Report T&B-Photech Phase II-III Draft 1

7/29/2019 Report T&B-Photech Phase II-III Draft 1

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Former Photech Imaging Systems, Inc.

330 Cole AvenueWilliamsburg, MA

Phase II Comprehensive Site

Assessment & Phase III

Remedy Implementation Plan

RTN 1-11635

Prepared For:

Town of Williamstown, MA

August 2012

Tighe&Bond


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Table of Contents Tighe&Bond

i

Section 1 Introduction1.1 Background Information ................................................................ 1-11.2 Conceptual Site Model ................................................................... 1-2

Section 2 Description of Site Release2.1 General Site Description ................................................................ 2-1

2.1.1 Current Site Conditions ....................................................... 2-12.1.2 Surrounding Receptors ........................................................ 2-22.1.3 Site Use History ................................................................. 2-2

2.2 Site Hydrogeological Characteristics ................................................ 2-32.2.1 Topography and Drainage .................................................... 2-32.2.2 Surficial and Bedrock Geology .............................................. 2-32.2.3 Site Hydrogeology .............................................................. 2-4

2.3 Summary of Previous Investigations ............................................... 2-42.3.1 Earlier Investigations Findings .............................................. 2-52.3.2 Tighe & Bonds MCP Investigations ........................................ 2-9

Section 3 Supplemental Phase II Investigations3.1 Drilling Event ............................................................................... 3-1

3.1.1 Soil Boring Advancement ..................................................... 3-13.1.2 Monitoring Well Installations ................................................ 3-2

3.2 Soil Sampling .............................................................................. 3-23.3 Groundwater Sampling .................................................................. 3-3

3.3.1 Groundwater Collection ....................................................... 3-33.3.2 Groundwater Flow .............................................................. 3-3

3.4 Sediment and Surface Water Sampling ............................................ 3-43.5 Laboratory Results........................................................................ 3-5

3.5.1 Soil Results ....................................................................... 3-53.5.2 Groundwater Results ........................................................... 3-53.5.3 Sediment Results ............................................................... 3-53.5.4 Surface Water Results ......................................................... 3-6

3.6 Discussion ................................................................................... 3-6Section 4 Risk CharacterizationSection 5 Phase III Remedial Action Plan

5.1 Initial Screening of Remedial Action Alternatives ............................... 5-15.1.1 Soil Excavation and Off- Site Disposal.................................... 5-15.1.2 Soil Excavation, Stabilization and Off Site Disposal .................. 5-2

5.2 Detailed Evaluation of Remedial Action Alternatives ........................... 5-25.2.1 Soil Excavation and Off Site Disposal ..................................... 5-2


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Table of Contents Tighe&Bond

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5.2.2 Soil Excavation, Stabilization, and Off Site Disposal ................. 5-25.3 Selection of Remedial Action Alternative .......................................... 5-35.4 Remedial Action Plan .................................................................... 5-3

Section 6 Conclusions6.1 Public Notification ......................................................................... 6-1

Section 7 Regulatory Limitations

Appendices

Appendix A Figures

Appendix B Copies of Relevant Site Information Generated from Earlier SiteInvestigations

Appendix C Summary Data Tables

Appendix D - Boring Logs and Field Sampling Sheets

Appendix E Laboratory Reports

Appendix F Method 3 Risk Characterization

Appendix G Copy of Public Notification Documents

Figures (Appendix A)

Figure 1 USGS Site Locus

Figure 2 MassGIS Priority Resource Map

Figure 3 OrthophotographFigure 4 Site Plan

Figure 5 Groundwater Contour Plan

Tables (Appendix C)

Table 2-1 - Summary of Initial Phase I Soil Results

Table 2-2 - Summary of Historical Cadmium and Silver Results in Soils

Table 2-3 Summary of Historical Groundwater Results

Table 2-4 Summary of Historical Petroleum Compound Results in Soils for IRAExcavation Areas

Table 3-1 - Summary of Soil Borings (Supplemental Phase II Investigations)

Table 3-2 Summary of Groundwater Elevations (Supplemental Phase IIInvestigations)

Table 3-3 Summary of Soil Results (Supplemental Phase II Investigations)

Table 3-4 Summary of Groundwater Results (Supplemental Phase IIInvestigations)

Table 3-5 - Summary of Sediment Results (Supplemental Phase II Investigations)

J:\W\W0987 PHOTEC\Site Assessment_2012\Phase II_III Report\Report.doc


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Tighe&Bond

Revised Phase II CSA and Phase III RAP - RTN 1-11635 1-1

Section 1Introduction

On behalf of the Town of Williamstown, Tighe & Bond is submitting this Revised Phase II

Comprehensive Site Assessment and Phase III Identification, Evaluation, and Selectionof Comprehensive Response Action Alternatives for the former Photech ImagingSystems, Inc. (Photech) site located at 330 Cole Avenue in Williamstown, Massachusetts(the site). This submittal has been prepared for a release of oil and/or hazardousmaterials (OHM) at the site in conformance with the Massachusetts Contingency Plan(MCP; 310 CMR 40.0000). A Site Locus, a Massachusetts Geographic InformationSystems (MassGIS) Priority Resource Map, and an Orthophotograph are provided inAppendix A as Figures 1, 2, and 3, respectively.

The Massachusetts Department of Environmental Protection (MADEP) first assignedRelease Tracking Number (RTN) 1-11635 to the site in December 1996 for the threat ofa release from drums of OHM at the abandoned site. Subsequent cleanup actions andassessment activities were performed by the U.S. Environmental Protection Agency

(EPA) in 1997, with additional site investigations conducted by MADEP in 1998. Tighe &Bond conducted site investigations and MCP response actions between 2000 and 2004,with the Town serving as the Responsible Party (as a Municipality with Exempt Status)for site RTN 1-11635.

The Town recently received funding for performing an evaluation to determine theremedial costs for addressing the contamination at the abandoned site. Tighe & Bondconducted supplemental Phase II investigations at the site, and based on those findingsand our previous investigations we completed a site-wide Method 3 risk characterization.Site risks were evaluated assuming unrestricted activities and uses, current and futurerisk of harm to human health, safety, the public welfare and the environment posed byrelease-related conditions.

In summary, a Condition of No Significant Risk does not exist for the single familyresidential scenario. In general, that risk is driven predominantly through consumptionof homegrown produce. Under the multi-family residential scenario, a condition of NoSignificant Risk does exist subject to the restriction that theres no consumption ofhomegrown produce (indicating that an Activity and Use Limitation will be required).Due to the presence of one site contaminant detected in sediment, at one location alongthe abutting Hoosic River, at a concentration above benchmark values, a risk to theenvironmental cannot be ruled out without additional investigation into a potentialsource and the limits of distribution in sediment.

In order to have unrestricted site use, extensive excavation would be required toachieve a Permanent Solution under a Class A-1 or A-2 Response Action Outcome

(RAO). However, placement of an AUL on the property would allow a wide-range offuture uses at the site. The remedial options and associated costs are evaluated underPhase III (Section 5) of this report.

1.1 Background InformationTighe & Bond conducted previous MCP investigations for site RTN 1-11635, which weresummarized in the following submittals:


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Section 1 Introduction Tighe&Bond


Phase I - Initial Site Investigation and Tier Classification report (May 2003)

Immediate Response Action (IRA) Completion Statement report (September 2003)

Phase II Comprehensive Site Assessment (CSA) report (October 2004)

The site data contained in those earlier submittals has been incorporated into this

revised Phase II report, as appropriate. Since the October 2004 Phase II reportsubmittal, no known additional investigations and/or MCP submittals have beencompleted for the site until our recent investigations described herein.

1.2 Conceptual Site ModelThe abandoned site consists of 4.9 acres of land and is improved by an approximate5,580 square-foot four-story building (referred to as Building #2) with a basement area.Access to the abandoned building is not currently restricted as some of the doorways tothe building are open or unlocked. The sites original three-story mill building (referredto as Building #1) was connected to Building #2 to the north/northwest, and that formerbuilding was demolished in 2005 under EPA oversight. The area of former Building #1 is

now primarily covered by grass vegetation. The site entrance off Cole Avenue and thewestern portion of the site are covered by asphalt pavement generally in poor condition.The remaining portions of the site are generally covered by grass with tree growth alongthe fairly steep river embankment along the east/northeastern portion of the site and onthe southern-most portion of the site.

The elongated site parcel is abutted by the northwesterly flowing Hoosic River to theeast/northeast, residential properties to the west/southwest and northwest, andundeveloped land to the south. Situated across Cole Avenue (to the northwest) is also acommercial property. A chain link fence and locked gate currently prevent vehicleaccess to the site off Cole Avenue, but currently there is no fencing between the site andthe abutting residential neighborhood to the west.

The site is located within a MADEP Wellhead Protection Area that is associated with threepublic water supply wells located within one half mile of the property. The area alongthe Hoosic River and its bank are mapped within Priority Habitat.

When in use, the site was serviced by municipal sewer and water that are located offCole Avenue. A 25-foot sewer line easement traverses along the western portion of thesite parcel, near the abutting residential properties. A separate water line for theHoosac Regional Water District has been abandoned on the site. A former bedrock wellon the site, which was previously used for process water, was decommissioned by theTown in 2007.

The site was first developed circa 1860s. The site has been occupied by several

industries, including textile, paper, and photographic film manufacturing. Manufacturingof film emulsion coating and dye materials last occurred at the site circa 1988 when theproperty was abandoned. The Town of Williamstown has since obtained ownership ofthe property through non-payment of taxes.

A canal system (fed by the Hoosic River) that originated south/southwest of the siteproperty previously traversed through the south/southeastern portion of the property toBuilding #2, then discharged back to the river from beneath the eastern portion of thebuilding. Based on historical mapping, the canal system existed pre-1900 to at least


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the 1930s, and was filled in by the 1950s. The portion of the river bank where the canaldischarged from beneath Building #2 was also apparently filled by that time.

The site is underlain by fill soil that, in some areas, contains debris including metal,brick, wood, concrete, clay pipe, glass, and/or paper. Coal, coal ash, and wood ash (allMCP-exempt), as well as coal tar (not MCP-exempt) were also observed and detected

through microscopic analysis in the fill. Transite pipe that contained asbestos-containingmaterial (ACM) was also encountered in the fill on the southern portion of the site,within or near where the former canal system was located. Below the fill, the site isunderlain by native alluvial deposits on a glacial outwash plain. These soils aredescribed as an approximate 10 to 15-foot layer of fine sands to gravel (in areas wherefill is not present) that is followed by a layer of silt and clay that is greater than 100 feetin thickness. A layer of sand and gravel reportedly underlies the silt/clay layer (creatingartesian aquifer conditions), and dolomite bedrock is situated approximately 300 feetbelow grade. The depth to groundwater in the overburden aquifer is betweenapproximately 5 feet below grade (on the upper, northwest portion of the site) and 15feet below grade (on the eastern developed portions of the site), and groundwater flowis toward the abutting Hoosic River.

A 20,000-gallon heating oil underground storage tank (UST), a 6,000-gallon methanoland heating oil UST, and a 3,000-gallon gasoline UST were removed from the site in1986. During those removals, no releases were reportedly encountered and nosignificant levels of contaminants were reportedly detected in soil samples collected fromthe tank graves. Between 1986 and 1996, environmental investigations conducted atthe site included the sampling of groundwater in the general vicinity of these formerUSTs, and no levels of contaminants were reported above applicable ReportableConcentrations or Method 1 standards.

During former photographic film operations, industrial wastewater was processedthrough two concrete basins prior to their discharge to the municipal sewer system.Each basin consisted of two chambers and essentially served to settle out sludge. The

sludge generated was a hazardous material, primarily based on its elevated cadmiumand silver content. Sludge collected in the basins was reportedly mixed with wood chipsand removed from the site by a waste hauler for recovery of the silver. One basin waslocated along the east/northeastern side of Building #2 (i.e., between the building andthe river), and the other basin was located further to the southeast of Building #2. Thebasin adjacent to Building #2 reportedly overflowed or foamed over periodically whenin operation. In 1986, approximately 30 cubic yards of discolored metals-impacted soilwas removed along the length of this basin to a depth of approximately 5 feet belowgrade. In the late 1980s, the basin further to the southeast of Building #2 was replacedwith a larger, multi-chambered concrete basin. After abandonment of the property, thewastewater and contaminated sludges that remained in the two basins were eventuallyremoved and disposed by EPA during response actions conducted in 1997. As part ofthat work, EPA removed 40,000 gallons of industrial wastewater and 188 tons ofcontaminated wastewater treatment sludge, as well as over 500 abandoned drums ofhazardous materials that were scattered mostly across the southern portions of the site.

In 1997, EPA also completed 15 test pit explorations across the southern portions of thesite and in the paved parking area to the west of the Building #2. EPA collected surficialsoil samples from areas of concern, including adjacent to the two wastewater treatmentbasins and where former drum storage occurred. EPA reported elevated concentrationsof cadmium and silver in surficial soil samples with the highest concentrations detectedin soils adjacent to the two wastewater treatment basins. EPA also reported elevated


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concentrations of polynuclear aromatic hydrocarbons (PAHs) in several subsurface soilsamples with the highest PAH concentrations in a test pit sample collected in theapproximate location of the former 20,000-gallon fuel oil UST.

In 1998, MADEP collected soil/sediment and surface water samples from the HoosicRiver along the site property boundary to assess the potential impacts to the river from

the site. The samples were analyzed for RCRA 8 metals, polychlorinated biphenyls(PCBs), and semi-volatile organic compounds (SVOCs). PCBs were not detected, andthe consistent levels of metals and SVOCs detected in the sediment samples wereattributed to Local Conditions along the river at that time.

Between 2000 and 2003, Tighe & Bond conducted Phase I investigations at the site. Soilsamples were analyzed for metals of concern (cadmium, silver and lead), and selectsamples were analyzed for volatile organic compounds (VOCs) and extractablepetroleum hydrocarbons (EPH). Silver and cadmium concentrations were detected atelevated concentrations in shallow soils (to depths of three feet below grade) in theareas of the wastewater treatment basins and in the vicinity of the former drum storagearea on the southern portion of the site. Cadmium levels in three of the surficial soil

samples collected in the vicinity of the former basin adjacent to Building #2 triggered anImminent Hazard condition. Target PAHs were also detected at elevated concentrationsin shallow soils near the former 20,000-gallon fuel oil UST and near a former slab on-grade barn-type building (referred to as Building #3) that was situated to the southwestof Building #2. These results were fairly consistent with the findings from EPAs 1997test pit program. Groundwater samples were also collected from five site monitoringwells that were located within or adjacent to the two former wastewater treatmentbasins, near the former 20,000-gallon fuel oil UST, near an abandoned 20,000-gallonNo. 2 fuel oil UST situated immediately adjacent to the west/southwestern portion of theBuilding #2, and on the northeastern portion of the site near Cole Avenue. The sampleswere analyzed for EPH, VOCs, and dissolved metals of concern (cadmium, silver andlead). One petroleum carbon fraction was detected at an elevated concentration in amonitoring well TB-2B situated adjacent to the former 20,000-gallon fuel oil UST.

As part of IRA activities conducted in June 2003, contaminated soil excavation occurredin six different areas of concern. This included the following:

Excavation of approximately 40 cubic yards (62.95 tons) of cadmium-impactedsurficial soils (characterized as hazardous waste) from the area where theImminent Hazard condition was identified.

Excavation of approximately 600 cubic yards (859.99 tons) of non-hazardousmetals-impacted soils in the areas of the two former wastewater treatmentbasins, and in the general vicinity of a former drum storage area on the southernportion of the site. The total depths of the excavations in these areas were threefeet or less. In the excavation on the southern portion of the site, a drum

containing asbestos containing material (ACM) was also encountered (andultimately removed) in the fill.

Excavation of approximately 300 cubic yards (447 tons) of petroleum-impactedsoil from three areas of the site. This included the excavation of the surficial soilsadjacent to the former Building #3, subsurface soils in the former 20,000-gallonfuel oil UST area, and subsurface soils in the area of the abandoned 20,000-gallon No. 2 fuel oil UST. That abandoned tank was also removed as part ofthese activities.


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In July 2003, Tighe & Bond conducted follow-up Phase II investigations at the site, whichincluded test pit explorations, soil boring advancement, installation of additionalgroundwater monitoring wells, and the collection of additional soil, groundwater andsurface water samples for laboratory analysis. This work was performed to furtherdelineate and characterize the remaining contamination following the completion of the IRAactivities. The 2004 Phase II report concluded that a Condition of No Significant Risk did

not exist at the site because exposure point concentrations (EPCs) for silver and petroleumcompounds in site soils were above Method 1 standards. Since the submittal of the PhaseII report in 2004, the Method 1 standards for some of the contaminants of concern forthe site were modified when the Wave 2 changes to the MCP became effective in April2006. Of particular importance is that cadmium decreased from 30 milligrams perkilogram (mg/kg) to 2 mg/kg for the S-1 soil category. Because of the change in thisstandard, more site soil is now considered to be impacted by cadmium above Method 1standards than what was described in the 2004 Phase II report submittal.

At this time, the Town has preliminary plans for the demolition of the remaining sitebuilding (i.e., Building #2) and possibly re-developing the site for affordable housing use(if feasible) and/or as riverfront park area. Tighe & Bond conducted supplemental Phase

II investigations at the site between June and July 2012 to update site conditions and tofurther evaluate impacts to environmental media across the site in preparation of futuresite remediation (as needed) prior to the planned redevelopment of the site. Thisincluded subsurface investigations in previously un-assessed area of the former mainmill building (Building #1), further evaluation of cadmium in soils across the site sincethe change in MCP Method 1 standards in 2006, and a delineation of other impacts toenvironmental media in areas of potential concern at the site.


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Tighe&Bond


Section 2Description of Site Release

A description of the site and the background conditions associated with subject RTN 1-

11635 were provided in previous MCP submittals. The site description is summarizedand updated where appropriate in the sections below. A Phase II Site Plan is providedas Figure 4 in Appendix A for reference. [Note: The site plans provided in the earlierPhase II submittal referenced a Project North direction that is not shown on Figure 4and is not being used in this revised Phase II report submittal.]

2.1 General Site Description

2.1.1 Current Site Conditions

The abandoned site is listed at 330 Cole Avenue in the Town of Williamstown, BerkshireCounty, Massachusetts (see Figure 1 for reference). The geographical location of thesite is 424308 north latitude and 731228 west longitude.

According to the Williamstown Assessors office, the site parcel is listed on Map 119,Block 0, Lot 18, and the parcel contains 4.90 acres of land. According to currentAssessors card, the Town of Williamstown obtained ownership of the property in August2001.

The abandoned site is currently improved by a four-story building (Building #2) that hasa basement area and a footprint of approximately 5,580 square feet. This building wasbuilt in 1941 with an addition in 1944. A separate mill building (Building #1) formerlyabutted Building #2 to the north/northwest, and the footprint of that former larger millbuilding is now mostly covered by grass vegetation. The site entrance off Cole Avenueand the western portion of the site are covered by asphalt pavement generally in poor

condition. The remaining portions of the site are primarily grass covered with treegrowth along the fairly steep river embankment on the east/northeastern portion of thesite, and on the southern portion of the site parcel (see Figure 3 for reference).

When in use, the site was serviced by municipal sewer and water that are enters the siteoff Cole Avenue. A sewer line easement is located along the western portion of thesite, near the abutting residential properties. A separate water line for the HoosacRegional Water District is abandoned on the site. A bedrock water supply well waslocated adjacent to the southern portion of Building #2 (see Figure 4 for reference).That private well was decommissioned by the Town in 2007.

The elongated site parcel is abutted by the northwesterly flowing Hoosic River to theeast/northeast, residential properties to the west/southwest, and undeveloped land to

the south/southeast. Situated across Cole Avenue from the site are additionalresidential properties and a commercial property. A chain link fence and locked gatecurrently prevent vehicle access to the site off Cole Avenue, but there is currently nofencing between the site and the abutting residential neighborhood to thewest/southwest.


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Section 2 Additional Phase II Investigations Tighe&Bond


2.1.2 Surrounding Receptors

The site is abutted by residential properties to the west/southwest and by the HoosicRiver along the northeastern property line.

According to MassGIS mapping (see Figure 2), the site is located within a MADEP

Approved Wellhead Protection Area (i.e., Zone II) for three public water supply wellsthat are located within one half mile of the site. The site is also located above a Non-Potential Drinking Water Source Area (High Yield). The area along the Hoosic Riverabutting the site is mapped within NHESP Priority Habitat for State-Protected RareSpecies and Estimated Habitat for Rare Wildlife. This mapped area extends onto thesubject site, on the southern portion of the site parcel.

2.1.3 Site Use History

The site was first developed circa the 1860s. The site has been occupied by severalindustries, including textile, paper, and photographic film manufacturing.Manufacturing of film emulsion coating and dye materials last occurred at the site untilthe site was abandoned circa 1988. The Town of Williamstown has since obtainedownership of the property through non-payment of taxes.

A canal system (fed by the Hoosic River) that originated to the south/southwest of thesite previously traversed through the southeastern portion of the property to Building#2, then discharged back to the river from beneath the northeast of Building #2. Basedon Historical Sanborn Fire Insurance Mapping, that canal system was established pre-1900 and its use continued through at least 1938 while the site was used for textilemanufacturing. A 1959 Sanborn map of the site area no longer shows the canal system,and that the portion of the river bank where the canal previously discharged frombeneath Building #2 had also apparently been filled in by that time. Previousinvestigations describe a sunken concrete pit floor in the basement of Building #2 whichcontains three oil burners. Sump pumps in that pit reportedly discharged to the Townsstorm system when in operation.

During the former photographic film operations, industrial wastewater was processedthrough two concrete basins prior to their discharge to the municipal sewer system.Each basin consisted of two chambers and essentially served to settle out sludge. Thesludge generated was a hazardous material, primarily based on its elevated cadmiumand silver content. Sludge collected in the basins was reportedly mixed with wood chipsand removed from the site by a waste hauler, for recovery of the silver. One basin waslocated on the east/northeastern side of Building #2 (i.e., between the building and theriver), and the other basin was located further to the southeast of Building #2. In thelate 1980s, the basin further to the southeast of Building #2 was replaced with a larger,multi-chambered concrete basin. After abandonment of the property, wastewater andcontaminated sludges remained in the two basins. The contents of both basins wereeventually removed and disposed by EPA during response actions conducted in 1997

(see Section 2.3 for further discussion).

In 1986, a 20,000-gallon heating oil UST, a 6,000-gallon methanol and heating oil UST,and a 3,000-gallon gasoline UST were each removed from the site. A separate 20,000-gallon No. 2 fuel oil UST situated along the west/southwestern portion of Building #2was removed from the site in 2003. The approximate locations of the former tanks wereshown on the site plan provided in our Phase I report submittal.


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An 8,159 square-foot building (Building #3) was situated to the south of Building #2.That former slab-on-grade barn-type building was built in the 1860s with an addition in1944. Demolition of Building #3 was completed in 2003. The approximate footprint offormer Building #3 is shown on Figure 4 for reference.

Since the submittal of the Phase II report in October 2004, the larger Building #1 was

demolished in 2005 under EPA oversight. That former 16,760 square-foot building wasoriginally constructed in the 1860s as a textile mill and was connected to Building #2.According to the EPA website (http://www.epa.gov/aboutepa/region1.html), aNovember 29, 2005 press release regarding this demolition project stated the following:

After removing more than 1,700 tons of debris containing asbestos from anabandoned mill complex, the U.S. Environmental Protection Agency has

completed the cleanup work at the Photech site in Williamstown, Mass. EPA'swork included the safe removal of contaminated materials, followed by off-site

transport for proper disposal.

EPA oversaw the removal of asbestos-containing material from the multi-story

building by carefully demolishing the already partially collapsed center portion ofthe mill building. As part of the cleanup, 1,782 tons of the contaminated debriswere removed from the building and shipped off-site for disposal at a licensed

facility. In addition, 243 tons of scrap metal were transported off-site forrecycling. Brick from the razed portions of the mill complex was used to backfill

the open basement area where the mill building previously stood. After backfilling

the area with the masonry debris, EPA placed six inches of clean fill over thebrick, graded the area, and re-established or installed erosion control fence along

the riverbank.

The approximate footprint of the former Building #1 is shown on Figure 4 for reference.

2.2 Site Hydrogeological Characteristics

2.2.1 Topography and Drainage

The site is situated at approximately 190 meters above mean sea level. Topographyacross the site is generally level, but pitches toward the Hoosic River with a steeplysloped embankment adjacent to the river especially on the northern and central portionsof the site parcel.

2.2.2 Surficial and Bedrock Geology

2.2.2.1 Mapping

According to the U.S. Department of Agriculture, Soil Conservation Service, BerkshireCounty, Massachusetts Central Part Soil Atlas (Map no. 17) the site is underlain with asoil characterized as Urban Land with areas of Copake soil units. Urban land soil is madeup of areas of soils that have been so altered or obscured by urban works and structuresthat identification of the original soil type is impossible. Structures built on the site andfilling of site areas have resulted in Urban Land soil classification. The Copake soil isgenerally encountered in vacant lots and is used as lawns, parks, and other areas thatare interspersed among buildings and streets and has few limitations to most urbanuses. Typically this soil category consists of deep loamy sands that are somewhatexcessively drained with 0 to 15 percent slopes. The permeability of these soils is


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moderate to moderately rapid in the subsoil and very rapid in the substratum.Consequently the available water capacity in these units is moderate.

According to the USGS Bedrock Geologic Map of Massachusetts, the site is underlain bythe Stockbridge bedrock formation. The Stockbridge formation is described as beige, tanand dark gray weathering quartzose dolomite marble containing interbeds of black,

green and maroon phyllite and weathered blue quartz pebble quartzite.

2.2.2.2 Other Information

Further information on geological conditions at and immediately surrounding the subjectsite was obtained from the following sources:

A draft report entitled Groundwater Exploration Program at the Green River Siteprepared by Camp, Dresser & McKee, Inc (CDM) for delineation of the Town ofWilliamstown public water supply aquifer and Zone II.

A well log (dated 1944) for the on-site process water well that was ultimatelydecommissioned by the Town in 2007.

The existing overburden geology of the site area was shaped by glacial advance andretreat approximately 15,000 years ago and by river and stream action since that time.The site geology is comprised of four primary layers: (1) an upper layer of fine sandsand gravel, bearing an unconfined aquifer; (2) a confining layer of silt and clay; (3) alower layer of fine to coarse sand mixed with gravel, bearing a confined aquifer; and, (4)fractured dolomite bedrock, bearing a confined bedrock aquifer. The depth to bedrockwithin the site area is reportedly 285 feet below grade. The former process water wellat the site was set to approximately 330 feet below grade within dolomite, and the welllog indicates that the artesian well flowed at a rate of 700 gallons per minute. Thestratigraphy for the site area (which includes the former Photech well) is shown on across sectional plan prepared by CDM, a copy of which is provided in Appendix B forreference.

Previous structural borings advanced at the subject site to depths of up to 80 feet belowground indicated that the silt and clay confining layer was encountered to at least thisdepth.

2.2.3 Site Hydrogeology

In the upper unconfined aquifer, the depth to groundwater is generally between 5 and15 feet below grade across the site, and the groundwater flow direction is generally tothe east/northeast toward the abutting Hoosic River. Further site hydrogeologyinformation is provided in Section 3.

2.3 Summary of Previous Investigations

A review of earlier site investigations conducted by others and Tighe & Bond wasprovided in our previous MCP submittals for the site. As part of this revised Phase IIreport submittal, supplemental site information was obtained from MADEPs releaselookup website for site RTN 1-11635. A summary of previous site investigations isprovided below.


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2.3.1 Earlier Investigations Findings

Earlier site investigations were conducted by Rizzo Associates in 1986, by Scalise-KnyshAssociates, Inc. (SKAI) in 1996, by the EPA in 1997 and 1998 (using Roy F. Weston,Inc. (Weston) as the environmental consultant), and by MADEP in 1998.

2.3.1.1 Summary of 1986 Site Investigations and RemediationIn 1986, a 3,000-gallon gasoline UST, a 6,000-gallon methanol UST and a 20,000-gallonfuel oil UST were removed from the site. During the tank removals, Rizzo reported thatno releases from the tanks were encountered, and that no significant levels ofcontaminants were detected in soil samples collected from the tank graves. Other OHMstorage areas at the site that Rizzo identified included an abandoned 20,000-gallon No.2 fuel oil UST, two concrete wastewater settling tanks, an exterior transformer vault,and a drum storage area. Rizzo collected soil samples from each of these areas ofconcern. In summary, Rizzo reported the following:

No PCBs were detected in soil samples collected near the transformer pad

No VOCs were detected in soil samples collected beneath and adjacent to the

drum storage area Some detections of oil and grease were reported in soil samples collected near

the abandoned 20,000-gallon No. 2 fuel oil UST

A release of cadmium and silver was reported to soils from the periodic overflowof the (former) wastewater treatment basin located adjacent to Building #2

A copy of a site plan prepared by Rizzo showing soil sample locations is provided inAppendix B for reference. [Note: Laboratory data and/or a summary table for this soildata were not located in previous reports or in MADEPs on-line files.]

As part of follow-up activities conducted in 1986, Rizzo excavated approximately 30cubic yards of silver and cadmium contaminated soil from the visibly stained area

around the wastewater treatment basin adjacent to Building #2 for off-site disposal as ahazardous waste. The excavation reportedly occurred along the length of this basin overa width of approximately 8 feet and to depths between 5 and 7 feet below grade (thedeeper depths were excavated closer to the basin). Confirmatory soil samples analyzedby EP toxicity analysis (predecessor to the TCLP analysis) indicated concentrations hadbeen reduced to below hazardous waste levels. However, total silver and cadmiumconcentrations in the remaining soils were not analyzed.

As part of this follow-up investigation Rizzo also installed three monitoring wells. Onewell (MW-102) was installed on the upgradient portion of the property off Cole Avenue,one well (MW-101) was installed near the (former) abandoned 20,000-gallon No. 2 fueloil UST located along the western portion of Building #2, and one well (MW-103) wasinstalled to the east of Building #2 near the wastewater treatment basin. Rizzo collectedgroundwater samples from the wells for VOC analysis. The groundwater samplecollected from well MW-103 was also submitted for dissolved RCRA 8 metals. Rizzoreported that one VOC (trans-1,2-dichloroethylene) was detected in well MW-103 at alow concentration of 15 micrograms per liter (g/L), which was below the Safe DrinkingWater Act standard of 270 g/L at that time. [Note: This concentration is also belowthe current MCP Reportable Concentration of 90 g/L for the applicable RCGW-1groundwater category.] No other VOCs were detected in the three groundwatersamples. Rizzo also reported that no dissolved RCRA 8 metals were detected. A copy of


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a site plan and summary tables prepared by Rizzo for post-excavation EP soil data andfor groundwater samples are provided in Appendix B for reference.

2.3.1.2 Summary of 1996 Site Investigations

SKAIs assessment included installation of three additional monitoring wells (MW-3, MW-4, and MW-5) in areas to the south of Building #2, and the collection of groundwatersamples from the three new wells and from two existing (Rizzo) wells located to the eastand west of Building #2. [Note: These two existing wells were identified as MW-2 andMW-1 by SKAI, and correspond to Rizzos earlier MW-103 and MW-101, respectively.]Three of the samples were submitted for VOC analysis, and three of the samples weresubmitted for dissolved RCRA 8 metal analysis. SKAI also collected a surficial soilsample adjacent to the (former) wastewater treatment basin east of Building #2 forRCRA 8 metal analysis. A copy of a site plan prepared by SKAI showing approximatemonitoring well locations is provided in Appendix B for reference. Copies of data tablesprepared by SKAI summarizing the results for the groundwater samples and one soilsample are provided in Appendix B for reference. A summary of SKAIs sample resultsis as follows:

Seven petroleum-related VOCs were detected at low concentrations (i.e., belowapplicable RCGW-1 groundwater values, as summarized in SKAIs data table) inthe groundwater sample collected from the existing well MW-1. No VOCs weredetected above laboratory reporting limits in the other two groundwater samplessubmitted for VOC analysis.

Low concentrations (i.e., below applicable RCGW-1 groundwater values, assummarized in SKAIs data table) of dissolved arsenic and lead were detected inone or more of the monitoring wells. No other metal was detected abovelaboratory reporting limits in the three groundwater samples submitted fordissolved RCRA 8 metals analysis.

Low concentrations (i.e., below applicable RCS-1 soil values, as summarized inSKAIs data table) of arsenic, barium, cadmium, chromium (total), and silver

were detected in the surficial soil sample. It should be noted that the cadmiumresult of 9 mg/kg in the soil sample was above the current RCS-1 value (andMethod 1, S-1 standard) of 2 mg/kg. However, the surficial soils in this areawere subsequently removed during IRA activities conducted by Tighe & Bond, asfurther reviewed below in Section 2.3.2.

2.3.1.3 Summary of EPA Response Actions and Investigations

After abandonment of the property, the wastewater and contaminated sludges thatremained in the two basins were removed and disposed by EPA during response actionsconducted in 1997. As part of that work, EPA ultimately removed 40,000 gallons ofindustrial wastewater and 188 tons of contaminated wastewater treatment sludge, aswell as over 500 abandoned drums of hazardous materials that were scattered across

the abandoned site. Also as part of this work, oily water that was in the abandoned20,000-gallon UST adjacent to Building #2 was pumped out and disposed off-site.

As part of their site assessment, EPA completed 15 test pit explorations across thesouth/southeastern portions of the site and in the paved parking area to the west ofBuilding #2. From those test pits, six soil samples were selected for laboratory analysisof RCRA 8 metals, PAHs, PCBs, VOCs, cyanide, methanol, and formaldehyde. Inaddition, EPA collected six surficial soil samples (including five composite samples andone grab sample) from identified areas of concern, including areas adjacent to the two


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wastewater treatment basins and where former drum storage reportedly occurred. Thesix surficial soil samples were submitted for laboratory analysis of RCRA 8 metals andPAHs. Three of the samples were also analyzed for PCBs, and three of the samples wereanalyzed for cyanide. The approximate locations of where EPA conducted test pitexplorations and soil sampling is shown on a site plan prepared by Weston in 1997, acopy of which is provided in Appendix B for reference. Data tables summarizing soil

results were also prepared by Weston and are provided in Appendix B. A summary ofEPAs soil sample results is as follows:

Barium, chromium (total), and lead were detected at low concentrations (i.e.,below current RCS-1 values of 1,000 mg/kg, 30 mg/kg, and 300 mg/kg,respectively, for these three metals), and arsenic, cadmium, mercury, selenium,and silver were not reported above method detection limits in the six test pit soilsamples.

Silver was detected at elevated concentrations (i.e., above the current RCS-1 andMethod 1, S-1 standard of 100 mg/kg) in the surficial soil samples collected nearthe two former wastewater treatment basins. Cadmium was also detected above2 mg/kg in these two samples. As further reviewed below in Section 2.3.2, the

impacted surficial soils near the two former wastewater treatment basins weresubsequently removed during IRA activities conducted by Tighe & Bond.Cadmium was also detected above 2 mg/kg in three of the other surficial soilsamples (concentrations ranging between 3.09 mg/kg and 15.1 mg/kg). Barium,chromium (total), and lead were detected at low concentrations, and arsenic andselenium were not reported above method detection limits in the six surficial soilsamples. Mercury was detected at low concentrations (i.e., below current RCS-1value of 20 mg/kg) in two of the surficial soil samples.

PAHs were reported above the method detection limits in two of the test pitsamples. In the soil sample collected from approximately 10 feet below grade ina test pit excavated in the general location of the former 20,000-gallon fuel oilUST, four PAHs (including benzo(a)anthracene, benzo(b)fluoranthene,

benzo(a)pyrene, and dibenzo(a,h)anthracene) were detected at elevatedconcentrations (i.e., above the current RCS-1 values). As further reviewed belowin Section 2.3.2, the impacted subsurface soils in this area were subsequentlyremoved during IRA activities conducted by Tighe & Bond. No other PAHs werereported at elevated concentrations in the test pit soil samples.

In a surficial soil sample collected adjacent to (west of) former Building #3 and ina surficial soil sample collected near the former wastewater basin adjacent toBuilding #2, benzo(a)pyrene was detected above the current RCS-1 value of 2mg/kg. As further discussed in Section 2.3.2, the impacted surficial soils in thesetwo locations were subsequently removed during IRA activities conducted byTighe & Bond. No other PAHs were detected at elevated concentrations in thesurficial soil samples.

Tetrachloroethene was detected at 0.014 mg/kg and 0.015 mg/kg (i.e., wellbelow the current RCS-1 value 1 mg/kg) in two of the test pit soil samples. Noother VOC was reported above the method detection limits in the test pit soilsamples.

No PCBs were reported above method detection limits in the test pit soil samplesor in the surficial soil samples submitted for PCB analysis.

Cyanide (total) was detected at a very low concentration of 0.29 mg/kg (i.e., wellbelow the current RCS-1 value of 100 mg/kg) in one test pit soil sample.


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Cyanide was not reported above method detection limits in the other test pit soilsamples or in the surficial soil samples submitted for cyanide analysis.

Methanol and formaldehyde were not reported above method detection limits inthe test pit soil samples.

2.3.1.4 Summary of MADEP InvestigationsFollowing the conclusion of EPAs work, MADEP collected soil/sediment and surface waterfrom along the bank of the Hoosic River on July 14, 1998 to assess the potential impactsto the river from the site. A total of five sediment samples, four surface water samples,and one soil sample were collected for laboratory analysis. A copy of a site planprepared by MADEP that shows the approximate locations where MADEP collected thesamples is provided in Appendix B for reference.

Sediment sample PR-1 was collected near the southeastern corner (upstream edge) ofthe property, and each of the other sediment samples was collected progressivelydownstream of the PR-1 location with sediment sample PR-5 being collected near thenortheastern corner of the property near the Cole Avenue bridge. Sediment samplesPR-3 and PR-4 were collected adjacent to the two discharge/outfall pipes located east ofBuilding #2. At each of these sediment sample locations (except PR-1), surface watersamples were also collected. Lastly, one soil sample was collected from the river bank inthe same general vicinity of where EPA had collected a surficial soil sample near theformer wastewater treatment basin that abutted Building #2.

Each of the samples was submitted for laboratory analysis of PCBs, RCRA 8 metals, andSVOCs. A copy of a data table summarizing sample results prepared by MADEP isprovided in Appendix B for reference. A summary of MADEPs sample results is asfollows:

The concentrations of metals and SVOCs (four PAHs were detected) detected inthe five sediment samples were fairly consistent with each result well within the

same order of magnitude. No PCBs were detected in the sediment samples. Itshould also be noted that silver was not detected in any of the sediment samples,and cadmium concentrations ranged between 1.2 mg/kg and 3.1 mg/kg in thesediment samples.

Two metals (barium and chromium) were detected in the surface water sampleswith their concentrations also being consistent with one another. No SVOCs orPCBs were detected in the four surface water samples.

As MADEP also reported that although there are no MCP standards for sedimentand surface water, the results were below both the MCP's Groundwater-1 andSoil-1 standards.

No PCBs, RCRA 8 metals or SVOCs were detected in the one soil sample.

2.3.1.5 Conclusions

In general, the results from the previous investigations indicated the following:

Surficial soils in the vicinity of the two former wastewater treatment basins wereimpacted by elevated concentrations of silver and cadmium.

Subsurface soils in the vicinity of the former 20,000-gallon fuel oil UST to thesouth of Building #2 were impacted by elevated concentrations of petroleum-related compounds including PAHs.


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Surficial soils adjacent to (west of) former Building #3 were impacted by elevatedconcentrations of one PAH compound.

No contaminants detected in groundwater exceeded applicable (and current)RCGW-1 values.

No significant impacts from the site to sediments or surface water within the

abutting Hoosic River were encountered. Furthermore, the two primary metals ofconcern for the site (silver and cadmium) were either not detected or weredetected at consistently low concentrations from the upstream to thedownstream portions of the river bank area abutting the site. These findingssuggested that the contaminants identified in sediments and in the surface waterbody could be attributed to local conditions.

2.3.2 Tighe & Bonds MCP Investigations

As reviewed above, the known product primarily used or stored at the site waspetroleum and the known wastes primarily generated at the site were silver andcadmium-containing wastewater and sludge. Based on this history and the results ofprevious investigations, the primary focus of our MCP investigations was further

assessment (and remediation) of petroleum contaminants (including PAHs) and silverand cadmium.

2.3.2.1 Phase I Investigations

As further discussed in our May 2003 Phase I report submittal, Tighe & Bond conductedsubsurface investigations at the site between August 2000 and May 2003 as part ofPhase I and pre-IRA excavation activities. In general, these investigations included thefollowing:

The advancement of 38 soil borings (identified as B-1 through B-30, B-1A, B-26A, B-27A, TB-1, TB-2A, TB-2B, TB-3, and TB-4).

The completion of borings TB-1, TB-2B, TB-3, and TB-4 as groundwater

monitoring wells.

The submittal of 75 soil boring samples and two additional surficial soil samples(identified as SS-GEN and SS-Bldg 3) for laboratory analysis. [Note: Of the 75soil boring samples submitted for laboratory analysis, 72 of the samples werecollected from shallow depth intervals of less than three feet below surfacegrade.] The soil samples were submitted for laboratory analysis of silver (71samples), cadmium (71 samples), lead (26 samples), EPH with target PAHs (6samples), and/or VOCs (1 sample).

The collection of groundwater samples from the newly installed wells TB-1, TB-2B, TB-3, and TB-4, and from existing well MW-2 in August 2000, and the re-sampling of well TB-4 in October 2000 and well TB-2B in April 2003. Thegroundwater samples were submitted for laboratory analysis of dissolved silver,cadmium and lead (5 samples), EPH with target PAHs (5 samples), and/or VOCs(5 samples).

The approximate locations of the Phase I soil borings, monitoring wells, and surficial soilsamples are shown on Figure 4, with the exception of the following:


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Borings B-1A, B-9, B-21, B-26A, and B-30, and surficial soil sample location SS-Bldg 3 because these sample locations were subsequently excavated during IRAactivities, as further described below.

Wells TB-2 and TB-4 which were subsequently replaced by wells MW-2B and MW-1, respectively, during Phase II investigations, as further described below.

In general, the significant findings from our Phase I investigations were as follows:

Silver and/or cadmium were detected at elevated concentrations (i.e., aboveapplicable Method 1 standards at that time) in several additional shallow soilsamples collected in the vicinity of the two former wastewater treatment basins(consistent with EPA findings), and in shallow soil samples collected on thesouthern portion of the site.

A total cadmium concentration above the Imminent Hazard threshold of 60mg/kg cadmium was also identified in select soil samples in the vicinity of theformer wastewater treatment basin adjacent to Building #2. This findingtriggered a 2-hour IRA condition (reported on May 5, 2003).

Target PAHs were detected at elevated concentrations (i.e., above applicableMethod 1 standards at that time) in shallow soils adjacent to (west of) formerBuilding #3 (consistent with EPA findings) and in the vicinity of the former20,000-gallon fuel oil UST.

The EPH carbon fraction C11-C22 aromatics was detected at 223 g/L inmonitoring well TB-2B during the second (April 2003) sampling event. Thisconcentration exceeded the Method 1, GW-1 standard of 200 g/L.

Tables 2-1, 2-2, and 2-3 provided in Appendix C summarize soil results from the initialPhase I investigations (conducted in August 2000), historical results for cadmium andsilver in site soils, and historical groundwater results from Tighe & Bonds investigations,respectively. In the tables, soil and groundwater results are compared to current

Method 1 standards (i.e., since the Wave 2 changes to the MCP became effective inApril 2006) for reference. It should also be noted that soil results from Tighe & Bond'searlier investigations that were ultimately removed during our subsequent IRA activitiesare not included in Tables 2-1 and 2-2.

2.3.2.2 IRA Completion

As part of IRA cleanup activities conducted in June 2003, the excavation ofcontaminated soils for proper off-site disposal occurred in six different areas of concernat the site. This cleanup work included the following:

Excavation of approximately 40 cubic yards (62.95 tons) of cadmium-impactedsurficial soils characterized as hazardous waste from where the Imminent Hazard

condition was identified in earlier soil samples (i.e., in the vicinity of the formerwastewater treatment basin adjacent to Building #2).

Excavation of approximately 600 cubic yards (859.99 tons) of non-hazardouscadmium and silver-impacted soils in three areas of concern. This included thefollowing:

o Continued soil excavation in the vicinity of the former wastewatertreatment basin adjacent to Building #2 on top of and along the riverembankment. The excavation occurred over an approximate 4,090


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square-foot area. The depth of excavation was generally less than onefoot below grade on the upper portions of this area (i.e., closer to Building#2) and up to 3.5 feet below grade along the river bank area. Excavationalong the embankment was performed to the extent feasible, whilemaintaining stability of the slope and several of the relatively largerexisting trees, in accordance with Conservation Commission requirements.

Upon completion of this excavation, the embankment was re-graded to aconsistent slope and covered with 0.5 to 2 feet of angular stone rip-rapalso in accordance with the Conservation Commission EmergencyCertification for this work.

o Soil excavation across an approximate 2,530 square-foot area to theimmediate south of the other former wastewater treatment basin. Thetotal depth of the excavation across this area was between approximately0.5 and 3 feet below grade.

o Soil excavation across an approximate 5,200 square-foot area on thesouthern portion of the site in the general vicinity of a former drumstorage area. The total depth of the excavation across this area was

between approximately 0.5 and 3 feet below grade. In this area, a 55-gallon drum containing asbestos containing material (ACM) was alsoencountered and ultimately removed for off-site disposal during the IRA.

Excavation of approximately 300 cubic yards (total of 447 tons) of petroleum-impacted soil from three areas of concern. This included the following:

o Excavation of surficial soils across an approximate 310 square-foot areaadjacent to (west of) the former Building #3 location (also referred to asformer Barn B area) where elevated PAHs were previously identified.The total depth of this excavation was approximately one foot.

o Excavation of subsurface soils from approximately 7 to 11 feet belowgrade across an approximate 400 square-foot area in the former 20,000-gallon fuel oil UST area where elevated PAHs (and oil and grease) werepreviously identified.

o The abandoned 20,000-gallon No. 2 fuel oil UST to the west of Building #2was removed as part of the IRA activities because there were reports thatthe tank previously had a leaking suction line. This included demolition ofa four to five-foot thick concrete pad overlying the entire tank, removal of122 gallons of residual oily water and sludge from the bottom of the tank,and excavation of subsurface soils from portions of the excavation whereevidence of a petroleum release was encountered. Petroleum-impactedsoils were removed from approximately 5 to 14 feet below grade acrossan approximate 1,480 square-foot area.

At the completion of the IRA excavations, the areas were backfilled to grade with cleansoil, unless otherwise noted above. The approximate limits of the earlier IRA excavationareas are included on Figure 4 for reference. Subsequent confirmatory soil samplingand other assessment that occurred in the IRA excavation areas was completed underPhase II.

2.3.2.3 Phase II Investigations

Between June and July of 2003, Tighe & Bond completed confirmatory soil samplingand/or additional investigations in each of the six IRA excavation areas. Additional


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assessment occurred in areas outside of the known release areas at the site and in theHoosic River. In general, the Phase II investigations included the following:

The collection of 28 final confirmatory soil samples for laboratory analysis ofcadmium and silver, and the collection of 16 confirmatory soil samples for EPHanalysis. [Note: Two additional confirmatory soil samples were for laboratory

analysis of cadmium and silver, but those representative soils were subsequentlyremoved during additional IRA activities, as further discussed below.]

The advancement of 14 additional soil borings, with three of the borings beingcompleted as groundwater monitoring wells identified as MW-1 (replacing earlierwell TB-4), MW-2B (replacing earlier well TB-2), and MW-3. From the soilborings, 11 additional soil samples were submitted for EPH analysis for furtherdelineation of petroleum impacts.

The advancement of 21 additional shallow hand auger borings and/or exploratorytest pits for further delineation of metals impacts. From those locations, 41additional soil samples (from varying sample intervals) were submitted foranalysis of cadmium and silver.

The collection of three additional groundwater samples for EPH analysis.

The collection of three surface water samples for total cadmium and silveranalysis.

The collection of three background soil samples for analysis of cadmium andsilver.

The approximate locations of the IRA confirmatory soil samples and other Phase IIdrilling, test pitting, and/or sampling locations are included on Figure 4. Laboratoryresults from these earlier Phase II investigations are summarized in Tables 2-2, 2-3, and2-4 (Appendix C), as further discussed below. For details on these earlier Phase IIinvestigations (including boring and test pit logs, complete laboratory reports, etc.),refer to the 2004 Phase II report.

Former Basin Adjacent (East) to Building #2: During the IRA activities, finalconfirmatory soil samples were collected from 10 separate locations (identified as B-1B,B-24A through B-24D, B-26B, B-26C, B-27B, B-27C, and B-30A) within this excavationarea. One soil sample from each location was submitted for analysis of cadmium andsilver. [Note: Two additional confirmatory soil samples were collected from this area aspart of IRA activities. Confirmatory soil sample B-30 (1-1.5) was collected on June 9,2003 from the B-30 boring location and confirmatory soil sample B-31 (6) (i.e., from sixinches below grade) was collected on June 2, 2003. Soils represented by these twosamples were subsequently removed during continued IRA excavation activitiesconducted in this area. Therefore, these sample locations are not shown on Figure 4and those earlier cadmium and silver results are not included in Table 2-2.]

Also in June 2003, hand borings were advanced at three additional locations (identifiedas B-32, B-33, and B-34) outside the limits of this IRA excavation area. From thesehand boring location, four soil samples were submitted for analysis of cadmium andsilver.

In July 2003, two additional hand auger borings were advanced within the limits of thisIRA excavation area in the area of earlier confirmatory sample locations B-30A and B-27C. Samples B-30A(5') and B-27C(3.5') were collected below the previous IRA


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confirmatory sample depths at these locations, and submitted for analysis of cadmiumand silver.

The cadmium and silver results for the 16 representative soil samples collected fromthis area during these earlier Phase II activities are included in Table 2-2. Assummarized, cadmium and/or silver were detected at elevated concentrations (i.e.,

above current Method 1 standards) in several of the soil samples. Also, the cadmiumconcentration of 199 mg/kg in sample B-30A(3') remained above the IH threshold of 60mg/kg. However, as described in the earlier Phase II report, this sample does notrepresent an IH condition as it is located beneath 2 feet of rip-rap and is not consideredaccessible.

Former Basin Further Southeast of Building #2: During the IRA activities,confirmatory soil samples were collected from seven separate locations (identified as B-20A, B-20B, and B-22A through B-22E) within this excavation area. From theselocations, a total of nine soil samples (collected from varying depths) were submitted foranalysis of cadmium and silver.

The cadmium and silver results for the nine soil samples collected from this area duringthese earlier Phase II activities are included in Table 2-2. As summarized, cadmiumand/or silver were detected at elevated concentrations (i.e., above current Method 1standards) in several of the soil samples.

Metals-impacted area on Southern Portion of Site: During the IRA activities,confirmatory soil samples were collected from nine separate locations (identified as B-7.1, B-7.2, B-9A, B-9B, B-10A, B-10B, B-10C, B-16A, and B-16B) within the excavationconducted in this former drum storage area. From these locations, a total of 11 soilsamples were submitted for analysis of cadmium and silver.

In July 2003, six elongated test pits (identified as test pits B-7AB, B-7C, B-7DE, B-7.3F,B-7GH, and B-7.4I) were excavated outside the limits (to the east and south) of the IRA

excavation area for further delineation of metals-impacts at varying depths between 0 to0.5 feet, 0.5 to 3 feet and 3 to 6 feet below grade. In general, sand and gravel fill wasencountered to depths of 3 to 5 feet below grade, below which gray to brown silt andsand was encountered in each of the test pits. Significant percentages of debris(including metal, bricks, wood, concrete, ash, coal, clay pipe, glass and paper) wereencountered in layers within the fill in test pit sample locations B-7AB, B-7C, B-7E andB-7F. A total of 30 soil samples collected from within these six test pit exploration areaswere submitted for silver and cadmium analysis. Pieces of transite board were alsoobserved in the fill at sample locations B-7A(3') and B-7F(4'), and that suspect ACMmaterial was submitted for analysis to determine asbestos content. In addition,samples B-7A(0.5-3') and B-7F(3-5') were collected from soil in the immediate vicinityof the ACM for asbestos analysis to evaluate potential impacts to soil.

In July 2003, three test pit explorations (identified as B-9A, B-9CD, and B-16C) werealso excavated through sand and gravel backfill within limits of the former IRAexcavation area. Three soil samples collected from these test pits were submitted foranalysis of cadmium and silver to further delineate vertical impacts. In addition, soilsample B-16C(4-5') collected from the vicinity of the former 55-gallon drum containingACM (removed during the IRA) was submitted for asbestos analysis to evaluate potentialimpacts to soil.


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The cadmium and silver results for the 44 soil samples collected from this area duringthese earlier Phase II activities are included in Table 2-2. As summarized, cadmiumand/or silver were detected at elevated concentrations (i.e., above current Method 1standards) in several of the soil samples.

It should also be noted that the suspect ACM from sample location B-7F(4') was found to

contain 20% chrysotile asbestos. Asbestos was not detected in soil samples B-7A(0.5-3'), B-7F(3-5'), and B-16C(4-5').

Former 20,000-gallon Fuel Oil UST Area: During the IRA activities, confirmatory soilsamples were collected from the four sidewalls (identified as B-21 East, B-21 South, B-21 West, and B-21 North) of the excavation at separate intervals of 0 to 7 feet belowgrade and 7 to 11 feet below grade. A confirmatory soil sample was also collected fromthe base of the excavation (identified as B-21 Bottom). Each of these nine confirmatorysoil samples was submitted for EPH analysis. Observation of the soils encountered inthe excavation indicated the presence of fill (consisting of concrete, bricks, metal,cobbles, wood, coal and cinder/ash) in both the shallow and deeper soils in theexcavation. Four of the confirmatory sidewall soil samples were subsequently submitted

for microscopic analysis to confirm the presence of coal and/or ash. In addition, a testpit (identified as Basin TP) was excavated outside the limits of this IRA excavation forfurther soil characterization, and soil samples collected from 1 to 5 feet below grade and7 to 11 feet below grade from this test pit were also submitted for EPH analysis.

In July 2003, a total of 12 additional soil borings (identified as B-21A through B-21L)were advanced in areas outside the limits of this IRA excavation. In general, soilsencountered in these borings were consistent with those found within the IRA excavationand consisted of approximately 7 feet of fill (concrete, brick, limestone cobbles, wood,coal and cinder/ash) overlying gray to dark gray silty fine sand with trace organics(wood fiber) to 11 feet below grade. Apparent native gray silty fine sand wasencountered between 11 and 12 feet below grade. As shown on Figure 4, this IRAexcavation area and most of these surrounding borings were located in the area of the

former canal headrace that directed Hoosic River water to the mill. It appears that thetop 7 feet of soil consists of fill used to backfill in the former canal, and that the darkgray organic silt and sand between 7 and 11 feet below grade may consist of riversediment that collected at the base of the former canal. From these 12 soil borings, 11additional soil samples were submitted for EPH analysis. Four of the samples were alsosubmitted for microscopic analysis.

A summary of the EPH results is provided in Table 2-4. Within the table, soil results arecompared to current Method 1 standards for reference. The target PAH results are alsocompared to MADEPs identified background levels in soils containing coal, coal ash orwood ash associated with fill material. As shown, EPH carbon ranges were belowMethod 1 standards in each of the 11 confirmatory soil samples. Target PAHs, includingacenaphthylene, benzo(a)pyrene, and/or dibenzo(a,h)anthracene, were detected aboveMethod 1, S-1/GW-1 standards in five of the samples. Acenaphthylene and/ordibenzo(a,h)anthracene were also detected slightly above MADEPs background valuesfor soil containing coal and/or ash in the samples. Particles of coal, coal ash, and/orwood ash were also identified in each of the eight samples submitted for microscopicanalysis. Small amounts of coal tar were also identified in two of the samples.

Former Abandoned 20,000-gallon No. 2 Fuel Oil UST: Following the removal of theabandoned tank and the petroleum-impacted soils, four confirmatory samples were


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submitted for EPH analysis. The samples selected for analysis from this former TB-3well location were labeled TB-3 Bot-2, TB-3 NW-2, TB-3 SW-4, and TB-3 EW-3.

A summary of the EPH results is provided in Table 2-4. As shown, EPH carbon rangesand target PAHs were not detected above laboratory reporting limits in any of the fourconfirmatory soil samples.

Former Barn B Area: In this PAH-impacted soil area adjacent to (west of) theformer Building #3 location, one confirmatory soil sample (labeled Barn B-2) wascollected from the IRA excavation for EPH analysis.

A summary of the EPH results is provided in Table 2-4. As shown, low concentrations(i.e., below Method 1 standards) of EPH carbon ranges and target PAHs were detected inthe confirmatory soil sample.

Surface Water Sampling: Three surface water samples were collected from theHoosic River from locations generally upstream (sample SW-1) and downstream(samples SW-2 and SW-3) of the metals-impacted area of the site (See Figure 4 for

reference). Each sample was submitted for total cadmium and silver analysis. Neithermetal was detected above laboratory reporting limits in the three surface water samples.

Other Background Sampling: Three background soil samples (labeled as S-BKGRND1, S-BKGRND2, and SBKGRND3) were collected from the north/northwesternportion of the site off Cole Avenue (see Figure 4 for reference). Each sample wascollected from approximately 0 to 1 feet below grade and submitted for analysis ofcadmium and silver. Neither metal was detected above laboratory reporting limits in thethree soil samples.


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Tighe&Bond


Section 3Supplemental Phase II Investigations

Tighe & Bond conducted supplemental investigations at the site between June 2012 and

July 2012. In general, the purpose of these investigations was to update site conditionsand to further evaluate impacts to environmental media across the site in preparationfor future site remediation (as needed) prior to the planned redevelopment of the site.This included subsurface investigations in previously un-assessed areas, and furtherevaluation of the cadmium in soils across the site since the change in MCP Method 1standards in 2006.

3.1 Drilling EventDrilling occurred at the site on July 9 and July 10, 2012. Drilling was conducted byMartin Geo-Environmental, LLC of Belchertown Massachusetts under Tighe & Bondobservation. The drilling event included the following:

The advancement of eight soil borings using a truck-mounted Mobile Drill B-53rig and the hollow stem auger (HSA) drilling method

The advancement of 17 additional soil borings using a track-mounted GeoprobeModel 6610DT vibratory direct-push probe unit.

Based on a survey completed by Tighe & Bond using Global Positioning System (GPS)equipment, the approximate locations of the borings are shown on both theOrthophotograph (Figure 3) and Site Plan (Figure 4) for reference. Further details areprovided below.

3.1.1 Soil Boring Advancement

3.1.1.1 HSA Method

On July 9, 2012, borings B-101, B-102, B-103, B-103A, B-104, B-105, B-106, and B-107 were advanced using the HSA drilling method. During boring advancement, soilsamples were collected in five foot intervals using two-foot split-spoon samplers forlogging site stratigraphy. Each boring was advanced to a depth below the groundwatertable interval. Boring logs prepared by Tighe & Bond are provided in Appendix D forreference.

In general, fill soils were encountered to total depths of less than five feet below grade(in borings B-106 and B-107) to greater than seven feet below grade (in borings B-103and B-104). A minor amount of brick debris was encountered in the fill in borings B-101, B-102, B-105, and B-106. In general, sand and gravel were encountered below

the fill in borings B-101, B-102, B-104, B-105, and B-107. In borings B-102, B-103A,B-106, and B-107, a silt layer with intervals of clay was encountered at depth. At boringB-102, advanced within the footprint of the former Building #1 (see Figure 4), augeradvancement occurred through concrete at approximately five feet below grade. Theconcrete is presumably associated with the former building foundation. At boringlocation B-103 advanced between Building #2 and the river (i.e., in the area of theformer wastewater treatment basin), auger refusal occurred at approximately 12 feetbelow grade. Boring B-103A was advanced approximately 30 feet to thenorth/northwest of B-103 (see Figures for reference). At boring location B-106, some


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staining and little petroleum type odor were encountered in the shallow fill soilsimmediately beneath the paved surface area. [Note: This boring was advanced ingeneral vicinity of the former 6,000-gallon methanol UST removed in 1986.] Nosignificant evidence of petroleum contamination or other suspect discoloration (e.g.,petroleum staining) or odors were noted in any of the other soil samples collected fromthese eight borings.

3.1.1.2 Direct-Push Method

On July 10, 2012, borings B-108 through B-124 were advanced across the site using thevibratory direct push method. During boring advancement, soil samples were collectedin four-foot increments using macro-core samplers. Each boring was advanced to fourfeet below grade. Borings B-111, B-112, B-114, B-117, B-121, B-122 and B-124 wereadvanced to eight feet below grade for further soil characterization at depth. Table 3-1which summarizes the soil boring findings is provided in Appendix C for reference.

In general, fill soils were encountered in each of the borings. In the fill, brick and/orconcrete debris were encountered in 10 of the borings, and evidence of coal and/or ashwere also observed in four of the borings. In boring B-124 advanced in the paved

surfaced area to the northwest of Building #2 (see Figure 4), a layer of gray soil withpetroleum type odor was observed in soils generally between 2 and 4 feet below grade.No significant evidence of petroleum contamination or other suspect discoloration (e.g.,petroleum staining) or odors were noted in any of the other soil samples collected fromthese 17 borings.

3.1.2 Monitoring Well Installations

As part of the July 9, 2012 drilling event, soil borings B-101, B-103A, B-104, and B-107were completed as groundwater monitoring wells MW-4, MW-5, MW-6 and MW-7,respectively. As shown on Figure 4, the general locations of the new wells is as follows:

Well MW-4 was installed on the north/northeastern portion of the site.

Well MW-5 was installed on the eastern portion of the site within the former IRAexcavation for metals-impacted soils in this area, immediately downgradient ofthe former Building #1 and Building #2 connection.

Well MW-6 was installed on the southern portion of the site within the former IRAexcavation for metals-impacted soils.

Each well was completed with two-inch diameter, Schedule 40 PVC riser and 10 feet of0.010-inch slotted well screen set across the groundwater table as encountered duringdrilling. Clean, washed silica sand was placed in the boring annulus around the wellscreen to a depth of approximately two-feet above the well screen, and a two-footbentonite seal was placed above the sand pack. Native backfill was placed above thebentonite seal. Wells MW-4, MW-5, and MW-6 were completed with a protective steel

standpipe casing cemented in-place. Well MW-7, situated in the paved surface area,was completed at the surface with flush-mounted road box cemented in place.Monitoring well details are included on the borings logs proved in Appendix D.

3.2 Soil SamplingDuring the July 9 and July 10, 2012 drilling event, soil samples collected fromapproximately 0 to 2 feet below grade in borings B-108, B-113, B-114, B-115, B-116, B-122, and B-124 were submitted for the laboratory analysis of cadmium and silver to


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further characterize the metals impacts in shallow soils across the site. In addition, soilboring samples B-103 (5-7), B-103A (10-12'), B-113 (2-4), B-114 (4-8), B-117 (2-4'),B-117 (4-8'), B-121 (0-4), and B-124 (2-4) were submitted for analysis of cadmiumand silver to further characterize the metals impacts at depth. Soil boring samples B-104 (5-7), B-105 (5-7), B-105 (12-13), B-106 (0-2), and B-124 (2-4) were submittedfor analysis of EPH with target PAHs.

On July 26, 2012, Tighe & Bond collected additional soil samples using a stainless steelhand auger. As part of this event, borings B-125 through B-129 were advanced alongthe east/southeastern portions of the site near or along the slope embankment to theriver. The locations of these hand borings were also surveyed using GPS equipment andare shown on Figures 3 and 4. Soil samples collected from approximately 0 to 2 feetbelow grade in each hand boring were submitted for analysis of cadmium and silver tofurther delineate the metals impacts in shallow soils in those areas.

3.3 Groundwater SamplingOn July 26, 2012, Tighe & Bond personnel collected groundwater samples from the three

newly installed monitoring wells, and from existing monitoring wells MW-1, MW-2B, andMW-3 described earlier.

3.3.1 Groundwater Collection

Groundwater samples were collected using low-flow procedures, in general compliancewith U.S. Environmental Protection Agencys Region I Low Stress (low flow) Purging andSampling Procedure. During low flow purging of the wells, field measurements for pH,conductivity, oxidation reduction potential (ORP), dissolved oxygen (DO), andtemperature were monitored using a Horiba water quality meter and a flow-throughcell. Turbidity was measured separately using a Turbidimeter. Copies of Tighe & BondsWell Purging Field Water Quality Measurements Forms from this event are provided inAppendix C.

Low flow purging occurred for a minimum of 30 minutes at each well prior to beginningsampling. DO and/or turbidity readings did not properly stabilize in accordance with EPAprotocols before sampling occurred at many locations. When turbidity readings are highit typically overestimates the concentrations of contaminants in a well. Consequently, itis our opinion that this does not represent an issue with respect to the groundwater datacollected from those wells. No sheens of odors were noted in the purged water prior tosampling.

Each of the six groundwater samples was submitted for laboratory analysis of EPH withtarget PAHs, and dissolved cadmium and silver. Each of the water samples submittedfor dissolved metal analysis was filtered in the field using separate 0.45 micron filtersbefore preserving.

3.3.2 Groundwater Flow

On July 26, 2012, Tighe & Bond personnel surveyed the relative elevation of the top ofeach well based on an assumed datum. Using groundwater gauging information wecollected, groundwater elevations were calculated for each well, and groundwatercontours were developed for the site. Table 3-2, provided in Appendix C, summarizesthe calculated groundwater elevations for the six wells. Based on these calculatedelevations, a Groundwater Contour Plan was developed and is provided as Figure 5 inAppendix A.


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As shown on Figure 5, the groundwater flow direction was calculated to be to theeast/northeast toward the river across the northern and central portions of the site. Onthe portion to the south of Building #2, the groundwater hydraulics may be influencedby the former canal system that ran through this portion of the site as the calculatedgroundwater elevations for wells MW-1 and MW-6 (situated within or near the formercanal channel) are similar to or lower than in the assumed downgradient wells MW-2B

and MW-3 situated to the east, nearer to the river. Therefore, groundwater contoursand flow direction cannot be easily deciphered for this portion of the site without furtherdata.

3.4 Sediment and Surface Water SamplingOn July 26, 2012, Tighe & Bond personnel collected eight sediment samples from thesite. Each sediment sample was collected from the observed river bank/water interfaceat the time of the sampling event. Sediment samples were collected using a stainlesssteel spoon or a stainless steel hand auger, and the sediment was homogenized in astainless steel bowl. Sampling equipment was decontaminated with an Alconox solutionbetween sample locations. Sediment samples were placed in laboratory-supplied

containers for analysis. A brief description of the sampling locations is as follows:

Sample SED-1 was collected upstream of the site at a location off the subjectproperty. No notable conditions were observed at this sampling location.

Samples SED-2 and SED-3 were collected downstream of sample SED-1 andupgradient of Building #2. Minor debris (brick, concrete and scrap metal) wereobserved near these sampling locations.

Samples SED-4 and SED-5 were collected below the base of two outfall pipes thatwere observed down slope of Building #2. These two outfall pipes were alsoshown on MADEPs 1998 sediment sample location plan and our samplinglocations generally correspond to MADEPs sample locations PR-3 and PR-4,

respectively (see Appendix B for reference). Moderate flow was observeddischarging from both outfall pipes. A red-brown leachate was also observedseeping from the river bank at a location approximately 40 feet upstream of SED-4.

Sample SED-6 was collected slightly downstream of sample SED-5 at a locationimmediately below the former IRA soil excavation to the east of Building #2.Notable conditions were not observed at this sampling location.

Sample SED-7 was collected downstream of sample SED-6 at a location east offormer Building #1. No notable conditions were observed at this samplinglocation.

Sediment sample SED-8 was collected on the downstream portion of the site,

near the bridge crossing for Cole Avenue. No notable conditions were observedat this sampling location.

Each of the eight sediment samples was submitted for laboratory analysis of cadmiumand silver.

Also as part of this event, surface water samples SW-4, SW-5, and SW-6 were collectedfrom sediment sample locations SED-1, SED-6, and SED-8, respectively. The three


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surface water samples were submitted for laboratory analysis of EPH and total cadmiumand total silver.

3.5 Laboratory ResultsThe soil, groundwater, sediment and surface water samples collected during oursupplemental Phase II investigations were submitted to Con-Test Analytical Laboratory(Con-Test) of East Longmeadow, Massachusetts. Laboratory reports are provided inAppendix E.

3.5.1 Soil Results

Soil results for the 24 soil samples submitted for laboratory analysis as part of oursupplemental Phase II investigations are summarized in Table 3-3 provided in AppendixC. Within the table, soil results are compared to Method 1 standards. Also forreference, soil results are compared to MADEPs identified background levels in soilscontaining coal, coal ash or wood ash associated with fill material.

As shown, EPH was not detected above Method 1 standards in any of the five samples

submitted for EPH analysis. In three of the samples, EPH carbon ranges and the targetPAHs were not detected above laboratory reporting limits.

In seven of the 20 samples submitted for metals analysis, cadmium was detected abovethe S-1 standard of 2 mg/kg. In general, those seven samples were collected fromsoutheastern and eastern portions of the site in the general vicinity of the earlier IRAexcavations of metals-impacted soils. In those samples, cadmium concentrationsranged between 2.1 mg/kg and 28 mg/kg (i.e., lower than the previous standard of 30mg/kg prior to the Wave 2 changes to the MCP). Cadmium was not detected above 2mg/kg in soil samples collected from the northern portions of the site (including withinthe footprint of former Building #1) or in areas to the west and northwest of Building#2. In boring sample B-117 (4-8), silver was detected at the Method 1 standard of 100mg/kg. As shown on Figure 4, boring B-117 was advanced within the former IRAexcavation for the metal-impacted soils in the former basin area adjacent to Building#2. Silver results for the other 19 soil samples were all below 100 mg/kg.

3.5.2 Groundwater Results

Groundwater results for the six groundwater samples submitted for laboratory analysisas part of our supplemental Phase II investigations are summarized in Table 3-4provided in A

Report T&B-Photech Phase II-III Draft 1

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