, as well as other non-Site related debris (i.e., "local conditions"). c. For sediment, there is no visible presence of oil, tar, or other non-aqueous phase hazardous material over an area equal to or greater than 1,000 square feet in sediment within one foot of the sediment surface. Significant Exposure Pathways - The potential exposures identified above cannot be ruled out as being totally attributed to the Site or to "local conditions". Therefore, "potentially significant exposures" associated with the Site may exist based on the following: a. As indicated in the previous section, the detected concentrations reported in Site surface water samples that may be attributed to the Site exceed MassDEP LOECs. However, the surface water concentrations near other sources of metals (SW-1) exceed the MassDEP LOECs by a greater degree (Table 20). b. The concentrations of metals (cadmium, chromium, mercury, and/or lead) in Site sediments (SED-17, SED-18, and SS-22) and PCBs (SS-22 and SS-23) that may be attributed to the materials in the access road exceed MassDEP Consensus-Based Threshold Effect Concentrations (TECs). However, the concentrations of these four metals in sediments near the former auto repair/Crown Limousine (SED-16) were higher and also exceeded the MassDEP TECs (Table 19). In addition, the concentrations of PAHs adjacent to the outfall pipe (SS-21), and the former auto repair/Crown Limousine exceed the MassDEP TECs by a greater degree than sediments along the access road and in the inner wetlands. 40 Forest Street, Attleborough 27 8/28/2008 5075-09-01 AttleboroM3text T O'Reilly, Talbot & Okun E E 0-+ [A 5 5 0 C I A T E S ] c. The existing groundwater concentrations at the access road indicate that groundwater discharge into the wetlands is not the likely migration pathway. No EPH, PAHs, or the RCRA 8 metals were detected or they were detected at concentrations that did not exceed the MCP Method 1 GW-3 standards (Table 2). Therefore, it was OTO's opinion that current and future conditions at the Site, prior to remedial actions, may represent "potentially significant exposures" to ecological aquatic receptors from metals, PCBs, and PAHs present in materials in the access road. However, the access road has been paved or capped, thereby, mitigating surface runoff from the access road that may further impact the wetlands. However, the materials associated with the former auto repair shop/Crown Limousine (metals and PAHs) and the outfall pipe (PAHs) also contribute to the exposures, and in some cases contribute more to exposures. Based on the criteria outlined in the MCP, 310 CMR 40.956, a Condition of No Substantial Hazard exists for aquatic receptors in the wetlands. 5.3 Terrestrial Habitat Screening Complete Exposure Pathways - The analytical data for soils collected at the Site (Table 1) indicate that the highest OHM (i.e., PCBs, EPH, PAHs, and the RCRA 8 metals) were detected in the samples collected at the surface. The natural vegetation on and along the access road is limited. The accessible, impacted soils have been reported at a depth of 0-3 feet. Therefore, terrestrial plants and wildlife could directly contact these impacted Site soils under premeditated conditions. In addition to a potential for chemical exposure, there is a potential for physical exposure. In Eco-Solutions' Method 3 Risk Characterization, it was noted that there is a physical hazard to wildlife and turtles that use the road as a corridor and may attempt to burrow into the road bank. This hazard is associated with the presence of sharp metal turnings in the soil used to construct the access road. However, the access road has been paved or capped, thereby, mitigating direct contact exposure to terrestrial receptors. Readily Apparent Harm - For soil, there is no visible presence of oil, tar, or other non- aqueous phase hazardous material within three feet of the ground surface over an area equal to or greater than two acres. Therefore, there is no "readily apparent harm" to the terrestrial environment. Significant Exposure Pathways - A further evaluation of the presence of potentially significant exposure pathways was completed. Since no soil screening criteria are available, the terrestrial habitat has been screened on the basis of its size. 40 Forest Street, Attleborough 28 8/28/2008 5075-09-01 AttleboroM3text ENtEEIG O'Reilly, Talbot & Okun -4 [ A S S 0 C A T E S ]I For the purposes of this screening, the size of undeveloped/open land at the Site determines the specific evaluation of terrestrial environments. MassDEP (1996a) states that for the purposes of the screening process, undeveloped/open land is characterized by the presence of native vegetation, and does not include landscaped residential and commercial parcels, landscaped parks, or golf courses. Based on this definition, the terrestrial open space on the Site is less than 2 acres in size. Therefore, no further action to characterize ecological risk is required for the Site unless: 1. Contaminant transport from surface soil to an Area of Critical Environmental Concern (ACEC) is possible, or 2. State-listed threatened or endangered species, or other species of special concern are present. According to the MassDEP Site Scoring map, the Site is not: 1. Within an ACEC nor is contaminant transport from surface soil to an ACEC possible, or 2. The location of state-listed threatened or endangered species, or other species of special concern. Based on the above information, potentially significant exposures do not exist for terrestrial ecological receptors potentially exposed to soils. Overall, a Condition of No Significant Risk to the environment does not exist. However, a Condition of No Substantial Hazard to the environment exists. 6.0 CONCLUSIONS In accordance with the Massachusetts Contingency Plan, 310 CMR 40.0990, we have conducted a Method 3 risk characterization for OHM located at 40 Forest Street in Attleborough, Massachusetts. To assess whether reported concentrations of OHM represent a Condition of No Significant Risk, this Method 3 risk characterization was completed. In accordance with the MCP, the Method 3 risk characterization included the following components: 1. Assessment of risks to human health, 2. Assessment of risks to public welfare, 3. Assessment of risk of harm to safety, and 4. Assessment of environmental risks. The risk characterization concluded that a Condition of No Significant Risk to public welfare and safety exists at the Site based on available Site data and exposures evaluated for current and foreseeable Site activities and uses. 40 Forest Street, Attleborough 29 8/28/2008 5075-09-01 AttleboroM3text t O'Reilly, Talbot & Okun ENaEEIG 1 --1 [ A S S 0 C I A T E ] The Method 3 Risk Characterization for human health evaluated potential exposures to soil by construction workers, trespassers, and future residents, and to sediment and surface water to trespassers. Vapor intrusion from soil and groundwater is not considered to be a complete, significant exposure pathway under current and future conditions. There are no current direct, complete exposure pathways related to groundwater. There are no exceedances of applicable and suitably analogous standards. A Condition or No Substantial Hazard to human health exists for the Site based on current activities and uses. A Condition of No Significant Risk exists for trespassers. However, A Condition of No Significant Risk does not exist for construction workers and future on-Site residents. Therefore, an AUL is required to achieve and maintain a Condition of No Significant Risk under specific current and foreseeable future Site activities and uses. An AUL is required to restrict activities in the AUL area, such that direct contact exposure to soil is controlled for construction workers and future on-Site residents. For construction workers, excavation is permitted in the AUL area with the implementation of a Health and Safety Plan and Soil Management Plan. For future on-Site residents, an AUL is required to ensure that the soil in the AUL area is not accessible for direct contact soil exposure. Under these requirements of the AUL, a Condition of No Significant Risk exists for the Site. A Condition of No Significant Risk to the environment does not exist due to potential harm to the wetlands. However, a Condition of No Substantial Hazard to the wetlands environment exists. 40 Forest Street, Attleborough 30 8/28/2008 5075-09-01 AttleboroM3text t O'Reilly, Talbot & Okun +- [ A 5 S 0 C I A T E S ] REFERENCES Battle. 2007. Sediment Toxicif ofPetroleum HydrocarbonFractions. Prepared by Battle, Duxbury, MA. Prepared for MassDEP, Office of Research and Standards, Boston, MA. September 2007. Massachusetts Department of Environmental Protection (MassDEP). 1992. Documentationfor the Risk Assessment Shorform ResidentialScenario. Policy #WSC/ORS-142-92. October 1992. Massachusetts Department of Environmental Protection. (MassDEP). 1994. Background Documentationfor the Development of the MCP NumericalStandards. April 1994. Massachusetts Department of Environmental Protection (MassDEP). 1995. Guidance for DisposalSite Risk Characterization- In Support of the Massachusetts Contingency Plan. July 199 5. Massachusetts Department of Environmental Protection (MassDEP). 1996a. Guidance for DisposalSite Risk CharacterizationIn Support ofthe Massachusetts Contingeny Plan * Chapter 9 *** Method 3 Environmental Risk Characterization.Bureau of Waste Site Cleanup and Office of Research and Standards. Interim Final Policy, BWSC/ORS-95-141. April 1996. Massachusetts Department of Environmental Protection (MassDEP). 1996b. Draft Commerial/IndustrialShortform Exposure Scenarios. December 1996. Massachusetts Department of Environmental Protection (MassDEP). 2002a. Background Levels of Polygclic Aromatic Hydrocarbons and Metals in Soil. Technical Update. May 2002. Massachusetts Department of Environmental Protection (MassDEP). 2002b. Calculation of an Enhanced Soil Ingestion Rate. Technical Update. April 2002. Massachusetts Department of Environmental Protection (MassDEP). 2002c. Weighted Skin- SoilAdherence Factors. Technical Update. April 2002. Massachusetts Department of Environmental Protection (MassDEP). 2002d. CharacteriZing Risks Posed by Petroleum Contaminated Sites: Implementation of MADEP VPH/EPHApproach and Background/SupportDocumentation. Final Policy. October 31, 2002. Policy #WSC-02-41 1. Massachusetts Department of Environmental Protection (MassDEP). 2003. Updated Petroleum Hydrocarbon Fraction Toxicity Values for the VPH/EPHMethodology. Final. November 2003. Massachusetts Department of Environmental Protection (MassDEP). 2005. Bureau of Waste Site Cleanup MasterMCP.Q&A 1993-2004. Massachusetts Department of Environmental Protection (MassDEP). 2006. Technical Update - Revised Sediment Screening Values. 40 Forest Street, Attleborough 31 8/28/2008 5075-09-01 AttleboroM3text I O'Reilly, Talbot & Okun --+ [ A S S 0 C I A T E S ] REFERENCES (Contd.) Massachusetts Department of Environmental Protection (MassDEP). 2007. ShortFormsfor Human Health Risk Assessment under the MCP. Revised February 2007. Massachusetts Department of Environmental Protection (MassDEP). 2008a. 310 CMR 40.0000, the Massachusetts Contingenc Plan. Effective February 14, 2008. Including spreadsheets for Development of MCP Risk-based Levels for Soil and Groundwater. Massachusetts Department of Environmental Protection (MassDEP). 2008b. Characterization of Risks Due to Inhalation of Particulatesby Construction Workers. Technical Update. Revised July 2008. United States Environmental Protection Agency (EPA). 1989. Risk Assessment Guidancefor Superfund, Volume I, Human Health Evaluation Manual (PartA). Interim Final. EPA/540/1 - 89-002. December 1989. United States Environmental Protection Agency (EPA). 199 7 a. Health Efects Assessment Summar Tables, FY 1997 - Update. EPA 540/R-97-036. July 1997. United States Environmental Protection Agency (EPA). 1997b. Exposure Factors Handbook. Office of Research and Development, EPA/600/P-95/002Fa. August 1997. United States Environmental Protection Agency (EPA). 2008. Integrated Risk Information System. Office of Health and Environmental Assessment. On-line database. August 2008. 40 Forest Street, Attleborough 32 8/28/2008 5075-09-01 AttleboroM3text I O'Reilly, Talbot & Okun 4-- a -- k [ A $ S 0 C l A T E $S '4. TABLES 40 Forest Street, Attleborough 8/28/2008 5075-09-01 AtdeboroM3text Table 1 Soil Analytical Results Sampling Location KE1&2 KE1 KE1 KE1 KE1 KE2 KE2 KE2* Method 1 Standards Date 3/7/2002 3/7/2002 3/7/2002 3/7/2002 6/14/2005 3/7/2002 3/7/2002 3/7/2002 S-1/GW-2 S-1/GW-3 Depth 0-3 0-3' 6-8' 15-16' 0.5-2' 0-3' 4-6' 13-15* PCBs 1.55 NT NT NT 275 NT NT NT 2 2 TPH 1 170 NT NT NT NT NT NT NT 800 800 EPH C9-C18 Aliphatics NT ND 35.3 ND 99.8 ND ND NT 1,000 1,000 C1 9-C36 Aliphatics NT 371 353 185 1,560 50.7 ND NT 2,500 2,500 C1 1-C22 Aromatics NT 196 123 75 257 38.4 ND NT 800 800 PAHs - Acenaphthene NT ND NO ND <0.157 ND ND ND 1,000 1,000 Acenaphthylene NT ND ND ND 0.181 ND ND ND 100 100 Anthracene NT ND ND ND <0.157 ND ND ND 1,000 1,000 Benzo(a)anthracene NT ND ND ND 0.185 0.429 ND ND 0.7 0.7 Benzo(a)pyrene NT ND ND ND 0.2 0.475 ND ND 0.7 0.7 Benzo(b)fiuoranthene NT ND ND ND 0.225 0.691 ND ND 0.7 0.7 Benzo(g,hi)perylene NT ND ND ND <0.157 ND ND ND 1,000 1,000 Benzo(k)fluoranthene NT ND ND ND 0.181 ND ND ND 7 7 Chrysene NT ND ND ND 0.209 0.473 ND ND 7 7 Dibenzo(a,h)anthracene NT ND ND ND <0.157 ND ND ND 0.7 0.7 Fluoranthene NT ND ND ND 0.402 0.846 ND ND 1,000 1,000 Fluorene NT ND ND ND <0.157 ND ND ND 1,000 1,000 lndeno(1,2,3-cd)pyrene NT ND ND ND <0.157 ND ND ND 0.7 0.7 2-Methylnaphthalene NT ND ND ND <0.157 ND ND ND 500 500 Naphthalene NT ND ND ND <0.157 ND ND ND 100 100 Phenanthrene NT ND ND ND <0.157 ND ND ND 1,000 100 Pyrene NT ND ND ND 0.336 0.785 ND ND 700 700 RCRA 8 Metals Silver NT NT NT NT 8.15 NT NT NT 100 100 Arsenic NT NT NT NT 53.6 NT NT NT 30 30 Barium NT NT NT NT 18.8 NT NT NT 1,000 1,000 Cadmium NT NT NT NT <0.553 NT NT NT 30 30 Chromium NT NT NT NT 12i NT NT NT 1,000 1,000 Mercury NT NT NT NT <0.208 NT NT NT 20 20 Lead NT NT NT NT 462 NT NT NT 300 300 Selenium NT NT NT NT <3.32 NT NT NT 400 400 Notes: All results presented In mgikg. NT- Not Tested; PC - Polychorinated Blphenyis; TPH - Total Petroleum Hydrocarbons; EPH - Extractable Petroleum Hydrocarbons: PAHa - Polycyclic Aromatic Hydrocarbons (PAMS); and ND - Not Detected above laboratory detection limits. * - Sample analyzed for semivolatiles via EPA Method 8270, not via the EPH Method. For detection limits of compounds indicated with not detected (ND) refer to the "Immediate Response Action Completion Statement Phase I Completion Statement & Tier Classification" dated April 2002, and completed by Kaegael Environmental, Inc. Page 1 of 2 Data Tables Soil 8/28/2008 C0 n 1CC easduvco-czzu z z$$$ z v v v ziz en oiflg3-- I- -r L u w AM m z z z z z z 00 u q r zzzzz z z z2 2z v 3v ZZZAdoZZ-Z'Z ve~ z z z tC soed~ozrzzzzzz V_zzco z I- VVVV_ z z z zz --- " enumn zeo zL z zz z z z z z zz zz z z z 00z V- ('7 -un --Ew-MclrnZ2ZZZZ2ZZ ZZ .6.2ZZZZ22do zzzgzz ~dzzzzzzzzzz,H *ue~03rrfluwntlzzz~zzz ~ I-.1- F- H I- 1H~- V S2 -I HHH u emAdsanzt-- I- - F P222 2N22Z="6M ZZ Z zzz n oOvS ered"zzzzzzzzczz zzz,,oo V zzzzzzzzzz"" V euinanjeedeagzzzzzzzzzz'Pzzz.oszzzzzzzzzz @ v V C 0 -.2 2226 22 Zzz 222 S 2 00 ovo -- 6N071(0 00 -"A *u~ow~v pP -" O zz zz zzzA z -vV- V- zz zz z .MC E *uqw ouontu zZZZZZZ2Z222' n zz - _ z zz~zz~lzzzzzC_ F -F N2zz ZZZ~z2 w' ,,MIS V 0- ,uwz HH zzzwqdwun_'lHH HH 0H H IzHH HI HH 3 2 7 0 2 2 2 2 2 2 . c zzzzzzz~zxo2 Z2 Z2 Z2 2 ( N 2 Z 0 a ZZ ZZ ZZ Z"z zz6zzzzzzz~zvV V NARO)nguo wO 17_ _- - F. H It- 00 2-06- Table 2 Groundwater Sample Results Sampling Location SHU-1S KE-1 KE-2 Method 1 Groundwater Standards Date 3/28/2002 3128/2002 6/14/2005 3/28/2002 GW-2 GW-3 EPH C9-C18 Aliphatics <200 <200 NT <200 1,000.00 20,000.00 CI9-C36 Aliphatics <200 <200 NT <200 N/A 20,000.00 C11-C22 Aromatics <200 <200 NT <200 50,000.00 30,000.00 PAHs Acenaphthene <0.2 <0.2 NT <0.2 N/A 5,000 Acenaphthylene <0.2 <0.2 NT <0.2 N/A 3,000 Anthracene <0.2 <0.2 NT <0.2 N/A 3,000 Benzo(a)anthracene <0.2 <0.2 NT <0.2 N/A 3,000 Benzo(a)pyrene <0.2 <0.2 NT <0.2 N/A 3,000 Benzo(b)fluoranthene <0.2 <0.2 NT <0.2 N/A 3,000 Benzo(g,h,i)perylene <0.2 <0.2 NT <0.2 N/A 3,000 Benzo(k)fluoranthene <0.2 <0.2 NT <0.2 N/A 3,000 Chrysene <0.2 <0.2 NT <0.2 N/A 3,000 Dibenzo(a,h)anthracene <0.2 <0.2 NT <0.2 N/A 3,000 Fluoranthene <0.2 <0.2 NT <0.2 N/A 200 Fluorene <0.2 <0.2 NT <0.2 N/A 3,000 Indeno(1,2,3-cd)pyrene <0.2 <0.2 NT <0.2 N/A 3,000 2-Methylnaphthalene <0.2 <0.2 NT <0.2 10,000 3,000 Naphthalene <0.2 <0.2 NT <0.2 6,000 6,000 Phenanthrene <0.2 <0.2 NT <0.2 N/A 50 Pyrene <0.2 <0.2 NT <0.2 N/A 3,000 RCRA 8 Metals Silver <5 <5 <5 <5 N/A 7 Arsenic <50 <50 <4 <4 N/A 400 Barium 600 <200 12.2 700 N/A 30,000 Cadmium <5 <5 <1.2 <1.2 N/A 10 Chromium <50 <50 <2.5 <2.5 N/A 2,000 Mercury <0.5 <0.5 <0.2 <0.2 N/A 1 Lead <5 <5 <3.8 <3.8 N/A 30 Selenium <10 <10 <7.5 <7.5 N/A 80 Notes: All results presented In ug/. NT- Not Tested; NIA - Not Available; EPH - Extractable Petroleum Hydrocarbons; and PAHs - Polycyclic Aromatic Hydrocarbons. "<"- Not Detected above laboratory detection limits. Page 1 of 1 Data Tables Groundwater 8/18/2008 ocoo E, Es11 H%8 o -8888 85:18 c; 6m - - 60 0 0 N.Zr-- 1.1N F- - I- -- F-- EnN et nor mz: . t oo 2zz 00 0i N Q 6~ 6 ______V__V "04c~~c-0) ."40zz z 0 8 -- s--- -- r szz*ozr r n z~l 0 U ~ 0 M0,?0 0 o0 9 T0 0 ,~D t zzz zzzzzzz zzzzzz F zzzzzzz N N z '7 00 z VVV000ao too VVVV 0 0 v vvVV0 6 . odioo Od v v vv v v v v ON zzzzz z a 8 v 000) 1:rN'Zw - -omz - - VVVzz Oo9oood~o~6969odd o *de 0 c Vr v v v v v v v v v v v v 0 *fl 75 dcoo d??o?~?5 0 *i 0 0vOd a 0 E S EE zzzz zz z dV OOdddo?6696 v _ __ - -a 0 N ~V H--I-HI- - -- 2iU. S i8 e V8 E 3 e 0z nuz z z v~000 96 ~ 6ddod'? 00 in ..... o9. . o .? .'O zz z S C 0 E * -*u v v9 v v vv v v vv v Y v v vv o e 8 3n 2 2 ON i v L wlaa z !E -o . -So Ch g N iN NNNs N N - z -F z z z * * v - N 2 -N- 0 0 Z. * C @E 0 0C L C ock c ^*N .Q a ~~~ e e ag o ic w Z V- m . c la s C aecjE cds, -I- mroE s . ej c mC i -) e * = E2" eE ,. Snufl. I C99 - ani-IL?2 8 8iCm>4- '.2 9 A =5 qoM li li IL 2 .000 N< ~- . . F' -- ~ I ' V'~., f AI Sampling Location SW-East SW-West SW-1 VV-2 VV-3 SWV-4 SWv-5 Dato 3/28/2002 3/28/2002 6/13/2005 6/13/2005 6/13/2005 6/13/2005 6/13/2005 6E1PH2005 6/13/2005 C9-C18 Aliphatics <200 <200 NT NT NT NT NT C19-C36 Aliphatics <200 <200 NT NT NT NT NT C 11-C22 Aromatics <200 <200 NT NT NT NT NT PAI-Is Acenaphthene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Acenaphthylene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Anthracene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Benzo(a)anthracene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Benzo(a)pyrene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Benzo(b)fluoranthene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Benzo(gh,i)perylene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Benzo(k)fluoranthene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Chrysene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Dibenzo(a,h)anthracene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Fluoranthene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Fluorene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Indeno(1,2,3-cd)pyrene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 2-Methylnaphthalene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Naphthalene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Phenanthrene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 Pyrene <0.2 <0.2 <7.14 <7.14 <7.14 <6.25 <7.14 RCRA 8 Metals aSilver <5 <5 21.5 <5 <5 <5 11.8 Arsenic <50 <50 <4 <4 <4 <4 <4 Barium <200 <200 404 159 43.6 156 136 Cadmium <5 <5 41 <1.2 <1.2 <1.2 3.8 Chromium <50 <50 188 14.5 5.8 11.6 78.1 Mercury <0.5 <0.5 <1.65 <0.22 <0.2 <0.2 <0.6 Lead <5 <5 204 14 7.6 29.1 169 Selenium <10 <10 <7.5 <7.5 <7.5 <7.5 7.5 Notes: All results presented in ug/. NT- Not Tested; EPH - Extractable Petroleum Hydrocarbons; and PAIs - Polycyclic Aromatic Hydrocarbons. "<" - Not Detected above laboratory detection limits. Page 1 of 1 Data Tables Surface Water 8/18/2008 - - -O - -~1~ - I I:--- > T .o 2's 8.. C4 - 8-c 0z d S aa s ir l dbi t-I Oa~~In ~ IIW s 26 a L ~~ ~n I LI U 4 K I8 ~ 0 LI 8 ~J up 26~n;£2 g e I a I C i 8- 2 I .1 Page 1 of 1 Table 6 Relative Absorption Factors (RAFs) Ing estion Soil Dermal Soil Compound Name Carcinogen Non-Carcinogen Carcinogen Non-Carcinogen EPH Target Analytes Acenaphthylene NC 0.36 NC 0.1 Anthracene NC 0.36 NC 0.1 Benzo(a)anthracene 0.28 0.28 0.02 0.02 Benzo(a)pyrene 0.28 0.28 0.02 0.02 Benzo(b)fluoranthene 0.28 0.28 0.02 0.02 Benzo(g,h,i)perylene NC 0.36 NC 0.1 Benzo(k)fluoranthene 0.28 0.28 0.02 0.02 Chrysene 0.28 0.28 0.02 0.02 Dibenzo(a,h)anthracene 0.28 0.28 0.02 0,02 Fluoranthene NC 0.36 NC 0.1 Indeno(1,2,3-cd)pyrene 0.28 0.28 0.02 0.02 Naphthalene NC 0.36 NC 0.1 Phenanthrene NC 0.36 NC 0.1 Pyrene NC 0.36 NC 0.1 Extractable Petroleum Hydrocarbons C9-C18 Aliphatics NC 1 NC 0.5 C19-C36 Aliphatics NC 1 NC 0.1 C11-C22 Aromatics NC 0.36 NC 0.1 PCBs 0.85 0.85 0.16 0.16 Metals Arsenic 1 1 0.03 0.03 Barium NC 1 NC 0.05 Cadmium NC 1 NC 0.14 Chromium (III) NC 1 NC 0.04 Chromium (VI) NC 1 NC 0.09 Lead NC 0.5 NC 0.006 Mercury NC 1 NC 0.05 Silver NC 1 NC 0.25 NC - Non-carcinogen MassDEP, 2008a. RAF2008 8/18/2008 Table 7 Exposure Assumptions and Equations for Construction Worker - Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates Construction Worker - Soil: Table CW-2 ShortForm Version 01-07 Equations to Calculate Cancer Risk for Construction Worker Cancer Risk from Ingestion ELCRi1,= LADDin * CSFml ED * EP * CI LADDJ EPC * IR' RAFE * E* BW * AlIitum Cancer Risk from Dermal Absorption ELCR4m_ - LADDdWM * CSFOral * EF * ED Fm*EP *C C LADDd = P EPC * SA * AF * RAFkAr BW * APiiream Cancer Risk from Particulate Inhalation - Gastrointesdnal Absorption ELCR.oG - LADDiW.oG* CSFto LADDi.", = EPC*v RCAfth * PM10o* VRtor * RAFeieg * EF * EDiA * EP *C2 *C3 *C4 BW * AlPl i Cancer Risk from Pardiculate Inhaladion - Pulmonary Absorption ELCRj - LADDi.* CSFiadamj~ * C3 * C4 * VR * RAF-h * EF * EDi * EP * C2 LADD EPC* RCAFh * PM 0 BW * AP1mime page t of 3 of7cwset up Sheet:C Eq Table 7 (Cont'd) Exposure Assumptions and Equations for Construction Worker - Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates *Construction Worker - Soil: Table CW-3 ShortForm Version 01-07 Equations to Calculate Noncancer Risk for Construction Worker Noncancer Risk from Ingestion ANN HQio -ADDi. RfDoMlebeaniM EPC *IR *RAY .i.* EF *MEi.,* EP *l CI'M. ADD, - R b, EPCI BWrN~re~~* A~ r d 59 'O bt' Noncancer Risk from Dermal Absorption XA iEvj6s tBlT HQ 2 ADD 2_ RfDowgbaj j _ EPC*SA*AF*RAFA *EF*ED&,*EP*C2 , 7 , I' BW * AP. C. Noncancer Risk from Particulate Inhalation - Gastrointestinal Absorption 3 MI 0. c H ADDjh 0 RfD~o neub~i EPC RCAF,., * PM Io *VRm RAF 34., EF ED, *EP C2 C3 C4 d0" BW *ALP ' 0 .29 Noncancer Risk from Particulate Inhalation - Pulmonary Absorption , I I t D=- ADDL I ~BW * APrrL Cyanide can cause a significant health risk from a one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure, Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. Page 2 of 3 stD7cwset up Sheet:NC Eq Table 7 (Cont'd) Exposure Assumptions and Equations for Construction Worker - Incidental Ingestion of and Dermal Contact with Soil, and Inhalation of Airborne Particulates Construction Worker - Soil: Table CW-4 ShortForm Version 01-07 Definitions and Exposure Factors Parameter Value Units Notes ELCR - Excess Lifetime Cancer Risk chenical specific dimensioness Pathway specific (ing -ingestion, deno-denal, mb-inhalation) HI -Hazard Index chemical specific dinensionless Pathway specific (ing -ingestion, derer al, job-inhalalion) CSF - Cancer Slope Factor chemical specific (ng/kg-day) s Table CW-5. RfD - Reference Dose chemical specific mg/kg-day seeTable CW-5. LADD - Lifetime Average Daily Dose chemical specific mgg-day Pathway specific. SeeTable CW-2. ADD - Average Daily Dose chemical specific mg/kg-dy Pathway specific. SeeTable CW-3. EPC - Exposure Point Concentration chemical specific 1 g/L seeTable CW- I IR - Soil Ingestion Rate 100 mg/day MADEP. 2002. Technical Update Calculation ofan Enhanced Soil Ingestion Rate. (http://ww.rnass gov/dep/ors/ospusb3.htns) RAF, -Relative Absorption Factor for Cancer Effects chsmical specific dimensionlesa Pathway specific - aceTable CW-5. RAFi - Relative Absorption Factor for Noncancer Effects chesical specific dimensionless Pathway specific - seeTable CW-S. EF - Exposure Frequency 0.714 event/day 5 days/week; MADEP 1995 Guidance for Disposal Site Risk Characterization pg B-39. El , - Exposure Frequency for Cyanide Exposures 1.00 event/day MADEP 1995. Guidanse for Disposal Site Risk Characterization. Page5-5. ED _- Exposure Duration for ingestion or dermal exposure I day/event ED_ -Exposure Duration for inhalation exposure 0333 day/event Represents S hours I event. EP - Exposure Period 182 days MADEP 1995 Guidance for Disposal Site Risk Characterization pg B-38 EP,,mne- Exposure period for cyanide exposure 1 day MADEP. 1995 Guidance for Disposal Site Risk Characterization. Page5-5 BW - Body Weight 58.0 kg U S EPA 1997. Exposure Factors Handbook. Table 7-7, Females, ages 18 - 25. APir_ -Averaging Period for lifetime 25,550 days Rcpresents 30 years APij ) - Averging Period for noncancer 182 days MADEP 1995 Guidance for Disposal Site Risk Characteration Pg B-38 AP_ - Averaging period for assessing cyanide exposure I day MADEP. 1995 Guidance for Disposal Site Risk Characterization Page5-5. AF -Adherence Factor 0.29 mg/cm MA DER 2002 Technical Update: Weighted Skin-Soil Adherence Factors. (http:i/WWW.as5ss.gov/depforsorspubs hot) VRaI - Ventilation Rate during work (heavy exertion) 60 k/mm Table B- MADEP 1995 Guidance for Disposal Site lisk Characterization. SA - Surface Area 3473 cm' MADEP. 1995. Guidance for Disposal Site Risk Characterization M0tpercentile for females. Appendix Table B-2. RCAFO - Relative Concentration Adjustemt Factor, gastrointestinal 1.5 dimensionless MADEP 2007. Characterization ofRisks Due to InhalationofParticulates by Construction Workers RCAF, -Relative Concentration Adjustiment Factor, inhalation 0.5 dimensionless MADEP 2002. Characterization of Risks Due to Inhalation ofParticulates by Construction Workers for Disposal Site Risk Cparectefzation pg B t PM 10 - Concentration of PM15 60 "g/nc MADEP 1995 Guidance Page 3 no3 sffl7cw setup Sheet.Ep Table 8 Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Soil *Trespasser - Soil: Table TS-2 Viookup Version v< Equations to Calculate Cancer Risk for a Trespasser (Ave 11-18 years) fS Pa Ige 4D6tsemupSheet: C Eq Table 8 (Cont'd) Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Soil .6 Trespasser - Soil: Table TS-3 Equations to Calculate Chronic Noncancer Risk for a Trespasser (Age 11-18 years) Chronic Noncancer Risk from Ingestion ADDa, RfD EP * C ADD, [OHM], * IR * RAF-., * EFi, * ED * BW * AP Chronic Noncancer Risk from Dermal Absorption HQ- =ADDi,,g RfD EPC ADD, - (OHM]l * SA * RAFk * SAF ' E,. * ED * BW * AP Cyanide can cause a significant health risk from one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, white both the exposure period (EP) and averaging period (AP) are 1 day. Page 2 of 4 sf6tssetup Sheet: cNC Eq Table 8 (Cont'd) Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Soil Trespasser - Soil: Table TS-4 Equations to Calculate Subchronic Noncancer Risk for a Trespasser (Age 11-12 years) Subchronlc Noncancer Risk from Ingestion HQ. = ADDifg "' - RfD.w. * EF*EDj * EP * C ADD - [OHM], * IR * RAF '"E, BW * AP Cyanide can cause a significant health risk from one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. Page 3 0f4 stD6tssetup Sheet:scNC Eq I- Nc 8 a U C 0 (U) S 2~ U *0 C C Ipq 0 a 0 U, U at C N; 'U U U U - I 1~ U 02 Cu Os rjpj U I- I- 0 4- U) C 0 C U *0 C Cu 0) C 0 04 E C U) Cnu I- Po C U) 0 04 N Nm ';u Table 9 Exposure Assumptions and Equations for Resident - Incidental Ingestion of and Dermal Contact with Soil, and Ingestion of Homegrown Produce . IResident - Soil: Table RS-2 Equations to Calculate Cancer Risk for Resident (Age 1-31 years) Cancer Risk from Ingestion ELCRW = LADDWI.)* CSF LADDAB(I.33)= LADDg-sy+ LADDi.,sI-),+ LADDiJ .,5-J1) * ED * EP, * C LADD.,(,, po_ ) [OHM].* I1RI* RAF,.g * EFj.1 BW, * AP,, Cancer Risk from Dermal Absorption ELCR.= LADD, * CSF LADDaw._3= LADD.(,) + LADDm,8 s)+LADD",.3 _V [OHM}, *SA, * RAFede * SAF, * EF *ED EP, * C LADD, 1 BW, * APji. Cancer Risk from Homegrown Produce ELCR,= LADD,, ,,,) * CSF LADDmd.01-3= LADD ,w!Jg) + LADDJg 15j) + LADD,..ec _ [OHM ,]* PUF PIR,* RAF * EF,,, * ED * EP, * C LADDIx W APlr Page 1 of 6 PfD6rsSheet: C Eq Table 9 (Cont'd) Exposure Assumptions and Equations for Resident - Incidental Ingestion of and Dermal Contact with Soil, and Ingestion of Homegrown Produce Resident - Soil: Table RS-3 Equations to Calculate Chronic Noncancer Risk for Resident Child (Age 1-8 years) RS-3 Table -Soil: lResident Vlookup Version v0207 Chronic Noncancer Risk from Ingestion HQ-= ADDL,2 RfD ED * EP * C ADD- - {OHMkj * IR * RAF * EF,, * BW*AP Chronic Noncancer Risk from Dermal Absorption HQ'= ADDi4 RfD * ED*EP*C ADD, - [OM] *SA*RAFi . *SAF*EF BW *AP Chronic Noncancer Risk from Homegrown Produce ADDm, RfD * EP * C ADDrO_ [OHM,,] * PUF * PIR * RAFVAC * EF, , * ED BW * AP Cyanide can cause a significant health risk from one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. Page 2 orf6 sft6rs Sheet: cNC Eq Table 9 (Cont'd) Exposure Assumptions and Equations for Resident - Incidental Ingestion of and Dermal Contact with Soil, and Ingestion of Homegrown Produce .Resident - Soil: Table RS-4 Equations to Calculate Subchronic Noncancer Risk for Resident Child (Age 1-2 years) Vlookup Version v0207 Subehronic Noncancer Risk from Ingestion ADD , ofD3f' S-%4A-tHMifi&F i~ wg'ii~ HQI- = AD IOHM]r* IR *RAFe * EFg* ED *EPCCt4~ ~i ADD, _ BW *AP Subchronic Noncancer Risk from Dermal A bsorption ,= H- ADDA 1 C7* '' il [OHMiSA*RAF ,,,*SAF*EF ED*EP*C ADD., BW AP . Noncancer Risk from Homegrown Produce a PrtC r M t eir SubchronicCyanide can cause a significant health risk from one-time exposure to concentrati averaging1 day eriodOCAP)are RAF O p ah da = ADD,- B*EP 14 Cynd elhrikfomoetmeepsuetcncus iniiat onetatosthtaeofe0577i heevromnAsscniki OHM * PUFcacltdfo * PIRhsfrcaidteepsuefeuny* RAFdigeexoue *A EF, *ED EP C E)i00vetdy hiebt h epsr ego EI n ADSBWO*AP1 ____Y-t averagiB (A)ae1dy 07io Page 3 Of6 sIO6rs Sheet:scNC Eq CL 8 a, C C 0t0 CU -C .e C U U N C C *) (.. == L E5i = 'a o - n %0 c-r O V- in 0 n raiUem 04 'S o oVi . .2 a o a. > .a a 03 U a .4) 4) a 4) "0 0 a S ' .0 = S = A) (4 N 06 te 4) E 4) 'C a E)N ' N 4 0 IL) ' W4 So I- 0 5 0 , 0 .= a U I- C U a --- , i -0 C.c4 Os j CUV) 0 '2 Z Sa -e 'M a o A 'C 0. " 'a So-0 2)e ) 0 ii E-.y So Ei N n- N 004 U, 4 4) 4. 4) & a ,as r o '- i 0 o'VS- o eq0 4n %D 0 'a SN 00 '0 cd .0 0 ii E "a a o -) (A *.s at C- -) C g 26= .- 2* a 'a 'C 4) 4) a U 4) E 4) -5 o0 I- 5- o a C7,' 0 - 'C - t1'400 Cs *oo... xI 1 0 T 8= 0 o, ;~ a 2 aC 02 - ) .-. S e-o 4) a 1~ 8a. N>. V = 2- 0 0 5 o s E 0 -e 5- 7 4 ) -7 CN 'C 4) 4) Cs 'a I- 4).2 /, ) - = EOo .0 0-3 S == 0 - - a. 0I '0- - e 2- r_ 2~ .o 2 5 e 0 - 4- 4) 7 o - -. .. * 2 00 '0R N e ' 0 4 'C a 4) S E CL 0 a 'a 0 2 2 a U U o- C =8E 8 . 0) 'C 4) S a C C a 4) S .4) S E0 .en a-o' a 03 = o 0 cc ~IQW(N o' - . E .2 - 0 'C a 0 d-0N orsWo.l 0~ 4) 0 r-1N N- r / U 0 4) C-4~eM l I- C a a 0 'a e - m 4)5 a -5o- S 0 0 > o 1.. - .2-> *.24 0 7 a 0n "-= ~ 4) = c* N en CL S C t n tC3 V 02 - 4) 4 -10 o e E 0 2 -o .2 .C SO=O 2 rn 2 ' *0 '4) 4) 4) - e 'C a S c' .. 0 03 4) C 4 )~ goa "o-o 0. ;"0~ 4. = 0! = es 0 0 0 2- = i- a 0 Um Cs is.- C 0' ca O C.). 4 o4 4) e Cs A %6 eri Cs o CC -.-o C N fl N ~ 0% r~i - t -o ' -o V eq K - N to .M S ca V fIn0(D0% Or- 2- S N -0- 'l '0 0 0 'St. - eel Ut .0 1N C 51SUenC ko 0% 5 ~ *e en C u E S cm u -- n- - o Ut CC I= ow U U 045 U = 0 C U U s, 3 U .E a b + C= I - 7 o a ons Cs V -2 c C v C6 N- >=- tn u U 02 I- S- ! -a* -t eq N U a U .0 4. 6 ~ - en - r4I 2 Table 10 Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Sediment Variables Exposure Assumptions Notes: Receptor Trespasser (1) Age Youth (11 to 18) years (1) Average body weight (BW) 50.7 kilograms (2) Frequency of Exposure (EF) 10 days/year (1 day/week for 10 weeks) (3) Duration of Exposure Period (EP) 7 years (4) Averaging Period (AP) (5) for noncancer risk 490 days (7 days/week for 10 weeks for 7 years) for cancer risk 25,550 days (365 days for 70 years) Incidental sediment ingestion rate on days exposed (IR) 0.05 grams/day (6) Oral Relative Adjustment Factor (RAF) contaminant - specific (7) Exposure Point Concentration (EPCsediment) measured mg/kg (8) Noncarcinogenic Effects Youth Trespasser Noncancer = IR (grams/day) x E'F (days/year) x EPl (years) x Ingestion Sediment (NCISed) Factor (I/day) (1/BW (kg)) x (1 kg/1,000 grams) x (1 /AP (days)) NCISed Factor = I4E-07 (1/day) Chronic Average Daily Dose (mg/kg-day) = HPCsediment (mg/kg) x NCISed Factor (1/day) x oralRAF Carcinogenic Effects Youth Trespasser Cancer = IR (grams/day) x F (days/year) x HP (years) x Ingestion Sediment (CISed) Factor (1/day) (1/ BW (kg)) x (1 kg/1,000 grams) x (1/Al (days)) CISed Factor = 2.7E-09 (1/day) Lifetime Average Daily Dose (mg/kg-day) = EPCsediment (mg/kg) x CISed Factor (1/day) x oralRAF Notes: (1) Youth, 11 to 18 years of age, were used to represent trespassers that may be exposed to sediments in the wetlands. (2) Typical (median) age-specific body weights were assumed for Youth (11 to 18 years) as 50.7 kg. MassDEP, 2007. (3) Frequency of exposure describes how long each event occurs over a given period of time. It was assumed that youth would be exposed to sediments in the wedands for 1 day per week for 10 weeks (during warm weather), or 10 days per year. (4) The duration of exposure period describes the length of time over which the youth may come into contact with contaminants. The period of exposure is considered to be 7 years. (5) For noncancer risks, the averaging period is set equal to the exposure period (7 days per week for 10 weeks per year for 7 years or 490 days). For cancer risks, the averaging period is equal to a lifetime (i.e., 365 days per year for 70 years or 25,550 days). (6) Youth (11 to 18 years) assumed to ingest soil at a rate of 50 mg/day. MassDE P, 2007. (7) Contaminant-specific sediment contact RAFs. (8) Sediment exposure point concentrations. Page 1 of 2 tssedexp Y Rec Sed Ingest 8/18/2008 Table 10 (cont'd.) Exposure Assumptions and Equations for Trespasser - Incidental Ingestion of and Dermal Contact with Sediment Variables Exposure Assumptions Notes: Receptor Trespasser (1) Age Youth (II to 18) years (1) Average body weight (BW) 50.7 kilograms (2) Frequency of Exposure (EF) 10 days/yea (1 day/week for 10 weeks) (3) Duration of Exposure Period (El) 7 years (4) Averaging Period (AP) (5) for noncancer risk 490 days (7 days/week for 10 weeks for 7 years) for cancer risk 25,550 days (365 days fur 70 years) Skin surface area in contact with sediment on days exposed (SA) 2,940 em2/day (6) Soil Adherence Factor (AF) I mg/cm2 (7) Dermal Relative Adjustment Factor (RAID contaminant - specific (8) Exposure Point Concentration (E~lcsediinent) measured nag/kg (9) Nonearcinogenic Effects Youth Trespasser Nonca(r1) SA (cm3/dsy) x Al(mg/cm) x E (days/year) t El' (years) x Dermal Sediment (NCDtSed) actor (1/day) (1/1W (kg)) x (1 kg/1,000,00 nag) x (1/All (days)) NCDSed Factor d 3E-06 (1 day) Chronic Average Daily Dose (mg/kg-day) = FPscdioenr (mg/kg) x NCDI'Scd Factor (I/day) xtRAF Carcinogenic Effects Youth Trespasser Canced SA (cm7day) eAF (g/cm) x E (days/year) x RP (years) x Dermal Sediment (COSed) Factor (1/day) 2 (1/8W (kg)) x (1 kg/I ,00,000 tog) (d /Al( (days)) CDSed Factor .6E-07 (I/day) Lifetime Average Daily Dosem(mg/kg-day) = r /sedim t (mg/kg) x CSed Factor (9/day) RAF ) Notes: (1) Youth, I I to 17 years of age, were used to represent trespassers that may be exposed to sediments in the wetlands. (2) Typical (redian) age-specific body weights were assumed for Youth ( to 18 =years) as 50.7 kg. MassD/, 2007. (3) Frequency of exposure describes how long each event occurs over a given period of time. It was assumed that youth would be exposed to sediments in the wetlands for day Sper week for 10 weeks (during warm weather), or 10 days per year. (4) The duration of exposure pcriod describes the length of time over which the youth may come intoi contact with contaminants. TNhe period of exposure is considered to be 7 years. (5) For noncancCr risks, the averaging period is set equal to the exposure period days per week for 10 weeks per year for 7 years or 490 days). For cancer risks, the averaging period is equal to a lifetime (i.e., c65days pet year for 70 years or 25,550 days). (6) Skin surface area is based on MasD 2002.eim, Weighted Skin-Soil Adherence Factors. Technical Update. April 2002. Assumes hands, forearms, aad feet exposed. m7LMass of soil on skin (adherence factor) obtained from MassD 2002.-P, Weighted Skin-Sod Adherence Factors.Technical Update. Apri 2002. Based on unweighted adherence factor for children exposed to sediments. (4) Contaminant-specific sediment contact R Ales. (9) Sediment exposure point concentrations. Pa-ge 2 of 2 tssedexp Y Rec Sed Dermal 8/18/2008 Table 11 Exposure Assumptions and Equations for Trespasser - Dermal Contact with Surface Water Variables Exposure Assumptions Notes: Receptor Trespasser (1) Age Youth (11 to 18) yeats (1) Average body weight (BW) 50.7 kilograms (2) Frequency of Exposure (EF) 10 days/year (1 day/week for 10 weeks) (3) Duration of Exposure (ED) 1 hour/day Duration of Exposure Period (EP) 7 year (4) Averaging Period (AP) for noncancer risk 490 days (7 days/week for 10 weeks for 7 years) (5) for cancer risk 25,550 days (365 days for 70 years) 2 Skin surface area in contact with water on days exposed (SA) 2,940 cm (6) Dermal Permeability Constant (Kp) contaminant - specifc (7) Exposure Point Concentration (EPCsurfacewater) measured mg/1 (8) Conversion Factor 0.001 eme (8) Chronic Noncarcinogenie Effects Youth Trespasser NonesnYr = SA (m) t 1) (days/year) P (years) ( Derayal Surface Water - NCDSW Factor (kg) /A /cm2/ya(days)(1 d//W 1 w 5 NCDSW Factor = 83E+00 (cm /kg) Chronic Average Daily Dose (mg/koday) = water (mg/cmuPCsurfsce p (cm/hour) x ED (hours/day) it NCDSW (emjkg) (ac4)r Carcinogenic Effects Youth Trespasser Cancer = SA (cm) x El? (days/year)a EP (years) Dermal Surface Water - CDSW Factor (em2davny/ksday) x 1/15W (kg) i I/All (days) CDSW Factor = 16E-01 (cm/k(6 letime Average Daily Dose (mg/kgdsy) = EPCsueface water (mng/cm') a Kp (cm/hour) x ED (hours/day) C CDSW Factor (cm(/kg) Notes: (1) Youth, 11 to 18 years of age, were used to represent trespassers that may be exposed to surface water in the wetlands. (2) Typical (median) age-specific body weights were assumed for Youth ( 1 to 18 years) as 50.7 kg. MasDEP, 2007. (3) Frequeney of exposure descrnbes how long each event occurs over a given period ofrinse. It was assumed that youth would be exposed so surface water in rhe wetand for I day per week for 10 weeks (during warm weathe), or 10 days per year. (4) The duration of exposure period describes the length of time over which the youth may come into contact with contaminants. The period of exposure is considered ts be 7 years. (5) Foe risks,Concanher the averaging period is set equal to the exposure period (7days pe week for 10 weeks per year f 7or years cr490 days). For cancer risks, the averaging period is equal to a lifeyme (i.e.s 365 days pee year fur 70 years or 25,550 days) (6) Skin surface area 'a based on MasaDEP, 2002. Weighted Skin-Soil Adherence Factorstechnical Update. April 2002 Assumes hands, forearms, and feet exposed. (7) Dermal permeability constanvs are cheDical-specific LSEPA, 2004. Risk Assessment Guidance for Superfund. Volume 1: Human Health Evaly)bon Manual. (Part , Supplemental Guidance for Dermal Risk Assessmenr. interim Guidance. If contaminsnt-specific kP -05 .. k. assumed tube 1E-03 cm/hr (EPA's default value) for inorganics am s MassDEP, 200. 3 (8) Surface water exposure point concentrations. converho the exposure point concentration from mo itmg/em , multiply the concentration by 0.001. 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'~ U C C - 0:0 0 >a I cooo S p. .- Z~ .2- 1 $-s 4( oil!35E03 E $ E 404$ 6$$$ -Z GS q".. o >m o 0., g A: e I-I NCC IDE 2 - - 2 o a e -a US! aeq - UCI-- Cee .. ow w 9 N 0.1 OnW "R99 l9 19 9 9 9 09 9 99 9 W IJ W W LU L LU LULU LiiLii LU L Lu LU wU wUL UL UL UL aa Soz oa 7 ..-. .e m .. r n e NN 0 0 - O c5 E- - C a e a n r.Ie n, e E nN a U 3CaO 2Um- a e n o99 N - od60C2r t -N N- 00- Ok. 8 E 1 . z 9 999 E 2 - z en n>e o C 4- 9999 LO~W - 0nen- Z - - Nz -aZ a .ca 7 20 a USE Q - DD'oCJC PC D '-'.5 ' Q 3 U C TABLE 16 CALCULATION OF AVERAGE DAILY DOSES AND RISK ESTIMATES FOR INCIDENTAL INGESTION OF SEDIMENT RECEPTOR: Youth Trespasser NONCARCINOGENIC EFFECTS Oral Average Oral Hazard Contaminant x Relative x NCISed = Daily / Chronic = Index EPCsed Absorption Factor Dose RfD (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day) EPH C19-C36 Aliphatics 1220 1.00 1.4E-07 1.711-04 2.01+00 8,51-05 C11-C22 Aromatics 541 0.36 1.41-07 2.7E3-05 3.01;-02 9.1E-04 PAHs Phcnanthrenc 0.794 0.36 1.4E-07 4.01E-08 3.0E-02 1.3E-06 Anthracene 0.185 0.36 1.4E-07 9.3E-09 3.0E-01 3,1 E-08 Pyrene 1.18 0.36 1.4E-07 5.9L-08 3.0E-02 2.0E-06 Benzo(a)anthracene 0.576 0.28 1.41-07 2.3E-08 3.0E-02 7,51-07 Benzo(b)fluoranthenc 0.645 0.28 1.4E-07 2,5E,-08 3.01;-02 8.4E-07 Benzo(k)fluoranthenc 0.469 0.28 1.4E,-07 1.81E-08 3.01-02 611E-07 Benzo(a)pyrene 0.621 0,28 1.4-07 2.4E-08 3.0E-02 8.1rE-07 Indeno(1,2,3-cd)pyrene 0.405 0.28 1.41-07 1.61E-08 3.0E-02 5.3r--07 Benzo(g,h,i)perylene 0.457 0.36 1.4E-07 2.3f;-08 3.0E-02 7.7E-07 Chrysene 0,654 0.28 1.4E-07 2.6E-08 3.01-02 8.51-07 14uoranthene 1.7 0.36 1.4E-07 8.6E-08 4.0E-02 2.1E3-06 PCBs PCBs 1.71 0.85 1.4E-07 2.0E-07 2,01;-05 1.01-02 Metals Arsenic 24.5 1.00 1.4E-07 3.4E-06 3.0E-04 1.1U-02 Barium 1540 1.00 1.4E-07 2.21,-04 2.01E01 1.1-03 7.0 1.00 1.41-07 9.8F-07 1.017-03 IlCadrmum - -- . .I .- .. 9.8E1-04 Chromium 1110 1.00 1.4E,-07 1.6E-04 1.5E+00 .OE-04 I Lade 822 0.50 1.4E-07 5.8F-05 7.5E-04 7.71-02 Mercury 3.62 1.00 1.4-07 -- 5.1 E-07 1.0E-04 5.11E03 Silver 12.8 1.00 1.41-07 1,81-06 5.01-03 3.6-04 CARCINOGENIC EFFECTS Oral Average Oral Contaminant x Relative x CIDaily x Cancer ELCR EPCsed Absorption Factor Dose Slope Factor (mg/kg) Factor (1/day) (mg/kg-day) -mg/kg-day*J PAHs Benzo(a)anthracene 0.576 0.28 2.71-09 4.4E-10 7.3E-01 3.21 -10 Benzo(b)fluoranthenc 0.645 0.28 2.71-09 4.914-10 7.31-01 3,61-10 Benzo(k)fluoranthene 0.469 0.28 2.7E-09 3.5E-10 7.31-02 2.61-11 Benzo(a)pyrene 0.621 0.28 2.7E-09 4.7-10 7.3E+00 3.4E-09 Indeno(1,2,3-cd)pyrene 0.405 0.28 2.71-09 3.1E-10 7.31-01 2.21E-10 Chrysene 0.654 0.28 2.7 E-09 4.9E-10 7.31-02 3.61E-11 PCBs PCBs 1.71 0.85 2.7E-09 3.9F-09 2.01+00 7.81E-09 Metals Arsenic 24.5 1.00 27-09 6.6F-08 1.51.-+00 9.9E-08 ± ____ _Subtotal 1.1E-07 tssedressk Ingestion Soil 8/18/2008 TABLE 16 (cont'd.) CALCULATION OF AVERAGE DAILY DOSES AND RISK ESTIMATES FOR DERMAL CONTACT WITH SEDIMENT RECEPTOR: Youth Trespasser NONCARCINOGENIC Dermal Average Oral Hazard Contaminant X Relative x NCDSed Daily / Chronic Index EPCsed Absorption Factor Dose RfD (rn /k- F actor (1/d \) /k. dL.... EPH C19-C36 Aliphatics 1220 0.10 8.3E-06 1.0E-03 2.01+00 5.1E.7-04 CI-C22 Aromatics 541 0.10 8.3E-06 4.51E-04 3.011-02 1.5E-02 PAHs Phenanthrene 0.794 0.10 8.31E-06 6.6E2-07 3.0E-02 2.2E-05 Anthracene 0.185 0.10 8.3E-06 1.5E-07 3.0E-01 5.1 E-07 Pyrene 1.18 0.10 8.3E-06 9.812-07 3.0U'-02 3.31-05 Benzo(a)anthracenc 0,576 0.02 8.3E-06 9.61E-08 3.01-02 3.2E-06 Benzo(b)fluoranthene 0.645 0.02 8.3E-06 1.11-07 3.0E-02 3.6E-06 Benzo(k)fluoranthenc 0.469 0.02 8.31-06 7.8E-08 3.0E-02 2.6E'-06 Benzo(a)pyrene 0.621 0.02 8,31-06 1.0E-07 3.0E-02 3.41-06 ITndeno(1,2,3-cd)pyrene 0.405 0.02 8.31;-06 6.71-08 3,0E.-02 2.2E-06 Bcnzo(g,hi)perylene 0.457 0.10 8.31-06 3.81E-07 3.017-02 1.3E,-05 Chrysene 0.654 0.02 8.3,-06 1.1E-07 3.0E-02 3.6E2-06 Fluoranthene 1.7 0.10 8.3E-06 1.41E-06 4.0E-02 3.5E,-05 PCBs PCBs 1.71 0.16 8.3E-06 2.3E-06 2.0E-05 1.1E-01 Metals Arsenic 24.5 0.03 8.31-06 6.1E-06 3.0E--04 2.01E-02 Barium 1540 0.05 8.3E-06 6.4E-04 2.011-01 3.2E-03 C-admium 7.0 0.14 8.311'06 8.1 H-06 1.01,"-03 8.1 F-03 Chromium 1110 0.04 8.3E-06 3.7E--04 1,5E+00 2.51-04 Lead 822 0.006 8.31-06 4.1E-05 7.5E-04 5.5E-02 Mercury 3.62 0.05 8.3E-06 1.51E-06 1.01E-04 1.5E-02 Silver 12.8 0.25 8.31 -06 2.7E -05 5.0E-03 5.3E--03 I I Subtotal = 2.4-01 [CARCINOGENIC EFFECTS Dermal Average Oral Contaminant x Relative x CDSed Daily x Cancer = ELCR EPCsed Absorption Factor Dose Slope Factor (mg/kg) Factor (1/day) (mg/kg-day) (mg/kg-day)~ _ PAHs Benzo(a)anthracene 0.576 0.02 1.61-07 1.81-09 7.31E-0l 1.3E2-09 Benzo(b)fluoranthene 0.645 0.02 1.6-07 2.1 1-09 7.3E-01 1.5E1-09 Benzo(k)fluoranthene 0.469 0.02 1.6E-07 1.5E-09 7.3E1-02 1.1E-10 Bcnzo(a)pyrene 0.621 0.02 1.6E-07 2.0E--09 7.31;+00 1.5K-08 lndeno(1,2,3-cd)pyrene 0,405 0.02 1.61-07 1.31-09 7.31E-01 9.51-10 Chrysene 0.654 0.02 1.6E-07 2.1 E-09 7.3E-02 1.5E,-10 PCBs PCBs 1.71 0.16 1.61-07 4.417-08 2.0E,+00 8.8E-08 Metals Arsenic 24.5 0.03 1.6E-07 1.2E--07 1.5E+00 1.8E-07 Subtotal 2.81-07 tssedressk Dermal Soil 8/18/2008 Page 1 of I TABLE 17 CALCULATION OF AVERAGE DAILY DOSES AND RISK ESTIMATES FOR SURFACE WATER DERMAL CONTACT EXPOSURE RECEPTOR: Youth Trespasser NONCARCINOGENIC EFFECTS Dermal Average Oral Hazard Compound x Permeability x Exposure x = Daily / Chronic = Index EPCsw Constant (Kp) Duration NCDSW Dose RfD (mg/cm3) (cm/hour) (hour/day) (cm2/kg) (mg/kg-day) (mg/kg-day) Metals Silver 2.2E-05 0.0006 1 8.3E-+00 1.1E-07 5.0E-03 2.1E-05 Barium 4.0E-04 0.001 1 8.3E+00 3.4E-06 2.0E-01 1.7E-05 Cadmium 4.1E-05 0.001 1 8.3E+00 3.4E-07 1.0E-03 3.4E-04 Chromium 1.9E-04 0.001 1 8.3E+00 1.6E-06 1.5E+00 1.0E-06 Lead 2.E-04 0.0001 1 8,3E+00 I 1.7E-07 7.5E-04 2.3E-04 _Subtotal = 6.1E-04 [CARCINOGENIC EFFECTS Dermal Lifetime Compound x Permeability x Exposure x x Daily x Orl ELCR EPCsw Constant (Kp) Duration CDSW Dose CSF (mg/cm3) (cm/hour) (hour/day) (cm2/kg) (mg/kg-day) (mg/kg/day)-1 None tsSWDCRSK Dermal 8/18/2008 Page 1 of 1 TABLE 18 SUMMARY OF HAZARD INDICES AND RISK ESTIMATES 40 Forest Street, Attleborough, MA RECEPTOR Hazard Index (HI) Excess Lifetime Media Exposure Pathway Subchronic Chronic Cancer Risk (ELCR) CONSTRUCTION WORKER Soils - Metals Present - Paved or Capped Incidental Ingestion and Dermal Contact, 2E+00 -- 3E-06 and Inhalation of Airborne Particulats Soils - No Metals Present - Paved or Capped l Incidental Ingestion and Dermal Contact, 4R-01 - 51-f07 and Inhalation of Airborne Particulates Soils - No Metals Present - Not Paved or Capped Incidental Ingestion and Dermal Contact, 9E-03 - 4E-08 and Inhalation of Airborne Particulates TRESPASSER Soils - Metals Present - Paved or Capped Incidental Ingestion and Dermal Contact 2E-01 2E-01 2E-06 Soils - No Metals Present - Paved or Capped 4E-02 4E-07 Contact 6E-02 Incidental Ingestion and Dermal Soils - No Metals Present - Not Paved or Capped Incidental Ingestion and Dermal Contact 2E-03 71-03 NC Wedand Sediment Incidental Ingestion and Dermal Contact -- 4E-01 4E-07 Wetland Surface Water Dermal Contact - 6F,04 NC Total Trespasser Soil, Sediment, and Surface Water 6E-01 2E-06 FUTURE RESIDENTS Soils - Metals Present - Paved or Capped Incidental Ingestion and Dermal Contact, 9E+01 1E+02 1E-03 and Ingestion of lomegrown Produce Soils - No Metals Present - Paved or Capped Incidental Ingestion and Dermal Contact SE+01 4E+01 2E-04 and Ingestion of Hornegrown Produce Soils - No Metals Present - Not Paved or Capped Incidental Ingestion and Dermal Contact 9E-02 4E-01 NC and Ingestion of Homegrown Produce jMassDEP Risk Limits: f 1E+00 11+00 1E-05 Notes: NC indicates no carcinogens detected. Bolded values exceed MassDEP risk limits. For construction workers, the primary contributer to the HI is arsenic, and the primary contributors to the ELICR are chromium and arsenic. For future residents, the primary contributors to the 1II are lead, PCBs, and arsenic, and the the primary contributors to the ELCR are arsenic and PCBs. risksum 8/27/2008 o 0I - st -flH Nn.'"" - ,' 0 41 S N E 2) mi3 z .9 o 14ON 4"R 2 R z z z z HI H '0 0 V o ______U e-- - zN - N PI 4) Lfasw) 61 qat z l' LU2 a v v Z o ~ ~ ~ t LoNNNNr.N Ei CL 8 co 0 S NNr~z & N C c6 U)c c v Q 8 00 0. U)- 8 6 Ni=' 0r ' - - a) M - e0 oo C0 7 % ... . -- E - -- v v vF-e 8 ~ ~~~;!3~ ~ ~ 3 U 1 'E1L 0 v oz zzzzz 22 -33 mo. ZZo' ;: 66666666666 zz zz z -5 -~~~~ v v_V8V V vj V Yj V _ _ _ - I v 6 L-0""i faan- r- N c;dd dc - oco Zv Z o2m ZZ I S 6 66 6 - 66l-l Z Z Z Z ZN f on ZC. ; r' _ woo ftV go 2 23o! 15 CL: 2 o o6 501 zZ Z 5" ZZ vZZN Z 13 Luv~~~ ~~ ~ ~~~ L ~ ~C mi m ommc)2 I uC w) &n o ou o mI no D V v "3 ncg EBE a.s E c sa4 v OD 00 . 0 -C t:n mu O C) 0 0 (UU) -j EvU) LO cc 0O C C m l co U.< CLE eq 'ot r (D * ci S-o - - to 0to 4C- 0 'I) 0 CC 00 OwlnA 0 CDC omC a CD 0 0 O C ~ ~ A ~ 1 (0L 10 UC -% 'a ~ v eLv (a vo cn2 z +. O v C 0 0 -J 2 .s C) cio E E E mU cn o.- a >u r o M-z CT O'Reilly, Talbot & Okun -4 [ A S S 0 C I A T E S ] APPENDIX A TOXICITY PROFILES 40 Forest Street, Attleborough 8/28/2008 5075-09-01 AttleboroM3text ACENAPHTHENE GENERAL BACKGROUND INFORMATION Acenaphthene is a member of the polycyclic aromatic hydrocarbons (PAH). PAHs are a class of non-polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. The database for accnaphthene is very limited. PHARMACOKINETICS No data were found regarding the pharmacokinetics of acenaphthene. HUMAN TOXICOLOGICAL PROFILE No data were found regarding the human toxdcology of acenaphthene. MAMMALIAN TOXICOLOGICAL PROFILE Adverse effects on the lungs, glands, and blood were observed in rats following aerosol administration of 12 mg/in acenaphthene for 5 months (U.S. EPA, 1981). GENOTOXICITY Mutagenicy tests for acenaphithene were agative (U.S. EPA, 1981). Carcinogenicity tests were negative (IARC, REFERENCES International Agency for Research on Cancer (IARC) (1983) Monograph on the evaluadon of crcinogenic risk of chmicals to man poynuckar amomade hydrocarbons. 32:33-43. U.S. Environmenral Protection Agency (U.S EPA) (1981) An exposure and risk assessment for acenaphthalne. U.S. EPA Contract No. 601-6017. Office of Water Regulations and Standards, Washington. D.C. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versos 1.6 a & b - 10/92 B-3 ANTHRACENE GENERAL BACKGROUND INFORMATION Anthracene is a polycyclic aromatic hydrocarbon (PAH). PAHs are a class of compounds which are non-polar and contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. As a PAH, anthracene is found in tobacco smoke, certain foods, and the emissions from industrial or natural burning. PHARMACOKINETICS Little data were found regarding the pharmacokinetics of anthracene. The intestinal absorption of anthracene is less dependent on the presence of bile in the stomach than is the absorption of larger PAHs such as benzo(a)pyrene (Rahman et al, 1986). HUMAN TOXICOLOGICAL PROFILE Anthracene is a skin irritant and allergen (Sax, 1984). Humans exposed to anthracene in an occupational setting may demonstrate skin disorders (Clement, 1985). Anthracene has been associated with gastrointestinal tract toxicity in humans (Badiali et al, 1985). However, the usefulness of this study is limited due to confounding factors. Hematopoietic toxicity has also been observed in cancer patients who have been treated with anthracene-containing chemotherapeutics (Falkson et al, 1985). No control groups and concomitant exposure to other ingredients in the therapeutic agents prevents any definitive conclusions. MAMMALLAN TOXICOLOGICAL PROFILE A subchronic study where anthracene was administered to mice by gavage for at least 90 days found no treatment-related effects at doses up to 1000 mg/kg-day (USEPA, 1989). The data on the carcinogenicity of anthracene are considered inadequate by EPA (IRIS, 1991). GENOTOXICITY Tests for DNA damage, mutation, chromosome effects and cell transformation in a variety of eukaryotic cell preparations have shown negative results. The majority of tests using anthracene in prokaryotes are negative, but positive results are reported in one or two tests (ATSDR, 1990; IRIS, 1991). MA DBP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 7 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990)Toxicological summary for polcyclic aromatic bydrarbons. U.S. Public Health Service. Badiali, D. et al. (1985) Melanosis of the rectum in padenu with constant consdpadon. Dis Colon Rectum 28:241-245. Clement (1985) Chemical, physical and biological properties of compounds present at hazardous waste sites Falkson, G. Klein, B., Falkson, H. (1985) Hematologicaltaicity: xperience with anracyclines adn antwacenes. Exp. Hematol 13:64-71. Integrated Risk Information System (IRIS) (1991) US. Environmental Protection Agency International Agency for Research on Cancer (IARC) (1983) Monograph on the evaltion of carcinogenicrisk of chemicals to man, andhracene. 32:433-440. Sax, N.I. (1984) Dangerous Properties of Industrial Materials. 6th edition. Van Nostrand Reinhold Company, N.Y. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 8 BENZO[a]ANTHRACENE GENERAL BACKGROUND INFORMATION Benzo[alanthracene (BaA) is a member of the polycyclic aromatic hydrocarbons (PAH). PAHs are a class of non-polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. The overall database for benzofa]anthracene is limited. Human exposures to BaA can come from the oral, inhalation or dermal routes. BaA is produced when gasoline or other organic material is burned. It is also found in cigarette smoke and cooked food. People most at risk from exposure to BaA are those in the coal tar and asphalt production industries, cooking plants, coal gasification plants, smoke houses and industrial plants that burn wood, trash, coal or oil. PHARMACOKINETICS BaA is absorbed by the dermal and oral routes. There is no information on absorption by inhalation. Biotransformation to reactive intermediates is necessary for toxicity (ATSDR, 1990). BaA accumulates in adipose tissue. The metabolism of BaA is similar to the metabolism of benzo[a]pyrene (Cooper et al., 1983). In briet the aromatic ring is oxidized by arene oxides to form reactive intermediates. The reactive intermediates are subsequently hydrolyzed to diols (Sims and Grover, 1974). The diols are conjugated with glutathione and excreted. HUMAN TOXICOLOGICAL PROFILE There are no reports directly correlating human exposure to BaA with the development of excess tumors. MAMMALIAN TOXICOLOGICAL PROFILE The only toxicity endpoint that has been adequately studied for BaA is dermal carcinogenicity. There is some evidence that benz[a]anthracene is carcinogenic in laboratory animals by the oral route (Klein, 1963; Bock and King, 1959) and also by subcutaneous injection (IARC, 1973). BaA has been shown to cause skin tumors after dermal application (Bingham and Falk, 1969). Tumorigenicity of the diol epoxide metabolite has been shown (Levin et al., 1978) as well as the mutagenicity of the diol epoxide (Wood et al., 1977). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions L6 a & b - 10/92 B - 14 GENOTOXICITY The metabolism of BaA is an essential event in producing genotoxic effects in both in viro and in ivo biological test systems (ATSDR, 1990). The intermediates formed by BaA metabolism are reactive electrophiles which are capable of interacting with DNA. REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) Toxicolouical summary for benzofalanthracene. U.S. Public Health Service. Bingham, F. and Falk, H.L (1969) The modifying effect ofcarcinogenson the threshold response.Arch. Environ. Health 19:79-783. Bock, F.G. and King, D.W. (1959) A study of the sensidvhy of the mouse forestomach toward certain polycclic hydrocarbons.3. Nail. Cancer Inst. 23:833. Cooper, C.S. Grover, P.L, and Sims, P. (1983). The metabolisn and activadon of benzo(a)pyrene. In: Bridges, J.W. and LF. Chase, eds. Progress in Drug Metabolism. Vol. 7. John Wiley and Sons, New York, pp. 295-395. Klein, M. (1963) Susceptibility of strainB6AF/J hybrid infant mice to atmorigenesir with 1,2-benzanthracene,deoxycholic aci4 and 3-melrycholanthrene. Cancer Res. 23:1701-1707 Lmin, W., Thakker, D.R., Wood, A.W. et al. (1978) Evidence that benzo(a)anwacene 3,4-diol-1,2-epoxide is an ulimare carcinogen on mouse skin. Cancer Res. 38:1705-1710. 4 Sanders, CAL, Skinner, C. and Gehnan, RA. (1986) Percutaneous absorption of 7,10 ' C-benzo(a)pyrene and 7,12 4C. dimeqhylbenzo(a)pyene in mice. JEPTO 3:25-34. IARC (Internation Agency for Research on Cancer) (1973) Certain Polycyclic Aromatic Hydrocarbons and Heterocyclic Compounds. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemicals to Man. Volume 3. IARC, Lyon, France, pp. 46-68. Sims, P. and Grover, P.L (1974) Epaxides in polycyclic aromatic hydrocarbon metabolism and carcinogenesis.Adv. Cancer Res. 20:165-274. Wood, A.W., Chang, LL, Levin, W., et al. (1977) Mutagenicity and cytotoxicity of benz(a)anthracene dial epaxide and tearahydroepaxides.Exceptional activity of the bay region 1,2-epoxides. Proc. NatL Acad. SeL USA 74:2746-2750. MA DEP, ORS & BWSC Documotation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 15 BENZO(a]PYRENE GENERAL BACKGROUND INFORMATION Benzo[alpyrene (BaP) is a member of the class of compounds generally referred to as polyaromatic hydrocarbons (PAH). PAHs contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. BaP is a component of fossil fuels and is produced from the incomplete combustion of organic compounds. BaP and other PAHs are found in coal tar, creosote oils and pitches formed from the distillation of coal tars (ATSDR, 1990). PHARMACOKINETICS BaP is readily absorbed by dermal, inhalation and oral routes (see section on Relative Absorption Factors). Distribution of BaP is rapid among several tissues. Following inhalation exposure to 'H labeled BaP, maximum levels of radioactivity were found in the liver, esophagus, small intestine and blood after 30 minutes. After 12 hours, maximum levels were found in the cecum, stomach and large intestine (Sun et al., 1982). This and other studies provide evidence for the enterohepatic circulation of BaP metabolites. Mammalian metabolism of BaP follows the mechanism established for smaller aromatic compounds (Williams, 1959). There is an initial oxidation of a double bond on one of the rings to an arene oxide. The oxide is then hydrolyzed to the diol. Oxidations may occur at multiple sites on the BaP molecule. Phase H metabolism is considered the detoxication pathway and involves the conjugation of the activated Phase I metabolites with easily eliminated substrates such as glutathione, glucuronide or sulfate (Cooper et al., 1983). In addition to being conjugated, the diol intermediate.can undergo (1) further oxidation to several uncharacterized metabolites via the P-450 monooxygenase system, (2) spontaneous rearrangement to the phenol or (3) hydration to the trans- diols through a reaction catalyzed by epoxide hydrolase (Cooper et al., 1983). BaP 7,8-diol-9,10-epoxide has been established as an ultimate carcinogen (ATSDR, 1990). The primary route of excretion of BaP is through the feces. BaP undergoes first-pass metabolism and is reabsorbed via enterohepatic circulation (Chipman et al., 1982). Rats exposed by gavage to "C labeled BaP in peanut oil excreted up to 85% in the feces. Excretion in the urine was 1 to 3% of the administered dose (Hecht et al., 1979). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 16 HUMAN TOXICOLOGICAL PROFILE The database for the toxicological effects of BaP on humans, separate from PAils, is limited. Toxic effects attributable to mixtures of PAHs include a variety of skin lesions and non-cancer lung diseases such as bronchitis (IARC, 1973). MAMMALIAN TOXICOLOGICAL PROFILE BaP is a moderately potent experimental carcinogen in numerous species by many routes of exposure (IARC, 1983). Mice exposed to doses of Ba? ranging from 1.5 to 400 mg/kg/d developed benign and malignant tumors of the forestomach (Hartwell, 1951; Thompson, 1971). Acute intragastric doses of 50 to 67 mg/kg of Ba? have been shown to elicit pulmonary adenomas and forestomach papillomas in mice (Sparnins et al., 1986; Wattenberg and Beuding, 1986). Intermittent gavage exposure of mice to 50 to 67 mg/kg BaP resulted in 100% forestomach and pulmonary tumor incidences at 30 weeks of age (Sparnins et al., 1986; Wattenberg and Leong, 1970). Mice fed Ba? at concentrations equivalent to 33.3 mg/kg/d exhibited gastric neoplasms following two or more days of consumption. However, lower concentrations of BaP (equivalent to 13.3 mg/kg/d) administered for up to 7 days did not produce any forestomach tumors (Neal and Rigdon, 1967). Hamsters have developed papillomas and carcinomas of the alimentary tract following gavage or dietary exposure to BaP (Chu and Malmgrem, 1965). A single oral dose of 100 mg BaP (200mg/kg) produced mammary tumors in 88% of female Sprague-Dawley rats (Huggins and Yang, 1962). A 77% mammary tumor incidence was observed 90 weeks after a single oral dose of BaP of 50 mg (100mg/kg) was administered to rats (McCormick, 1981). GENOTOXICITY There are no studies relating exposure to BaP in humans to genotoxicity. In short-term in vitro and in vivo genetic toxicology tests, BaP has been shown to be a potent genotoxic agent when metabolically activated. In mice, oral exposure to 10 mg/kg BaP produced gene mutations in the mouse coat color spot test (Davidson and Dawson, 1976,1977). Ba? shows positive mutagenic activity, in vitro, in several strains of Salmonella typhimurium in the presence of either rodent microsomes or hepatocytes for exogenous metabolic activation (ATSDR, 1990). Epidemiological studies have shown increased incidences of lung cancer in humans exposed via inhalation to mixtures of PAHs which include BaP (ATSDR, 1990). MA DEP, ORS & BWSC Docunntation for the Risk Assessment Shortform Residential Scenario versions 1.6 a & b - 10/92 B - 17 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) Toxicological crofile for benzo(a)vyrene. U.S. Public Health Service. Chipman, J.K, Hirom, P.C., Front, G.S. and Milburn, S. (1982) Benro(a)pyrene metabolism and enterohepatic ckuladon in the rat. In: Snyder, R. et al. eds. Biological Reactive Intermediates L. Chemical Mechanisms and Biological Bffects.ParA. Plenum Press. New York, pps. 761-768. Chu, B.W. and Malmgren, R.A. (1965) An inhibitory effect of vitamin A on the induction of taorsin the forestomach and cervb: in the Syrian hamster by carcinogenicpo4cyclic hydrocarbons. Cancer Res. 25: 884-895. Cooper, CS., Grover, P.L and Sims, P. (1983) 77e metabolism and activation of benz(a)pyne. In: Bridges, J.W., Chase, LF. eds Prorress in drug metabolism. Vol. 7. John Wiley and Sons, New York. pps. 295-395. Davidson, GE. and Dawson, G.W.P. (1976) Chemically inducedprenmedsomaticmtations in the mouse. Muiat. Res. 38:151-154. Davidson, G.E and Dawson, G.W.P. (1977) Induction of somatic muations in mouse embryos by benzo(a)pyrene. Arch. ToxicoL 38:99-103. Hecht, S., Grabowski, W. and Groth, K. (1979) Analysis offaeces for BaP after consumption of chasroal-broledbeef by rats and humans. Food Cosmet. ToxicoL 17:223-227. Huggins C. and Yang, N.C. (1962) Induction and eainction of mammary cancer, Science 137:257-262. International Agency for Research on Cancer (IARC) (1983) IARC monograph on the evaluation of carcinoenic risk of chemicals to man. Vol 32 IARC, Lyon, France. Mc Cormick, D. et at. (1981) Inhibitionof benro(a)pyreneinduced mammary carcinogenesisby redinyl acetate.J. Natl. Cancer Inst. 66:559-564. Neal, 1. and Rigdon, R.H. (1967) Gastic mmors in mice fed benzo(a)pyrene: A quantitativesudy. Ta. Rep. BIot Med. 25:553-557. Sanders, CL, Skinner, C. and Gelman, RA. (1986) Percutaneous absorption of 7,10 dC-benzo(a)pyrene and 7,12 JC- dimethylbenz(a)anthracenein mice. .E1T0 2:25-34. Sparnins, V.L, Mott, A.W., Baraney, G. and Wattenberg, G. (1986) Effects of allyl methy mudfde on glutathlone-s-tranrferase activity. Natr. Cancer 8:211-215. Sun, J.D., Wolff, LK., and Kanapilly, G.M., (1982) Deposidon, retention and biological fate of inhaled pure benzo(a)pyrene adsorbed onto ulrafneparticles and as a pure aerosol. ToxicoL AppL Pharmacol. 65:231-244. Wattenberg, LW. and Bueding, E (1986) Inhibitory effects of 5-(2-pyrazonyl)-4-methyl-I,2-dihiol-34hione (Oltipraz) on carcinogenesisinduced by benzo(a)ppmne, dethylnirosomine, and uracil mustard. Carcinogenesis 7:1379-1381. Wattenberg, LW. and Leong, J.L (1970) Inhibition of the carcinogenicaction of benzo(a)pyrene byflavones. Cancer Res. 30:1922- 1925. Williams, R.T. (1959) petoxication Mechanisms. 2nd ed. Chapman and Hall, London. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 18 BENZO[b]FLUORANTHENE GENERAL BACKGROUND INFORMATION Benzo[b]fluoranthene (BbF) is a member of the class of compounds referred to as polycyclic aromatic hydrocarbons (PAHs). PAHs contain two or more aromatic rings. PAHs are ubiquitous in nature and are both naturally occurring and man-made. Exposure to BbF can come from air, water, or soil. As a PAH, BbF is present in the emissions from industrial plants that produce coal tar, cooking plants, asphalt production plants, and home heating with wood and coal. BbF is also present in charcoal-broiled foods and cigarette smoke (ATSDR, 1990). PHARMACOKINETICS No data on the absorption, distribution or excretion of BbF were identified. BbF is metabolized under in viro incubation conditions to phenol and dihydrodiol metabolites (Amin et al., 1982). The general metabolic pathways elucidated for benzo(a)pyrene are also active on BbF (Cooper et al., 1983; Levin et al., 1982; Grover et al., 1986). The reactive metabolites associated with the tumorigenic effects of BbF may not be the diol epoxides (Amin et al., 1982; Amin et al., 1985). As for the other PAHs, the material excreted is expected to consist primarily of dihydrodiol and phenol conjugates (Grover et al., 1986). HUMAN TOXICOLOGICAL PROFILE The database for human toxicity is very limited. There are no studies correlating exposure to BbF and cancer or systemic toxicity. The only data implicating BbF as a carcinogen come from carcinogenicity studies using a mixture of PAHs. MAMMALIAN TOXICOLOGICAL PROFILE The database on the toxicity of BbF is limited, Intratracheal administration of BbF to rats resulted in an increase in respiratory tract tumors (Deutsch-Wenzel et al., 1983). BbF has caused skin tumors in mice following dermal application (Wynder and Hoffman, 1959). The skin tumor initiating ability of BbF has been demonstrated in mice using a standard initiation/promotion protocol with either croton oil or phorbol myristate acetate as a tumor promotor (Amin et al., 1985; LaVoie et al., 1979, 1982). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 20 GENOTOXICITY The genotoxicity of BbF has been shown equivocally in three in viro studies. BbF has been shown to be mutagenic in Salmonella typhimurium in the presence of an exogenous rat-liver preparation (LaVoie et al., 1979). Mutagenic activity has been reported in another similar study (Hermann, 1981). Negative results were reported by Mossanda (1979). The results cannot support an unequivocal determination regarding the genotoxicity of BbF at this time. REFERENCES Agency for Toxic Substance and Disease Registry (AISD R) (1990) Toxicololical profile for benzo(b)fluoranthene. U.S. Public Health Service. Amin, S, LaVoie, E.-. and Hecht, &S. (1982) Idendfrcation of metabolizes of benzo(a)fluoramnhene. Carcinogenesis 3:171-174. Amin, S., Huie, K, Hussaur, N., Geddie, I.E. and Hecht, S.S. (1985) Mutagenicity and tumor inidadng actvity of methylated benzo(b)fluoranthenes. Carcinogenesis 6:1023-1025. Cooper, C.S., Grover, P.L and Sims, P. (1983) The metabolism and activationof benzo(a)pyrene. In: Bridges, LW., Chase, LF. cds. Progess in druy metabolism, Vol.7. John Wiley and Sons, New York, pps. 295-395. Deutsch-Wenzel, R.P., Brune, H., Grimmer, 0., Dettbarn, G. and Misfield, J. (1983) Eapeimen sadies in rat lungr on the carcmnogenicity and dose-response relaionshipsof eiglu frequently occuning envonmental polycyclic aromatic hydrocarbons. J. NatLCancer Inst. 71:539-544. Grover, P.L (1986) Pathways involved in the metabolism and activationofpolycyclic aromatic hydrocarbons.Xenobiolica. 16:915- 931. Hermann, M. (1981) Synergistic effects ofindividualpo4cyclicaromatic hydrocarbons and the mutagenicity of theirminres. Muta. Res. 90:399-409. LaVoie, .J., Amin, S., Hecht, SS., Furuya, K and Hoffmann, D. (1979) On the metabolic acdvation of the environmental carcinogens benzo()fluoranthene and beno(b)fluranthene.Proc. Am. Assoc. Ca. 20:81. LaVoie, 2.J., Amin, S., Hecht, S.S., Furuya, K and Hoffmann, D. (1982) Tumour inidating acvy of dihydrodials of benzo(b)fluoranthene,benzoj)wfuoranthene and benzo(k)fluoranthene. Carcinogenesis 3:49-52. Levin, W., Wood, A., Chan& R.L et at (1982) Oxatve metabolism ofpolycylic aromatic hydrocarbonsto ultimate carcinogens. Drug Metab. Rev. 13:555-580. Mossanda, K., Poncelet, F., Fouassin, A. and Mercier, M. (1979) Detection of mutagenic polycyclic aromatic hydrocarbons in African smoked fish. Food Cosmet. ToxicoL 17:141-143. Wynder, E.L and Hoffmann, D. (1959) The carcinogenicityof benzofluoranthenes. Cancer 12:1194-1199. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 21 BENZO[g,h,i]PERYLENE GENERAL BACKGROUND INFORMATION Benzo[g,h,i]perylene is a member of the polyaromatic hydrocarbons (PAH). PAHs constitute a class of non- polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. The data regarding benzo[g,h,i]perylene are limited. As a PAH, it is found in food (charcoal broiled meats), vegetables, tobacco smoke and soot (U.S. EPA, 1980). Exposure occurs by inhalation, ingestion and by dermal contact. PHARMACOKINETICS No data were found regarding the pharmacokinetics of benzo[g,h,i]perylene. HUMAN TOXICOLOGICAL PROFILE No data were found regarding the human toxicology of benzo[g,h,ilperylene. MAMMALIAN TOXICOLOGICAL PROFILE No data were found regarding the mammalian toxicity of benzo[g,h,iperylene. GENOTOXICITY No data were found regarding the genotoxicity of benzo[g,h,ijperylene. REFERENCES U.S. Environmental Protection Agency (U.S. EPA). (1980) An exposure risk assessment of nolycyclic aromatic hydmocarbns (benzo(ehilocrvene). U.S. EPA Contract 68-01-6017. Office of Water Regulations and Standards. Washington, D.C. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 22 BENZO[k]FLUORANTHENE GENERAL BACKGROUND INFORMATION Benzo[klfluoranthene (BkF) is a member of the class of compounds referred to as polycyclic aromatic hydrocarbons (PAIls). PAHs contain two or more aromatic rings. PAHs are ubiquitous in nature and are both naturally occurring and man-made. Exposure to BkF can come from air, water, or soil. As a PAH BkF is present in the emissions from industrial plants that produce coal tar, cooking plants, asphalt production plants, and home heating with wood and coal. BkF is also present in charcoal-broiled foods and cigarette smoke (ATSDR, 1990). PHARMACOKINETICS No data on the absorption, distribution or excretion of BkF were identified. BkF is believed to be metabolized to phenol and dihydrodiol metabolites (ATSDR, 1990). The general metabolic pathways elucidated for benzo[a]pyrene are believed to be active on BkF. As for the other PAHs, the material excreted is expected to consist primarily of dihydrodiol and phenol conjugates (Levin et al., 1982; Cooper et al., 1983; Grover et al., 1986). HUMAN TOXICOLOGICAL PROFILE The database for human toxicity is very limited. There are no studies correlating exposure to BkF and cancer or systemic toxicity. The only data implicating BkF as a carcinogen come from carcinogenicity studies using a mixture of PAHs. MAMMALIAN TOXICOLOGICAL PROFILE The database on the toxicity of BkF is limited. The skin tumor initiating ability of BkF has been demonstrated in mice using a standard initiation/promotion protocol with either croton resin or phorbol myristate acetate as tumor promotors (Van Duuren et al., 1966; LaVoie et al., 1982). Chronic dermal application of benzofk]fluoranthene to mice resulted in no skin tumors, suggesting that BkF alone is not a complete carcinogen (Wynder and Hoffman, 1959). GENOTOXICITY The genotoxicity of BkF has not been documented in in vitro studies. In vivo, a single topical application of BkF was reported to bind to DNA in CD-1 mouse skin (Weyland et al., 1987). Covalent binding of chemicals to DNA can result in strand breaks and DNA damage, ultimately leading to mutations (ATSDR, 1990). REFERENCES Agency for Toxic Substance and Disease Registry (ATSDR) (1990) Toxicological profile for polycylic aromatic hydrocarbons. U.S. Public Health Service. Cooper, CS., Grover, P.L and Sims, P. (1983) The metabolism and activation of benzo(a)pyrene. In: Bridges, J.W., Chase, LF. eds. Proress in drup metabolism, Vol.7. John Wiley and Sons, New York, pp. 295-395. Grover, P.L (1986) Pathways invoked in the metabolism and activationof polycyclic aromatic hydrocarbons.Xenoblotica. 16:915- 931. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1. a & b - 10/92 B - 24 LaVoie, EJ., Amin, S. and Hecht, S.S. (1982) Tumor iitadng acivity ofdihydrodlols ofbenzo(b)fluoranthene, bnodj)luoranthee and beno(k)fluoranthene. Carcinogenesis 3:49-52. Levin, W., Wood, A., Chang, R.L et al. (1982) On'dadve metabolism ofjpolycyclic aromatc hydrocarbons to uldmate carcinoges. Drug Metab. Rev. 13:555--580. Van Duuren, B.L, Sivak, A. and Segal, A. (1966) The tamorproducingagents oftobacco leaf and tobacco smoke condensate. JNCI 37:519. Weyand, EH., Rice, J.E-, and LaVoie, EJ. (1987) 32P-posdabeling analysis of DNA adducts from non-aterant PAN using thin- layer and high performance liquid chromaography.Cancer Latt 37:257-266. Wynder, EL and Hoffmann, D. (1959) The carcinogenicity of benzofluoranthenes. Cancer 12:1194-1199. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 25 CHRYSENE GENERAL BACKGROUND INFORMATION Chrysene is one of the polycyclic aromatic hydrocarbon (PAR) compounds which are formed during the combustion of organic material. Chrysene often exists in particulate form, adsorbing to existing particulate material in air. Human exposure can occur in the workplace (coal and asphalt production plants, cooking plants, smoke houses) or in the environment due to chrysene contamination of air, food, soil and water (ATSDR, 1990). PHARMACOKINETICS Chrysene can be absorbed by all routes of exposure (see section on Relative Absorption Factors). Its absorption is believed to be qualitatively similar to benzo[a]pyrene (ATSDR, 1990). Following absorption, chrysene distributes to all organs, reaching the highest concentration in tissues with large fat content (adipose tissue, mammary tissue, brain) (Modica et al., 1983). Chrysene undergoes metabolic biotransformation mediated by the mixed function oxidase enzyme system to form reactive intermediates hypothesized to be responsible for its toxicity. The major metabolites include trans-dihydrodiols, phenols, diol epoxides and triol epoxides (Thakker et al., 1985). The reactive metabolites are conjugated and excreted primarily in feces (Schiede et al., 1970). HUMAN TOXICOLOGICAL PROFILE There is no information available on threshold toxic effects of chrysene in humans. Since it is structurally similar to benzo[a]pyrene, it would be expected to produce effects similar to B[a]P following acute or chronic exposure (see Toxicity Profile on Benzo[alpyrene). MAMMALIAN TOXICOLOGICAL PROFILE There is no information available on threshold toxic effects of chrysene in animals. Since it is structurally similar to benzo[a]pyrene, it would be expected to produce effects similar to B[a]P following acute or chronic exposure (see Toxicity Profile for Benzo[a]pyrene). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 45 GENOTOXICITY The genotoxicity of chrysene has been evaluated in in vivo and in vitro cytogenetic tests. Chrysene produced weak positive results in bacterial mutation assays, human epithelial mutation studies, cell transformation assays and in vivo cytogenetic studies (Waters et al., 1987). Metabolism of chrysene is essential to produce the observed positive responses. Chrysene is not genotoxic in all test systems, however, it is believed to be a weak mutagen (ATSDR, 1990). The carcinogenicity of chrysene has not been adequately studied. There are no reports directly correlating human chrysene exposure and tumor development. There is limited evidence that chryesene is a skin carcinogen in animals following long-term dermal application (Wynder and Hoffmann, 1959; Hecht et al., 1974). REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) Toxicological profile for chrysene. U.S. Department of Health and HUman Services, Public Health Service. Hecht, S.S., Bondinell, W.E and Hoffmann, D. (1974) Chrysene and methylchrpene: Presence in tobacco anake and carcinogniciky. . NatL Cancer Inst. 53:1121-1133. Modica, R., Fume, M., Guaitani, A. and Bartosek, L (1983) Comparative imdcs of bez[aanthracene,chrysene and ipheylene in rats after oral adminiration.ToxicoL Left. 18:103-109. Schiede, E, Kunlzman, RL, Haber, S.and Conney, A.H. (1970) Effect of enzyme induction on the metabolism anddue disribudon of benrofajpyrene. Canter Res. 30:2898-2904. Thakker, DJL, Yagi, H., Levin, W., Wood, A.H., Conney, A.L and Jerina, D.M. (1985) Po4cyclic aromadc hydrocarbons Metabolic activation of uldmate carcinogens. In Anders, M.W., ed. Bioactivation of Foreign Compounds. Academic Press, New York, pps. 178-242. Waters, M.D., Stack, H.P., Brady, A.L, Lohman, P.H., Haroun, L and Vainio, H. (1987) Use of coendtrized data listinsLand activity Profiles of genetic and'related effects in the review of 195 compounds. Genetic Toxicology Division, Health Effects Research Laboratory, EPA, Reasearch Triangle Park, N.C Wynder, E.L and Hoffmann, D. (159)A sudy of tobacco carcinogenesis.P71. The role of higherpolycyclic hydrocarbons.Cancer 12:1079-1086. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForn Residential Scenario versions 1.6 a & b - 10/92 B3-46 DIBENZO[a,h]ANTHiRACENE GENERAL BACKGROUND INFORMATION Dibenzo[a,h]anthracene is a member of the polycyclic aromatic hydrocarbons (PAI). PAs are a class of compounds which are non-polar and contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. The data regarding dibenzola,h]anthracene are very limited. As a PAHl, it is found in tobacco smoke, food, and the emissions from industrial or natural burning. PHARMACOKINETICS Dibenzo[a,h]anthracene is metabolized similarly to benzo(a)pyrene (ATSDR, 1990). However, while the metabolic profiles of these two compounds (and other alternant PAHs) are qualitatively similar, there are differences in the levels and rates of formation of specific metabolites among tissues and cell preparations used. Sanders et al (1986) applied 14C - dibenzo[a,h]anthracene to the shaved backs of mice. After 24 hours, the majority of activity was recovered from the application site, with the remainder from body tissues and excreta. In comparison, benzo(a)pyrene similarly applied was found predominantly in the excreta and body tissues, with the remainder at the application site. HUMAN TOXICOLOGICAL PROFILE The database for the toxicological effects of dibenzo[a,h]anthracene on humans, separate from other PAHs, is limited. Toxic effects attributable to mixtures of PAHs include a variety of skin lesions and non-cancer lung diseases such as bronchitis (IARC, 1973). MAMMALIAN TOXICOLOGICAL PROFILE Dibenzo[ah]anthracene has been shown to induce skin tumors in lab animals (i.e. it is a complete carcinogen) following dermal exposure (Wyndner and Hoffman, 1959; Van Duuren et al, 1967; and Lijinsky et al, 1965). Dibenzo[a,h]anthracene ahs also demonstrated tumor initiation activity (Slaga et al. 1980). Carcinogenic PAHs as a group has immunosupprssive effects, with the degree of immunosuppression correlated with carcinogenic potency (ATSDR, 1990). Dibenzo[ah]anthracene was also tested for developmental effects via parenteral routes and was found to produce fetolethal effects in rats (Wolfe and Bryan, 1939). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 51 GENOTOXICITY Dibenzo[a,hlanthracene is mutagenic (Barfknecht et al, 1982; Rocchi et al, 1980) and produces DNA damage (Martin et al, 1978) in cultured human cells. Test results in nonhuman systems were also positve (ATSDR, 1990). REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) Toxicolopical orofile for nolvevclic aromatic hydrocarbons. U. S. Public Health Service. Barlknecht, T.R et al. (1982) Human ceu muzagenicky of polycyclic aromadc hydrocarbonscomponens of diesel emissions. Dev. ToxicoL Environ. ScL 10:277-294. Lijinsky, WI, Garcia, B., Terracini, B. (1965) Thmorigenic acdiy of hydrogenated deivadves of dibenz(ah)anthracene.JNCI 34:1. Martin, CN., McDermid, A.C., Garner, R.C (1978) Testing of known carcinogens and noncarcinogensfor their abiii0y to induce unscheduled DNA synthesis in HeLA cells. Cancer res. 38:2621-2627. Rocchi, P. et al. (1980) Poycyclic hydrocarbonsinduction of dptheriasauin-resiamt mutants in human cells. Cardnogenesis 1:765- 767. Sanders, CL, Skinner, C., Gelman, RA. (1986) Pacutaneous absorptdon of 7,10 "C-benro(a)pyrene and 7,12 "C dimethylbenz(a)anthracene in mice. J. Environmental Pathol Toxicol Oncol 7:25-34. Slap, TJ., Gleason, G.L, Well, G. (1980) Comparisonof sin nimor-inidadaactivides in dihydrodioisand dio.epaxide of various polycyclic aromatic hydrocarbons. Cancer Res 40:1981-1984. U.S. Environmental Protection Agency (U.S. EPA) (1981) An exposure and risk assessment of polycyclic aromatic hydrocarbons (dibenz(a.hlanthracenel. U.S. EPA Contract 68-01-6017. Office of Water Regulations and Standards, Washington, D.C. Van Duuren, B.L, Langseth, L Goldschmidt, B.M. (1967) Carcinogencity of eparides, lacones and pemxy compoundt K. Srucas-e and carcinogenic activity. JNCI 39:1217-1227. Wolfe, IM. and Bryan, W.R. (1939) Effects induced in pregnam rat by injection of chemically pure carcinogenic agenu. Am J Cancer 36:359-368. Wydner. EL and Hoffman, D. (1959) A sudy of tobacco carcinogeneis. VI. The role of higher polycyclic hydrocarbons.Cancer 12:1079-1086. MA DEP, ORS & BWSC Documantation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 52 FLUORANTHENE GENERAL BACKGROUND INFORMATION Fluoranthene is a member of the polyaromatic hydrocarbons (PAH). PAHs constitute a class of non-polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. Fluoranthene has been detected in food, cigarette smoke, and smoke from industrial and natural burning. PHARMACOKINETICS No data were found regarding the pharmacokinetics of fluoranthene. HUMAN TOXICOLOGICAL PROFILE The database for the toxicological effects of fluoranthene on humans, separate from other PAHs, is limited. Toxic effects attributable to mixtures of PAHs include a variety of skin lesions and non-cancer lung diseases such as bronchitis (IARC, 1973). MAMMALIAN TOXICOLOGICAL PROFILE The database on the toxicity of fluoranthene is limited. A 13 week subchronic study where CD-1 mice were gavaged with up to 500 mg/kg-day of fluoranthene indicated nephropathy, increased liver weights, hematological alterations and clinical effects (EPA, 1988). A developmental study in which fluoranthene was administered once via intraperitoneal injection to pregnant mice reported only an increased rate of embryo resorption (Irvin and Martin, 1987). Chronic dermal application of up to 1 percent fluoranthene to the backs of mice did not induce skin tumors following lifetime application (Hoffman et al, 1972; Horton and Christian, 1974; and Wydner and Hoffman, 1959a). Fluoranthene is not a complete carcinogen (ATSDR, 1990) and does not exhibit iniation activity (Hoffman et al, 1972). GENOTOXICITY There is some evidence that fluoranthene is genotoxic (ATSDR, 1990). Genotoxic effects have been reported in human cells with exogenous metabolic activation, but negative results were recorded without metabolic activation. MA DBP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 71 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) soncoloecal vrcdlt fornolyeveic aromatic hydrocrbon U. S. Public Health Service. Hoffiman, D. et at. (1972) FluoranthenerQuantiadw detminadon in cigareue.moke, formation bypyrsis and anor inidating acdviy. JNCI 49:1165-1175. Hoton, A.W. and Christian, G.M. (1974) Cocarcinogenicvwus incomplete carcinogenic activity among aromatic hydrocarbons conam between chrysena and benro(b)triphnylene. J Natl Cancer Inst 53:1017-1020. international Agency for Research on Cancer (IARC) (1983) Monograph on the evaluation of chemicals in man, fluoranthene. 32:355-364. Irvin, T.R. and martin, J.B. (1987) In vion and in vvo embryowxiciy of fluoranthene, a majorprenatal onic component of diesel soot. Teratalor 35:65A. U.S. Environmental Protection Agency (EPA) (1988) 13-week mouse oral subcbronic toxicity study. Prepared by Toxicity Research Laboratories, Ltd. Muskegon, MI for the Office of Solid Waste, Washington, D.C. Wydner. E.L. and Hoffman, D. (1959) A saudy of tobacco carcinogenesis.VR. The role of higherpolycyclic hydrocarbons.Cancer 12:1079-1086. MA DEP, ORS & BWSC Documatation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 0 B - 72 INDENO(1,2,3-cd]PYRENE GENERAL BACKGROUND INFORMATION Indeno[1,2,3,-cdJpyrene is a member of the polyaromatic hydrocarbons (PAH). PAHs constitute a class of non- polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. Indeno[1,2,3-cdlpyrene is present in cigarette smoke (IARC, [983) as well as emissions from industrial stacks. PHARMACOKINETICS No data were found regarding the pharmacokinetics of indeno1,2,3-cd]pyrene. However, its metabolism should be similar to another non-alternant PAH, benzo(b)fluoranthene (ATSDR, 1990). HUMAN TOXICOLOGICAL PROFILE The database for the toxicological effects of indeno[1,2,3-cdjpyrene on humans, separate from other PAHs, is limited. Toxic effects attributable to mixtures of PAHs include a variety of skin lesions and non-cancer lung diseases such as bronchitis (IARC, 1973). MAMMALIAN TOXICOLOGICAL PROFILE Studies on laboratoyr animals have demonstrated that indeno(1,2,3-cd]pyrene can induce skin tumors (i.e. it is a complete carcinogen) following dermal exposure (ATSDR, 1990). It has tumor initiating activity, but is not as potent as benzo(b)fluoranthene (Rice et al, 1985). Carcinogenic PAHs as a group are immunosuppressant, with the degree of suppression correlated with the degree of potency (ATSDR, 1990) GENOTOXICITY In test systems using non-human cells, indeno[1,23-cdjpyrene was found to be genotoxic (ATSDR, 1990). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortFonn Residential Scenario versions 1.6 a & b - 10/92 B - 75 REFERENCES Agency for Toxic Substances and Disease Regstry (ATSDR) (1990) Toxicolodcal profile for ohlvelic aromatic hydrocarbons, U. S. Public Health Service. International Agency for Research on Cancer (IARC) (1983) Monograph on he eratuadon of cardnogede risk of chanicals to man, Indeno(iZ3-cd)pyrene. 32:419-430. Rice, JE. t aL (1985) On he metabofim, magencity and anor-indadngacdviy of ino(12Jcd)pyrwe. In Cooke, M. Dennis, A-J. eds. Polynuclear aromatic hvdoarbons: metabolisms, methods and metabolism. Proceedings of the Eighth International Symposium. Columbus, Ohio: Batelle Press, 10970-1109. MA DEP, ORS & BWSC Documtation for the Risk Assessment ShortForm Residential Scenario versions L6 a & b - 10/92 B - 76 NAPHTHALENE GENERAL BACKGROUND INFORMATION Naphthalene is a white solid substance at room temperature. It has a distinct odor of mothballs or tar. Humidity and sunshine cause evaporation into the air within a few hours. When placed in water or soil, bacteria will destroy napbthalene, or will render it airborne within a few hours (ATSDR, 1990). Tobacco smoke is known to release 3 ug of naphthalene per cigarette (U.S. EPA, 1982). The compound is used in the production of dyes, solvents, lubricants, motor fuels (U.S. EPA, 1980) and is a major component of many moth ball preparations. PHARMACOKINETICS Humans can absorb naphthalene by dermal, inhalation and oral routes (see section on Relative Absorption Factors). Metabolism occurs via the P450 mixed function oxidase enzyme system to yield multiple intermediates which are then conjugated. Key metabolites are responsible for each toxicity endpoint following intraperitoncal administration: 2-naphthoquinones -> hemolysis; 1,2-naphtboquinones -- > cataracts; 3-GSH adducts -> pulmonary toxicity (Buckpitt et al., 1984). Excretion of metabolites occurs via urine and feces (ATSDR, 1990). HUMAN TOXICOLOGICAL PROFILE Adults and children exposed to airborne naphthalene experience vomiting, abdominal pain and anemia (ATSDR, 1990). Most of the data is for inhalation of naphthalene from mothballs. The primary site of toxicity is the erythrocyte resulting in hemolytic crisis (hemolytic anemia). Jaundice is seen upon dermal, inhalation, and oral exposures, as are kidney effects (ATSDR, 1990). Near-blindness resulted in male and female subjects with 5 gram ingestion (ATSDR, 1990). MAMMALIAN TOXICOLOGY PROFILE Oral doses in rats have hepatic effects. Dogs (1800 mg/kg) for 5 days of exposure showed signs of lethargy and ataxia, and decreased hemoglobin levels (ATSDR, 1990) GENOTOXICITY No studies of genotoxic effects in humans or laboratory animals were located. No human epidemiological evidence for cancer. Inconclusive evidence for cancer in rats and mice were found (ATSDR, 1990). REFERENCES Agency for Toxic Substances and Disease Registry (ATSD R) (1990) Toxicoloaical profile for nachthatene 2-methvlnapthalene. US. Public Health Service. Buckpitt, A. and Richieri, P. (1984) Comgarative biochemistry and metabolism: Parn 2. Nashtbalene g toxicity. Wright- Patterson Air Force Base, OH: Air Forte Systems Command, Aerospace Medical Division. Air Force Aerospace Medical Research Laboratory. APAMRLTR-84-SS. U.S. Environmental Protection Agency (U.S. EPA) (1980) Ambient water quality criteria for nolEyclic aromatic hydrocarbons. Office of Emergency and Remedial Response. Washington, DC. MA DEP, ORS & BWSC Documnation for the Risk Assessment ShortForm Residential Scenario versions 1A a & b - 10/92 B - 93 PHENANTHRENE GENERAL BACKGROUND INFORMATION Phenanthrene is a member of the polyaromatic hydrocarbons (PAH). PAis constitute a class of non-polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. The database on the potential health effects of phenanthrene is limited. PHARMACOKINETICS Little data are available regarding the pharmacokinetics of phenanthrene. The intestinal absorption of phenanthrene is less dependent on the presence of bile in the stomach than is the absorption of the larger PAHs (such as benzo(a)pyrene) (Rahman et a, 1986). HUMAN TOXICOLOGICAL PROFILE Phenanthrene has been shown to be a skin photosensitizer in humans (Sax, 1984). MAMMALIAN TOXICOLOGICAL PROFILE Phenanthrene has a reported LD 50 of 700 mg/kg in mice (Simmon et al., 1979). Rats injected intraperitoneally evidenced liver effects (Yoshikawa et al, 1987). There is equivocal evidence for cancer from dermal application of phenanthrene in rats (IARC, 1983). Phenanthrene is not a complete skin carcinogen (ATSDR, 1990). It is neither an initiator (LaVoie et al, 1981; Roe, 1962) nor a promoter (Roe and Grant, 1964). Higgins and Yang (1962) reported no tumor production within two months after the ingestion of 200 mg of phenanthrene by rats. GENOTOXICITY There are limited data that suggest that phenanthrene is mutagenic (Wood et al., 1979). However, the majority of tests are negative (ATSDR, 1990). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 96 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) Tozicological profile for nolycyclic aromatic hydrocarbons. U. S. Public Health Service. Higgins, L and Yang, Y. (1962) Inducdon and exuinction of mammary canc. Science 137:257-262. International Agency for Research on Cancer (IARC) (1983) Monograph on the evaluation of carcinogenic rids of chemicals to man, Phenanthme. 32:419-430. LaVoie, K e at. (1981) Mutagenicity and nAmor inidang activity and metabolism ofphenanhena. Cancer Res. 41:3441-3447. Rahman, A., Barrowman, ].A., Rahimtula, A. (1986) The influence of bile on the bioavailability of poiynuclear aromatic hydrocarbonsfrom the rat intestine. Can J Physio Pharmacol 64:1214-121& Roe, F.C. (1962) Effect of phenandreneon mour-initiaian by 3,4-benzpyrene. Br J Cancer 16503-506. Sax, N.I. (1984) Dangerous Properties of Industrial Materials. 6th edition. Van Nostrand Reinhold Company. N.Y. Simmon, P. et al (1979) Mutagenic activity of chemicals carcinogens and reated compounds in the intrapeitonealhost-mediated assay. I. NatL Cancer Inst. 62:911-918. Wood, R. et al, (1979) Mutagenicity and mumorigenicity of phenandtnme and chrysene epoxides and diol epaxides. Cancer Res. 39:4069-4077. Yoshikawa, T. et al. (1987) Taxicity of polycycllc aromatic hydrocarbons L. Effects of beta-naphtoflavone preveament on hepatotoxicityof compoundsproduced in the ozonadon or NO2-niuradonofphenanthrene andpyrene by rats. Vetern HumanToxicoL 29:113-117. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions t.6 a & b - 10/92 B - 97 PYRENE GENERAL BACKGROUND INFORMATION Pyrene is a member of the polyaromatic hydrocarbons (PAH). PAHs constitute a class of non-polar compounds that contain two or more aromatic rings. They are ubiquitous in nature and are both naturally occurring and man-made. As with many of the other PAHs, pyrene has been detected in charbroiled meats and shellfish (US. EPA, 1982). It is found in tobacco smoke, industrial stack smoke, and smoke from forest fires. PHARMACOKINETICS No data were found regarding the pharmacokinetics of pyrene. HUMAN TOXICOLOGICAL PROFILE Pyrene is reported to be a skin irritant (Sax, 1984). MAMMALIAN TOXICOLOGICAL PROFILE Rats given 150 mg/kg of pyrene had changes in blood chemistry, liver and kidney damage (USEPA, 1982). A 1989 EPA study (EPA, 1989) reported nephropathy and decreased kidney weights in mice exposed to 125 mg/kg- day of pyrene by gavage for 13 weeks. Mouse skin painting assays indicate that pyrene is neither a complete skin carcinogen, nor an initiating agent (ATSDR, 1990, IRIS, 1991). GENOTOXICITY The majority of genotoxic tests of pyrene are negative. Positive results have been recorded in Salmonella typhimurium mutagenicity tests and in in vitro mammalian cell systems (ATSDR, 1990). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 16 a & b - 10/92 B - 106 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1990) Todiological Drofile for rolvcdic aromatic hvdroearbons. U. S. Public Health Service. Sax, NJ. (1994) Dangerous Properties of Industrial Materials. 6th Edition. Van Nostrand Reinhold Company. NX. U.S. Environmental Protection Agency (US. EPA) (1982) An exnosure and risk assessment of colvycclic aromatic hydm9Ca1bons L|n0). USEPA Contract 68-01-6017. Office of Water Regulations and Standards, Washington, D.C U.S. Eavironmental Protection Agency (EPA) (1989) Mouse oral subchronic toxdcitv study of nvrene. Prepared by Toxicity Research Laboratories, Ltd. Muskegon, MI for the Office of Solid Waste, Washington, D.C Integrated Risk Information System (IRIS) (1991) U.S. Environmental Protection Agency. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 107 VOLATILE/EXTRACTABLE PETROLEUM HYDROCARBON FRACTIONS - VPHIEPH The following toxicity profile was compiled using information taken directly from MA DEP documents (MA DEP, 1994, 2002, and 2003). Secondary references are cited to the MA DEP document where the information was presented. GENERAL BACKGROUND INFORMATION Petroleum products are a complex and highly variable mixture of hundreds of individual hydrocarbon compounds. Industry specifications for refined products, such as gasoline and diesel fuel, are based upon physical and performance-based criteria rather than on a specific chemical formulation. The compositions of petroleum products released to the environment are therefore complex and variable, and are a function of the origin and chemistry of the parent crude oil, the refining and blending processes, and the use of performance-enhancing additives. Once released to the environment, the chemistry of a petroleum product is further altered by contaminant fate and transport processes, such as leaching, volatilization, and biodegradation (MA DEP, 2002). Although little toxicological data are available for the vast majority of petroleum constituents, it is possible to make some broad observations and conclusions: * Petroleum products are comprised mainly of aliphatic and aromatic hydrocarbon compounds * Aromatic hydrocarbons appear to be more toxic than aliphatic compounds; and * The toxicity of aliphatic compounds appears to be related to their carbon number/molecular weights. These three precepts are the foundation of the VPH/EPH approach. Under this approach, the non-cancer toxicity of petroleum-contaminated media is established by determining the collective concentrations of specified ranges of aliphatic and aromatic hydrocarbons and assigning a toxicity value (e.g., reference dose) to each range. Well-characterized compounds within specified ranges are selected as "surrogate" indicators to define the toxicity of the entire range (e.g., every aliphatic compound having between 5 and 8 carbon atoms (C5-C8 aliphatic hydrocarbons) are assumed to be as toxic as n-hexane). Cancer effects are evaluated separately by the identification and quantitation of those specific hydrocarbons, such as benzene and certain polycyclic aromatic hydrocarbons (PAHs), which are designated carcinogens. (MA DEP, 2002). HUMAN TOXICOLOGICAL PROFILE - General Inhaled or ingested volatile hydrocarbons have both general and specific effects. Many organic solvents, including petroleum hydrocarbons, have the potential on acute high-level vapor exposure to cause central nervous system (CNS) disturbances like disorientation, euphoria, giddiness, and confusion; progressing to unconsciousness, paralysis, convulsion, and death from respiratory or cardiac arrest (Browning, 1965 in MA DEP, 2003). These effects have been observed with aliphatic and aromatic compounds found within the C5 - C9 (aliphatics) and C6 - CIO (aromatics) carbon ranges. The acute narcotic effects of the volatile hydrocarbons result from direct chemical action. The similarity of CNS disruption produced by hydrocarbons of diverse structures suggests that these effects result from a common process, which is physical interaction of the solvents with the cells of the CNS (Andrews and Snyder, 1991 in MA DEP, 2003). For example, interaction of the lipid-soluble hydrocarbons with the synaptosomal membranes causes CNS toxicities. The potency of the CNS effects depends on the structure of the individual hydrocarbon molecule. Other non-specific effects of hydrocarbons are exhibited after prolonged exposure to these agents. The nonspecific effects observed in animals and humans are neurobehavioral toxicities. The neurobehavioral effects are manifested as sensory, cognitive, affective, and motor abnormalities. There is some evidence suggesting that the mechanism of the behavioral effects is alterations in the utilization and turnover of biogenic amines in the brain. These effects occur at lower hydrocarbon concentrations than those producing morphological changes. September 2004 I VPHEPHtoxprofile Recent animal studies indicate that both aromatic (Korsak and Rydzynski, 1996; Gralewicz et al., 1997 in MA DEP, 2003) and aliphatic (Lund et al., 1995 in MA DEP, 2003) volatile hydrocarbons may cause nonspecific neurobehavioral toxicities with differing intensities depending on the structure of the hydrocarbon. Distinct from the general CNS effects of hydrocarbons are their associated specific organ toxicities. Examples of such effects include the hematopoietic toxicity of benzene and the neurodegenerative toxicity of n-hexane. The specific toxicities of hydrocarbons may be directly related to their metabolites, as is the case with benzene and n-hexane (Andrews and Snyder, 1991 in MA DEP, 2003). HUMAN TOXICOLOGICAL PROFILE - Volatile/Extractable Petroleum Hydrocarbon Fractions Aliphatic Fractions gC Aliphatics n-Hexane was originally selected by MA DEP as the indicator for this range because its toxicity has been well investigated and also because of some evidence demonstrating that the other alkanes in the group may have similar neurotoxic capacities. The peripheral neurotoxicity of n-hexane is of particular human health concern, although respiratory and irritation effects have also been observed. Several epidemiological studies have demonstrated that human inhalation exposure to n-hexane resulted in polyneuropathy. In the epidemiological studies, exposure was to n-hexane, commercial grade hexane, or other mixtures within the specified carbon ranges for this fraction. The mixtures contained n-hexane at levels ranging from 12.3 to 60%. The data do not allow comparison of the severity of the neuropathy induced by pure n-hexane or the aliphatic mixtures in the series (MA DEP, 2003). C,-Cl1 Aliphatics Inhalation exposure of painters to white spirit resulted in early disability work status due to neuropsychological disorders. In most of the studies, workers were exposed to mixtures of organic solvents, with the principal component being white spirit. The effects were mainly functional disturbances in the CNS including memory and learning impairments (Lund et al. (1995) and references therein in MA DEP, 2003). C19-. , Aliphatics No human toxicological data are available. However, emerging studies suggest that exposures to petroleum distillates appear to increase the risk of autoimmune diseases (e.g., undifferentiated connective tissue diseases (Lacey et al., 1999 in MA DEP, 2003)). Aromatic Fractions Co-C8 Aromatics In the MA DEP fractions approach (MA DEP, 1994), aromatic hydrocarbons with fewer than nine carbon atoms (e.g., benzene, toluene) are evaluated on a compound-specific basis. No toxicity data were identified on mixtures in this carbon range. However, the MA DEP has selected a representative oral reference dose for the carbon range considering the availability of good toxicity data for styrene, ethylbenzene, and xylenes and compositional information for this fraction. The human health concerns for these compounds include CNS effects, mucous membrane irritations, and developmental and reproductive effects. £ r Aromatics The MA DEP grouped the entire range of C9 -C32 aromatic hydrocarbon compounds as a single fraction for the purposes of deriving the oral RfD. For the purposes of evaluating inhalation toxicity, MA DEP evaluated the C9-C 8 and CL-C32 carbon ranges. September 2004 2 VPHEPHtoxprofile The CrCis fraction includes two and three ring PAHs, such as naphthalene, 2-methylnaphthalene, and fluorene; and alkylated benzenes, such as 1,2,4-trimethylbenzene and isopropylbenzene. The critical effects for these compounds from inhalation exposure are pulmonary, hepatic, renal, CNS, and developmental/reproductive effects. C19 Aromatics No appropriate data were identified to support development of inhalation RfCs for the individual components or mixtures in this carbon range. The compounds in this carbon range are not very volatile and inhalation of gaseous compounds is not a likely route of exposure. ANIMAL TOXICOLOGICAL PROFILE - Volatile/Extractable Petroleum Hydrocarbon Fractions Aliphatic Fractions CCt Aliphatics Overall, the chronic commercial hexane studies used by the Total Petroleum Hydrocarbon Criteria Working Group (TPHCWG) demonstrated that an inhalation exposure to a hexane mixture containing 53% n-hexane produced no toxicity in rodents. However, and most importantly, other chronic human and animal studies showed that commercial hexane causes peripheral neuropathy. In addition, many potential diketone metabolites of n-alkanes produce peripheral neurotoxicity. C9-C 8 Aliphatics New oral gavage studies on various petroleum streams covering C9 - C17 carbon ranges observed adverse effects in the treated animals such as body weight, organ weight, and blood chemistry changes. A recent neurotoxicity study revealed that exposure of rats to dearomatized white spirit for six months induced long- lasting and possibly irreversible effects in the nervous system. In acute animal studies, white spirit with low aromatic content produced significant reductions in animal response to learned performances. Increased levels in brain noradrenaline, dopamine, and 5-hydroxytryptamine were observed in rats exposed to various levels of white spirit. Changes in indices of oxidative stress in the synaptosomes were also reported in animals exposed to white spirit for 3 weeks. £is&' Aliphatics Based on a rat subchronic feeding study of several different highly refined white mineral oil samples representing various mineral hydrocarbon (MHC) sizes, the low molecular weight (average molecular weight 320-420) MHC caused mesenteric lymph node histiocytosis and liver granulomas, while the high molecular weight MIHC demonstrated minimal effect (Smith et at., 1996 in MA DEP, 2003). No inhalation toxicity data are available. Aromatic Fractions LC~s Aromatics See discussion under human toxicological profile. September 2004 3 VPHEPHtoxprofile _2-_C2 Aromatics The C-Ci fraction includes low molecular weight PAHs and alkylated benzenes. Naphthalene is a hematopoietic and pulmonary toxicant. Inhalation exposure to naphthalene produced severe pulmonary damage and lesions in mice (NTP, 1992 in MA DEP, 2003). A recent oral study of a structurally related compound, 1-methylnaphthalene, suggested that the target site might be the pulmonary tissues. Chronic oral administration of 1-methylnaphthalene was associated with significantly increased nodular alveolar proteinosis in mice. A significant increase in pulmonary adenoma was observed in males (Murata et al., 1993 in MA DEP, 2003). In some short-term, high dose experiments, animals exposed to isopropylbenzene exhibited damage to the spleen and fatty changes to the liver. The critical treatment-related effects were to the kidney (Sandmeyer, 1981 in MA DEP, 2003). Rats exposed to trimethylbenzene demonstrated significant changes in CNS function by the behavioral tests in the higher dose groups (Gralewicz et al., 1997 in MA DEP, 2003). Systemic, reproductive, and developmental toxicities have also been demonstrated in animals exposed to C9 aromatic mixtures (MA DEP, 2003). For C19-C3 2 aromatics, see discussion under human toxicological profile. GENOTOXICITY There are no studies relating TPH-VPHIEPH exposure in humans to genotoxicity. An inhalation oncogenicity study of commercial hexane in rats and mice (API, 1995, Part II in MA DEP, 2003) demonstrated liver tumors in female mice in the highest dose group. REFERENCES Andrews, L. S. and Synder, R. 1991. In: MA DEP, 2003. Toxic effects of solvents and vapors. In: Casarett and Doull's Toxicology: The Basic Science of Poisons (M.O. Amadur, J. Doull and C.D., Klaassen, Eds), pp. 681-722. Pergamon Press, New York. API. 1995. In: MA DEP, 2003. An Inhalation Oncogenicity Study of Commercial Hexane in Rats and Mice. Part I and Part II. Toxicology Report No. 40:CAIS No. 41-33.231 and 41-33.232. American Petroleum Institute, Washington, D.C. Browning, E. 1965. In: MA DEP, 2003. Toxicity and Metabolism of Industrial Solvents. Elsevier Publishing Co. New York. pp. 739. Gralewicz, S., Wiaderna, D., Tomas and Rydzynski, K. 1997. In: MA DEP, 2003. Behavioral changes following 4-week inhalation exposure to pseudocumene (1,2,4-trimethylbenzene) in rat. Neurotox. Teratol. 19:327-333. Korsak, Z., Rydzynski, K. 1996. In: MA DEP, 2003. Neurotoxic effects of acute and subchronic inhalation exposure to trimethylbenzene isomers (pseudocumene, mesitylene, hemmimellitene) in rats. Int. J. Occup. Med. Environ. Health 9:341-349. Lacey, J.V., Jr., Garabrant, D.H., Laing, T., Gillespie, B.W., Mayes, M.D., Cooper, B.C., and Schottenfeld, D. 1999. In: MA DEP, 2003. Petroleum distillate solvents as risk factors for undifferentiated connective tissue disease (UCTD). Am. J. Epidemiol. 149:761-770. Lund, S.P., Simonsen, L., Hass, U., Ladefoged, 0., Lam, H.R., and Ostergaard, G. 1995. In: MA DEP, 2003. Dearomatized white spirit inhalation exposure causes long-lasting neurophysiological changes in rats. Neurotox. Terat.18:67-76. MA DEP, 1994. Interim Final Petroleum Report: Development of Health-Based Alternative to the Total Petroleum Hydrocarbon (TPH) Parameter. Office of Research and Standards, Boston. August, 1994. September 2004 4 VPHEPHtoxprofile REFERENCES (Cont'd.) MA DEP, 2002. Characterizing Risks posed by Petroleum Contaminated Sites: Implementation of the MA DEP VPH/EPH Approach. Final Approach. Office of Research and Standards. October 31, 2002. MA DEP, 2003. Updated Petroleum Hydrocarbon Fraction Toxicity Values for the VPH/EPH/APH Methodology. Final. Office of Research and Standards. November 2003. Murata, T., Denda, A., Maruyama, H., et al., 1993. In: MA DEP, 2003. Chronic toxicity and carcinogenicity studies of I-methylnaphthalene in B6C3FI mice. Fundam. Appl. Toxicol. 21:44-51. NTP 1992. National Toxicology Program. In: MA DEP, 2003. Technical report series No. 410. Toxicology and carcinogenesis studies of naphthalene (CAS No. 91-20-3) in B6C3F mice (inhalation studies). Research Triangle Park, NC: U. S. Department of Health and Human Services, US Public Health Service, National Institutes of Health. NIH Publication No. 92-3141. Sandmeyer, E.E. 1981. In: MA DEP, 2003. Aliphatic Hydrocarbons, In: Patty's Industrial Hygiene and Toxicology, 3" Rev. Ed., Vol. 2B. Toxicology, G.D. Clayton and F.E. Clayton, Eds. pp. 3175-3194. John Wiley and Sons, New York. Smith, J.H., Mallett, A.k, Priston, R.A.J., Brantom, P.G., Worell, N.R., Sexsmith, C, and Simpson, B.J. 1996. In: MA DEP, 2003. Ninety-day feeding study in Fischer 344 rats of highly refined petroleum- derived food grade white oils and waxes. Toxicol. Pathol. 24:214-230. September 2004 5 VPH EPHtoxprofile POLYCHLORINATED BIPHENYLS (PCBs) GENERAL BACKGROUND INFORMATION The thermal stability, nonflammability, and dielectric capability of PCBs resulted in their use in electrical capacitors and transformers (NIOSH, 1986). The manufacturing, processing, distribution in commerce, and use of PCBs after January 1, 1978 was prohibited under Section 6(e) of the Toxic Substances Control Act. PCBs can be released to the environment during fires involving electrical equipment containing these compounds. PCBs are strongly adsorbed on solid surfaces, including glass and metal surfaces in laboratory apparatus, and onto soils, sediments, and particulates in the environment. PHARMACOKINETICS Gastrointestinal absorption of most PCB isomers is large. PCBs can also be absorbed by the inhalation and dermal routes but limited data are available (see section on Relative Absorption Factors). Distribution of PCBs follows a biphasic pattern. Initially, PCBs distribute to liver and muscle tissue. They are then redistributed to the fat, skin, and other fat-containing organs (ATSDR, 1989). PCBs are poorly metabolized in humans with major metabolites being 3- or 4-hydroxy compounds. Metabolism may proceed through formation of arene oxide intermediates (U.S. EPA, 1988). The slow metabolism of PCB congeners to more polar compounds is responsible for long biological half-lives of PCBs. Excretion occurs primarily through the feces (Goto et al., 1974). HUMAN TOXICOLOGICAL PROFILE Dermatologic signs are the most persistent indicator of PCB toxicity. Skin manifestations have been observed also in newborn infants of mothers exposed to high levels of PCBs and related compounds. Cases of severe chloracne were reported in a work environment in which PCB air levels were found to be between 5.2 and 6.8 mg/M3 . The workers developing chloracne had been exposed for 2 to 4 years. Other analyses revealed worker complaints of dry sore throat, skin rash, gastrointestinal disturbances, eye irritation, and headache at work area concentrations of 0.013 to 0.15 mg PCB/m3 . Higher blood PCB levels are associated with higher serum triglyceride and/or cholesterol levels, as well as high blood pressure. Air PCB concentrations as low as 0.1 mg/n 3 can produce toxic effects, and exposure to levels producing no overt toxicity can affect liver function. Recovery after termination of exposure occurs but is slow and depends upon the amount of PCBs stored in adipose tissue (Clayton and Clayton, 1981). Human exposures to PCBs resulting in toxic effects have almost all resulted from the ingestion of rice oil contaminated with "Kanechlor 400" in Japan (resulting in Yusho or rice oil disease) or from industrial exposure. Clinical symptoms of poisoning included acne-like skin eruptions (chloracue), eyelid edema, conjunctival discharge, skin and nail pigmentation, and hyperkeratosis. Yusho patients are estimated to have ingested approximately 0.07 mg/kg/day for at least 50 days. The rice oil was found to be contaminated with polychlorinated dibenzofuran, which is believed to have played a significant role in the observed toxicity (Bandiera et al., 1984; Kashimoto et al., 1981). As suggested by laboratory experiments with Rhesus monkeys, fetal and newborn primates, including humans, may be particularly susceptible to PCBs. Fein et al. (1984) studied the effects of low-level chronic exposure to PCBs in pregnant women and their newborn offspring from consumption of Lake Michigan fish. Low levels of PCBs were reported to cause decreases in birth weight, head circumference, and gestational age of the newborn. PCBs were apparently transmitted to the fetus across the placenta and to the newborn through breast milk. Behavioral deficiencies, including immaturity of reflexes and depressed responsiveness, were reportedly observed in infants exposed to PCBs. Jacobson et al. (1984) correlated maternal consumption of PCB-contaminated fish with behavioral abnormalities in newborns, MA DEP, ORS & BWSC Documniation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 100 including autonomic immaturity and depressed responsiveness. The authors likened these responses to similar effects in laboratory animals. MAMMALIAN TOXICOLOGICAL PROFILE PCBs are only slightly toxic in acute exposures to laboratory animals. LD5 values for rats, rabbits, and mice are generally in the range of 1 to 10 g/kg body weight (U.S. EPA, 1980). Nonhuman primates seem to be particularly sensitive to PCB-induced reproductive effects (U.S. EPA, 1980). Dietary exposures of cynomolgus and Rhesus monkeys to 200 ug of Aroclor 1254/kg-day, 5 days per week for 28 months, resulted in symptoms of enlarged tarsal glands, conjunctivitis, loss of eyelashes, progressive detachment of fingernails, exuberant nail beds, hyperplasia of biliary ducts, hepatocellular enlargement and necrosis, and normocytic anemia (Tryphonos et aL, 1986a; Tryphonos et al., 1986b). Effects were less pronounced in cynomolgus monkeys. Monkeys that were fed diets containing 1.0 ppm of Aroclor 1016 for approximately 7 months prior to mating and during pregnancy delivered infants with reduced birth weights (Barsotti and Van Miller, 1984). Fetal mortality occurred at >2.5 ppm (0.1 mg/kg/day) of Aroclor 1248 in the diet in other studies with monkeys (Allen and Barsotti, 1976; Barsotti et al., 1976; Allen et al., 1980). In rats, a dose of 269 ppm of Aroclor 1254 given continuously in the food over the duration of pregnancy caused a decrease in the number of impregnated rats that delivered litters. Pups that were born were underweight, and most died within 7 days of birth. Two lower doses (26 and 2.5 ppm) caused altered neurobehavioral and somatic ontogeny (Overmann et al., 1987). PCBs have been shown to be teratogenic in mice. Cleft palate, dilated kidney pelvis, and thymus hypoplasia were observed. The ED50 (effective dose for 50% of the animals) for formation of cleft palate was a single 100 mg/kg dose, with peak sensitivity occurring on the twelfth day of gestation (d'Argy et al., 1987). Immunological effects (decreased IgM, IgG induction) were noted in monkeys following a 27 month exposure at a dose of 0.005 mg/kg/day (Tryphonos et al., 1989). GENOTOXICITY Most genotoxicity assays of PCBs have been negative. The majority of microbial assays of PCB mixtures and various congeners show no evidence of mutagenic effects (U.S. EPA, 1980). The carcinogenic effects of PCBs have been studied in rats and mice. In a study conducted by Kimbrough et al. (1975) rats were exposed via the diet to 100 ppm Aroclor 1260 for 21 months. Hepatocellular carcinomas were observed in 26 of the 184 treated rats but only in one of the 173 controls. Neoplastic nodules were not found in controls but occurred in 144/184 of treated rats. The National Cancer Institute (NCI, 1978) reported a high incidence of hepatocellular proliferative lesions in male and female Fischer 344 rats fed three dose levels of Aroclor 1254 for 104-105 weeks, but, in part due to the small number of animals tested, carcinogenicity was not statistically demonstrable. Norback and Weltman (1985) fed a diet containing relatively high concentrations Aroclor 1260 (100 ppm for 16 months followed by 50 ppm for an additional 8 months) to Sprague-Dawley rafts. In the PCB-exposed group, neoplastic nodules were observed at 12 months followed by trabecular carcinoma at 15 months and adenocarcinoma at 24 months (52/93). In the control rats, the incidence of hepatocellular neoplasms was low (1/81). Metastases to distant organs was not observed and mortality in the PCB exposed animals was not increased. The incidence of these slow-growing hepatocellular neoplasms was strikingly higher in female rats than in male rats. MA DEP, ORS & BWSC Documrntation for the Risk Assessment ShortForm Residential Scenario versions 16 a & b - 10/92 B - 101 PCBs (Clophen C) have also been shown to be cocarcinogenic. When PCBs were mixed with diethylnitrosamine (DENA), twice as many tumors were observed as were observed in animals treated with DENA alone (Brunn, 1987). Based on the positive evidence for carcinogenicity of Aroclor 1254, Aroclor 1260, Kaneclor 500, and Clophen A-30 and A-60 in animals, along with adequate evidence in humans, the U.S. EPA has placed these PCBs in categroy B2 - probable human carcinogen (U.S. EPA, 1988). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 102 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1989) Toidcolorical irofile for selected PCBs. U.S. Public Health Service. Allen, J.LR., Barsotti, D.A and Carstens, L.A (1980) Resiual effects of polychlorinated biphenyl on adult nonhuman primaues and their ofspring. . ToxicoL Environ. Health 6:55-66. Allen, J.R. and Barsotti, D.A. (1976) The effects of ramsplacentaland mammary movement of the PCBS on infant rhesus monkeys. Toxicology 6:331. Bandiera, S., Farrell, K., Mason, G., Kelley, M., Romkes. M., Bannister, R. and Safe, S. (1984) Comparadve rnie of the polychlorinateddibenzofuran (PCDG) and bipheny$ (PCB) minures which pmist in Yusho vicams. Chemosphere 13507-512. Barsotti, DA., Marlar, RJ. and Allen, J.R. (1976) Reproduction dysfuncion in Rhesus monkeys exposed to low levels of polychloarnatedbiphenyls (Aroclor 1248). Food Cosmet. Toilcol 14:99. Barsotti, DA and Van Miller, J.P. (1984)Accumuladon of a commercialpoochornatedbphenymixture(Aroclor 1016) in adult rhesus monkeys and their nursing infants. Toxicology 30:31-44. Brunn, H., Schmidt, E, Reinacher, M., Manz, D. and Eigenbrodt, E (1987) Histology and histochemisay of the liver of chickens after DENA-induced hepatocarcinogenesisand ingestion of low chlorinatedbiphenyls. Arch. ToxicoL 60337-342. Dayton, F.D. and Qayton, RE. (eds.). (1981) Patty's Industrial Hygiene and Toxicology. Volume 2B, Toxicology, Third Revised Edition. John Wiley and Sons, New York, NY. pp. 3645-3669. d'Argy, R., Dencker, L, Klasson-Wehler, E., Bergman, A. Darnerud, P.O. and Brandt, L (1987) 3,3,4,4'-Tetrachlorobipheylin pregnant mice Embrooxik, terageniciy,and taxi effects on the cultured embryonic dyus. PharmacoL ToxIcoL 61:53-57. Fein, G., Jacobson, J.L, Jacobson, S.W. and Schwarz, P. (1984) Intrauterine exoosure of humans to PCBs (Polychlorinated Biphenvls): Newborn effects. EPA-0/3-84-60. Goto, M., Sugiurn K-, Hattori M., Miyagawa, T. and Okamura, M. (1974) Metabolism of Z3-dichlorobpheny-"Cand Z4,6- richlorobiphenyl- C in the rat. Chemosphent 5:227-232. Jacobson, J.L, Schwartz, PM., Fein, G.G. and Dowler, JK (1984) Prenatalexposure to an environmental taxin; A tes of the multiple effects model. Dev. PsychoL 20:523-532. International Agency for Research on Cancer (IARC) (1982) Monographs on the evaluation or the carcinogenic risk of chemicals to humans. Polychlorinated biphenyls and polybrominated biphenyls. Vol 18. Lyon, France. Kashimoto, T., Tung, T-C., and Ohi, G. (1981) Role of polychlorinated dibenzofuran in Yusho (PCBpoisoning). Arch. Envima. Health 36:321-326. Kimbrough, R.D., Squire, RA., inder, R.E., Strandburg, J.D., Montaili, R.D. and Burs, V.W. (1975) Prepared by PCB Risk Assessment Work Force. In Appendix A, U.S. EPA, 1981. Draft Environmental Impact Statement for the Hudson River PCB Demonstration Reclamation Protect. National Cancer Institute (NCI) (1978) Bioassay of Aroclor 1254 for Possible Carcinoenicity. National Institute for Occupational Safety and Health (NIOSH) (1986) Polychlorinatedbiphenys (PCBs):Potential health hazards from elecrical equipment fires or failures. Current Intelligence Bulletin 45. Norback, D.H. and Weltman, R.H. (1985) Polychlorinatedbiphenyl induction of hepatocellularcarcinoma in the Sprague-Dawley rat. Environ. Health Perspect. 6(:97-105. Overmann, S.R., Kostas, J., Wilson, LR., Shain, W. and Bush, B. (1987) Neurobehavioraland somatic effects of perinatalPCB exposure in rats. Environ. Res. 44:56-70. Tryphonos, L, Charbonneau, S., Tryphonas, H., Zawidzka, Z., Mes, J., Wong, M. and Arnold, D.L (1986a) Comparativeaspect of Aroclor 1254 tzcuy in adult cynomolgus and Rhesus monkeys: A pilot study. Arch. Envimn. Contam Toxicol 15:159-169. Tryphonos, L, Arnold, D.L. Zawidzka, Z., Mes, J., Charbonneau, S. and Wong, J. (1986b) A pilot sudy on adultRhems monkeys (M. munan) oeated with Aroclor 1254 for two years. Toxicol Pathol 14:1-10. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 103 Tryphonos, L, at al. (1989) Immunooxcity Studies of PCB (Arochlor 1254) in the Adult Rhesus (Macca nutafW) Monkey - PteliminaryRepor. Int. J. ImmunopharmacaL 11:199-206. U.S. Environmental Protection Agency (U.S. EPA) (1980) Ambient warer quality criteria for polychlorinated biohenv4. EPA- 440/540-068. Office of Water Regulations and Standards, Washington, DC. U.S. Environmental Protection Agency (US EPA) (1988) Drinking water criteria docurnent f olhorinated bi henvis (PCBs. EACO-4N-414. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 104 ARSENIC GENERAL BACKGROUND INFORMATION The toxicity of arsenic depends upon its chemical form along with the route, dose, and duration of exposure. In general, arsenites (As*) are potentially more toxic than arsenates, soluble arsenic compounds are potentially more toxic than insoluble compounds, and inorganic arsenic compounds are potentially more toxic than organic derivatives (U.S. EPA, 1985). PHARMACOKINETICS Absorption from the gastrointestinal tract is dependent upon the solubility of the specific arsenic compound and the dose. Absorption from the respiratory tract is also dependent upon the specific arsenic compound, along with particle size (see section on Relative Absorption Factors). HUMAN TOXICOLOGICAL PROFILE Depending upon dose and exposure route, arsenic is an irritant of the skin, mucous membranes, and the gastrointestinal tract. Acute toxicity from the ingestion of higher doses of arsenic may result in vomiting, diarrhea, convulsions, a severe drop in blood pressure, and cardiovascular effects. The lethal dose for humans is reported to be 1.0 to 2.6 mg/kg-bw (Vallee et al., 1960). Acute toxicity from inhalation exposure to arsenic adsorbed to particulate matter may result in conjunctivitis and pharyngitis. Subchronic effects included hyperpigmentation (melanosis), multiple arsenical keratoses, sensory-motor polyneuropathy, persistent chronic headache, lethargy, gastroenteritis, and mild iron deficiency anemia. Inhaled arsenic compounds have been reported to be associated with skin lesions, cardiovascular and respiratory effects, and peripheral neuropathy (Stokinger, 1981; [ARC, 1980). Chronic oral exposure of humans to inorganic arsenic compounds has been reported to cause skin lesions, peripheral vascular disease, and peripheral neuropathy (Silver and Wainman, 1952). The incidence of blackfoot disease, a peripheral circulatory disease characterized by gangrene of the extremities, has reportedly been related to the presence of arsenic in the drinking water of residents of the southwest of Taiwan (Tseng, 1977). The symptoms of chronic inhalation exposure to arsenic compounds are similar to those associated with chronic oral toxicity. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 9 MAMMALIAN TOXICOLOGICAL PROFILE Oral LD0 values for trivalent arsenic vary from 15 to 293 mg/kg in rats and from 10-150 mg/kg in other test species (U.S. EPA, 1984). Chronic toxicity data from arsenic exposure to rats cannot be extrapolated to man as the rat is able to store this compound bound to hemoglobin in red blood cells (Lanz et al., 1950). This binding results in extremely slow excretion by rats compared to other species (Mealey et al., 1959). For this reason, dogs have been used to obtain experimental toxicity information. Studies of the subchronic oral toxicity of diets containing sodium arsenite or sodium arsenate in dogs report that arsenite is potentially more toxic than arsenate. The NOEL (no observed effect level) was reported to be 50 mg/kg-diet for both substances (Byron et al., 1967). Schroeder and Balassa (1967) studied the chronic oral toxicity of arsenic on growth and survival in mice. Ingestion of water containing As* at 5 mg/L over two years is reported to have resulted in decreased survival and reduced median life span in male and female mice. No information regarding chronic inhalation exposure of experimental animals to arsenic could be located in the available literature. Animal studies to test the teratogenic potential of arsenic have been performed. Matsumoto et al. (1973) reported decreased fetal weight in oral doses of up to 40 mg-arsenate/kg-bw/day administered to pregnant mice for three consecutive days. Diets containing up to 100 mg-arsenite/kg-diet, however, were reported to have had no effect on offspring (Kojima, 1974). No data regarding the teratogenicity of inhaled arsenic could be found in the literature. GENOTOXICITY Nearly all results of gene mutation studies for arsenic (IIl) and arsenic (V) compounds have been negative. Arsenite and arsenate also have been inactive in gene-specific mutation assays in yeast and in cultured mammalian cells. In contrast, arsenic (III), arsenic (V), arsenite and arsenate have been found to result in chromosome aberrations and sister chromatid exchanges in cultured animal and human cells tested in vitro (ATSDR, 1987). There is limited evidence that occupational exposure to arsenic may cause chromosome changes in humans (Beckman et al., 1977). Beckman et al. (1977) reported an increase in gaps, chromatid aberrations and chromosome aberrations from mine workers at a smelter in northern Sweden. The majority of tests in which experimental animals were exposed orally to a variety of arsenic compounds produced negative results regarding carcinogenicity (Hueper and Payne, 1962; Byron et al., 1967). A few studies have, however, reported tumorigenic effects of arsenic treatment (Schrauzer et al., 1978). Mixed results were reported in arsenic inhalation studies (Ishinishi et al., 1977; Ivankovic et al., 1979). Epidemiological studies conducted in the U.S. have failed to correlate the incidence of skin cancer with arsenic in drinking water (Morton et al., 1976; Goldsmith et al., 1972). A dose-response relationship between the occurrence of skin cancer and arsenic consumption in the drinking water of Taiwanese, however, was reported by Tseng et al. (1977). Arsenic exposure at certain doses may produce a pattern of skin disorders, hyperpigmentation, and keratosis that may develop into basal or squamous cell carcinoma (U.S. EPA, 1985). Several epidemiological studies of workers occupationally exposed to arsenic have reported a correlation between this exposure and mortality due to respiratory cancer (Higgins et al., 1982; Enterline and Marsh, 1982; Brown and Chu, 1983). Based upon epidemiological data, the EPA has classified arsenic as Group A -Human Carcinogen. REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1987) Toxicological profile for arsenic. U.S. Public Health Service. Beckman, G. et al., (1977) Chromosome aberrations in workers apsed to arsenic. Environ. Health Perspect. 19:145. Brown, C.C. and Chu, KC. (1983). Implicadons ofthe mutistage theory of carcinogenesis applied to occupational arsenic epomr. J. NatL Cancer Inst. 70:455-463. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 10 Byron, W.R., Bierbower, G.W., Brouwer, J.B. and Hansen, W.H. (1967) Pathological changes in rau and dogs from two-year feeding of sodium arsenite or sodium arsenate. ToxicoL AppL Pharmiacol. 10:132-147. Enterline, P.E. and Marsh, G.M. (1982) Mortality among workers eposed to arsenic and other substances in a copper smelter. Am. J. EpidentioL 116:895-910. Goldsmith, J.R. et al. (1972) Evaluation of health implications of elevated arsenic in well water. Water Res. 6:1133-1136. Higgins, I., Welch, K. and Burchfiet, C. (1982) Mortality of Anaconda smelter workers in relation to arsenic and other exposures. Dept. of Epidemiology, Univ. of Michigan, Ann Arbor, MI, Hueper, W.C. and Payne, W.W. (1962) Experimental studies in metal carcinogenesis. Chromium, nicke4 iron, arsenic. Arch. Environ. Health 5:445. IARC (International Agency for Research on Cancer). (1980) Arsenic and arsenic compounds. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemicals to Humans. WHO, Lyon, France. 23:39-142. Ishinishi, N., et al (197). Preliminay ctperimental study on carcinogenicity of arsenic aioxide in rat lung. Environ. Health Perspect. 19:191-196. Ivankovic, S., Eisenbrand, 0. and Pressman, R. (1979) Lung carcinoma induction in BD rats after single intratracheal instillation of an arsenic containing pesticide miLure fonnerly used in vineyards. Int. J. Cancer 24:786-788. .Kojima, H. (1974) Sadies on developmental pharmacology of arsenie. 11. Effect of arsenite on pregnancy, nutidon, and hard tissue. Fol. Phanacol. Japon. 70:149-163. 74 Lantz, H., Wallace, P.W. and Hamilton, 3.0. (1950) The metabolism of arsenic in laboratory animals using As as trace. Univ. Cailf Pub. Pharmacol. 2:263-282. Mealey, J., Bronwell, G.L and Sweet, W.H. (1959) Radioarsenic inplasma, urine, normal tissues, and intracranialneoplasms. Arch. Neurl. Psychiatry 81:310-320. Morton, W., Starr, G., Pohl, D., Stoner, J., Wagner, S. and Weswig, P. (1976) Skin cancer and water arsenic in Lane County, Oregon. Cancer 37:2523-2532. ' Schrauser, G.N., White, J.E., McGinness, J.E., Schneider, Cl. and Bell, LJ. (1978) Arsenic and cancer: Effects of joint administration of arsenite and selenite on the genesis of mammary adenocarcinoma in inbred female C3H/ST mice. Bioorg. Khim. 9:245-253. Schroeder, H.A and Balassa, JJ. (1967) Arsenic, germanium, tin, and vanadium in mice: Effects on growth, survival and tissue levels. . Nutr. 92:245-252. Silver, A.S. and Wainman, P.L (1952) Chronic arsenic poisoning following use of an asthma remedy. JAMA 150:584. Stokinger, I.E. (1981) The Metals: Arsenic. In: Patty's Industrial Hygiene and Toxicology, Vol. II, 3rd ed., CD. Clayton and P.E. Clayton, Ed.; John Wiley and Sons, Inc., NY. pp. 1517-1531. Tseng, W.P. (1977) Effects and dose-response relationships of skin cancer and Blackfoot Disease with arsenic. Environ. Health Perspect. 19:109-119. U.S. Environmental Protection Agency (EPA) (1985) Health advisories for 52 chemicals which have been detected in drinking water. Office of Drinking Water. N11S PB860118338. U.S. Environmental Protection Agency (EPA) (1984) Health effects assessment for arsenic. ECAO-H020. Prepared for the Office of Emergency and Remedial Response by the Environmental Criteria and Assessment Office. Vallee, BL, Ulmer, D.D. and Wacker, W.E.C. (1960) Arsenic toxicology and chemistry. Arch. Ind. Health 21:132-151. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 11 CADMIUM GENERAL BACKGROUND INFORMATION Cadmium typically exists in the environment as a salt of the +2 valence state or as a metal. It forms no stable organic compounds. Cadmium releases are generally associated with mining, smelting, manufacturing operations, and from the disposal of alkaline batteries containing cadmium (Doull, 1980; U.S. EPA, 1981). PHARMACOKINETICS Cadmium is absorbed by all routes of exposure (see section on Relative Absorption Factors). Absorption through the gastrointestinal tract is low, respiratory absorption more efficient and dermal absorption relatively insignificant (ATSDR, 1989). Absorbed cadmium is widely distributed throughout the body, with the major portion of the body burden located in liver and kidney (Sumino et al., 1975). The distribution of cadmium is linked to the distribution of metallothionein, a low-moleculer-weight protein, rich in cadmium-binding sites. Cadmium is not known to undergo any direct metabolic conversions in vivo. The principle excretory route for absorbed cadmium is urinary. Excretion is slow, accounting for the long half-life of cadmium in the body (17-38 years) (ATSDR, 1989). HUMAN TOXICOLOGICAL PROFILE Cadmium is a local respiratory tract irritant. Systemic symptoms occur in a few hours after an acute exposure to cadmium dust or fumes. Upper respiratory tract irritation is followed by coughing, chest pain, sweating, and chills These symptoms resemble nonspecific upper respiratory infection (Sittig, 1985). Within 24 hours severe pulmonary irritation may develop, with progressively increasing pain in the chest, dyspnea, pulmonary edema, cough, and generalized weakness. Chronic exposure to cadmium fumes may result in emphysema-like lung damage (Sittig, 1984). Renal dysfunction may ensue (Friberg, 1950). Bernard and Lauwerys (1984) observed that the gastrointestinal tract is adversely affected by acute oral exposure with such symptoms as nausea, vomiting, salivation, abdominal pain, cramps, and diarrhea. The principal effects of chronic cadmium exposure are osteomalacia and osteoporosis (Itai Itai disease) secondary to glomerular and tubular necrosis in the kidney. The Itai Itai ("ouch-ouch") disease is endemic areas in Japan, which have been contaminated with mining wastes containing cadmium. Victims display the osteomalacia and osteoporosis as primary symptoms, as well as protein, sugar and amino acids not normally found in the urine. Other chronic effects include immunosuppression and decreases in measures of respiratory fitness (ventilation capacity, vital capacity, forced expiratory volume, etc.) (U.S. EPA, 1981). MAMMALIAN TOXICOLOGICAL PROFILE Several subchronic and chronic oral toxicity studies have been conducted in animals. Koller et al. (1975) and Fitzhugh and Meiller (1941) conducted feeding studies using mice and rats, respectively. The first group of researchers reported immunological impact manifested by a decrease in the number of lymphocytes secreting antibodies (to sheep red blood cells) as well as some renal effects. The second set of authors observed hematological symptoms expressed as marked anemia. Yuhas et al. (1979) conducted a drinking water study using Sprague-Dawley male rats. Decreased weight gain was observed at the highest dose level. In addition, the authors identified increases in cadmium content and decreases in the zinc content of the bone. Renal dysfunction or otherwise generalized adverse effects on the kidney have been reported in a number of long-term cadmium ingestion studies (Friberg et al., 1974; Kijikawa et al., 1981; Schroeder et al., 1964; Kanisawa and Schroder, 1969). In addition, the latter two research groups have observed renal and cardiac arteriosclerosis. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 aB - 28 GENOTOXICITY Results of mutagenicity tests in bacteria and yeasts have been inconclusive. Positive results have been obtained in mutation assays in Chinese hamster cells and in mouse lymphoma cells. Conflicting results have been obtained in assays of chromosomal aberrations in human lymphocytes treated in vitro or obtained from exposed workers. Cadmium treatment in vitro or in vivo appears to result in aneuploidy in germ cells of mice or hamsters (ATSDR, 1989). Reports of elevated prostate cancer in cadmium workers have been evaluated as insufficient evidence of the carcinogenic action of the compound (U.S. EPA, 1985), but the elevated risk of lung cancer observed by Thun et al. (1985) is more convincing. Thus, the carcinogenic potential of inhaled cadmium should be viewed as limited, but suggestive. Although ingestion of cadmium may result in kidney effects, no carcinogenic response has been demonstrated for this route. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 29 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1989) Toxicolosical orofile for cadmium. U.S Public Health Service. Bernard, A. and Lauwerys, R. (1984) Cadmium In the human populaton. Experimenti 40:143-152. DouR, J., lassen, C.D. and Amdur, M.D. (1980) CAsarett and Doull's Toxicolory. 2nd ed., MacMillan Publishing Co.., Inc. New York. Fitzhugh, O.G. and Meiller, F.H. (1941) The chronic toxicity of cadmium. . Pharm. Exp. Ther. 72:15. Friberg, L (1950) H ealth hazards in the manufacure of alkaline accumulatorswith specialreffence to chronic cadmiumpoisoning. Acts. Med. Stand. 138(Suppl. 240): 1-124. Friberg, L, Piscator, M., Nordberg, G.F. and Kjelstrom, T. (1974) Cadmium in the Environment, 2nd ed., CRC Press, Boca Raton, FL Kanisawa, M. and Schroeder, HA. (1969) Life term studiers on the effect of o-ace elements on spontaneous uamors in mice and rauts. Cancer Res. 29:892-895. Kijikawa, K., Nakanishi, L and Kuroda, K. (1981) Morphological changes of the kidney and bone of rats in chronic cadmium poisoning. Exp. Molec. PathoL 34:9-24. Koller, LD., Exon, J.H. and Roan, J.G. (1975) Antbody suppression by cadmium. Arch. Environ. Health 30:598. Schroeder, HA, Balassa, JJ. and Vinton, W.H. (1964) Chromium, lea4 cadmium, nicke, and titanium in mice: Effects on morality, tumors and tissue levels. . Nutr. 83:239-250. Sittig, M. (1985) Handbook of Toxic and Hazardous Chemicals and Carcinocens. Noyes Publication; Park Ridge, NJ. Sumino, K., Hayakawa, K., Shibata, T. and Kitamura, S. (1975) He"vy metals in normal Japanesetissues. Arch. Environ. Health 30:487-494. Thun, MJ., Schnorr, T.M., Smith, A., Halperin, WE. and Lewen, RA. (1985) Mortality among a cohort of U.S. cadmium production workers - an update. J. Nall. Cancer Inst. 74:325-333. U.S. Environmental Protection Agency (EPA) (1981) Health assessment document for cadmium Environmental Criteria and Assessment Office. EPA-600/8-81/023. U.S. Environmental Protection Agency (EPA) (1985) Cadmium contamination of the environment: an assessment of nationwide rizk. Office of Health and Environmental Assessment. EPA-440/4-85-023. Yuhas, E.M., Miya, T.S. and Schnell, R.C. (1979) Dose-related alterations in growth and mineral deposiaon by chronic oral cadmium adminisrationin the male rat. Toxicology 12:19-29. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 30 CHROMIUM GENERAL BACKGROUND INFORMATION Chromium is used in plating for corrosion resistance and decorative purposes (appliances, tools, automobiles, etc.), in the manufacture of alloys (including stainless steel and heat resistant alloys), and in printing, dyeing, photography, tanning, and numerous other industrial applications (ATSDR, 1989). PHARMACOKINETICS Absorption studies of chromium compounds indicate that it is absorbed by all routes of exposure (see section on Relative Absorption Factors) with chromium (VI) compounds being more readily absorbed than chromium (III) compounds. Once absorbed, chromium is rapidly distributed to all organs, including the developing fetus. Chromium VI is readily reduced to Cr III in vivo. Excretion occurs primarily through the kidneys via urine (ATSDR, 1989). HUMAN TOXICOLOGICAL PROFILE In humans, the respiratory tract is the primary system of concern for chromium toxicity. Renal damage has also been observed. Hexavalent chromium has been shown to be highly toxic, causing ulceration of nasal mucosa and carcinoma of the lung following long-term occupational exposure. Cases of acute poisoning in man have been reported from the medical use of chromic acid. Chronic exposures of workers in chromium-related industries have been observed to result in skin and nasopharyngeal irritations. Both Cr(II) an Cr(VI) can cause allergic contact dermatitis and irritation (Samitz and Shrager, 1966). Chromium was shown to be an allergen in recurrent contact dermatitis of the feet (Correia and Brandao, 1986). Hexavalent-forms are responsible for effects on the upper respiratory system, including ulceration and perforation of the nasal septum, chronic rhinitis, and pharyngitis. Lindberg and Hedenstierna (1983) reported that subjective and objective evidence of adverse nasal effects were found at exposure levels of 2 to 20 ug Cr(VI)/m but not at less than 1 ug/m. They also reported that workers exposed to 2 to 20 ug Cr(VI)/m' had slight transient decreases in measures of pulmonary mechanics (e.g., forced vital capacity, FVC) with recovery (no changes) seen by two (non-exposed) days later. MAMMALIAN TOXICOLOGICAL PROFILE In laboratory animals, Cr compounds are of low oral acute toxicity. Hexavalent chromium is more acutely toxic than Cr(III), with kidney failure being the primary symptom. The LC, in rats for inhalation of sodium 3 chromate(VI) was reported as 33 mg Cr/m /4H, and the LD5,'s for oral and dermal exposures were given as 16.7 mg Cr/kg and 514 mg Cr/kg, respectively (Gad et al., 1986). Chromium was found to localize in the proximal renal tubules when intraperitoneal doses of potassium dichromate were administered to rats 5 times weekly for 8 months (Berry et al., 1978). Low level hexavalent chromium exposure increases respiratory defense mechanisms while they are inhibited by long-term, high level exposure (Glaser et al., 1985). Chromium salts have been shown to be teratogenic and embryotoxic in mice and hamsters following intravenous or intraperitoneal injection. However, these are unnatural routes of administration for assessing effects of environmental exposures, and further research is needed (U.S. EPA, 1984). GENOTOXICITY Both Cr(III) and Cr(VI) have been shown to interact with DNA in bacterial systems. Cr(III) is generally considered to be a relatively inactive genotoxic agent since it is unable to cross cell membranes. It was recently MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario verions 1.6 a & b - 10/92 B - 41 shown, however, to cause chromosomal aberrations in human lymphocytes (Friedman et al., 1987). Hexavalent chromium has consistently caused transformations and mutations in a wide variety of in vitro assays (Bianchi and Lewis, 1985). Chromosomal damage has been observed in lymphocytes cultured from workers exposed to chromium. The epidemiologic studies of respiratory cancer in chromate production workers provide the bulk of the evidence for chromium carcinogenicity. Studies of chromate production facilities in the United States, Great Britain, and Japan have all found an association between occupational exposure to chromium and lung cancer (US. EPA, 1984). Workers were exposed to both Cr(VI) and Cr(III), and it is unclear whether Cr(VI) alone is the etiologic agent or whether Cr(III) is implicated as well. The U.S. EPA (1984) concluded that in rats, only calcium chromate had consistently produced lung tumors by several routes of administration, and that other Cr(VI) compounds produced local sarcomas or lung tumors in rats at the site of administration (subcutaneous, intraperitoneal, intermuscular, intrabroncheal, and intratracheal). Trivalent chromium compounds have not been found to be carcinogenic by any route of administration, but these compounds have not been studied as extensively. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 42 REFERENCES Agency for Toxic Substances and Disease Registry (ATSDR) (1989) Toxicological profile for chromium. U.S. Public Health Service. Berry, JP., Houdry, J., Galle P. and Laquie, G. (1978) Chromium conceraion by proximal renal tubule cellsan ulrasmuceral micnoanalydcal and cyrochemical sdy. J. Histochem. Cytochem. 26:651-657. Bianch, B. and Lewis, AG. (1985) Mechanisms of chromium genoraxicity. In: Merian, E., Fe, R.W., Hardi, W. and Schlatter, C. (eds). Carcinorenic and Mutagenic Metal Compounds : Environmental and Analytical Chemistry, and Biological Effects. Gordon and Breach Science Publishers, London. Correia, S., and Brandao, F.M. (1986) Contact damadtids of the feet. Derm. Beruf Umwelt. 34:102-106. Friedman, J, Shabtai, F., Levy, LS. and Djaldetti, M. (1987) Chromium chloride-induced chromosomal aberadons in human 4mphocyres via indirect action. Mutat. Res. 191:207-210. Gad, S.C., Powers, WJ., Dunn, BJ., Hoffman, G.M., Siino, K.M. and Walsh, R.D. (1986) Acute tmicity offour chromate salu. In; Serrone, D.M., ed. Chromium Symposium 1986: An Update. Pittsburgh, PA: Industrial Health Foundation, Inc., pp. 43-58. Glaser, U., Hochrainer, D., Kloppel, H. and Kuhuen, H (1985) Low-leel chromium (VI) effects on alveolar macrophagesand immune funcdons in War rats. Arch. ToxicoL 57:250-256. indberg, R.G. and Hedenstierna, L (1983) Chromeplating: Symptoms, findings in the upper airways and effects on lung function. Arch. Environ. Health 38:367-374. Samitz, M.H. and Shrager, J. (1966) Patch test reactions to heravalent and nivalen chromium compounds. Arch DenmafoL 94:304- 306. US. Environmental Protection Agency (U.S. EPA) (1984) Health assessment document for chromium. Final Report EPA-600/8- 83-014F. Environ. Criteria and Assessment Office, Res.Triangle Park, N.C. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 43 LEAD GENERAL BACKGROUND INFORMATION Lead is used extensively in the manufacture of storage batteries and was used in gasoline and paint. Lead is also a natural constituent of many soils, for which concentrations normally range from 10 to 30 mg lead per kilogram of soil (U.S. EPA, 1980). PHARMACOKINETICS Lead can be absorbed by the oral, inhalation or dermal exposure routes (see section on Relative Absorption Factors). Gastrointestinal absorption of lead varies considerably depending upon chemical form, dietary intake, and age (Forbes and Reina, 1974; Barltrop and Meek, 1975). The deposition and absorption of inhaled lead depends upon particle size, chemical form and the rate and depth of breathing (Randall et al., 1975; Nozaki, 1966; Chamberlain et al., 1975). Once absorbed, lead is distributed to the various organs of the body, with most distribution occurring into mineralized tissues (ATSDR, 1990). Placental transfer to the developing fetus is possible (Bellinger et al., 1987). Inorganic lead is not known to be biotransformed within the body. Absorbed lead is excreted via the urinary or fecal routes (ATSDR, 1990) HUMAN TOXICOLOGICAL PROFILE Cases of acute lead poisoning in humans are not common and have not been studied in experimental animals as thoroughly as chronic lead poisoning. Symptoms of acute lead poisoning from deliberate ingestion by humans may include vomiting, abdominal pain, hemolysis, liver damage, and reversible tubular necrosis (U.S. EPA, 1984). Subacute exposures in humans rpportedly may produce a variety of neurological effects including dullness, restlessness, irritability, poor attention span, headaches, muscular tremor, hallucinations, and loss of memory. Nortier et al., (1980) report encephalopathy and renal damage to be the most serious complications of chronic toxicity in man and the hematopoietic system to be the most sensitive. For this reason, most data on the effects of lead exposure in humans are based upon blood lead levels. The effects of lead on the formation of hemoglobin and other hemoproteins, causing decreased levels, are reportedly detectable at lower levels of lead exposure than in any other organ system (Betts et al., 1973). Peripheral nerve dysfunction is observed in adults at levels of 30 to 50 Lg/dL-blood. Children's nervous systems are reported to be affected at levels of 15 tg/dL- blood and higher (Benignus et al., 1981). In high doses, lead compounds may potentially cause abortions, premature delivery, and early membrane rupture (Rom, 1976). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 77 MAMMALIAN TOXICOLOGICAL PROFILE Acute oral lethal doses of lead in animals depend upon chemical form, but generally range from 500 to 30,000 mg/kg. Several reproduction studies on the effects of subchronic oral exposure to lead in rats have been conducted (Kimmel et al., 1976; Grant et al., 1980; Fowler et al, 1980). These studies report that lead acetate administered in drinking water at various concentrations caused depressed body weights at 50 and 250 mg-Pb/L water, histological changes in the kidneys of offspring, cytokaryomegaly of the tubular epithelial cells of the inner cortex at concentrations greater than or equal to 25 mg/L and postnatal developmental delays at 50 to 250 mg/L Higher oral doses of lead may result in decreased fertility and fetotoxic effects in a variety of species (Hilderbrand et al., 1973). A reduction in the number of offspring of rats and mice exposed to 25 mg Pb/L drinking water with a chromium deficient diet was reported by Schroeder et al. (1970). Chronic oral exposure of female Long-Evans rats to lead (5 mg/PB/L-water) reportedly resulted in slight effects on tissue excitability, systolic blood pressure, and cardiac ATP concentrations (Kopp et al., 1980ab). GENOTOXICITY Results of in vitro studies with human lymphocyte cultures using lead acetate were nearly equally positive and negative. Results of in vivo tests are also contradictory but suggest that lead may have an effect on chromosomes (sister chromatid exchange). Results for gene mutations, DNA modification, and recombinations in various microorganisms using lead acetate, lead nitrate and lead chloride were consistently negative with or without metabolic activation. Lead chloride has been reported to inhibit both DNA and RNA synthesis. In in vitro mammalian test systems, lead acetate gave conflicting results. No epidemiological data regarding the oral carcinogenic potential of lead could be located in the available literature. Chronic inhalation may result in a statistically significant increase in deaths due to tumors in the digestive organs and respiratory systems in lead smelter workers and battery plant workers (Kang et al, 1980). Several studies have reported tumor formation in experimental animals orally administered specific lead salts, not normally ingested by humans (Zawirska and Medras, 1972; Boyland et al, 1962; Ito, 1973). The carcinogenicity of inhaled lead in experimental animals could not be located in the available literature. The U.S. EPA has classified lead and lead compounds as Group B2 - Probable Human Carcinogens. MA DEP, ORS & BWSC Documntation for the Risk Asessment ShortFonn Residential Scenario versions 1.6 a & b - 10/92 B - 78 REFERENCES Agency for Toic Substances and Disease Registry (ATSDR) (1990) Toxicolopical mofile for lead. U.S. Public Health Service. Baritrop, D. and Meek, F. (1975) Absorption of different lead compounds. Postgrad. Med. J. 51:805-809. Bellinger, D.C, Leviton, A., Waternaux, C., Needleman, H. and Rabinowitz, M. (1987) Longitudinalanalyser ofprenataland postnatal lead eapossre and early cognitive development. N. EngL J. Med. 316.1037-1043. Benignus, V.A., Otto, D.A., Muller, K. and Seiple, KJ. (1981) Effects of age and body lead burden on CNS fuicon in young children. H EEG specra. Electroencephalograph. Clin. NeurophysioL 52:240-248. Betts, P.R., Astley, R. and Raine, R.N. (1973) Lead inaxicadon in children in Birmingham. Br. Med. J. 1:402-406. Boyland, E., Dukes, CE, Grover, P.L and Mitchley, B.CV. (1962) The induction of renal tumors by feeding hada~rt to rats. Br. J. Cancer 16:283-288. Chamberlain, D. et al. (1975) Uptake of lead by inhalation of motor ehaus. Proc. Roy. Soc. London IL 192:77-110. Forbes, G.B. and Reina, J.C (1974) Effect of age on gamoimestinalabsorption (Fe, Sr, Pb) in the rat. J. Nutr. 102:647-652. Fowler, B A et al. (1980) Chronic low level lad taxiciy in the rat Xi. An integratedassessment of long-tamn azicity with special reference to the kidney. ToxdcoL AppL PharmacoL 56:59-77. Grant, LD. et al. (1980) Chronic low-leve lead oicity in the rat: . Effects on posnatalphysical and behavioral development. ToxicoL AppL PharmacoL 56.42-58. Hilderbrand, D.C et al. (1973) Effect of lead acetate on reproduction. Am. J. Obstet. GynecoL 115:1058.1065. Ito, N. (1973) Experimental stdies on munmorson the urinary system of rats induced by chemical carcinogens.Acts. PathoL (Jap.) 23:87-109. Kang, H.D. et al. (1980) Occupational lead oposrre and cancer: Letter to the Editor. Science 207:935. Kopp, L et al. (1980a) Altered metabolism andfunction of rat heartfollowing chronic low level cadmium/leadfeeding. J. Mol Cell. CardioL 12:1407-1425. Kopp, L. et al. (1980b) Cardiacphysiological-meabolc changes after chronic low-level heavy metal feeding. Am. J. Physiol 239:H22-H30. Nortier, J.W., Sangster, B. and Van Kestern, R.G. (1980) Acute lead poisoning with hemolysis and Liver wicity after ingeston of red lead. Vet. Hun. ToxicoL 22:145-147. Nozaki, K. (1966) Method for studies on inhaledparicles in human respiratorysystem and retentionof leadfume. Ind. Health (lap.) 4:118-128. Randall, K. et at, (1975) The effect of particle size on absorption of inhaledlead. J. An Ind. Hyg. Assoc. 36:207-213, Rom, W.N. (1976) Effects of lead on female reproduction:A review. Mt. Sinal J. Med. 43:542-552. Schroeder, P. et al. (1970) Zirconium, niobium, tn, vanadium, and lead in rats: Lifeterm studies. J. Nutr. 100:59-8. MA DEP, ORS & BWSC Documatation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 79 US. Environmental Protection Agency (US. EPA) (1980) Ambient water ouality criteria document for lead. Office of Regulations and Standards, U.S. Environmental Protection Agency (U.S. EPA) (1984) Drinking water criteria document on lead (Quantification of toxicological effects section) Office of Drinking Water. Zawirska, B. and Medras, K. (1972) The rok of the kidneys in disondersofporphydn muabolisn duringcawinogmesis induced nwh lead acaze. Arch. mmunoL Ther. Exp. 20:257-272. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 80 MERCURY GENERAL BACKGROUND iNFORMATION Mercury has been used in the past for medicinal purposes (Gosselin et al., 1984). There are a number of occupations associated with mercury exposure, particularly through inhalation. These include mining smelting, chloralkali production, and the manufacture of mercury-containing products such as batteries, measuring devices (thermometers) and paints. Mercury has also been used agriculturally as a seed and cereal protectant and as a fungicide. PHARMACOKINETICS The pharmacokinetics and pharmacodynamics of mercury depend largely on its chemical form, organic, inorganic or elemental. Absorption efficiencies vary depending on route of exposure and chemical form (see section on Relative Absorption Factors). Distribution, metabolism and excretion depend largely on the lipid solubility, ionization state and molecular size of the specific chemical form (ATSDR, 1989). HUMAN TOXICOLOGICAL PROFILE Exposure to most forms of mercury is associated with a high degree of toxicity. Elemental (metallic) mercury causes behavioral effects and other nervous system damage. Inorganic mercury salts do not generally reach the brain, but will produce kidney damage. Divalent (mercuric) mercury is substantially more toxic in this regard than the monovalent (mercurous) form. Organic mercury compounds are also toxic. Symptoms of chronic mercury poisoning can be both neurological and psychological in nature as the central nervous system is the primary target organ. Hand and finger tremors, slurred or scanning speech patterns, and drunken, stupor-like (ataxic) gait are some motor-control impairments that have been observed in chronic mercurial toxicity. Visual disturbances may also occur, and the peripheral nervous system may be affected. A psychological syndrome known as erethism is know to occur. It is characterized by changes in behavior and personality including depression, fearfulness, restlessness, irritability, irascibilty, timidity, indecision, and early embarrassment. Advanced cases may also experience memory loss, hallucination, and mental deterioration. MAMMALIAN TOXICOLOGICAL PROFILE In a study by Mitsumori et al. (1981), male and female mice were fed methyl mercury chloride in their diet for up to 78 weeks. Most of the high dose group died from neurotoxicity before the 26th week. Renal tumors developed in 13 of 16 males in the intermediate dosage group by 53 weeks while only 1 male in the control group developed tumors. No renal tumors occurred in exposed or control females. Studies on rats have reported similar effects such as damage to kidneys and the peripheral nervous system (U.S. EPA, 1980). Mice treated with alkyl mercury phosphate were reported to have an increased frequency of offspring with cleft palates (Obarazawa, 1968) while mice treated with methylinercury had offspring with sigruficantly lowered birth weights and possible neurological damage (Fujita, 1969). No adequate epidemiological studies exist on the teratogenic effects of methylmercury on humans (U.S. EPA, 1980). GENOTOXICITY Skerfving et al. (1974) reported a statistical relationship between chromosome breaks and concentrations of methyl mercury in the blood of Swedish subjects on fish diets. Concentrations were reported to be from 14-116 ng Hg/mi in the blood of exposed subjects and from 3-18 ng/ml in nonexposed subjects. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForn Residential Scenario versions 1.6 a & b - 10/92 B - 81 REFERENCES Agency For Toidc Substances and Disease Registry (AThDR) (1989) Toxicolonical profile formercurY. U.S. Public Health Service. Fujita, . (1969) Eycpifmenta edies on organic mercwypoisoning The behavior of Minamata Disease causal agent in mateai bodies and it nnsfer to their infants via either placenta or breast milk. Jour. Kumanoro Med. Soc. 43:47. Gosselin, T.A. et al. (1984) Principles of ainical Toxicoloev. Raven Press; New Yort Mitsumori, K., Maita, K., Saito, T., Tsuda, T. and Shikasu, Y. (1981) Carcinogenicityof methyl macury chloride in ICR mice: Preliminarynote on renal carcinogens.Cancer Lett. 12:305-310. Oharazawa, H. (1968) Chromosomalabnormaide and teraogenesisinducedbythyl mercuricphosphate in pregnantmice.Nippon Sanka-Fujinka Gakk. Zasshi 20:(1) 479. Skerfving, S. et a. (1974) Methylmecury-induced chromosome damage in man. Environ. Res. 7:83. U.S. Environmental Protection Agency (U.S. EPA) (1980) Ambient water quality criteria for mercury. Office of Water Standards and Regulations. EPA 440/540-058. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 82 SILVER GENERAL BACKGROUND INFORMATION Silver is used in photographic materials, batteries, paints and jewelry. Silver is used medically in dental amalgam and in medical supplies for burn treatment. Photographic materials are the major source of silver that is released into the environment. Trace amounts of silver are found in water from natural sources and industrial waste. PHARMACOKINETICS Studies in humans and animals indicate that silver compounds are absorbed readily by the inhalation and oral routes. Individuals and individual organs absorb silver selectively. The greatest concentrations are found in the reticuloendothelial organs. Silver undergoes oxidation and reduction reactions within the body and is excreted primarily via the fecal route (ATSDR, 1990). HUMAN TOXICOLOGICAL PROFILE Blue-gray discoloration of the skin has been observed in many individuals who have ingested metallic silver and silver compounds over periods of months to years. This condition is termed argyria. The pigmentation of the skin is primarily in sun-exposed areas. Silver-containing granules are also observed in the dermis. Gradual accumulation of 1 to 5 grams of silver will lead to generalized argyria. The discoloration is not known to be diagnostic of any other toxic effect (ATSDR, 1990). Occupational exposure to silver dusts can lead to respiratory and gastrointestinal irritation. The average air level was estimated to range from 0.039 to 0378 mg/m3. Duration of employment ranged from less than one year to greater than ten years. Symptoms included abdominal pain, sneezing, stuffiness, and sore throat. Granular deposits were also observed in the conjunctiva and corneas of the eyes (Rosenman et al., 1979; 1987). Medical case histories indicate that dermal exposure to silver and silver compounds for extended periods of time can lead to local skin discoloration similar in nature to the generalized pigmentation seen after repeated oral exposure. The amount of silver and the duration of exposure necessary to produce this effect have not been established (McMahon and Bergfeld, 1983). MAMMALIAN TOXICOLOGICAL PROFILE Oral doses of 1,680 mg/kg silver colloid resulted in the deaths of rats after four days (Dequidt et al., 1974). Ingestion of silver nitrate and silver chloride will also cause deposition of silver granules in the skin of animals (Walker, 1971). Granules were observed in the eyes of rats exposed to silver nitrate in drinking water at doses of 222 mg/kg/day over 37 weeks. These doses also cause general deposition in other tissues (Matuk et al., 1981). Mice given oral doses of 18.1 mg/kg/day silver nitrate for 125 days were observed to have silver deposits in their nervous systems. These animals were less active than unexposed controls (Runghy and Danscher, 1984). Silver has been found in the brains of neonatal rats whose mothers received silver lactate on days 18 and 19 of gestation (Rungby and Danscher, 1984). No studies were located that examine the reproductive effects of silver in animals or humans. GENOTOXICITY Silver is not mutagenic in bacteria but it has been found to cause DNA damage in mammalian cell culture (Robinson et al, 1982). No studies were located regarding cancer in humans or animals following oral, inhalation or dermal exposure to silver or silver compounds (ATSDR, 1990). MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 108 REFERENCES Agency for Toxic Substances and Disease Registry (AThDR) (1990) Toxicolozical profile for silver. U.S Public Health Service. Dequidt, J., Vasseur, P. and Gomez-Potentier, P. (1974) Expdimenzal toxicological sndy of some 4!VCr derivadves. Bulletin de Societe de Pharnacle de Lille 1:2335. Maruk, Y., Ghosh, M. and McCulloch, C. (1981) Distibution of slver in he eyes and plasma proteinsof the albino rat. Can. J. OphthabnoL 16:1391-1395. McMahon, J.T. and Bergfeld, W.F. (1983) Metallic cutaneous contaminant mimicking malignant melanoma. Cleveland Clinic Quarterly 50:177-181. Robinson, S.H., Cantoni, 0. and Costa, M. (1982) Strandbreakage and decreased molecular weight of DNA induced by specifc meal compounds. Carcinogenesis 3:657-662. Rosenman, K.D., Moss, A. and Kon, S. (1979) Argyia: Clinicalimplications of expoure to ilver niate and silver axide. J. Occup. Med. 21:430-435. Rosenman, K.D., Seis, N. and Jacobs, L (1987) Potendal nephrotaxic effects of eposre to aiver. Br. J. Ind. Med. 44:267-272. Rungby, J. and Danscher, G. (1984) Hypoacdry in siyve oposed mice. Acta PhannacoL ToxIco 55:398401. Walker, P. (1971) Fiperimentalargyria: a model for basement membrane sulle. Br. J. Exp. PathoL S2:589-593. MA DEP, ORS & BWSC Documntation for the Risk Assessment ShortForm Residential Scenario versions 1.6 a & b - 10/92 B - 109 APPENDIX F Analytical Reports WESTERN MASS ENVIRONMENTAL e 2008, Project 1484 APPENDIX . Report Date: Final Report - 01-Jul-05 17:07 o Re-Issued Report 0 Revised Report SPECTRUM ANALYTICAL, INC. Featuring IIANIBAL TECHNOLOGY Laboratory Report Jacques Whitford Company, Inc. - 24 Albion Rd, Suite 220 Project: 40 Forest St-Attleboro, MA Lincoln, RI 02865 Project #: 1000400 Attn: Kurt Klages Laboratory ID Client Sample ID Matrix Date Sampled Date Received SA29522-01 SED-15 Sediment 13-Jun-05 13:35 15-Jun-05 15:33 . SA29522-02 SED-16 Sediment 13-Jun-05 13:50 15-Jun-05 15:33 SA29522-03 SED-17 Sediment 13-Jun-05 14:25 15-Jun-05 15:33 SA29522-04 SED-18 Sediment 13-Jun-05 14:45 15-Jun-05 15:33 SA29522-05 SED-19 Sediment 13-Jun-05 15:05 15-Jun-05 15:33 SA29522-06 SED-20 Sediment 13-Jun-05 15:30 15-Jun-05 15:33 SA29522-07 SED-21 Sediment 13-Jun-05 15:50 15-Jun-05 15:33 SA29522-08 SW-1 Surface Water 13-Jun-05 13:40 15-Jun-05 15:33 -- SA29522-09 SW-2 Surface Water 13-Jun-05 13:55 15-Jun-05 15:33 SA29522-10 SW-3 Surface Water 13-Jun-05 14:50 15-Jun-05 15:33 SA29522-11 SW-4 Surface Water 13-Jun-05 15:10 15-Jun-05 15:33 SA29522-12 SW-5 Surface Water 13-Jun-05 15:35 15-Jun-05 15:33 SA29522-13 KE1 Ground Water 14-Jun-05 12:45 15-Jun-05 15:33 SA29522-14 KEI 6"-2Ft Soil 14-Jun-05 12:25 15-Jun-05 15:33 - I attest that the information contained within the report has been reviewed for accuracy and checked against the quality control requirements for each method. All applicable NELAC requirements have been met. Please note that this report contains 32 pages of analytical data plus Chain of Custody document(s). This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. Massachusetts Certification # M-MA138/MAl110 Connecticut # PH-0777 -- Florida # E87600/E87936 Maine # MA138 New Hampshire # 2538/2972 New York # 11393/11840 Rhode Island # 98 -Hanilil'C. Thyh, Ph.D. USDA # S-51435 . President/Laboratory Director . Vermont # VT-11393 Spectrum Analytical, Inc. is a NELAC accreditedlaboratory organizationand meets NELAC testing standards. Use of the NELAC logo however does not insure that Spectrum is currentlyaccreditedfor the spec ic method indicated. Pleaserefer to our "Quality" webpage at www.spectrum-analyticaltcomforafull listing of our current certifications. ENVIRONMENTAL ANALYSES 11 Almgren Drive - Agawam, Massachusetts 01001 ' Operational Building &Sample Receiving 830 Silver Street - Agawam, Massachusetts 01001 'Administrative Offices, Volatile &Air Departments Page 1 of 32 1-800-789-9115' 413-789-9018 - Far 413-789-4076 CASE NARRATIVE: The data set for work order SA29522 complies with internal QC criteria for the methods performed. The samples were received @ 5.0 degrees Celsius. An infrared thermometer with a tolerance of +/- 2.0 degrees Celsius was used immediately upon receipt of the ampies. MADEP has published a list of analytical methods (CAM) which provides a series of recommended protocols for the acquisition, analysis and reporting of analytical data in support of MCP decisions. "Presumptive Certainty" can be established only for those methods published by the MADEP in the MCP CAM. The compounds and/or elements reported were specifically requested by the client on the Chain of Custody and in some cases may not include the full analyte list as defined in the method. According to WSC-CAM 5/2004 Rev.4, Table 11 A-1, recovery for some VOC analytes have been deemed potentially difficult. Although they may still be within the recommended 70%-130% recovery range, a range has been set based on historical control limits. Please refer to "Notes and Definitions" for all sample/analyte qualifiers. Qualifiers will note any exceedance levels and issues relating to sample analysis/matrix. This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 2 of 32 Sample Identification Client Project # Matrix Collection Dateffime Received SED-15 1000400 Sediment 13-Jun-05 13:35 15-Jun-05 - SA29522-01 jjA. No. Analyte(s) Result *RDLUnits Diludon Method Ref. Prepared Analyzed Batch Analyst Flag W ivolatile Organic Compounds by GCMS PARs by SW846 8270C Prepared by method SW846 3545A 33-32-9 Acenaphthene BRL, 419 pg/kg dry 1 SW846 8270C 20-Jun-05 22-Jun-05 5061237 203-96-8 Acenaphthylene BRL 419 pg/kg dry I 120-12-7 Anthracene BRL 419 pg/kg dry 1 "I" 56-55-3 Benzo (a) anthracene 449 419 pg/kg dry I " 50-32-8 Benzo (a) pyrene BRL 419 pg/kg dry I 205-99-2 Benzo (b) fluoranthene BRL 419 pg/kg dry 1 " 191-24-2 Benzo (g,h,i) perylene BRL 419 pg/kg dry 1 207-08-9 Benzo (k) fluoranthene BRL 419 pg/kg dry I 21"-1-9 Chrysene 470 419 pg/kg dry I " " 53-70-3 Dibenzo (ah) anthracene BRL 419 pg/kg dry 1 206-44-0 Fluoranthene 1,540 419 pg/kg dry 1 " " 86-73-7 Fluorene BRL 419 pg/kg dry 1 " " 193-39-5 Indeno (1,2,3-cd) pyrene BRL 419 pg/kg dry I . " 9012-0 1-Methylnaphthalene BRL 419 pg/kg dry I " " " " 91-57-6 2-Methylnaphthalene BRL 419 pg/kg dry I "f " 91-20-3 Naphthalene BRL 419 pg/kg dry 1 *" " " 85-01-8 Phenanthrene 508 419 g/kg dry 1 "f " " 129-0-0 Pyrene 805 419 pg/kg dry I "f " "f Surrogate recoveries: 321-0-8 2-Fluorobiphenyl 76.9 30-130% " " " - 1-0 Terphenyl-d14 66,0 30-130% " otalI Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 5.29 mg/kg dry 1 SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7440-38-2 Arsenic 24.5 7.94 mg/kg dry I " 7440-39-3 Barium 1,540 2.65 mg/kg dry 1 " " " " 7440-43-9 Cadmium 7.01 1.32 mg/kg dry I if " f " 744047-3 Chromium 1,110 2.65 mg/kg dry I * * " " 7439-97-6 Mercury 3.62 0.499 mg/kg dry I SW846 7471A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 163 3.97 mg/kg dry I SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 7.94 mg/kg dry 1 " " " "f General Chemistry Parameters % Solids 35.7 % 1 SM2540 G 16-Jun-05 17-Jun-05 5061074 JAK Mod. Total Organic Carbon 225,000 100 mg/kg dry 1 SW846 9060 28-Jun-05 28-Jun-05 5061939 AW This laboratory report is not valid without an authorized signatureon the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 3 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received SED-16 1000400 Sediment 13-Jun-05 13:50 15-Jun-05 SA29522-02 AS No. Analyte(s) Result *RDIAnts Dilution Method Ref: Prepared Analyzed Batch Analyst Flag Wemivolatile Organic Compounds by GCMS PANs by SW846 8270C Prepared by method SW846 3545A 83-32-9 Acenaphthene BRL 393 pg/kg dry 1 SW8468270C 20-Jun-05 22-Jun-05 5061237 208-96-8 Acenaphthylene BRL 393 pg/kg dry 1 120-12-7 Anthracene BRL 393 pg/kg dry 1 56-55-3 Benzo (a) anthracene 528 393 pg/kg dry 1 50-32-8 Benzo (a) pyrene 528 393 pg/kg dry 1 205-99-2 Benzo (b) fluoranthene 544 393 pg/kg dry 1 191-24-2 Benzo (g,h,i) perylene BRL 393 pg/kg dry 1 207-08-9 Benzo (k) fluoranthene 469 393 pg/kg dry 1 218-01-9 Chrysene 600 393 pg/kg dry 1 53-70-3 Dibenzo (ah) anthracene BRL 393 jig/kg dry 1 206-44-0 Fluoranthene 1,700 - 393 pg/kg dry " - f 86-73-7 Fluorene BRL I 393 pg/kg dry N" f i 193-39-5 Indeno (1,2,3-ed) pyrene BRL 393 sg/kg dry I "f i"f 90-12-0 1 -Methylnaphthalene BRL 393 pg/kg dry I 91-57-6 2-Methylnaphthalene BRL 393 pg/kg dry 1 91-20-3 Naphthalene BRL' 393 pg/kg dry 1 " - f i 85-01-8 Phenanthrene 651 393 pg/kg dry I 129-00-0 Pyrene 842 393 pg/kg dry I Surrogate recoveries; 321-0-8 2-Fluorobiphenyl 58.3 30-130% q 18-51- Terphenyl-d14 44.2 30-130% otal Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 5.32 mg/kg dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7440-3-2 Arsenic BRL - 7.99 mg/kg dry 7440-39-3 Barium 220 2.66 mg/kg dry 7440-43-9 Cadmium 2.74 1.33 mg/kg dry 7440-47-3 Chromium 26.0 2.66 rg/kg dry 7439-97-6 Mercury 1.61 0.496 mg/kg dry SW846 7471A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 822 3.99 mg/kg dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 7.99 mg/kg dry General Chemistry Parameters % Solids 35.3 I SM2540 G 16-Jun-05 17-Jun-05 5061087 JAK Mod. Total Organic Carbon 313,000 100 mg/kg dry I SW846 9060 28-Jun-05 28-Jun-05 5061939 AW This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 4 of 32 Sample Identification SED-17 Client Project # Matrix Collection Date/Time Received - SA29522-03 1000400 Sediment 13-Jun-05 14:25 15-Jun-05 U No. Analytes) Restilt t RDL/Unlus Dilution Method Ref. Prepared Analyzed Batch Analyst flag Nractable Petroleum Hydrocarbons EPHAliphaic/Aromatic Ranges Prepared by method SW846 3545A C9-C 18 Aliphatic BRL 187 mg/kg dry I +MADEP 20-Jun-05 30-Jun-05 5062034 JD Hydrocarbons 5/2004 R C19-C36 Aliphatic BRIL 187 mg/kg dry I " Hydrocarbons CI I-C22 Aromatic BRIL 187 mg/kg dry I Hydrocarbons Unadjusted CII-C22 Aromatic BRL 187 mg/kg dry I Hydrocarbons Total Petroleum Hydrocarbons BRL 187 mg/kg dry I - Unadjusted Total Petroleum BRIL 187 mg/kg dry 1 "I" Hydrocarbons Semivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3545A 83-32-9 Acenaphthene BRL 463 pg/kg dry I SW846 8270C 20-Jun-05 22-Jun-05 5061237 205-96-S Acenaphthylene BRI, 463 pg/kg dry I " " " 120-12-7 Anthracene BRIL 463 pg/kg dry 1 "I" 56-55-3 Benzo (a) anthracene BRL 463 pg/kg dry 1 ." 50-324 Benzo (a) pyrene BRIL 463 pg/kg dry I " " " 205-99-2 Benzo (b) fluoranthene BRL 463 pg/kg dry I " " N N 191-24-2 Benzo (gii) perylene BRL 463 pig/kg dry I " 20748-9 Benzo (k) fluoranthene BRL 463 pg/kg dry I " 1-9 Chrysene BRL 463 pg/kg dry It " 3 Dibenzo (ah) anthracene BRIL 463 pg/kg dry 1 " 20644-0 Fluoranthene 631 463 pg/kg dry 1 " " 86-73-7 Fluorene BRIL 463 sg/kg dry 1 "I" 193-39-5 Indeno (1,2,3-cd) pyrene BRL 463 pg/kg dry 1 " 90-12-0 1-Methylnaphthalene BRL 463 pg/kg dry 1 " 91-574 2-Methylnaphthalene BRL 463 pg/kg dry I " " 91-20-3 Naphthalene BRL 463 pg/kg dry I " " 85-01-S Phenanthrene BRL 463 pg/kg dry It " 1290-0 Pyrene BRIL 463 pg/kg dry It " Surrogaterecoveries: 32140-8 2-Fluorobiphenyl 76.1 30-130 % " 1718-51-0 Terphenyl-dl4 46.6 30-130% " " Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 6.51 mg/kg dry I SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7440-38-2 Arsenic BRL 9.76 mg/kg dry 1 "I " 7440-39-3 Barium 46.0 3.25 mg/kg dry I " " " " " 7440-43-9 Cadmium 3.55 1.63 mg/kg dry 1 "I " " " 7440-47-3 Chromium 115 3.25 mg/kg dry 1 "H " " 7439-976 Mercury BRL 0.602 mg/kg dry 1 SW846 7471A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 91.8 4.88 mg/kg dry I SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 9.76 mg/kg dry I " " " " General Chemistry Parameters . % Solids 29.1 % 1 SM2540 G 16-Jun-O5 17-Jun-05 5061087 JAK Mod. Total Organic Carbon 260,000 100 mg/kg dry 1 SW846 9060 28-Jun-05 28-Jun-45 5061939 AW This laboratory report is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 5 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received SED-18 1000400 Sediment 13-Jun-05 14:45 15-Jun-05 SA29522-04 AI S No. Anatlefs) Result *RDI~Inls Dilution Method Ref Prepared Analyzed Batch Analyst Flag Wxtractable Petroleum Hydrocarbons EPHAliphatic/A romaticRanges Prepared by method SW846 3545A C9-C18 Aliphatic BRL 170 mg/kg dry 1I +MADEP 20-Jun-05 30-Jun-05 5062034 J Hydrocarbons 5/2004 R C19-C36 Aliphatic BRL 170 mg/kg dry 1 "If Hydrocarbons Cl 1-C22 Aromatic BRL 170 mg/kg dry 1 " " "t Hydrocarbons Unadjusted C 1-C22 Aromatic BRL 170 mg/kg dry I Hydrocarbons Total Petroleum Hydrocarbons BRL 170 mg/kg dry I Unadjusted Total Petroleum BRL 170 mg/kg dry 1 Hydrocarbons Semivolatile Organic Compounds by GCMS PAiHs by SW846 8270C Prepared by method SW846 3545A R-0s 83-32-9 Acenaphthene BRL 419 pg/kg dry 2 SW846 8270C 20-Jun-05 22-Jun-05 5061237 208-96-8 Acenaphthylene 2 BRL 419 pg/kg dry " " "t 120-12-7 Anthracene BRL 419 pg/kg dry 2 56-55-3 Benzo (a) anthracene BRL 419 pg/kg dry 2 " " " 50-32-4 Benzo (a) pyrene BRL 419 pg/kg dry 2 205-99-2 Benzo (b) fluoranthene BRL 2 419 pg/kg dry " " " 191-24-2 Benzo (g,h,i) perylene 2 BRL 419 pg/kg dry " " 207-08-9 Benzo (k) fluoranthene BRIL 419 pg/kg dry 2 B-01-9 Chrysene BRL 419 pg/kg dry 2 ", " " -70-3 Dibenzo(ah) anthracene BRL 2 419 pg/kg dry " 206-44-0 Fluoranthene 796 419 pg/kg dry 2 86-73-7 Fluorene BRL 2 419 pg/kg dry "t 193-39-5 Indeno (1,2,3-cd) pyrene BRL 419 pg/kg dry 2 90-12-0 1-Methyinaphthalene BRL 419 pg/kg dry 2 " " t 91-57-6 2-Methylnaphthalene BRL 419 pg/kg dry 2 91-20-3 Naphthalene BRL 419 pg/kg dry 2 85-01-8 -Phenanthrene BRL 419 pg/kg dry 2 129-00-0 Pyrene BRL 419 pg/kg dry 2 " Surrogaterecoveries: 321-60-8 2-Fluorobiphenyl 52.8 30-130% 1718-51-0 Terphenyl-d4 34.7 30-130% " Total Metals by EPA 600017000 Series Methods 7440-22-4 Silver BRL 5.69 mg/kg dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7440-38-2 Arsenic BRL 1' 8.53 mg/kg dry " "t " 7440-39-3 Barium 75-5 2.84 mg/kg dry 7440-43-9 Cadmium 3.41 1.42 mg/kg dry 7440.47-3 Chromium 27.6 2.84 mg/kg dry 7439-97-6 Mercury 0.541 0.506 mg/kg dry SW846 7471 A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 114 4.27 mg/kg dry SW8466010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 8.53 mg/kg dry General Chemistry Parameters % Solids 33.2 0 I SM2540 G0 16-Jun-05 17-Jun-05 5061087 JAK Mod. Total Organic Carbon 242,000 100 mg/kg dry I SW846 9060 29-Jun-05 29-Jun-05 5062062 AW This laboratoryreport Is not valid without an authorized signatureon the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 6 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received SED-19 1000400 Sediment 13-Jun-05 15:05 15-Jun-05 SA29522-05 No. Analyte(s) R esult *RDLIUnits Dilution Method Ref. Prepared Analyzed Batch Analyst Flag W ractable Petroleum Hydrocarbons EPH Aliphatic/4romaticRanges Prepared by method SW846 3545A C9-CI8 Aliphatic BRL 101 mg/kg dry 1 +MADEP 20-Jun-05 30-Jun-05 5062034 JD Hydrocarbons 5/2004 R CI 9-C36 Aliphatic' BRL 101 mg/kg dry 1 " Hydrocarbons C11 -C22 Aromatic BRL 101 mg/kg dry I Hydrocarbons Unadjusted Cl 1-C22 Aromatic BRL 101 mg/kg dry I Hydrocarbons Total Petroleum Hydrocarbons BRL 101 mg/kg dry I Unadjusted Total Petroleum BRL 101 mg/kg dry I Hydrocarbons - Semivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3545A 93-32-9 Acenaphthene BRL 250 pg/kg dry I SWS46 8270C 20-Jun-05 22-Jun-05 5061237 - 208-96-S Acenaphthylene BRL 250 pg/kg dry 1 "f 120-12-7 Anthracene BRL 250 pg/kg dry 56-55-3 Benzo (a) anthracene BRL 250 pg/kg dry 1" - 50-32-S Benzo (a) pyrene BRL 250 pg/kg dry I "f 205-99-2 Benzo (b) fluoranthene BRL 250 pg/kg dry 1 i 191-24-2 Benzo (g,h,i) perylene BRL 250 pg/kg dry I "f 207-08-9 Benzo (k) fluoranthene BRL 250 pg/kg dry I if BRL 250 pg/kg dry 0 0-31-9 ChryseneDibenzo (a,h) anthracene BRL 250 pg/kg dry 206-44-0 Fluoranthene BRL 250 pg/kg dry I if 6-73-7 Fluorene BRL 250 pg/kg dry 1 "f " 193-39-5 Indeno (1,2,3-cd) pyrene BRL 250 pg/kg dry I if 90-12-0 1-Methylnaphthalene BRL 250 pg/kg dry I "f 91-57-6 2-Methylnaphthalene BRL 250 pg/kg dry 91-20-3 Naphthalene BRL 250 pg/kg dry 85-01-8 Phenanthrene BRL 250 pg/kg dry 129-00-0 Pyrene BRL 250 pg/kg dry " Surrogate recoveries: 321-60-S 2-Fluorobiphenyl 60.8 30-130% 1718-51-0 Terphenyl-d14 39.8 30-130% " Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 3.36 mg/kg dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7440-38-2 Arsenic BRL 5.04 mg/kg dry 7440-39-3 Barium 19.6 1.68 mg/kg dry 7440-43-9 Cadmium BRL 0.840 mg/kg dry 7440-47-3 Chromium 11.2 1.68 mg/kg dry 7439-974 Mercury BRL 0.275 mg/kg dry SW846 7471A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 17.5 2.52 mg/kg dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 5.04 mg/kg dry General Chemistry Parameters - % Solids 56.3 I SM2540 G 16-Jun-05 17-Jun-05 5061087 JAK Mod. Total Organic Carbon 27,000 100 mg/kg dry I SW846 9060 29-Jun-0S 29-Jun-05 5062062 AW This laboratoryreport Is not valid without an authorizedsignature on the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 7 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received SEP-20 1000400 Sediment 13-Jun-05 15:30 15-Jun-05 SA29522-06 AS No. Analyte(s) Result *RDI/Fnits Dilution Method Ref. Prepared Analyzed Batch Analyst Flag Umivolatile Organic Compounds by GCMS PAHs bv SW846 8270C Prepared by method SW846 3545A R-05 83-32-9 Acenaphthene BRL 682 pg/kg dry 2 SW846 8270C 20-Jun-05 22-Jun-05 5061237 208-96-8 Acenaphthylene BRL 682 pg/kg dry 2 " " N" 120-12-7 Anthracene BRL 682 pg/kg dry 2 N 56-55-3 Benzo (a) anthracene BRL 682 pg/kg dry 2 50-32-8 Benzo (a) pyrene BRL 682 pg/kg dry 2 205-99-2 Benzo (b) fluoranthene BRL 682 pg/kg dry 2 191-24-2 Benzo (gh,i) perylene BRL 682 pg/kg dry 2 207-08-9 Benzo (k) fluoranthene BRL 682 pg/kg dry 2 218-0-9 Chrysene BRL 682 pg/kg dry 2 53-70-3 Dibenzo (ah) anthracene BRL 682 pg/kg dry 2 - 206-44-0 Fluoranthene 1,320 682 pg/kg dry 2 " 86-73-7 Fluorene BRL 682 pg/kg dry 2 193-39-5 Indeno.(1,2,3-cd) pyrene BRL 682 pg/kg dry 2 90-12-0 1-Methylnaphthalene BRL 682 pg/kg dry 2 " 91-57-6 2-Methylnaphthalene BRL 682 pg/kg dry 2 91-20-3 Naphthalene BRL 682 pg/kg dry 2 *N " 85-01-8 Phenanthrene BRL 682 pg/kg dry 2 129-00-0 Pyrene BRL 682 pg/kg dry 2 Surrogaterecoveries: 321-60-8 2-Fluorobiphenyl 55.7 30-130% " * " 9 18-51.0 Terphenyl-d l 34.7 30-130% otal Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 1.90 mg/kg SW846 6010B 21-Jun-05 22-Jun-05 5061277 RE 7440-38-2 Arsenic BRL 2.85 mg/kg 7440-39-3 Barium 15.7 0.951 mg/kg 7440-43-9 Cadmium BRL 0.475 mg/kg 7440-47-3 Chromium 14.4 0.951 mg/kg 7439-97-6 Mercury BRL 0.177 mg/kg SW846 7471A " 23-Jun-05 5061278 YP 7439-92-1 Lead 21.1 1.43 mg/kg SW846 6010B " 22-Jun-05 5061277 RE 7782-49-2 Selenium BRL 2.85 mg/kg General Chemistry Parameters % Solids 14.3 1 SM2540 G 17-Jun-05 17-Jun-05 5061151 BD Mod. Total Organic Carbon 143,000 100 mg/kg 1 SW846 9060 29-Jun-05 29-Jun-05 5062063 AW This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 8 of 32 Sample Identification Client Project # Matrix Collection DateTime Received SED-21 1000400 Sediment 13-Jun-05 15:50 15-Jun-05 - SA29522-07 No. Analyte(s) Resul *RDLUnits Dilution Method Ref. Prepared Analyzed Batch Analyst Flag - Wractable Petroleum Hydrocarbons EPHAliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C 18 Aliphatic BRL 65.1 mg/kg dry 1 +MADEP 20-Jun-05 30-Jun-05 5062034 JD --. Hydrocarbons 5/2004 R C19-C36 Aliphatic 120 65.1 mg/kg dry 1 " N I Hydrocarbons Cl 1-C22 Aromatic BRL 65.1 mg/kg dry I " "- Hydrocarbons Unadjusted Cl l-C22 Aromatic BRL 65.1 mg/kg dry 1 Hydrocarbons Total Petroleum.Hydrocarbons 165 65.1 mg/kg dry 1 Unadjusted Total Petroleum 169 65.1 mg/kg dry 1 Hydrocarbons Semivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3545A 83-32-9 Acenaphthene BRL 322 pg/kg dry .2 SW846 827 0C 20-Jun-05 22-Jun-05 5061237 208-96-8 Acenaphthylene * BRL 322 pg/kgdry 2 " * 120-12-7 Anthracene BRL 322 pg/kg dry 2 " 56-55-3 Benzo (a) anthracene 396 322 pg/kg dry 2 " 50-32-8 Benzo (a) pyrene 439 322 pg/kg dry 2 " " 205-99-2 Benzo (b) fluoranthene 539 322 pg/kg dry 2 " 191-24-2 Benzo (g,h,i) perylene BRL 322 pg/kg dry 2 V 207-08-9 Benzo (k) fluoranthene 448 322 pg/kg dry 2 R 507 322 pg/kg dry 2 1-9 ChryseneDibenzo (ah) anthracene BRL 322 pg/kg dry 2 206-44-0 Fluoranthene 1,530 322 pg/kg dry 2 86-73-7 Fluorene BRL 322 pg/kg dry 2 193-39-5 Indeno (1,2,3-cd) pyrene BRL 322 pg/kg dry 2 " 90-12-0 1-Methyinaphthalene BRL 322 pg/kg dry 2 " 91-57-6 2-Methylnaphthalene BRIL 322 pg/kg dry 2 " 91-20-3 Naphthalene " " BRL 322 gg/kg dry 2 " " 85-01-8 Phenanthrene 526 322 pg/kg dry 2 " " 129-00-0 Pyrene 760 322 pg/kg dry 2 " Surrogaterecoveries: 321-60-8 2-Fluorobiphenyl 62.3 30-130% 1718-51-0 Terphenyl-d14 42.4 30-130% Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 2.21 mg/kg dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7440-38-2 Arsenic BRL 3.31 mg/kg dry " " " " 7440-39-3 Barium 8.21 1.10 mg/kg dry 7440-43-9 Cadmium BRL 0.552 mg/kg dry 7440-47-3 Chromium 3.93 1.10 mg/kg dry 7439-97-6 Mercury BRL 0.204 mg/kg dry SW846 7471A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 9.58 1.66 mg/kg-dry SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 3.31 mg/kg dry " " General Chemistry Parameters % Solids 86.0 1 SM2540 G 16-Jun-05 17-Jun-05 5061087 JAK -0 Mod. Total Organic Carbon 14,400 100 mg/kg dry 1 SW846 9060 29-Jun-05 29-Jun-05 5062062 AW This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 9 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received Sw- 8 15-Jun-05 SA29522-08 1000400 Surface Water 13-Jun-05 13:40 CAS No. Analyte(s) Result *RDLIUnlft Dilution Method Ref. Prepared Analyzed Batch Analyst Flag * mivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3535 83-32-9 Acenaphthene BRL 7.14 pg/I 1 SW846 8270C 17-Jun-05 21-Jun-05 5061128 M.B 208-96-S Acenaphthylene BRL 7.14 pg/l " " "f "f 120-12-7 Anthracene BRL 7.14 pg/I 1 "t "f " N "f 56-55-3 Benzo (a) anthracene BRL 7.14 pg/l I 50-324 Benzo (a) pyrene BRL 7.14 pg/i 205-99-2 Benzo (b) fluoranthene BRL 7.14 pg/i 191-24-2 Benzo (g,h,i) perylene BRL 7.14 pg/l " 207-08-9 Benzo (k) fluoranthene BRL 7.14 pg/l " " 218-01-9 Chrysene BRL 7.14 pg/l " " 53-70-3 Dibenzo (ah) anthracene BRL 7.14 pg/i 20644-0 Fluoranthene BRL 7.14 pg/i " "t 86-73-7 Fluorene BRL 7.14 pg/i 193-39-5 Indeno (1,2,3-cd) pyrene BRL 7.14 pg/i 90-12-0 1 -Methyinaphthalene BRIL 7.14 pg/i "q " 91-57-6 2-Methylnaphthalene BRL 7.14 pg/l "f " 91-;20-3 Naphthalene BRL 7.14 pg/ 85-01-8 Phenanthrene BRL 7.14 pg/l 129-0"o- Pyrene BRL 7.14 pg/l " " Surrogate recoveries: 321-604 2-Fluorobiphenyl 68.7 30-130% " " 77.6 30-130 % Terphenyl-dl4 0 otal18-51-0 Metals by EPA 6000/7000 Series Methods .7440-22-4 Silver 0.0215 0.0050 mg/l SW846 60.10B 21-Jun-O5 21-Jun-05 5061292 HB 7440-38-2 Arsenic BRL 0.0040 mg/l 7440-39-3 Barium 0.404 0.0025 mg/l if ft " 7440-43-9 Cadmium 0.0410 0.0012 mg/l 7440-47-3 Chromium 0.188 0.0025 mg/l 7439-92-1 Lead 0.204 0.0038 mg/l 7782-49-2 Selenium BRL 0.0075 mg/l Total Metals by EPA 200 Series Methods 7439-97-6 Mercury 0.00165 0.00020 mg/l 1 EPA 21-Jun-05 22-Jun-05 5061293 YP 245.2/7470A This laboratory report is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 10 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received SW-2 1000400 Surface Water 13-Jun-05 13:55 15-Jun-05 - SA29522-09 hINo. Analyte(s) Result *RDL/Units Dilution Method Ref. Prepared Analyzed Batch Analyst Flag W ivolatile Organic Compounds by GCMS PAfs by SW846 8270C Prepared by method SW846 3535 83-32-9 Acenaphthene BRL 7.14 pg/i SW846 8270C 17-Jun-05 22-Jun-05 5061128 M.B - 208-96-8 Acenaphthylene BRL 7.14 pg/l " 120-12-7 Anthracene BRL 7.14 pg/i " 56-55-3 Benzo (a) anthracene BRL 7.14 pg/I K" , - 50-32-8 Benzo (a) pyrene BRL 7.14 pg/I 205-99-2 Benzo (b) fluoranthene BRL 7.14 pg/l 191-24-2 Benzo (g,h,i) perylene BRL 7.14 pg/I - 207-08-9 Benzo (k) fluoranthene BRL 7.14 pg/I 218-01-9 Chrysene BRL 7.14 pg/i 53-70-3 Dibenzo (ah) anthracene BRL 7.14 pg/i - 206-44-0 Fluoranthene BRL 7.14 pg/i 86-73-7 Fluorene BRL 7.14 pg/l 193-39-5 Indeno (1,2,3-cd) pyrene BRL 7.14 pg/Il 90-12-0 1-Methylnaphthalene BRL 7.14 pg/Il 91-57-6 2-Methylnaphthalene- BRL 7.14 pg/I 91-20-3 Naphthalene BRL 7.14 pg/l 85-01-S Phenanthrene BRL 7.14 pg/I 129-00-0 Pyrene BRL 7.14 pg/i 0 ft Surrogate recoveries: K K 321-60-8 2-Fluorobiphenyl 83.9 30-130 % 51-0 Terphenyl-d14 111 30-130 % 'Total Metals by EPA 6000/7000 Series Methods - 7440-22-4 Silver BRL 0.0050 mg/l SW846 6010B 21-Jun-05 21-Jun-05 5061292 HB 7440-38-2 Arsenic BRL 0.0040 mg/i K K K " " 7440-39-3 Barium 0.159 0.0025 mg/I " " " " K 7440-43-9 Cadmium BRL 0.0012 mg/l " " " " " 7440-47-3 Chromium 0.0145 0.0025 mg/l " " K K " 7439-92-1 Lead 0.0140 0.0038 mg/I " " " 7782-49-2 Selenium BRL 0.0075 mg/I " Total Metals by EPA 200 Series Methods 7439-97-6 Mercury 0.00022 0.00020 mg/i I EPA 21-Jun-05 22-Jun-05 5061293 YP 245.2/7470A This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page I1 of 32 Sample Identification Client Project # Matrix Collection Date/Time Received SW-3 1000400 Surface Water 13-Jun-05 14:50 15-Jun-05 SA29522-10 . SNo. Analyte(s) Result *RDL/Units Dilution Method Ref- Prepared Analyzed Batch Analyst Flag W emivolatile Organic Compounds by GCMS PA Hs by SW846 8270C Prepared by method SW846 3535 83-32-9 Acenaphthene BRL 7.14 pg/il I SW846 8270C 17-Jun-05 21-Jun-05 5061128 M.B " " " 208-96-8 Acenaphthylene BRL 7.14 pg/l 1 120-12-7 Anthracene BRL 7.14 pg/l 1 56-55-3 Benzo (a) anthracene BRL 7.14 pg/l 1 "t "t " 50-32-8 Benzo (a) pyrene BIRL 7.14 pg/l 1 "tft f 205-99-2 Benzo (b) fluoranthene BRL 7.14 pg/l 1 191-24-2 Benzo (gh,i) perylene BRL 7.14 pg/l " 207-08-9 Benzo (k) fluoranthene BRL 7.14 pg/l " 21"-1-9 Chrysene BRL 7.14 pg/l 1 53-70-3 Dibenzo (ah) anthracene BRL 7.14 pg/ 1" 206-44-0 Fluoranthene BRL 7.14 pg/1 I 86-73-7 Fluorene BRL 7.14pg/l 1 " 193-39-5 Indeno (1,2,3-cd) pyrene BRL 7.14 pg/l I 90-12-0 1-Methylnaphthalene BRL 7 .14 pg/ 1 "" 91-57-6 2-Methylnaphthalene BRL 7.14 pg/l 1 91-20-3 Naphthalene BRL -7.14 pg/l 1 " 85-01-8 Phenanthrne BRL 7.14 pg/l 1 129-00-0 Pyrene BRL 7.14 pg/l 1 Surrogate recoveries: 321-60-8 2-Fluorobiphenyl 32.0 30-130% S18-51-0 Terphenyl-d14 35.4 30-430% Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver - BRL 0.0050 mg/I 1 SW846 6010B 21-Jun-05 21-Jun-05 5061292 HB 7440-38-2 Arsenic BRL 0.0040 mg/l 1 "t "t " 7440-39-3 Barium 0.0436 0.0025 mg/I 1 7440-43-9 Cadmium BRL 0.0012 mg/l 1 " " 7440-47-3 Chromium 0.0058 0.0025 mg/l 1 7439-92-1 Lead 0.0076 0.0038 mg/i 1 778249-2 Selenium BRL 0.0075 mg/i 1 Total Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL 0.00020 mg/l I EPA 21-Jun-05 22-Jun-05 5061293 YP 245.2/7470A This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 12 of 32 Samnle Intification Client Project # Matrix Collection Date/Time Received SW-4 15-Jun-05 - VAO''1 1000400 Surface Water 13-Jun-05 15:10 No. Anal4te(s) Result *RDLjnils Dilution Method Ref, Prepared Analyzed Batch Analyst Flag imivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3535 83-32-9 Acenaphthene BRL 625 pg/l 1 SW846 8270C 17-Jun-05 22-Jun-05 5061128 M.B 208-96-S Acenaphthylene BRL 6.25 Ig/ 1 " 120-12-7 Anthracene BRL 6.25 pg/l 1 " 56-55-3 Benzo (a) anthracene BRL 6.25 pg/l 1 50-32-8 Benzo (a) pyrene BRL 625 pg/i 1 205-99-2 Benzo (b) fluoranthene BRL 6.25 pg/l 1 " 191-24-2 Benzo (gh,i) perylene BRL 6.25 pg/i 1 " 207-08-9 Benzo (k) fluoranthene BRL 6.25 pg/i 1 " " 218-01-9 Chrysene BRL 6.25 pg/1 1 " " 53-70-3 Dibenzo (ah) anthracene BRL, 6.25 pg/ i " " 206-44-0 Fluoranthene BRL 6.25 pg/i I " 86-73-7 Fluorene BRL 6.25 pg/i I " 193-39-5 Indeno (1,2,3-cd) pyrene BRL 6.25 pg/l I 90-12-0 1-Methylnaphthalene BRL 625 pg/i 1 91-57-6 2-Methylnaphthalene BRL 6.25 pg/i I 91-20-3 Naphthalene BRL 6.25 pg/i t " " 85-01-8 Phenanthrene BRL 6.25 pg/i I 129-00-0 Pyrene BRL 625 pg/i I Surrogate recoveries: 321-804 2-Fluorobiphenyl 50.9 30-130% *51-0 Terphenyl-d14 56.2 30-130% " " Total Metals by EPA 6000/7000 Series Methods 7440-224 Silver BRL 0.0050 mg/l I SW8466010B 21-Jun-05 21-Jun-05 5061292 HB 7440-38-2 Arsenic BRL 0.0040 mg/I I * " 7440-39-3 Barium 0.156 0.0025 mg/i I " " 7440-43-9 Cadmium BRL 0.0012 mg/I I " 7440-47-3 Chromium 0.0116 0.0025 mg/I I "f" 7439-92-1 Lead 0.0291 0.0038 mg/I I " " 7782-49-2 Selenium BRL 0.0075 mg/I 1 " " " " Total Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL 0.00020 mg/I I EPA 21-Jun-05 22-Jun-05 5061293 YP 245.2/7470A This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL Below Reporting Limit Page 13 of 32 Sample Identification Client SW-5 Project # Matrix Collection Date/Time Received 1000400 Surface SA29522-12 Water 13-Jun-05 15:35 15-Jun-05 4S No. Analyte(s) Result *RDI/Units Dilution Method Ref. PreparedAnalyzed Batch Analyst Flag t eivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3535 83-32-9 Acenaphthene BRL 7.14 pg/l 1 SW846 8270C 17-Jun-05 21-Jun-05 5061128 M.B 208-96-8 Acenaphthylene BRL 7.14 pg/l 1 120-12-7 Anthracene BRL 7.14 pg/ 56-55-3 Benzo (a) anthracene BRL 7.14 pg/ 50-32-8 Benzo (a) pyrene BRL 7.14 pg/I 205-99-2 Benzo (b) fluoranthene BRL 7.14 pg/ " 191-24-2 Benzo (gh,i) perylene BRL 7.14 pg/I I " 207-08-9 Benzo (k) fluoranthene BRL 7.14 pg/l 1 " 218-01-9. Chrysene BRL 7.14 pg/l 1 53-70-3 . Dibenzo (ah) anthracene BRL 7.14 pg/1 1 " " 206-44-0 Fluoranthene BRL 7.14 pg/l 1 86-73-7 Fluorene BRL 7.14 pg/ I " 193-39-5 Indeno (1,2,3-cd) pyrene BRL 7.14 pg/1 " 90-12-0 1-Methylnaphthalene BRL 7.14pg/1 1 " 91-57-6 2-Methylnaphthalene BRL 7.14 pg/l 1 91-20-3 Naphthalene BRL 7.14 pg/1 " 85-01-8 Phenanthrene BRL 7.14 4g/l 1 129-00-0 Pyrene BRL 7.14pg/l 1" Surrogaterecoveries: 321-60-S 2-Fluorobiphenyl 55.9 30-130% 18-51 0 Terphenyl-d14 56.5 30-130% * Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver 0.0118 0.0050 mg/i 1I SW8466010B 21-Jun-05 21-Jun-05 5061292 HB 7440-38-2 Arsenic BRL 0.0040 mg/I t * "f "f 7440-39-3 Barium 0.136 0.0025 mg/I 7440-43-9 Cadmium 0.0038 0.0012 mg/I 7440-47-3 Chromium 0.0781 0.0025 mg/I 7439-92-1 Lead 0.169 0.0038 mg/i 7782-49-2 Selenium BRL . 0.0075 mg/I Total Metals by EPA 200 Series Methods 7439-97-6 Mercury 0.00060 0.00020 mg/l I EPA 21-Jun-05 22-Jun-05 5061293 YP 245.2/7470A This laboratoryreport is not valid without an authorizedsignature on the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 14 of 32 Sample Identification Client Project # Matrix Collection-Date/Time Received KEl 1000400 Ground Water 14-Jun-05 12:45 15-Jun-05 - SA29522-13 g No. Analyte(s) Result *RDU/Units Dilution Method Ref Prepared Analyzed Batch Analyst Flag - uble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL 0.0050 mg/I i SW8466010B 21-Jun-05 21-Jun-05 5061218 HB 7440-3B-2 Arsenic BRL 0.0040 mg/l 1 *t "tN 7440-39-3 Barium 0.0122 0.0025 mg/I 1 " ft ft 7440-43-9 Cadmium BRL 0.0012 mg/l 1 7440-47-3 Chromium BRL 0.0025 mg/l 1 ft if ft 7439-92-1 Lead BRL 0.0038 mg/l 1 778249-2 Selenium BRL 0.0075 mg/l 1 Soluble Metals by EPA 200 Series Methods - Filtration Field Filtered N/A 1 EPA 17-Jun-05 17-Jun-05 5061203 YP 200,7/3005A 7439-97-6 Mercury BRL 0.00020 mg/l 1 EPA 21-Jun-05 22-Jun-05 5061219 " 245.2/7470A This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 15 of 32 Sample Identification Client Project # Matrix Collection DatefTime Received KE1 6"-2Ft 1000400 Soil 14-Jun-05 12:25 15-Jun-05 SA29522-14 Prepared Analyzed Batch Analyst Flag WAcSNo. Analyte(s) Result *RDIUnits Dilution Method Ref Mtractable Petroleum Hydrocarbons EPHAliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic 99.8 63.4 mg/kg dry 1 +MADEP 20-Jun-05 30-Jun-05 5062034 JD Hydrocarbons 512004 R C19-C36 Aliphatic 1,560 63.4 mg/kg dry 1 Hydrocarbons CII-C22 Aromatic 257 63.4 mg/kg dry I Hydrocarbons Unadjusted C 1-C22 Aromatic 257 63.4 mg/kg dry I Hydrocarbons Total Petroleum Hydrocarbons 1,910 63.4 mg/kg dry I " Unadjusted Total Petroleum 1,910 63.4 mg/kg dry I Hydrocarbons Semivolatile Organic Compounds by GC PolychorinatedBiphenyls by SW846 8082 Prepared by method SW846 3545A 12674-11-2 PCB 1016 BRL 33.3 ig/kg dry 1 SW846 8082 27-Jun-05 28-Jun-05 5061750 SM 11104-28-2 PCB 1221 BRL 33.3 pg/kg dry 1 " f 11141-16-5 PCB 1232 BRL 33.3 pg/lkg dry 1 53469-21-9 PCB 1242 BRL 33.3 pg/kg dry I 12672-29-6 PCB 1248 BRL 33.3 pg/kg dry I 11097-69-1 PCB 1254 2,750 33.3 pg/kg dry 1 11096-42-5 PCB 1260 BRL 33.3 pg/kg dry 1 37324-23-5 PCB 1262 BRL 33.3 ig/kg dry 1 " 1 00-14-4 PCB 1268 -BRL 33.3 pg/kg dry I Worrogate recoveries: 10386-84-2 4,4-DB-Octafluorobiphenyl (Sr) 55.0 30-150% 2051-24-3 Decachlorobiphenyl(Sr) 49.8 30-150 % Total Metals by EPA 6000/7000 Series Methods RE 7440-22-4 Silver 8.15 2.21 mg/kg dry 1 SW846" 6010B 22-Jun-05" 23-Jun-05N 5061279U if- 7440-38-2 Arsenic 53.6 3.32 mg/kg dry 1 7440-39-3 Barium 18.8 1.11 mg/kg dry 1 7440-43-9 Cadmium BRL 0.553 mg/kg dry 1 7440-47-3 Chromium 1,310 1.11 mg/kg dry 1 * " " "f " 7439-97-6 Mercury BRL 0.208 mg/kg dry 1 SW846 7471A 20-Jun-05 22-Jun-05 5061280 YP 7439-92-1 Lead 462 1.66 mg/kg dry 1 SW846 6010B 22-Jun-05 23-Jun-05 5061279 RE 7782-49-2 Selenium BRL 3.32 mg/kg dry 1 f " "f "f " General Chemistry Parameters % Solids 85.7 %0 I SM2540 G 16-Jun-05 17-Jun-05 5061087 JAK Mod. This laboratoryreport Is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 16 of 32 Extractable Petroleum Hydrocarbons - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level ~ Result %REC Limits RPD Limit Flag *h 0507003 - 5062034 Calibration Check (0507003-CCV1) Prepared & Analyzed: 30-Jun-05 C9-C18 Aliphatic Hydrocarbons 0.579 mg/kg wet 0.600 96.5 75-125 C19-C36 Aliphatic Hydrocarbons 0.669 mg/kg wet 0.800 83.6 75-125 C11-C22 Aromatic Hydrocarbons 1.92 mg/kg wet 1.70 113 75-125 Batch 5062034 - SW846 3545A Blank (5062034-BLK1) Prepared & Analyzed: 30-Jun-05 C9-CI8 Aliphatic Hydrocarbons BRL 13.4 mg/kg wet C19-C36 Aliphatic Hydrocarbons BRL 13.4 mg/kg wet C11-C22 Aromatic Hydrocarbons BRL 3A mg/kg wet Unadjusted Cl 1-C22 Aromatic BRL 13.4 mg/kg wet Hydrocarbons Total Petroleum Hydrocarbons BRL 13A mg/kg wet Unadjusted Total Petroleum Hydrocarbons BRL 13.4 mg/kg wet LCS (5062034-BSI) Prepared & Analyzed: 30-Jun-05 C9-C18 Aliphatic Hydrocarbons 20.7 13.4 mg/kg wet 40.0 51.8 40-140 C19-C36 Aliphatic Hydrocarbons 33.3 13.4 mg/kg wet 53.3 62.5 40-140 CI -C22 Aromatic Hydrocarbons 70.7 13.4 mg/kg wet 113 62.6 40-140 Fractionation Check Standard (5062034-BS2) Prepared & Analyzed: 30-Jun-05 C9-C18 Aliphatic Hydrocarbons 21.7 13.4 mg/kg wet 40.0 54.2 40-140 C19-C36 Aliphatic Hydrocarbons 37.3 13.4 mg/kg wet 53.3 70.0 40-140 C11-C22 Aromatic Hydrocarbons 98.0 13.4 mg/kg wet 113 86.7 40-140 LCS Dup (5062034-BSD1) Prepared & Analyzed: 30-Jun-05 C9-C18 Aliphatic Hydrocarbons 18.4 13.4 mg/kg wet 40.0 46.0 40-140 11.9 25 25 QR-02 *-C36 Aliphatic Hydrocarbons 43.9 13.4 mg/kg wet 53.3 82.4 40-140 27.5 -C22 Aromatic Hydrocarbons 65.3 13.4 mg/kg wet 113 57.8 40-140 7.97 25 This laboratory report Is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 17 of 32 Semivolatile Organic Compounds by GC - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag *tch 5061750 - SW846 3545A Blank (5061750-BLKl) Prepared & Analyzed: 27-Jun-5 PCB 1016 BRL 28.6 pg/kg wet PCB 1221 BRL 28.6 pg/kg wet PCB 1232 BRL 28.6 pg/kg wet PCB 1242 BRL 28.6 pg/kg wet PCB 1248 BRL 28.6 pg/kg wet PCB 1254 BRL 28.6 pg/kg wet PCB 1260 BRL 28.6 pg/kg wet PCB 1262 BRL 28.6 pg/kg wet PCB 1268 BRL 28.6 gg/kg wet Surrogate: 4,4-DB-Octafluorobiphenyl (Sr) 21.4 pg/kg wet 28,6 74.8 30-150 Surrogate: Decachlorobiphenyl (Sr) 27.1 g/kg wet 28.6 94.8 30-150 LCS (5061750-BS1) Prepared & Analyzed: 27-Jun-05 PCB 1016 253 28.6 yg/kg wet 357 70.9 40-140 PCB 1260 264 28.6 pg/kg wet 357 73.9 40-140 Surrogate: 4,4-DB-Octafluorobiphenyl(Sr) 17.1 pg/kg wet 28.6 59.8 30-150 Surrogate: Decachlorobiphenyl(Sr) 21.4 g g/kg wet 28.6 74.8 30-150 Duplicate (5061750-DUP1) Source: SA29788-04 Prepared & Analyzed: 27-Jun-05 PCB 1016 BRL 34.9 pg/kg dry BRL 40 PCB 1221 BRL 34.9 pg/kg dry BRL 40 PCB 1232 BRL 34.9 pg/kg dry BRL 40 PCB 1242 BRL 34.9 pg/kg dry BRL 40 PCB 1248 BRL 34.9 pg/kg dry BRL 40 PCB 1254 BRL 34.9 pg/kg dry BRL 40 aCb 1260 BRL 34.9 pg/kg dry BRL 40 W CB 1262 BRL 34.9 pg/kg dry BRL 40 PCB 1268 BRL 34.9 pg/kg dry BRL 40 Surrogate: 4.4-DB-Octafluorobiphenyl (Sr) 22.7 pg/kg dry 34.9 65.0 30-150 Surrogate: Decachlorobiphenyl (Sr) 22.7 pg/kg dry 34.9 65.0 30-150 Matrix Spike (5061750-MS1) Source: SA29788-04 Prepared & Analyzed: 27-Jun-05 PCB 1016 305 33.0 pgtkg dry 412 BRL 74.0 40-140 PCB 1260 295 33.0 gg/kg dry 412 BRL 71.6 - 40-140 Surrogate:4,4-DB-Octafluorobiphenyl(Sr) 21.4 pg/kg dry 33.0 64.8 30-150 Surrogate: Decachlorobipheny/ (Sr) 24.7 pg/kg dry 33.0 74.8 30-150 Matrix Spike Dup (5061750-MSD1) Source: SA29788-04 Prepared & Analyzed: 27-Jun-05 PCB 1016 298 35A pg/kg dry 441 BRL. 67.6 40-140 9.04 50 PCB 1260 281 35.4 pg/kg dry 441 BRL 63.7 40-140 11.7 50 Surrogate: 4,4-DB-Octafluorobiphenyl (Sr) 21.2 ypgIkg dry 35.3 60.1 30-150 Surrogate: Decachlorobiphenyl (Sr) 21.2 pg/kg dry 35.3 60.1 30-150 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 18 of 32 Semivolatile Organic Compounds by GCMS - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag h 5061128 - SW846 3535 Blank (5061128-BLK1) Prepared & Analyzed: 17-Jun-05 Acenaphthene BRL 2.50 pig/I Acenaphthylene BRL 2.50 pg/l Anthracene BRL 2.50 pg/I Benzo (a) anthracene BRL 2.50 pg/I Benzo (a) pyrene BRL 2.50 pg/I Benzo (b) fluoranthene BRL 2.50 pg/l Benzo (g,h,i) perylene BRL 2.50 pg/l Benzo (k) fluoranthene BRL 2.50 pg/I Chrysene BRL 2.50 pg/i Dibenzo (ah) anthicene BRL 2.50 pg/I Fluoranthene BRL 2.50 pg/i Fluorene BRL 2.50 pg/I Indeno (1,2,3-cd) pyrene BRL 2.50 pig/ 1-Methylnaphthalene BRL 2.50 pg/l 2-Methylnaphthalene BRL 2.50 pg/l Naphthalene BRL 2.50 pg/ Phenanthrene BRL 2.50 ig/I Pyrene BRL 2.50 pig/ Surrogate: 2-Ruarobtphenyl 51.6 pg/L 100 51.6 30-130 Surrogate: Terphenyl-d14 75.6 Ig/L 100 75.6 30-130 LCS (5061128-BS1) Prepared & Analyzed: 17-Jun-05 Acenaphthene 62.4 2.50 pg/Il 100 62.4 40-140 Acenaphbthylene 64.8 2.50 pg/l 100 64.8 40-140 75.6. 2.50 pig/I 100 75.6 40-140 4(.) anthracee 75.5 2.50 pg/l 100 75.5 40-140 Benzo (a) pyrene 77.5 2.50 pg/l 100 77.5 40-140 Benzo (b) fluoranthene 73.9 2.50 pig/I 100 73.9 40-140 Benzo (g,h,i)perylene 101 2.50 pg/I 100 101 40-140 Benzo (k) fluoranthene 70.0 2.50 pg/l 100 70.0 40-140 Chrysene 70.2 2.50 pg/I 100 70.2 40-140 Dibenzo (ah) anthracene 74.6 2.50 pg/I 100 74.6 40-140 Fluoranthene 81.0 2.50 pg/I 100 81.0 40-140 Fluorene. 68.7 2.50 pg/I 100 68.7 40-140 Indeno (1,2,3-cd) pyrene 97.8 2.50 pig/i 100 97.8 40-140 l-Methylnaphthalene 51.5 2.50 pg/I 100 51.5 40-140 2-Methylnaphthalene 59.0 2.50 pg/i1 100 59.0 40-140 Naphthalene 53.1 2.50 pg/I 100 53.1 40-140 Phenanthrene 67.5 2.50 pig/i 100 67.5 40-140 Pyrene 6'4.5 2.50 pg/i 100 64.5 40-140 Surrogate: 2-Fluorobiphenyl 61.8 pg/ 100 61L8 30-130 Surrogate: Terphenyl-d14 75.8 pg/I 100 75.8 30-130 Batch 5061237 - SW846 3545A Blank (5061237-BLK1) Prepared: 20-Jun-05 Analyzed: 21-Jun-05 __ - Acenaphthene BRL 66.0 pg/kg wet Acenaphthylene BRL 66.0 pg/kg wet Anthracene BRL 66.0 pg/kg wet Bezo (a) anthracene BRL 66.0 pg/kg wet Beaz (a) pyrene BRL 66.0 pg/kg wet Benzo (b) fluoranthene BRL 66.0 pg/kg wet en (gh.i) perylene BRL 66.0 pg/kg wet I n(k) fluoranthene BRL 66.0 pig/kg wet hrysene BRL 66.0 pig/kg wet Dibenzo (ajh) nthracene BRL 66.0 pig/kg wet This laboratoryreport is not valid without an authorizedsignature on the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 19 of 32 Semivolatile Organic Compounds by GCMS - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag * tch 5061237 - SW846 3545A Blank (5061237-BLK1) Prepared: 20-Jun-05 Analyzed: 21-Jun-05 Fluoranthene BRL 66.0 pg/kg wet Fluorene BRL 66.0 pg/kg wet Indeno (1,2,3-cd) pyrene BRL 66.0 pg/kg wet I-Methylnaphthalene BRL 66.0 pg/kg wet 2-Methylnaphthalene BRL 66.0 pg/kg wet Naphthalene BRL 66.0 pg/kg wet Phenanthrene BRL 66.0 pg/kg wet Pyrene BRL 66.0 pg/kg wet Surrogate:2-Fluorobiphenyl 3470 pg/kg wet 6670 52.0 30-130 Surrogate: Terphenyl-d4 3670 pg/kg wet 6670 55.0 30-130 LCS (5061237-BSI) Prepared: 20-Jun-05 Analyzed: 21-Jun-05 Acenaphthene 4570 66.0 pg/kg wet 6670 68.5 40-140 Acenaphthylene 4750 66.0 pg/kg wet 6670 71.2 40-140 Anthracene 4870 66.0 pg/kg wet 6670 73.0 40-140 iBenzo (a) anthracene 5030 66.0 pg/kg wet 6670 75.4 40-140 Benzo (a) pyrene 5080 66.0 pg/kg wet 6670 76.2 40-140 Benzo (b) fluoranthene 5190 66.0 pg/kg wet . 6670 77.8 40-140 Benzo (g,h,i)perylene 4820 66.0 pg/kg wet 6670 72.3 40-140 Benzo (k) fluoranthene 4860 66.0 pg/kg wet 6670 72.9 40-140 Chrysene 4620 66.0 pg/kg wet 6670 69.3 40-140 Dibenzo (ah) anthracene 3760 66.0 pg/kg wet 6670 56.4 40-140 Fluoranthene 4830 66.0 pg/kg wet 6670 72.4 40-140 Fluorene 4680 66.0 pg/kg wet 6670 70.2 40-140 Indeno (1,2,3-cd) pyrene 4730 66.0 pg/kg wet 6670 70.9 40-140 Methyinaphthalene 4130 66.0 pg/kg wet 6670 61.9 40-140 0 -Methynaphthalene 4470 66.0 pg/kg wet 6670 67.0 40-140 Naphthalene 4370 66.0 pg/kg wet 6670 65.5 40-140 Phenanthrene 4590 66.0 pg/kg wet 6670 68.8 40-140 Pyrene 5210 66.0 pg/kg wet 6670 78.1 40-140 Surrogate: 2-Fluorobiphenyl 3760 pg/kg wet 6670 56.4 30-130 Surrogate: Terphenyl-d14 4200 pg/kg wet 6670 63.0 .30-130 Duplicate (5061237-DUPI) Source: SA29523-01 Prepared: 20-Jun-05 Analyzed: 21-Jun-05 Acenaphthene BRL 45.7 pg/kg dry BRL 50 Acenaphthylene 119 45.7 pg/kg dry 61.6 63.6 50 QM-04 Anthracene 113 45.7 pg/kg dry 52.4 73.3 50 QM-04 Benzo (a) anthracene 275 45.7 pg/kg dry 173 45.5 50 Benzo (a) pyrene 241 45.7 pg/kg dry 156 42.8 50 Benzo (b) fluoranthene 174 45.7 pg/kg dry I19 37.5 50 Benzo (g,h,i) perylene 199 45.7 pg/kg dry 159 22.3 50 Benzo (k) fluoranthene 155 45.7 pg/kg dry 108 35.7 50 Chrysene 281 45.7 pg/kg dry 176 46.0 50 Dibenzo (ah) anthracene BRL 45.7 pg/kg dry 26.2 33.9 50 Fluoranthene 486 45.7 pg/kg dry 319 41.5 50 Fluorene BRL 45.7 pg/kg dry BRL 50 Indeno (1,2,3-cd) pyrene 225 45.7 pg/kg dry 179 22.8 50 1-Methylnaphthalene BRL 45.7 pg/kg dry BRL 50 2-Methyinaphthalene B3RL 45.7 pg/kg dry BRL 50 Naphthalene BRL 45.7 pg/kg dry BRL 50 Phenanthrene 284 45.7 pg/kg dry 138 69.2 50 QM-04 Pyrene 444 45.7 pg/kg dry 278 46.0 50 urrogate:2-Fluorobiphenyl 1420 pg/kg dry 2310 61.5 30-130 W Surrogate: Terphenyl.d4 1740 pg/kg dry 2310 75.3 30-130 Matrix Spike (5061237-MS1) Source: SA29523-01 Prepared: 20-Jun-05 Analyzed: 21 -Jun-05 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 20 of 32 Semivolatile Organic Compounds by GCMS - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag h 5061237 - SW846 3545A Matrix Spike (5061237-MS1) Source: SA29523-01 Prepared: 20-Jun-05 Analyzed: 21-Jun-05 Acenaphthene 2770 45.5 jig/kg dry 4600 BRL 60.2 40-140 Pyrene 2980 45.5 pg/kg dry 4600 278 58.7 40-140 Surrogate:2-Fluorobiphenyl 2670 jig/kg dry 4600 58.0 30-130 Surrogate: Terphenyl-d14 2450 jig/kg dry 4600 53.3 30-130 Matrix Spike Dup (5061237-MSD1) Source: SA29523-01 Prepared: 20-Jun-05 Analyzed: 21-Jun-05 - Acenaphthene 2860 46.4 pg/kg dry 4680 BRL 61.1 40-140 1.48 30 Pyrene 2330 46.4 pg/kg dry 4680 278 43.8 40-140 29.1 30 Surrogate: 2-Fluorobiphenyl 2580 pg/k g dry 4680 55.1 30-130 Surrogate: Terphenyl-d14 1910 pg/kg dry 4680 40.8 30-130 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 21 of 32 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level - Result %REC Limits RPD Limit Flag tch 5061277 - SW846 3050B Blank (5061277-BLK1) Prepared: 214un-05 Analyzed; 22-Jun-05 Selenium BRL 3.00 mg/kg Lead BRL 1.50 mg/kg Arsenic BRL, 3.00 mg/kg Silver BRL 2.00 mg/kg Chromium BRL 1.00 mg/kg Cadmium BRL, 0.500 mg/kg Barium BRL 1.00 mg/kg LCS (5061277-BSL) Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Selenium 1.07 0.0300 mg/kg 1.00 107 85-115 Silver. 1.06 0.0400 mg/kg 1.00 106 85-115 Cadmium 1.11 0.0050 mg/kg 1.00 111 85-115 Barium 1.08 0.0100 mg/kg 1.00 108 85-115 Arsenic 1.06 0.0300 mg/kg 1.00 106 85-115 Iead 1.08 0.0150 mg/kg 1.00 108 85-115 Chromium 1.04 0.0100 mg/kg 1.00 104 85-115 Duplicate (5061277-DUPI) Source: SA29522-06 Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Selenium BRL 2.82 mg/kg BRL 35 Silver BRL 1.88 mg/kg 1.75 35 Chromium 2.92 0.939 mg/kg 14.4 133 35 QR-05 Cadmium BRL 0.469 mg/kg 0.409 50.5 35 QR-05 Barium 15.6 0.939 mg/kg 15.7 0.639 35 Lead 16.7 1.41 mg/kg 21.1 23.3 35 Arsenic BRL 2.82 mg/kg BRL 35 st atrix Spike (5061277-MS1) Source: SA29522-06 Prepared: 21-Jun-05 Analyzed: 22-Jun-05 elenium 92.7 2.82 mg/kg 93.9 BIRL 88.1 75-125 - Barium 108 0.939 mg/kg 93.9 15.7 98.3 75-125 Chromium 91.6 0.939 mg/kg 93.9 14.4 82.2 75-125 Lead 102 1.41 mg/kg 93.9 21.1 86.2 75-125 Arsenic 85.9 2.82 mg/kg 93.9 BRL 91.5 75-125 Cadmium 90.6 0.470 mg/kg 93.9 0.409 96.1 75-125 Silver 45.9 1.88 mg/kg 47.0 1.75 93.9 75-125 Matrix Spike Dup (5061277-MSD1) Source: SA29522-06 Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Selenium 88.1 2.84 mg/kg 94.5 BRL 93.2 75-125 6,32 35 Lead 109 1.42 mg/kg 94.5 21.1 93.0 75-125 6.64 35 Silver 48.5 1.89 mg/kg 47.3 1.75 98.8 75-125 5.51 35 Chromium 94.7 0.945 mg/kg 94.5 - 14.4 85.0 75-125 3.33 35 Arsenic 91.1 2.84 mg/kg 94.5 BRL 96.4 75-125 5.88 35 Cadmium 93.9 0A73 mg/kg 94.5 0.409 98.9 75-125 3.58 35 Barium il1 0.945 mg/kg 94.5 15.7 101 75-125 2.74 35 Reference (5061277-SRM1) Prepared: 21 Jun-05 Analyzed: 22-Jun-05 Selenium 114 3.00 mg/kg 113 101 85-115 Cadmium 117 0.500 mg/kg 115 102 85-115 Lead 112 1.50 mg/kg 127 88.2 85-115 Barium 12.7 1.00 mg/kg 13.1 96.9 85-115 Silver 26.3 2.00 mg/kg 26.0 101 85-115 Chromium 51.2 1.00 mg/kg 57.2 89.5 85-115 Arsenic 72.6 3.00 mg/kg 71.6 101 85-115 Reference (5061277-SRM2) Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Selenium 112 3.00 mg/kg 112 100 85-115 admium 119 0.500 mg/kg 115 103 85-115 118 1.50 mg/kg 126 93.7 85-115 Silver 26.2 2.00 mg/kg 25.8 102 85-115 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Lirnit Page 22 of 32 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag Sh 5061277 - SW846 3050B R feference (5061277-SRM2) Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Arsenic 74.7 3.00 mg/kg 71.1 105 85-115 Chromium 52.7 1.00 mg/kg 56.8 92.8 85-115 Barium 12.8 1.00 mg/kg 13.0 98.5 85-115 Batch 5061278 - EPA200/SW7000 Series Blank (5061278-BLK1) Prepared: 21-Jun-05 Analyzed: 23-Jun-05 Mercury BIRL 0.179 mg/kg LCS (5061278-BSt) Prepared: 21-Jun-05 Analyzed: 23-Jun-O5 Mercury 0.845 0.179 mg/kg 0.893 94.6 80-120 Duplicate (5061278-DUP1) Source: SA29522-06 Prepared: 21-Jun-05 Analyzed: 23-JunO5 Mercury BRL 0.177 mg/kg BRL 35 Matrix Spike (5061278-MSI) Source: SA29522-06 Prepared: 21-Jun-05 Analyzed: 23-Jun-05 Mercury 0.381 0.174 mg/kg 0.406 BRL 93.8 75-125 Matrix Spike Dup (5061278-MSD1) Source: SA29522-06 Prepared: 21-Jun-05 Analyzed: 23-Jun-05 Mercury 0.417 0.165 mg/kg 0.383 BRL 109 75-125 9.02 35 Batch 5061279 - SW846 3050B - Blank (5061279-BLKI) Prepared: 22-Jun-05 Analyzed: 23-Jun-05 Selenium BIL 3.00 mg/kg wet Lead BRL 1.50 mg/kg wet Arsenic BRL 3.00 mg/kg wet Cadmium BRIL 0.500 mg/kg wet - Silver BRL 2.00 mg/kg wet mium BRL 1.00 mg/kg wet 'um BRIL 1.00 mg/kg wet LCS (5061279-BS1) Prepared: 22-Jun-05 Analyzed: 23-Jun-O5 Selenium 0.984 0.0300 mg/kg wet 1.00 98.4 85-115 Lead 1.02 0.0150 mg/kg wet 1.00 102 85-115 Silver 0.989 0.0400 mg/kg wet 1.00 98.9 85-115 Cadmium 1.06 0.0050 mg/kg wet 1.00 106 85-115 Arsenic 0.971 0.0300 mg/kg wet 1.00 97.1 85-115 Chromium 0.974 0.0100 mg/kg wet 1.00 97.4 85-115 Barium 1.03 0.0100 mg/kg wet 1.00 103 85-115 Duplicate (5061279-DUP1) Source: SA29522-07 Prepared: 22-Jun-05 Analyzed: 23-Jun-05 Lead 13.1 1.66 mg/kg dry 9.58 31.0 35 Selenium BRL 3.31 mg/kg dry BRL 35. Silver BRIL 2.21 mg/kg dry BRIL 35 Cadmium BRL 0.552 mg/kg dry BRL 35 Arsenic BIL 3.31 mg/kg dry BRL 35 Chromium 6.03 1.10 mg/kg dry 3.93 42.2 35 QR-05 Barium 10.1 1.10 mg/kg dry 8.21 20.6 35 Matrix Spike (5061279-MS1) Source: SA29522-14 Prepared: 22-Jun-05 Analyzed: 23-Jun-05 Lead 531 1.66 mg/kg dry 111 462 62.2 75-125 QM-07 Selenium 66.9 3.33 mg/kg dry 11 BRL 60.3 75-125 QM-07 Silver 58,9 2.22 mg/kg dry 55.4 8.15 91.6 75-125 Chromium 1300 1.11 mg/kgdry 111 1310 NR 75-125 QM-07 Arsenic 145 3.33 mg/kg dry 111 53.6 82.3 75-125 Cadmium 89.9 0.554 mg/kg dry 111 BLL 81.0 75-125 120 1.11 mg/kg dry 111 18.8 91.2 75-125 . trix Spike Dup (5061279-MSD1) Source: SA29522-14 Prepared: 22-Jun-O5 Analyzed: 23-Jun-05 Selenium 85A 3.30 mg/kg dry 110 BRL 77.6 75-125 24.3 35 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 23 of 32 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag *atch 5061279 - SW846 3050B Matrix Spike Dup (5061279-MSD1) Source: SA29522-14 Prepared: 22-Jun-05 Analyzed: 23-Jun-05 Lead 564 1.65 mg/kg dry 110 462 92.7 75-125 6.03 35 Arsenic 142 3.30 mg/kg dry 110 53.6 80.4 75-125 2.09 35 Cadmium 87.7 0.551 mg/kg dry 110 BRL 79.7 75-125 2.48 35 Chromium 1620 1.10 mg/kg dry 110 1310 282 75-125 21.9 35 QM-07 Silver 56.9 2.20 mg/kg dry 55.1 8.15 88.5 75-125 3.45 35 Barium 115 1.10 mg/kg dry 110 18.8 875 75-125 426 35 Reference (5061279-SRM1) Prepared: 22-Jun-05 Analyzed: 23-Jun-05 Selenium 102 3.00 mg/kg wet 113 90.3 85-115 Silver 24.3 2.00 mg/kg wet 26.0 93.5 85-115 Arsenic 70.1 3.00 mg/kg wet 71.6 97.9 85-115 Chromium 52.2 1.00 mg/kg wet 57.2 91.3 85-115 Cadmium i11 0.500 mg/kg wet I15 96.5 85-115 Barium 12.8 1.00 mg/kg wet 13.1 97.7 85-115 Reference (5061279-SRM2) Prepared: 22-Jun-05 Analyzed: 23-Jun-05 Selenium 107 3.00 mg/kg wet 112 95.5 85-115 Lead 110 1.50 mg/kg wet 126 87.3 85-115 Cadmium 113 0.500 mg/kg wet 115 98.3 85-115 Arsenic 69.7 3.00 mg/kg wet 71.2 97.9 85-115 Chromium 51.1 1.00 mg/kg wet 56.9 89.8 85-115 Silver 25.2 2.00 mg/kg wet 25.9 97.3 85-115 Bariuri 12.8 1.00 mg/kg wet 13.0 98.5 85-115 Batch 5061280 - EPA200/SW7000 Series W lank (5061280-BLK1) Prepared: 20-Jun-05 Analyzed: 22-Jun-05 ercury BRL 0.179 mg/kg wet LCS (5061280--BS1) Prepared: 20-Jun-05 Analyzed: 22-Jun-05 Mercury 0.826 0.179 mg/kg wet 0.893 92.5 80-120 Duplicate (5061280-DUPI). Source: SA29522-02 Prepared: 20-Jun-05 Analyzed: 22-Jun-05 Mercury 1.66 0.475 mg/kg dry 1.61 3.06 35 Matrix Spike (5061280-MS1) Source: SA29522-14 Prepared: 20-Jun-05 Analyzed: 22-Jun-05 Mercury 0.579 0.206 ng/kg dry 0.480 0.158 87.7 75-125 Matrix Spike Dup (5061280-MSD1) Source: SA29522-14 Prepared: 20-Jun-05 Analyzed: 22-Jun-05 Mercury 0.715 0.203 mg/kg dry 0.473 0.158 118 75-125 21.0 35 Batch 5061292 - SW846 3005A Blank (5061292-BLK1) Prepared & Analyzed: 21-Jun-05 Lead BRL 0.0038 mg/I Selenium BRL 0.0075 mg/I Chromium BRL 0.0025 mg/l Arsenic BRL 0.0040 mg/I Barium BRL 0.0025 mg/I Cadmium , BRL 0.0012 mg/I Silver BRL 0.0050 mg/I LCS (5061292-BS1) Prepared & Analyzed: 21-Jun-05 Selenium 0.0988 0.0030 mg/1 0.100 98,8 85-115 Lead 0.100 0.0015 mng/1 0.100 100 85-115 Barium 0.0866 0.0025 mg/I 0.100 86.6 85-115 Arsenic 0.0945 0.0016 mg/I 0.100 94.5 85-115 Chromiurn 0.0990 0.0010 mg/I 0.100 99.0 85-115 0.100 0.0005 mg/I 0.100 100 85-115 Sile 0.0487 0.0020 mg/I 0.0500 97.4 85-115 This laboratoryreport Is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 24 of 32 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag 9och 5061292 - SW846 3005A CS Dup (5061292-BSD1) Prepared & Analyzed: 21 -Jun-05 Lead 0.101 0.0015 mg/l 0.100 101 85-115 0.995 20 Selenium 0.0982 0.0030 mg/I 0.100 98.2 85-115 0.609 20 Cadmium 0.0995 0.0005 mg/l 0.100 99.5 85-115 0.501 20 Arsenic 0.0950 0.0016 mg/l 0.100 95.0 85-115 0.528 20 Silver 0.0497 0.0020 mg/l 0.0500 99.4 85-115 2.03 20 Barium 0.101 0.0010 mg/I 0.100 101 85-115 15.4 20 Chromium 0.0993 0.0010 mg/ 0.100 99.3 85-115 0.303 20 Duplicate (5061292-DUP1) Source: SA29522-10 Prepared & Analyzed: 21-Jun-05 Lead 0.0098 0.0038 mg/i 0.0076 25.3 20 - QR-05 Selenium BRL 0.0075 mg/I BRL. 20 Arsenic BRL 0.0040 mg/i BRL 20 Cadmium BRL 0.0012 mg/ 0.0003 0.00 20 Barium 0.0429 0.0025 mg/l 0.0436 1.62 20 Chromium 0.0047 0.0025 mg/l 0.0058 21.0 20 QR-05 Silver BRL 0.0050 mg/I BRL 20 Matrix Spike (5061292-MS1) Source: SA29591-18 Prepared & Analyzed: 21 -Jun-05 Lead 0.0918 0.0038 mg/I 0.100 BRL 91.8 75-125 Selenium 0.0815 0.0075 mg/l 0.100 BRL 81.5 75-125 Chromium 0.0952 0.0025 mg/I 0.100 BRL 95.2 75-125 - Arsenic 0,0848 0.0040 mg/l 0.100 BRL 84.8 75-125 Cadmium 0.0904 0.0012 mg/ 0.100 BRL 90.4 75-125 Silver 0.0450 0.0050 mg/l 0.0500 BRL 90.0 75-125 Barium 0.0975 0.0025 mg/l 0.100 BRL. 97.5 75-125 AftDu(pie u12592-MS[ Ii)Source: SA29591-18 Prepared & Analyzed: 21 Jun-05 0.0882 0.0075 mg/I 0.100 BR]. 88.2 75-125 7.90 20 Lead 0.0946 0.0038 mg/I 0.100 BRL 94.6 75-125 - 3.00 20 Silver 0.0469 0.0050 mg/ 0.0500 BRL 93.8 75-125 4.13 20 Cadmium 0.0951 0.0012 mg/i 0.100 BRL 95.1 75-125 5.07 20 Chromium 0.0972 0.0025 mg/l 0.100 BRL 97.2 75-125 2.08 20 Barium 0.0995 0.0025 mg/I 0.100 BRL 99.5 75-125 2.03 20 Arsenic 0.0879 0.0040 mg/I 0.100 BRL 87.9 75-125 3.59 20 Total Metals by EPA 200 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag Batch 5061293 - EPA200/SW7000 Series Blank (5061293-BLK1) Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Mercury BRL 0.00020 mg/- LCS (5061293-BS1) Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Mercury 0.00249 0.00020 mg/l 0.00250 99.6 80-120 Duplicate (5061293-DUPI) Source: SA29522-09 Prepared: 21 -Jun-05 Analyzed: 22-Jun-05 Mercury BRL 0.00020 mg/I 0.00022 138 20 QR-04 Matrix Spike (5061293-MS1) Source: SA29591-18 Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Mercury 0.00294 0.00020 mg/l 0.00250 0.00006 115 75-125 - Matrix Spike Dup (5061293-MSD1) Source: SA29591-18 Prepared: 2 1-Jun-05 Analyzed: 22-Jun-05 Mercury 0.00249 0.00020 mg/I 0.00250 0.00006 97.2 75-125 16.6 20 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 25 of 32 Soluble Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag atch 5061218 - SW846 3005A Blank (5061218-BLK1) Prepared & Analyzed: 21 -Jun-05 Lead BRL 0.0150 mg/ Selenium BRL 0.0300 mg/I Barium BRL 0.0100 mg/i Cadmium BRL 0.0050 mg/I Chromium BRL 0.0100 mg/l Arsenic BRL 0.0160 mg/l Silver BRL 0.0200 mg/il LCS (5061218-BS1) Prepared & Analyzed: 21 -Jun-05 Lead 0.994 0.0150 mg/I 1.00 99.4 85-115 Selenium 0.979 0.0300 mg/l 1.00 97.9 .85-115 Cadmium LO 0.0050 mg/l 100 101 85-115 Barium 1.01 0.0100 mg/l 1.00 101 85-115 Chromium 0.986 0.0100 mg/I 1.00 98.6 85-115 Silver 0.984 0.0400 mg/I 1.00 98.4 85-115 Arenic 0.962 0.0160 mg/I 1.00 96.2 85-115 LCS Dup (5061218-BSD1) Prepared & Analyzed: 21-Jun-05 Lead 1.00 0.0150 mg/l 1.00 100 85-115 0.602 20 Selenium 0.988 0.0300 mg/l 1.00 98.8 85-115 0.915 20 Cadmium 1.00 0.0050 mg/i 1.00 100 85-115 0.995 20 Arsenic 0.945 0.0160 mg/I 1.00 94.5 85-115 1.78 20 Silver 0.975 0.0400 mg/I 1.00 97.5 85-115 0.919 20 Barium 1.01 0.0100 mg/l 1.00 101 85-115 0.00 20 Chromium 0.990 0.0100 mg/l 1.00 99.0 85-115 0.405 20 S uplicate (5061218-DUPI) Source: SA29522-13 Prepared & Analyzed: 21-Jun-05 Sou e: SA29522-13 ' elenium BRL 0.0075 mg/I BRL 20 Lead BRL 0.0038 mg/I 0.0014 0.00 20 Cadmium BRL 0.0012 mg/l BRL 20 Silver BRL 0.0050 mg/I BRL 20 Arsenic BRL 0.0040 mg/I BRL 20 Chromium BRL. 0.0025 mg/l BRL 20 Barium 0.0125 0.0025 mg/I 0.0122 2.43 20 Matrix Spike (5061218-MS1) Source: SA29522-13 Prepared & Analyzed: 21-Jun-05 Selenium 0.0919 0.0075 mg/l 0,100 BRL 91.9 75-125 Lead 0.0854 0.0038 mg/i 0.100 0.0014 84.0 75-125 Silver 0.0430 0.0050 mg/l 0.0500 BRL 86.0 75-125 Arsenic 0.0862 0.0040 mg/i 0.100 BRL 86.2 75-125 Chromium 0.0865 0.0025 mg/l 0.100 BRL 86.5 75-125 Barium 0.101 0.0025 mg/I 0.100 0.0122 88.8 75-125 Cadmium 0.0882 0.0012 mg/l 0.100 BRL 88.2 75-125 Matrix Spike Dup (5061218-MSD1) Source: SA29522-13 Prepared & Analyzed: 21-Jun-05 Lead 0.0870 0.0038 mg/I 0.100 0.0014 85.6 75-125 1.86 20 Selenium 0.0928 0.0075 mg/I 0.100 BRL 92.8 75-125 0.975 20 Arsenic 0.0847 0.0040 mg/I 0.100 BRL 84.7 75-125 1.76 20 Chromium 0.0879 0.0025 mg/i 0.100 BRL 87.9 75-125 1.61 20 Barium 0.101 0.0025 mg/i 0.100 0.0122 88.8 75-125 0.00 20 Cadmium 0.0885 0.0012 mg/i 0.100 BRL 88.5 75-125 0.340 20 Silver 0.0431 0.0050 mg/ 0.0500 BRL 86.2 75-125 0.232 20 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 26 of 32 Soluble Metals by EPA 200 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag * ch 5061219 - EPA200/SW7000 Series Blank (5061219-BLK1) Prepared:21-Jun-05 Analyzed: 22-Jun-05 Mercury BRL 0.00020 mg/I LCS (5061219-BS1) Prepared: 21-Jun-05 Analyzed: 22-Jun-O5 Mercury 0.00514 0.00020 mg/I 0.00500 103 75-125 Duplicate (5061219-DUP1) Source: SA29522-13 Prepared: 2 1-Jun-05 Analyzed: 22-Jun-05 Mercury BRL 0.00020 mg/l 0.00018 57.1 20 QR-04 Matrix Spike (5061219-MS1) Source: SA29522-13 Prepared: 21-Jun-45 Analyzed: 22-Jun-05 Mercury 0.00306 0.00020 mg/l 0.00250 0.00018 115 75-125 Matrix Spike Dup (5061219-MSD1) Source: SA29522-13 Prepared: 21-Jun-05 Analyzed: 22-Jun-05 Mercury 0.00303 0.00020 mg/I 0.00250 0.00018 114 75-125 0.985 20 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 27 of 32 General Chemistry Parameters - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag * atch 5061074 - General Preparation Duplicate (5061074-DUPI) Source: SA29522-01. Prepared: 16-Jun-05 Analyzed: 17-Jun-05 %Solids 36.3 % 35.7 1.67 20 Batch 5061087 - General Preparation Duplicate (5061087-DUP1) Source: SA29541-03 Prepared: 16-Jun-05 Analyzed: 17-Jun-05 % Solids 87.0 % 87.1 0.115 20 Batch 5061939 - General Preparation Blank (5061939-BLK1) Prepared & Analyzed: 28-Jun-05 Total Organic Carbon BRL 100 mg/kg wet Blank (5061939-BLK2) Prepared & Analyzed: 28-Jun-05 Total Organic Carbon BRL 100 mg/kg wet Duplicate (5061939-DUP1) Source: SA29522-02 Prepared & Analyzed: 28-Jun-05 Total Organic Carbon 296000 100 mg/kg dry 313000 5.58 20 Reference (5061939-SRM1) Prepared & Analyzed: 28-Jun-05- Total Organic Carbon 7020 100 mg/kg wet 5370 131 56-144 Reference (5061939-SRM2) Prepared & Analyzed: 28-Jun-05 Total Organic Carbon 1050 100 mg/kg wet 1000 105 85-115 Reference (5061939-SRM3) Prepared & Analyzed: 28-Jun-05 Total Organic Carbon 1040 100 mg/kg wet 1000 104 85-115 Batch 5062062 - General Preparation Blank (5062062-BLK1) Prepared & Analyzed: 29-Jun-05 0 Tota Organic Carbon BRL 100 mg/kg wet S nk (5062062-BLK2) Prepared & Analyzed: 29-Jun-05 Total Organic Carbon BRL 100 mg/kg wet Duplicate (5062062-DUPI) Source: SA29522-05 Prepared & Analyzed: 29-Jun-05 Total Organic Carbon 26700 100 ng/kg dry 27000 1.12 20 Reference (5062062-SRMI) Prepared & Analyzed:-29-Jun-05 Total Organic Carbon 7150 100 mg/kg wet 5370 133 56-144 Reference (5062062-SRM2) Prepared & Analyzed: 29-Jun-05 Total Organic Carbon 992 100 mg/kg wet 1000 99.2 85-115 Reference (5062062-SRM3) Prepared &Analyzed: 29-Jun-05 Total Organic Carbon 1020 100 mg/kg wet 1000 102 85-115 Batch 5062063 - General Preparation Blank (5062063-BLKI) Prepared & Analyzed: 29-Jun-05 Total Organic Carbon BRL 100 mg/kg Blank (5062063-BLK2) Prepared & Analyzed: 29-Jun-05 Total Organic Carbon BRL 100 mg/kg Duplicate (5062063-DUPI) Source: SA29522-06 Prepared & Analyzed: 29-Jun-05 Total Organic Carbon 123000 100 mg/kg 143000 15.0 20 Reference (5062063-SRMI) Prepared & Analyzed: 29-Jun-05 Total Organic Carbon 7150 100 mg/kg 5370 133 56-144 Reference (5062063-SRM2) Prepared & Analyzed: 29-Jun-05 Total Organic Carbon 992 100 mg/kg 1000 99.2 85-115 Reference (5062063-SRM3) Prepared & Analyzed: 29-Jun-05 W otal Organic Carbon 1020 100 mg/kg 1000 102 85-115 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 28 of 32 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF % D Limit Y ch 0507003 - alibration Check (0507003-CCV1) C9-C18 Aliphatic Hydrocarbons, 1.71275E+08 3.14692E+09 1740 0 25.00 C19-C36 Aliphatic Hydrocarbons 1.03411E+08 2.48571E+09 2300 # 25.00 - C 1-C22 Aromatic Hydrocarbons 21737.9 19.265 -99.9 0 25.00 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL ==Below Reporting Limit Page 29 of 32 Notes and Definitions FF Field Filtered QM-04 Visual evaluation of the sample indicates the RPD is above the control limit due to a non-homogeneous sample matrix. QM-07 The spike recovery was outside acceptance limits for the MS and/or MSD. The batch was accepted based on acceptable LCS recovery. QR-02 The RPD result exceeded the QC control limits; however, both percent recoveries were acceptable. Sample results for the QC batch were accepted based on percent recoveries and completeness of QC data. QR-04 Analyses are not controlled on RPD values from sample concentrations less than the reporting limit. QC batch accepted based on LCS and/or LCSD QC results QR-05 RPD out of acceptance range. R-05 The sample was diluted due to the presence of high levels of non-target analytes resulting in elevated reporting limits. BRL Below Reporting Limit - Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis NR Not Reported RPD Relative Percent Difference A plus sign (+) in the Method Reference column indicates the method is not accredited by NELAC. Laboratory Control SamRle (LCS): A known matrix spiked with compound(s) representative of the target analytes, which is used to document laboratory performance. Matrix Duplicate: An intra-laboratory split sample which is used to document the precision of a method in a given sample matrix. Aatrix Spike: An aliquot of a sample spiked with a known concentration of target analyte(s). The spiking occurs prior to sample preparation and analysis. A matrix spike is used to document the bias of a method in a given sample matrix. Method Blank: An analyte-free matrix to which all reagents are added in the same volumes or proportions as used in sample processing. The method blank should be carried through the complete sample preparation and analytical procedure. The method blank is used to document contamination resulting from the analytical process. Method Detection Limit (MDL): The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is greater than zero and is determined from analysis of a sample in a given matrix type containing the analyte. Reortable Detec tion Limit (D : The lowest concentration that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. For many analytes the RDL analyte concentration is selected as the lowest non-zero standard in the calibration curve. While the RDL is approximately 5 to 10 times the MDL, the RDL for each sample takes into account the sample volume/weight, extract/digestate volume, cleanup procedures and, if applicable, dry weight correction. Sample RDLs are highly matrix-dependent. Surrogate: An organic compound which is similar to the target analyte(s) in chemical composition and behavior in the analytical process, but which is not normally found in environmental samples. These compounds are spiked into all blanks, standards,. and samples prior to analysis. Percent recoveries are calculated for each surrogate. Validated by: Hanibal C. Tayeh, Ph.D. Nicole Brown This laboratory report Is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 30 of 32 The following outlines the condition of all EPH samples contained within this report upon laboratory receipt. - Matrix 0 Aqueus E Soil M'Sediment 3 Other Containers C-9atisfactory 0 Broken 0 Leaking _ Aqueous Preservative I/A E pH<2 3 pH>2 0 pH adjusted to <2 in lab Comment Temperature 0 Received on ice iMeceived at 4± 2 *C 0 Other: *C - Were all QA/QC procedures followed as required by the EPH method? Yes ' No . Were any significant modifications made to the EPH method as specified in Section 11.3? No Were all performance/acceptance standards for required QA/QC procedures achieved? Yes No--N - I attest that based upon my inquiry of those individuals immediately responsible for obtaining the information, the material contained in this report is, to the best of my knowledge and belief, accurate and complete. Authorized by: Hanibal C. Tayeh, Ph.D. President/Laboratory Director This laboratory report is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 31 of 32 MADEP MCP ANALYTICAL METHOD REPORT CERTIFICATION FORM MADEP RTN': This form provides certifications for the following Spctrun Analytical, Inc. work order #: SA29522 a. Matrix E3 Groundwater OSoil/Sediment 0 Drinking Water E-0kr % A 'a O 82,6B O 8151A 0 8330 a6-tOt B1a470Al1lA M thods sed g8270C 0 8081A 0 VPH 0 6020 0 9014M 2 0 8082 0 8021B PH 0 7000S3 0 7196A I List Release Tracking Number (RTN), if known 2 M - SW-846 Method 9014 or MADEP Physiologically Available Cyanide (PAC) Method 3 S - SW-846 Methods 7000 Series List individual method and analyte A n affirmative response to questions A, B, C and D is requiredfor "Presumptive Certainty" status A Were all samples received by the laboratory in a condition consistent with that described on the 0 No Chain of Custody documentation for the data set? es Were all QA/QC procedures required for the specified analytical method(s) included in this report B followed, including the requirement to note and discuss in a narrative QC data that did not meet a-Ies 0 No appropriate performance standards or guidelines? Does the data included in this report meet all the analytical requirements for "Presumptive C Certainty", as described in Section 2.0 (a), (b), (c) and (d) of the MADEP document CAM VII A, es 0 No "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of Analytical Data"? VPH and EPHmethods only: Was the VPH or EPH method conducted without significant 0 No D modifications (see Section 11.3 of respective methods)? A response to questionsE and F below is requiredfor "PresumptiveCertainty" status E Were all analytical QC performance standards and recommendations for the specified methods Q..sd 0 No achieved? F Were results for all analyte-list compoundsfelements for the specified method(s) reported? 0 Yes O-NC All negative responses are addressedin a case narrative on the cover page of this report.- I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. Hanibal C. Tayeh, Ph.D. President/Laboratory Director Date: 7/1/2005 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 32 of 32 -'- _ _ -, is 0 4) N~a 5" S s is 0 S U) . C L U 0 Vn C -J I' 3 - C V *aO Z S n o 4 K S 0 C.) C-) t~4as 4; 044 On V . 45 ..qJ Idi 04 0 ---is 4 U -A4 'a. -g -A4 N- 06Mg o #dg -'C U 00 en t e S 00 0 cA ~0 9 .0 C C-) ON H -v ON 00 Cr N- p s A VOA JO # .3 en 4)00 4 .5 0 S04 OA4JUAfaSoid U C -4 C xnw C *0 odj o C.) 0 .0 C.) '4) z -4 £0 '-4 0 rn a 0 a A 4,i I, $ .4 0~ -I.- .0 N N 4* r A0 N N N .4% (Cu) 40 di Oil k I:- Cl N p di 0 I 0 0 £4 .4% 0 di t~h 0, 00 S I .0 t 0 S IN '.4 II .4. DO 4- C-, 0 '0 .21 .0 -4 CO di 4-I No 1;3 4 S Ad N -4. 0 tj I II t 0 4 "a N xi CI N ~54 ~44 ) (hr An 4) L C) C) 4 4 5.4 S S C. S 0- S n 0 p .4 Co - 0 H C 0 0 C. .0 'I 0. 4S *0 - LI 0 7- SO 0 -b 4O. H 0 0 uuu T r- z V 4Q 4 N"7 N n N. so 0& 0H U&0: 7 i9 y U '4k a 40 ou oy 4 Q0 C N,': 00-- - 05 - 4). ge A /;dj u Osl X!nsatS2IJO # U F Z C> CO SPIOA VOAJO # 0 C' ON -i ci 'S .1 C) 0 4 \N II C-N 'a- - N K - 4tn q @ '1 0& 4 tO o 24 ii It C)0 4 N. II oI* Ia TC o- 0 It C) C)4 -tI -S .4) 4) -C C.) N 4) .0 k5 cU 0 '4 04 -C 'H z 4- -C N SC -C -k Ni Ir< '2 Ca 4-. C. '4) 0 c~ 4) - 4) H .4) - C- N ~ .~ ~ U .0 0 .4 4) '4 0 34 4) 3-4 0.4 Report Date: -Report 14-Jul-05 16:11 0 Re-Issued Report SRevised Report SPECTRUM ANALYTICAL, INC. Featuring HANIBAL TECHNOLOGY LaboratoryReport Jacques Whitford Company, Inc. 24 Albion Rd, Suite 220 Project: 40 Forest St-Attleboro, MA Lincoln, RI 02865 Project #: 1000400 Attn: Kurt Klages Laboratory ID Client Sample ID Matrix Date Sampled Date Received SA30678-01 SED-22 Soil 07-Jul-05 13:45 11-Jul-05 14:28 SA30678-02 SED-23 Soil 07-Jul-05 13:55 11-Jul-05 14:28 I attest that the information contained within the report has been reviewed for accuracy and checked against the quality control requirements for each method. All applicable NELAC requirements have been met. Please note that this report contains 11 pages of analytical data plus Chain of Custody document(s). This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. Massachusetts Certification # M-MAl38/MA1 110 b Connecticut # PH-0777 Florida # E87600/E87936 Maine # MA138 New Hampshire # 2538/2972 New York # 11393/11840 Rhode Island # 98 eh, Ph.D. USDA #S-51435 President/Labo ry Director Vermont # VT-1 1393 Spectrum Analytical, Inc. is a NELAC accreditedlaboratory organization and meets NELAC testing standards. Use of the NELAC -- logo however does not insure that Spectrum is currently accredited for the specific method indicated. Please refer to our "Quality" webpage at www.spectrum-analytical.com for afull listing ofour current certifications. CASE NARRATIVE: The data set for work order SA30678 complies with internal QC criteria for the methods performed. The samples were received @ -1.0 degrees Celsius, An infrared thermometer with a tolerance of +/- 2.0 degrees Celsius was used immediately upon receipt of the samples. MADEP has published a list of analytical methods (CAM) which provides a series of recommended protocols for the -acquisition, analysis and reporting of analytical data in support of MCP decisions. "Presumptive Certainty" can be established only for those methods published by the MADEP in the MCP CAM. The compounds and/or elements reported were specifically requested. by the client on the Chain of Custody and in some cases may not include the full analyte list as defined in the method. According to WSC-CAM 5/2004 Rev.4, Table 11 A-1, recovery for some VOC analytes have been deemed potentially difficult Although recovery may still be within the recommended 70/-130% range, the analytical range has been set based on historical control limits. Please refer to "Notes and Definitions" for all sample/analyte qualifiers. Qualifiers will note any exceedance levels and items specific to sample analysis/matrix. ENVIRONMENTAL ANALYSES II Almgren Drive - Agawam, Massachusetts 01001 *Operational Building &Sample Receiving 830 Silver Street ' Agawam, Massachusetts 01001 - Administrative Offices, Volatile &Air Departments Page 1 of II 1-2A-790-011; *Al 71 AIQ -niV-t, 1 '70n rl Sample Identification Client Project # Matrix Collection Date/rime Received SED-22 1000400 SA30678-01I Soil 07-Jul-05 13:45 11-Jul-05 AS No. Analyte(s) Result *RDL/Units Diludon Method Ref. Prepared Analyzed Batch Analyst Flag M emivolatile Organic Compounds by GC PolychlorinatedBiphenyls by SW846 8082 Prepared by method SW846 3545A 12674-11-2 PCB 1016 BRL 63.3 pg/kg dry SW846 8082 13-Jul-05 13-Jul-05 5070651 sm 11104-28-2 PCB 1221 BRL 63.3 pg/kg dry " N 1 11141-16-5 PCB 1232 BRIL 63.3 pg/kg dry " " i 53469-21-9 PCB 1242 BRL 63.3 pg/kg dry " " 12672-29-6 PCB 1248 BRL 63.3 pg/kg dry ".N 11097-69-1 PCB 1254 1,710 63.3 pg/kg dry 1109642-5 PCB 1260 BRL 63.3 pg/kg dry 37324-23-5 PCB 1262 BRL 63.3 pg/kg dry 11100-14-4 PCB 1268 BRL 63.3 pg/kg dry Surrogate recoveries: 10386-84-2 4,4-DB-Octqfluorobiphenyl (Sr) 45.0 30-150% 2051-24-3 Decachlorobiphenyl (Sr) 30.0 30-150% Semivolatile Organic Compounds by GCMS PAHs by SW846 8270C Prepared by method SW846 3545A 33-32-9 Acenaphthene BRL 298 pg/kg dry I SW846 8270C 12-Jul-OS 13-Jul-45 5070578 ML 203-96-8 Acenaphthylene BRL 298 pg/kg dry N NN N 120-12-7 Anthracene BRL 298 pg/kg dry I " " "N 56-55-3 Benzo (a) anthracene 464 298 pg/kg dry "N " "N 50-32-3 Benzo (a) pyrene 461 298 pg/kg dry 1 " " N " . 05-99-2 Benzo (b) fluoranthene 436 298 pg/kg dry j " " N "N 91-24-2 Benzo (g,h,i) perylene BRL 298 pg/kg dry 3 " " " "N 207-08-9 Benzo (k) fluoranthene 355 298 pg/kg dry S* " "- "N 218-01-9 Chrysene 527 298 pg/kg dry 1 " " " "N 53-70-3 Dibenzo (ah) anthracene BRL 298 pg/kg dry 1 N " N " 206-444 Fluoranthene 807 298 pg/kg dry 86-73-7 Fluorene BRL 298 pg/kg dry 193-39-5 Indeno (1,2,3-cd) pyrene BRIL 298 pg/kg dry 90-12-0 1-Methylnaphthalene BRL 298 pg/kg dry 91-57-6 2-Methylnaphthalene BRL 298 pg/kg dry 1 " N , N 91-20-3 Naphthalene BRL 298 pg/kg dry 1 "9N 85-01-4 Phenanthrene 412 298 pg/kg dry 1 129-00-0 Pyrene 497 298 pg/kg dry Surrogate recoveries: 321-604 2-Fluorobiphenyl 81.5 30-130 % " N N 1718-51-4 Terphenyl-d4 57.8 30-130 % * Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver 12.8 1.96 mg/kg dry SW846 6010B 12-Jul-05 13-Jul-05 5070609 RE 7440-38-2 Arsenic BRIL 2.94 mg/kg dry 7440-39-3 Barium 41.1 0.980 mg/kg dry 7440-43-9 Cadmium BRL 0.490 mg/kg dry 7440-47-3 Chromium 327 0.980 mg/kg dry 7439-97-6 Mercury 0.420 0.382 mg/kg dry SW846 7471A " 14-Jul-45 5070610 YP * 7439-92-? Lead 250 1.47 mg/kg dry SW846 6010B " 13-Jul-05 5070609 RE 7782-49-2 Selenium BRIL 2.94 mg/kg dry " General Chemistry Parameters This laboratoryreport is not valid without an authorizedsignature on the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 2 of 11 Sample Identification Client Project # Matrix Collection Date/Time Received SED-22 1000400 Soil 07-Jul-05 13:45 11-Jul-05 - SA30678-01 A No, Analye(s) Result *Rl/UnIfj Dilution Method Ref: Prepared Analyzed Batch Analyst Flag - Wneral Chemistry Parameters I, ./o Solids 45.7 1 SM2540 0 11-Jul-05 -JulI-05 5070558 BD Mod. This laboratory report is not valid without an authorizedsignature on the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 3 of 11 Sample Identification Client Project # Matrix Collection Dateffime Received SED-23 1000400 Soil 07-Jul-05 13:55 11-Jul-05 SA30678-02 AS No. Analyte(s) Result *RDIUnit Dilution Method Ref Prepared Analyzed Batch Analyst Flag Wemivolatile Organic Compounds by GC PolychlorinatedBiphenvis by SW846 8082 Prepared by method SW846 3545A 12674-11-2 PCB 1016 BRL 72.9 pg/kg dry SW846 8082 13-Jul-05 13-Jul-05 5070651 sm I 11104-28-2 PCB 1221 BRL 72.9 pg/kg dry " " " " 11141-16-5 PCB 1232 BRI, 72.9 pg/kg dry 53469-21-9 PCB 1242 BRI, 72.9 pg/kg dry 12672-29-6 PCB 1248 BRL 72.9 pg/kg dry 11097-69-1 PCB 1254 175 72.9 pg/kg dry " " 11096-82-5 PCB 1260 BRL 72.9 pg/kg dry " 37324-23-5 PCB 1262 BRIL 72.9 pg/kg dry " 111o-14-4 PCB 1268 BRL 72.9 pg/kg dry " Surrogaterecoveries: 10386-84-2 4,4-DB-Octafluorobiphenyl (Sr) 115 30-150% 2051-24-3 Decachlorobiphenyl (Sr) 65.0 30-150 %a General Chemistry Parameters %Solids 39.0 1 SM2540 0 11-Ju-05 11-Jul-05 5070558 BD Mod. This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 4 of 11 Semivolatile Organic Compounds by GC - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag *h 5070651 - SW846 3545A Blank (5070651-BLK1) Prepared & Analyzed: 13-Jul-05 PCB 1016 BRL 28.6 pg/kg wet PCB 1221 BRL 28.6 pg/kg wet PCB 1232 BRL 28.6 pg/kg wet PCB 1242 BRL 28.6 pg/kg wet PCB 1241 BRL 28.6 pg/kg wet PCB 1254 BRL 28.6 pg/kg wet PCB 1260 BRL 28.6 pg/kg wet PCB 1262 BRL 28.6 pg/kg wet PCB 1268 BRL 28.6 pg/kg wet Surrogate: 4,4-DB-Octaluorobiphenyl(Sr) 21.4 pg/kg wet 28.6 74.8 30-150 Surrogate:Decachlorobipheny (Sr) 25.7 pg/kg wet 28.6 89.9 30-150 LCS (5070651-BS1) Prepared & Analyzed: 13-Jul-05 PCB 1016 301 28.6 pg/kgwet 357 84.3 40-140 PCB 1260 286 28.6 pg/kg wet 357 80.1 40-140 Surrogate: 4,4-DB-Octafluorobiphenyl (Sr) 22.9 pg/kg wet 28.6 80.1 30-150 Surrogate: Decachlorobiphenyl(Sr) 31.4 pg/kgwet 28.6 110 . 30-150 Duplicate (5070651-DUP1) Source: SA30753-06 Prepared & Analyzed: 13-Jul-05 PCB 1016- BRL 28.6 pg/kg dry BRL 40 PCB 1221 BRL 28.6 pg/kg dry BRL 40 PCB 1232 BRL 28.6 pg/kg dry BRL 40 PCB 1242 BRL 28.6 pg/kg dry BRL 40 PCB 1248 BRL 28.6 pg/kg dry BRL 40 1254 101 28.6 pg/kg dry 74.2 30.6 40 1260 BRL 28.6 pg/kg dry 18.2 14.7 40 CE 1262 BRL 28.6 pg/kg dry BRL 40 PCB 1268 BRL 28.6 pg/kg dry BRL 40 Surrogate: 4,4-DB-OctafluorobJhenyI(Sr) 18.5 pg/kg dry 28.5 64,9 30-150 Surrogate:Decachlorobiphenyl (Sr) 18.5 pg/kg dry 28.5 64.9 30-150 Matrix Spike (5070651-M11) Source: SA30753-06 Prepared & Analyzed: 13-Jul-05 PCB 1016 313 28.7 pg/kg dry 358 BRL 87.4 40-140 PCB 1260 285 28.7 pg/kg dry 358 18.2 74.5 40-140 Surrogate:4,4-DB-Octafluorobiphenyl (Sr) 21.5 pg/kg dry 28.7 74.9 30-150 Surrogate: Decachlorobiphenyl(Sr) 21.S pg/kg dry 28.7 74.9 30-150 Matrix Spike Dup (5070651-MSD1) Source: SA30753-06 Prepared & Analyzed: 13-Jul-05 PCB 1016 281 28.8 pg/kgdry 360 BRL 78.1 40-140 11.2 50 PCB 1260 288 28.8 ig/kg dry 360 18.2 74.9 40-140 0.535 50 Surrogate: 4,4-DB-Octafluorobiphenyl (Sr) 18.7 pg/kg dry 28,8 64.9 30-150 Surrogate: Decachlorobiphenyl(Sr) 18.7 pg/kg dry 28.8 64.9 30-150 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 5 of 11 Semivolatile Organic Compounds by GCMS - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag W atch 5070578 - SW846 3545A Blank (5070578-BLK1) Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Acenaphthene BRL 66.0 pg/kg wet Acenaphthylene BRL 66.0 pg/kg wet Anthracene BRL 66.0 pg/kg wet Benzo (a) anthracene BRL 66.0 pg/kg wet Beno (a) pyrene BRL 66.0 pgkg wet Benzo (b) fluoranthene BRL 66.0 pg/kg wet Benzo (g,h,i) perylene, BRL 66.0 pg/kg wet Benzo (k) fluoranthene BRL 66.0 pg/kg wet Chrysene BRL 66.0 pg/kg wet Dibeno (ah) anthracene BRL 66.0 pg/kg wet Fluoranthene BRL 66.0 pg/kg wet Fluorene BRL 66.0 pg/kg wet Indeno (1,2,3-cd)pyrene BRL 66.0 pg/kg wet 1-Methylnaphthalene BRL -66.0 pg/kg wet 2-Methylnaphthalene BRL 66.0 pg/kg wet Naphthalene 66,0 pg/kg wet Phenanthrene BRL 66.0 pg/kgwet Pyrene BRL 66.0 pg/kg wet Surrogate: 2-Fluorobiphenyl 3210 pg/kg wet 6670 481 30-130 Surrogate: Terphenyl-d41 3690 pg/kg wet 6670 5.3 30-130 LCS (5070578-BS1) Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Aceaaphthene 4420 66.0 pg/kg wet 6670 66.3 40-140 Acenaphthylene 4480 66.0 pg/kg wet 6670 67.2 40-140 Anthracene 4580 66.0 pg/kg wet 6670 68.7 40-140 Benzo (a) anthracene 4750 66.0 pg/kg wet 6670 71.2 40-140 Benz (a) pyrene 4920 66.0 pg/kg wet 6670 73.8 40-140 Benzo (b) flucranthene 5050 66.0 pg/kg wet 6670 75.7 40-140 Benzo (gAl) perylene 4430 66.0 pg/kg wet 6670 66.4 40-140 Beno (k) fluoranthene 4600 66.0 pg/kg wet 6670 69.0 40-140 Chrysene 4560 66.0 pg/kg wet -6670 68.4 40-140 Dibenzo (a,h) anthracene 4900 66.0 pg/kg wet 6670 73.5 40-140 Fluoranthene 4730 66.0 pg/kg wet 6670 70.9 40-140 Fluorene 4680 66.0 pg/kg wet 6670 70.2 40-140 Indeno (1,2,3-ed) pyrene 4710 66.0 pg/kg wet 6670 70.6 40-140 1-Methylnaphthaiene 3880 66.0 pg/kg wet 6670 58.2 40-140 2-Methylnaphthalene 4410 66.0 pg/kg wet 6670 66.1 40-140 Naphthalene 4240 66.0 pg/kg wet 6670 63.6 40-140 Phenanthrene 4560 66.0 pg/kg wet 6670 68.4 40-140 Pyrene 4450 66.0 pg/kg wet 6670 66.7 40-140 Surrogate:2-Fluorobiphenyl 4390 pgkg wet 6670 65.8 30-130 Surrogate: Terphenyl-d4 4570 pg/kg wet 6670 68.5 30-130 Duplicate (5070578-DUPI) Source: SA30661-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Acenaphthene 302 97.2 pg/kg dry 482 45,9 50 Acenaphthylene 562 97.2 pg/kg dry 822 37.6 50 Anthracene 670 97.2 pg/kg dry 962 35.8 50 Benzo (a) anthracene 913 97.2 pg/kg dry 1110 19.5 50 Benzo (a) pyrene 640 97.2 pg/kg dry 745 15.2 50 Benzo (b) fluoranthene 599 97.2 pg/kg dry 703 16.0 50 Benm (g,h,) perylene 539 97.2 pg/kg dry 689 24.4 50 Benzo (k) fluoranthene 512 97.2 pg/kg dry 686 29.0 50 Chrysene 932 97.2 pg/kg dry 1150 20.9 50 Dibenzo (ajh) anthracene 168 97.2 pg/kg dry 210 22.2 50 Fluornthene 2070 97.2 pg/kg dry 2620 23.5 50 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 6 of I1 Semivolatile Organic Compounds by GCMS - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag 5070578 - SW846 3545A Duplicate (5070578-DUPI) Source: SA30661-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Fluorene 349 97.2 pg/kg dry 537 42.4 50 Indeno (1,2,3-cd) pyrene 730 97.2 pg/kg dry 790 7.89 50 1-Methylnaphthalene 105 97.2 pg/kg dry 185 55.2 50 QM-04 2-Methylnaphthalene 203 97.2 pg/kg dry 348 52.6 50 QM-04 Naphthalene 244 97.2 pg/kg dry 420 53.0 50 QM-04 Phenanthrene 1650 97.2 pg/kg dry 2000 19.2 50 Pyrene 1690 97.2 pg/kg dry 1930 13.3 50 Surrogate: 2-Fluorobiphenyl 1590 pIg/kg dry 2460 64.6 30-130 Surrogate: Terphenyl-d14 1870 pig/kg dry 2460 76.0 30-130 Matrix Spike (5070578-MS1) Source: SA30661-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Acenaphthene 3300 96.8 pig/kg dry 4890 482 57.6 40-140 Pyrene 3890 96.8 pg/kg dry 4890 1930 40.1 40-140 Surrogate: 2-Fluorobiphenyl 3030 pg/kg dry 4890 62.0 30-130 Surrogate: Terphenyl-d14 2770 pg/kg dry 4890 56.6 30-130 Matrix Spike Dun (5070578-MSD1) Source: SA30661-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Matrix Spike Dup (5070578-MSDi) Acenaphthene 3240 96.7 pg/kg dry 4880 482 56.5 40-140 1.93 30 Pyrene 4780 . 96.7 pg/kg dry 4880 1930 58.4 , 40-140 37.2 30 QM-04 Surrogate: 247uorobiphenyl 266t ig/kg dry 4880 54.5 30-130 Surrogate: Terpheny-dl4 298 0yg/kg dry 4880 61.1 30-130 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 7 of 11 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag *atch 5070609 - SW846 3050B Blank (5070609-BLK1) Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Selenium BRL 1.50 mg/kg wet Lead SRL 0.750 mg/kg wet Silver BRL 1.00 mg/kg wet Chromium BRL 0.500 mg/kg wet Cadmium BRI 0.250 mg/kg wet Arsenic BRI 1.50 mg/kg wet Barium BRI 0.500 mg/kg wet LCS (5070609-BS1) Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Lead 93.5 0.750 mg/kg wet 100 93.5 85-115 Selenium 89.3 1.50 mg/kg wet 100 89.3 85-115 Arsenic 94.3 1.50 mg/kg wet 100 94.3 85-115 Silver 44.4 1.00 mg/kg wet 50.0 88.8 85-115 Cadmium 98.2 0.250 mg/kg wet 100 98.2 85-115 Chromium 99.0 0.500 mg/kg wet 100 99.0 85-115 Barium 97.9 0.500 mg/kg wet 100 97.9 85-115 Duplicate (5070609-DUP1) Source: SA30678-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Selenium BRL 2.99 mg/kg dry BRI. 35 Lead 185 1.49 mg/kg dry 250 29.9 35 Chromium 582 0.996 mg/kg dry 327 56.1 35 QR-05 Cadmium BR 0.498 mg/kg dry BRL 35 - Arsenic BRI 2.99 mg/kg dry BRL 35 Silver 11. 7 1.99 mg/kg dry 12.8 8.98 35 Barium 39.3 0.996 mg/kg dry 41.1 4.48 35 gbMaktrlx Spike (5070609-MMI) Source: SA30678-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Selenium 166 3.16 mg/kg dry 211 BR 78.7 75-125 Lead 474 1.58 mg/kg dry 211 250 106 75-125 Cadmium 206 0.526 mg/kg dry 211 BRI 97.6 .75-125 Silver 79.6 2.11 mg/kg dry 105 12.8 63.6 75-125 QM-07 Arsenic 191 3.16 mg/kg dry 211 BRI 90.5 75-125 Chromium 522 1,05 mg/kg dry 211. 327 92.4 75-125 Barium 241 1.05 mg/kg dry 211 41.1 94.7 75-125 Matrix Spike Dup (5070609-MSD1) Source: SA30678-01 Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Lead 434 1.52 mg/kg dry 203 250 90.6 75-125 8.81 35 Selenium 150 3.04 mg/kg dry 203 BRL 73.9 75-125 10.1 35 QM-07 Arsenic 174 3.04 mg/kg dry 203 BRL 85.7 75-125 9.32 35 Cadmium 191 0.507 mg/kg dry 203 BRI 94.1 75-125 7.56 35 Silver 74.2 2.03 mg/kg dry 101 12.8 60.8 75-125 7.02 35 QM-07 Chromium 465 1.01 mg/kg dry 203 327 68.0 75-125 11.6 35 QM-07 Barium 255 1.01 mg/kg dry 203 41.1 105 75-125 5.65 35 Reference (5070609-SRM1) Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Lead 59.2 0.750 mg/kg wet 61.1 96.9 85-115 Selenium 50.1 1.50 mg/kg wet 54.5 91.9 85-115 Arsenic 31.8 1.50 mg/kg wet 34.5 92.2 85-115 Cadmium 51.5 0.250 mg/kg wet 55.5 92.8 85-115 Chromium 24.4 0.500 mg/kg wet 27.5 88.7 85-115 Reference (5070609-SRM2) Prepared: 12-Jul-05 Analyzed: 13-Jul-05 Lead 62.2 0.750 mg/ks wet 62.7 99.2 85-115 Selenium 50.8 1.50 mg/kg wet 55.9 90.9 85-115 Arsenic 34.0 1.50 mg/kg wet 35.4 96.0 85-115 Cadmium 54.1 0.250 mg/kg wet 56.9 95.1 85-115 Chromium 26.3 0.500 mg/kg wet 28.3 92.9 85-115 Silver 12.2 1.00 mg/kgwet 12.8 95.3 85-115 This laboratoryreport Is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 8 of I1 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag ch 5070610 - EPA200/SW7000 Series Blank (5070610-B LK1) Prepared: 12-Jul-05 Analyzed: 14-Jul-05 Mercury BRL 0.179 mg/kg wet LCS (5070610-BS 1) Prepared: 12-Jul-05 Analyzed: 14-Jul-05 Mercury 0.904 0.179 mg/kg wet 0.893 101 80-120 Duplicate (5070610-DUP1) Source: SA30678-01 Prepared: 12-Jul-05 Analyzed: 14-Jul-05 Mercury 0.402 0.362 mg/kg dry 0.420 4.38 35 Matrix Spike (5070610-MS1) Source: SA30678-01 Prepared: 12-Jul-05 Analyzed: 14-Jul-05 Mercury 0.914 0.351 mg/kg dry 0.816 0.420 60.5 75-125 QM-07 Matrix Spike Dup (5070610-MSD1) Source: SA30678-01 Prepared: 12-Jul-05 Analyzed: 14-Jul-O5 Mercury 1.26 0.347 mg/kg dry 0.807 0.420 104 75-125 31.8 35 Reference (5070610-SRM1) Prepared: 12-Jul-05 Analyzed: 14-Jul-05 Mercury 1.20 0.179 mg/kg wet 131 91.6 85-115 General Chemistry Parameters - Quality Control Spike Source %REC RPD Analyte(s) Result *RDL Units Level Result %REC Limits RPD Limit Flag Batch 5070558 - General Preparation Duplicate (5070558-DUPI) Source: SA30685-10 Prepared & Analyzed: I1-Jul-05 % Solids 91.5 % 91.6 0.109 20 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 9 of 11 Notes and Definitions QM-04 Visual evaluation of the sample indicates the RPD is above the control limit due to a non-homogeneous sample matrix. QM-07 The spike recovery was outside acceptance limits for the MS and/or MSD. The batch was accepted based on acceptable LCS recovery. QR-05 RPD out of acceptance range. BRL Below Reporting Limit - Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis NR Not Reported RPD Relative Percent Difference A plus sign (+) in the Method Reference column indicates the method is not accredited by NELAC. Laboratory Control Sample (LCS): A known matrix spiked with compound(s) representative of the target analytes; which is used to document laboratory performance. Matrix Duplicate: An intra-laboratory split sample which is used to document the precision of a method in a given sample matrix. Matrix Spike: An aliquot of a sample spiked with a known concentration of target analyte(s). The spiking occurs prior to sample preparation and analysis. A matrix spike is used to document the bias of a method in a given sample matrix. Method Blank: An analyte-free matrix to which all reagents are added in the same volumes or proportions as used in sample processing. The method blank should be carried through the complete sample preparation and analytical procedure. The method blank is used to document contamination resulting from the analytical process. Method Detection Limit (MDL): The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is greater than zero and is determined from analysis of a sample in a given matrix type containing the analyte. Reportable Detection Limit (RDL): The lowest concentration that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. For many analytes the RDL analyte concentration is selected as the lowest non-zero standard in the calibration curve. While the RDL is approximately 5 to 10 times the MDL, the RDL for each sample takes into account-the sample volume/weight, extract/digestate volume, cleanup procedures and, if applicable, dry weight correction. Sample RDLs are highly matrix-dependent. Surrogate: An organic compound which is similar to the target analyte(s) in chemical composition and behavior in the analytical process, but which is not normally found in environmental samples. These compounds are spiked into all blanks, standards, and samples prior to analysis. Percent recoveries are calculated for each surrogate. Validated by: Hanibal C. Tayeh, Ph.D. Nicole Brown 0 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 10 of 11 MADEP MCP ANALYTCAL METHOD REPORT CERTIFICATION FORM MADEP RTN': is form provides certifications for the following Spctrum Analytical, Inc. work order #: SA30678 atrix D3 Groundwater "Soil/Sediment 0 Drinking Water 0 Other E 82,B a 8151A 0 8330 0-'6tiOB a,1470A/IA MCP SW-8462 2 MethodsUsed ' C 8081A 0 VPH 0 6020 0 9014M 8082 0 8021B 0 EPH 0 7000Sa 0 7196A I List Release Tracking Number (RTN), if known 2 M - SW-846 Method 9014 or MADEP Physiologically Available Cyanide (PAC) Method 3 S - SW-846 Methods 7000 Series List individual method and analyte An affirmative response to questions A, B, C andD is requiredfor "PresumptiveCertainty" status A Were all samples received by the laboratory in a condition consistent with that described on the 0O No Chain of Custody documentation for the data set? Were all QA/QC procedures required for the specified analytical method(s) included in this report B followed, including the requirement to note and discuss in a narrative QC data that did not meet &es 0 No appropriate performance standards or guidelines? Does the data included in this report meet all the analytical requirements for "Presumptive Certainty", as described in Section 2.0 (a), (b), (c) and (d) of the MADEP document CAM VI A, es 0 No "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of Analytical Data"? No D VPH and EPH methods only: Was the VPH or EPH method conducted without significant 0 Y modifications (see Section 11.3 of respective methods)? A response to questions E and F below is requiredfor "Presumptive Certainty" status E Were all analytical QC performance standards and recommendations for the specified methods es 3 No achieved? F Were results for all analyte-list compounds/elements for the specified method(s) reported? 0 Yes El o All negative responses are addressed in a case narrativeon the cover page of this report. I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. Hanibal C. Taych, Ph.D. President/Laboratory Director Date: 7/14/2005 This laboratoryreport is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 11 of 11 7 -F g En 0 0 o .4; 0O-.0 2 .~f: .~ *e0.104 z 0 Uu! . 44 0 0 An a; o q a to H o 4 mE=. t -) r 36l'YId JO # SSUfD MI flJO # t sse 7-qmujo # -o H C4 SIUIA VOAJ # 4 .4) 0 §A7IDM3S/Jd csie's, 201 -I! - kIt% ~dAj u-4 o 4 4) B '4, '0 N -'C x tJ Kr *0 0 N C.) 3 a 4) t3I 0 & 0 0- 0 4) o~ 2 CM 0 c Q 0c o)I 4) c) I tO 4) 4) "4 CO -4 C, C) 0 ~ - 0 CO *.) 0 - cl 2 I Page 1 of 3 R.I. Analytical Specialists in Environmental Services CERTIFICATE OF ANALYSIS Aquatronics Industries Inc. Date Received: 05/12/2005 Attn: Mr. Howard Schachter . Date Reported: 05/17/2005 501 Bullock's Point Ave P.rO#: Riverside, RI 02915 Work Order # 0505-07499 DESCRIPTION: SCHUSTER ATTLEBORO ROAD BED (TWO SOIL SAMPLES) Subject sample(s) has/have been analyzed by our Warwick, R.I. laboratory with the attached results. Reference: All parameters were analyzed by U.S. EPA approved methodologies and all NELAC requirements were met. The specific methodologies are listed in the methods column of the Certificate Of Analysis. Data qualifiers (if present) are explained in full at the end of a given sample's analytical results. - Certification #: RI-033, MA-RI015, CT-PH-0508, ME-RIO15 NH-253700 A & B, USDA S-41844, NY-1 1726 If you have any questions regarding this work, or if we may be of further assistance, please contact us. Approved by: Data Reporting ene: Chain of Custody tA ACt0 0 - 1' '4. , C*) '~' 41 Illinois Avenue, Warwick, RI 02888 * 131 Coolidge Street. Bldg 2, Hudson, MA 01749 C,. *. - Tel: (401) 737-8500 Fax: (401) 738-1970 C t Tel: 19781 568.0Q41 Fvc 17RI %APf-l7R Page 2 of 3 R.L Analytical Laboratories, Inc. CERTIFICATE OF ANALYSIS Aquatronics Industries Inc. Date Received: 05/12/2005 Approved Work Order #: 0505-07499 Sample# 001 SAMPLE DESCRIPTION: SCHUSTER ATTLEBORO ROAD BED EAST LAB #0502086 SAMPLE TYPE: COMPOSITE SAMPLE DATEIfME: 05/05/2005 SAMPLE DET. DATE PARAMETER RESULTS LIMIT UNITS METHOD ANALYZED ANALYST PAH Naphthalene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Acenaphthylene <1.0 Lo mg/kg dry SW-846 8270C 05/17/2005 DMM Acenaphthene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Fluorene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Phenanthrene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Anthracene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Fluoranthene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Pyrene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Benzo(a)anthracene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Chrysenre Benzo(b)fluoranthene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Benzo(k)fluoranthene <1.0 1.0 mg/kg dry SW-846 3270C 0517/2005 DMM Benzo(a)pyrene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Indeno(1,2,3-cd)pyrene <1.0 1.0 mg/kg dry SW-846 8270C 05/17/2005 DMM Dibenzo(ah)anthracene R.I. Analytical Laboratories, Inc. CERTIFICATE OF ANALYSIS ) Aquatronics Industries Inc. Date Received: 05/12/2005 Approved Work Order #: 0505-07499 Data Reporting S LE# 002 S=LE DESCRIPTION: SCHUSTER ATTLEBORO ROAD BED WEST LAB #0502087 SAMPLE TYPE: COMPOSITE SAMPLE DATE/TIME: 05/05/2005 SAMPLE DET. DATE PARAMETER RESULTS LIMIT UNITS METHOD ANALYZED ANALYST PAH Naphthalene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Acenaphthylene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Acenaphthene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Fluore. <0.7 0.7 mg/kg dry SW-46 8270C 05/17/2005 DMM Phenanthrene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Anthracene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Fluomanthene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Pyrene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Benzo(b)fluoranthene - <0.7 0.7 mg/kg dry SW-84 8270C 05/17/2005 DMM Benzo(k)fluoranthene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Benzo(a)pyrene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Indeno(1,2,3-cd)pyrene <0.7 0.7 mg/kg dry SW-46 8270C 05/17/2005 DMM Dibenzo(ah)anthracene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Benzo(g,h)perylene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM 2-Methylnaphthalene <0.7 0.7 mg/kg dry SW-846 8270C 05/17/2005 DMM Dibenzofuran <0.7 0.7 mg/kg dry SW-46 8270C 05/17/2005 DMM MOISTURE 13 SM2540 G: 05/12/2005 KR SURROGATES RANGE SW-846 8270C 05/17/2005 DMM Nitrobenzene-d5 63 23-120% SW-846 8270C 05/17/2005 DMM 2-Fluorobiphenyl 60 30-115% SW-846 8270C 05/17/2005 DMM P-Terphenyl-d14 88 18-137% SW-846 8270C 05/17/2005 DMM Extraction date Extracted SW846 3550 05/16/2005 RAS z It c cc Z -CC - z UTA c3: o 1.O u -- 'U ~li0 I: I t~-~~ I *a CI n 8 , II - 0 3. Cz 0. 0 (0 C)3114 z.6 mz 000 "r~ Atto 0.0 Eg 0 o > 0NnA ("1 Ii0 3.3. a e 14E E C -4 - u0 < L7d * wc .. r - T Page of 2 R.I. Analytical Speialists inEnronmentai Sevices CERTIFICATE OF ANALYSIS - zatrcs Industries Inc. Date Received: 04/07/2005 nMr. Howard Schachter Date Reported: 04/12/2005 501 Bullock's Point Ave P.O. #: Riverside, RI 02915 Work Order # 0504-05344 DESCRIPTION: SCHUSTER AITLEBORO ROAD BED (TWO SOIL SAMPLES) Subject sample(s) has/have been analyzed by our Warwick, R.I laboratory with the attached results. Reference: All parameters were analyzed by U.S. EPA approved methodologies and all NELAC requirements were met The specific methodologies are listed in the methods column of the Certificate Of Analysis. Data qualifiers (if present) are explained in full at the end of a given sample's analytical results. Certification #: RI-033, MA-R1015, CT-PH-0508, ME-RIO15 NH-253700 A & B, USDA S-41844, NY-1 1726 If you have any questions regarding this work, or if we may be of further assistance, please contact us. Approved by: S-'0 D~ata Repo 'i ene: Chain of Custody ~s 41 Illinois Avenue, 4' Warwick, RI 02888 6 131 Coolidge Street, Btdg 2, Hudson, MA 01749 Tel: '3 (401) 737-8500 Fax: (401) 738-1970 C S Tel: (978) 568-0041 Fax: (978) 568-0078 Page 2 of 2 RL Analytical Laboratories, Inc. CERTIFICATE OF ANALYSIS Aquatronics Industries Inc. Date Received 04/07/2005 Approved by: 'sill Work Order#: 0504-05344 Data ltorting le# 001 DESCRIPTION: SCHUSTER ATILEBORO ROAD BED EAST IAB# 04012084 SAMPLE TYPE: COMPOSiTE - SAMPLE DATE/TIME: 04/01/2005 SAMPLE DET. DATE PARAMETER RESULTS LIMIT UNITS METHOD ANALYZED ANALYST TCiMErAS ARSENIC 4.5 0.5 mg0 SW4466010 04/112005 iNs BARnRM <04.2 02 mep SW4466010 0411)2005 m cADMKm <0.025 0.025 SW-646 6010 04/112005 mB CHRMIUM Ae <0.15 0.15 mgnI sw-466010 0411 V005 mB LEAD <0.20 020 mgA SW446 6010 04/11)005 mB MERCURY <.0005 0.0005 mgni SW446 7470A 04/09/2005 NR SELENIUM <05 0.5 mg/ SW446 6010 04/11AM005 1MB SILER <0.10 0.10 MeS' SW4K6 6010 04/11/2005 mB Smje #002 SAbSDESCRIPTON: SCHUS'IR ATTLEBORO ROAD BED WEST LAB# 04012085 SAMPLE TYPE: COMPOSITE SAMPLE DATE/TIME: 04101/2005 SAMPLE DET. DATE PARAMETER RESULTS LIMIT UNITS METHOD ANALYZED ANALYST TCp METALS ARSEC <0.j 0.5 mg/ SW446 6010 04/11/2005 mB BARIUM <0.2 02 mgn SW-84 6010 04/11/2005 mB CADMIUM <0.025 0.025 mtI SW446 6010 04/11005 JNB CHROMIUM <0.t5 0.15 m/Il SW446 6010 04/11005 mB LEAD - 0.46 0.04 mg/A sw446 6010 04/11(2005 MB MsacURY <0.0005 0.0005 mg/I SW.- 7470A 04/09/2005 NR . SEMUM <05 03 mgn SW-46 6010 04/l2005 mB SILVER <0.10 0.10 mg/I SW446 6010 04/112005 WB -f------i - ~~ ~ ~a -- - "I17= lbs / 7 - * Mj y- 'C tO** I?:.aL)i .1 - - .. I 900 c7C? 9 jo~ *(r II W~ ca C,(o~5 ZI 0( A.A C}*** CQ A . z F4 I It iot 00 00 & ielll Report Date: Final Report 28-Dec-07 15:56 0 Re-Issued Report Revised Report SPECTRUM ANALYTICAL, INC. Fetwuing HANIBAL TECHNOLOGY Laboratory Report Western Mass Environmental 16 Ponders Hollow Road, P.O. Box 1295 Project: Ralph Shuster Metals - Attleboro, MA Westfield, MA 01086 Project 1484 Attn: Kurt Klages Laboratory ID Client Sample ID Matrix Date Sampled Date Received SA72543-Ol TP-1 Soil 19-Dec-07 09:30 20-Dec-07 14:47 SA72543-02 TP-9 Soil 19-Dec-07 11:45 20-Dec-07 14:47 SA72543-03 TP-11 Soil 19-Dec-07 12:05 20-Dec-07 14:47 SA72543-04 TP-15 Soil 19-Dec-07 12:40 20-Dec-07 14:47 SA72543-05 TP-16 Soil 19-Dec-07 12:50 20-Dec-07 14:47 SA72543-06 TP-17 Soil 19-Dec-07 13:00 20-Dec-07 14:47 SA72543-07 TP-7 Soil 19-Dec-07 11:15 20-Dec-07 14:47 SA72543-08 TP-5 Soil 19-Dec-07 10:30 20-Dec-07 14:47 SA72543-09 TP-14 Soil 19-Dec-07 12:30 20-Dec-07 14:47 I attest that the information contained within the report has been reviewed for accuracy and checked against the quality control requirements for each method. These results relate only to the sample(s) as received. All applicable NELAC requirements have been met. Please note that this report contains 27 pages of analytical data plus Chain of Custody document(s). This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. Massachusetts Certification # M-MA138/MA 110 Authorized by: Connecticut # PH-0777 Florida # E87600/E87936 Maine # MA138 \ Cw , New Hampshire # 2538/2972 New Jersey # MA01ll/MA012 New York # 11393/11840 Hanibal C. Taych, Ph.D. Rhode Island # 98 President/Laboratory Director USDA # S-51435 Vermont # VT-l 1393 Technical Reviewer's Initial: 62 Spectrum Analytical, Inc. is a ATELAC accredited laboratory organisation and meets NELAC testing standards. Use of the NELAC logo however does not insure that Spectrum is currently accreditedfor the specific method or analyte indicated Please refer to our "Quality" web page at www.spectrum-analytical com for afull listing of our current certifications and fields of accreditation. States in which Spectrum Analytical, Inc. holds NELA C certification are New York, New Hampshire, New Jersey and Florida. All analytical workfor Volatile Organic and A ir analysis are transferred to and conducted at our 830 Silver Street location (NH-2972, NY-11840, FL-E87936 and NJ-MA012). Headquaners: II Almagren Drive & 830 Silver Street- Agawam, MA 01001 1-800-789-9115 - 413-789-9018 - FAX 413-789-4076 FL Division: 8180 Woodland Center Boulevard - Tampa, FL 33614 - 1-888-497-5270 - 813-888-9507 -FAX 800-480-6435 Page 1 of 27 www.spectrum-analytical.com CASE NARRATIVE: The samples were received @ 3.8 degrees Celsius, please refer to the Chain of Custody for details specific to temperature upon receipt, An infrared thermometer with a tolerance of +/- 2.0 degrees Celsius was used immediately upon receipt of the samples, MADEP has published a list ofanalytical methods (CAM) which provides a series of recommended protocols for the acquisition, analysis and reporting of analytical data in support of MCP decisions. "Presumptive Certainty" can be established only for those methods published by the MADEP in the MCP CAM. The compounds and/or elements reported were specifically requested by the client on the Chain of Custody and in some cases may not include the fill analyte list as defined in the method. According to WSC-CAM 5/2004 Rev.4, Table I 1 A-1, recovery for some VOC analytes have been deemed potentially difficult. Although they may still be within the recommended 70%-130% recovery range, a range has been set based on historical control limits. See below for any non-conformances and issues relating to quality control samples and/or sample analysis/matrix. SW846 6010B Duplicates: 7121580-DUPI Source: SA72567-02 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for MS/MSD. Chromium Lead SW846 7471A Duplicates: 7121581-DUP I Source: SA 72543-03 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for MS/MSD. Mercury SW846 8082 Samples: SA72543-04 TP-15 Elevated Reporting Limits due to the presence of high levels of non-target analytes. SA72543-05 TP-16 Elevated Reporting Limits due to the presence of high levels of non-target analytes. SA72543-06 TP-17 Elevated Reporting Limits due to the presence of high levels of non-target analytes. This laboratory repon is not valid withoutan authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 2 of 27 Sample Identification Client Project #i Matrix Collection Date/Time Received T- 0 1484 Soil 19-Dec-07 09:30 20-Dec-07 SA72543-01 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Senilvolatile Organic Compounds by GC Polychlorinated Biphenyis by SW840 8082 Prepared by method SW846 3545A 12674-11-2 PC8 1015 BRIL pg/kg dry 33.1 1 SW846 8082 24-Dec-07 24-Dec-07 7121652 FMR 11104-28-2 PCB 1221 BRL pg/kg dry 33.1 1 11141-15-5 PCB 1232 BRL pg/kg dry 33.1 1 53469-21-9 PC8 1242 BRL pg/kg dry 33.1 1 12672-29-6 PCB 1248 BRL pg/kg dry 33.1 1 110979-i PCB 1254 203 pg/kg dry 33.1 1 11096-82-5 PCB 1260 52.8 pg/kg dry 33.1 1 " 37324-23-5 PCB 1262 BRL pg/kg dry 33.1 1 " 11100-14-4 PCB 1268 BRL pg/kg dry 23.1 1 Surogate recoveries: 1038-84-2 4, 4-DB-Octafluorobiphenyl (Sr) 30 30-150% 2051-24-3 Decachtorbiphenyl (Sr) 35 30-10 % Total Metals by EPA 6000/700 Series Methods 7440-47-3 Chromium 510 mg/kg dry 1.15 1 SW846 60108 21-Dec-07 22-Dec-07 7121580 LR General Chemistry Parameters % Solids 86.2 1 SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM This laboratory report is not vaUd without an authorized signature on the cover page. *' Reportable Detection Limit BRL = Below Reporting Limit Page 3 of 27 Saple Identification Client Project # Matrix Collection Date/Time Received TP-9 1484 Soil 19-Dec-07 11:45 20-Dec-07 SA72543-02 CASNo. Analyte(s) ResuIt Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 23 5 mg/kg dry 1.05 1 SW846 60108 21-Dec-07 22-Dec-07 7121580 LR General Chemistry Parameters % Solids 88 .3 I SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM This laboratory reportis not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 4 of 27 Sample Identification Client Project # Matrix Collection Date/fime TP-1 1 Received 1484 Soil 19-Dec-07 12:05 20-Dec-07 SA72543-03 a w CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Semtvolatile Organic Compounds by GC Polychlorinated Biphenyls by SW846 8082 Prepared by method SW846 3545A 12674-11-2 PCB 1016 BRL pg/kg dry 30.2 1 SW846 8082 24-Dec-07 24-Dec-07 7121652 IMR 11104-28-2 PCB 1221 BRL pg/kg dry 30,2 1 11141-16-5 PC8 1232 BRL pg/kg dry 30.2 1 53469-21-9 PCB 1242 BRL pg/kg dry 30.2 1 12872-29- PC8 1248 BRL pg/kg dry 30.2 1 1109749-1 PCB 1254 210 pg/kg dry 30.2 1 " 1109-82-5 PCB 1260 BRL pg/kg dry 30.2 1 37324-23-5 PCB 1262 BRL pg/kg dry 30.2 1 11100-14-4 PCB 1268 BRL pg/kg dry 30.2 1 " Surrogate recoveries: 10386-84-2 4,4-DB-Octafluorobiphenyl (Sr) 50 30-1 50 % 2051-24-3 Decachlombiphenyl (Sr) 55 30-150% Extractable Petroleum Hydrocarbons EPH Aliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons BRL mg/kg dry 30-1 1 -MADEP EPH 5/2004 22-Dec-07 27-Dec-07 7121527 M.8 R C19-C36 Aliphatic Hydrocarbons 307 mg/kgh dry 30.1 1I 011-C22 Aromatic Hydrocarbons 152 mg/kg dry 30.1 1 C11-C22 Aromatic 180 mg/kg dry 30.1 Unadjusted 1 Total Petroleum Hydrocarbons 460 mg/kg dry 30.1 1 Unadjusted Total Petroleum 488 rg/kg dry 30.1 EPH Target PAH Analytes Prepared by method SW846 3545A 91-20-3 Naphthalene 230 pg/kg dry 150 91-57-6 2-Methylnaphthalene BRL pg/kg dry 150 208-9-8 Acenaphthylene 267 pg/kg dry 150 8-32-9 Acenaphthene SRL pg/kg dry 150 86-73-7 Fluorene BRL pg/kg dry 150 85-01-8 Phenanthrene 1,390 pg/kg dry 150 120-12-7 Anthracene 412 pg/kg dry 150 206-44-0 Fluoranthene 3,700 pg/kg dry 150 129-00-0 Pyrene 3,720 pg/kg dry 150 58-55-3 Benzo (a) anthracene 2,040 pg/kg dry 150 21-01-9 Chrysene 2,350 pg/kg dry 150 205-99-2 Senzo (b) fluorantherne 2,690 pg/kg dry 150 207-08-0 Benzo (k) fluoranthene 2,160 pg/kg dry 150 50-32-8 Benzo (a) pyrene 2,920 pg/kg dry 150 193-39-S Indeno (1,2,3-cd) pyrene 2,560 pg/kg dry 150 53-70-3 Dibenzo (a,h) enthracene 353 pg/kg dry 150 191-24-2 Benzo (gh,i) perylene 3,170 pg/kg dry 150 Surrogate recoveries: 3386-33-2 1-Ch/orooctadecane 75 40-140% 84-15-1 Ortho-Terphenyl 68 40-140% 321-1-8 2-Fluorobiphenyl 69 40-140% Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver 4.83 mg/kg dry 1.55 1 SW4846 6010B 21-Dec-7 22-Dec-07 7121580 LR 7440-38-2 Arsenic 3.96 mg/kg dry 1.55 1 7440-39-3 Barium 213 mg/kg dry 1.04 1 7440-43-0 Cadmium 1.64 mg/kg dry 0.518 1 This laboratory report is not valid without an authorized signature on the coverpage. * Reportable Detection Limit BRL = Below Reporting Limit Page 5 of 27 Sample Identification Client Proect# Matrix Collection Date/Time Received TP-1 1484 Soil 19-Dec-07 12:05 20-Dec-07 SA72543-03 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 15.3 mg/kg dry 1.04 1 SW846 6010B 21-Dec-07 22-Dec-07 7121580 LR 7439-97-6 Mercury 0.244 mg/kg dry 0.0312 1 SW846 7471A " 27-Deo-07 7121581 CRM LR 7439-92-1 Lead 328 mg/kg dry 1.55 1 SW848 60108 22-Dec-07 7121580 7782-49-2 Selenium BRL mg/kg dry 1.55 1 General Chemistry Parameters % Solids 91.0 I SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM This laboratory report Is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 6 of 27 Sample Identification Client Project # Matrix Colection Dateffime Received TP-15 1484 Soil 19-Dec-07 12:40 20-Dec-07 B SA72543-04 w CASNo. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Analyst SemIvolatile Organic Compounds by GC Polychlorinated Biphenyls by SW846 8082 R05 Prepared by method SW846 3545A 12674-11-2 PCB 1016 BRL pg/kg dry 147 1 SWS46 6082 24-Dec-07 24-Dec-07 7121652 ]MR 11104-28-2 PCB 1221 BRL pg/kg dry 147 1 11141-16-5 PCB 1232 BRL pg/kg dry 147 1 53469-21-9 PCB 1242 BRL pg/kg dry 147 1 12672-29-8 PCB 1248 BRL pg/kg dry 147 1 11097-69-1 PCB 1254 BRL pg/kg dry 147 1 " 11096-82-5 PCB 1260 BRL pg/kg dry 147 1 37324-23-6 PCB 1262 BRL pg/kg dry 147 1 " 11100-14-4 PCB 1268 BRt. pg/kg dry 147 1 Surrogate recoveries: 10386-84-2 4,4-DB-Octafluorobiphenyl (Sr) 30 30-150% 2051-24-3 Decachlorobiphenyt (SO 50 30-150% Extractable Petroleum Hydrocarbons EPH Allphatic/AromatiC Ranges Prepared by method SW846 3545A C9-018 Aliphatic Hydrocarbons 379 mg/kg dry 44.1 1 -MADEP EPH 512004 22-Dec-07 27-Dec-07 7121527 M.B R 019-C36 Aliphatic Hydrocarbons 6,830 mg /kt.A d ry A44 1 C11-C22 Aromatic Hydrocarbons 1,630 mg/kg dry 44.1 1 Unadjusted C1 1-C22 Aromatic 1,630 mg/kg dry 44.1 1 Total Petroleum Hydrocarbons 8,840 mg/kg dry 44.1 1 44.1 Unadjusted Total Petroleum 8,840 mg/kg dry 1 EPH Target PAH Anatytes Prepared by method SW846 3545A 91-20-3 Naphthalene BRL pg/kg dry 219 91-57-6 2-Methylnephthalene BRL pg/kg dry 219 20&96-8 Acenaphthylene BRL pg/kg dry 219 83-32-9 Acenaphthene BRL pg/kg dry 219 6-73-7 Fluorene BRL pg/kg dry 219 85-01-8 Phenanthrene 429 pg/kg dry 219 120-12-7 Anthracene BRL pg/kg dry 219 206-44-0 Fluoranthene 398 pg/kg dry 219 129-00-0 Pyrene 438 pg/kg dry 219 56-55-3 Benzo (a) anthracene BRL pg/kg dry 219 218-01-9 Chrysene BRL pg/kg dry 219 205-99-2 Benzo (b) fluoranthene BRL pg/kg dry 219 207-0-9 Benzo (k) fluoranthene BRL pg/kg dry 219 60-32-8 Benzo (a) pyrene BRL pg/kg dry 219 193-39-5 Indeno (1,2,3-cd) pyrene BRL pg/kg dry 219 53-70-3 Dibenzo (a,h) anthracene BRL pg/kg dry 219 191-24-2 Benzo (g,h,i) perylene BRL pg/kg dry 219 Surrogate recoveries: 3386-33-2 1-Chlorooctadecane 68 40-140% 84-15-1 Ortho-Terpheny/ 67 40-140% 321-60-8 2-Fluorobiphenyl 70 40-140% Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/kg dry 1.36 1 SW646 6010B 21-Dec-07 22-Dec-07 7121580 LR 7440-38-2 Arsenic 3.95 mg/kg dry 1.36 1 7440-39-3 Barium 37.8 mg/kg dry 0,905 1 7440-43-9 Cadmium BRL mg/kg dry 0.452 1 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 7 of 27 Sample Identification Client Project # Matrix Collection Date/Time Received TP-15 1484 Soil 19-Dec-07 12:40 20-Dec-07 SA72543-04 CAS No. Analyte(s) Result flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods SW846 6010B 21-Dec-07 22-Dec-07 7121580 LR 7440-47-3 Chromium 22.8 mg/kg dry 0.905 1 SW846 7471A 27-Dec-07 7121581 CRM 7439-97-6 Mercury 0.0753 mg/kg dry 0.0309 1 SW846 6010B6 22-Dec-07 7121580 LR 7430-92-1 Lead 5 3.9 mg/kg dry 1.36 1 7782-49-2 Selenium B RL mg/kg dry 1 36 1 General Chemistry Parameters 1 SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM % Solids 2.9 This laboratory reportIs not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 8 of 27 Identification Sample Client Project # Matrix Collection Datefrime Recived TP-16 1484 Soil 19-Dec-07 12:50 20-Dec-07 A SA72543-05 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref. Prepared Analyzed Batch Analyst Semvolatile Organic Compounds by GC Polychlorinated Biphenyts by SW846 8082 Ro5 Prepared by method SW846 3545A 12674-11-2 PCB 1016 BRL pg/kg dry 154 1 SW846 8082 24-Dec-07 24-Dec-07 7121652 IMR 11104-28-2 PCB 1221 BRL pg/kg dry 154 1 11141-16-5 PCB 1232 BRL pg/kg dry 154 1 53469-21-9 PCB 1242 BRL pg/kg dry 154 1 12672-29" PCB 1248 BRL pg/kg dry 154 1 11097-69-1 PCB 1254 BRL pg/kg dry 154 1 11096-82-5 PC8 1260 BRL pg/kg dry 154 1 37324-23-5 PCB 1262 BRL pg/kg dry 154 1 11100-14-4 PC8 1268 BRL pg/kg dry 154 1 Surrogate recovefles: 10386-84-2 4,4-DB-Octafluorobiphenyl (Sr) 50 30-150% " 2051-24-3 Decachlorobiphenyt (Sr) 50 30-150 % Extractable Petroleum Hydrocarbons EPH A1p1hatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons 124 mg/kg dry 30.2 1 -MADEP EPH 5/2004 22-Dec07 27-Dec-07 7121527 M.B R C19-C36 Aliphatic Hydrocarbons 3,020 mg/kg dry 30.2 1 C11-C22 Aromatic Hydrocarbons 1,040 mg/kg dry 30.2 1 Unadjusted C11-C22 Aromatic 1,040 mg/kg dry 30,2 1 Total Petroleum Hydrocarbons 4,180 mg/kg dry 30.2 1 Unadjusted Total Petroleum 4,180 mg/kg dry 30.2 1 EPH Target PAH Analytes Prepared by method SW846 3545A 91-20-3 Naphthalene BRL pg/kg dry 150 1 " 91-57-8 2-Methylnaphthalene BRL pg/kg dry 150 1 208-96-8 Acenaphthylene BRL pg/kg dry 150 1 83-32-9 Acenaphthene BRL pg/kg dry 150 1 86-73-7 Fluorene BRL pg/kg dry 150 I 85.01-8 Phonanthrene BRL pg/kg dry 150 1 120-12-7 Anthracene BRL pg/kg dry 150 1 206-44-0 Fluoranthene BRL pg/kg dry 150 1 "I 129-00-0 Pyrene BRL pg/kg dry 150 1 56,55-3 Benzo (a) anthracene BRL pg/kg dry 150 1 218-01-9 Chrysene BRL pg/kg dry 150 1 205-99-2 Benzo (b) fluoranthene BRL pg/kg dry 150 1 " 207-08-9 Benzo (k) fluoranthene BRL pg/kg dry 150 1 50-32-8 Benzo (a) pyrene BRL pg/kg dry 150 1 193-39-5 Indeno (1,2,3-cd) pyrene BRL pg/kg dry 150 1 53-70-3 Dibenzo (ah) anthracene SRL pg/kg dry 150 1 191-24-2 Benzo (g,h,i) perylene 250 pg/kg dry 150 1 Surrogate ecoveries: 3386-33-2 I-Chlorooctadecane 51 40-140 % 84-1--1 Ortho-Terphenyl 73 40-140%H 321-60- 2-Fluorobiphenyl 80 40-140% Total Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver 7.39 mg/kg dry 1.51 1 SW846 60108 21-Dec-47 22-Dec-07 7121580 LR 7440-38-2 Arsenic 13-0 mg/kg dry 1.51 1 7440-39-3 Barium 42.8 mg/kg dry 1.00 1 7440-43-9 Cadmium 13A mg/kg dry 0.502 1 This laboratory report is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 9 of 27 Sample Identification Client Project # Matrix Collection Date/Time Received TP-16 1484 Soil 19-Dec-07 12:50 20-Dec-07 SA72543-05 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 118 mg/kg dry 1.00 1 SW846 80108 21-Dec-07 22-Dec-07 7121580 LR 7439-97-6 Mercury 0.462 mg/kg dry 0.0330 1 SW846 7471A 27-Dec-07 7121581 CRM 7439-92-1 Lead 254 mg/kg dry 1.51 1 SW846 6010B 22-Dec-07 7121580 LR 7782-49-2 Selenium BRL mg/kg dry 1.51 t General Chemistry Parameters % Solids 90.5 1 SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM This laboratory report Isnot valid without an authorized signature on the cover page. * Reportable Detection Limit BRL - Below Reporting Limit Page 10 of 27 Sample Identification Client Project # Matrix Collection Date/rime Received TP-17 1484 Soil 19-Dec-07 13:00 20-Dec-07 SA72543-06 a CASNo. Analyte(s) Resut Flag Units *RDL Dilation Method Ref: Prepared Analyzed Batch Analyst Sendvolattle Organic Compounds by GC Polychlorinated Biohenyis by SW848 8082 R05 Prepared by method SW846 3545A IMR 12674-11-2 PCB 1018 BRL pg/kg dry 152 SWV846 8082 24-Dec-07 24-Dec-07 7121652 11104-28-2 PCB 1221 BRL pg/kg dry 152 11141-16-5 PCB 1232 BRL pg/kg dry 152 534e9-21-9 PCB 1242 BRL pg/kg dry 152 12672-29-6 PCB 1248 BRL pg/kg dry 152 11097-89-1 PCS 1254 BRL pg/kg dry 152 11096-82-5 PCB 1260 BRL pg/kg dry 152 37324-23-5 PCB 1262 BRL pg/kg dry 152 11100-14-4 PCB 1268 BRL pg/kg dry 152 Surrogate recoveries: 1038684-2 4,4-DB-Octafluorobiphenyl (Sr) 35 30-150% 2051-24-3 Decachlorobiphenyt (Sr) 95 30-150% Extractable Petroleum Hydrocarbons EPH AliphaticlAromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons 151 mg/kg dry 29.4 1 -MADEP EPH 5/2004 22-Dec-07 27-Dec-07 7121527 M.B R C19-C36 Aliphatic Hydrocarbons 2,540 mg/kg dry 29.4 1 CI1 -C22 Aromatic Hydrocarbons 977 mg/kg dry 294 Unadjusted C11 -C22 Aromatic 979 mg/kg dry 29A4 I Total Petroleum Hydrocarbons 3,670 mg/kg dry 29.4 1 Unadjusted Total Petroleum 3,670 mg/kg dry 29.4 EPH Target PAH Analytes Prepared by method SW846 3545A 91-20-3 Naphthalene BRL pg/kg dry 146 91-57-6 2-Methylnaphthalene BRL pg/kg dry 146 208-96-8 Acenaphthylene BRL pg/kg dry 146 83-32-9 Acenaphthene BRL pg/kg dry 146 8673.7 Fluorene BRL pg/kg dry 146 85-01-8 Phenanthrene 214 pg/kg dry 146 120-12-7 Anthracene BRL pglkg dry 146 206-44-0 Fluoranthene 331 pg/kg dry 146 129-00-0 Pyrene 320 pg/kg dry 146 56-55-3 Benzo (a) anthraene 213 pg/kg dry 146 218-01-9 Chrysene 276 pg/kg dry 146 205-99-2 Benzo (b) fluoranthene 252 pg/kg dry 146 207-08-9 Benzo (k) fluoranthene 280 pg/kg dry 146 60-32-8 Benzo (a) pyrene 327 pg/kg dry 146 193-395 Indeno (1,2,3-cd) pyrene 293 pg/kg dry 146 53-70-3 Dibenzo (a,h) anthracene BRL pg/kg dry 146 191-24-2 Senzo (g,hi) perylene 393 pg/kg dry 146 Surrogate recoverfes: 3386-33-2 1-Chlorooctadecane 55 40-140 % 84.151 Ortho-Terphenyl 77 40-140% 321-40-8 2-Fluorobiphenyl 85 40-140% Total Metals by EPA 600017000 Series Methods 7440-22-4 Silver 5.01 mg/kg dry 1.50 1 SW846 6010B 21-Dec-07 22-Dec-07 7121580 LR 7440-38-2 Arsenic 11.9 mg/kg dry 1.50 1 7440-39-3 Barium 35.3 mg/kg dry 0.997 1 7440-43-9 Cadmium 9.82 mg/kg dry 0.498 1 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BIRL = Below Reporting Limit Page I I of 27 Sample Identification Client Project # Matrix Collection Date/Time Received TP-17 1484 Soil 19-Dec-07 13:00 20-Dec-07 SA72543-06 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods 7121580 LR 7440-47- Chromium 10 5 mg/kg dry 0.997 1 SW846 6010B 21-Dec-07 22-Dec-07 27-Dec-07 7121581 CRM 7439-97-6 Mercury 0.321 mg/kg dry 0.0324 1 SW846 7471A " 22-Dec-07 7121580 LR 7439-92-1 Lead 1773 mg/kg dry 1.50 1 SW846 601013 7782-49-2 Selenium B RL mg/kg dry 1.50 1 General Chemistry Parameters SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM % Solids 9 0-.8 I This laboratory report is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 12 of 27 Smple Identification Client Project# Matrix Collection Date/ime Received TP-7 1484 Soil 19-Dec-07 11:15 20-Dec-07 SA72543-07 CASNo. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods SW846 6010B 21-Dec47 22-Dec-07 7121580 LR 7440-47-3 Chromium 844 mg/kg dry 0.996 1 General Chemistry Parameters SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM % Solids 85.7 % 1 This laboratoryreport is not valid without an authorizedsignature on the cover page. of 27 * Reportable Detection Limit BRL - Below Reporting Limit Page 13 Sample Identification Client Project # Matrix Collection TP-5 Date/Time Received 1484 Soil 19-Dec-07 10:30 20-Dec-07 SA72543-08 CASNo. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Metbo ds 7440-47-3 Chromium 1,070 mg/kg dry 1.17 1 SW846 601OB 21-Dec-07 22-Dec-07 7121580 LR General Chemistry Parameters % Solids 76.8 % 1 SM2540 G Mod. 26-Dec-7 26-Dec-07 7121735 DBM This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 14 of 27 Sample Identification Client Project # Matrix Collection DateFime Received TP-14 1484 Soil 19-Dec-07 12:30 20-Dec-07 SA72543-09 . CAS No. Analyte(s) Result flag Units *RDL Dilution Method Ref; Prepared Analyzed Batch Analyst Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 419 mg/kg dry 1.02 1 SW846 60108 21-Dec-07 22-Dec-07 7121580 LR General Chemistry Parameters % Solids 81.8 % 1 SM2540 G Mod. 26-Dec-07 26-Dec-07 7121735 DBM This laboratoryreport Is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL - Below Reporting Limit Page 15 of 27 Semivolatile Organic Compounds by GC - Quality Control Spike Source %REC RPD a Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 7121652 - SW846 3545A Blank 17121652-BLKI) Prepared & Analyzed: 24-Dec-07 PCB 1016 SRL pg/kg wet 28.6 PCB 1221 BRL pg/kg wet 28.6 PCB 1232 BRL pg/kg wet 28.6 PCB 1242 6RLI pg/kg wet 28.6 PCB 1248 BRL pg/kg wet 28.6 PCB 1254 BRL pg/kg wet 28.6 PCB 1260 BRL pg/kg wet 28,6 PCB 1262 BRL pg/kg wet 28.6 PCB 1268 BRL pg/kg wet 28.6 Surrogate: 4,4-DB-Octafuorobiphenyl (Sr) 15.7 pg/kg wet 28.6 55 30-15 Sunogate. Decachlombiphenyl (Sr) 24.3 pg/kg wet 28.6 85 30-150 LCS (7121652-BS1) Prepared & Analyzed: 24-Dec-07 PCB 1016 354 pg/kg wet 28.6 357 99 40-140 PCB 1260 377 pg/kg wet 28.6 357 106 40-140 Surrogate:4,4-DB-Octafluorobipheny/ (Sr) 14.3 pg/kg wet 26.6 50 30-150 Surrogate: Decachlombiphenyl (Sr) 24.3 pg/kg wet 28.6 65 30-150 LCS Dup 17121662-BSDil Prepared & Analyzed: 24-Dec-07 PCB 1016 364 pg/kg wet 28.6 357 102 40-140 3 30 PCB 1260 371 pg/kg wet 28.6 357 104 40-140 2 30 Surrogate: 4,4-DB-Octanfuotobiphenyt (S) 14.3 pg/kg wet 2&.6 50 30-150 Surrogate: Decachlorobipheny (SO 24.3 pg/kg wet 28.6 65 30-150 Duplicate (7121652-DUPI) Source: SA7240841 Prepared & Analyzed: 24-Dec-07 PCB 1016 BRL pg/kg dry 31.6 BRL 40 PC8 1221 BRL pg/kg dry 31.6 BR L 40 PCB 1232 BRL pg/kg dry 31.6 BR L 40 PCB 1242 SRL pg/kg dry 31.6 BRL 40 PCB 1248 BFRL pg/kg dry 31.6 BRL 40 PCB 1254 8RL pg/kg dry 31.6 BRL 40 PCB 1260 BRL pg/kg dry 31.6 BRL 40 PCB 1262 BRL pg/kg dry 31.6 BRL 40 PCB 1268 BRL pg/kg dry 31.6 BRL 40 Surrogate: 4,4-D8-Octafluorobtphenyl (Sr 9 46 pg/kg dry 31.5 30 30-150 Surrogate: Decachlorobiphenyl (Sr) 17.4 pg/kg dry 31.5 55 30-150 Matrix Spike 17121662-MS1I Source: SA72408-41 Prepared & Analyzed: 24-Dec-07 PCB 1016 449 pg/kg dry 32.5 405 BRL 111 40-140 PCB 1260 451 pg/kg dry 32.5 405 BRL 111 40-140 Surrogate: 4,4-DB-Octafluorobiphenyl (SO 17.8 pg/kg dry 324 55 30-150 Surrogate: Decachlorobiphenyl (Sr) 34 1 pg/kg dry 32.4 105 30-150 Matrix Seike Dun 17121852-MSDil Source: SA72408-01 Prepared & Analyzed: 24-Dec-07 PCB 1016 445 pg/kg dry 32.8 409 BRL 109 40-140 2 50 PCB1260 468 pg/kgdry 32.8 409 BRL 114 40-140 3 50 Surrogate: 4,4-DB-Octafluomobipheny (Sr) 19.6 pg/kg dry 32.7 60 30-150 Surrogate: Decachlorobiphenyl (Sr) 36.0 pg/kg dry 32.7 110 30-150 This laboratory report Is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 16 of 27 Extractable Petroleum Hydrocarbons - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 7121527 - SWS46 3545A Blank (7121527-BLK1) Prepared: 22-Dec-07 Analyzed: 26-Dec-07 C9-C18 Aliphatic Hydrocarbons BIRL mg/kg wet 13.4 C19-C36 Aliphatic Hydrocarbons BRL mg/kg wet 13.4 C11-C22 Aromatic Hydrocarbons BRL mg/kg wet 13.4 Unadjusted C11-C22 Aromatic Hydrocarbon BRL mg/kg wet 13.4 Total Petroleum Hydrocarbons BRL mg/kg wet 13.4 Unadjusted Total Petroleum Hydrocarbons BRL mg/kg wet 13.4 Naphthalene BRL pg/kg wet 66.5 2-Methylnaphthalene BRIL pg/kg wet 66.5 Acenaphthylene SIRL pg/kg wet 66.5 Acenaphthene BRL pg/kg wet 66.5 Fluorene BRI. pg/kg wet 66.5 Phenanthrene BRL pg/kg wet 66.5 Anthracene BRL pg/kg wet 66.5 Fluoranthene BRL pg/kg wet 66.5 Pyrene BRL pg/kg wet 66.5 Benzo (a) anthracene BRL pg/kg wet 66.5 Chrysene BIRL pg/kg wet 66.5 Benzo (b) fluoranthene BIRL pg/kg wet 66.5 Benzo (k) fluoranthene BRL pg/kg wet 66.5 Benzo (a) pyrene BRL pg/kg wet 66.5 Indeno (1,2.3-cd) pyrene BRL pg/kg wet 66.5 Dibenzo (a,h) anthracene BRL pg/kg wet 66.5 Benzo (g,h,i) perylene BRL pg/kg wet 66.5 Sunngate: 1-Chlorooctadecane 3020 pg/kg wet 3330 90 40-140 Surrogate: Ortho-Terphenyl 2350 pg/kg wet 3330 71 40-140 Sumgate. 2-Fluorobiphenyl 1580 pg/kg wet 2670 59 40-140 LCS 17121527-BS1) Prepared: 22-Dec-07 Analyzed: 26-Dec-07 C9-C18 Aliphatic Hydrocarbons 21.1 mg/kg wet 13.4 40.0 53 40-140 C19-C36 Aliphatic Hydrocarbons 48.0 mg/kg wet 13.4 53.3 90 40-140 C11-C22 Aromatic Hydrocarbons 90.0 mg/kg wet 13.4 113 79 40-140 Naphthalene 3390 pg/kg wet 66.5 6670 51 40-140 2-Methyinaphthalene 3680 pg/kg wet 66.5 6670 55 40-140 Acenaphthylene 4140 pg/kg wet 66.5 6670 62 40-140 Acenaphthene 4240 pg/kg wet 66.5 6670 64 40-140 Fluorene 4620 pg/kg wet 66.5 6670 69 40-140 Phenanthrene 5180 pg/kg wet 66.5 6670 78 40-140 Anthracene 4960 pg/kg wet 66.5 6670 74 40-140 Fluoranthene 5260 pg/kg wet 66,5 6670 79 40-140 Pyrene 5180 pg/kg wet 66.5 6670 78 40-140 Benzo (a) anthracene 5480 pg/kg wet 66.5 6670 82 40-140 Chrysene 5290 pg/kg wet 66.5 6670 79 40-140 Senzo (b) fluoranthene 6230 pg/kg wet 66.5 6670 93 40-140 Benzo (k) fluoranthene 5760 pg/kg wet 66.5 6670 86 40-140 Benzo (a) pyrene 5280 pg/kg wet 66.5 6670 79 40-140 Indeno (1,2,3-cd) pyrene 5480 pg/kg wet 66.5 6670 82 40-140 Dibenzo (a,h) anthracene 5510 pg/kg wet 66.5 6670 83 40-140 Benzo (g,hi) perylene 5370 pg/kg wet 66.5 6670 81 40-140 Naphthalene (aliphatic fraction) 0.00667 pg/kg wet 6670 0.0001 0-200 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BR L = Below Reporting Limit Page 17 of 27 Extractable Petroleum Hydrocarbons - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 7121527 - SW846 3545A LCS (7121527-BSI Prepared: 22-Dec-07 Analyzed: 26-Dec-07 2-Methyinaphthalene (aliphatic fraction) 0.00667 pg/kg wet 6670 0.0001 0-200 Sunogate: 1-Chlorroctadecane 2930 pg/kg wet 3330 88 40-140 Surrogate: Ortho-Terphenyl 2570 pg/kg wet 3330 77 40-140 Surrogate: 2-Fuorobiphonyl 1720 pg/kg wet 2670 64 40-140 Naphthalene Breakthrough 0 00% (-5 2-Methyinaphthalene Breakthrough 0.00 % 0-5 LCS (7121527-BS2) Prepared: 22-Dec-07 Analyzed: 27-Dec-07 C9-C18 Aliphatic Hydrocarbons 191 mg/kg wet 134 40.0 48 40-140 C19-C36 Aliphatic Hydrocarbons 46.6 mg/kg wet 13.4 53.3 67 40-140 C11-C22 Aromatic Hydrocarbons 57.3 mg/kg wet 13.4 113 51 40-140 Naphthalene 2670 pg/kg wet 66.5 6670 40 40-140 2-Methyinaphthalene 2790 pg/kg wet 66.5 6670 42 40-140 Acenaphthylene 2790 pg/kg wet 66.5 6670 42 40-140 Acenaphthene 2760 pg/kg wet 66.5 6670 41 40-140 Fluorene 2890 pg/kg wet 66.5 6670 43 40-140 Phenanthrene 3100 pg/kg wet 66.5 6670 47 40-140 Anthracene 3010 pg/kg wet 66.5 6670 45 40-140 Fluoranthene 3140 pg/kg wet 66.5 6670 47 40-140 Pyrene 3220 pg/kg wet 66.5 6670 4B 40-140 Benzo (a) anthracene 3600 pg/kg wet 66.5 6670 54 40-140 Chrysene 3140 pg/kg wet 66.5 6670 47 40-140 Benzo (b) fluoranthene 4020 pg/kg wet 66.5 6670 60 40-140 Benzo (k) fluoranthene 3400 pg/kg wet 66.5 6670 51 40-140 Benzo (a) pyrene 3140 pg/kg wet 66.5 6670 47 40-140 Indeno (1,2,3-cd) pyrene 3120 pg/kg wet 66.5 6670 47 40-140 Dibenzo (a,h) anthracene 3070 pg/kg wet 66.5 6670 46 40-140 Benzo (gh,i) perylene 2960 pg/kg wet 66.5 6670 44 40-140 Naphthalene (aliphatic fraction) 0.00 pg/kg wet 6670 0-200 2-Methylnaphthalene (aliphatic fraction) 0.00 pg/kg wet 6670 0-200 Sunogate: 1-Chlorooctadecane 2690 pg/kg wet 3330 61 40-140 Sunogate: Ortho-Terphenyl 1530 pgtkg wet 3330 46 40-140 Surrogate: 2-Fluorobiphenyl 1260 pg/kg wet 2670 47 40-140 Naphthalene Breakthrough 0.00 % 0-5 2-Methylnaphthalene Breakthrough 0.00 % 0-5 LCS Dup (7121 527-BSD) Prepared: 22-Dec-07 Analyzed: 26-Dec-07 C9-C18 Aliphatic Hydrocarbons 18.7 mg/kg wet 13.4 40.0 47 40-140 12 25 C19-C36 Aliphatic Hydrocarbons 46.6 mg/kg wet 13.4 53.3 87 40-140 - 3 25 C1I-C22 Aromatic Hydrocarbons 75.3 mg/kg wet 13.4 113 66 40-140 18 25 Naphthalene 2790 pg/kg wet 66.5 6670 42 40-140 19 30 2-Methylnaphthalene 3080 pg/kg wet 66.5 6670 46 40-140 18 30 Acenaphthylene 3410 pg/kg wet 66.5 6670 51 40-140 19 30 Acenaphthene 3610 pg/kg wet 66.5 6670 54 40-140 16 30 Fluorene 3990 pg/kg wet 66.5 6670 60 40-140 15 30 Phenanthrene 4400 pg/kg wet 66.5 6670 66 40-140 16 30 Anthracene 4180 pg/kg wet 66.5 6670 63 40-140 17 30 Fluoranthene 4380 pg/kg wet 66.5 6670 66 40-140 18 30 Pyrene 4300 pg/kg wet 66.5 6670 65 40-140 19 30 Benzo (a) anthracene 4450 pg/kg wet 66.5 6670 67 40-140 21 30 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page I8 of727 Extractable Petroleum Hydrocarbons - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Sa Batch 7121527 - SW846 3545A LCS Dup (7121527-BSDII Prepared: 22-Dec-07 Analyzed: 26-Dec-07 Chrysene 4240 pg/kg wet 66.5 6670 64 40-140 22 30 Benzo (b) fluoranthene 5910 pg/kg wet 66.5 6670 69 40-140 5 30 Benzo (k) fluoranthene 4450 - pg/kg wet 66.5 6670 67 40-140 26 30 Benzo (a) pyrene 4180 pg/kg wet 66.5 6670 63 40-140 23 30 Indeno (1,2,3-cd) pyrene 4370 pg/kg wet 66.5 6670 66 40-140 23 30 Dibenzo (a,h) anthracene 4320 pg/kg wet 66.5 6670 65 40-140 24 30 Benzo (g,h,i) perylene 4210 pg/kg wet 66.5 6670 63 40-140 24 30 Naphthalene (aliphatic fraction) 0.00667 pg/kg wet 6670 0.0001 0-200 0 200 2-Methyinaphthalene (aliphatic fraction) 0.00667 pg/kg wet 6670 0.0001 0-200 0 200 Surogate: 1-Chloroctadecane 2810 pg/kg wet 3330 84 40-140 Surrogate: Ortho-Terphenyl 2180 pg/kg wet 3330 66 40-140 Surrogate: 2-Fluorobiphenyl 1530 pg/kg wet 2670 58 40-140 Naphthalene Breakthrough 0.00 0-5 2-Methylnaphthalene Breakthrough 0.00 0-5 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Lirnit Page 19 of'27 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 7121580 - SW846 3050B Blank (7121580-BLK1) Prepared: 21-Dec-07 Analyzed: 22-Dec-07 Selenium BRL mg/kg wet 1.28 Lead BRL mg/kg wet 1.28 Arsenic BRL mg/kg wet 1.28 Silver BRL mg/kg wet 1.28 Chromium BRL mg/kg wet 0.857 Cadmium BRL mg/kg wet 0.428 Barium BRL mg/kg wet 0.857 Duolicate (7121 580-DUPiI Source: SA72567-02 Prepared: 21-Dec-07 Analyzed: 23-Dec-07 Selenium 1.35 J mg/kg dry 4.84 BRL 20 Lead 69 3 QR6 mg/kg dry 4.64 72.7 21 20 Chromium 25.0 QR8 mg/kg dry 3.10 19,6 24 20 Cadmium 0.402 J mg/kg dry 1.55 0.436 8 20 Arsenic 5.00 mg/kg dry 4.64 4.21 17 20 Silver BRL mg/kg dry 4.64 BRL 20 Barium 167 mg/kg dry 3.10 141 17 20 Matrix Spike (7121580-MSI Source: SA72567-03 Prepared: 21-Dec-07 Analyzed: 23-Dec-07 Selenium 450 mg/kg dry 5.57 464 1.89 97 75-125 Lead 475 mg/kg dry 5.57 464 39.9 94 75-125 Chromium 466 mg/kg dry 3.71 464 10.3 98 75-125 Arsenic 441 mg/kg dry 5.57 464 3.77 94 75-125 Silver 466 mg/kg dry 5.57 464 BRL 100 75-125 Cadmium 458 mg/kg dry 1.86 464 0.247 99 75-125 Barium 633 mg/kg dry 3.71 464 138 107 75-125 Matrix Spike Dup (7121580-MSDII Source: SA72567-03 Prepared: 21-Dec-07 Analyzed: 23-Dec-07 Lead 432 mg/kg dry 4.97 415 39.9 95 75-125 9 35 Selenium 399 mg/kg dry 4.97 415 1.89 96 75-125 12 35 Arsenic 393 mg/kg dry 4.97 415 3 77 94 75-125 12 35 Silver 416 mg/kg dry 4.97 415 BRIL 100 75-125 11 35 Chromium 438 mg/kg dry 3.32 415 10.3 103 75-125 6 35 Cadmium 418 mg/kg dry 1.66 415 0.247 101 75-125 9 35 Barium 602 mg/kg dry 3.32 415 138 112 75-125 5 35 Post Spike (7121580-PSII Source: SA72567-03 Prepared: 21-Dec-07 Analyzed: 23-Dec-07 Selenium 457 mg/kg dry 5.60 467 1.89 98 80-120 Lead 494 mg/kg dry 5.60 467 39.9 97 80-120 Cadmium 472 mg/kg dry 1.87 467 0.247 101 80-120 Chromium 483 mg/kg dry 3.73 467 10.3 101 80-120 Arsenic 451 mg/kg dry 5.60 467 3,77 96 80-120 Silver 471 mg/kg dry 560 467 BRL 101 80-120 Barium 642 mg/kg dry 373 487 138 108 80-120 Refernce l7121580-SRM1I) Prepared: 21-Dec-07 Analyzed: 22-Dec-07 Lead 56.4 mg/kg wet 1.50 60.1 94 78.4-120.1 Selenium 67.2 mg/kg wet 1.50 69.1 97 77.5-122.5 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 20 of 27 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 7121580 - SW846 3050B Reference (7121580-SRM1I Prepared: 21-Dec-07 Analyzed: 22-Dec-07 Chromium 56.1 mg/kg wet 1.00 60.1 93 80.5-119.2 Silver 48.3 mg/kg wet 1.50 48.5 100 66.3-133.3 Cadmium 45.1 mg/kg wet 0.500 47.7 95 80.1-119.6 Arsenic 72.7 mg/kg wet 1.50 75.6 96 76.8-123.2 Barium 132 mg/kg wet 1,00 136 97 82.1-118 Reference (7121580-SRM2) Prepared: 21-Dec-07 Analyzed: 22-Dec-07 Lead 60.0 mg/kg wet 1.50 60.4 99 78.4-120.1 Selenium 69.8 mg/kg wet 1.50 69.4 101 77.5-122.5 Cadmium 46.4 mg/kg wet 0.500 47.9 97 80.1-119 6 Chromium 59.0 mg/kg wet 1.00 60.4 98 80.5-119.2 Arsenic 7688 mg/kg wet 1.50 76.0 101 76.8-123.2 Silver 50.4 mg/kg wet 1.50 48.7 103 66.3-133.3 Barium 142 mg/kg wet 1.00 137 104 82.1-118 Batch 7121581 - EPA200/SW7000 Series Blank (7121581 -BLKII Prepared: 21-Dec-07 Analyzed: 27-Dec-07 Mercury BRL mg/kg wet 0.0277 Duplicate I7121581-DUP1l Source: SA72543-03 Prepared: 21-Dec-07 Analyzed: 27-Dec-07 Mercury 0.334 CR6 mg/kg dry 0.0292 0.244 31 20 Matrix Spike (7121581-MSi) Source: SA72543-04 Prepared: 21-Dec-07 Analyzed: 27-Dec-07 Mercury 0.497 mg/kg dry 0.0287 0.399 0.0753 106 75-125 Matrix Spike DuD 17121581-MSD1l Source: SA72543-04 Prepared: 21-Dec-07 Analyzed: 27-Dec-07 Mercury 0.532 mg/kg dry 0.0304 0.423 0 0753 108 75-125 7 35 Post Spike (7121581-PS1) Source: SA72543-D4 Prepared: 21-Dec-07 Analyzed: 27-Dec-07 Mercury 0.529 mg/kg dry 0.0289 0.402 00753 113 85-115 Reference 17121581-SRM1 Prepared: 21-Dec-07 Analyzed: 28-Dec-07 Mercury 1.82 mg/kg wet 0.0300 1.45 126 66-132,6 General Chemistry Parameters - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 7121735 - General Preparation Duplicate (7121735-DUP1) Source: SA72464-O1 Prepared & Analyzed: 26-Dec-07 % Solids 81.6 % 08 1 20 This laboratoryreport Is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 21 of 27 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF Limit Batch S701086 Calibration Check (S701086-CCVI) C9-C1O Aliphatic Hydrocarbons L607582E+1' L012017E+OE -23.2 25.00 C19-C36 Aliphatic Hydrocarbons t.824724E+1' I.513773E+O -19.9 25.00 C11-C22 Aromatic Hydrocarbons 20324.62 19.46499 4.1 25.00 Naphthalene 9.257733 8.920133 -3.6 20.00 2-Methylnaphthalene 5.587085 5.313387 -4.9 20.00 Acenaphthylene 8.055222 7.892736 -2.0 20.00 Acenaphthene 5.157653 4.944045 -4.1 20.00 Fluorene 5.410564 5.271509 -2.6 20.00 Phenanthrene 6.425417 6.532506 1.7 20.00 Anthracene 7.179341 6.930381 -3.5 20.00 Fluoranthene 6,40582 6.27694 -2.0 20.00 Pyrene 6.883299 6.676965 -2.7 20.00 Benzo (a) anthracene 5.474587 5.701945 4.2 20.00 Chrysene 7.337876 6.839947 -6.8 2000 Benzo (b) fluoranthene 5.709973 6.036313 5.7 20.00 Benzo (k) fluoranthene 8.845426 8.578665 -3,0 20.00 Benzo (a) pyrene 7.225794 7.087691 -1.9 20.00 Indeno (1,2,3-cd) pyrene 9.59351 9.35757 -2.5 20.00 Dibenzo (a,h) anthracene 7.949525 7.637741 -3.9 20.00 Benzo (g,h,i) perylene 9.051411 8.642681 4.5 20.00 5-alpha-Androstane 1 1 0.0 5-alpha-Androstane 26585.58 1 -100 This laboratoryreport Is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 22 of 27 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF % D Limit Batch S701127 Calibration Check (S701127-CCVI) C9-C18 Aliphatic Hydrocarbons !.115921E+1- 1.256996E+0E -5.7 25.00 C19-C36 Aliphatic Hydocarbons 1.832401E+V I003941E+01 -7.9 25.00 C1 1-C22 Aromatic Hydrocarbons 15280.94 14.04189 -2.9 25.00 Naphthalene 6.217333 6.310177 1.5 20.00 2-Methylnaphthalene 4.043761 4.062853 0.5 20.00 Acenaphthylene 5.943642 6038856 1.6 20.00 Acenaphthene 3.885325 3.950904 1.7 20.00 Fluarene 4.568016 4.669145 2.2 20.00 Phenanthrene 6.211913 6.218293 0.1 20.00 Anthracene 6.118963 6.148077 0.5 20.00 Fluoranthene 6.313196 6.17204 -2.2 20.00 Pyrene 6.493861 6.25964 -3.6 20.00 Benzo (a) anthracene 5.229533 4.723186 -9.7 20.00 Chrysene 5.330208 4.793517 -10.1 20.00 Benzo (b) fluoranthene 5.257497 4 936611 -6.1 20.00 Benzo (k) fluoranthene 4.994278 4.544949 -9.0 20.00 Benzo (a) pyrene 4.778066 4.472109 -6.4 20.00 Indeno (1,2,3-cd) pyrene 5.287587 5.881662 11.2 2000 Dibenzo (a,h) anthracene 4.472638 4.799199 7.3 20.00 Benzo (g,h,i) perylene 4.592007 5.085782 10.3 20.00 5-alpha-Androstane 2289.51 1 -100 5-alpha-Androstane 2289510 1 -100 This laboratory report is not valid wihout an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 23 of 27 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF %D Limit Batch S701127 Calibration Check (S701127-CCV2) C9-C18 Aliphatic Hydrocarbons l115921E+1' 1.367922E+01 4.8 25.00 C19-C36 Aliphatic Hydrocarbons .832401E+1- 1.790393E+01 -23.2 25.00 C1 1-C22 Aromatic Hydrocarbons 15280.94 12.93787 -12.2 25.00 Naphthalene 6.217333 5.649432 -9.1 20.00 2-Methylnaphthalene 4.043761 3.780217 -6.5 20.00 Acenaphthylene 5.943642 5.717738 -3.8 20.00 Acenaphthene 3.885325 3.655032 -5.9 20 00 Fluorene 4.568016 4.313983 -5.6 20.00 Phenanthrene 6.211913 5.858159 -5.7 20.00 Anthracene 6.118963 5.736 -6.3 20.00 Fluoranthene 6.313196 5.893938 -6.6 20.00 Pyrene 6.493861 6061153 -6.7 20.00 Benzo (a) anthracene 5,229533 4.442184 -15.1 20.00 Chrysene 5.330208 4.496176 -15.6 20.00 Benzo (b) fluoranthene 5.257497 4.712097 -10.4 20,00 Benzo (k) fluoranthene 4.994278 4.807752 -3.7 20.00 Benzo (a) pyrene 4.778066 4.097344 -14.2 20.00 Indeno (1,2,3-cd) pyrene 5.287587 5.309944 0.4 20.00 Dibenzo (a,h) anthracene 4.472638 4.380173 -2.1 20.00 Benzo (g,hi) perylene 4.592007 4741494 3.3 20.00 5-alpha-Androstane 2289510 1 -100 5-alpha-Androstane 2289.51 1 -100 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 24 of27 Notes and Definitions QR6 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for MS/MSD. R05 Elevated Reporting Limits due to the presence of high levels of non-target analytes. BRL Below Reporting Limit - Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis NR Not Reported RPD Relative Percent Difference J Detected but below the Reporting Limit; therefore, result is an estimated concentration (CLP J-Flag). A plus sign (+) in the Method Reference column indicates the method is not accredited by NELAC. Laboratory Control Sample (LCS): A known matrix spiked with compound(s) representative of the target analytes, which is used to document laboratory performance. Matrix Duplicate: An intra-laboratory split sample which is used to document the precision of a method in a given sample matrix. Matrix Spike: An aliquot of a sample spiked with a known concentration of target analyte(s). The spiking occurs prior to sample preparation and analysis. A matrix spike is used to document the bias of a method in a given sample matrix. Method Blank: An analyte-free matrix to which all reagents are added in the same volumes or proportions as used in sample processing. The method blank should be carried through the complete sample preparation and analytical procedure. The method blank is used to document contamination resulting from the analytical process. Method Detection Limit (MDL): The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is greater than zero and is determined from analysis of a sample in a given matrix type containing the analyte. Reportable Detection Limit (RDL): The lowest concentration that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. For many analytes the RDL analyte concentration is selected as the lowest non-zero standard in the calibration curve. While the RDL is approximately 5 to 10 times the MDL, the RDL for each sample takes into account the sample volume/weight, extract/digestate volume, cleanup procedures and, if applicable, dry weight correction, Sample RDLs are highly matrix-dependent. Surrogate: An organic compound which is similar to the target analyte(s) in chemical composition and behavior in the analytical process, but which is not normally found in environmental samples. These compounds are spiked into all blanks, standards, and samples prior to analysis. Percent recoveries are calculated for each surrogate. Validated by: Hanibal C. Tayeb, Ph.D. Kim Wisk Rebecca Merz This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL - Below Reporting Limit Page 25 of 27 The following outlines the condition of all EPH samples contained within this report upon laboratory receipt. Matrix so0A Containers Ef Satisfactory 0 Broken 0 Leaking Aqueous Preservative ElIZN/A 0 pK-<2 O pH->2 0 pH adjusted to <2 in lab Comment: Temperature E Received on ice El Received at 4 + 2 *C 0 Other: "C Were all QA/QC procedures followed as required by the EPH method? Yes Were any significant modifications made to the EPH method as specified in Section 11.3? No Were all performance/acceptance standards for required QA/QC procedures achieved? Yes I attest that based upon my inquiry of those individuals immediately responsible for obtaining the information, the material contained in this report is, to the best of my knowledge and belief, accurate and complete. Authorized by: Hanibal C. Tayeh, Ph.D. President/Laboratory Director This laboratory report Is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 26 of 27 MADEP MCP ANALYTICAL METHOD REPORT CERTIFICATION FORM Laboratory Name: Spectrum Analytical, Inc. - Agawam, MA Project #: 1484 Project Location: Ralph Shuster Metals - Attleboro, MA MADEP RTN 1: This form provides certifications for the following data set: SA72543-01 through SA72543-09 Sample matrices: Soil 0 8260B 0 8151A 0 8330 0 6010B E 7470A/lA MCP SW-846 U 8270C I 8081A 0 VPI4 0 6020 0 9014M 2 Methods Used 8 0 8082 0 8021B E EPH l 7000S3 0 7196A I List Release Tracking Number (RTN), if known 2 M - SW-846 Method 9014 or MADEP Physiologically Available Cyanide (PAC) Method 3 S - SW-846 Methods 7000 Series List individual method and analyte An affirmative response to questionsA, B, C and D is requiredfor "Presumptive Certainty" status Were all samples received by the laboratory in a condition consistent with that described on the 9 Yes 0 No Chain of Custody documentation for the data set? Were all QA/QC procedures required for the specified analytical method(s) included in this report B followed, including the requirement to note and discuss in a narrative QC data that did not meet 0 Yes D No appropriate performance standards or guidelines? Does the data included in this report meet all the analytical requirements for "Presumptive Certainty", as described in Section 2.0 (a), (b), (c) and (d) of the MADEP document CAM VII A, C "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of E Yes 0 No Analytical Data"? D VPH and EPH methods only: Was the VPH or EPH method conducted without significant 0 Yes 0 No modifications (see Section 11.3 of respective methods)? Y A response to questions E and F below is requiredfor "Presumptive Certainty" status E Were all analytical QC performance standards and recommendations for the specified methods EYes ONo achieved? F Were results for all analyte-list compounds/elements for the specified method(s) reported? 0 Yes B No All negative responsesare addressedin a case narrativeon the coverpage of this report 1, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. Hanibal C. Taych, Ph.D. President/Laboratory Director Date: 12/28/2007 This laboratory report Is not validwithout an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 27 of27 SIN 1 I -x ci- -Dcc >0 e rr N 1 -- II :;fl~ p Report Date: 0 Final Report 29-Feb-08 16:08 0_4 Re-Issued Report L Revised Report SPECTRUM ANALYTICAL, INC. Feawring HANIBAL TECHNOLOGY Laboratory Report Western Mass Environmental 93 Wayside Avenue Project: Shuster - Attleboro, MA West Springfield, MA 01089 Project 1484 Attn: Kurt Klages Laboratory ID Client Sample ID Matrix Date Sampled Date Received SA74605-01 MW1 Ground Water 14-Feb-08 11:30 15-Feb-08 15:10 SA74605-02 SS1 Soil 14-Feb-08 12:15 15-Feb-08 15:10 SA74605-03 SS2 Soil 14-Feb-08 12:30 15-Feb-08 15:10 SA74605-04 SS3 Soil 14-Feb-08 12:50 15-Feb-08 15:10 SA74605-05 SS4 Soil 14-Feb-08 13:05 15-Feb-08 15:10 SA74605-06 SSS Soil 14-Feb-08 13:15 15-Feb-08 15:10 SA74605-07 SS6 Soil 14-Feb-08 13:25 15-Feb-08 15:10 I attest that the information contained within the report has been reviewed for accuracy and checked against the quality control requirements for each method. These results relate only to the sample(s) as received. All applicable NELAC requirements have been met. Please note that this report contains 23 pages of analytical data plus Chain of Custody document(s). This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. Massachusetts Certification # M-MA138/MAI I10 Authorized by: Connecticut # PH-0777 Florida # E87600/E87936 Maine# MA138 s ACC New Hampshire # 2538 New Jersey # MAO 1/MAO 12 New York# 11393/11840 Hanibal C. Tayeh, Ph.D. Rhode Island # 98 President/Laboratory Director USDA # S-51435 Vermont # VT-11393 Technical Reviewer's Initial: 6(2 Spectrum Analytical, Inc. is a NELAC accreditedlaboratory organization and meets NELAC testing standards. Use ofthe NELAC logo however does not insure that Spectrum is currently accreditedfor the specific method or analyte indicated.Please refer to our "Quality" web page at wwwspectrum-analytical.comfor afull listing of our current certifications andfields of accreditation.States in which Spectrum Analytical, Inc. holds NELA C certification are New York, New Hampshire,New Jersey and Florida.All analytical work for Volatile Organic and Air analysis are transferredto and conducted at our 830 Silver Street location (NY-] 1840, FL-E87936 and NJ-MA012). Headquarters:I1 Alimgren Drive & 830 Silver Street - Agawan, MA 01001 - 1-800-789-9115 -413-789-9018 ' FAX 413-789-4076 FL Division: 8180 Woodland Center Boulevard -Tampa, FL 33614 * 1-888-497-5270 - 813-888-9507 - FAX 800-480-6435 www.spectrumanalytical.com Page 1 of 23 CASE NARRATIVE: The samples were received @ 3.4 degrees Celsius, please refer to the Chain of Custody for details specific to temperature upon receipt. O ninfrared thermometer with a tolerance of +/- 2.0 degrees Celsius was used immediately upon receipt of the samples. MADEP has published a list of analytical methods (CAM) which provides a series of recommended protocols for the acquisition, analysis and reporting of analytical data in support of MCP decisions. "Presumptive Certainty" can be established only for those methods published by the MADEP in the MCP CAM. The compounds and/or elements reported were specifically requested by the client on the Chain of Custody and in some cases may not include the full analyte list as defined in the method. According to WSC-CAM 5/2004 Rev.4, Table 11 A-1, recovery for some VOC analytes have been deemed potentially difficult. 7 0 3 0 Although they may still be within the recommended /o-l % recovery range, a range has been set based on historical control limits. See below for any non-conformances and issues relating to quality control samples and/or sample analysis/matrix. SW846 601DB Laboratory Control Samples: 8021924-BSDI Analyte out of acceptance range in QC spike but no reportable concentration present in sample. Cadmium Duplicates: 80211 30-DUPI Source: SA 74612-03 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for MS/MSD. Chromium This laboratory report is not valdwithout an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 2 of 23 Sample Identification Client Project # Matrix Collection Date/Time S WI Received 1484 Ground Water 14-Feb-08 11:30 15-Feb-08 SA74605-0 1 ,jASNo. Analyte(s)j Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst I tractable Petroleum Hydrocarbons EPH Aliphatic/Aromatic Ranges Prepared by method SW846 3510C C9-C18 Aliphatic Hydrocarbons BRL mg/I 0.2 1 -MADEP EPH 5/2004 19-Feb-08 21-Feb-08 8021099 J.G R C19-C36 Aliphatic Hydrocarbons BRL m / 2" C1 1-C22 Aromatic Hydrocarbons BRL mg/l 0.2 1 Unadjusted C1 1-C22 Aromatic BRL mgi 0.2 Total Petroleum Hydrocarbons BRL mg/I 0.2 Unadjusted Total Petroleum BRL mg/I 0.2 Soluble Metals by EPA 200/6000 Series Methods Filtration Lab Filtered N/A 1 EPA 200.7/3005A 28-Feb-08 28-Feb-08 8021865 JR Soluble Metals by EPA 6000/7000 Series Methods 7440-22-4 Silver BRL mg/ 0.0050 1 SW846 601OB 28-Feb-08 29-Feb-08 8021924 SA 7440-30-2 Arsenic BRL mg/I 0.0040 1 7440-39-3 Barium 0.0432 mg/A 0.0050 7440-43-9 Cadmium BRL mg/I 0.0025 1 7440-47 3 Chromium BRL mg/i 0.0050 1 7439-92-1 Lead BRL mg/I 0.0075 1 7782-49-2 Selenium BRL mg/I 0.0150 t Soluble Metals by EPA 200 Series Methods 7439-97-6 Mercury BRL mg/I 0,00020 1 EPA 245.1/7470A 29-Feb-08 29-Feb-08 8021869 CRM This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 3 of 23 Sample Identification SS1 Client Project # Matrix Collection Date/Time Received 1484 Soil SA74605-02 14-Feb-08 12:15 15-Feb-08 ,fSNo. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst mtractable Petroleum Hydrocarbons EPH Aliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons BRL mgkg dry 30.0 1 -MADEP EPH 5/2004 19-Feb-08 21-Feb-08 8021108 J.G3 R C19-C36 Aliphatic Hydrocarbons BRL mg/kg dry 30.0 1 C1I1-C22 Aromatic Hydrocarbons BRL mg/kg dry 30.0 1 ".'I I Unadjusted C11-C22 Aromatic BRL mg/kg dry 30.0 Total Petroleum Hydrocarbons BRL mg/kg dry 30.0 Unadjusted Total Petroleum BRL mg/kg dry 30.0 Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 1 6.1 mg/kg dry 1.02 1 SW846 60108 19-Feb-08 20-Feb-08 8021130 LR General Chemistry Parameters % Solids 866.7 1 SM2540 G Mod. 25-Feb-08 25-Feb-08 8021592 DBM This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 4 of23 Sample Identification Client Project # Matrix SS2 Collection Date/Time Received 1484 Soil 14-Feb-08 12:30 15-Feb-08 SA74605-03 ASNo. Analyte(s) Result Flag Units *RDL Dilution Method Ref: Prepared Analyzed Batch Analyst Utractable Petroleum Hydrocarbons EPH Aliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons BRL mg/kg dry 34.5 1 -MADEP EPH 5/2004 19-Feb-08 21-Feb-08 8021108 J.3 R C19-C36 Aliphatic Hydrocarbons BFRL mg/kg dry 34.5 1 C11-C22 Aromatic Hydrocarbons BFRL mg/kg dry 34.5 Unadjusted C11-C22 Aromatic BFRL mg/kg dry 34.5 Total Petroleum Hydrocarbons BERL mg/kg dry 34.5 Unadjusted Total Petroleum BERL mg/kg dry 34 5 Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 13 .2 mg/kg dry 1.20 1 SW846 6010B 19-Feb-08 20-Feb-08 8021130 LR General Chemistry Parameters % Solids 76,3 1 SM2540 G Mod. 25-Feb-08 25-Feb-08 8021592 DBM This laboratory repqrt is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page $ of 23 Sample Identification Client Project # Matrix Collection Date/Time Received SS3 1484 Soil 14-Feb-08 12:50 15-Feb-08 SA74605-04 AS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref: Prepared Analyzed Batch Analyst Stractable Petroleum Hydrocarbons EPH AliphaticlAromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons BRL mg/kg dry 32.9 1 -MADEP EPH 5/2004 19-Feb-08 21-Feb-08 8021108 J.G R C19-C36 Aliphatic Hydrocarbons BRL mg/kg dry 32.9 1 "." "9 C1I-C22 Aromatic Hydrocarbons BRL mg/kg dry 32.9 1 "9 9 '" " Unadjusted C11 -C22 Aromatic SRL mg/kg dry 32.9 1 "* ",9 9 . Total Petroleum Hydrocarbons BRL mg/kg dry 32.9 1 "" ", ". " Unadjusted Total Petroleum BRL mg/kg dry 32.9 1 " "9 " ". " Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 15.6 mg/kg dry 1.18 1 SW846 601OB 19-Feb-08 20-Feb-08 8021130 LR General Chemistry Parameters % Solids 78.1 1 SM2540 G Mod. 25-Feb-08 25-Feb-08 8021592 DBM This laboratory report Is not valid withoutan authorized signature on the cover page. * ReportabI7 Detection Limit BRL = Below Reporting Limit Page 6 of 23 Sample Identification SS4 Client Project # Matrix Collection Date/Time Received 1484 Soil 14-Feb-08 13:05 SA74605-05 15-Feb-08 'SNo, Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst tractable Petroleum Hydrocarbons EPH AliphatidAromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons BRL mg/kg dry 32.0 1 -MADEP EPH 5/2004 19-Feb-08 21-Feb-08 8021108 J.G R C19-C36 Aliphatic Hydrocarbons BR L mg/kg dry 32.0 1 C11-C22 Aromatic Hydrocarbons BR L mg/kg dry 32.0 1 Unadjusted C 1-C22 Aromatic BR L mg/kg dry 32 0 1 Total Petroleum Hydrocarbons BR L mg/kg dry 32 0 t Unadjusted Total Petroleum BR L mg/kg dry 32.0 1 Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 17.8 mg/kg dry 1.16 SW846 6010B 19-Feb-08 20-Feb-08 8021130 LR General Chemistry Parameters % Solids 79 .4 SM2540 G Mod. 25-Feb-08 25-Feb-08 8021592 DBM This laboTory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 7 of 23 Sample Identification Client Project # Matrix Collection Date/Time Received SS5 1484 Soil 14-Feb-08 13:15 15-Feb-08 SA74605-06 SNo. Analyte(s) Result Flag Units *RDL Dilution Method Ref: Prepared Analyzed Batch Analyst tractable Petroleum Hydrocarbons EPH Aliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons BRL mg/kg dry 37.3 1 -MADEP EPH 512004 19-Feb-08 21-Feb-08 8021108 J.G R C19-C36 Aliphatic Hydrocarbons BRL mg/kg dry 37.3 1 " " "." C1I-C22 Aromatic Hydrocarbons BRL mg/kg dry 37.3 1 ".4" " Unadjusted C11-C22 Aromatic BRL mg/kg dry 37.3 1 "" ", ", " Total Petroleum Hydrocarbons BRL mg/kg dry 37.3 1 " "", " Unadjusted Total Petroleum BRL mg/kg dry 37,3 1 *," " Total Metals by EPA 6000/7008 Series Methods 7440-47-3 Chromium 17.8 mg/kg dry 1.36 1 SWB46 6010B 19-Feb-08 20-Feb-08 8021130 LR General Chemistry Parameters % Solids 70.2 I SM2540 G Mod. 25-Feb-08 25-Feb-08 8021592 DBM This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 8 of 23 Sample Identification SS6 Client Project # Matrix Collection Date/Time Received 1484 Soil 14-Feb-08 SA74605-07 13:25 15-Feb-08 , SNo. Analyle(s) Resmult Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst tractable Petroleum Hydrocarbons EPH Aliphatic/Aromatic Ranges Prepared by method SW846 3545A C9-C18 Aliphatic Hydrocarbons 149 mg/kg dry 28.6 1 -MADEP EPH 5/2004 19-Feb-08 21-Feb-08 8021108 J.G R C19-C36 Aliphatic Hydrocarbons 1,540 mg/kg dry 28.6 1 I C11-C22 Aromatic Hydrocarbons 6440 mg/kg dry 28.6 Unadjusted C 1-C22 Aromatic 6440 mg/kg dry 28.6 1 " " ", " Total Petroleum Hydrocarbons 2,330 mg/kg dry 28.6 Unadjusted Total Petroleum 2, 330 mg/kg dry 28.6 1 "*9.. Total Metals by EPA 6000/7000 Series Methods 7440-47-3 Chromium 11.9 mg/kg dry 0.974 1 SW846 6010B 19-Feb-08 20-Feb-08 8021130 LR General Chemistry Parameters % Solids 92.5 1 SM2540 G Mod. 25-Feb-08 25-Feb-08 8021592 DBM This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL - Below Reporting Limit Page 9 of 23 Extractable Petroleum Hydrocarbons - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit *atch 8021099 - SW846 3510C Blank (8021099-BLKIt Prepared & Analyzed: 19-Feb-06 C9-C18 Aliphatic Hydrocarbons BRL mgnI 0.2 CI9-C36 Aliphatic Hydrocarbons BRL mgn 0.2 C11-C22 Aromatic Hydrocarbons BRL mgn 0..2 Unadjusted C11-C22 Aromatic Hydrocarbon BRL mgA 012 Total Petroleum Hydrocarbons BRL mg/1 0.2 Unadjusted Total Petroleum Hydrocarbons BRL mg/ 0 2 LCS (8021099-BS1) Prepared & Analyzed: 19-Feb-08 C9-C18 Aliphatic Hydrocarbons 0.314 mgn 0.2 0.600 52 40-140 C19-036 Aliphatic Hydrocarbons 0.559 mg/I 0.2 0.800 70 40-140 C11-C22 Aromatic Hydrocarbons 1.19 mg/I (.2 1,70 70 40-140 LCS (8021099-BS2I Prepared: 19-Feb-08 Analyzed: 20-Feb-08 C9-C18 Aliphatic Hydrocarbons 0.395 mg/I 0.2 0.600 66 40-140 C19-C36 Aliphatic Hydrocarbons 0.640 mg/I 0.2 0.800 80 40-140 C11-C22 Aromatic Hydrocarbons 1.50 mg/I 0.2 1.70 88 40-140 LCS Duo (8021099-BSDi Prepared 19-Feb-08 Analyzed: 20-Feb-08 C9-C18 Aliphatic Hydrocarbons 0.329 mg/I 02 0.600 55 40-140 5 25 C19-C36 Aliphatic Hydrocarbons 0.574 mg/i 0.2 0.800 72 40-140 3 25 * 11-C22 Aromatic Hydrocarbons 1.32 mg/i 02 1.70 78 40-140 10 25 atch 8021108 -SW846 3545A Blank (8021108-BLKII Prepared: 19-Feb-0a Analyzed: 21-Feb-08 C9-C18 Aliphatic Hydrocarbons BRL mg/kg wet 13.4 C 19-C36 Aliphatic Hydrocarbons BRL mg/kg wet 13.4 C11-C22 Aromatic Hydrocarbons BRL mg/kg wet 13.4 Unadjusted C11-C22 Aromatic Hydrocarbon BRL mg/kg wet 13.4 Total Petroleum Hydrocarbons BRL mg/kg wet 13.4 Unadjusted Total Petroleum Hydrocarbons BRL mg/kg wet 13.4 LCS (8021108-BS1) Prepared: 19-Feb-08 Analyzed: 21-Feb-08 C9-C18 Aliphatic Hydrocarbons 20.7 mg/kg wet 13.4 40.0 52 40-140 C19-C36 Aliphatic Hydrocarbons 407 mg/kg wet 13.4 53.3 76 40-140 C11-C22 Aromatic Hydrocarbons 85.3 mg/kg wet 13.4 113 75 40-140 LCS (8021108-BS2) Prepared: 19-Feb-08 Analyzed: 20-Feb-08 C9-018 Aliphatic Hydrocarbons 23.1 mg/kg wet 13.4 40.0 58 40-140 C19-C36 Aliphatic Hydrocarbons 38.9 mg/kg wet 13.4 53.3 73 40-140 C11-C22 Aromatic Hydrocarbons 98.7 mg/kg wet 13.4 113 87 40-140 LCS Dup (8021108-BSDI) Prepared: 19-Feb-08 Analyzed: 21-Feb-08 C9-C18 Aliphatic Hydrocarbons 22.7 mg/kg wet 13.4 40.0 57 40-140 9 25 019-C36 Aliphatic Hydrocarbons 40.8 mg/kg wet 13.4 53.3 77 40-140 0.2 25 11-C22 Aromatic Hydrocarbons 93.3 mg/kg wet 13.4 113 62 40-140 9 25 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 10 of 23 Total Metals by EPA 6000/l000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit * blf8021130 - SW846 3050B Blank (8021130-BLK1) Prepared: 19-Feb-08 Analyzed: 20-Feb-08 Chromium BRL mg/kg wet 0.980 Duplicate (8021130-DUPI) Source: SA74612-03 Prepared: 19-Feb-08 Analyzed: 20-Feb-08 Chromium 9.33 QR6 mg/kg dry 1.05 3.13 100 20 Matrix Spike (8021130-MS1) Source: SA74612-01 Prepared 19-Feb-08 Analyzed: 20-Feb-08 Chromium 117 mg/kg dry 0.915 114 4,70 98 75-125 Matrix Spike Dup (8021130-MSDII Source: SA74612-01 Prepared: 19-Feb-08 Analyzed: 20-Feb-08 Chromium 114 mg/kg dry 0.916 114 4.70 96 75-125 2 35 Post Spike (8021130-PSI) Source: SA74612-01 Prepared 19-Feb-08 Analyzed: 20-Feb-08 Chromium 116 mg/kg dry 0.912 114 4.70 97 80-120 Reference (8021130-SRM1) Prepared: 19-Feb-08 Analyzed: 20-Feb-08 Chromium 46.2 mg/kg wet 1.00 50.0 92 78.9-120.5 Reference (8021130-SRM2) Prepared: 19-Feb-08 Analyzed: 20-Feb-08 Chromium 44.9 mg/kg wet 1.00 50.1 90 78.9-120.5 0 This laboratory report is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 11 of 23 Soluble Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit * atch 8021924 - SW846 3005A Blank (8021924-BLKI) Prepared & Analyzed: 29-Feb-08 Selenium BRL mg/I 0.0150 Lead BRL mg/I 0.0075 Chromium BRL mg/ 0.0050 Barium BRL mg/ 0.0050 Arsenic BRL mg/ 0.0040 Silver BRL mg/I 0.0050 Cadmium BRL mg/I 0.0025 LCS (8021924-BS1) Prepared & Analyzed: 29-Feb-08 Selenium 1.39 mg/ 0.0150 1.25 111 85-115 Lead 1.32 mgA/ 0.0075 1.25 106 85-115 Chromium 1.40 mg/l 0.0050 1.25 112 85-115 Silver 1.30 mgA 0.0050 1.25 104 85-115 Arsenic 1.33 mgA 0.0040 1.25 106 85-115 Banum 1.42 mg/I 0.0050 1.25 113 85-115 Cadmium 1.43 mg/I 0.0025 1.25 114 85-115 LCS Dup (8021924-BSD1) Prepared & Analyzed: 29-Feb-08 Selenium 1.42 mg/i 0.0150 1.25 114 85-115 2 20 Lead 1.37 mg/I 0.0075 1.25 110 85-115 4 20 e arium 1.39 mg/I 0.0050 1.25 111 85-115 2 20 hromium 1.44 mg/i 0.0050 1.25 115 85-115 3 20 Cadmium 1.47 QC2 mg/i 0.0025 1.25 117 85-115 3 20 Silver 1.34 mg/I 0.0050 1.25 108 85-115 3 20 Arsenic 1.37 mg/I 0.0040 1.25 110 85-115 3 20 Duplicate (8021924-DUPI) Source: SA74749-01 Prepared & Analyzed: 29-Feb-08 Lead BRL mg/i 0 0075 BRL 20 Selenium BRL mgi 0.0150 BRL 20 Barium 0.139 mgA/ 0.0050 0.134 4 20 Chromium BRL mg/i 0.0050 BRL 20 Cadmium BRL mg/i 0.0025 BRL 20 Silver BRL mg/1 0"0050 BRL 20 Arsenic BRL mg/i 0.0040 BRL 20 Matrix Spike (8021924-MS I Source: SA74749-03 Prepared & Analyzed: 29-Feb-08 Selenium 1.07 mg/i 0,0150 1.25 BRL 86 75-125 Lead 0.958 mg/i 0.0075 1.25 BRL 77 75-125 Barium 1.07 mg/i 0.0050 1,25 0.0977 78 75-125 Cadmium 1.05 mg/I 0.0025 1.25 0.0034 83 75-125 Chromium 1.03 mg/ 0.0050 1.25 0.0088 82 75-125 Silver 0.990 mg/i 0.0050 1.25 BRL 79 75-125 Arsenic 1.02 mg/i 0.0040 1.25 0.0038 81 75-125 Matrix Spike DUp (8D21924MSD1 Source: SA74749-03 C pared & Analyzed: 29-Feb-08 ad 0.940 mg/i 0.0075 1.25 BRL 75 75-125 2 20 Selenium 1.03 mg/i 0.0150 1.25 BRL 82 75-125 4 20 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 12 of23 Soluble Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit *atch 8021924 - SW846 3005A Matrix Spike DuD (8021924-MSDII Source: SA74749-03 Prepared & Analyzed: 29-Feb-08 Arsenic 0.982 mgni 0.0040 1.25 0.0038 78 75-125 3 20 Barium 1.06 mg/l 0.0050 1.25 0.0977 77 75-125 0.9 20 Cadmium 1.02 mgi 0.0025 1.25 0.0034 82 75-125 2 20 Chromium 0.980 mg/i 0.0050 1.25 0.0088 78 75-125 5 20 Silver 0.942 mg/I 0.0050 1.25 BRL 75 75-125 5 20 Post Spike (8021924-PSI) Source: SA74749-03 Prepared & Analyzed: 29-Feb-08 Lead 1.10 mg/i 0.0150 1.25 BRL 88 80-120 Selenium 117 mg/l 0.0300 1.25 BRL 94 80-120 Silver 110 mg/i 0.0100 1.25 BRL 88 80-120 Chromium 1.16 mg/I 0.0100 1.25 0.0088 92 80-120 Cadmium 1.19 mgn 0.0050 1.25 0.0034 95 80-120 Barium 1.20 mgn 0.0100 1.25 0.0977 88 80-120 Arsenic 1.11 mg/i 0.0080 1.25 0.0038 89 80-120 Soluble Metals by EPA 200 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 8021869 - EPA200/SW7000 Series Blank 8021869-BLK1 29-Feb-08 0epared & Analyzed: Mercury BRL mgn 0.00020 LCS (8021889-BS1) Prepared & Analyzed: 29-Feb-08 Mercury 0.00427 mgn 0.00020 0.00500 85 85-115 Duplicate (8021869-DUP1) Source: SA7460541 Prepared & Analyzed: 29-Feb-08 Mercury BRL mg/I 0.00020 BRL 20 Matrix Spike 18021869-MS1) Source: SA74605-01 Prepared & Analyzed: 29-Feb-08 Mercury 0.00422 mg/i 0.00020 0.00500 BRL 84 75-125 Matrix Spike Dup (8021869-MSD1I Source: SA74605-01 Prepared & Analyzed: 29-Feb-08 Mercury 0.00447 mgn 0.00020 0.00500 BRL 89 75-125 6 20 Post Spike (8021869-PS1) Source: SA74605-01 Prepared & Analyzed: 29-Feb-08 Mercury 0.00427 mg/I 0.00020 0.00500 BRL 85 85-115 General Chemistry Parameters - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 8021592 - General Preparation &11fcat80215 2-D)UPI Source: SA74587-09 wrrepared & Analyzed: 25-Feb-08 % Solids 91.4 92.1 0.7 20 91.4 92.1 0.7 20 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 13 of 23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF %D Limit . Batch S802151 Calibration Check (S802151-CCV1) C9-C18 Aliphatic Hydrocarbons 1.047298E+1' !.488122E+O 11.2 25.00 C1 9-C36 Aliphatic Hydrocarbons !.349734E+1 - 1.740031E+O0 -1.5 25.00 C11-C22 Aromatic Hydrocarbons 14868.08 14.00216 1.7 25,00 5-alpha-Androstane 1 1 0.0 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL - Below Reporting Limit Page 14 of 23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF % D Limit Batch S802151 Calibration Check (S802151-CCV2) CS-C18 Aliphatic Hydrocarbons 5.047298E+1- 2.23425E+08 -1.2 25.00 C1 9-C36 Aliphatic Hydrocarbons !.349734E+1I 1.578316E+01 -11.1 25.00 C1 l-C22 Aromatic Hydrocarbons 14868.08 13.70221 -1.2 25.00 5-alpha-Androstane 1 1 0.0 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 15 of23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF %D Limit Batch S802151 Calibration Check (S802151-CCV3) C9-C18 Aliphatic Hydrocarbons .047298E+1' L219918E+0( -2.0 25.00 C19-C36 Aliphatic Hydrocarbons ?.349734E+1' 1.658819E+0f -6.4 25.00 C1-C22 Aromatic Hydrocarbons 14868.08 13.85705 0.6 25.00 5-alpha-Androstane 1 1 0.0 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 16 of23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF % D Limit CCalibration atch S802220 Check (S802220-CCVI) C9-C18 Aliphatic Hydrocarbons L047298E+' 2.22057E+08 -1.8 25.00 C19-C36 Aliphatic Hydrocarbons L349734E+1' 1543178E+0I -132 25.00 C 1-C22 Aromatic Hydrocarbons 14868.08 14.01656 1.7 25.00 5-alpha-Androstane 1 1 0.0 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 17 of 23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF %D Limit .8 atch S802220 Calibration Check (S802220-CCV2) C9-C18 Aliphatic Hydrocarbons .047298E+' !.192798E+0E -3.2 25.00 C19-C36 Aliphatic Hydrocarbons 2.349734E+I 1.580634E+0E -10.9 25.00 C11-C22 Aromatic Hydrocarbons 14868.08 13.04874 -6.4 25.00 5-alpha-Androstane 0.0 This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 18 of 23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF %D Limit . CalibrationBatch S802248 Check (S802248-CCVI) C9-C18 Aliphatic Hydrocarbons k047298E+1' 2,15652E+08 -5.0 25.00 C19-C36 Aliphatic Hydrocarbons !.349734E+1- 1.721307E+O -2.6 25,00 C1 1-C22 Aromatic Hydrocarbons 14868.08 13.75134 -0.6 25.00 5-alpha-Androstane 1 1 0.0 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 19 of 23 Extractable Petroleum Hydrocarbons - CCV Evaluation Report Average Analyte RF CCRF % D Limit Batch S802248 Calibration Check (S802248-CCV2) 09-C 18 Aliphatic Hydrocarbons L.47298E+1 2.50143E+08 11.8 25.00 C19-C36 Aliphatic Hydrocarbons ?.349734E+1- 1.571939E+04 -11.4 2500 C11-C22 Aromatic Hydrocarbons 14866.08 13.66601 -1.2 25.00 5-alpha-Androstane 1 0.0 This laboratory report is not valid without an authorized signatureon the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 20 of 23 Notes and Definitions QC2 Analyte out of acceptance range in QC spike but no reportable concentration present in sample. QR6 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for MS/MSD. I BRL Below Reporting Limit - Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis NR Not Reported RPD Relative Percent Difference A plus sign (+) in the Method Reference column indicates the method is not accredited by NELAC. Laboratory Control Sample (LCS): A known matrix spiked with compound(s) representative of the target analytes, which is used to document laboratory performance. Matrix Duplicate: An intra-laboratory split sample which is used to document the precision of a method in a given sample matrix. Matrix Spike: An aliquot of a sample spiked with a known concentration of target analyte(s). The spiking occurs prior to sample preparation and analysis. A matrix spike is used to document the bias of a method in a given sample matrix. Method Blank: An analyte-free matrix to which all reagents are added in the same volumes or proportions as used in sample processing. The method blank should be carried through the complete sample preparation and analytical procedure. The method blank is used to document contamination resulting from the analytical process. Method Detection Limit (MDL: The minimum concentration of a substance that can be measured and reported with 99/a confidence that the analyte concentration is greater than zero and is determined from analysis of a sample in a given matrix type containing the analyte. S eortable Detection Limit (RDL): The lowest concentration that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. For many analytes the RDL analyte concentration is selected as the lowest non-zero standard in the calibration curve. While the RDL is approximately 5 to 10 times the MDL, the RDL for each sample takes into account the sample volume/weight, extract/digestate volume, cleanup procedures and, if applicable, dry weight correction. Sample RDLs are highly matrix-dependent, Surrogate: An organic compound which is similar to the target analyte(s) in chemical composition and behavior in the analytical process, but which is not normally found in environmental samples. These compounds are spiked into all blanks, standards, and samples prior to analysis. Percent recoveries are calculated for each surrogate. Validated by: Hanibal C. Tayeh, Ph.D. Nicole Brown This laboratoryreport is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 21 of23 The following outlines the condition of all EPH samples contained within this report upon laboratory receipt. Matrix Ground Water Soil IContaiiners I P Satiqfsacnyv 0 Broken 0 Leaking Al~I- Aqueous Preservative 0 N/A 2 pH<2 0 pH>2 0 pH adjusted to <2 in lab Comment: Temperature E!f Received on ice El Received at 4 ±2 "C 0 Other: "C Were all QA/QC procedures followed as required by the EPH method? Yes Were any significant modifications made to the EPH method as specified in Section 11.3? No Were all performance/acceptance standards for required QA/QC procedures achieved? Yes I attest that based upon my inquiry of those individuals immediately responsible for obtaining the information, the material contained in this report is, to the best of my knowledge and belief, accurate and complete. Authorized by: Hanibal C. Tayeh, Ph.D. President/Laboratory Director This laboratoryreport is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL - Below Reporting Limit Page 22 of23 MADEP MCP ANALYTICAL METHOD REPORT CERTIFICATION FORM Laboratory Name: Spectrum Analytical, Inc. - Agawam, MA Project #: 1484 MADEP RTN 1: MA AN Project Location: Shuster - Attleboro, This form provides certifications for the fol[owing data set: SA74605-01 through SA74605-07 Sample matrices: Ground water sod 0 8260B 0 8151A 0 8330 10 6010B 0 7470A/1A MCP SW-846 8270C 1 D 8081A D VPH O 6020 D 9014M 2 Methods Used 0 8082 [ 8021B El EPH 0 7000S3 0 7196A I List Release Tracking Number (RTN), if known 2 M - SW-846 Method 9014 or MADEP Physiologically Available Cyanide (PAC) Method 3 S - SW-846 Methods 7000 Series List individual method and analyte An affirmative response to questions A, B, C and D is required for "Presumptive Certainty status A Were all samples received by the laboratory in a condition consistent with that described on the 0 Yes 0 No Chain of Custody documentation for the data set? Were all QA/QC procedures required for the specified analytical method(s) included in this report B followed, including the requirement to note and discuss in a narrative QC data that did not meet E1 Yes 0 No appropriate performance standards or guidelines? Does the data included in this report meet all the analytical requirements for "Presumptive Certainty", as described in Section 2.0 (a), (b), (c) and (d) of the MADEP document CAM Vii A, 0 No C "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of 0 Yes Analytical Data"? D VPH and EPH methods only: Was the VPH or EPH method conducted without significant 0 Yes 0 No modifications (see Section 11.3 of respective methods)? A response to questions E and F below is requiredfor "Presumptive Certainty" status E Were all analytical QC performance standards and recommendations for the specified methods 0 Yes 3 No achieved? F Were results for all analyte-list compounds/elements for the specified method(s) reported? 0 Yes 21 No All negative responses are addressed in a case narrative on the cover page of this report. I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. Hanibal C. Tayeh, Ph.D. President/Laboratory Director Date: 2/29/2008 This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 23 of 23 I '1 C-.x -- - C> - - IV P J~2~K I -t i - I n 0 ij~ Ir. K.IF 21 I'Prcewrvaiti o -- , - S C oAmherI G i c0 - ut' hat' i L x nr C7-. Lr - 61-S n- -T - 0 I Ncn rn K cz Report Date: 0 Final Report 28-Mar-08 16:46 Re-Issued Report Revised Report SPECTRUM ANALYTICAL, INC. Featuring HANIBAL TECHNOLOGY Laboratory Report Western Mass Environmental 93 Wayside Avenue Project: Ralph Shuster Metals - Attleboro, MA West Springfield, MA 01089 Project 1484 Attn: Kurt Klages Laboratory ID Client Sample ID Matrix Date Sampled Date Received SA76245-01 SV )7 Soil 25-Mar-08 15:20 26-Mar-08 13:00 SA76245-02 SS7- f Soil 25-Mar-08 15:30 26-Mar-08 13:00 SA76245-03 Swer Vf 1 1 ' Soil 25-Mar-08 15:45 26-Mar-08 13:00 I attest that the information contained within the report has been reviewed for accuracy and checked against the quality control requirements for each method. These results relate only to the sample(s) as received. Alt applicable NELAC requirements have been met. Please note that this report contains 6 pages of analytical data plus Chain of Custody document(s). This report may not be reproduced, except in full, without written approval from Spectrum Analytical, Inc. Massachusetts Certification # M-MA138/MAI 110 Authorized by: Connecticut # PH-0777 Florida # E87600/E87936 Maine #tMAI38 ACC New Hampshire # 2538 New Jersey # MAOI 1/MA012 New York # 11393/11840 < Hanibal C. Tayeh, Ph.D. Rhode Island # 98 President/Laboratory Director USDA # S-51435 Vermont # VT-1 1393 Technical Reviewer's Initial: .2 Spectrum Analytical, Inc. is a NELAC accredited laboratoryorganization and meets NEL4C testing standards. Use ofthe NELAC logo however does not insure that Spectrum is currenty accreditedforthe specifc method or analyte indicated Please refer to our "Quality" web page at www.spectrum-analyuical.comforafull listing of our current certificationsand fields of accreditation.States in which Spectrum Analytical, Inc. holds NELA C certificationare New York, New Hampshire, New Jersey and Florida.All analytical workfor Volatile Organic and A ir analysis are transferredto and conductedat our 830 Silver Street location (NY- 11840, FL-E87936 and NJ-MA012). Headquariers: II Almgren Drive & 830 Silver Street - Agawam, MA 01001 - 1-800-789-9115 - 413-789-9018 - FAX 413-789-4076 FL Division: 8180 Woodland Center Boulevard - Tampa, FL 33614 - 1-888-497-5270 - 813-888-9507 - FAX 800-480-6435 www.spectrum-analytical.com Page I of6 CASE NARRATIVE: The samples were received 2.5 degrees Celsius, please refer to the Chain of Custody for details specific to temperature upon receipt. An infrared thermometer with a tolerance of +/- 2.0 degrees Celsius was used immediately upon receipt of the samples. MADEP has published a list of analytical methods (CAM) which provides a series of recommended protocols for the acquisition, analysis and reporting of analytical data in support of MCP decisions. "Presumptive Certainty" can be established only for those methods published by the MADEP in the MCP CAM. The compounds and/or elements reported were specifically requested by the client on the Chain of Custody and in some cases may not include the full analyte list as defined in the method, According to WSC-CAM 5/2004 Rev4, Table 1 A-1, recovery for some VOC analytes have been deemed potentially difficult. See below for any non-conformances and issues relating to quality control samples and/or sample analysis/matrix. SW846 6010B Spikes: 8031837-MSDI Source: SA76245-O1 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for batch duplicate. Chromium This laboratoryreport is not valid without an authorizedsignature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 2 of 6 Sample Identification Client Project # Matrix Collection Date/fime Received 1484 Soil 25-Mar-08 15:20 26-Mar-08 SA76245-01 0 CAS Na. An alyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 600017000 Series Methods 7440-47-3 Chromium 9.46 mg/kg dry 0.967 1 SW846 6010B 26-Mar-08 27-Mar-08 8031837 LR General Chemistry Parameters % Solids 90.1 1 SM2540 G Mod. 26-Mar-08 26-Mar-08 8031835 DBM Sample Identification Client Project # Matrix Collection Date/fime Received S5, 1 1484 Soil 25-Mar-08 15:30 26-Mar-08 SA76245-02 CAS No. Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 60007000 Series Methods 7440-47-3 Chromium 8.11 mg/kg dry 0.954 1 SW8a46 601OB 26-Mar-08 27-Mar-08 8031837 LR General Chemistry Para meters % Solids 91.4 % 1 SM2540 G Mod. 26-Mar-08 26-Mar-08 8031835 DBM Sample Identification Client Project 4 Matrix Collection Date/Time Received S f1 1484 Soil 25-Mar-08 15:45 26-Mar-08 SA76245-03 CAS Na Analyte(s) Result Flag Units *RDL Dilution Method Ref Prepared Analyzed Batch Analyst Total Metals by EPA 6000n000 Series Methods 744047-3 Chromium 13.7 mg/kg dry 0.924 1 SWB46 6010B 26-Mar-08 28-Mar-08 8031837 LR General Chemistry Parameters % Solids 92.5 SM2540 G Mod. 26-Mar-08 26-Mar-08 8031835 DBM This laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 3 of 6 Total Metals by EPA 6000/7000 Series Methods - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 8031837 - SW846 30508 Blank (8031837-BLKiI Prepared. 26-Mar-08 Analyzed: 27-Mar-08 Chromium BRL mg/kg wet 0.949 Duclicate (8031837-DUP1) Source: SA76245-02 Prepared: 26-Mar-08 Analyzed: 28-Mar-08 Chromium 9,75 mg/kg dry 0.978 8,11 18 20 Matrix SWike 18031837-MSII Source: SA76246-01 Prepared: 26-Mar-08 Analyzed: 27-Mar-08 Chromium 239 mg/kg dry 0.986 246 9.46 93 75-125 Matrix Spike DuD 18031837-MSDI) Source: SA76245-01 Prepared: 26-Mar-08 Analyzed: 27-Mar-06 Chromium 132 QR7 mg/kg dry 1.01 126 9.46 97 76-125 58 35 Reference (80311837-SRMIl Prepared: 26-Mar-08 Analyzed: 28-Mar-08 Chromium 112 mg/kg wet 1.00 111 101 81.7-117.8 Reference (8031837-SRM2I Prepared: 26-Mar-08 Analyzed: 28-Mar-08 Chromium 112 mglkg wet 1.00 111 101 81.7-117.8 General Chemistry Parameters - Quality Control Spike Source %REC RPD Analyte(s) Result Flag Units *RDL Level Result %REC Limits RPD Limit Batch 8031835 - General Preparation Duplicatle (8031835-DUPI) Source: SA76047-05 Prepared & Analyzed: 26-Mar-08 % Solids 93.6 % 94.3 0.8 20 This laboratory report is not void without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page 4 of 6 Notes and Definitions QR7 The RPD exceeded the QC control limits; however precision is demonstrated with acceptable RPD values for batch duplicate. BRL Below Reporting Limit - Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis NR Not Reported RPD Relative Percent Difference A plus sign (+) in the Method Reference column indicates the method is not accredited by NELAC. Laboratory Control Sample (LCS): A known matrix spiked with compound(s) representative of the target analytes, which is used to document laboratory performance. Matrix Duplicate: An intra-laboratory split sample which is used to document the precision of a method in a given sample matrix. Matrix Spike: An aliquot of a sample spiked with a known concentration of target analyte(s). The spiking occurs prior to sample preparation and analysis. A matrix spike is used to document the bias of a method in a given sample matrix. Method Blank: An analyte-free matrix to which all reagents are added in the same volumes or proportions as used in sample processing. The method blank should be carried through the complete sample preparation and analytical procedure. The method blank is used to document contamination resulting from the analytical process. Method Detection Limit (MDL): The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is greater than zero and is determined from analysis of a sample in a given matrix type containing the analyte. Reportable Detection Limit (RDL): The lowest concentration that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. For many analytes the RDL analyte concentration is selected as the lowest non-zero standard in the calibration curve. While the RDL is approximately 5 to 10 times the MDL, the RDL for each sample takes into account the sample volume/weight, extract/digestate volume, cleanup procedures and, if applicable, dry weight correction. Sample RDLs are highly matrix-dependent. Surrogate: An organic compound which is similar to the target analyte(s) in chemical composition and behavior in the analytical process, but which is not normally found in environmental samples. These compounds are spiked into all blanks, standards, and samples prior to analysis. Percent recoveries are calculated for each surrogate. Validated by: Hanibal C. Taych, Ph.D. Nicole Brown This laboratory report is not valid without an authorized signatureon the cover page. * Reportable Detection Limit BRL = Below Reporting Limit Page S of 6 MADEP MCP ANALYTICAL METHOD REPORT CERTIFiCATION FoRM Laboratory Name: Spectrum Analytical, Inc. - Agawam, MA Poett18 Project Location: Ralph Shuster Metals - Attleboro, MA AERT This form provides certifications for the following data set: SA76245-01 through SA76245-03 Sample matrices: Soil o 8260B [ 8151A 0 8330 E1 6010B 0 7470A/IA MCP S 8270C 0 8081A 0 VPH 0 6020 0 9014M Methods UsedI 2 0 8082 0 8021B 0 EPH 0 7000S3 0 7196A I List Release Tracking Number (RTN), if known 2 M - SW-846 Method 9014 or MADEP Physiologically Available Cyanide (PAC) Method 3 S - SW-846 Methods 7000 Series List individual method and analyte An affirmative response to questionsA, B, C and D is required for "Presumptive Certainty" status A Were all samples received by the laboratory in a condition consistent with that described on the 0 Yes 0 No Chain of Custody documentation for the data set? Were all QA/QC procedures required for the specified analytical method(s) included in this report B followed, including the requirement to note and discuss in a narrative QC data that did not meet El Yes 0 No appropriate performance standards or guidelines? Does the data included in this report meet all the analytical requirements for "Presumptive Certainty", as described in Section 2.0 (a), (b), (c) and (d) ofthe MADEP document CAM VII A, C "Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of E Yes 0 No Analytical Data"? D VPH and EPH methods onl: Was the VPH or EPH method conducted without significant 0 Yes [ No modifications (see Section 11.3 of respective methods)? A response to questions E and F below is requiredfor "Presumptive Certainty" status E Were all analytical QC performance standards and recommendations for the specified methods E Yes 0 No achieved? F Were results for all analytce-list compounds/elements for the specified method(s) reported? 3 Yes El No All negative responses are addressed in a case narrativeon the cover page of this report. 1, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and betief, accurate and complete. Hanibal C, Tayeh, Ph.D. President/Laboratory Director Date: 3/28/2008 7his laboratory report is not valid without an authorized signature on the cover page. * Reportable Detection Limit BRL = Below Reporting Limnit Page 6 of 6 - - 2 IAA -y - APPENDIX G Public Notification WESTERN MASS ENVIRONMENTAL © 2008, Project 1484 APPENDIX Toll Free: 1866-662-2622 Ph: 413-788-2622 August 29, 2008 Mayor Kevin J. Dumas Mayors Office 77 Park Street Attleborough, MA 02703 RE: Notice of Response Action Outcome (RAO) Statement and Activity and Use Limitation RTN 4-16211, 40 Forest Street, Attleborough, MA Dear Mayor Dumas: Pursuant to 310 CMR 40.1403(3)(e)(f) of the Massachusetts Contingency Plan, 310 CMR 40.0000, the Chief Municipal Officer and Board of Health in the community(ies) in which a disposal site is located and any other communities which are, or are likely to be, affected by the disposal site shall be notified of the availability of any Response Action Outcome (RAO) Statements filed pursuant to 310 CMR 40.1000. Western Mass Environmental has recently filed an RAO Statement report package with the Massachusetts Department of Environmental Protection (MADEP) for the above-mentioned location, in addition, pursuant to 310 CMR 40.1403(7)(a), a copy of the Activity and Use Limitation (AUL) amendment for a property shall be provided to the Chief Municipal Officer, Board of Health, Zoning Official, and Building Code Enforcement Official. Western Mass Environmental (WME) has filed an RAO package in response to a releaselthreat of release of oil and/or hazardous material, and outlined that a level of No Substantial Hazard and a Temporary Solution was achieved at the disposal site. Additionally WME has filed an amendment to the AUL for the property at the Bristol County Registry of deeds in accordance with 310 CMR 40.1070, and as such a copy was also filed with at the MADEP. A copy of the AUL amendment is included as an attachment to this letter for you files. A complete copy of the Response Action Outcome (RAO) Statement report package for the above-mentioned location/release, is available to you through the Southeast Regional Office of the Massachusetts Department of Environmental Protection at 20 Riverside Drive in Lakeville, MA 02347. Arrangements may be made with that office to schedule a file review appointment by contacting them at (508) 946-2700, cc: Gary Kyrassian, Director of Planning Doug Semple, Code Enforcement Jim Mooney, Health Agent - azardous Waste Transportation and Disposal 93 Wayside Avenue, West Springfield, MA 01069 S24-hour Emergency Spill Response 880 Washington Street, Attleborough, MA 02703 - Site Remediation - Storage Tank Cleaning and Removal www. westernmassenv. com Industrial Facility Maintenance Waste Recycling Services APPENDIX H Geotextile Fabric WESTERN MASS ENVIRONMENTAL0 2008, Project 1484 APPENDIX THE GREEN GEOTEXTILESTM Made From Post-Consunwr Recycled Plastic Bottles "ONE T RUCKLOAD OF- GEOTE XTILES S AVES 300,0100 LBOTF[ES FROM L ANDFILLS! Americans use approximaitely 2,000,000 plastic bottles every hour! From high-quality rewettable polyester, made from post-consumer recycled plastic bottles, Greeniii colol The Green Geotextiless can be used for LEED Credits and Certification s M Q s 70 70 n GEOTKCHNICAL SUPPLY ) AMERICAN ENGINEERING FABRICS, Inc. MUF ACruRER$ oi GEOTEX1 h. BOOM