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PHASE II COMPREHENSIVE SITE ASSESSMENT REPORT

CYPHER CORPORATION PROPERTY Corner of B Street and West First Street South Boston, Massachusetts

DEP Release Tracking Number 3-21146 [Former SAK Recycling/Boston Junk RTN 3-0580]

VOLUME I Text, Tables, Figures, Appendixes A to I

Prepared for:

Cypher Corporation 15 Cobbler Drive Fitchburg, MA 01420 APR C 2035

Prepared by: N ORTH DEP ORTHEAST REGIONAL ALTON ENGINEERING OFFICE 10 Rugg Road Sterling, MA 01564

March 2005

Alton Day one, LS Principal Engineer

AE Project No: CYPHER0001 File No: Phase II CSA_Cypher

ALTON ENGINEERING HYDRAULIC, WATER RESQOURCES AND ENVIRONMENTAL ALTON ENGINEERING Hydraulic, Water Resources and Environmental

Alton Day Stone, PE, LSP

10 Rugg Road. Sterling. MA 01564 Office: 978.422.8014 Mobile: 978.661).7728 Email: [email protected]

March 30, 2005 AE Project No: CYPHER0001

Mr. Richard J. Chalpin, Deputy Regional Director Department of Environmental Protection Metropolitan Boston - Northeast Regional Office One Winter Street Boston, MA 02108

RE: Phase II Comprehensive Site Assessment Report- NON-NE-04-3A186 Release Tracking No. 3-21146 Cypher Corporation Property Corner of B Street and North End of West First Street South Boston, Massachusetts

Master (Former) Release Tracking No. 3-0580 Former Boston Junk Property 14 Louis Street South Boston, Massachusetts

Dear Mr. Chalpin:

Enclosed please find a Phase II Comprehensive Site Assessment Report for the Cypher Property Site, RTN 3-21146, prepared by Alton Engineering on the behalf of Cypher Corporation (Mr. Walter Fiore, President). In accordance with the DEP Amended Notice of Noncompliance With The MCP, dated November 17, 2004, the Phase II CSA Report and, if applicable, a Phase III Remedial Action Plan, are to be submitted to the Department by March 31, 2005.

The results of the Phase II CSA indicate a disposal site is present on the Cypher Site and further remedial response actions will be required to close the disposal site and file a Response Action Outcome Statement. A Release Abatement Measure Plan describing the remedial actions proposed for disposal site closure is submitted under a separate cover.

Yours truly, ALTON ENGINEERI G

Alton Day to e, LSP Principal Engineer enclosure: Phase II CSA Report cc: Jack Merrill, Esq., Kushner & Sanders LLP Walter Fiore, Cypher Corporation Karen Stromberg, DEP (w/o enclosure) PIP Repositories

File No: AE\Cypher\$P2CSA DEP Cov Let.doc TABLE OF CONTENTS

1.0 INTRODUCTION ...... 1 2.0 SITE INDENTIFICATION AND DESCRIPTION...... 3 2.1 Site Identification...... 3 2.2 Regulatory Status...... 3 2.3 Site Description...... 4 2.4 Surrounding Properties ...... 4 2.5 Local Receptors ...... 6 3.0 SITE HISTORY ...... 8 3.1 History of the Boston Junk/SAK Recycling Site, RTN 3-0580...... 8 3.1.1 Overview of RTN 3-0580 History...... 8 3.1.2 Summary Outline of Boston Junk/SAK Recycling Site History...... 9 3.2 Cypher Property/Site History...... 13 3.3 Cypher Site Regulatory History...... 14 3.4 Remedial Response Action Summary ...... 17 3.4.1 Contos Property Assessment...... 18 3.4.2 South Boston Haul/ByPass Road Remedial Response...... 19 3.4.3 ABB Environmental Services Assessment...... 23 3.4.4 Cypher Street Construction...... 24 4.0 PHASE II CSA SCOPE OF WORK AND SUMMARY OF FIELD WORK...... 27 5.0 SOIL ASSESSM ENT ...... 28 5.1 Soil Borings and Sample Locations...... 28 5.1.2 Cypher Site Soil Borings and Sample Stations - Parcel 2782000...... 28 5.1.3 B Street Extension Soil Borings and Sample Stations...... 29 5.2 Soil Description ...... 29 5.3 Cypher Site Soil Sampling - Analytical Schedule and Results...... 30 5.3.1 Sample Schedule...... 30 5.3.2 TPH to EPH Conversion...... 31 5.3.3 Analytical Results ...... 31 5.3.4 Polychlorinated Biphenyls...... 32 5.3.5 Extractable Petroleum Hydrocarbons ...... 33 5.3.6 Polynuclear Aromatic Hydrocarbons...... 34 5.3.7 Volatile Petroleum Hydrocarbons...... 35 5.3.8 Lead...... 35 5.4 Cypher Property - Soil Pile Samples ...... 35 5.5 B Street Extension Soil Samples - Analytical Schedule and Results ...... 36 5.5.1 Sample Schedule...... 36 5.5.2 Analytical Results ...... 36 5.5.3 Polychlorinated Biphenyls...... 36 5.5.4 Extractable Petroleum Hydrocarbons ...... 37 5.5.5 Polynuclear Aromatic Hydrocarbons...... 38 5.5.6 Volatile Petroleum Hydrocarbons...... 38 5.5.7 Lead...... 39

Cypher Phase II CSA i March 2005 5.6 Soil Contaminants of Concern and Potential Sources ...... 39 5.6.1 Polychlorinated Biphenyls...... 40 5.6.2 Extractable Petroleum Hydrocarbons ...... 43 5.6.3 Polynuclear Aromatic Hydrocarbons...... 44 5 .6 .4 L e ad ...... 4 5 5.7 Extent of Soil Contamination and Disposal Site...... 46 5.7.1 PCB ...... 46 5 .7 .2 E P H ...... 4 7 5 .7 .3 Lead ...... 47 5.7.4 Extent of Disposal Site...... 47 5.7.5 Contaminated Soil Volume...... 48 5.8 OHM M igration Routes ...... 48 5.8.1 W ind-Blown Particulates...... 48 5.8.2 Stormwater Transport ...... 49 6.0 GROUNDW ATER ASSESSM ENT...... 50 6.1 M onitoring W ell Installation...... 50 6.2 Groundwater Quality - Sampling, Analysis and Results...... 50 6.2.1 Cypher Site and B Street Extension...... 50 6.2.2 Other Off-Site ...... 51 6.2.3 Groundwater Quality Conclusions...... 52 6.3 Hydrogeology ...... 52 7.0 RISK CHARACTERIZATION ...... 54 7.1 Introduction ...... 54 7.2 Contaminants of Concern ...... 54 7.3 Disposal Site Information ...... 55 7.3.1 Physical Characteristics ...... 55 7.3.2 Source and Extent of Release ...... 55 7.4 Characteristics of OHM ...... 56 7.5 Identification of Human Receptors ...... 56 7.5.1 Current Use ...... 56 7.5.2 Future Use ...... 56 7.6 Identification of Environmental Receptors ...... 56 7.7 Identification of Disposal Site Activities and Uses ...... 56 7.8 Identification of Applicable Soil and Groundwater Categories...... 57 7.8.1 Groundwater ...... 57 7 .8 .2 S oil ...... 57 7.9 Identification of Exposure Points, Pathways and Concentrations ...... 57 7.9.1 Groundwater ...... 57 7.9.2 Soil ...... 57 7.9.3 Outdoor Air ...... 57 7.10 Method 3 Risk Evaluation - Human Health and Public Welfare...... 58 7.10.1 Risk Assessments completed by Other Consultants for Current Use...... 58 7.10.2 Alton Engineering Risk Assessment for Human Health...... 59 7. 11 M ethod 3 Risk Evaluation - Environment ...... 60 7.12 M ethod 3 Risk Evaluation - Public W elfare ...... 60 7.13 M ethod 3 Risk Evaluation - Safety...... 61

Cypher Phase II CSA ii March 2005 8.0 QUALITY ASSURANCE AND QUALITY CONTROL...... 62 9.0 FINDINGS AND CONCLUSIONS ...... 63 10.0 PHASE II CSA COMPLETION STATEMENT...... 65 11.0 PUBLIC INV OLVEM ENT ...... 65 12.0 LIM ITATIONS AND CONDITIONS...... 65

Comprehensive Response Action Transmittal Form and Phase I Completion Statement, BWSC-108 (includes Phase II Completion Statement)

TABLES 1 Soil Boring and Monitoring Well Specifications 2 Well Gauging and Piezometric Head Elevation Data 3A Cypher Property ABB Soil Samples, Summary of Analytical Results: Polychlorinated Biphenyls - Total Petroleum Hydrocarbons - Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons - Total Metals 3B Cypher Property C&J Soil Samples, Summary of Analytical Results: Volatile Petroleum Hydrocarbons - Polychlorinated Biphenyls - Lead 3C Cypher Property C&J Soil Samples, Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons 3D. 1 Cypher Property RAM/ADL Soil Samples, Summary of Analytical Results: Polychlorinated Biphenyls 3D.2 Cypher Property CDM Soil Samples, Summary of Analytical Results: Polychlorinated Biphenyls - Total Petroleum Hydrocarbons 3E Cypher Property Alton Engineering Soil Samples, Summary of Analytical Results: Polychlorinated Biphenyls - Lead 3F Cypher Property Alton Engineering Soil Samples, Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons 3G Cypher Property C&J Soil Pile Samples, Summary of Analytical Results: Volatile Petroleum Hydrocarbons - Polychlorinated Biphenyls - Lead 3H Cypher Property C&J Soil Pile Samples, Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons 4A B Street Extension C&J Soil Samples, Summary of Analytical Results: Volatile Petroleum Hydrocarbons - Polychlorinated Biphenyls - Lead 4B B Street Extension C&J Soil Samples, Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons 5A Cypher Property, Summary of Soil Sample Data: Polychlorinated Biphenyls - Lead - Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons 5B B Street Extension, Summary of Soil Sample Data: Polychlorinated Biphenyls - Lead - Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons 6A C & J Groundwater Samples, Summary of Analytical Results 6B Alton Engineering Groundwater Samples, Summary of Analytical Results

Cypher Phase II CSA March 2005 RC- I Threshold Risk Characterization - Inhalation Exposure To Contaminated Soil Particulates RC-2 Excess Lifetime Cancer Risk Calculation - Inhalation Exposure To Contaminated Soil Particulates

FIGURES 1 Site Location Map 2 MassGIS 21E Map 3 Neighborhood Plan 4 Site Plan 5 Sampling and Remediation Plan 6 PCB Plan 7 PCB Aroclor Data Plan 8 EPH Plan 9 Lead Plan 10 Disposal Site Plan

APPENDICES A References B Photographs C Tax and Zoning Maps D Boring Logs E Field Notes F Limitations G Calculations H Consultants Figures I Public Involvement J Laboratory Reports [Volume II]

Cypher Phase II CSA March 2005 1.0 INTRODUCTION

This report presents a Phase II Comprehensive Site Assessment Report and Method 3 Risk Characterization for a release of oil and hazardous materials - extractable petroleum hydrocarbons, polychlorinated biphenyls, and lead - to soil at the Cypher Corporation property (the Site) located at the corner of B Street and West First Street in South Boston, Massachusetts. The Massachusetts Department of Environmental Protection (DEP) Bureau of Waste Site Cleanup currently tracks response actions at the Site under Release Tracking Number 3-21146. The Site location is shown on Figure 1, Site Location Map, local neighborhood features are depicted on Figure 3, Neighborhood Plan, and property features are depicted on Figure 4, Site Plan.

The Cypher Site (RTN 3-21146) is a 14,410± square foot lot (Parcel 2782000) that formerly was part of a larger site identified by the DEP as the Boston Junk/SAK Recycling site, 14 Louis Street in South Boston, DEP RTN 3-0580. Releases of oil and hazardous materials (OHM) were first identified on the Boston Junk/SAK Recycling site in 1982 and response actions have continued up to the present date. In 1999 the Boston Redevelopment Authority (BRA) and the Massachusetts Convention Center Authority (MCCA) acquired most of the properties that comprise the Boston Junk/SAK Recycling site through eminent domain proceedings. The BRA/MCCA did not take one parcel (the Site) that subsequently was acquired by Cypher Corporation (Cypher). The DEP acknowledges that the Boston Junk/SAK Recycling properties are now owned by the BRA/MCCA who are responsible for and have been conducting response actions on these properties. However, the DEP has required Cypher to complete response actions at the small lot owned by the company.

The Site that is the subject of this Phase II CSA Report includes only the Cypher property, and the associated disposal site is that portion of the Cypher property where a release of OHM to soil or groundwater has occurred, as defined by the Massachusetts Contingency Plan (MCP) 310 CMR 40.0000. In 2001 the DEP assigned a separate RTN to distinguish response actions being conducted by Cypher specifically at the Site (Parcel 2782000), from those being conducted by the BRA and MCCA at the original Boston Junk/SAK Recycling site.

CGK Environmental, Inc. and Cushing & Jammallo, Inc. prepared a Phase II Scope of Work pursuant to 310 CMR 40.0834 that was approved by the DEP in 2001. Cushing & Jammallo conducted initial fieldwork - drilling of 11 soil borings and three monitoring wells, soil and groundwater sampling - in the spring of 2002. -Work was then halted and Cushing & Jammallo resigned as Consultant and Licensed Site Professional (LSP) of Record in the summer of 2003. Alton Engineering subsequently was contracted by Cypher in September 2004 to complete the Phase II CSA and Risk Characterization, and as appropriate, the further response actions necessary to file a Response Action Outcome Statement (RAO) to close the Site and associated disposal site. Alton Engineering conducted supplemental fieldwork - groundwater and soil sampling and analysis - in November 2004 and January 2005.

This Phase II CSA Report was prepared in accordance with the requirements presented in the MCP, § 40.0830 et seq., and the Risk Characterization was completed in accordance with the requirements of § 40.0900 et seq. Cypher Corporation, mailing address 15 Cobbler Drive, Fitchburg, MA 01420, authorized preparation of this document. Mr. Walter Fiore, President, is the contact person for Cypher.

Cypher Phase II CSA March 2005 The Site is a Public Involvement Plan (PIP) site and public involvement activities have been conducted pursuant to 310 CMR 40.1400 et seq. CGK Environmental and Cushing & Jammallo prepared a final PIP dated December 10, 2001 and held a public meeting to present the Phase II Scope of Work.

The results of this Phase II CSA and Risk Characterization indicate that:

1. Releases of polychlorinated biphenyls (PCB), extractable petroleum hydrocarbons (EPH), and lead to soil have occurred at the Site. The area to which the OHM were released represent a disposal site. Polynuclear aromatic hydrocarbons (PAH) have also been detected in media samples collected from the Site. The presence of PAH is consistent with the MCP definition of "background".

2. A small area of PCB contaminated soil was identified that represents a "hotspot" as defined by the MCP.

3. Under current Site use, there is no risk to human health, public welfare, safety or the environment. The Site is enclosed within chainlink fencing having a locked gate, is posted with hazard warning signs, has no buildings or structures, and is vacant and unused.

4. Remedial response action cleanup was completed by the Massachusetts Highway Department (MassHighway) in 1992 along a MassPort railroad easement that extends through the northeast corner and the east side of the Cypher property. This area totals 2,000± square feet. OHM contaminated soil was excavated and removed for off-site disposal, and a MCP permanent solution was achieved for the area. Further remedial action is not required for this portion of the Site.

5. Further comprehensive remedial response including preparation of a Phase III Remedial Action Plan (RAP) and a Phase IV Remedial Implementation Plan (RIP), or Release Abatement Measure (RAM), and associated remedial action will be required to close the PCB hot spot portion of the disposal site.

6. Implementation of an Activity and Use Limitation (AUL) coupled with paving the disposal site would be sufficient to prevent risk under future industrial use for the disposal site, and would permit filing a Class A3 Response Action Outcome Statement (RAO) to close the disposal site.

7. Remedial response actions conducted by other parties have resulted in MCP permanent or temporary solutions for all but one property - B Street extension - located adjacent to or in the immediate vicinity of the Site.

Cypher Phase II CSA March 2005 2.0 SITE INDENTIFICATION AND DESCRIPTION

2.1 Site Identification

Site Name: Cypher Corporation Property

DEP RTN: 3-21146 [Formerly part of RTN 3-0580, Boston Junk/SAK Recycling]

Site Location: Intersection of B Street and the north end of West First Street, South Boston

County: Suffolk

Assessors Map and Parcel: Boston Assessors Plan Ward 6, Section-2, Block 19, Parcel 0602782000

Geographic Location: Latitude 42o-20'-34" N and Longitude 710-03'-05" W

UTM 331022mE and 4689865mN

USGS Topographic Quad: South Boston Massachusetts (1987, 7.5 x 15 minute)

Site Owner/Operator: Cypher Corporation 15 Cobbler Drive, Fitchburg, MA 01420 Mr. Walter Fiore, President (978.353.3192)

Zoning: General Industrial (Map: South Boston Map 4)

Easement: MassPort easement for railroad track, believed to be 40 feet wide*, extending through the northeast corner and east side of the property. Referenced in the Locus Deed recorded with the Suffolk County Registry of Deeds, Book 25240 Page 163. [*Documents specifying the exact location and dimensions of the easement have not been available to Alton Engineering for review.]

2.2 Regulatory Status

The current regulatory status of the Cypher Site is summarized below.

RTN: 3-0021146. Notice of Noncompliance: NON-NE-04-3A186. MCP Phase: Phase II Comprehensive Site Assessment (CSA)/Phase III Remedial Action Plan (RAP) in process; due date of March 31, 2005 per DEP revised compliance schedule (see Section 3.3). Tier Classification: Tier 1A.

Cypher Phase n CSA March 2005 The DEP Sites List identifies the Site as follows: Address - West First Street; Site Name/Location Aid - no location aid; Reporting Category - none; Notification Date - 01/15/87; Compliance Status - Tier ID (default); Compliance Date - 10/10/94; Phase - blank; RAO Class - blank; Chemical Type - hazardous material.

2.3 Site Description

The Cypher Site/property (Parcel 2782000) is 14,410± sf (65.5 ft x 220 ft) in area, open, generally is level, and is without improvements (see attached photographs in Appendix B). The Site is surfaced with compacted gravel and has a thick vegetation cover consisting of grasses, weeds and plants common to barren ground. Reportedly (GZA 1985, CDM 1990), the property was paved during the period it was used as junkyard. Surficial soil consists of fill, generally sand and gravel, which contains some demolition and solid waste debris. A large pile of soil having some intermixed construction materials extends along the east side of the property. Small amounts of construction materials - e.g. concrete culverts - are stored on the property. Buildings, structures, and utilities are not present on the Site.

The Site is abutted to the east by Cypher Street public way, to the south by the C & H Trust property (Parcel 2778000), to the west by West First Street, and to the north by a currently unused extension of B Street, referred to herein as "B Street extension".

Chainlink fencing encloses all of the Site and B Street extension with the exception of approximately 2,000 sf of the northeast corner and east edge of the Site along a MassPort easement and railroad spurline. A locked gate that provides the only access to the Site and the B Street extension is situated at the corner of B Street and West First Street. Placards indicating the presence of PCB and associated hazards are posted at regular intervals along the fence line.

The MassPort railroad spurline easement is believed to be 40 feet wide, extending from the adjacent properties to the north through the northeast corner and easternmost edge of the Site and thence southward along the adjacent Cypher Street public way. In 1990, MassHighway completed remedial response actions - excavation and off-property disposal of OHM contaminated soil - for the portion of the easement on the Site (as well as property further north of the Site) that resulted in a MCP permanent solution during construction for the South Boston Bypass (Haul) Road (SBBR). The easement area is outside of the chainlink fence enclosure and currently is used by the Boston Railway Terminal Corp. (160 West First Street) for storage of equipment and as an active spurline.

Utility poles with overhead wires extend through B Street extension. Utilities including sewer mains extend along West First Street and the active portion of B Street, west of the Site.

2.4 Surrounding Properties

For specific parcels noted below, the following information is presented: number*, owner, and zoning. None of the parcels are permitted for, or have an exemption for, residential use. Parcel locations are shown on Figure 3 and on Figures included in Appendix C. [* All of the parcels have a prefix of 060 as part of the formal identification, which is omitted for simplification.]

Cypher Phase II CSA March 2005 North. An inactive 50-foot wide extension of B Street extends eastward from the intersection of West First Street and B Street along the north side of the Site to Cypher Street public way. B Street extension is a City of Boston owned public way. Much of B Street extension is surfaced with tight fitting granite paving (cobble) stones, particularly in the west portion of the street. Alton Engineering personnel did not observe evidence of substantial oil spillage (e.g. dark stain) on the cobbles. The surface grade of B Street extension is commensurate with that of the Cypher property.

Parcel 2769200 - Nicholas J. Contos, Commercial - abuts the north side of B Street extension. Office trailers for the Boston Railway Terminal Corp. are situated on this property. BRT operates a rail terminal for the transport of structural steel into Boston. Consolidated Railroad Corporation (Conrail) railroad tracks extend east-west through this parcel. MCP remedial response that achieved a permanent solution was completed for a substantial portion of this property during construction of the Haul/SBBR (see Section 3.4.2).

Parcel 2771100 - Energy International, Commercial - abuts the north side of the east end of B Street extension. During the SBBR construction, MCP remedial response that achieved a permanent solution was completed for a substantial portion of this property.

Parcel 2769010 - Commonwealth of Massachusetts, Exempt - located north of the Contos and Energy International parcels is utilized for the SBBR.

East. Cypher Street public way borders the east side of the Site. Cypher Street is a City of Boston owned public way, and is an un-constructed paper street. A new paved "Cypher Street" was constructed in 2000 on BRA properties located east of Cypher Street public way (see Section 3.4.4).

Parcel 2771000 - BRA, Exempt - is now part of the Boston Convention and Exhibition Center (BCEC) site. During construction, MCP remedial response that achieved a permanent solution was completed for this property.

Parcel 2773001 - BRA, Exempt - is now part of the BCEC site. A portion of this property is surfaced by the EM-1 Cap, a bituminous concrete surface that was placed to provide a laydown area for BCEC construction. The EM-1 Cap is a MCP temporary solution (see Section 3.1.2).

Parcels 2773002 - BRA, Exempt - is now part of the BCEC site. MCP remedial response that achieved a permanent solution was completed for this property.

Parcels 2771000, 2773001 and 2773002 were formerly owned by Boston Junk and then SAK Recycling, and are part of RTN 3-0850 (see Section 3.1).

South. The city block situated south of the Site is used for a variety of industrial and commercial operations.

Parcel 2778000, William Casey, Trustee for C & H Trust, Industrial - abuts the south side of the Site. The northern 1/3 to 1/2 of this property is a paved parking lot. Shawmut Crane and Rigging, and warehouse space occupy the south portion of the property. Assessment was conducted on the parking lot portion of this property in 1998 (see Section 3.4.3).

Cypher Phase II CSA March 2005 Commercial properties situated further south towards C Street include: Findlich & Moore Electrical, i Inc., C Street Garage Fleet & Auto Center, Store Front Security, and Boston Grate.

West. West First Street abuts the west side of the Site. Commercial properties are situated along the I west side of this street, between West First Street and West Second Street, and include: warehouse space, Signal Industries, and American Ramp Systems. The west side of West First Street, and property further to the west are part of the St. Vincent Neighborhood and Neighborhood I Development Area that includes residential use (see Section 2.5). Residential apartment buildings are located along the west side of West Second Street, and these apartments are the nearest residential dwellings to the Site.

1 2.5 Local Receptors 1A neighborhood (windshield) survey was conducted of the surrounding properties, to evaluate the presence of sensitive receptors within 500 feet of the Site. In addition, information regarding receptors was obtained through review of the Boston Zoning Maps (Appendix C), the USGS I Quadrangle Map - Boston South (Figure 1), and the MassGIS 21E Site (Figure 2). [Note: all distances presented below are approximate.]

I Zoning. [South Boston Map 4, and St. Vincent Map 4E. See Appendix C.] The location of the Site and all properties to the immediate north, and east and southeast are identified as I-2 "General Industrial" use. Properties located southwest of the Site, as far southwest as the east side of West First Street are also designated as General Industrial. Properties to the north, northwest and west are identified as M-2, M-4, and M-8 "Restricted Manufacturing" uses. Properties located southwest of West First Street are part of the St. Vincent Neighborhood, and are designated NDA "Neighborhood Development Area". This is a mixed-use designation that does permit residential and day care center uses. However, as described below, these uses were not observed along West First Street.

1 Water Supplies. Water supplies are not present on or in the vicinity of the Site. All business and residences utilize the Massachusetts Water Resources Authority (MWRA) municipal water supply and distribution system, which obtains water from the Quabbin and Wachusett Reservoirs located over 40 miles to the west. The Site is not located in a potential productive aquifer or a potential drinking water source area.

Surface Water Bodies. The nearest surface water (tidal) is the Fort Point Channel located 2,000 feet west of the Site. The Reserve Channel is situated 3,500 feet east of the Site. Both channels are i dead-end urban waterway canals extending though heavily urbanized/industrialized areas.

Residences. Although the NDA zoning permits residential use along the east side of West First IStreet, the neighborhood survey conducted by Alton Engineering did not identify residential properties next to the Site. The nearest residences are located along the west side of West Second Street, :300 feet west of the Site. The Site location and vicinity are zoned as Industrial or 1Manufacturing, and the zoning boundary between the Residential/NDA and the Industrial and Manufacturing Zoning Districts is shown on Figure 3. I

3 Cypher Phase ILCSA 6 March 2005 Institulions. In regard to the St. Vincent NDA zoning; schools are only allowed with a special Spermit; hospitals are not permitted; and day care centers are permitted. However, these uses were not identified during the neighborhood survey conducted by Alton Engineering. Hospitals have not been identified within 500 feet of the Site. The Cardinal Cushing High School, located 1,000 feet west of the Site, is the nearest school. The Condon and Bigelow Schools are located 1,500 feet south of the Site. Other schools are located more than 2,500 feet from the Site.

i Open Space and Conservation Lands. Open space, park or conservation lands are not situated within 1,500 feet of the Site. The closest large open space (parkland) is situated on Telegraph Hill 3,000 feet south of the Site. I Rare or Endangered Species, and Sensitive Habitat. Sensitive biological/ecological features are not situated within 2,000 feet of the Site. As noted above, the Fort Point and Reserve Channels are 3urban industrial canals and are likely to be largely devoid of significantly valuable marine habitat. I I I I I I I I

I I

Cypher Phase II CSA March 2005 3.0 SITE HISTORY

Information on the Cypher property and Site history, and history of the Boston Junk/SAK Recycling site was obtained from: (1) on-site inspection of the property, (2) review of Commonwealth of Massachusetts regulatory agency file information, (3) review of Sanborn Fire Insurance Maps, (4) review of documents prepared by and obtained from previous environmental contractors, (5) review of documents at the Massachusetts Highway Department. In particular, Alton Engineering conducted a review of assessment reports and related documents prepared by other consultants. A list of references is included in Appendix A. Alton Engineering did not verify information obtained from these documents.

3.1 History of the Boston Junk/SAK Recycling Site and Properties, RTN 3-0580

Although from a regulatory standpoint the Cypher Site is no longer part of the Boston Junk/SAK Recycling site, the history of RTN 3-0580 is reviewed herein because until 1999 the Cypher property was part of the Boston Junk/SAK Recycling properties and operations, and until 2001 the Cypher Site was included as part of RTN 3-0580. Until 2001, MCP response actions initiated for the Boston Junk/SAK Recycling site included the Cypher property. However, most of these actions did not directly involve the Cypher property.

3.1.1 Overview of RTN 3-0580 History. From 1947 through approximately 1988, Messrs. Louis and Frank Freeman operated two junkyard/salvage companies - Boston Junk Company and Boston Iron & Metal Company (abbreviated to Boston Junk) on four parcels under their ownership totaling approximately 3.6 acres, as well as on portions of the adjacent Energy International property. The DEP now identifies these properties as the Boston Junk/SAK Recycling site, 14 Louis Street, Boston, RTN 3-0580. This site has also been referred to (RAM 1999) as the Former Boston Junk/Boston Iron and Metal Company site. RTN 3-0580 has, depending upon definition, included the following properties:

1 Parcels 2772002, 2773001, 2773002, and 2782000 formerly owned/operated by the Freemans as Boston Junk. The BRA now owns the first three parcels. Parcel 2782000 is now the Cypher property/Site.

2 Parcel 2771000 that formerly was owned by Energy International and now is owned by the BRA, Boston Junk did not own this parcel; however, a portion of the property apparently was utilized by the business as a junkyard.

3 Cypher Street, a City of Boston public way. Cypher Street public way is unimproved and may have been used for the junkyard operations.

4 Parcel 2778000 owned/operated by C & H Trust. A portion of this property has on occasion (RAM 1999, ABB 1997) been included as part of RTN 3-0580 because assessment actions were conducted on this parcel during assessment of the Boston Junk/SAK Recycling site. However, it is not part of the Boston Junk/SAK Recycling site.

Cypher Phase II CSA March 2005 Available records (GZA 1985) indicate that Boston Junk did not utilize B Street extension for storage and dismantling of junk or other operations. Apparently, B Street was open for traffic during the years of operation by Boston Junk. Fencing to limit access to this portion of B Street was not installed until 1998, by Boston Edison Company (BECo).

During its period of operation, Boston Junk reportedly used the property for storage, disassembly and salvage of electrical capacitors, transformers, lead-coated wire and cable, and related equipment obtained from the BECo, as well as metal junk and salvage from other operations. Over time, Boston Junk's operations resulted in the accumulation of massive piles of scrap metal and soil. Records (GZA 1985) indicate Boston Junk directly utilized the Cypher property for the storage and handling of scrap materials. Remedial investigations and response actions were initiated by the US Environmental Protection Agency (EPA) in 1982 in regard to PCB in soil and were continued by the DEP into the late 1980s and are ongoing by the BRA and MCCA.

SAK Recycling Corporation (SAK) acquired the Boston Junk properties (four parcels) in 1992 for use as a construction yard and for the storage and recycling of construction materials - e.g. sewerage structures, pipe, concrete, and soil. SAK sold some of the existing scrap metal and brought additional soil and construction materials onto the site. However, there is no record that SAK brought hazardous materials or waste onto the site, or that SAK removed such from the site. Reportedly, SAK also concentrated large amounts of the scrap metal remaining from the Boston Junk operation into large piles, and then screened the piles to remove the salvageable scrap metal.

3.1.2 Summary Outline of Boston Junk/SAK Recycling Site History. MCP remedial response actions were initiated by the DEP in the late 1980s and an outline of major site historical events is provided below. Several consultants contracted by Boston Junk, SAK, BECo, BRA, MCCA or MassHighway have completed MCP remedial response. PCB, lead and EPH in surface soil have been the primary contaminants of concern/media throughout the Boston Junk/SAK Recycling site. All of these OHM are common to electrical equipment and railroad operations (see Section 5.6).

November 1982, US Environmental Protection Agency (EPA 1982) completed a Site Inspection of the Boston Junk property. Transformers were observed and PCB detected (16 mg/kg) in the one soil sample collected.

1983, Department of Environmental Quality Engineering (DEQE, predecessor to the DEP) conducted an investigation of the Boston Junk property.

1985, Goldberg-Zoino & Associates (GZA 1985) conducted an assessment on the Contos property located north of the Boston Junk properties. The assessment noted that in March of 1985 a large scrap pile and transformers were observed on the Cypher property; however, by July of 1985 the scrap pile and transformers had been moved east to the vicinity of Louis Street (see Section 3.4.1.).

February 1985, DEQE (1985) issued a Notice of Responsibility (NOR) to Mr. Frank Freeman of Boston Junk regarding a Release/Threat of Release of Oil/Hazardous Material. The letter requested information regarding the transformers and potential PCB contents.

Cypher Phase II CSA March 2005 August 1985, EPA (1985) conducted a second inspection and met with Mr. Freeman of Boston Iron and Metal Company. Transformers and capacitors were observed, and PCB were detected in soil and transformer oil samples.

I 1986, NUS Corporation (1986), an EPA contractor, completed a Perimeter Survey and a Preliminary Assessment of the Boston Junk property. Boston Junk accepted cable, wire, boilers, motors, generators, transformers and capacitors. Scrap piles were not observed on the Cypher property; however, stained soil was observed.

1987, haInland Pollution Control, contracted by BECo, removed the PCB-containing electrical items I from the Boston Junk property and disposed of the equipment in accordance with the Massachusetts Hazardous Waste Regulations 310 CMR 30.00. 1 September and November 1987, DEQE performed two site inspections and observed that the electrical equipment had been removed and that records were in place documenting the proper disposal.

I December 1987, DEQE (1987) issued a Notice of Responsibility to BECo because Boston Junk had purchased electrical equipment from BECo. 1 December 1988, DEQE (1988) prepared a Site Inspection Report for Boston Junk that noted in particular: (a) observation of large piles of transformers and electrical equipment in 1984, (b) the I NOR sent to Boston Junk and BECo in 1985 and 1987, respectively, (c) manifests and bills of sale documenting the sale and transfer of PCB containing electrical equipment and wire to Boston Junk, and (d) a 1979 letter from Boston Junk to BECo complaining of residual oil in the bottoms of transformer tanks.

1988, Asaf A. Qazilbash was contracted by Mr. Frank Freeman to complete an environmental site 3 assessment of the Boston Junk property. PCB - 36 to 280 mg/kg - were detected in three soil samples collected from the property. Sampling was not conducted on the Cypher Parcel (RAM i 1999).

1989 - 1993, MassHighway conducted MCP remedial response action assessment and cleanup for the right-of-way for the Haul Road, later renamed the South Boston Bypass Road (SBBR) as part of 3 the Central Artery/Third Harbor Tunnel project (CA/T). This project included assessment, cleanup and achievement of a MCP permanent solution for the MassPort easement that extends through the northeast corner and east side of the Cypher property, as well as for the substantial portions of the 5properties located northeast of B Street and the Site (CDM 1990, see Section 3.4.2). I 1992, SAK Recycling Corporation purchased all four parcels of the Boston Junk property.

1994, DEP (1994) issued a Notice of Responsibility to SAK Recycling.

S1994 and 1995, DEP conducted several site inspections of the SAK properties.

ICypher Phase IICSA 10 March 2005

3 Cypher Phase II CSA 10 March 2005 1995, Caldwell Environmental, Inc. (now Brown & Caldwell, CEI 1995) prepared a Draft Immediate Response Action (IRA) Plan for bioremediation of PCB contaminated soil, in response to the NOR issued to SAK in 1994. The IRA Plan proposed a demonstration project for PCB bioremediation. The DEP (1995, letter to M. J. Hannon) subsequently provided initial approval for the project, and required Caldwell Environmental to obtain the necessary permits and to provide public notification. The IRA was not initiated.

February 1996, New England Environmental Technology Corporation (NEET 1996) completed a Phase I Initial Site Investigation of the Boston Junk/SAK Recycling site, for SAK. This appears to be the initial MCP-related assessment action conducted on this site. Media samples were not collected from the Cypher property. NEET classified the disposal site as Tier II and provided opinions that Inminent Hazard or Substantial Release Migration conditions were not present. The DEP subsequently classified the disposal site as Tier lA. NEET prepared an IRA Plan that proposed paving the site as a temporary IRA solution to limit exposure to OHM contaminated soil. The DEP did not approve the IRAP and the IRA was not conducted.

1996, BFIECo took over responsibility for response actions at the site.

1996, At the request of the DEP, the Attorney General issued an injunction ordering SAK to cease all activities at the site until remedial response was completed.

1997 and 1998, ABB Environmental Services, Inc. (now Harding Lawson Associates, ABB 1997, 1998) completed IRA assessment on behalf of BECo. A comprehensive soil-sampling program was completed across all of the properties associated with the Boston Junk/SAK Recycling site, including the Cypher and C & H Trust properties (see Section 3.4.3). ABB concluded that an Imminent Hazard condition was not evident at the site provided there were no activities resulting in direct contact with soil, and that a Condition of Substantial Release Migration did not exist at the site.

1997 and 1998, Weston & Sampson Engineers, Inc., (W&S 1987, 1989) on behalf of the BRA, completed comprehensive sampling of the soillscrap piles and installation of additional soil borings and monitoring wells. All of the sampling points were located 100+ feet east and southeast of the east border of the Cypher property.

July of 1999, RAM Environmental LLC completed a Phase II Comprehensive Site Assessment and prepared a Phase III Remedial Action Plan on behalf of BECo (RAM 1990). RAM apparently superceded Harding Lawson as the site environmental contractor for BECo. The Phase II CSA included collection of soil samples from two locations on the Cypher property. The Arthur D. Little consulting company was also involved in the soil sampling and analysis.

1999 and 2000, the BRA/MCCA acquired the Boston Junk/SAK Recycling properties (Parcels 2772002, 2773001, and 2773002), with the exception of the Cypher property (Parcel 2782000), and acquired one of the Energy International properties (Parcel 2771000). Due to the BRA/MCCA decision to conduct response actions necessary to make the site suitable for unrestricted human use and to comply with their construction schedule, BRA/MCCA did not employ the remedial action proposed by Caldwell Environmental. Instead, they opted to excavate and remove all OHM

Cypher Phase II CSA March 2005 contaminated soil for off-site disposal. Four remedial actions for cleanup of OHM contaminated soil were implemented by the BRA or MCCA on the Boston Junk/SAK Recycling site, for the purposes of making the property suitable for its intended future uses and to provide either a temporary or permanent solution pursuant to the MCP. None of these response actions directly affected the Cypher property.

Soil Pile Removal. Several soil and debris piles were present on the Boston Junk/SAK Recycling site at the time it was acquired by the BRA. The BRA removed these piles for off- site disposal between February and June of 2000. Approximately 4,000 cubic yards of soil were removed. Reportedly, the removal actions involved only the soil piles and did not include excavation of contaminated surface soil. A bituminous concrete cap, termed the EM- I Cap, was then placed across a portion of the area to be used for construction, as a MCP temporary solution. The response actions were conducted pursuant to a Release Abatement Measure (RAM) Plan prepared by Weston & Sampson (W&S 2000).

BCEC Hot Spot Removal. A PCB hot spot was identified within the footprint of the proposed BCEC, apparently on the former Energy International Parcel 2771000. The MCCA removed approximately 1,555 tons of PCB contaminated soil for off-site disposal in July 2000 under a Release Abatement Measure Plan prepared by Haley & Aldrich, Inc. in June 2000 (H&A 2000).

EM-1 Cap. The cap is a protective layer of bituminous pavement that was placed over a portion of the former Boston Junk/SAK properties to provide a laydown area for construction of the BCEC and to prevent contact with OHM contaminated soil. The EM-1 Cap underlies the majority of the new Cypher Street, covers a portion of the Cypher Street public way, and covers the majority the BRA (former Boston Junk/SAK Recycling) properties east of Cypher Street public way. The EM-1 Cap extends from C Street northward approximately to the junction of B Street extension and Cypher Street public way, and is located approximately 26 feet east of the east border of the Cypher property (Figure 5). The EM-I Cap installation was completed in 1999 as a RAM supervised by Weston & Sampson Engineers, Inc. (W&S 1999) for the BRA under RTN 3-0580. The EM-1 Cap is considered a MCP temporary, rather than permanent, solution. PCB concentrations present beneath the EM-1 Cap range up to 1,000+ mg/kg; however, those in the vicinity of the Cypher property are all less than 3.7 mg/kg.

Cypher Street Construction. The MCCA constructed a roadway through the Boston Junk/SAK Recycling site, connecting D Street with the SBBR along a corridor located east of the Cypher Street public way on BRA properties, to provide vehicle access during BCEC construction. Construction was conducted in April 2001, under a Construction RAM Plan prepared by Haley & Aldrich, Inc. in November 2000 (H&A 2000), for RTN 3-16224. Approximately 1,008 tons of contaminated soil were excavated for off-site disposal.

The majority of the work consisted of a temporary road that was installed over the EM-1 Cap. Almost all of the soil excavation was conducted on the BRA Parcels 2773001, 2771000, 2769150 (see Section 3.4.4).

Cypher Phase II CSA March 2005 3.2 Cypher Property/Site History

[This section provides a history of the Cypher property ownership and use. An outline of regulatory compliance activities is presented in Section 3.3.]

1. The Cypher property and surrounding properties have a long history of industrial use including, use as a junkyard, railroad yard and railroad maintenance and repair facility. These uses are well documented (NEET 1996, RAM 1999, Rizzo 1999, META 2002, Gradient 2002, Lightship 2002) and are identified as the primary sources of the OHM detected on the Site. From at least the late 1880s, most of the general area now identified as the Boston Junk/SAK Recycling site, including the Cypher property and portions of the surrounding properties, were utilized as a railroad yard and maintenance and repair facility operated by the New York, New Haven and Hartford Railroad, and later by Conrail.

2. T'he 1888 Sanborn Map of B Street Area indicates the Cypher property was occupied by the J.C. Story & Co., and apparently used as a cooperage and for the production and/or storage of tarpaper. The adjacent C & H Trust property was also a cooperage. Boston Cooperage and the NY, NH & H Railroad yard occupied the Contos property north of B Street which at that time extended through to the north end of Cypher Street public way. Properties on the west side of West First Street were commercial and industrial.

3. The 1923 Sanborn Map of Cypher Street delineates the Cypher property but does not indicate activities taking place on the property. However, the railroad spurline through the northeast corner of the property and railroad line extending southward down Cypher Street public way are depicted. Property east of Cypher Street public way is identified as the Boston Transit Commission Stockyard and associated railroad yard.

4. In 1947, Mr. Frank Freeman initiates the Boston Junk salvage and scrap yard operations. Mr. Louis Freeman and his son Frank operated the businesses from 1947 through approximately 1988. Junkyard activities were centered on the 14 Louis Street property. The date when Mr. Freeman began operations on the Cypher property was not available to Alton Engineering.

5. A plan of land dated May 4, 1953 entitled Commonwealth Land In South Boston prepared by the Port of Boston Authority (now MassPort), indicates the Commonwealth of Massachusetts owned the Cypher property as part of the Commonwealth Pier No. 5 South Boston. The plan depicts the existing railroad spurline, and a second spurline that is no longer present that formerly extended into the middle of the Cypher property.

6. Post 1953, Mr. Frank Freeman acquires Parcel 2782000 (currently the Cypher property) that has been, or subsequently will be, utilized by the Boston Junk scrap yard operation.

7. A site assessment report prepared by GZA (1985) for the Contos property located north of B Street extension, described a large scrap pile present on the Cypher property in April of 1985. The west end of the scrap pile contained transformers. Transfonrmer dismantling operations were not noted for the Cypher property. In July of 1985, the scrap pile and transformers had been moved eastward to the vicinity of Louis Street.

Cypher Phase II CSA March 2005 8. The 1988 Sanborn Map of Cypher Street labels the Cypher property as "junk" indicating the property was part of the Boston Iron & Metal Co. operation.

9. In 1989 through 1993 MassHighway conducted MCP remedial response assessment and cleanup for the right-of-way for the Haul/SBBR as part of the CA/T project. This project included assessment and cleanup of the MassPort rail easement that extends through the northeast corner and east side of the Cypher property.

10. In 1992 SAK Recycling Corporation purchased the four Boston Junk properties from the estate of Louis Freeman. SAK continued to sell the existing scrap, but primarily used the properties as a construction yard and for the storage and recycling of construction-related materials such as soil, rebar, and concrete sewerage structures. SAK ceased operations in 1996 after the Attorney General issued the injunction requiring SAK to cease all operations until remedial response had been completed.

11. MCP remedial response actions were initiated by SAK in 1996, in response to a DEP NOR. NEET (1996) completed a Phase I ISI. This assessment did not include collecting media samples from or specific evaluation of the Cypher property. Numerous assessment and cleanup actions subsequently were completed and were associated with the larger Boston Junk/SAK Recycling site.

12. In 1997 and 1998, ABB Environmental Services, Inc. completed an IRA assessment on behalf of BECo. Ten sampling stations were located on the Cypher property.

13. In 1999, the BRA took three of the SAK/Boston Junk properties (Parcels 2773001, 2773002 and 2772002) and one Energy International property (Parcel 2771000) by eminent domain. However, the Cypher property (Parcel 2782000) was not taken in 1999 and Cypher Corporation acquired ownership at that time.

14. The Cypher property has remained vacant and unused by Cypher from 1996 to the present. From 1999 until it was secured with fencing in April of 2000 the property was used for vehicle storage and parking.

3.3 Cypher Site Regulatory History

An outline of recent (post 1990) key regulatory compliance documents for the Cypher Site (and the Boston Junk/SAK Recycling site until the date the two sites were separated), and recent regulatory activities for the Site is presented below.

1992, SAK Recycling acquires the Boston Junk properties.

1994 (undated), letter from the DEP to SAK Recycling Corp., RE: South Boston-Boston Junk Louis Street, Boston, MA, RTN #3-0580, Notice of Responsibility & Interim Deadlines. On the basis of PCB concentrations up to 720 mg/kg detected in five soil samples collected by the DEP from the Boston Junk/SAK properties, and previous site assessment actions, the DEP had determined a release of OHM had occurred on the property. The letter required SAK to complete an IRA for the

Cypher Phase II CSA March 2005 release of PCB to surface soil, a Phase I Initial Site Investigation, Tier Classification, and if necessary a Tier I Permit Application (DEP 1994).

April 18, 2000, letter from the DEP to Walter A. Fiore, Urgent Legal Matter: Prompt Action Necessary, Certified Mail: Return Receipt Requested, Notice of Responsibility Under M.G.L c.21E and 310 CMR 40.000, Interim Deadlines To Conduct Response Actions. RE: Boston; SAK Recycling/Former Boston Junk; RTN 3-0580. This letter specifically addressed the "West First Street property" (i.e. Cypher property) as distinct from the three other Boston Junk/SAK Recycling properties that were acquired by the BRA, and acknowledged that the BRA now owned "14 Louis Street". The letter noted that: (1) the West First Street property was a "site" as defined by the MCP, (2) American Flag [company] was using the Site for truck storage, (3) because access to the Site was not restricted, an Imminent Hazard (IH) could exist through contact with PCB-contaminated soil, and (4) an IRA was required for the IH (DEP 2000).

The DEP required SAK to: (1) notify all Site tenants, lessees and/or users in writing of the PCB contamination and potential risk, (2) prevent access and/or direct contact by Site users/tenants, until an IH Evaluation was completed and any response actions necessary to abate the IH- were completed, (3) post the Site perimeter with hazard warning signs, (4) secure the Site against public access with fencing, and (5) file a RAO within 6 months. The IRA activities were completed. Apparently, the Department did not issue a new RTN for the 2-hour IH notification condition and IRA.

January 16, 2001, "Draft for Review and Comment Only" Phase II Scope of Work for SAK Recycling/Former Boston Junk Property At the Northern End of West First Street, South Boston, Massachusetts, Release Tracking No. 3-0580, prepared by CGK Environmental, Inc. for SAK Recycling. The Phase II CSA SOW was to be finalized after DEP review and comment. The SOW included drilling of soil borings, installation of three monitoring wells, soil and groundwater sampling and analysis, and Risk Characterization (CGK 2001).

May 23, 200 1, letter from the DEP to CGK Environmental, South Boston, SAK Recycling/Former Boston Junk, West First Street, DEP RTN 3-0580 - Approval to Submit CGK Environmental'sApril 6, 2001 Draft Phase II Scope Work for SAK Recycling/Former Boston Junk for Public Comment. The DEP approved the CGK Phase II SOW for distribution for public comment. However, the Department could not provide final approval until public comment had been addressed (DEP 2001).

April 6, 2001, Phase II Scope of Work for SAK Recycling/Former Boston Junk Property At Northern End of West First Street, South Boston, Massachusetts, Release Tracking No. 3-0580, prepared by CGK Environmental, Inc. for Cypher Corporation. The final Phase II CSA SOW included a stamped and signed Comprehensive Response Action Transmittal Form & Phase I Completion Statement (Form BWSC-108) dated April 6, 2001 (CGK 2001).

June 7, 2001, letter from CGK to the DEP presenting a schedule for implementation of Public Involvement activities. CGK also requested a separate RTN for the Cypher Site to distinguish it from RTN 3-0580 that was for the Boston Junk/SAK Recycling site now owned by the BRA. In October of 2001 the DEP provided the new RTN 3-21146 for the Site. The DEP was also going to issue a new RTN for the Boston Junk site, and retain RTN 3-0580 as a master RTN for the entire former Boston Junk site at large. This second RTN apparently has not been provided (CGK 2001).

Cypher Phase II CSA March 2005 October 24, 2001, CGK prepared a Draft Public Involvement Plan. The Draft PIP and Phase II CSA SOW were presented at a public meeting held in South Boston on this date.

December 10, 2001, Public Involvement Plan, SAK Recycling/Former Boston Junk, Property at Corner of B Street and Northern End of West First Street, South Boston, Massachusetts, Release Tracking No. 3-21146, Former Release Tracking No. 3-0580, prepared by CGK and Cushing & Jammallo for Cypher Corporation. The final PIP was submitted to the DEP (CGK 2001).

Note: Letters from the DEP to CGK or Cushing & Jammallo documenting final approval of the Phase II CSA SOW or final approval of the PIP have not been available to Alton Engineering. It is assumed that the approval was granted in some format because a final approval by the DEP was required for initiating the Phase II fieldwork.

April and May of 2002, field work for the Phase II CSA was conducted by Cushing & Jammallo and included: drilling 11 direct push (Geoprobe) soil borings; installation of three 1-inch diameter monitoring wells; analysis of 31 soil samples for PCB, volatile petroleum hydrocarbons (VPH), EPH and Target PAI, and total lead; and analysis of three groundwater samples for the same parameters plus volatile organic compounds (VOC). Draft tables presenting the analytical results were prepared; however, a Phase II CSA Report was not completed. No further remedial response actions appear to have been undertaken or completed since approximately June of 2002, until re-initiation of work by Alton Engineering in November 2004.

June 2 2003, letter from Joseph Jammallo, LSP #2259, with Cushing and Jammallo, providing notice to the DEP that he will no longer be serving as the LSP of Record for the RTN 3-2146 disposal site (C&J 2003).

June 16, 2004, letter from the DEP to Walter A. Fiore, RE:.SOUTH BOSTON, Former Boston Junk, 14 Louis Street, DEP RTN 3-00580 NON-NE-04-3A186. The DEP informed Mr. Fiore that he may be a Potentially Responsible Party (PRP) for the Boston Junk and SAK Recycling properties at 14 Louis Street and at the current Cypher property at the northern end of Cypher Street and West First Street in Boston (City of Boston Assessor's Office I.D. #06/02782/000). The Letter of Noncompliance (NON) required Mr. Fiore to submit a Phase II Report and if applicable a Phase III Remedial Action Plan by July 31, 2004 and a RAO by January 31, 2005 (DEP 2004).

July 9, 2004, letter from Jack Merrill, Esquire, Kushner & Sanders LLP, to the DEP, Re: Sak Recycling Corp. 14 Louis Street, South Boston. The letter provided an explanation for the delay in conducting remedial response actions at the 14 Louis Street property and the West First Street parcel due to ongoing litigation (K&S 2004).

October 15, 2004, letter from Alton Engineering to the DEP, RE: Proposed Remedial Response Schedule - NON-NE-04-3A186, Release Tracking No. 3-21146, Cypher Corporation Property, Corner of B Street and North End of West First Street, South Boston, Massachusetts. Alton Engineering proposed a compliance schedule with the following key dates, submittal of a final Phase II Report by March 31, 2005 and RAO by April 30, 2005 (AE 2004).

Cypher Phase II CSA March 2005 November 17, 2004, from the DEP to Walter A. Fiore, RE: SOUTH BOSTON SAK Recycling/Former Boston Junk, West First Street (City of Boston Assessor's Office LD. #06/02782/00) DEP RTNs 3-21146 & 3-0580, NON-NE-04-3A186a. The DEP approved the compliance schedule proposed by Alton Engineering: Phase II Report and, if applicable Phase III Remedial Action Plan by March 31, 2005, and an RAO by April 30, 2005 (DEP 2004).

November 2004, Alton Engineering resumes preparation of the Phase II Report and conducts additional Phase II fieldwork including excavation of four hand-auger soil borings, and soil and groundwater sample analysis.

November 16, 2004, letter from Alton Engineering to Ms. Karen Stromberg, DEP, RE: Phase II CSA Update #1, Release Tracking No. 3-21146, NON-NE-04-3A186, Cypher Corporation Property, Corner of B Street and North End of West First Street, South Boston, Massachusetts. The letter provided an update on proposed additional Phase II fieldwork, and an updated Health and Safety Plan (AE 2004).

November 16, 2004, letter from Alton Engineering to the PIP Notification List - Mayor Thomas Menino, Mr. Jack Tracy, Office of Environmental Health, Senator Stephen Lynch, Representative John Hart, Jr., and Brian R. Mahoney, Lower End Political Action Committee - RE: Phase II Field Work and Health and Safety Plan Release Tracking No. 3-21146 Cypher Corporation Property Corner of B Street and North End of West First Street South Boston, Massachusetts. The letter provided an update on the proposed additional Phase II fieldwork, the updated Health and Safety Plan, and notification that respiratory protection might be used during field activities (AE 2004).

November 16, 2004, letter from Alton Engineering to the PIP Mailing List, RE: Phase II Field Work and Health and Safety Plan Release Tracking No. 3-21146 Cypher CorporationProperty, Corner of B Street and North End of West First Street South Boston, Massachusetts. The letter provided an update on the proposed additional Phase II fieldwork, notification regarding the updated Health and Safety Plan, notification that Cypher Corporation had contracted Alton Engineering to complete remedial response actions at the Cypher property, and notification that Alton Day Stone LSP# 4058 would be the new LSP of Record (AE 2004).

3.4 Remedial Response Action Summary

This section provides a summary of four remedial response actions completed on or in the immediate vicinity of the Site. Reports describing the response actions provide information/documentation regarding: (1) Site history, (2) nature and extent of OHM formerly or currently present on the Site, (3) nature and extent of OHM formerly or currently present on adjacent properties and the relationship, if any, to OHM released on the Site, (4) soil lithology and surficial geology for the Site and surroundings, and (5) confirmation that MCP response actions completed for the Site or surrounding properties resulted in a permanent or temporary solution, in particular for the portion of the Cypher property along the MassPort easement. Pertinent sample and remedial response locations are depicted on Figure 5, and copies of Figures from previous reports are included in Appendix H.

Cypher Phase II CSA March 2005 " 3.4.1 Contos Property Assessment. Results of this assessment action were cited by the DEQE in 1 the NOR issued to Boston Junk. In 1984 Mr. Nicholas Contos contracted Goldberg-Zoino & Associates (GZA) to conduct an environmental site assessment of Parcels 2769200 and 2769150 under his ownership, which Conrail formerly owned or through which Conrail had an easement. The BRA subsequently obtained Parcel 2769150. The Contos property abuts the north side of B Street and the current (Parcel 2771100) and I former (Parcel 2771000) Energy International properties, and extends eastward from the junction of West Second Street and B Street almost to Fargo Street (Figures 3 and 5). A portion of the property is located inunmmediately north of the Cypher property and B Street extension at the current location of I the Boston Railway Terminal Corp. GZA conducted assessment actions at the Contos property in April, May and July of 1985 and prepared a report for Mr. Contos (GZA 1985). Key findings (as of the dates of the site visits in the 1980s) with regard to the Cypher Site are outlined below.

1. Several sets of railroad tracks extended lengthwise east-west through the Contos property and other tracks had been removed.

1 2. Boston Iron and Metal, Inc. (i.e. Boston Junk) occupied the property between West First Street and Cypher Street (currently the Cypher property) and other properties to the east. I Scrap metal piles were present on the Boston Iron and Metal property. In April of 1985 a large scrap pile was located "between West First Street and Cypher Street" (i.e. on the Cypher property) and transformers were present in the west end of the pile. In July of 1985, I the scrap pile and all transformers had been moved to another location further east on the Boston Iron and Metal property near Louis Street. The GZA report indicates the Cypher property was paved.

I 3.Figure 1of the report that delineates the Boston Iron and Metal scrap pile areas (by shading) does not indicate that scrap piles were present on B Street extension. The figure also I identifies the location of the transformers in the west end of the scrap pile on the Cypher property.

4. The report does not note that dismantling of transformers occurred on the Cypher property. The report does note that the area where transformer dismantling, ignition of oil during dismantling procedures, and fire suppression and associated water runoff occurred, was 3 located east of Louis Street.

5. GZA advanced five soil borings, excavated 12 test pits and installed five groundwater Smonitoring wells on the Contos property. Groundwater ranged from 3 to 6 feet below grade. Approximately 4 to 7 feet of fill were encountered which overlay organic silts and clays. An oily sheen was observed on groundwater in several of the test pits.

6. GZA collected several soil samples for PCB analysis. Most of the samples were collected from the eastern section of the Contos property and/or more than 150 feet north of the SCypher property border. Three surface soil samples were collected from stations located less than 150 north of the Cypher property border (AEFigure 5):

ICypher Phe CSA March 2005 1 Cypher Phase II CSA 18 March 2005 * Composite surface soil sample C-3 (three horizontally spatial locations), 140 to 200 feet north of the property border. PCB (Aroclorl1260) were detected at a concentration of 10.7 mg/kg. * Grab sample S-5, located 100 feet north of the property border. PCB were not detected in the sample. * Grab sample S-4 located in B Street extension, 50 feet north of the property border. PCB were detected at a concentration of 94 mg/kg.

7. GZA attributed the source of the PCB on the Contos property to the West First Street-Cypher Street scrap pile (sic) despite the distances of the sampling stations from the Cypher property border. However, given the long history of use of the Contos property as a railroad yard, location of the high concentration samples along railroad tracks, and the association of PCB with railroad operations, it is the opinion of Alton Engineering that the railroad operations were the likely source of the PCB on the Contos property and possibly the PCB on B Street extension.

Permanent MCP remedial response - soil excavation and disposal - was completed for a substantial portion of the Contos property, in particular the section that abuts the north side of B Street extension, and for the northeast portion of B Street extension, during construction of the SBBR.

3.4.2 South Boston Haul/ByPass Road Remedial Response. From 1989 through 1993, MassHighway constructed the Haul Road, later renamed the South Boston Bypass Road (SBBR), as part of the Central Artery and Third Harbor Tunnel construction project. The roadway originally was used as a construction haul road, currently is used as a trucking bypass road, and extends east- west along the Conrail railroad tracks just north of the Contos, Cypher and current and former Energy International properties. MCP remedial response actions completed as part of the Haul Road construction, are documented in reports prepared by HMM Associates, Inc. (now EarthTech), Cortell Associates, and Camp, Dresser & McKee, Inc. (CDM) for MassHighway.

Assessment. Prior to construction, MassHighway contracted for an initial assessment along the proposed 1.6-mile-long corridor right-of-way. In 1989, HMM Associates (HMM 1989) and Cortell Associates (CA 1989) completed the initial site assessment. Test borings and monitoring wells were drilled, and soil and groundwater samples were collected for analysis. Sampling was not conducted on the Cypher property. One surface soil sample - PCB-2 - was collected from former International Energy Parcel 2771000. PCB were not detected in the sample.

In 1990, CDM (1990) completed additional site assessment in the vicinity of the Boston Junk site, in response to reports of PCB contamination in that area. The "assessment area" included all or portions of B Street extension, Cypher Street public way, the Energy International properties (Parcels 2771100 and 2771000), the Contos property (Parcel 2769200), Commonwealth of Massachusetts property (Parcel 2769010), Boston Junk properties (Parcels 2782000 and 2773001), New York Central Lines, LLC (Parcel 2769100), and Parcel 2769150 (now BRA, former owner unknown). This area was 1,600+± feet long, had a typical width of 170+± feet, and a total area of 6.5± acres.

Cypher Phase II CSA March 2005 The 6.5 ± -acre assessment area was referred to by CDM as the "PCB Runoff Area" because CDM attributed the source of all PCB along the rail lines and corridor in the assessment area to PCB that migrated with surface water or fire suppression water from the Boston Junk properties (sic). Topography across the assessment area is level, and as noted by CDM, channels, watercourses or other evidence of stormwater flowages were not observed. Some of the sample points were over 160 feet north of the Cypher property border.

Key general information (in regard to the Cypher property) from the assessment is outlined below.

1. The majority of the PCB runoff area was situated on the former Energy International property (Parcel 2771000). The center portion of this property was paved and transformer dismantling was conducted in this area.

2. The PCB runoff area also included the current Energy International property (Parcel 2771100) and the portion of the Contos property (Parcel 2769200) located north of B Street extension, and portions of the former Boston Junk properties to the east.

3. The report states that Boston Junk Company operations appeared to extend onto B Street. However, B Street extension was open for vehicle use at the time of the assessment. The location described by CDM appears to be near the east end of B Street at the junction with Cypher Street public way (see next [ 4).

4. CDM stated that transformers were previously [i.e. prior to the date(s) of their assessment] dismantled in the vicinity of GL-45 [located on Energy International Parcel 2771100, near the junction of B Street and Cypher Street public way]. CDM did not provide a reference or otherwise note an observation to support this statement. This statement appears to be incorrect and based on an incorrect interpretation by CDM of information in the HMM Associates report (HMM 1989), that was in turn an incorrect interpretation and statement of information that HMM obtained from the 1985 GZA report for the Contos property assessment. CDM does not reference the GZA report. GZA (1985) observed transformers on the west end of the Cypher property; however, the observed dismantling took place on the former Energy International property in the vicinity of Louis Street. Furthermore, later in the report CDM states "The extent and concentration of PCBs generally coincide with the previously documented site history [i.e. HMM report, from the GZA report] where transformers were salvaged and runoff of stormwater and fire fighting water probably migrated onto the adjoining properties." This is the location in the vicinity of Louis Street, as noted by GZA.

5. Based on a statistical review of their PCB data, CDM opined that PCB contaminated soils detected during the assessment generally are encountered within a narrow band immediately adjacent to pavement edges, and that "In general, it appears that PCB runoff above 2 ppm associated with transformer spill sources is limited to 30 feet from the source."

6. Site topography across the assessment area was described as relatively flat.

Cypher Phase II CSA March 2005 Assessment included drilling 18 test borings, installation of seven monitoring wells, and the I collection of 940 surface and subsurface soil samples from borings drilled at 235 stations in a grid pattern (GL stations) across the assessment area. Most samples were analyzed for PCB using EPA Method 8080, and selected samples were analyzed for total petroleum hydrocarbons (TPH), semi- volatile compounds (SVOC), and heavy metals. Most of the sample stations were located more than 150 feet from the Cypher property borders. PCB concentrations up to 101 mg/kg (GL-43) were detected at stations situated more that 100 feet from the Cypher property border. As described in the Ifollowing subsection Remedial Action, almost all of the assessment areas described below underwent remedial cleanup; thus, PCB concentrations are not representative of current conditions. 5 Samples collected on/within 100 feet of the Site are summarized below and are shown on Figure 5.

Cypher Property - Parcel 2782000. Three deep test borings - HR-1 16, HR-162, and HR-163 - were Idrilled, and one monitoring well was installed. Logs for the three test borings were not included in the CDM report. Four GL stations - GL-47, GL-53, GL-54 and GL-55 - were located in the MassPort easement on the Cypher property. Analytical results for PCB are tabulated below.

I PCB concentrations (mg/k g)- 1990 GL-47 GL-47 GL-47 GL-47 GL-53 GL-54 I 0-1' 1-2' 2-3' 3-4' 0-1' 0-1' 82 16.5 <1.0 <1.0 24.8 10.9 Samples from GL-55 were not analyzed. I Contos Property - Parcel 2769200. Samples collected from four of six GL stations - GL-12, GL-24, GL-30 and GL-36 - located on a line situated 60± feet north of the Cypher property border were 3 analyzed for PCB. Analytical results are tabulated below.

PCB concentrations (mg/kg) - 1990 SGL-12 GL-24 GL-30 GL-30 GL-36 GL-36 GL-36 0-1' 0-1' 0-1' 1-2' 0-I' 1-2' 2-3' 2.8 17 104 31.4 21.7 8.1 <1.0 I Samples from GL-6 and GL-18 were not analyzed. Energy International Property - Parcel 2771100. Two stations were located on a line situated 60± I feet north of the Cypher property border. Stations and PCB concentrations for the 0- to 1-foot depth were: GL-45, 67.2 mg/kg; and GL-51, 0.8 mg/kg.

B Street Extension. Three surface soil samples were collected from the 0- to 1-foot depth interval at the east end of B Street extension. GL stations and PCB concentrations for the 0- to 1-foot depth were: GL-37, 0.7 mg/kg; GL-46, 34.1 mg/kg; and GL-52, 3.8 mg/kg.

I Cypher Street public way. Soil samples were collected from 9 of 12 GL stations, one of which (GL- 63) was drilled to a depth of 6 feet; GL-59 through 65, and GL-69 through 73. Surface soil samples I from the 0- to 1-foot depth interval were collected at each station, and samples were collected to a depth of 6 feet from GL 63. Stations and PCB concentrations are summarized below.

Cypher Phase 11 CSA March 2005 PCB concentrations (m g/kg) - 1990 GL-59 GL-60 GL-61 GL 63 GL-64 GL-65 GL-71 GL-72 GL-73 0-1' 0-1' 0-1' 0-1' 0-1' 0-1' 0-1' 0-1' 0-1' 0.5 2.5 3.7 0.6 1.1 <1 0.6 < 1 < 0.5 Samples from GL- 62, GL-69 and GL-70 were not analyzed.

Four additional samples were collected to a depth of 6 feet at GL-63, and PCB concentrations were all less than 1.0 mg/kg.

Conclusions Regarding the CDM Assessment. Conclusions made by Alton Engineering that are based on the CDM assessment are presented below.

1. A PCB concentration of 101 mg/kg (GL-43) was detected at a station located on the Contos and Energy International properties at a distance of 105± feet north of the Cypher property border. The presence of substantial PCB at such a distance is unlikely to be associated with the Site or former Boston Junk operations. This conclusion is based on: (a) the level topography of the area, (b) the presence of the railroad tracks and ballast berms that would limit water flow and associated PCB transport, and (c) the CDM data regarding PCB migration being limited to 30+± feet of a transformer spill. The PCB probably resulted from the railroad operations or other activity (see Section 5.6).

2. The location of the transformers on the Cypher property, as reported by GZA (1985), was 120± feet from station GL-30 at which the highest (104 mg/kg) PCB concentration was detected along the south borders of the Contos and Energy International properties. Observations or evidence of stormwater or fire suppression water running off the Cypher property onto either the Contos or former Energy International properties was not reported by GZA or CDM (GZA did note runoff from the Boston Junk operation to the Contos property near Louis Street where transformer dismantling was observed by GZA). This data, along with that summarized in I 1 above, also indicates that PCB detected along the south borders of the Contos and Energy International properties may be associated with the railroad operations or other activities that took place on these properties or on B Street extension, and are not necessarily attributable to activities on the Site, or to the former Boston Junk operations.

3. Sampling data collected from the Cypher Street public way indicates that Boston Junk, railroad or other operations, did not substantially affect this area. The maximum PCB concentration was only 3.7 mg/kg, and the majority of samples were less than 1.0 mg/kg.

Remedial Action. In March 1992, approximately 5,200 tons of PCB contaminated soil were excavated for off-site disposal, under the direction of CDM. Remedial action was completed as a Short Term Measure approved by the DEP, in which PCB contaminated soil cleanup was to be completed to a standard of 2 mg/kg, and achieve a permanent solution within the right-of-way of the Haul Road, and the MassPort easement on the Cypher property to permit realignment of the railroad tracks. Soil excavation was conducted to depths of between 2 and 6 feet and confirmation soil samples were collected from the bottom of the excavation. The extent of the remedial area in the vicinity of the Site is depicted on Figure 5. The remedial area included:

Cypher Phase H1CSA March 2005 * The portion of the Contos property (Parcel 2769200) situated north of B Street extension. * The majority of the Energy International property (Parcel 2771100) located north of B Street extension. * A large section of the former Energy International property (Parcel 2771000, now BRA). * The section of the Cypher property (Parcel 2782000) along the MassPort easement.

Remedial action does not appear to have been completed for Cypher Street public way.

A summary closeout report was prepared by CDM in 1992 and submitted to the DEP. Apparently the DEP had concerns with the results of confirmatory soil sampling, because CDM (1993) prepared a follow-up report presenting a revised statistical evaluation of confirmatory soil sample data that was submitted to the DEP. The DEP (1993) subsequently provided a letter to MassHighway stating that "...DEP concurs with CDM's conclusion in the evaluation that, '...the pre- and post- remediation sampling activities undertaken at the Haul Road site were conducted in a manner which allowed confirmation that remediation goals were achieved and documentation that the cross- contamination of clean areas did not occur as a result of remediation activities.' "

The remedial action completed by CDM/MassHighway included cleanup of the MassPort easement that extends through B Street extension and the northeast corner and east side of the Cypher property. Cleanup was completed to permit realignment of the tracks. The cleanup area along the Conrail easement resulted in a MCP permanent solution for approximately 2,000 sf of the Cypher property. This portion of the Cypher property is not enclosed by the chainlink fencing due to the achievement of a permanent solution.

3.4.3 ABB Environmental Services Assessment. In 1997 ABB Environmental Services, Inc. (now Harding Lawson Associates, ABB 1997, 1998) completed an IRA assessment on behalf of BECo. A comprehensive program of soil sampling was completed across all of the properties associated with the Boston Junk/SAK Recycling site, including the Cypher and C & H Trust properties. Direct push (GeoProbe) soil borings were drilled and samples were collected from over 50 locations and analyzed for PCB using EPA Method 8082. Selected samples were analyzed for Total Petroleum Hydrocarbons (TPH) using Method 8100, and EPH using the Method MADEP- EPH-98-1. Results for samples collected on or within 100 feet of the Site are summarized below.

Cypher Property - Parcel 2782000. Ten soil borings - SS-43 through SS-52 - to depths of 3 feet. Samples were collected from one or more of the following depth intervals: 0 - 1 foot, 1 - 2 feet, and 2 - 3 feet. A total of 14 samples were analyzed. Sample data is presented in Table 3A and was used in evaluating current conditions on the Site (see Section 5).

C & H Trust Property - Parcel 2778000. Four soil borings to depths of 1 foot. A TPH concentration of 2,600 mg/kg was detected in the one sample - SS-114 - analyzed for this parameter.

PCB concentrations (mg/kg) - 1998 SS-108 SS-111 SS-113 SS-114 0-1' 0-1' 0-1' 0-1' 0.8 < 0.4 1.5 < 0.4

Cypher Phase II CSA March 2005 - Energy International Property - Parcel 2771100. One soil boring SS-92 to a depth of 3 feet.

PCB concentrations (mg/kg - 1998 - TPH concentrations (mg/kg) SS-92 SS-92 SS-92 SS-92 SS-92 SS-92 S0-1' 1-2' 2-3' 0-1' 1-2' 2-3' 123 2 15 3,770 8,240 176

i Former Energy International Property - Parcel 2771000 (now BRA). Three soil borings to depths of 3 feet. PCB concentrations (mg/kg) - 1998 ISS-89 S-89 SS-89 SS-90 SS-90 SS-90 SS-91 SS-91 SS-91 0-1' 1-2' 2-3' 0-1' 1-2' 2-3' 0-1' 1-2' 2-3' 1.2 <0.4 <0.4 12 <0.4 <0.4 15 <0.4 <0.4

TPH concentrations (mg/kg)- 1998 SS-89 SS-89 SS-89 SS-90 SS-90 SS-90 SS-91 SS-91 SS-91 0-1' 1-2' 2-3' 0-1' 1-2' 2-3' 0-1' 1-2' 2-3' <10 NA NA <10 NA NA 14,200 NA 3,760

Former Boston Junk/SAK Recycling Property - Parcel 2773001 (now BRA). One soil boring SS-33 to a depth of 1 foot; PCB < 0.4 mg/kg.

5Conclusions made by Alton Engineering that are based on the ABB assessment data are presented below.

I1. Activities conducted on the Cypher property have not adversely affected the C & H Trust property. The C & H Trust property has a long history of industrial use and OHM present on i the property can be attributed to activities conducted on that property or to railroad operations.

i 2. The PCB concentrations in samples collected by ABB are similar in magnitude to those detected during the CDM assessment.

I 3.PCB exhibited a variable concentration gradient with depth in boring SS-92: 0-1', 123 mg/kg; 1-2', 2 mg/kg; 2-3', 15 mg/kg. This data indicates PCB may result from fill materials as well as surface deposition.

U MCP remedial response cleanup that achieved a permanent solution was conducted at the locations of the ABB borings drilled on the following properties: * Energy International Property - Parcel 2771100. * Former Energy International Property - Parcel 2771000 (now BRA). * Former Boston Junk/SAK Recycling Property - Parcel 2773001 (now BRA).

3.4.4 Cypher Street Construction. In April 2001, the MCCA constructed a new "Cypher Street" roadway through the Boston Junk/SAK Recycling site, to finalize the connection of D and C Streets Swith the SBBR, which would provide vehicle access during BCEC construction. The new Cypher

SCypher Phase II CSA 24 March 2005 Street is located east of the Cypher Street public way, and approximately 60±+feet east of the Cypher property border. A deceleration lane for the SBBR-Cypher Street junction was also constructed at that time.

The proposed roadway corridor north of the EM-1 Cap extended through a MCP site having OHM contaminated soil. Therefore, remedial action - soil excavation and disposal - was completed prior to construction, under a Construction RAM Plan prepared by Haley & Aldrich, Inc. in November 2000 (H&A 2000), for RTN 3-16224 (a "daughter" RTN provided by the DEP). At locations north of C Street, Cypher Street was constructed on property owned by the BRA - Parcels 2773000, 2773001, 2771000, and 2769150.

The portion of the Cypher Street constructed north of the EM-1 Cap under the Construction RAM, involved MCP assessment and remedial action cleanup for portions of BRA Parcels 2771000 (former Energy International) and 2769150. The remedial area matched with the area of the cleanup conducted by MassHighway for the Haul/SBBR.

Assessment. In year 2000 prior to submittal of the Construction RAM Plan, Haley & Aldrich completed MCP assessment along the proposed corridor for the new Cypher Street. Eleven test borings were drilled, two monitoring wells were installed, and 22 soil samples collected for analysis. Samples were analyzed for PCB using EPA Method 8082, volatile organic compounds (VOC) using EPA Method 8260, semi-volatile organic compounds (SVOC) using EPA Method 8270, EPH carbon ranges, TPH using EPA Method 8100, and heavy metals. Pertinent sample locations are shown on Figure 5.

Six test borings were located within 100 feet of the Cypher property east border. Results for PCB analysis are summarized below. PCB concentrations (mg/kg) - 2000 [HA7 HA7 HA10 HA10 HAll HAll HR21 SS-090 SS-090 SS-090 221-801 221-801 2.5-4' 16-18' 0.5-2.5' 4-6' 0.5-2.5 6-8' 6' 0-1' 1-2' 2.3' 1-3' 4-6' ND ND 0.83 ND 30 ND ND 12 0.2 0.2 51 9.6

Key findings by Haley & Aldrich, in regard to the Site, are presented below.

1. "SVOCs were also analyzed for in all 22 soil samples. Selected SVOCs, most commonly benzo(a)anthracene, benzo(b)fluoranthene, and benzo(a)pyrene, were detected in excess of the S-2/GW-3 criteria in nine samples collected from eight of the eleven test borings. Total SVOCs exceeded 100 mg/kg in two samples. Total SVOCs were detected in sample HA4-S3 (4.0 to 6.0 ft.) and sample HA5-S4 (6.0 to 8.0 ft.) at 210 mg/kg and 600 mg/kg, respectively. Both samples are located beneath the planned depth of excavation for roadway construction."

2. "TPH was analyzed for in four soil samples, primarily for the purpose of assessing future soil management options. TPH was detected in excess of the S-2/GW-3 criteria of 2,000 mg/kg in one sample. This sample is HAll-SI (0.5 to 2.5 ft.) with a TPH level of 5,600 mg/kg"

3. "No VOCs, EPH carbon ranges, or metals were detected in excess of S-2/GW-3 criteria in tested soil samples."

Cypher Phase IUCSA March 2005 Of note, is that the PAH detected by Haley & Aldrich are more common to pyrogenic wastes and materials - coal, coal and wood ash - rather than to petroleum products, in particularly #2 and diesel (Stout, et all. 2004). The PAH more common to petroleum oils - naphthalene, 2-methyl naphthalene, phenanthrene and acenapthene - were not prevalent. The highest concentrations of SVOC were detected in samples collected from depths of 4 to 8 feet. These results are similar to those for the Cypher Site and B Street extension (See Section 5) and indicate the PAH are derived from combustion wastes in the fill materials, or urban fallout - e.g. diesel and coal locomotive exhausts, rather than oil spills.

Remedial Action. The majority of the new Cypher Street was constructed as a temporary road over the EM-1 Cap, in recognition that additional MCP remedial action would be conducted in that area. The section of Cypher Street located north of the EM-1 Cap was completed as a permanent roadway and a MCP permanent solution was achieved for this area. Almost all of the soil excavation was conducted on BRA Parcel 2771000 (former Energy International). It does not appear that remedial action was completed for the portion of Cypher Street public way that was assessed by CDM.

During roadway construction soil in the cleanup area was excavated to depths of 2 to 6 feet below surface grade at locations that were to be under the permanent roadway surface. Approximately 1,008 tons of OHM contaminated soil were excavated for off-site disposal. Soil sampling was conducted upon completion of excavation and confirmed that the PCB cleanup standard of 2 mg/kg had been achieved.

Cypher Phase II CSA March 2005 4.0 PHASE II CSA SCOPE OF WORK AND SUMMARY OF FIELD WORK

The objectives of the Cypher Site Phase II Comprehensive Site Assessment were to: (1) investigate the vertical and horizontal extent of OHM soil contamination, (2) investigate whether a release of OHM to groundwater had occurred, (3) make an evaluation of the extent and magnitude of contamination, (4) describe Site conditions, (5) obtain data necessary for completing initial Risk Characterization, and if necessary a Phase III Evaluation of Remedial Action Alternatives, and (6) address the Phase II CSA requirements of the MCP.

To complete the objectives, Cushing & Jammallo, prepared a Phase II SOW that was approved by the DEP in 2000, and completed the following field tasks in the spring of year 2001:

1. Subsurface investigation. Installed four direct push (Geoprobe) soil borings and one monitoring well on the Site, and seven soil borings and two monitoring wells on the adjacent off-site B Street extension.

2. Media sampling and analysis. Analyzed 10 soil samples and one ground water sample collected from the Site, and 21 soil samples and two groundwater samples collected from the adjacent off- site B Street extension. Five samples were also collected for analysis from the soil pile situated at the east end of the Site.

3. Well gauging.

4. Site survey. Contracted Cullinan Engineering (Auburn, MA) to complete boundary and Site topographic surveys.

Alton Engineering completed the following tasks for the Cypher Phase II CSA in November 2004 and January 2005:

I. Background review and file search. Conducted a file review at the Northeast DEP Regional Office, reviewed files provided by other contractors, conducted a neighborhood windshield survey to evaluate for the presence of sensitive receptors, and reviewed Sanborn Insurance Maps, a MassGIS 21E Site Map, and related documents.

2. Subsurface investigation. Installed four shallow hand auger soil borings on the Site.

3. Media sampling and analysis. Analyzed six soil samples and one ground water sample collected from the Site, and two groundwater samples collected from the adjacent off-site B Street. One additional groundwater sample was collected from a well in B Street extension.

4. Report preparation and Risk Characterization.

In addition to the work completed by Cushing & Jammallo and Alton Engineering, soil and groundwater data from previous assessments was used in the Phase II CSA.

Cypher Phase II CSA March 2005 5.0 SOIL ASSESSMENT

The results of surface and subsurface investigations conducted both on the Cypher Site and on properties adjacent to or in the near vicinity of the Site are reviewed in this section. Data collected from off-site properties provides additional information on soil lithology in the area of the Site.

5.1 Soil Borings and Sample Locations

Soil borings were installed to: (1) collect soil samples for chemical analysis, (2) describe soil lithology, and (3) provide boreholes for installation of monitoring wells. Borings drilled on the Site were advanced using either standard penetration test/hollow-stem auger, direct push (Geoprobe), or hand-auger drilling methods. Soil samples collected from the Site were physically classified using a modified Burmister Soil Classification System. In addition, numerous shallow surface soil samples (0- to 1-foot depth) were also collected for PCB analysis.

Soil boring depths (and well construction details) for borings installed by Cushing & Jammallo and Alton Engineering are summarized in Table 1, and logs for borings are included in Appendix D. Analytical methods and results for soil samples are presented in the Table 3 and 4 series. Laboratory reports are included in Appendix G. Boring and sample locations are depicted on Figure 5.

Data stations utilized in this Phase II CSA are summarized below.

5.1.2 Cypher Site Soil Borings and Sample Stations - Parcel 2782000. A total of 27 soil borings and shallow surface soil sampling stations have been advanced on the Site.

Camp Dresser & McKee, 1990. Three test borings - HR-116, HR-162 and HR-163 - to depths of 10+ feet. Samples were collected from various depth intervals. Three samples were analyzed for PCB. Drilling logs were not available for the borings. These three borings were located outside of the MassPort easement cleanup area. Data from the four GL Stations located in the MassPort easement cleanup area is not used to evaluate current OHM levels because remedial action soil excavation was completed in this area.

ABB Environmental Services, 1997. Ten direct push soil borings - SS-43 through SS-52 - to depths of 3 feet. Sampling depth intervals were: 0 - 1 foot, 1 - 2 feet, and 2 - 3 feet. A total of 14 samples were analyzed for PCB, and selected samples were analyzed for TPH, EPH, and the eight RCRA heavy metals - arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.

RAM Environmental and Arthur D. Little, 2000. Two direct push soil borings - SS-43 and SS-51 - to depths of 2 feet. Two samples were for analyzed for PCB.

Cushing & Jammallo, 2001. Four direct push soil borings - B-8, B-9, B-10 and B-11 - to depths of 12 to 15 feet. A total of 10 samples were analyzed for PCB, EPH with Target PAH, VPH with Target aromatic VOC, and lead.

In addition, Cushing & Jammallo collected six soil samples from the soil pile situated on the east side of the Site. Each sample was analyzed for the same parameters as the soil boring samples.

Cypher Phase II CSA March 2005 Alton Engineering, November 2004. Four hand-auger soil borings -AE-1, AE-2, AE-3 and AE-3A - to depths of 2.4 ± feet. A total of six samples were analyzed for PCB, EPH, PAH, and lead.

5.1.3 B Street Extension Soil Borings and Sample Stations. Data from the GZA (1985) and CDM (1990) assessments is not used herein because MassHighway completed MCP response actions at the sample station locations and a permanent solution was achieved.

Cushing & Jammallo, 2001. Cushing and Jammallo conducted subsurface investigation on the City of Boston B Street extension property, that abuts the north side of the Site, apparently to evaluate the extent of PCB/OHM contamination on that property due to the PCB and TPH detected in ABB soil borings SS-43 and SS-44, located along the border between the two properties. As discussed in Section 3.4, there is little evidence that SAK Recycling or Boston Junk directly utilized B Street extension for storage of junk or related operations. Furthermore, the area in which several of the borings were located is paved with tight fitting granite paving stones and evidence of substantial oil spillage was not observed on the cobbles by Alton Engineering personnel.

Seven direct push soil borings - B-1 through B-7 - to depths of 12 to 15 feet were drilled and two monitoring wells were installed. A total of 22 samples (including one duplicate) were analyzed for PCB, EPH with Target PAH, VPH, and lead.

5.2 Soil Description

In general, most of the property in South Boston consists of filled land; land that originally was shallow open water or wetland associated with Boston Harbor that was filled 100± years ago. Fill materials are widely variable and include natural soil excavated from other locations, building and construction debris and waste, combustion wastes, industrial wastes, municipal rubbish, etc.

Soil on the Cypher Site was described using observations from the soil borings completed by Cushing & Jammallo and Alton Engineering. Soil to a depth of between 7 and 9 feet generally consists of urban mixed sand and gravel fill that frequently contained wood, combustion waste, coal, ash, wood ash, brick chips, asphalt and concrete, and shards of a variety of solid waste and construction debris - scrap metal, bricks, asphalt and concrete rubble, broken glass, etc. The fill layer extends to depths of at least 12 feet at some locations - e.g. C & J boring B-11. Natural marine deposits including sand, silt and clay were encountered below the fill layer.

Particular observations are summarized below.

1. At the locations of borings AE-1 and AE-2, the top 1±-foot thick layer of fill appeared to be more recent sand and gravel material that had been placed over the original soil surface exposed at the time of the Boston Junk operations. The soil was brown to olive brown in color and contained little to no solid waste. PCB and EPH concentrations detected in samples collected from this surface layer were relatively low. Soil beneath this upper layer was dark gray-black, and high PCB and/or EPH concentrations were detected in soil collected from this layer.

Cypher Phase II CSA March 2005 2. Soil at the location of boring AE-3A consisted of dense gray-black fill from the soil surface to the bottom of the boring at 1.8 feet, that contained 30 to 50% solid waste, coal and combustion waste, construction debris, scrap metal, and ceramic shards that appeared to be pieces of electrical insulators similar to those found on transformers. This boring was excavated in the approximate location of the transformers observed by GZA (1985) in the West First-Cypher Street scrap pile during assessment actions for the Contos property.

3. Coal, coal ash, ash (white, gray and black), and/or wood chips, were described in samples collected from 10 of the 11 borings drilled by Cushing & Jammallo, and in two of the shallow borings installed by Alton Engineering.

4. A creosote odor and/or black sand or tarry material were noted in the following C & J borings that were drilled on B Street extension: B-1, 11.5 - 12.0 feet (black sand); B-3, 11.75-12.0 feet (black sand); B-4, 11.5 - 12.0 feet (black sand); B-5, 10-11 feet (black tar- like substance with sand) and B-7, 0-4 feet.

5. A petroleum odor and/or iridescence (probably a pleochroic colored sheen) were noted in the following C & J borings: B-I, 0-8.5 feet; B-2, 12-15 feet (black sand); B-7, 8-10 feet; B-8, 8- 12 feet; B-9, 10-14 (iridescent); B-10, 7-8 feet. Borings B-1, B-2 and B-7 were drilled on B Street extension. Borings B-8, B-9 and B-10 were drilled on the Site.

6. Soil and fill encountered on the Site appears similar to that described in other reports for the vicinity (e.g. GZA 1985, W&S 1999, H&A 2000). All investigations encountered fill to depths of up to 20 feet, overlying organic and marine deposits - stratified sand layers, silt, organic silt, and clay - sometimes containing seashells. Fill materials described by Haley & Aldrich included granular materials containing cinders, coal ash, brick, wood and glass. Fill materials described by W&S across the Boston Junk/SAK properties included sand and gravel containing coal, ash, brick, concrete, bone, glass and wood fragments.

In summary: the Cypher property and surrounding properties consist of former marsh and shallow marine lands that were filled 100± years ago. Boring observations conlirm the presence of fill to depths of up to 12± feet. The fill appears to contain a considerable component of coal, cinders, coal ash, wood ash, and related pyrogenic combustion wastes that probably were derived from coal-fired heating systems and locomotives.

5.3 Cypher Site Soil Sampling - Analytical Schedule and Results

5.3.1 Sample Schedule. A total of 38 surface and subsurface samples representative of current conditions have been analyzed for OHM, as summarized in the following schedule:

Parameter 0-1' 0-2' 1-2' 2-3' 3-5' 5-7' 7-9' 10-12' Total PCB Method 8080/8082 20 2 5 4 4 1 1 1 38 TPH Method 8100 6 2 2 2 - - 1 - 13 EPH/PAH Method DEP/8270 7 1 2 4 1 1 16 VPH Method DEP 4 - 4 1 1 10 Lead -total 8 1 2 4 1 1 17 Total RCRA 8 metals I -- - - - 1

Cypher Phase II CSA March 2005 5.3.2 TPH to EPH Conversion. TPH values for the samples collected by ABB Environmental Services in 1995 were converted to EPH carbon ranges, based on guidelines presented in the DEP October 2002 Final Policy Implementation of the MADEP VPH/EPH Approach (DEP 2002). The following conversion ratio was employed: 30% C9-C18 Aliphatic Hydrocarbons, 40% C19-C36 Aliphatic Hydrocarbons, and 30% C 11-C22 Aromatic Hydrocarbons. This ratio was calculated from the EPH (MADEP-EPH-98-1 analysis) data for samples collected from the Site using the following method. The mean values for three EPH carbon ranges were summed to provide a total mean EPH value for all samples. The mean value for each carbon range was then divided by the mean total EPH value to provide the percentage of the total for the carbon range:

C9-C18 AliphatiCSMEAN + C19-C36 AliphaticsMEAN + C11-C22 AromaticMEAN = Total EPHMEAN. C9-C 18 AliphaticSMEAN / Total EPHMEAN = % C9-C18 Aliphatics

C19-C36 AliphaticSMEAN / Total EPHMEAN = % C19-C36 Aliphatics

Cl1-C22 AromaticsMEAN / Total EPHMEAN = % C11-C22 Aromatics

Use of the EPH data from 17 samples collected from the Site that were analyzed specifically for EPH provided a good estimate of the average ratio between carbon range fractions in the samples collected from the Site that were analyzed for TPH.

5.3.3 Analytical Results. Analytical results are presented in the following Table 3 Series - Soil Samples Collected From the Cypher Property:

Table 3A Cypher Property ABB Soil Samples - Summary of Analytical Results: Polychlorinated Biphenyls - Total Petroleum Hydrocarbons - Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons - Total Metals.

Table 3B Cypher Property C & J Soil Samples - Summary of Analytical Results: Volatile Petroleum Hydrocarbons - Polychlorinated Biphenyls - Lead. Table 3C Cypher Property C & J Soil Samples - Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons. Table 3D Cypher Property RAM/ADL Soil Samples - Summary of Analytical Results. Table 3E Cypher Property Alton Engineering Soil Samples - Summary of Analytical Results: Polychlorinated Biphenyls - Lead. Table 3F Cypher Property Alton Engineering Soil Samples - Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons.

Table 3G Cypher Property C & J Soil Pile Samples - Summary of Analytical Results: Volatile Petroleum Hydrocarbons - Polychlorinated Biphenyls - Lead. Table 3H Cypher Property C & J Soil Pile Samples - Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons.

Cypher Phase HICSA March 2005 Table 5A Cypher Property - Summary of Soil Sample Data: Polychlorinated Biphenyls - Lead - Extractable Petroleum Hydrocarbons - Total Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons.

Tables 5A includes sample population statistical data - frequency, mean and standard deviation - for each analyte. In calculations for all samples except TPH, analytical results described as "not detected" (ND) or "below reporting or detection limits" (BDL or BRL) were included as the full value, rather than /2 the detection limit, to be conservative, and because the incremental difference was determined to be insignificant given the large number of samples. PCB, EPH, several PAH, and lead were detected at significant concentrations in one or more soil samples. Key findings are outlined below and are further discussed in Sections 5.6.

5.3.4 Polychlorinated Biphenyls.

1I. PCB were detected in 29 of 38 samples (76%).

2. A concentration of 12,500 mg/kg was detected in one sample, AE-3A, SS-1, 1.4'-1.8'. This location represents a "hot spot" as defined by the MCP § 40.0006 and sample results are not averaged in with the other sample results.

3. PCB concentrations in the remaining 37 samples, exclusive of the hot spot, ranged up to 72.7 mg/kg with a mean of 11.4 mg/kg and standard deviation of 19.7 mg/kg.

4. The frequency, mean concentration and standard deviation for the samples collected from the 0- to 1-foot depth interval* are, respectively: 18/22 (82%), 10.5 mg/kg, and 21.1 mg/kg [*includes two CDM samples collected from the 0- to 2-foot depth interval].

5. PCB concentrations exceeded 50 mg/kg in only five of the 38 samples, and only one sample -. the hot spot - exceeded 100 mg/kg. Three of the five samples were collected from ABB borings SS-43 and SS-44 located in the northwest corner of the Cypher Property. The fourth sample was collected from RAM/ADL boring SS-51 situated in the southeast quadrant of the property, and the fifth sample was collected from the hotspot, boring AE-3A located in the southwest corner of the property.

6. With the exceptions of the hot spot and the location of RAMIADL boring SS-51 (72.7 mg/kg), PCB concentrations are highest in the northwest corner of the Site.

7. The hot spot location does not appear to be contiguous with PCB at the locations of ABB borings SS-43 and SS-44. Four borings with relatively low PCB concentrations are present at intermediate locations.

8. The area of higher PCB concentrations in the northwest corner of the Cypher Property, appears to be an extension onto the Cypher Property of a much larger area of high PCB concentration present on B Street extension (see Section 5.4).

Cypher Phase II CSA March 2005 9. PCB concentrations detected in borings B-8 and B-9 increased with depth, with the highest concentrations being present in the 3- to 5-foot depth range. This data indicates some PCB on the Site may be due to the historic fill materials, rather than surface activities associated with the junkyard.

10. PCB were detected in the three shallow CDM samples collected from within the Conrail easement, at concentrations of 82 mg/kg, 24.8 mg/kg and 10.9 mg/kg. This area was subsequently excavated and PCB concentrations were reduced to a mean concentration of less than or equal to 2 mg/kg. This data is not used in evaluating current Site conditions.

11. Specific Aroclors (i.e. trade names for various chemically distinct PCB types) were identified in 13 samples.

12. Aroclor 1260 was the most common PCB being detected 11 samples, combined with Aroclor 1254 in five samples, also combined with Aroclor 1242 in three samples, and singly in two samples.

13. Aroclor 1254 was detected in seven samples, combined with Aroclor 1250 in five samples, and singly in two samples.

14. Aroclor 1016 was detected in one sample, in combination with Aroclors 1260 and 1254.

15. Aroclor 1248 was not identified in any samples.

5.3.5 Extractable Petroleum Hydrocarbons

Samples Analyzed for EPH by Method MADEP-EPH-98-1 Carbon Range Max. (mg/kg) Mean (mg/kg) Standard Deviation (mg/kg) C9-C18 Aliphatics 9,685 1,625 2,939 C19-C36 Aliphatics 12,000 2,338 . 3,458 C11 -C22 Aromatics 6,210 1,827 2,009 Mean and Standard Deviation values include Non-Detects at full value.

All Samples Including TPH to EPH Conversion Carbon Range Max. (mg/kg) Mean (mg/kg) Standard Deviation (mg/kg) C9-C18 Aliphatics 9,780 2,288 3,736 C19-C36 Aliphatics 13,040 3,151 4,302 C11-C22 Aromatics 9,780 2,406 2,935 TPH results reported as Not Detected are not included in Mean and Standard Deviation.

1. EPH is present across most of the Site, with both the horizontal and vertical distribution having wide variability. However, with the exception of 132,800 mg/kg total EPH at the location of boring AE-1, the higher concentrations of TPH appear to be more prevalent in the northwest corner of the Property.

Cypher Phase II CSA March 2005 2. The presence of 10,370 mg/kg total EPH in sample B-9, 10-12', as well as the EPH profile of increasing concentration with depth, indicate the subsurface EPH probably results from the historic fill materials, rather than surface activities that occurred on the Site. A similar EPH profile was observed in boring B-8.

3. Total EPH was detected in sample AE-3A, 1.4-1.8'at a concentration of 1,950 mg/kg. This sample contained 12,500 mg/kg PCB. This data indicates there is not a good correlation between PCB and EPH,

5.3.6 Polynuclear Aromatic Hydrocarbons. PAH were detected in all samples. Significant PAH (i.e. high frequency of detection and/or mean concentrations) are tabulated below.

Compound Frequency Max. Mean Standard Deviation (mg/kg) (mg/kg) (mg/kg) Benzo(a)anthracene 11/17=65% 230 35.2 58.6 Benzo(a)pyrene 11/17=65% 200 33.2 53.6 Benzo(b)fluoranthene 10/17=59% 82 30.8 50.1 Benzo(g,h,i)perylene 11/17=65% 130 30.7 59.7 Chrysene 12/17=71% 230 38.3 60.5 Fluoranthene 13/17=76% 520 69.9 133.5 Phenanthrene 13/17=76% 600 67.1 146.6 Pyrene 12/17=71% 460 64.4 119.0 Mean and Standard Deviation values include Non-Detects at full value.

1. A pattern of PAHI distribution was not observed across the Site. Significant PAH were present in both surface and deeper subsurface soil samples.

2. A correlation between PAH and EPH concentrations was not observed.

3. The four PAH detected at significant concentrations are most common to pyrogenic sources - i.e., burned wood, coal and organic materials - rather than petroleum products (LSPA 1999; Stout et all. 2004).

4. The four PAH more common to petroleum products, in particular #2 oil and diesel fuel (DEP VPH/EPH Policy 2001, 2002; Stout et all. 2004), were largely absent from the 17 samples analyzed for these compounds and/or were detected at low concentrations. Data is tabulated below.

Compound Frequency Max. Mean* SD* Mean** SD** (%) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Acenapthene 3/17 = 18 18.6 22.2 48.6 7.0 10.0 Naphthalene 1/17 = 6 0.9 21.9 48.6 0.9 - 2 Methyl Naphthalene 1/17 = 6 0.6 21.9 48.6 0.6 P'henanthrene 13/17 = 76 600 67.1 146.6 85.8 164.4 Mean and Standard Deviation values include Non-Detects at full value.

Cypher Phase II CSA March 2005 * Mean and Standard Deviation for all samples. Some mean values exceed maximum values due to high detection limits in some non-detect samples. * * Mean and Standard Deviation for samples in which PAH were positively detected.

5.3.7 Volatile Petroleum Hydrocarbons. VPH carbon range and target volatile aromatic compound concentrations were near or below detection limits in all samples and within the range of expected background concentrations for an urban industrial location. Maximum detected concentrations and other values of note are tabulated below.

C-Range/Compound Max. Detected (mg/kg) Other Values (mg/kg) C5-C8 Aliphatics Not Detected DL Range 15.25 to 197 C9-C12 Aliphatics Not Detected DL Range 1.88 to 70.4 C9-C10 Aromatics 127 Mean 51.3, Frequency 10/10 Benzene Not Detected DL Range 0.14 to 5.2 Toluene Not Detected DL Range 0.14 to 5.2 Ethylbenzene Not Detected DL Range 0.14 to 5.2 Xylenes Not Detected DL Range 0.14 to 5.2 Methyl tertiary-butyl ether Not Detected DL Range 0.14 to 5.2 Naphthalene 13.2 & 2.9 Detected in two samples Mean includes detection limit for Non-Detects at full value.

5.3.8 Lead. Lead was detected in all 17 samples with the following concentration values: maximum 2,200 mg/kg, mean 605.8 mg/kg, standard deviation 739.3 mg/kg. The distribution of lead did not appear to exhibit a particular pattern. Lead was present in both shallow and subsurface soil samples - e.g. sample C&J B-9, 3-5'.

5.4 Cypher Property Soil Pile Samples - Sampling and Analytical Results

Cushing & Jammallo collected seven composite soil samples (including one duplicate) from the soil pile situated at the east end of the Site. Complete analytical results are presented in Table 3H and 3G and sampling notes are included in Appendix E. The samples were analyzed for PCB, EPH with target PAH, VPH, and lead. Almost all concentrations were near or below detection limits, and were within expected background levels for urban soil. PCB ranged from ND to 0.601 mg/kg. Lead ranged from 21.1 to 97.2 mg/kg. Three PAH - benzo(a)anthracene, benzo(a)pyrene, and benzo(b)fluoranthene - were detected in one sample. The concentrations were all less than the background (Bkg.) concentrations for natural urban soil established by the DEP (2002).

Compound Max. (mg/kg) Bkg. (mg/kg) benzo(a)anthracene 1.0 2 benzo(a)pyrene 0.9 2 benzo(b)fluoranthene 1.3 2

Cypher Phase II CSA March 2005 5.5 B Street Extension Soil Samples - Analytical Schedule and Results

5.5.1 Sample Schedule. Cushing & Jammallo collected a total of 22 surface and subsurface samples (including one duplicate) from soil borings drilled on B Street extension. Samples were analyzed for OHM, as summarized in the following schedule:

Parameter 0-1' 1-2' 2-3' 3-5' 7-9' 10-12' Total PCB Method 8082 8 - - 7 6 1 22 EPH/PAH Method DEP/8270 8 - - 7 6 1 22 VPH Method DEP 8 -- 7 6 1 22 Lead - total 8 -- 7 6 1 22

5.5.2 Analytical Results. Analytical results are presented in the following Table 4 Series - Soil Samples Collected Off Cypher Property: Table 4A B Street C & J Soil Samples - Summary of Analytical Results: Volatile Petroleum Hydrocarbons - Polychlorinated Biphenyls - Lead.

Table 4B B Street C & J Soil Samples - Summary of Analytical Results: Extractable Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons.

Table 5B B Street Extension - Summary of Soil Sample Data: Polychlorinated Biphenyls - Lead - Extractable Petroleum Hydrocarbons - Total Petroleum Hydrocarbons - Polynuclear Aromatic Hydrocarbons.

Tables 5B includes sample population statistical data - frequency, mean and standard deviation - for each analyte. In calculations for all samples except TPH, analytical results described as "not detected" (ND) or "below reporting or detection limits" (BDL or BRL) were included as the full value, rather than 2 the detection limit, to be conservative, and because the incremental difference was determined to be insignificant given the large number of samples.

PCB, EPH, several PAH, and lead were detected at significant concentrations in one or more soil samples. Key findings are outlined below.

5.5.3 Polychlorinated Biphenyls.

1. PCB concentrations in the 22 samples ranged up to 671 mg/kg with a mean of 123.7 mg/kg and standard deviation of 175.6 mg/kg. Concentrations in nine samples exceeded 100 mg/kg, and concentrations in five samples exceeded 200 mg/kg.

2. The extent and general magnitude of PCB contamination present on B Street extension significantly exceeds that identified on the Cypher Site, excluding the hot spot. The area of PCB contamination on B Street extension appears to originate on that property and extend onto the Cypher property, rather than visa versa. As noted above, the hot spot area on the Cypher property does not appear contiguous with the elevated concentrations detected in ABB borings SS-43 and SS-44 and the C & J borings in B Street extension.

Cypher Phase II CSA March 2005 3. Data from boring B-3 indicates that some of the PCB on B Street extension is associated with fill materials, not a surface release - e.g. spillage. A concentration of 103 mg/kg was detected in the 7- to 9-foot depth interval sample, beneath the cobblestone paving.

4. Data from boring B-6 also indicates PCB on this property may be due to fill materials. The PCB and Aroclor distributions with depth - 0-1' depth 296 mg/kg (Aroclor-1254), 3-5' depth 1.96 mg/kg (Aroclor-1254), 7-9' depth 116.4 mg/kg (predominantly Aroclor-1242/1016) - that exhibit a gap in the concentration profile and display Aroclor variation with depth, are not indicative of contamination resulting from a surface release.

5. Boring B-1 also exhibits variation in the Aroclor depth profile; Aroclor 1248 in the 0- to 1- foot depth, and Aroclor 1254 in the two deeper samples.

6. Specific Aroclors were identified in 15 samples. 7. Aroclor 1254 was the most common PCB being detected eight samples, singly in five samples, and combined with Aroclor mixture 1242/1016 in three samples.

8. Aroclor 1248 was detected in five samples, all singly, that included the highest PCB concentration detected on B Street extension. Aroclor 1248 is not used in electrical equipment (see Section 5.6).

9. Aroclor mixture 1242/1016 was detected in four samples, in combination with Aroclor 1254 in three samples, and once singly.

10. Aroclor 1260 was detected in one sample.

5.5.4 Extractable Petroleum Hydrocarbons.

Carbon Range Max. (mg/kg)* Mean (mg/kg) Standard Deviation (mg/kg) C9-C18 Aliphatics 14,100 1,990 3,465 C19-C36 Aliphatics 33,100 4,023 8,105 C 11-C22 Aromatics 17,500 2,710 4,762 Mean and SD values include non-detects at full value.

1. *The maximum EPH concentrations were detected in sample B-6, 7-8' (total EPH 64,700 mg/kg). EPH concentrations in sample B-6, 0-1', while high (total EPH 37,380 mg/kg), were significantly lower than in the 7- to 8-foot depth sample. A similar trend is observed in samples B-5, 0-1' and B-5, 3-5', and in the three samples collected from B-3. These data, which exhibit a trend of increasing concentrations with depth, indicate that a substantial portion - and possibly all - of the EPH contamination detected on B Street extension results from filling or operations conducted on B Street prior to placement of the paving stones.

2. The EPH concentrations detected in the samples collected from boring B-6 exhibited a gap EPH profile; high concentrations were detected in the 0- to 1-foot and 7- to 8-foot depth intervals, with relatively low concentrations in the intermediate 3- to 5-foot interval.

Cypher Phase II CSA March 2005 This data also indicates that fill materials rather than a surface release are the source for subsurface EPH.

3. Soil sample B-2, 12-15', is described in the boring log as "black iridescent Sand with a petroleum odor". Analysis of this sample did not detect particularly elevated levels of OHM analytes, with the exception of 2,050 mg/kg of Cl1-C22 aromatics, 17.3 mg/kg benzo(a)anthracene, 15.4 mg/kg chrysene and 146 mg/kg phenanthrene.

4. A correlation between PCB and EPH concentrations in soil samples was not observed. Several samples having higher PCB concentrations - e.g. B-1, 0-1' - did not exhibit high EPH or PAH concentrations.

5.5.5 Polynuclear Aromatic Hydrocarbons. PAH were detected in all samples. Significant PAH are tabulated below.

Compound Max. (mg/kg) Frequency (%) Mean (mg/kg) SD (mg/kg) Anthracene 803 11/22 =50 53.7 172.0 Benzo(a)anthracene 515 15/22 = 68 43.5 114.1 Benzo(a)pyrene 346 15/22 = 68 29.9 77.0 Benzo(b)fluoranthene 274 14/22 = 64 29.6 66.1 Chrysene 471 15/22 = 68 46.5 109.3 Fluoranthene 1,490 17/22 = 77 40.9 133.3 Phenanthrene 2,710 17/22 = 77 175.2 579.6 Pyrene 1,540 19/22 = 86 110.6 335.9 Mean and SD values include non-detects at full value.

PAH results are similar to those for the Cypher Site: (1) A pattern of PAH distribution associated with a specific release was not observed, (2) significant PAH were present in both surface and deeper subsurface soil samples, (3) a correlation between PAH and EPH or PCB concentrations was not observed, (4) the detected PAH are characteristic of pyrogenic wastes, (5) naphthalene, 2-methyl naphthalene and acenapthene, three of the four PAH most common to petroleum products were not significant, and (6) much of the PAH contamination may result from the historic use of the street by vehicles, from the coal and ash wastes identified in the soil borings, use of the general area as a railroad yard and transit operations, and coal and diesel locomotive engine exhaust.

5.5.6 Volatile Petroleum Hydrocarbons. VPH carbon range and target volatile aromatic compound concentrations were near detection limits in most samples and within the range of expected background concentrations for an urban industrial location. Only two analytes were detected: C9-C 10 aromatics and naphthalene.

C-Range/Compound Max. Detected (mg/kg) Other Value (mg/kg) C5-C8 Aliphatics Not Detected DL Range 5.3 to 262 C9-C12 Aliphatics Not Detected DL Range 1.82 to 94 C9-C10 Aromatics 162 Mean 40.7, S.D. 52.7, Frequency 18/22 Benzene Not Detected DL Range 0.14 to 7 Toluene Not Detected DL Range 0.14 to 7

Cypher Phase II CSA March 2005 Ethylbenzene Not Detected DL Range 0.14 to 7 Xylenes Not Detected DL Range 0.14 to 7 Methyl tertiary-butyl ether Not Detected DL Range 0.14 to 7 Naphthalene 39.2, 29.7 and 144 Detected in three samples Mean includes detection limit for non-detects at full value.

5.5.7 Lead. Lead was detected in all 22 samples with the following concentration values: maximum 3,060 mg/kg, mean 474.6 mg/kg, standard deviation 623.2 mrg/kg. The distribution of lead did not appear to exhibit a particular pattern. Lead was present in both shallow and deep soil samples, and in samples collected from beneath the paving stones - e.g. sample C&J B-1, 7-9'.

5.6 Soil Contaminants of Concern and Potential Sources

Several OHM are present on the Cypher Site and B Street extension, and are or were present on other surrounding properties. A review of potential OHM sources is required by the MCP, and provides information on the extent and nature of OHM on the Site and relationship to that detected on adjacent properties. The sources of OHM, in particular PCB, across the Boston Junk/SAK Recycling site (including the Site) and adjacent properties, have been reviewed by a number of parties (GZA 1985, HMM 1988, CDM 1990, ABB 1998, RAM 1999, Gradient 2002, META 2002, Lightship 2002, and Rizzo 2002). OHM is attributable to several factors and potential sources including: (1) the presence of up to 15± feet of historical urban fill materials - including coal, ash and related combustion wastes - on the Site and surrounding properties; (2) the long history of the Site and general area for industrial uses including the junkyard and scrap metal business, railroad and transit operations; (3) urban fallout; and (4) engine exhausts.

OHM located at depth - e.g. EPH and PAH in sample B-9, 10-12' - most likely is due to the urban fill materials. Surface contamination present in the 0- to 2-foot depth range may be attributable to property operations - e.g. PCB- and/or urban fallout - e.g. PAH. OHM at depths below 3± feet could be attributable to property operations, but is more likely attributable to fill materials.

Identification of Contaminants of Concern (COC) on the Site was based on substance concentration range, frequency of detection, and level of severity in regard to human and environmental toxicity. All of the COC have MCP Method 1 Risk Characterization Standards, are common, and have physical, chemical and toxicological properties that are well understood and documented. The spatial distribution - i.e. horizontal and vertical extent - of these OHM throughout the Site defines the extent of the disposal site. The COC are carried through Risk Characterization and will be the target compounds for remedial action design.

Given the nature and extent of OHM on the Site - e.g. EPH at depths of 12 feet in boring C&J B-9 - it is unlikely that remediation of all OHM on the Site or remediation to background will be feasible. Therefore, remedial action will necessarily focus on the COC for reduction of risk, and employ the underlying assumption that remedial action for the COC will also involve a commensurate reduction of risk for any other OHM.

Three COC were identified and are reviewed below in order of importance.

Cypher Phase II CSA March 2005 5.6.1 Polychlorinated Biphenyls. PCB are the principal COC on the Site, in particular due to the presence of the hot spot having a concentration of 12,500 mg/kg. PCB have also been the principal COC during remedial responses conducted at other abutting properties. Three consultants - META Environmental, Inc. (2002), Gradient Corporation (2002), and Lightship Engineering (2002) - have provided detailed reviews of PCB sources and PCB containing materials, and the specific PCB Aroclors as they relate to various industrial/commercial materials and related operations that occurred or may have occurred on the former Boston Junk/SAK Recycling properties.

PCB were first produced about 1890 and became generally available for commercial use in the 1920s. PCB are common to a wide variety of every-day industrial uses and manufactured products - e.g. inks, dyes, carbon-less carbon paper, tar paper, coatings, paints, plastics, adhesives, lubricants, floor tile, cinder blocks, roofing tar, insulation, and electrical equipment.

Aroclors 1016, 1242,1254 and 1260 have been detected on the Site. Aroclor 1248 was also detected on B Street extension, and all Aroclors have been detected on surrounding properties. Although each Aroclor may have a wide variety of uses, META Environmental (2002) noted the following use specific criteria:

1. 1242 is the only PCB used in carbon-less carbon paper. 2. 1254 and 1260 are used in inks. 3. 1260 is not used in lubricants [other PCB commonly were used in lubricants]. 4. 1242, 1254 and 1260 are all used in dielectric fluids and transformer oils. 5. 1016 is used only in capacitors. 6. 1248 is not used in electrical equipment.

Other environmental consultants identified three primary potential PCB sources:

1. Equipment used for electrical power generation and transmission, in particular capacitors and transformers that originated with BECo, that was brought to Boston Junk for scrap and salvage.

2. Railroad and transit operations conducted on the Site and all of the surrounding properties to the north and east of the Site.

3. Junk and scrap materials, other than transformers and capacitors, brought to Boston Junk for salvage and disposal, or that were otherwise present on surrounding properties.

Based on the results of this Phase II CSA, in particular the subsurface investigations, two additional potential sources are identified:

4. IHistoric fill materials from unknown sources that are present across the Site, B Street extension and the other properties.

5. Specific uses of the Cypher and nearby properties for manufacturing or commercial uses that involved potential PCB containing materials - e.g. tar paper storage/production on the Site and printing (inks) on nearby properties.

Cypher Phase II CSA March 2005 These potential PCB sources are described in greater detail below.

Boston Edison Company. Boston Junk records indicated that Boston Junk commonly purchased large numbers of electrical items including transformers, capacitors, wire, cable, and lead coated cable, from BECo (Gradient 2002). As early as 1983 and 1986, US EPA reports describe large piles of transformers and capacitors on the Boston Junk site, and note the presence of General Electric Pyranol capacitors and BECo regulators that contained or were leaking PCB dielectric fluid. GZA (1985) observed transformers on the west side of the Site and later observed transformer dismantling in the vicinity of Louis Street.

Historical Operation of Railroad and Transit Yards. The use and presence of PCB electrical equipment and fluids in railroad and transit operations are well documented by the US EPA, Department of Transportation and other parties (META 2002). PCB sources associated with railroad operations include: stationary (substation) transformers; on-board transformers; capacitors used in lighting, starter motors, air brake control units, and chopper propulsion systems; voltage regulators; circuit breakers; switches; electromagnets; reclosers; hydraulic equipment and fluids; paints; and lubricating and hydraulic oils for engines and rolling stock. Cranes, hoisting and other heavy equipment utilized by railroad and transit operations could also contribute to PCB soil contamination.

The presence of railroad and transit operations on and in the vicinity of the Site is well documented by other consultants (META 2002, Lightship 2002, Gradient 2002) and a review of historical maps. Two sets of railroad tracks extended along Cypher Street public way and across the northeast corner of the Site and a third set formerly extended into the middle of the Site. The City of Boston operated a maintenance yard for transit equipment on the parcel of land between Cypher and Louis Streets, directly east of the Site. MassPort apparently utilized the Site for railroad operations in the 1940's and 1950's during the period of ownership by the Commonwealth of Massachusetts, as indicated by the presence of railroad lines on the Site during that time period.

Sampling evidence indicating railroad operations had resulted in PCB soil contamination along lines owned or formerly owned by Conrail was provided in reports prepared by GZA (1985) and CDM (1992). During investigation of the Contos property, GZA personnel observed numerous areas of heavy oil staining in and along the railroad tracks. PCB in concentrations up to 240 mg/kg were detected in samples collected from adjacent to, and between, tracks. Samples collected by CDM from railroad-related equipment, during PCB remediation for the SBBR, contained PCB concentrations up to 390 ppm. PCB were also detected in soil samples collected from the railroad right(s).-of-way.

Boston Junk Salvage and Scrap Materials. Boston Junk apparently received a wide assortment of junk and scrap in addition to BECo electrical equipment (Lightship 2002). Materials that are likely to have ended up on the Boston Junk properties, that also may have contained PCB include: painted metals; motor vehicles and associated oils, hydraulic fluids, capacitors, and plastics; appliances (white goods) that contain capacitors and electrical motors. Cranes, hoisting and other heavy equipment utilized by Boston Junk, Conrail, MassPort, and/or the City of Boston could also have contributed PCB.

Cypher Phase II CSA March 2005 Historic Fill Materials. The Site and surrounding properties are all filled land. Subsurface investigations have identified a variety of fill materials and wastes, which probably were placed 60 or more years ago. However, large pieces of scrap metal, similar to the materials salvaged by Boston Junk, reportedly have not been identified at depth in the fill. The PCB profiles with depth in C&J borings B-1, B-3, B-6, B-8 and B-9, and the location of some high concentration samples beneath cobblestone paving, as discussed in Sections 5.3.4 and 5.5.3, indicate PCB at these locations and depths is derived from the historic fill materials, and is not associated with surface spillage resulting from the junk yard operations. Therefore, the historic fill materials must be regarded as a possible PCB source. In addition, asphalt pavement, either in fill materials or as an existing surface, is a possible source of PCB (RAM 1999).

Property Specific Uses. The Site and surrounding properties were used for a variety of manufacturing and commercial purposes, and raw products, materials, and waste are likely to have contained PCB. Records indicate tarpaper was produced andlor stored on the Site, and near by properties were used for printing. Reportedly, the Site was paved and asphalt pavement was detected in soil boring installed on the Site. Asphalt, tarpaper and inks are potentially PCB containing materials. Key conclusions regarding PCB are summarized below.

PCB Source Conclusions.

1. Spillage of PCB-containing dielectric fluid from BECo electrical equipment is the likely source of the PCB hotspot contamination, due to the very high PCB concentration (12,500 mg/kg), predominant Aroclor 1254 and 1260 content (which are used in dielectric fluid), relatively low EPH concentration (1,950 mg/kg total), shallow depth, presence of ceramic shards in the soil that appeared to be derived from electrical insulators of the type common to transformers, and observation of transformers in the hot spot area by GZA in 1985. The hot spot area does not appear to be associated or contiguous with PCB present in the northwest corner of the Site, due to the presence of relatively low PCB concentration in samples located intermediately between the two areas.

2. PCB present in the northwest comer of the Site, at concentrations up to 66 mg/kg, could be derived from either one or more of the five potential sources discussed above, or from activities conducted on B Street extension unconnected with Cypher, SAK, or Boston Junk operations, that migrated onto the Site.

3. PCB present across the remainder of the Site is probably associated with the historic use of the property as a junkyard, in particular the presence of BECo electrical equipment, and/or railroad and transit operations. RAM/ADL sample SS-51 (72.7 mg/kg), and CDM GL samples (max. 82 mg/kg) were situated along the current and former locations of railroad tracks apparently operated by MassPort. PCB also appears to be associated with fill materials. For example, the PCB concentration/depth profile in boring B-9 is not indicative of surface deposition; 0 to 1 foot, ND, and 3 to 5 feet, 27.5 mg/kg.

4. Based on the Aroclor profile in soil samples, PCB present in the highest concentrations on B Street extension- 671 and 371 mg/kg - does not appear to be related to the PCB identified on the Site, does not originate from spillage of transformer oil, and is not necessarily associated

Cypher Phase II CSA March 2005 I

with activities that occurred on the Site. PCB present on B Street extension likely results Sfrom activities that- occurred on B Street extension and possibly railroad and transit operations, or form historic fill materials

Aroclor Cypher Site B Street Extension Number ofsamples 13 15 1016 1 4 1242 3 4 1248 0 5 1254 7 8 1260 11 1

In the area on B Street extension containing the two highest, and three of the four highest, PCB concentrations present on that property, PCB consisted solely of Aroclor 1248, which is not used in electrical equipment, and was not identified on the Site. Conversely, Aroclor 1260 is the predominant Aroclor identified on the Site, which was detected in only one sample from B Street extension. Furthermore, the area of Aroclor 1248 contamination on B Street extension is located beneath the granite paving stones and is present to depths of up to at least 7 to 9 feet, which is different from the PCB distribution on the Site - i.e. predominantly shallow surface soil contamination.

5. Aroclors 1254 and 1242 are common to both the Cypher and B Street extension properties. These two Aroclors are very common to many uses and both were used in electrical equipment.

6. Railroad operations are the likely source of the PCB contaminated soil formerly present on the Contos property at locations north of the Site. This contamination does not appear to be associated with former activities conducted on the Site. GZA and CDM sampling stations at which PCB were detected in soil were located 60 feet or more north of the Cypher property boundary, often at locations in and around railroad tracks. As noted by CDM (1990) PCB typically did not migrate further than 30+± feet from a transformer spill point. The location at which GZA (1985) observed fire suppression water flowing onto the Contos property from the former Energy International-Boston Junk/SAK Recycling properties, was situated east of Cypher Street public way in the vicinity of Louis Street.

7. The low concentrations (max. 1.5 mg/kg) of PCB present on the C & H Trust property indicate activities conducted at the Site have not adversely. affected this property. The history of the C & H Trust property for industrial operations, as well as proximity to rail and transit operations, are sufficient to account for the PCB present on this property.

5.6.2 Extractable Petroleum Hydrocarbons. EPH have been detected on the Site and many of the surrounding properties. EPH sources are similar to those of PCB and include the railroad and transit operations, junkyard operations, historic fill materials, and asphalt pavement. Numerous petroleum spill scenarios involving a wide variety of petroleum products are possible given the long history of industrial use of the Site and surrounding properties. RAM Environmental (Phase II, 1999) attempted to provide a qualitative description of petroleum products that included asphalt,

Cypher Phase II CSA March 2005 motor/lubricating oils, hydraulic oil, dielectric fluid, and undifferentiated hydrocarbons. An attempt to identify the actual petroleum hydrocarbon sources and products for EPH present on the Site and surrounding properties is unlikely to be productive or provide important insight for the purposes of MCP remedial response. Key conclusions regarding EPH are summarized below.

EPH Source Conclusions.

1. EPH present in surface soil on the Site likely is due to the former junkyard and railroad/transit operations. Fill materials appear to be the source of the deeper subsurface EPH contamination - e.g. sample C&J B-9, 10-12'. Soil at depths below 3 feet, and in particular at depths greater than 5 feet, was unlikely to have been affected by surface oil spillage.

2. EPH present on the Site and activities conducted on the Site, are not identifiable as the source for EPH on the off-site properties. The histories of all of the off-site properties - e.g. industrial, junkyard, rail and transit operations, fill materials - indicate that these site-specific activities were likely sufficient to be the sources of EPH identified on those properties.

3. The high EPH concentrations detected in subsurface soil samples collected from borings drilled on B Street extension, and EPH profiles with depth, strongly indicate EPH at these locations is associated with historic fill materials, and not surface activities such as the railroad and junkyard operations.

5.6.3 Polynuclear Aromatic Hydrocarbons. PAH have been detected on the Site and the surrounding properties. Eight of the PAH identified on the Site had relatively high mean concentrations and/or frequency of detection: benzo(a)anthracene, benzo(a)pyrene benzo(b)fluoranthene, benzo(g,h,i)perylene, chrysene, fluoranthene, phenanthrene, and pyrene. These PAH were also prevalent on B Street extension. Three of the four PAH more common to petroleum products (DEP 2001, 2002; Stout et all. 2004) - acenapthene, naphthalene, and 2-methyl naphthalene - were largely absent from samples collected from the Site and B Street extension. Haley & Aldrich (2000) noted similar results for BRA properties located east of Cypher Street public way.

Potential PAH sources include coal, coal ash, wood ash and related combustion wastes, as well as those similar to EPH. Conclusions regarding PAH are summarized below.

PAH Source Conclusions.

1. The predominant sources of the PAH present on the Site are the pyrogenic wastes - coal, coal ash, and wood ash - present in the historic fill materials.

2. Urban fallout, in particular fly ash from coal-fired heating systems, and engine exhausts, in particular from diesel and coal burning locomotives, are likely to be secondary sources. (DEP, 2003).

Cypher Phase II CSA March 2005 3. These conclusions are based on the following data:

a.. Coal, coal ash and/or wood ash were identified in soil samples collected from 10 of the 11 borings drilled by Cushing and Jammallo on the Site and B Street extension. These pyrogenic waste materials are prevalent and ubiquitous throughout the Site.

b. The four PAH more common to petroleum products - acenapthene, naphthalene, 2-methyl naphthalene, and phenanthrene - were either largely absent from soil samples or present in low concentrations.

c. The four PAH that are prevalent on the Site - benzo(a)anthracene, benzo(a)pyrene benzo(b)fluoranthene, and chrysene - are characteristic of pyrogenic wastes rather than petroleum products.

d. The long history of the area for industrial use and as a railroad yard, which would have employed extensive use of coal-fired heating systems and locomotives, as well as diesel engine exhausts, would result in significant urban fallout over the time period.

e. The variable spatial distribution of the PAH, in which high concentrations were present in both shallow and deep soil samples.

4. The apparent major sources of PAH detected on the Site, as well as B Street extension, are coal, coal ash, wood ash, atmospheric deposition from industrial sources and engine emissions. Therefore, the presence of these compounds represents "background" as defined by the MCP § 40.0006.

5. Some of the PAH on the Site may also have been derived from the junkyard activities conducted on the Site, being imported along with oils or other substances on junk and scrap materials. However, the mass of PAH derived from junk is likely to be insignificant as compared to the other background sources.

5.6.4 Lead. Lead sources are similar to those of the other COC, excluding the BECo transformers and capacitors, and include: the railroad and transit operations, junkyard operations, historic fill materials - in particular coal, ash and combustion wastes - urban fallout, and engine exhausts. Lead-based paints are another potential source, and may have been present on structures formally present on the properties, paints used on rail and transit rolling stock and equipment, and on scrap metals brought onto the properties. Conclusions regarding lead are summarized below.

Lead source conclusions.

1. Lead is ubiquitous across the Site, B Street extension, and adjacent properties, and commonly is present in soil located on urban and industrial properties.

Cypher Phase II CSA March 2005 2. Much of the lead may be derived from background sources - e.g. engine emissions, industrial atmospheric deposition, and coal, coal ash, and wood ash materials. The lead mean concentration for the Cypher Site - 605.8 mg/kg - only slightly exceeds the DEP background value of 600 mg/kg for soils containing coal and wood ash.

3. Coal ash or other historic fill materials are the probable source(s) of lead detected in the deeper subsurface soil samples, and in soil samples collected from beneath the paving stones on B Street extension.

4. Junk and scrap materials - e.g. lead wire from BECo - are likely possible sources of lead detected in surface soil samples on the Site. Background sources are also likely to have attributed to lead in surface soils.

5.7 Extent of Soil Contamination

Soil sample locations and associated OHM concentrations are depicted on the following Figures: Figure 6 PCB Plan Figure 7 PCB Aroclor Data Plan Figure 8 EPH Plan Figure 9 Lead Plan

5.7.1 PCB. Figure 6 shows PCB concentrations at sampling locations on and off the Site. With the exception of a portion of Cypher Street, and the western portion of B Street extension, significant PCB in soil were removed during the remedial actions conducted by MassHighway, BRA and MCCA, that resulted in MCP permanent solutions for the remedial areas. Significant PCB contamination remains on the majority of the Site and the western one-half of B Street extension. Figure 7 presents data on the Aroclor(s) identified in the soil samples.

Conclusions regarding the extent of PCB contaminated soil are summarized below.

1. With the exception of one sample station - RAM/ADL SS-53, 72.7 mg/kg - PCB concentrations across the eastern two-thirds of the Site (excluding the MassPort easement/ SBBR remediation area) are all less than or equal to 5.9 mg/kg, with a mean (17 samples, excluding SS-53) of 2.0 mg/kg, equal to the Method 1 Soil 2 and Soil 3 Standards. Inclusion of SS-53 provides a mean of 5.9 mg/kg. While this concentration exceeds the Method 1 Standards, the concentration is well below the Upper Concentration Limit of 100 mg/kg.

2. Two particular areas of PCB contaminated soil are located on the western one-third of the Site: (a) the PCB hot spot, which appears to be relatively small - 80± sf and 3± cubic yards, and (2) the northwest corner of the Site in the vicinity of borings SS-43 and SS-44. These two areas are located in, or very near to, the area where GZA observed transformers in April of 1985.

3. An area of highly PCB contaminated soil is present in the southwest portion of B Street extension. Much of this area is surfaced with tight fitting cobblestone pavement. The extent of this area in the northward direction has not been determined. Concentrations up to a

Cypher Phase II CSA March 2005 I I maximum of 671 mg/kg were detected in this area with a mean (17 samples) for the area of I 149.9 mg/kg. With the exception of the PCB hot spot on the Site, PCB in this area is substantially higher - greater than one+ order of magnitude - than that detected on the Site.

4. PCB contamination appears to extend to depths of 3 to 5 feet - 27.5 mg/kg B-9 - on the Site, and to depths of 7 to 9 feet on B Street extension.

5. Aroclor distribution on the Site appears to be distinctly different from that on B Street extension, as discussed in Section 5.6. The distinction is depicted on Figure 7. In particular, much of the high-level PCB contamination on B Street extension is in the form of Aroclor S1248 that is not common to electrical equipment and was not identified on the Site. Furthermore, the area of Aroclor 1248 is beneath the cobblestone surface. Aroclor 1260, detected in only one sample on B Street extension, is the most prevalent Aroclor on the Site.

5.7.2 EPH. Figure 8 shows Total EPH concentrations at sampling locations on the Site and B I Street extension. Conclusions regarding the extent of EPH contaminated soil are summarized below.

1. EPH are ubiquitous across both properties without any particular distribution pattern.

2. High EPH concentrations are common at depths of 7 to 9 feet on both properties, including the area beneath the cobblestone paving on B Street extension. 55.7.3 Lead. Figure 9 shows Lead concentrations at sampling locations on the Site and B Street extension. Conclusions regarding the extent of lead contaminated soil are summarized below.

1. Lead is ubiquitous across both properties without any particular distribution pattern.

I 2. Lead concentrations on the Site are relatively low, given the Site history, having a maximum of 2,200 mg/kg and a mean of 605.8 mg/kg. 1 3.Lead contamination on the Site appears to be most prevalent in surface and near surface soil. 5.7.4 Extent of Disposal Site. The disposal site boundary is depicted on Figure 10, and is defined I on the west, north and south sides as the Cypher property borders, and on the east side as the western edge of the MassPort railroad easement (MassHighway SBBR remedial area). This determination is based on the conclusions outlined below.

I1. EPH and lead are ubiquitous across the Cypher Street and all properties to the east of West First Street where assessment actions have been completed. Given the long industrial history I of the area, there does not appear to be any evidence to attribute the presence of these substances on off-site properties to activities conducted on or associated with the Site.

I 2. PCB were ubiquitous across the Cypher Street and all properties to the east of West First Street where assessment actions were completed, until completion of remedial response across most of the off-site properties. Several potential sources of the PCB have been I identified, in particular the junkyard and railroad operations.

Cypher Phase II CSA March 2005 Given the property histories, property specific activities are likely sources of the PCB detected therein.

3. Evidence does not indicate that PCB present on B Street extension is attributable to activities conducted on or associated with the Site:

a. General PCB levels are significantly higher in B Street extension than on the Site.

b. Significant PCB are present at depths of 7 to 9 feet on B Street extension, and at some locations beneath cobblestone paving.

c. The pattern of Aroclor distribution on B Street extension does not match that on the Site.

d. Aroclor 1248 that is particularly prevalent on B Street extension was not identified on the Site and is not associated with electrical equipment. Electrical equipment is the most probable source of the PCB on the Site, in particular the PCB hot spot.

e. Aroclor 1260 that is the most prevalent Aroclor on the Site was identified in only one sample collected from B Street extension.

5.7.5 Contaminated Soil Volume - Cypher Site. Estimates of the surface area and volume of PCB contaminated soil are based on the distribution of PCB at a concentration greater than 2 mg/kg. The estimated quantities on the Site for contaminated soil in which PCB exceeds 2 mg/kg are: * Soil surface area 12,000+ sf. * Average soil depth 3± feet. * Soil volume of 36,000 cf (cubic feet) equal to 1,333± cy (cubic yards). * Soil weight of 2,000 tons (@ specific weight = 1.5 tons/cy).

The volume of soil containing OHM (excluding PAH) at concentrations exceeding background is estimated to be at least 2,220 cy equal to 3,333 tons, based on an average depth of 5 feet.

5.8 OHM Migration Routes

OHM contaminated soil could be transported beyond the Site boundaries via two transport mechanisms: (1) wind-blown suspension of contaminated particulates (fugitive dusts), and (2) suspension of contaminated particulates in stormwater runoff. Significant migration via both of these routes is unlikely.

5.8.1 Wind-Blown Particulates. The potential for wind blown transport of significant OHM mass, in particular PCB, off-site is very low because: (1) the portion of the Site containing substantial PCB concentrations in surface soil is quite small, in the range of 3,000 sf, (2) soil on the Site is predominantly sand and gravel, (3) the Site has a dense vegetation of weeds and grasses, and (4) the areas of high PCB concentration commonly are associated with transformer oil that binds soil particles together.

Cypher Phase II CSA March 2005 I I 5.8.2 Stormwater Transport. There appears to be little evidence of stormwater runoff from the I Site onto adjacent properties. Topography of the Site is rather level with a gentle slope to the east toward the soil pile, and the surface soil consists of sand and gravel. Alton Engineering personnel did not observe evidence of soil transport via stormwater runoff - e.g. erosion rills or gullies, small I sand deltas or fans, etc. Most stormwater appears to infiltrate on the Site. The soil pile at the down slope (east) end of the site, and concrete wall along the south boundary would help contain any runoff. Furthermore, a small closed internal drainage gully-like depression extends along the east I end of the Site, just east of the soil pile, and the depression would contain any runoff that advanced to that area. I I I I

Cypher Phase II CSA March 2005 U U I 6.0 GROUNDWATER ASSESSMENT Considerable assessment of groundwater has been conducted in the vicinity of the Site, particularly on the former Boston Junk/SAK Recycling site. However, evaluation of aquifer characteristics has not been emphasized during the assessment actions because: (1) groundwater is not used and is very unlikely to be used for any purpose, (2) human and environmental receptors of groundwater are not present on or in the vicinity of the Site, and (3) groundwater sampling and analysis conducted to date I have not identified significant groundwater contamination. Therefore, resources have been directed toward evaluating and correcting the identified soil contamination.

6.1 Monitoring Well Installation

I One standard 15-foot deep 1-inch diameter well - CJ-2 - was installed on the Cypher Site by Cushing & Jammallo in May 2003, and two standard 15-foot deep 1-inch diameter wells - CJ-1 and CJ-3 - were also installed on B Street extension in May 2003. Well specifications are summarized I in Table 1, and well construction details are included on the boring logs.

Cullinan Engineering established horizontal and vertical (top of PVC riser) control for the three I monitoring wells installed by Cushing & Jammallo, during a boundary and topographic survey conducted in August 2001. Elevations are referenced to an arbitrary benchmark - nail set in the base of the utility pole near the southwest corner of the Cypher property - having an assumed datum of I 100.00 feet.

Either CDM or HMM Associates (the reports are indefinite) installed one 15-foot deep standard 2- I inch diameter monitoring well - HR-116 - on the Site in 1989. Well construction information is not available for this well, and the well has been destroyed.

6.2 Groundwater Quality - Sampling, Analysis and Results

6.2.1 Cypher Site and B Street Extension. Analytical results for groundwater sampling conducted by Cushing & Jammallo and Alton Engineering are presented in Table 6 series.

HMM Associates/Cortell Associates, 1989. A sample from well HR-116 was analyzed for PCB and I TPH. Detected concentrations were: PCB, 5 ug/L; and TPH 32,600 ug/L. Available information did not indicate whether the sample was decanted or filtered. Based on the relatively high concentration, and the results of sampling conducted by Alton Engineering in 2004 & 2005 (described below), and by Weston & Sampson (W&S 2002) (see Section 6.3) for other wells in the Site vicinity, it is probable that the sample was not filtered or decanted, and the PCB, and possibly the TPH, is an artifact of PCB adsorption on particulate(s) rather than dissolved-phase PCB.

Cushing & Jammallo, May 15, 2002. Groundwater samples were collected from wells CJ-1, CJ-2 and CJ-3 and analyzed for PCB, EPH with Target PAH, VPH with Target BTEX, VOC and dissolved lead. Almost all concentrations were very low or at non-detectable levels, with the exception of PCB in sample CJ-1. A concentration of 0.87 ug/L (average of two duplicate samples) was detected. Available information did not indicate whether the sample was decanted or filtered. Alton Engineering observed similar results for well CJ-1 in 2004 & 2005 (described below). It is

Cypher Phase II CSA March 2005 probable that the May 2002 sample was not filtered or decanted, and the PCB is an artifact of particulate contamination.

Alton Engineering, November 22, 2004. Groundwater samples were collected from wells CJ-1, CJ- 2 and CJ-3 and analyzed for PCB, EPH, PAH (8270), VOC and dissolved lead. All concentrations were very low or at non-detectable levels, with the exception of EPH and PCB in sample CJ-1. A PCB concentration of 0.7 ug/L was detected. The well was re-sampled in January 2005 and a filtered sample analyzed. PCB were not detected at a DL of 0.5 ug/L. This suggests that PCB detected in the May 2002 and 1989 rounds, was adsorbed-phase rather than dissolved-phase. Similar results were observed in a review of Weston & Sampson groundwater sampling data from 2001 and 2002 (see below). Lead was not detected in the samples.

Prior to sample collection, the wells were re-developed on November 18, 2005, and then purged on the respective sampling dates. Sampling collection data is included in Appendix E.

6.2.2 Other Off-Site. Well locations are shown on consultants figures included in Appendix H.

HMM Associates/Cortell Associates, 1989. Groundwater samples were collected from eight monitoring wells located north and northeast of the Site along the proposed SBBR corridor, including on the Contos and Energy International properties (well HR-116 on the Cypher Site) was also sampled, as described in Section 6.2, above). Samples from all eight wells were analyzed for TPH and samples from seven wells were analyzed for PCB. TPH were not detected in any samples. PCB were detected in two samples at concentrations of 0.4 ug/L, and 0.03 ug/L. As described in Section 6.2, it is probable these samples were not decanted or filtered.

New England Environmental Technology, February 1996. NEET (1996) installed three monitoring wells on the Boston Junk/SAK Recycling site and collected groundwater samples that were analyzed for PCB (EPA Method 8080), TPH EPA Method 418.1), VOC (EPA Methods 8010/8020, and dissolved 8 RCRA Metals. Well MW-1, located approximately 880 feet east-southeast of the southeast corner of the Site, is closest to the Site. PCB were not detected in the samples. TPH were detected in one samples - MW-3 - at a concentration of 4,000 ug/L. Xylene was the only VOC detected in the samples, at a concentration of 2 ug/L sample MW-3. Concentrations of metals were all below respective RCGW-2 levels.

Weston & Sampson Engineers, 1998 and 1999. Groundwater samples were collected from 13 locations Boston Junk/SAK Recycling site and analyzed for PCB (EPA Method 8080), EPH and VPH (Methods MADEP-VPH-98-1 and MADEP-EPH-98-1), VOC (EPA Method 8260), PAH (EPA Method 8270), and dissolved 8 RCRA Metals (RAM, 1999). PCB were detected in one sample - well 221-WO4 - that is not close to the Site. EPH and several VOC were also detected in this sample. VOC were not detected in the other samples. EPH was detected in one other sample - well 274-W02. VPH was not detected in the samples.

Haley & Aldrich, 2000. Groundwater samples were collected using low flow sampling methods from several monitoring wells located east of the Site on former Boston Junk/SAK properties, including wells HAS-OW and HA5-OW. Samples were analyzed for PCB, SVOC, and EPH carbon ranges. Well HA8-OW is the well nearest to the Site and is located approximately 105 feet northeast

Cypher Phase II CSA March 2005 of the northeast corner of the Site. PCB and EPH were not detected in the samples. Naphthalene and phenanthrene were the only SVOC detected, and were detected at trace levels in sample HA5.

Weston & Sampson, 2001 and 2002. Groundwater samples were collected from 10 monitoring wells located southeast of the Site on former Boston Junk/SAK properties, in the area of the EM-1 Cap. Samples were analyzed for PCB. PCB were not detected in the filtered sample aliquots. However, PCB concentrations up to 4.3 ug/L were detected in the un-decanted and unfiltered sample aliquots. These results support the conclusion that positive detections of PCB in samples is related to adsorbed-phase rather than dissolved-phase PCB.

6.2.3 Groundwater Quality Conclusions.

1. PAH have been detected in unfiltered groundwater samples. The PAH represent background conditions and most likely are associated with particulate adsorbed-phase rather than dissolved-phase substances. PAH concentrations detected in samples collected by Cushing & Jammallo and Alton Engineering all were below respective Reportable Concentrations for Category GW-2.

2. PCB were detected in some unfiltered groundwater samples, and appear to result from the incorporation of adsorbed-phase PCB on particulates. Thus, these results would not be representative of dissolved-phase PCB.

3. The releases of OHM on the Site (and B Street extension), in particularly PCB, do not appear to have significantly affected groundwater. It is noted that the sample detection levels of 0.5 and 1.0 mg/L did not achieve the Method 1 Standard of 0.3 mg/L.

4. The results from numerous groundwater samples collected from the Boston Junk/SAK Recycling site, also indicate that activities conducted in association with the former operations did not result in significant groundwater contamination. Contaminated groundwater does not appear to be a media. of concern on and in the vicinity of the Site.

6.3 Hydrogeology

Due to the lack of significant groundwater contamination on the Site and vicinity, subsurface soils consisting of dense heterogeneous fill materials overlying marine deposits, location of the Site in an old industrialized urban area, numerous subsurface structures - e.g. sewer and drain lines, foundations, stormdrains, etc. - that affect groundwater flow, and lack of human and environmental receptors, an extensive investigation of aquifer characteristics and review of hydrogeological data was not conducted during this Phase II CSA.

Soils (aquifer materials) are described in Section 5.2. Fill materials on the Site extend to depths of 12± feet. Fill is underlain by marine deposits of fine sand, organic silt, silt and clay. Well gauging data (see below) indicates depths to groundwater are in the range of 6 to 11 feet below surface grade, and thus the water table is within the fill layer.

Cypher Phase II CSA March 2005 The Site is situated on a level peninsula of fill that is surrounded by extensions of Boston Harbor on the west, north and east sides. Significant topography - the Telegraph Hill drumlin - is situated south of the Site. Therefore, it is anticipated that groundwater topography should take the form of a shallow mound on the peninsula, with groundwater flowing radially to the west, north and east, depending upon location. However, the extensive alteration and placement of impervious surfaces throughout the area, and associated alteration of drainage and groundwater recharge could alter this simple qualitative model.

Well gauging data collected by Alton Engineering in November 2004 and January 2005 is presented in Table 2. Depths to water ranged from 6.68 feet to 10.81 feet. The limited gauging data indicates the hydraulic gradient (i.e. direction of groundwater flow) is to the northwest toward the Fort Point Channel that is the closest surface water. Given the location of the Site on the peninsula, the observed gradient is realistic. However, the magnitude of the hydraulic gradient - as evidenced by the discrepancy in water table elevations between wells CJ-2 and CJ-3, and CJ-1, - does not appear realistic. Water table elevations are commensurate in the wells CJ-2 and CJ-3; however, the elevation(s) are 2 to 3 feet lower in CJ-1. Well CJ-1 is located only 40±+feet from CJ-2 and 70 ±+feet from CJ-3. The resulting gradient scalar between CJ-1 and CJ-2 of 0.07, is unrealistic for the general area of South Boston, given the level topography of the area and presence of the surrounding ocean that provides constant (in the mean) water levels. It is likely that the steep gradient is a function of local subsurface variation - e.g. fills, old foundations or drain lines, etc. - and is not indicative of the general hydraulic gradient for the Site and surroundings. Water level data from studies associated with the SBBR construction indicated the water table on the peninsula was near level.

Calculations by NEET (1996) for the Boston Junk/SAK Recycling site using data from four monitoring wells, indicated a hydraulic gradient of 0.013 to the southwest. This direction would not appear to be realistic for the model because the direction is toward the land base and high ground of Telegraph Hill, and could be an artifact of the subsurface environment.

RAM (1999) evaluated piezometric data collected by Weston & Sampson from 11 monitoring wells in 1998 and 1999. Depths to groundwater ranged from 3.98 to 10.65 feet. RAM inferred that "groundwater northeast of the Louis and C Street building to flow to the southwest, and groundwater southwest of this building to flow northeast, towards a groundwater trough...Groundwater appears to flow southeast through this trough...". RAM correlated the groundwater trough with a depression in the upper surface of a subsurface layer of silt, clay and fine sand, and concluded "...groundwater flow near C Street and Louis Street appears to be influenced by the presence of this silt, clay and fine sand layer."

Bechtel/Parsons Brinckerhoff (1989) completed a formal piezometric study during construction of the SBBR to evaluate whether tidal fluctuations in Boston Harbor had an influence on groundwater elevations. The study concluded that groundwater levels were not influenced by tidal elevations in Boston Harbor.

In summary, the direction of groundwater flow in the vicinity of the Site is variable, and appears to be influenced by subsurface lithology, structures, and variable recharge areas.

Cypher Phase II CSA March 2005 7.0 PRELIMINARY RISK CHARACTERIZATION

7.1 Introduction

Preliminary Risk Characterization was conducted using Method 3 as described in the MCP, Sections 310 CMR 40.0900 et seq., because mean concentrations of three COC in soil - PCB, lead and C19- C36 aliphatics - exceed the applicable Method 1 Soil-3/GW-3 Standards. Mean concentrations of several PAHl also exceed respective applicable Standards. The Risk Characterization is preliminary because it is based on the results of the Phase II CSA and prior to completing any necessary remedial action.

Risk Characterization was conducted under the following conditions and assumptions:

1. The east portion of the Cypher property within the MassPort railroad easement that has undergone MCP remedial action that achieved a permanent solution by MassHighway, was excluded from further consideration. This area is not part of the disposal site.

2. The PCB hot spot is not included in the Risk Characterization. It is understood that this area represents significant risk to human heath and remedial response will be conducted for this area.

3. Remedial response for the disposal site, including soil excavation and on- or off-site treatment/disposal, and paving would be completed as a Phase IV and Phase V comprehensive response action, or a Release Abatement Measure. Thus, remedial response contractor personnel performing this work would be working directly under the requirements of a Health and Safety Plan and the associated levels of personnel protection. Remedial response contractor personnel are not evaluated as a "construction worker" receptor group in the Risk Characterization. Due to the degree of soil contamination on the disposal site, it is understood that remedial response personnel would employ Level C Personnel Protection - i.e. air purifying respirator, protective coverall, etc. - during the work.

Haley & Aldrich (H&A 2000) completed a "focused" Risk Characterization for the Construction RAM associated with the construction of new Cypher Street. The Risk Characterization concluded that remedial response contractors [i.e. clean up personnel utilizing hazmat personal protection] would need to reduce PCB concentrations in soil to less than 2 mg/kg for the site to be safe for general construction workers.

7.2 Contaminants of Concern

The following COC, and eight PAH are carried through the Risk Characterization: * PCB. * Lead. The majority of lead probably is derived from background sources, the mean concentration on the Cypher Site of 605.8 mg/kg only slightly exceeds the DEP background value for urban soils with coal and wood ash of 600 mg/kg. * EPA Carbon Ranges; C9-C18 aliphatic hydrocarbons, C19-C36 aliphatic hydrocarbons, and C11 -C22 aromatic hydrocarbons.

Cypher Phase II CSA March 2005 * Benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, chrysene, fluoranthene, phenanthrene, and pyrene.

As described in Section 5.6.3, PAH appear to be derived primarily from background sources. However, the eight PAW listed above all have detection frequencies greater than 50%, and most have Method 1 S-3/GW-3 Standards that are less than or equal to 100 mg/kg, and have mean concentrations that exceed or are near the respective Method 1 Standard.

7.3 Disposal Site Information

7.3.1 Physical Characteristics. Disposal site physical characteristics are described in Section 2.0 of this document.

7.3.2 Source and Extent of Release. a. Source of Release. COC sources are reviewed in Section 5.6 and included electrical equipment, railroad and transit operations, junk and scrap metal, fill materials, and historic activities conducted on the Site and surroundings. b. Extent of Contamination. The disposal site is defined by the extent of the COC contaminated soil, and includes the Cypher property west of the MassPort railroad easement, as presented in Section 5.7 c. Background Concentrations. In accordance with the MCP definition of "background" and background concentrations established by the DEP (DEP 2002), the following are background concentrations for COC: * PCB, zero mg/kg. * Lead in urban soils with coal ash, 600 mg/kg. * EPH, background concentrations have not been established. d. Off-Site Migration Pathways. Transport via wind-blown and fugitive dust, and particulates suspended in stormwater runoff are the only two potential migration pathways for contaminated soil. The migration potential for either route is very low, as discussed in Section 5.8. Each of the COC and PAIl has the potential to migrate to groundwater. However, with the exception of the EPH C 11- C22 aromatic hydrocarbons, the COC and PAH have low to very solubility's in water, readily adsorb on to soil particles, and have been assigned low to very low mobility values by the DEP (DEP VPH/EF'H 2002; MCP §40.1514(2); DEP 1994). Therefore, these substances are unlikely to leach to groundwater. Furthermore, as described in Section 6, groundwater sampling and analysis have indicted little to no migration of OHM from vadose zone soil to groundwater, or migration in the saturated zone. Although EPH are present in soil, volatilization and off-site migration of vapors in out door air is very unlikely to be a significant migration pathway.

Cypher Phase 1I CSA March 2005 7.4 Characteristics of OHM

Chemical, physical, environmental fate and transport, and toxicological characteristics are well understood and have been published for each COC. Each substance has a Method 1 Standard established by the DEP, and the documentation for the Standards (DEP 1994) provides the relevant information.

7.5 Identification of Human Receptors

7.5.1 Current Use. The disposal site (and Site) currently is surrounded by chainlink fencing, has a locked gate, is posted with hazard warning signs, is vacant and unused, and does not have buildings or structures. Therefore, there are no direct human receptors under current use for dermal (contact) and oral (ingestion) exposures to soil. An adult could conceivably climb the fence and enter the disposal site. Adult trespass is considered very unlikely, is not a current use of the disposal site, and if it occurred it would be an isolated event. There is no purpose for entering the disposal site; the disposal site perimeter is posted with PCB hazard warning signs, there is nothing on the disposal site to vandalize or steal, the disposal site is open and exposed, and the dense growth of weeds makes walking difficult. Utilities are not present on the disposal site.

However, the disposal site currently is not paved and exposure to airborne particulates in the outdoor air (inhalation exposure) is a potential exposure route under current use. As discussed in Section 5.8 there is a very low potential for migration of significant OHM via wind-blown particulates. Residences, schools, day care centers, and institutions are not located in the vicinity of the disposal site.

"Occasional personnel" including passers-by, trespassers, delivery personnel or other persons who might occasionally walk or drive by the disposal site, represent a human receptor group that could be exposed to air-born particulates under current use. This group includes local workers in buildings who might walk to and from vehicles.

7.5.2 Future Use. Human receptors under future use are variable depending upon the actual disposal site use. However, uses involving children are very unlikely due to the industrial zoning and industrial and commercial uses of the surrounding properties. School, day care center, institutional or similar uses are not permitted by zoning. Therefore, under future use human receptors could include adult employees and visitors to the business(es) established on the property, and occasional personnel.

7.6 Identification of Environmental Receptors

Potential environmental receptors are reviewed in Section 2.5, and are not present on or in the vicinity of the disposal site.

7.7 Identification of Disposal Site Activities and Uses

The disposal site currently is vacant and unused. No activities are conducted on the disposal site. Utilities are not located on the disposal site. Future disposal site uses would be industrial in nature.

Cypher Phase II CSA March 2005 7.8 Identification of Applicable Soil and Groundwater Categories

7.8.1 Groundwater. The disposal site is not located within the geographic boundaries of a potential or current drinking water source area. Thus, category GW-1 is not applicable. Buildings are not located within 30 feet of the disposal site boundary and thus GW-2 is not applicable. Groundwater on all disposal sites is categorized as Category GW-3, for protection of the environment.

7.8.2 Soil. Under current use, soil on the disposal site is not accessible to children because chainlink fencing encloses the disposal site. Soil would only be accessible to adults who trespassed on the disposal site. As discussed in Section 7.5.1, adult trespass is very unlikely. Contamination is present at depths of less than 3 feet and the disposal site is not covered with pavement. Under current use, the frequency of the disposal site use by adults is low, and the intensity would be low. Therefore, Soil Category S-3 is applicable, and soil would be categorized as S-3/GW-3 for the current use of the disposal site. Under potential future industrial use," a child's frequency and intensity of use would both be low. Adult frequency could be high; however, intensity would be low. Soil would be "accessible". Therefore, under unrestricted potential future use, soil would be categorized as S-2/GW-3. However, if the disposal site were paved, soil would become "potentially accessible" and the soil would be categorized as S-3/GW-3.

7.9 ][dentification of Exposure Points, Pathways and Concentrations

7.9.1 Groundwater. There are no direct groundwater exposure points or pathways under current or future use. Therefore, this media was not carried through the Risk Characterization.

7.9.2 Soil. Contaminated soil is an exposure point under current disposal site use. However, there is no pathway under current use, because access to the disposal site is restricted. Under future use without implementing remedial action, potential pathways would include contact with and ingestion of soil, and inhalation of particulates, during construction or industrial activities. Paving the disposal site and implementing an Activity and Use Limitation (AUL) would eliminate these exposure pathways under future use, and thus, would eliminate soil as an exposure point under future use.

7.9.3 Outdoor Air. Outdoor air (inhalation exposure) is a potential exposure point under current use via the pathway of wind blown soil particulates and fugitive dusts derived from the disposal site. However, human receptors are not present on the disposal site under current use. Furthermore, there is a very low potential for the migration of significant OHM in outdoor air to the occasional person receptor group in the vicinity of the disposal site. Under future use without implementing remedial action, outdoor air would continue to be a potential exposure point. Paving the disposal site and implementing an AUL would eliminate outdoor air as an exposure point and inhalation of particulates as an exposure pathway, under future use.

Cypher Phase II CSA March 2005 7.10 Method 3 Risk Evaluation - Human Health

7.10.1 Risk Assessments Completed by Other Consultants for Current Use

Risk Characterization to evaluate the potential human health risk associated with inhalation of OHM contaminated soil particulates derived from the Boston Junk/SAK Recycling site, which included the Site, was completed by ABB Environmental in 1988 (ABB 1998, now Harding Lawson) and by Haley & Aldrich in 2000 (H&A 2000). Both Risk Characterizations are summarized below and indicate the Site currently poses limited human health risk for inhalation exposure.

ABB Environmental evaluated human health risk to residents and children (note: these receptor groups are not present near the disposal site on a.regular basis) and workers in nearby buildings, associated with inhalation of wind-blown dust, during completion of the Imminent Hazard evaluation for the Site and the Boston Junk/SAK Recycling site. The following scenarios were evaluated:

* Short-term - children from age 1 to 5 years. * Long-term - adult residents for cancer and non-cancer risks over a 30-year period. * Long term - nearby adult workers over a 30-year period. * Short-term - nearby adult workers over a 5-year period.

ABB concluded that: "Total cancer risk estimates for off-site exposure to dust are below the appropriate MCP cancer risk limits for longer-term exposures (10-4) and for shorter-term exposures (10-). All hazard index values are below the risk limit of 1. Therefore, conditions at the site do not pose an imminent hazard to off-site receptors." [Note: this paragraph may include a typographic error. The MCP (in 1998) § 40.0995(2)(b) required that the Excess Lifetime Cancer Risk (i.e. long- term) be below 1 in 100,000 or 10-, to represent No Significant Risk.]

ABB evaluated the risks associated with the combined input of dust from the Site (0.3t acre) and Boston Junk/SAK Recycling site, having a combined total area of 4+ acres. Thus, the amount of dust and size of the dispersion plume would have been considerably larger than for the Site alone.

Haley & Aldrich, Inc. prepared a Construction RAM Plan for excavation of OHM contaminated soil, including PCB, during construction of the "new" Cypher Street located adjacent to the east side of the Cypher Site. Their RAM Plan included a Focused Risk Characterization to evaluate the risk to a child trespasser aged 7 to 17 years. The trespasser scenario included both respiratory exposure to fugitive dust, including incidental ingestion, and dermal exposure to contaminated soil, with a 2-hour exposure period per day over a 5-month-long project duration. This scenario represents a sub- chronic exposure.

Haley & Aldrich calculated the individual "Allowable Limit" for 45 OHM in soil (i.e. substance concentration) that would result in no significant risk to the trespasser receptor group for the OHM, based on a target Hazard Index of 0.2 for each individual OHM, and a target Cancer Risk Limit of 10-6 for each individual OHM. Allowable limits were calculated for individual Aroclors (PCB), individual PAH, EPH, and 13 Priority Pollutant Heavy Metals. Risk based allowable limit values* for the trespasser receptor group, and mean concentrations from the Cypher Site are tabulated below.

Cypher Phase II CSA March 2005 OHM Calculated* Cypher Site Mean Surface Soil Allowable Limit Concentration 0' to 1' Depth ing/kg mg/kg Each Aroclor 10 Not Calculated Total Aroclors 96 10.5 All EPH 50,000 All < 2,500 Lead 1,669 478.9 Benzo(a)anthracene 559 22.3 Benzo(a)pyrene 56 23.3 Benzo(b)fluoranthene 559 18.2 Benzo(g,h,i)perylene 8,784 21.3 Chrysene 5,592 24.0 Fluoranthene 129,856 47.8 Phenanthrene 8,784 37.1 Pyrene 133,181 44.3

* Haley & Aldrich subsequently adjusted the risk-based values so that all Allowable Limit values were less than or equal to the UCL (i.e. Final Allowable Limit was the lower of the risk-based and UCL values).

The mean concentrations in surface soil samples collected from the 0- to 1-foot depth interval for all COC on the Cypher Site are well below the respective Allowable Limits calculated by Haley & Aldrich.

Haley & Aldrich apparently did not calculate the Cumulative Risk (Hazard Index and Excess Lifetime Cancer Rate) associated with exposure to all OHM at the calculated Allowable Limits for the full exposure duration. However, nearly all of the mean OHM concentrations for surface soil from the Cypher Site are an order of magnitude or more smaller than the Allowable Limits, indicating the OHM soil concentrations on the Cypher Site are unlikely to represent significant risk.

7.10.2 Alton Engineering Risk Assessment for Human Health

Current Use. Under current disposal site use there is one exposure point - outdoor air - and one Receptor Group - "occasional personnel" in the vicinity of the disposal site. A Method 3 Risk Characterization was completed for this Receptor to evaluate the Risk due to the inhalation of OHM contaminated soil particulates. Inhalation risk is a combination of the risk from inhalation of particulates into the respiratory system (i.e. lungs) and the risk associated with the secondary ingestion of contaminated soil particulates into the gastrointestinal system. A Hazard Index (HI) and Excess Lifetime Cancer Risk (ELCR) were calculated for the Receptor using the following scenario for a person who grows up, lives, and works in the vicinity of the Cypher Site for 30 years.

Exposure Period - Child 6 years = 2,190 days. Exposure Period - Adult 24 years = 8,760 days. Exposure Period - Total 30 years = 10,950 days Exposure Duration-Child 30 minutes/Event = 0.5 hour/Event Exposure Duration-Adult 60 minutes/Event = 1 hour/Event

Cypher Phase II CSA March 2005 Exposure Frequency = 1 Event/Day ELCR Averaging Period = Lifetime = 75 years = 27,375 days HI Averaging Period = Child = 6 years = 2,190 days. Adult = 24 years = 27,375 days

OHM Exposure Point Concentrations = Mean OHM concentration in surface soil samples 0- to 1-foot depth (Table 5A) Relative Absorption Factor = 1.0 Open Air Particulate Concentration = PM10 = 32 ug/m 3 Mean Ventilation Rate-Child = 4.94 L/min for mild exertion Mean Ventilation Rate-Adult = 16.39 L/Umin for mild exertion Mean Body Weight-Child (Male & Female) = 13.98 kg Mean Body Weight-Adult (Male & Female) = 54.29 kg

Calculations and results are presented in Tables RC-1 for HI and RC-2 for ELCR.

The following values were calculated and are compared to the DEP limit for No Significant Risk:

M3 Calculated HI = 0.0012 DEP Value = 1.0 M3 Calculated ELCR = 6.0 x 108 DEP Value = 1.0 x 10-1

Based on the calculated values, a condition of No Significant Risk to human health exists for the Cypher Site under current use.

Future Use. Future disposal site uses could result in contact (dermal) exposure, incidental ingestion (oral exposure), and significant inhalation exposure to airborne particulate concentrations during construction or industrial work. A full Method 3 Risk Characterization for future use was not conducted herein because remedial action for removal of the PCB hot spot, or other remedial actions to reduce OHM concentrations, eliminate soils as an exposure point, or eliminate exposure pathways, has not been conducted. However, removal of the PCB hot spot, paving the disposal site, and implementing an AUL, would eliminate the soil exposure point and associated exposure pathways. This would result in a condition of No Significant Risk under future use. The AUL would need to restrict the disposal site to industrial use and would prohibit activities that would disturb the pavement and underlying soil.

7.11 Method 3 Risk Evaluation - Environment

As discussed in Section 2.5, environmental receptors are not present on or in the vicinity of the disposal site. A Stage I Environmental Screening, pursuant to DEP Interim Final Policy WSC/ORS- 95-141, Guidance for Disposal Site Risk Characterization,was not conducted. Inspection of the Fort Point and Reserve channels was very unlikely to provide information on potential exposure of marine aquatic organisms. Given the distance to the nearest receptor - Fort Point Channel, 1,700 feet - and the very low levels of groundwater contamination on the Site, it is very unlikely that significant dissolved-phase OHM would migrate to the Fort Point Channel. It is noted that EPH and lead concentrations in groundwater samples were well below respective Method 1 GW-3 Standards, and that PCB concentrations were near and likely below the Method 1 GW-3 Standard. Sample interferences prevented the analysis reaching the Method 1GW-3 PCB Standard of 0.3 ug/L.

Cypher Phase 1I CSA March 2005 A condition of No Significant Risk to the environment exists under the current Cypher Site activities and uses.

7.12 Method 3 Risk Evaluation - Public Welfare

Nuisance conditions, in particular noxious odors, are not currently associated with the disposal site. Paving the disposal site and maintaining the fencing, along with the implementation of the AUL will insure that nuisance conditions do not originate from the disposal site in the future. The local community will not receive significant adverse impacts due to current or future disposal site conditions.

Mean concentrations of all COC and PAH on the disposal site are well below respective Upper Concentration Limits, and fewer than 25% of all sample values for each COC exceed the UCL.

A condition of No Significant Risk to public welfare exists under the current Cypher Site Activities and uses.

7.13 Method 3 Risk Evaluation - Safety

The presence of soil contamination on the Site does not represent a Risk to Safety. The Site is vacant lot without structures or buildings, and there are no apparent safety hazards. A condition of No Significant Risk to safety exists under the current Cyplher Site activities and uses.

Cypher Phase II CSA March 2005 8.0 QUALITY ASSURANCE AND QUALITY CONTROL

Laboratory analytical data and the laboratory Quality Assurance/Quality Control (QA/QC) parameters were reviewed to assess data quality and suitability for the intended use. Analytical data and QA/QC narrative reports were prepared by the respective laboratories and are included in Appendix J. A review of the laboratory QA/QC parameters indicated that the laboratory performance criteria for the methods were met in most cases. The following is a synopsis of key QA/QC deficiencies noted in the laboratory data:

* The PCB detection limit was 1.0 ug/L for two groundwater samples, and 0.5 ug/L for one sample. These values exceed the Method 1 GW-3 Standard of 0.3 mg/L, due to matrix interferences.

* Detection limits for PAH in some soil samples exceeded respective Method 1 S-3/GW-3 Standards, due to matrix interferences.

A Method 1 Risk Characterization was not conducted. Therefore, these deficiencies do not affect the outcome of the Risk Characterization.

Cypher Phase 1 CSA March 2005 9.0 FINDINGS AND CONCLUSIONS

1. The Cypher Site (i.e. Cypher property) RTN 3-21146 is a 14,410± square foot lot (Parcel 2782000) that formerly was part of a larger site identified by the DEP as the Boston Junk/SAK Recycling site, 14 Louis Street in South Boston, DEP RTN 3-0580.

2. MassHighway completed MCP remedial response action cleanup in 1992 along a MassPort railroad easement that extends through the northeast corner and the east side of the Site. This area totals 2,000± sf. OHM contaminated soil was excavated and removed for off-site disposal, and a MCP permanent solution was achieved for the area. Further remedial action is not required for this portion of the Site.

3. Releases of PCB, lead, and EPH carbon ranges, and possibly PAH, to soil were identified during subsurface investigations that included the analysis of 38 soil samples collected from the Site/disposal site. PCB, lead, and EPH were determined to be the COC for the disposal site. Assessment activities were performed to delineate the vertical and horizontal extent of the COC in soil.

4. Minimal contamination of groundwater was detected. PCB were not detected in samples at Detection Limits ranging from 0.05 to 1.0 ug/L.

5. The disposal site for the identified releases of OHM to soil is delineated by the west, north and south property boundaries, and the west bound of the MassPort easement, and totals 12,410+ sf.

6. An evaluation of property histories, distribution of OHM - in particular PCB Aroclors - indicates that OHM present on the adjacent properties, in particular B Street extension that abuts the north side of the Site, do not appear to be derived from or associated with activities that took place on the Site. Therefore, the Site (i.e. property) borders and west side of the MassPort easement define the disposal site.

7. A small PCB hot spot was identified having a concentration of .12,500 mg/kg. The hot spot is estimated to be less than 80± sf in ground surface area with a volume of 3±+cubic yards.

8. Mean COC concentrations (excluding the PCB hotspot, and including TPH to EPH conversions) are: PCB, 11.4 mg/kg; lead 605.8 mg/kg; C9-C18 aliphatics, 2,288 mg/kg; C19-C36 aliphatics, 3,151 mg/kg; C11-C22 aromatics, 2,406 mg/kg. All of these concentrations are below respective UCL.

9. PAH were also detected in media samples collected from the Site. The presence of PAH is consistent with the MCP definition of "background", with the PAHI being derived from coal, coal ash, wood ash, and associated combustion byproducts, and it is likely that most of the PAH is derived from the pyrogenic wastes. However, it is possible that some PAH is derived from scrap materials and junk brought onto the Site during its use by Boston junk.

Cypher Phase II CSA March 2005 10. Under current disposal site use, there is no significant risk to human health, public welfare, safety or the environment. The Site is enclosed within chainlink fencing having a locked gate, is posted with hazard warning signs, is vacant and unused, and does not have buildings or structures.

11. Under current Site use - vacant, unused and unpaved - there is one Receptor Group - occasional persons - who may work or live in the vicinity of the Site, or occasionally visit the Site vicinity, and who potentially could be exposed to OHM contaminated soil particulates (i.e. fugitive dusts) derived from the disposal site. A Method 3 Risk Characterization was completed to evaluate the Receptor Group. A HI of 0.0012 and an ELCR of 6.0 x 10-8 were calculated. These results indicate there is No Significant Risk to human health under current use.

11. Further comprehensive remedial response including preparation of a Phase III RAP and a Phase IV RIP, or RAM Plan, and associated remedial action, will be required to close the PCB hotspot portion of the disposal site.

12. Implementation of an AUL coupled with paving the disposal site would be sufficient to prevent risk under future industrial use for the disposal site, and would permit filing a Class A3 RAO to close the disposal site.

Cypher Phase II CSA March 2005 10.0 PHASE II CSA COMPLETION STATEMENT

A Comprehensive Response Action Transmittal Form and Phase I Completion Statement [i.e. Phase II CSA Completion Statement] Transmittal Form (BWSC-108) is attached at the end of this text.

11.0 PUBLIC INVOLVEMENT

The Cypher Site is a Public Involvement Site. Cushing & Jammallo, Inc. prepared a Final PIP, dated December 10, 2001. As required by the PIP, Alton Engineering, on the behalf of Cypher Corporation, will perform the public involvement activities outlined below. Copies of PIP letters are included in Appendix I.

1. A copy of this Phase II Report will be submitted to each of the repositories specified in the PIP. 2. A letter regarding completion of the Phase II Report and its availability for review will be sent to each person on the PIP Mailing List. When a date has been set for a public meeting to present the results of the Phase II CSA, a letter providing notice of the meeting will be sent to each person on the PIP Mailing List. 3. A notice regarding completion of the Phase II Report and its availability for review, and a summary of the Report findings will be sent to each person and entity on the PIP Notification List. When a date has been set for a public meeting to present the results of the Phase II CSA, a letter providing notice of the meeting will be sent to each person on the PIP Notification List. 4. A public meeting will be held to present the results of the Phase I. CSA. 5. A 20-day comment period will be provided. 6. A written summary of PIP comments will be sent to each of the repositories and to each person who provided comment.

12.0 LIMITATIONS AND CONDITIONS

The disposal site evaluation is based on the conditions existing at the subject property on the dates of disposal site visits and field investigation activities. Past conditions are considered on the basis of readily available records, interviews, and recollections. Disposal site conditions are subject to variations and changes over time. This report is based on the current fully implemented environmental regulations. Future regulatory modifications, agency interpretations, and/or attitude changes may affect the environmental status of the disposal site. A statement of limitations is included in Appendix F.

Cypher Phase II CSA March 2005 TABLE 1 Soil Boring and Monitoring Well Specifications Cypher Corporation Phase It CSA - RTN 3-21146

Boring Monitoring Well Depth Top of Depth Bottom of Identification Installation Date Boring Depth Identification Screen Screen

B-1 5-6-02 12.0 B-2 5-6-02 15.0 CJ-1 5.0 15.0 B-3 5-6-02 12.0 B-4 5-6-02 12.0 B-5 5-6-02 12.0 B-6 5-6-02 12.0 8-7 5-6-02 14.0 CJ-3 2.0 12.0 B-8 5-6-02 12.0 B-9 5-6-02 15.0 CJ-2 5.0 15.0 B-10 5-6-02 12.0 B-11 5-6-02 12.0

All measurements in feet Note: Monitoring wells were installed by Cushing & Jammallo, Inc. (C&J). Table 1 was created using C&J field notes.

TABLE 2 Well Gauging and Piezometric Head Elevation Data Cypher Corporation Phase IICSA - RTN 3-21146

WELLHEADWELHEAD DEPTH DEPTH PIEZOMETRIC WELL ID DATE ELEVATIONELEVATON TO TO HEAD I WELL BOTTOM WATER ELEVATION 9/23/2004 97.46 14.60 9.46 88.00 CJ-1 11/18/2004 97.46 14.67 10.72 86.74 11/22/2004 97.46 14.87 10.81 86.65 9/23/2004 97.12 14.70 6.68 90.44 CJ-2 11/18/2004 97.12 14.60 7.57 89.55 11/22/2004 97.12 14.83 7.61 89.51 9/23/2004 96.52 NG NG CJ-3 11/18/2004 96.52 11.45 6.94 89.58 11/221/2004 96.52 11.79 6.98 89.54 All measurements in feet, Wellhead Elevation = top of monitoring well PVC casing (riser). Wellhead elevations surveyed by Cullinan Engineering Co., on July 31, 2001. Elevations referenced to assumed datum of 100,00 feet. NG Not Gauged.

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TABLE 3D.1 Cypher Property RAMIADL Soil Samples Summary of Analytical Results: Cypher Corporation Phase II CSA - RTN 3-21146 Polychlorinated Biphenyls

Sample I.D. SS-43 SS-51 Sample Depth 1-2' 0-1' S3-GW-3 UCL Sample Date 3/6100 3/6100

TotalB1Cogeners Cogeners .6..1 ,, 72.7 ... 2 J i100

All results are in milligrams per kilogram (mglkg). S-3/GW-3 Method 1 Risk Characterization Standard from 310 CMR 40.0975(6), Tables 2-4. UCL Method 3 Upper Concentration Limit from 310 CMR 40.0996(7), Table 6. SS Soil sample collected by RAM Environmental and Arthur D. Little. PCB Polychlorinated Biphenyls, EPA Method 8082 Modified.

TABLE 3D.2 Cvyher Property CDM Soil Samples Summary of Analytical Results: Cypher Corporation Phase I CSA - RTN 3-21146 Polychlorinated Biphenyls - Total Petroleum Hydrocarbons

Sample I.D. HR-116 HR-162 HR-163 Sample Depth 0-2' 0-2' 0-2' S3-GW-3 UCL Sample Date 1989 1989 1989 PC:B Total PCB ND 1.7 4.2 2 100 TPH Total Petroleum Hydrocarbons 15,000 32,600 25,800 5,000 10,000

All results are in milligrams per kilogram (mglkg). S-3/GG-3 Method 1 Risk Characterization Standard from 310 CMR 40.0975(6), Tables 2-4. UCL Method 3 Upper Concentration Limit from 310 CMR 40.0996(7), Table 6. HR Test boring soil samples colleted by HMM Associates or CDM. PCB Polychlorinated Biphenyls, EPA Method 8082 Modified. TPH Total Petroleum Hydrocarbons (method not specified). ND Not Detected. Detection Limit not specified.

Conversion of TPH to EPH values. EPH HR-116 HR-162 HR-163 C9-C18 Aliphatics 4,500 9,780 7,740 C19-C36 Aliphatics 6,000 13,040 10,320 C 11-C22 Aromatics 4,500 9,780 7,740

Conversion based on a ratio of 30% C9-C18 Aliphatics, 40% C19-C36 Aliphatics and 30% C11-C22 Aromatics. Ratio representative of mixed oils present on the Cypher Site including dielectric fluid, diesel and crankcase oils

Conversion based on a ratio of 30% 09-018 Aliphatics, 40% C19-C36 Aliphatics and 30% C11-C22 Aromatics. Ratio based on the results of the EPH by Method DEP-EPH-98-1 analysis from the Cypher Site.

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- m - m m m m m ma a .mm a aM TABLE 6A C & J Groundwater Samples Summary of Analytical Results Cypher Corporation Phase II CSA - RTN 3-21146

Sample I.D. CJ-1 CJ-1 (Dup) CJ-2 CJ-3 Method I I Method 3 Sample Date 5/15/02 5/15102 5115102 5/15/02 GW-3 UCL EPH and PAH C9-C18 Aliphatics 144.0 148 145 150 20,000 100,000 C19-C36 Aliphatics 84.0 86.6 84.8 875 20,000 100,000 Cl 1-C22 Aromatics 48.0 49.5 97.0 50o.o 30,000 100,000 Acenaphthene 5.o 5.2 8.8 5.2 5,000 50,000 Fluorene 5.0 5.2 6.3 5.2 3,000 30,000 Pyrene 5.0 5.2 5.1 5.2 3,000 30,000 VPH and BTEX C5-C8 Aliphatics .o2 69.0 69.0 6,o0 4,000 100,000 C9-C12 Aliphatics 34.0 34.0 34.0 340 20,000 100,000 C9-C10 Aromatics 145 154 242 2o o 4,000 100,000 Lead Dissolved Lead 20 20 20 20 30 300 PCB Aroclors 0.93 0.8 o.5 o. o5 0.3 5 VOC Methylene Chloride 13.6 7.3 18.0 5.3 50,000 100,000 Naphthalene 3.2 3.3 5.0 2.5 6,000 60,000 1,2,4-Trimethylbenzene 1.2 1.2 3.5 Q- NV NV Total Xylenes 1.7 1.5 2.5 05 50,000 100,000

All results are in micrograms per liter (uglL). Only compounds detected at or above Laboratory Method Detection Limit are included. GW-3 Method 1 Risk Characterization Standard for Groundwater Category GW-3, from 310 CMR 40.0974, Table 1. UCL Method 3 Upper Concentration Limit from 310 CMR 40.0996(7), Table 6. NV No Value. GW-3 Standard or UCL not established for compound. CJ Monitoring well groundwater sample collected by Cushing & Jamallo, Inc. EPH/PAH Extractable Petroleum Hydrocarbons including Target Polynuclear Aromatic Hydrocarbons by Method MADEP-EPH-98-1. VPH Volatile Petroleum Hydrocarbons including Target Aromatic Hydrocarbons and MTBE by Method MADEP-VPH-98-1. VOC Volatile Organic Compounds by EPA Method 8260B. PCB Polychlorinated Biphenyls by EPA Method 8082. Lead Dissolved (filtered) concentration by Method SM 3111B. 0. - Laboratory Method Detection Limit. Analyte not detected at concentration equal to or above specified value.

Trip Blank analyzed for VOC. All compounds were ND, with the exception of 28.3 ug/L methylene chloride.

Wells CJ-1 and CJ-3 located on City of Boston B Street (extension). Well CJ-2 located on Cypher property.

C:\Cypher\Phase IICSAXTables\$TSA-CJ GW.xlS 3/15/05 TABLE 6B Alton Enqineering Groundwater Samples Summary of Analytical Results Cypher Corporation Phase II CSA - RTN 3-21146

Sample I.D. C&J-1 C&J-2 C&J-3 Md I Method 3 SSample Date 11/22/04 11/22/04 GW-3 UCL EPH C9-C18 Aliphatics 2800 20 20 20,000 100,000 C19-C36 Aliphatics 5700 22 85 20,000 100,000 C11-C22 Aromatics 2800 78 140 30,000 100,000 PAH Acenaphthene 12 13 10o 5,000 50,000 Lead Dissolved Lead 30 0 3o 30 300

PCB ,. Arociors - 11/22/04 7 1 1' 0.3 5 Aroclors - 1/5/05 oJ 'vs A s 0.3 5 VOC Benzene 1 1 1 7,000 70,00 n-Butylbenzene 3 5 1 NV NV Ethylbenzene . 3 1 4,000 100,000 Toluene 1 1 I 50,000 100,000 Naphthalene 1 18 1 6,000 60,000 Total Xylenes 1 3 1 50,000 100,000

All results are in micrograms per liter (uglL). Only compounds detected at or above Laboratory Method Detection Limit are included. GW-3 Method 1 Risk Characterization Standard for Groundwater Category GW-3, from 310 CMR 40.0974, Table 1. UCL Method 3 Upper Concentration Limit from 310 CMR 40.0996(7), Table 6. VS Not Sampled. NV No Value. GW-3 Standard or UCL not established for compound. C&J Monitoring well groundwater sample collected by Alton Engineering. EPH Extractable Petroleum Hydrocarbons by Method MADEP-EPH-98-1. PAH Polynuclear Aromatic Hydrocarbons by EPA Method 8270. VOC Volatile Organic Compounds by EPA Method 8260B. PCB Polychiorinated Biphenyls by EPA Method 8082. Lead Dissolved (filtered) concentration by EPA Method 200.7. 7 Value exceeds Method 3 Upper Concentration Limit. 0. - Laboratory Method Detection Limit. Analyte not detected at concentration equal to or above specified value.

Trip and Equipment (field) Blanks analyzed for VOC. All compounds below Detection Limits.

Wells CJ-1 and CJ-3 located on City of Boston, B Street (extension). Well CJ-2 located on Cypher property.

Only compounds detected at or above Laboratory Method Detection Limit are included.

C:ACypher\Phase IICSA\Tables\$T5B-AE GW.xlS 3/15/05 - I - II

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I- 0 L) APPENDIX A

References Phase II Comprehensive Site Assessment - Cited References

ABB 1997. Immediate Response Action Plan, ABB Environmental Services, Inc., July 10, 1997.

ABB 1998. Immediate Response Action Status Report, ABB Environmental, Services, November 10, 1997.

AE 2004. Letter to Ms. Karen Stromberg, DEP, RE: Phase II CSA Update #1, Release Tracking No. 3-21146, NON-NE-04-3A186, Cypher Corporation Property, Corner of B Street and North End of West First Street, South Boston, Massachusetts, Alton Stone, LSP, Alton Engineering, for Cypher Corporation, November 16, 2004.

AE 2004. Letter to Public Involvement Plan Notification List (Mayor Thomas Menino, Mr. Jack Tracy, Office of Environmental Health, Senator Stephen Lynch, Representative John Hart, Jr., and Brian R. Mahoney, Lower End Political Action Committee, RE: Phase II Field Work and Health and Safety Plan Release Tracking No. 3-21146 Cypher Corporation Property Corner of B Street and North End of West First Street South Boston, Massachusetts, Alton Stone, LSP, Alton Engineering, for Cypher Corporation, November 16, 2004.

AE 2004. Letter to Public Involvement Plan Mailing List, RE: Phase II Field Work and Health and Safety Plan Release Tracking No. 3-21146 Cypher Corporation Property, Corner of B Street and North End of West First Street South Boston, Massachusetts, Alton Stone, LSP, Alton Engineering, for Cypher Corporation, November 16, 2004.

AE 2004. Letter to the DEP, RE: Proposed Remedial Response Schedule - NON-NE- 04_3A186, Release Tracking No. 3-21146, Cypher CorporationProperty, Corner of B Street and North End of West First Street, South Boston, Massachusetts, Alton Stone, LSP, Alton Engineering, for Cypher Corporation, October 15, 2004.

BPB 1989 Interoffice Memorandum, Subject: South Boston By-Pass Road, Existing GroundwaterLevels, Bechtel/Parsons Brinckerhoff, August 16, 1989.

CA 1989. Groundwater Quality Reconnaissance Report, Cortell Associates, prepared for Massachusetts Highway Department, 1989.

CA 1989. Groundwater Quality for South Boston Haul Road, Cortell Associates, prepared for Massachusetts Highway Department, 1989. Caldwell Bioremediationand Hazardous Waste Cleanup Division - SAK Recycling 1995 Corporation,Louis Street, South Boston (Summary of Actions to Date), Caldwell Environmental, Inc., July 19, 1995. The following documents are included as attachments: * Summary of Events * Re: South Boston - Boston Junk, Louis Street, Boston, MA, Notice of Responsibility and Interim Deadlines, prepared by Stephen Spencer (DEP), undated. * Re: SAK Recycling Corporation, prepared by William Stowe (BECo), dated December 22, 1994. * Letter from Linda Benevides (DEP) to Michael Hannon, dated April 25, 1995.

CDM 1990. Assessment Alternatives for PCB Remediation, Camp, Dresser & McKee, Inc., prepared for Massachusetts Highway Department, December 1990.

CDM 1992. Summary Documentation Report For Close-Out of PCB Remediation Site, South Boston Haul Road, Central Artery/Tunnel Project, Camp, Dresser & McKee, Inc., prepared for Massachusetts Highway Department, June 1992.

CGK 2001 "Draft for Review and Comment Only" Phase II Scope of Work for SAK Recycling/FormerBoston Junk PropertyAt the Northern End of West FirstStreet, South Boston, Massachusetts,.Release Tracking No. 3-0580, CGK Environmental, Inc. (now Brown and Caldwell) for SAK Recycling, January 16, 2001.

CGK 2001. Phase II Scope of Work for SAK Recycling/Former Boston Junk Property At Northern End of West First Street, South Boston, Massachusetts, Release Tracking No. 3-0580, CGK Environmental, Inc., April 6, 2001.

CGK 2001. Letter to the DEP Re: Proposed Schedule for Implementation of Public Involvement Activities, CGK Environmental, Inc., June 7, 2001.

CGK 2001. Public Involvement Plan, SAK Recycling/Former Boston Junk, Property at Corner of B Street and Northern End of West First Street, South Boston, Massachusetts, Release Tracking No. 3-21146, Former Release Tracking No. 3- 0580, CGK Environmental, Inc. and Cushing & Jammallo, Inc., December 10, 2001.

C&J 2003. Letter to the DEP Re: SAK Recycling/Former Boston Junk - Change in LSP of Record, Cushing and Jammallo, Inc., June 2, 2003.

DEQE 1985. Notice of Responsibility to Mr. Frank Freeman of Boston Junk RE: Release/Threatof Release of Oil/HazardousMaterial at Boston Junk, South Boston, Department of Environmental Quality Engineering, February 9, 1985. DEQE 1987. Notice of Responsibility to Boston Edison Company RE: Boston Junk 14 Louis Street Notice of Responsibility, Pursuant to M.G.L. Chapter 21E, DEQE Case No. 3-0580, Department of Environmental Quality Engineering, December 1, 1987.

DEQE 1988. Site Inspection Report - Memo to Harish Panchalfrom Mark Casey, Department of Environmental Quality Engineering.

DEP 1994. Background Documentationfor the Development of the MCP Numerical Standards, Department of Environmental Protection, April 1994.

DEP 1994. Notice of Responsibility prepared by Stephen Spencer - Re: South Boston - Boston Junk, Louis Street, Boston, MA, Notice of Responsibility and Interim Deadlines, Department of Environmental Protection, undated, but otherwise referenced as 1994.

DEP 1991 Letter from Steven Lipman, P.E. DEP to Peter Zuk, Director, Massachusetts Highway Department, Re: CA/THT SBHR PCB Remediation Close-Out Report, Department of Environmental Protection, November 4, 1993.

DEP 2000. Letter from the DEP to Walter A. Fiore, Urgent Legal Matter: Prompt Action Necessary, Certified Mail: Return Receipt Requested, Notice of Responsibility Under M.G.L c.21E and 310 CMR 40.000, Interim Deadlines To Conduct Response Actions. RE: Boston; SAK Recycling/FormerBoston Junk; RTN 3-0580, Department of Environmental Protection, April 18, 2000.

DEP 2001. Letter to CGK Environmental, South Boston, SAK Recycling/FormerBoston Junk, West First Street, DEP RTN 3-0580 - Approval to Submit CGK Environmental's April 6, 2001 Draft Phase II Scope Work for SAK Recycling/Former Boston Junk for Public Comment, Department of Environmental Protection, May 23, 2001.

DEP 2000. Implementation of the MADEP VPFH/EPH Approach, Final Draft, Department of Environmental Protection, June 2000.

DEP 2002. Implementation of the MADEP VPH/EPH Approach, Final Policy, Department of Environmental Protection, October 31, 2002.

DEP 2002. Implementation of the MADEP VPH/EPH Approach, Background/Support Documentation for the Development of Public Guidelines & Rules of Thumb, Policy #WSC-02-411, Department of Environmental Protection, October 2002.

DEP 2002. Technical Update Background Concentrations of Polycyclic Aromatic Hydrocarbonsand Metals in Soil, Department of Environmental Protection, May 2002.

DEP 2003. Best Management Practicesfor Controlling Exposure to Soil During the Development of Rail Trails, Department of Environmental Protection. DEP 2004. Letter to Walter A. Fiore, RE: SOUTH BOSTON SAK Recycling/Former Boston Junk, West First Street (City of Boston Assessors's Office LD. #06/02782/00) DEP RTNs 3-21146 & 3-0580, NON-NE-04-3A186a, Department of Environmental Protection, November 17, 2004.

DEP 2004. Letter to Walter A. Fiore, RE: SOUTH BOSTON, Former Boston Junk, 14 Louis Street, DEP RTN 3-00580 NON-NE-04-3A186, Department of Environmental Protection, June 16, 2004.

Gradient Expert Opinion of Dr. Eric L. Butler Evaluation of PCB, TPH, and Lead 2002. ContaminationBoston Junk Site, Gradient Corporation, September 13, 2002.

GZA 1985. Environmental Site Assessment Conrail Properties,South Boston, Massachusetts, prepared for Nicholas Contos, Goldberg Zoino and Associates, Inc., November 1885.

H&A 2000. Construction Release Abatement Measure Plant,Boston Convention & Exhibition Center, South Boston, Massachusetts, RTN 3-16200, prepared for the Massachusetts Convention Center Authority, Haley & Aldrich, Inc., June 2000.

H&A 2000. Construction Release Abatement Measure Plan, Cypher Street, Boston Convention & Exhibition Center, South Boston, Massachusetts, RTN 3-16224, prepared for the Massachusetts Convention Center Authority, Haley & Aldrich, Inc., November 2000.

H&A 2000 Construction Release Abatement Measure Plan, Status Report No.], Boston Convention and Exhibition Center, Boston, MA, Release Tracking Number 3- 16200, Haley & Aldrich, Inc., September 2000.

HMM 1989. Environmental Site Assessment, Haul Road, South Boston, Massachusetts, HMM Associates, prepared for the Massachusetts Department of Public Works, June 21, 1989.

HMM 1989. Preliminary Risk Assessment, Haul Road, South Boston, Massachusetts, HMM Associates, prepared for Massachusetts Department of Public Works, October 20, 1989.

K&S 2004. Letter to the DEP, Re: Sak Recycling Corp. 14 Louis Street, South Boston, Jack Merrill, Esquire, Kushner & Sanders LLP, July 9, 2004.

Lightship Expert Report Sources and Divisibility of Contaminationat the Former 2002 Boston Junk/Boston Iron and Metal Company 14 Louis Street Boston, Massachusetts, Lightship Engineering, LLC, September 13, 2002. Lightship Supplemental Expert Opinion FormerBoston Junk/Boston Iron and Metal 2002 Company 14 Louis Street Boston, Massachusetts, Lightship Engineering, LLC, November 27, 2002.

LSPA 1999. Methods for Evaluating Applications of the Coal Ash and Wood Ash Exemption Under the Massachusetts Contingency Plan, LSP Association, October 19, 1999.

META 2002 Expert Report - The Presence and Sources of PolychlorinatedBiphenyls (PCBS) at the Former Boston Junk Site and Adjacent Properties (The Site), META Environmental, September 12, 2002.

NEET 1996. Phase I Initial Site Investigation Report and Tier Classification Submittal for Property Located at: 14 Louis Street, South Boston, MA, New England Environmental Technologies Corporation, November, 1996.

NEET 1997. Letter to Richard Chalpin DEP Re: IRA Plan Denial, New England Environmental Technologies Corporation, March 27, 1997.

NUS 1986 Preliminary Assessment; Boston Junk Property, NUS Corporation Superfund Division, March 17, 1986.

RAM 1999. Phase II Comprehensive Site Assessment Report, Boston Junk/Boston Iron and Metal Company, 14 Louis Street, Boston, MA, RTN 3-0580, RAM Environmental, LLC, July 12, 1999.

RAM 1999. Phase III Remedial Action Plan Boston Junk/Boston Iron and Metal Company, 14 Louis Street, Boston, MA, RAM Environmental, LLC, July 12, 1999.

Rizzo 2002 Document Review and Opinion of Raymond C. Johnson, P.G., L.S.P., Former Boston Junk/SAK Recycling Property South Boston, Massachusetts, Rizzo Associates, August 1, 2002.

W&S 1998. SAK Recycling Corporation - Draft Sampling and Analysis Plan, Addendum Regarding Stockpile Sampling and Deep Soil Borings, RTN 3-0580, Weston & Sampson Engineers, Inc., November 16, 1998.

W&S 1999. Data Package - W&S Subsurface Investigation, Weston & Sampson Engineers, Inc., letter from Goulston & Storrs to DEP-NERO, April 22, 1999.

W&S 1999. Release Abatement Measure Plan: Boston Convention & Exhibition Center, Former Energy International Site (444 C St.) and Former Boston Junk/SAK Recycling Site (14 Louis St.), Report to the Boston Redevelopment Authority, Weston & Sampson Engineers, Inc., 1999. W&S 2000. Release Abatement Measure Plan: Boston Convention & Exhibition Center, Former Boston Junk/SAK Recycling Site RTN 3-0580 - Parcel 27, Parcel 24, Parcel 25, Parcel 26, South Boston, MA, Report to the Boston Redevelopment Authority, Weston & Sampson Engineers, Inc., January 2000.

W&S 2002. Letter Re: July 2002 PCB Groundwater Monitoring Data, Weston & Sampson Engineers, Inc., January 17, 2003.

Additional Documents Letter from South Boston Environmental Health Watch c/o South Boston Public Health Initiative to Mr. Auerbach, dated February 14, 2000.

Letter from DEP to Mr. Tracy, Re: Boston SAK Recycling, 14 Cypher Street, April 12, 2000.

Letter from DEP to Mr. Murphy, Re: Notice to Proceed(IRA SS# 100550), April 28, 2000.

Letter from CGK Environmental, Inc. to Richard Chalpin DEP Re: South Boston - SAK Recycling/Former Boston Junk, West First Street, June 7, 2001.

Letter prepared by CGK Environmental, Inc. Re: South Boston - SAK Recycling/FormerBoston Junk, August 1, 2001.

Letter from Cushing & Jammallo, Inc. to DEP Re: SAK Recycling/FormerBoston Junk, June 1, 2001.

Letter prepared by Cushing & Jammallo, Inc. Re: SAK Recycling/Former Boston Junk, June 18, 2001.

Letter prepared by Cushing & Jammallo, Inc. Re: SAK Recycling/FormerBoston Junk, July 16, 2001.

Letter prepared by Cushing & Jammallo, Inc. Re: Local Information Repository for Public Involvement Site, August 6, 2001.

Letter from Cushing & Jammallo, Inc. to Richard Chalpin DEP Re: SAK Recycling/Former Boston Junk, September 28, 2001.

Letter from Cushing & Jammallo, Inc. to Petitioner and/or Interested Parties Re: SAK Recycling/Former Boston Junk, September 28, 2001

Letter prepared by Cushing & Jammallo, Inc. Re: Local Information Repository for Public Involvement Site SAK Recycling/FormerBoston Junk, December 14, 2001. Letter from Cushing & Jammallo, Inc. to Mr. Chalpin DEP Re: SAK Recycling/Former Boston Junk, December 14, 2001.

Letter from Cushing & Jammallo, Inc. to Petitioner and/or Interested Parties Re: SAK Recycling/FormerBoston Junk, December 14, 2001.

Expert Report of Dr. Eugene Meyer, Volume I Attachments 1-77, and Volume II Attachments 78- 117, dated September 13, 2002. APPENDIX B

Pfhotographs ! 7

#1 - CYPHER SITE AND B STREET EXTENSION, VEWED EAST TO WEST

CORNER OF W$1 FIRT AND B STREETS IN UPPtR RIGHT tNW) CO(NEF; B 5TREET Ex1EN'ON (COLUS) ALCE4G FMGC4T(N) 5JDf

#2 - B STREET EXTENSION AND SITE, VIEWDL EAST TO WEST COEBI5TNE PAOVNC; UP UARKS NORTH SCONDARY UNE OF SITE; B STREET AND GATE IN UPPtR RIGH4T(N*) CORNE #3 - CYPHER SITE, VIEWED FROM MIDDLE NORTH TO SOUTH I

#4 - CYPHER SITE, VIEWED ALONG CENTERLINL FROM WEST TO EASI DRUM OF MILL CIU-tTINS, CRRAYVE SLRAACE I FORCK.JW SOL PIl1 IN LEFT BACOGRDUND i

#5 - CL'PHER SIT, VIE~ED WEST TO EAST, FROM MIDDLE TO NE CORNER

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#6 - NE CORNER OF CYPHER SITE AND MASSPORT RAILROAD EASEMENT CHAJNUNK FENC DEiARKS EA5T SIDE OF DSPOSAL STE, ALONG WID E PCE8 REEVA4. ARIA

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APPENDIX D Boring Logs I ALTON ENGINEERING BORING NO. B-1 city of Boston Street Extension S SOIL BORING LOG WELL NO. NA 8 PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: TECHNICAL DRILLING SERVICES ELEVATION 97.92 GROUNDWATER: 8' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE NO. CLASSIFICATION DEPTH REC. BLOWS PER (FT.) (FT.) 0.5 FOOT 0'-8.5', FILL, red brick, white and gray ash, coal, glass, petroleum odor S-1 2.5 0-4

4.0

S-2 3.0 4-8 27_- 8.0 8.0', Wet OlIve-gray CLAY S-3 3.0 8.5'-11.5', 8-12

1 1.5'-12', Black SAND, creosofte odor, red brck, roots 12.0 B.O.H. = 12.0

NOTE- BORING DRILLED UNDER SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. WAD FILENAME: C&J B-1

t ______I__ ._ _ _ _ _ ALTON ENGINEERING BORING NO. B-2 City of Boston CJ-1 B Street Extension I SOIL BORING LOG WELL NO. PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: TECHNICAL DRILLING SERVICES ELEVATION 97.59 GROUNDWATER: 8.5' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER I WT. INSPECTOR C&J ..... FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE WE ii-07 DEPTH REC. BLOWS PER CLASSIFICATION (FT.) (FT.) 0.5 FOOT 0 0'-3', Gray, Aluminum i block, and light Volvo Box brown FILL, coal, red brick Riser: 1" 0 PVC S-1 0-4 Medium o Chip Bentonite o 0 3'-5', FILL, black with wood o 0a 4.0

o a -5 5'-8', Fine to medium, gray, black, and light Filter Sand S-2 brown FILL, coal, red brick 4-8 -7- 8.0 8'-12'. Gray, elIty SAND S-3 8.5', Wet

0 8-12

12.0 . - -.-_ 12'-15', Black, irredescent SAND, trace slit, roots, 21' S-4 petroleum odor Screen:-- -- 1i" 0 PVC- 12-14 with 0.010" slate 15.0

8.0.H. = 15.0

0

-2 NOTE: BORING DRILLED UNDER 5 SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ICAD FILENAME: C&J B-2 ALTON ENGINEERING BORING NO. B-3 city of Boston NO. NA B Street Extension I SOIL BORING LOG WELL PROJECT: CYPHER CORPORATION - PHASE iI CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHEROOO1 i BORING CONTRACTOR: TCHNICAL DRILLING SERVICES ELEVATION 97.42 GROUNDWATER: 8' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER iWT, INSPECTOR C&J FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE NO. CLASSIFICATION DEPTH REC. BLOWS PER (FT_) (FT.) 0.5 FOOT 0 O'-8.5', FILL, red brick, coal, wood, fine to medium sand, trace slit

S-1 3.0 0-4

4.0

-5 S-2 3.5 4-8

8.0 ___,. 8', Wet 8.5'-11.75', Olive-brown Silt and Clay S-3

10 8-12 2.5 11.75'-12', Black Irldecent SAND, creosote like, petroleum odor 12.0

B.O.H. = 12.0

-15

20

NOTE: BORING DRILLED UNDER -25 SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ICAD FILENAME: C&J B-3

______-_____IrA -.. FILENAME .- C& B__±_____L3 ALTON ENGINEERING BORING NO. B-4 City of Boston SOIL BORING LOG WELL NO. NA e Street Extension PROJECT: CYPHER CORPORATION - PHASE 11 CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: TECHNICAL DRILLING SERVICES ELEVATION 97.67 GROUNDWATER: NA CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J . FALL " DRILL RIG GEOPROBE WELL CONSTRUCTION NO. SAMPLE REC. BLOWS PER CLASSIFICATION DEPTH (FT.) (FT.) 0.5 FOOT O'-7', FILL, glass, fine sand, gray and block coal ash, brick, wood, glass

S-1 3.0 0-4

4.0

S-2 2.5 4-8 7'-9', No description 8.0

S-3 g'- 1.5', Olive-gray CLAY 8-12 3.0

EH E111.5'-12', Black SAND, wood, creosata odor 12.0 B.O.H. = 12.0

NOTE: BORING DRILLED UNDER SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. S ALTON ENGINEERING BORING NO. B-5 city of Boston NA B Street Extension I SOIL BORING LOG WELL NO. PROJECT: CYPHER CORPORATION - PHASE II CSA 'SHEET INO,.1 OF I CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: TECHNICAL DRILLING SERVICES I ELEVATION 97.54 GROUNDWATER: 8' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 A DIA. 2" 2" DRILLER WT. INSPECTOR C&J ... _. FALL DRILL RIG GEOPROBE WELL CONSTRUCTION4 NO, SAMPLE REC. BLOWS PER CLASSIFICATION DEPTH (FT.) (FT.) 0.5 FOOT 0 0'-6', FILL, red brick

5-1 3.5 0-4

4.0

-5 S-2 4 6'-7', FILL, slitl and fine sand 4-8 7'-8'. FILL, red brick _V_ 8.0 8'-9'. FILL, black wood, wet

S-3 9'-10', Grey-black SILT, trace Clay

10 8-12 3 10'-11', Black tarry substance wlth sand

11'-12', Gray SILT, trace Clay 12.0

B.0.H. = 12.0

15

-20

NOTE: BORING DRILLED UNDER 25 SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ICAD FILENAME: C&J B-5 ______.t ___ I ______£______I SLTON ENGINEERING OIL BORING LOG ROJECT: CYPHER CORPORATION - PHASE II CSi

0'-4'. FILL, brown, black, gray fine coal ash, red brick, wood

. .__ 8', Wet

12.0 B.O.H. = 12.0

NOTE: BORING DRILLED UNDER SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ! ALTON ENGINEERING BORING NO. B-7 ciy of Boston I SOIL BORING LOG WELL NO. CJ-3 B Street Extension PROJECT: CYPHER CORPORATION - PHASE i1 CSA SHEET NO. I1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHERO001 BORING CONTRACTOR: TECHNICAL DRILULING SERVICES ELEVATION 96.62 GROUNDWATER: 7' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE NO. DEPTH REC. BLOWS PER CLASSIFICATION (FT.) (FT.) 0.5 FOOT Aluminum 0'-4', FILL, coal ash, brown, black, and gray fine Valve Box sand, red brick Risenr 1" 0 PVC S-1 4 0-4 3'-4' Creosole-like

4.0 4'-8', FILL, sand

Filter Sand S-2 3 4-8 7', Wet ______8.0 8.0 __ 8'-10', Black, fine to coarse SAND, petroleum odor S-3

8-12 10'-12', No description Screen: 1" 0 PVC with 0.010" slots 12.0 12'-14', Olive-gray CLAY S-4 12-14 14.0 B.O.H. = 14.0

.NOTE: BORING DRILLED UNDER SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES.

- t - L J.. ______L |CAD FILENAME: C&J B-7-- T BORING NO. B-8 Cypher S ALTON ENGINEERING Corporaflon SOIL BORING LOG WELL NO. NA Parcel 2782 PROJECT: CYPHER CORPORATION - PHASE IICSA SHEET NO. I OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: TECHNICAL DRILLING SER ICES ELEVATION 97.69 GROUNDWATER: 8' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE rW_ REC. BLOWS PER CLASSIFICATION PID I DEPTH (FT.) (FT.) 0.5 FOOT 0 O'-5', FILL, red brick, cool fragments, wood, ash

S-1 3.0 0-4

-5 4.0

5 S-2 -2 5'-6', FILL, slit and fine sand, wood

4-8 4-8 4.0 6'-7', FILL, red brick, coal fragments, wood, ash 7'-8' FILL, tar-like substance _W 8.0 8'-12', Black, fine sand and silt, petroleum odor, wet S-3

10 8-12 3.0

12.0

B.O.H. = 12.0

15

-20

NOTE: BORING DRILLED UNDER -25 SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. [CAD FILENAME: C&J B-8 i BORING NO. B-9 Cypher ALTON ENGINEERING Corporation SOIL BORING LOG WELL NO. CJ-2 Parcel 2782 I PROJECT: CYPHER CORPORATION - PHASE I CSA SHEET NO. 1 OF I CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR; TECHNICAL DRILLING SERVICES ELEVATION 97.22 GROUNDWATER: 8.0' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 I DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J FALL DRILL RIG GEOPROBE WELL CONSTRUCTION I SAMPLE LI LI DEPTH REC. BLOWS PER' CLASSIFICATION -0 (FT.) (FT.) 0.5 FOOT 0.0 Aluminum '-3', FILL, black and light brown gray ash Valve Box

S-1 0-4 Medium Chip Bentonie 3'-4', FILL, coal, coal ash, gray soil 4.0 Riser: 4'-5', FILL, black slit and sand 1" 0 PVC -5 5'-7', FILL, black wood, coal, ash S-2

4-8 7'-8', FILL, black slit, fine sand 8.0 8'-10', FILL, wet ViterSand S-3 -1 0 8-12 10'-14', Black wood chips (?), Irridescent, Filter Sand petroleum odor

12.0

Screen: 5-4 1" 0 PVC 12-15 with 0.010" slots 14'-15', Olive-gray CLAY -1 5 15.0 5 B.O.H. = 15.0

2 0

NOTE: BORING DRILLED UNDER 2 5 SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ICAD FILENAME: C&J B-9 , ALTON ENGINEERING BORING NO. B-10 cpaon SOIL BORING LOG WELL NO. NA Parcel 2782 PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: TECHNICAL DRILLING SER ICES ELEVATION 97.11 GROUNDWATER: 7' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J I FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE N O ,. E DEPTREC. BLOWS PER CLASSIFICATION (FT.) (FT.) 0.5 FOOT 0'-6', FILL, red brick, coal, white ash, fine to medlum sand

S-1 4.0 0-4

4.0

S-2 4-8 4.0 7'-B', Wood chips, petroleum odor 4-8 _ X 7'-11'. Black, brown SILT. some Clay, wet 8.0

Fine to medium SAND S-3 11.5'-12',

8-12 2.0

12.0

B.0.H. = 12.0

NOTE: BORING DRILLED UNDER SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ICAD FILENAME:C&J B-10 ALTON ENGINEERING BORING NO. B-11 CorporationCypher SOIL BORING LOG WELL NO. NA Parcel 2782 PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. I OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001- BORING CONTRACTOR: TECHNICAL DRILULING SERYVCES ELEVATION 97.29 GROUNDWATER: 8' CAS. SAMPLE CORE TUBE DATE STARTED 05/06/02 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 05/06/02 DIA. 2" 2" DRILLER WT. INSPECTOR C&J FALL DRILL RIG GEOPROBE WELL CONSTRUCTION SAMPLE No. REC. BLOWS PER CLASSIFICATION PID DEPTH (FT.) (FT.) 0.5 FOOT 0'-8'. FILL, fine to medium, brown, black, and gray sand, red brick fragments, coal, coal ash, gray ash

-1 4.0 0-4

4.0

S-2 4.0 4-8

8.0 V 8'-9.5', FILL, block, coarse to fine sand, red S-3 S-3 brick, wood, wet, no petroleum odor 8-12 1.5 9.5'-12', FILL, fine to medium, brown, black, and 812 gray sand, red brick fragments, coal, coal ash, gray ash 12.0

B.O.H. = 12.0

NOTE: BORING DRILLED UNDER SUPERVISION OF CUSHING & JAMMELLO, INC. LOG PREPARED FROM C&J FIELD NOTES. ICAD FILENAME:C&J B-11 U

I ALTON ENGINEERING BORING NO. AE-1 Cypher Coporation NA Parcel 2782 I SOIL BORING LOG WELL NO. PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. I OF I CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING CONTRACTOR: ALTON ENGINEERING - HAND AUGER -ELEVATION ... I GROUNDWATER: CAS. SAMPLE CORE TUBE DATE STARTED 11/22/04 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 11/22/04 DIA. DRILLER ADS WT. INSPECTOR AE FALL DRILL RIG HAND AUGER WELL CONSTRUCTION SAMPLE NO. REC. BLOWS PER CLASSIFICATION D P SFLT (FT.) 0.5 FOOT 0'-1' Olive brown sand, slit & gravel fill. Compact. Utitle to no solid waste.

1'-2.4' Grey black fill. Sand, silt,& gravel. Ash and coal fragments. Little to no solid waste. 4.0

8.0

12.0

|CAD FILENAME: AE B-1 P______--- _- . - -E - 1 ALTON ENGINEERING BORING NO. AE2 Cypher Coporation SOIL BORING LOG WELL NO. NA Parcel 2782 PROJECT: CYPHER CORPORATION - PHASE 11CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHER0001 BORING .CONTRACTOR: ALTON ENGINEERING - H ND AUGER ELEVATION GROUNDWATER: CAS. SAMPLE CORE TUBE DATE STARTED 11/22/04 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 11/22/04 DIA. DRILLER ADS WT. INSPECTOR AE FALL DRILL RIG HAND AUGER WELL CONSTRUCTION SAMPLE w La NO. PID I DEPT REC. BLOWS PER CLASSIFICATION (FT.) (FT.) 0.5 FOOT 0 0'-1': fill. Olive brown sand silt and gravel. LUtle to no solid waste. Brick chips.

1'-2.4'+ Grey black flit. Sand, silt, and gravel. Coal and ash fragments. 4.0

-5

8.0

10

12.0

r-5

- 2 0

-25

[CAD FILENAME: AE B-2 ALTON ENrGINEERING BORING NO. AE-3 Cypher Coporatlon SOIL BORING LOG WELL NO. NA Parcel 2782 PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATIQN JOB NO. CYPHER0001 BORING CONTRACTOR: ALTON ENGINEERING - HAND A GER ELEVATION GROUNDWATER: CAS. SAMPLE CORE TUBE DATE STARTED 11/22/04 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 11/22/04 DIA. DRILLER ADS WT. INSPECTOR AE FALL RILL RIG HAND AUGER WELL CONSTRUCTION SAMPLE NO. PID DEPTH REC. BLOWS PER CLASSIFICATION (FT.) (FT.) 0.5 FOOT 1'-1.2' Fill. Grey crushed stone mix.

0.2'-0.8' Grey block fill. Silt, sand and gravel. No solid waste.

Asphalt at approximately 1.0'. 4.0

-5

8.0

-10

12.0

-15

20

-25

ICAD FILENAME: AE B-3 ALTON ENGINEERING BORING NO. AE-3A ypher Coporation S SOIL BORING LOG WELL NO. NA Parcel 2782 PROJECT: CYPHER CORPORATION - PHASE II CSA SHEET NO. 1 OF 1 CLIENT: CYPHER CORPORATION JOB NO. CYPHEROOI BORING CONTRACTOR; ALTON ENGINEERING - Hi.ND AUGER - ELEVATION GROUNDWATER: CAS. SAMPLE CORE TUBE DATE STARTED 11/22/04 DATE TIME WATER DEPTH REFERENCE TYPE GEO GEO DATE FINISHED 11/22/04 DIA. DRILLER ADS WT. INSPECTOR AE FALL DRILL RIG HAND AUGER WELL CONSTRUCTION SAMPLE No. DE PTH REC. BLOWS PER CLASSIFICATION (FT.) (FT.) 0.5 FOOT 0-1.3', Fill. Grey -black silt, sand and gravel. Construcilon debris - pieces of brick, cement, ash, cinder, ceramic Insulofor fragments

4.0

5

8.0

10

12.0

-15

-20

-25

CAD FILENAME: AE B-3A APPENDIX E

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I I I APPENDIX F Limitations STATEMENT OF LIMITATIONS AND CONDITIONS, ATTACHMENT TO OPINION OF MASSACHUSETTS LICENSED SITE PROFESSIONAL

Alton Engineering

Name of Licensed Site Professional: Alton Day Stone

LSP Registration Number: 4058

Date of Opinion: March 30, 2005

Client to Whom Opinion was Rendered: Cypher Corporation

RTN: 3-21146

This Statement of Limitations and Conditions is an integral part of, and is incorporated by reference into, the Opinion of Massachusetts Licensed Site Professional (LSP) referenced above.

LIMITATIONS

1. Purpose of Opinion

A. This Opinion is being provided in compliance with the requirements set forth in the Massachusetts Contingency Plan ("MCP"), 310 CMR 40.0000 et seq. Specifically, the LSP has prepared an Opinion at the request of the Client identified above as part of a Phase IIComprehensive Site Assessment for a release of PCB, EPH and Lead to soil. This stated purpose has been a significant factor in determining the scope and level of services required to render this Opinion.

B. Should the purpose for which this Opinion is to be used change, this Opinion shall no longer be valid.

2. General

This Opinion was prepared for the sole and exclusive use of the Client, subject to the provisions of the MCP. No other party is entitled to rely in any way on the conclusions, observations, specifications, or data contained herein without the express written consent of Alton Engineering and the LSP who rendered this Opinion. Any use of this Opinion by anyone other than Client, or any use of this Opinion by Client or others for any purpose other than the stated purpose set forth above, without the LSP's review and the written authorization of Alton Engineering and the LSP, shall be at the user's sole risk, and neither Alton Engineering nor the LSP shall have any liability or responsibility thereof. I 3. Scope of Service

I The observations and conclusions described in this Opinion are based solely on the Services provided pursuant to the Agreement with the Client and any approved additional 3services authorized by Client. Without limitation of any other applicable limitations or conditions, neither Alton Engineering nor the LSP shall be liable for the existence of any condition, the discovery of which would have required the performance of services not authorized under the Agreement. To the best knowledge and belief of Alton Engineering and the LSP who I signed this Opinion, no inquiry of an attorney-at-law having being made, no laws, regulations, orders, permits or approvals are applicable to the response actions to which i this opinion relates except, if and to the extent applicable, M.G.L. c 21A, Sections 19-19J, 309 CMR, M.G.L. c. 21 E and 310 CMR 40.0000. Accordingly, this opinion is not intended to and does not address compliance with any other laws, regulation, orders, 3 permits or approvals.

4. Changed Circumstances IThe passage of time may result in changes in technology, economic conditions or regulatory standards, manifestations of latent conditions, or the occurrence of future I events that would render this Opinion inaccurate or otherwise inapplicable. Neither Alton Engineering nor the LSP shall be liable or responsible for the consequences of any such changed circumstances or conditions on the accuracy of this Opinion. In addition, I under no circumstances shall the Client nor any other person or entity rely on the information or conclusions contained in this Opinion after six months from its date of submission without the express written consent of Alton Engineering and the LSP. jReliance on the Opinion after such period of time shall be at the user's sole risk.

5. Use by Others I Should Alton Engineering or the LSP be required or requested to review or authorize others to use this Opinion after its date of submission, Alton Engineering shall be entitled I to additional compensation at then existing rates or such terms as may be agreed upon between Alton Engineering and the Client. Nothing herein contained shall be deemed to require Alton Engineering or the LSP to undertake any such review or authorize others to j use this Opinion. 6. The conclusions stated in this Opinion are based upon [check and initial appropriate boxes]:

1I Visual inspection of existing physical conditions;

Review and interpretation of Site history and Site usage information that was made available or obtained within the scope of work authorized by the Client;

d' Information provided by the Client;

Information and/or analyses for designated substances or parameters provided by an independent testing service or laboratory on a limited number of samples;

S A limited number of subsurface explorations made on dates indicated in documentation supporting the Opinion;

U Other:

upon which the LSP has relied and presumed accurate, and upon which the LSP is entitled to reasonably rely. The LSP was not authorized and did not attempt to independently verify the accuracy or completeness of information or materials received from the Client and/or from laboratories and other third parties during the performance of its services. Neither Alton Engineering nor the LSP shall be liable for any condition, information, or conclusion, the discovery of which required information not available to the LSP or for independent investigation of information provided to the LSP by the Client and/or independent third parties.

7. Purpose

This Opinion is rendered for the limited purpose stated above, and should not be deemed to be an opinion concerning the compliance of any past or present owner or operator of the site with any federal, state or local law or regulation. NO WARRANTY OR GUARANTEE, WHETHER EXPRESS OR IMPLIED, IS MADE BY THIS OPINION, AND ANY IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXPRESSLY DISCLAIMED. Without limiting the generality of the foregoing, no warranty or guarantee is made that all contamination at a site or sources or contamination has been detected or identified, that any action or recommended action will achieve all of its objectives, or that this Opinion or any action as to which this Opinion relates will be upheld by any audit conducted by the DEP or any other party. APPENDIX G Calculations L>h ]0L LiUI rhc Li!] oLO -I 0 8 L0 L .]C'4

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IEEE- um - '| APPENDIX I

Public Rnvolvement ALTON ENGINEERING Hydraulic, Water Resources and Environmental

Alton Day Stone, PE, LSP

10 Rugg Road. Sterling. MA 01564 Office: 978.422.8014 Mobile: 978.660.7728 Email: [email protected]

March 30, 2005 AE Project No: CYPHER0001

TO: PUBLIC INVOLVEMENT PLAN - NOTIFICATION LIST Mayor Thomas Menino Mr. Jack Tracy, Office of Environmental Health Senator Stephen Lynch Representative John Hart, Jr. Mr. Brian R. Mahoney, Lower End Political Action Committee

RE: Phase II Comprehensive Site Assessment Report Release Tracking No. 3-21146 Cypher Corporation Property Corner of B Street and North End of West First Street, South Boston, Massachusetts

This letter is intended to provide notification pursuant to the Massachusetts Contingency Plan 310 CMR 40.0000, and the Public Involvement Plan prepared for the disposal site, that Alton Engineering has completed a Phase II Comprehensive Site Assessment Report for the Cypher Corporation property located at the corner of B Street and West First Street in South Boston, Massachusetts.

A copy of Section 9.0 of the report Findings and Conclusions is attached. A copy of the Phase II Report may be reviewed at the following locations:

1. Department of Environmental Protection Northeast Regional Office, One Winter Street, Boston. 2. South Boston Public Library, 646 East Broadway, South Boston. 3. Lower End Political Action Committee, 298 West Third Street, South Boston. 4. Public Health Initiative, South Boston Community Health Center, 718 East 2nd Street, South Boston.

If you have any questions or require additional information, please contact me.

Yours truly, ALTON ENGINEERING Alton Day t ne,S Principal Engineer enclosure: Section 9.0 of Phase II CSA Report cc without enclosure: Jack Merrill, Esq., Kushner & Sanders LLP Walter Fiore, Cypher Corporation Richard J. Chalpin, DEP Deputy Regional Director Karen Stromberg, DEP

.File No: AE\CYPHER0001\NotificationList_Letter_2_CSA.doc ALTON ENGINEERING Hydraulic, Water Resources and Environmental Alton Day Stone, PE, LSP

10 Rugg Road. Sterling, MA 01564 Office: 978.422.8014 Mobile: 978.660.7728 Email: [email protected]

March 30, 2005 AE Project No: CYPHER0001

TO: PUBLIC INVOLVEMENT PLAN - MAILING LIST

RE: Phase II Comprehensive Site Assessment Report Release Tracking No. 3-21146 Cypher Corporation Property Corner of B Street and North End of West First Street, South Boston, Massachusetts

Former (Master) Release Tracking No. 3-0580 Former Boston Junk Property 14 Louis Street, South Boston, Massachusetts

This letter is intended to provide notification pursuant to the Massachusetts Contingency Plan 310 CMR 40.0000, and the Public Involvement Plan prepared for the disposal site, that that Alton Engineering has completed a Phase I Comprehensive Site Assessment Report for the Cypher Corporation property located at the corner of B Street and West First Street in South Boston, Massachusetts.

A copy of the Phase II Report may be reviewed at each of the following locations:

1. Department of Environmental Protection Northeast Regional Office, One Winter Street, Boston. 2. South Boston Public Library, 646 East Broadway, South Boston. 3. Lower End Political Action Committee, 298 West Third Street, South Boston. 4. Public Health Initiative, South Boston Community Health Center, 718 East 2 nd Street, South Boston.

Yours truly, ALTON ENGINEERIN

Altonay .to, L Principal Engineer cc: Jack Merrill, Esq., Kushner & Sanders LLP Walter Fiore, Cypher Corporation Richard J. Chalpin, DEP Deputy Regional Director Karen Stromberg, DEP

File No: AE\CYPHER0001\Notification_List_Letter 2 CSA.doc ALTON ENGINEERING Hydraulic, Water Resources and Environmental

Alton Day Stone, PE, LSP

10 Rugg Road, Sterling, MA 01564 Office: 978.422.8014 Mobile: 978.660.7728 Email: [email protected]

March 30, 2005 AE Project No: CYPHER0001

TO: PUBLIC INVOLVEMENT PLAN - REPOSITORIES

Ms. Francie Francis South Boston Public Library, 646 East Broadway, South Boston, MA 02127

Mr. Brian Mahoney Lower End Political Action Committee, 298 West Third Street, South Boston, MA 02127

Ms. Lucky Devlin Public Health Initiative, South Boston Community Health Center, 718 East Second Street, South Boston 02120

RE: Phase II Comprehensive Site Assessment Report Release Tracking No. 3-21146 Cypher Corporation Property Corner of B Street and North End of West First Street, South Boston, Massachusetts

Former (Master) Release Tracking No. 3-0580 Former Boston Junk Property 14 Louis Street, South Boston, Massachusetts

Please find enclosed a copy of the Phase II Comprehensive Site Assessment Report prepared by Alton Engineering on the behalf of Cypher Corporation. A copy of the Phase H Report is to be submitted to each of the repositories designated in the Public Involvement Plan, pursuant to the Massachusetts Contingency Plan 310 CMR 40.0000, where the copies will be available for public review.

Yours truly, ALTON ENGIN RIN

Al onDa St e, -SP Principal Engineer

enclosure: Phase II Report

cc without enclosure: Jack Merrill, Esq., Kushner & Sanders LLP Walter Fiore, Cypher Corporation Richard J. Chalpin, DEP Deputy Regional Director Karen Stromberg, DEP

File No: AE\CYPHEROI0001\RepositoryListLetter lCSA.doc