198 River Street

New Haven, Connecticut

Self-Implementing On-site

PCB Cleanup & Disposal Plan

Prepared For:

The City of New Haven

July 19, 2024

Tighe & Bond Project No. 23-5005-016D

Table of Contents Tighe&Bond i

Section 1 Introduction

1.1 Purpose ........................................................................................1-1

1.2 Project Contact Information .............................................................1-1

1.3 Site Description and History ............................................................1-2

1.4 Project Background ........................................................................1-3

1.5 Remediation Criteria .......................................................................1-3

1.6 Remedial Action Objectives & Selected Strategy .................................1-5

1.7 Plan Organization ...........................................................................1-6

Section 2 Previous Investigations

Section 3 Supplemental Site Characterization

3.1 Sample Collection ...........................................................................3-1

3.2 Sample Analytical Results ................................................................3-1

3.2.1 Soil Analytical Results ........................................................... 3-2

3.2.2 Debris Analytical Results ....................................................... 3-2

3.2.3 Concrete Analytical Results .................................................... 3-2

3.2.4 Site Characterization Summary .............................................. 3-2

3.3 Data Quality Assessment / Data Usability Review ...............................3-2

3.3.1 Sample Management .............................................................. 3-3

3.3.2 Duplicate Samples ................................................................. 3-3

3.3.3 Trip Blanks ............................................................................ 3-3

3.3.4 Laboratory Quality Control ...................................................... 3-3

3.3.5 Data Usability Evaluation ........................................................ 3-5

3.4 PCB Waste Stream Characterization and Disposal Requirements ..........3-5

3.4.1 Solid PCB Remediation Waste Disposal .................................... 3-5

3.4.2 Liquid PCB Remediation Waste Disposal .................................. 3-5

Section 4 Conceptual Site Model

Section 5 Remediation Plan

5.1 General Requirements ....................................................................5-1

5.2 Other Activities Related to PCB Remediation ......................................5-1

5.3 Waste Characterization Sampling .....................................................5-1

5.4 Marking of PCB-Impacted Material Limits ..........................................5-2

5.5 Site Preparation and Controls ..........................................................5-2

5.6 Worker Decontamination .................................................................5-2

5.7 PCB Remediation Waste Removal Procedures .....................................5-3

5.8 Decontamination Procedures ...........................................................5-6

5.9 Dust Monitoring & Air Sampling ........................................................5-6

5.10 Project Remediation Plan .................................................................5-7 ii

5.10.1 Area 1 ................................................................................ 5-7

5.10.2 Area 2 ................................................................................ 5-8

5.10.2 Area 3 ................................................................................ 5-8

5.11 ELUR & TSCA DEED Restriction ........................................................5-8

Section 6 Post-Remediation Verification Sampling Plan

6.1 Visual Inspection ............................................................................6-1

6.2 Verification Sampling ......................................................................6-1

Section 7 Schedule and Certification

7.1 Schedule .......................................................................................7-1

7.2 Certification ...................................................................................7-1

APPENDICES

Appendix A Figures and Drawings

Figure 1 Site Location Map

Figure 2 Site Plan with Exploration Locations

Figure 3 Areas of Environmental Concern & Confirmed Release Areas

Figure 4 Groundwater Flow Direction (June 13, 2016)

Figure 5A PCBs in Soil and Debris

Figure 5B Extent of PCBs in Soil & Debris Exceeding Regulatory Criteria

Figure 6 PCBs in Concrete and Proposed Extent of Removal

Figure 7 Groundwater Analytical Results

Figure 8 Proposed Soil Excavation Areas

Sheet C-101 Proposed Site Layout Plan, dated January 26, 2024

Appendix B Tables

Table 1 – Groundwater Monitoring Well Gauging Data

Table 2A – Historical Soil Analytical Data

Table 2B – Interior Soil Analytical Data (DTC)

Table 2C - Exterior Soil Analytical Data (DTC)

Table 2D - Soil Analytical Data – Transformer Spill Area (DTC)

Table 2E – Soil Boring Analytical Data (Tighe & Bond)

Table 2F – Shallow Soil & Debris PCB Data – Hand Borings (Tighe & Bond)

Table 3 – Debris PCB Analytical Data (DTC)

Table 4 – Summary of Waste Characterization Data

Table 5A – Interior Concrete PCB Analytical Data (DTC)

Table 5B – Exterior Concrete PCB Analytical Data (DTC)

Table 5C – Exterior Concrete PCB Analytical Data (Tighe & Bond)

Table 6A – Historical Groundwater Analytical Data

Table 6B – Groundwater Analytical Data – Well MW-202 (Tighe & Bond) iii

Appendix C Soil Boring and Monitoring Well Logs

Appendix D Laboratory Reports and Chain-of-Custody Forms

Tighe&Bond

PCB Cleanup and Disposal Plan 198 River Street, New Haven, CT 1-1

Section 1

Introduction

1.1 Purpose

This Self-Implementing Polychlorinated Biphenyl (PCB) Cleanup and Disposal Plan (the “Plan”) is being submitted by Tighe & Bond, Inc. on behalf of the City of New Haven (the City) for a parcel of land addressed as 198 River Street in New Haven, CT (the site). The purpose of the Plan is to support the removal and disposal of PCB impacted concrete, soil, and shallow urban fill material containing entrained scrapyard debris with concentrations of PCBs greater than 10 parts per million (mg/kg) (>10 mg/kg). The City is working with a developer, Bigelow Square, LLC, to redevelop the site with an approximately 12,000 square foot, one-story, slab-on-grade commercial building, fronting on River St., and sitewide asphalt paved drives and parking areas. Planned uses for the proposed building include assembly, light manufacturing, and/or warehouse space.

The Plan has been prepared in accordance with 40 CFR 761.61(a) and 61(c) with the intent of obtaining approval for the proposed cleanup plan from the US Environmental Protection Agency (EPA). The cleanup is also being performed to satisfy the requirements of Connecticut General Statute (CGS) 22a-463 through -469 (the PCB statutes) and

Regulations of Connecticut State Agencies (RCSA) Section 22a-133k-1 through -3, the Remediation Standard Regulations (RSRs), as pertaining to PCB cleanup of soil and groundwater. The location of the site is shown on Figure 1 (Appendix A). An aerial photograph of the site is shown on Figure 2.

The goal of the proposed remedial activities is to achieve compliance with 40 CFR §761.61(a) and 61(c), such that the remaining concrete and soil will not contain concentrations of PCBs >10 mg/kg after remediation is complete. The proposed remedial activities will also achieve compliance with the CT Department of Energy & Environmental Protection (DEEP) RSRs for PCBs and other contaminants of concern (COCs), as outlined in a Remedial Action Plan (RAP), dated January 26, 2024, prepared by Tighe & Bond.

1.2 Project Contact Information

City of New Haven:

Helen Rosenberg

Economic Development Officer City of New Haven Office of Economic & Business Development 165 Church Street, 6th Floor

New Haven, CT 06510 Email: hrosenb@newhavenct.org / Phone: (203) 946-5889

Tighe & Bond, Inc.:

Christopher P. Koelle, LEP Senior Project Manager Tighe & Bond, Inc.

1000 Bridgeport Avenue, Floor 3 Shelton, CT 06484 Email: ckoelle@tighebond.com / Phone: (203) 494-0347

Section 1 Introduction Tighe&Bond

198 River Street, New Haven, CT

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1.3 Site Description and History

The current configuration of the site is shown on Figure 2. The site is comprised of a single parcel of land, currently addressed as 198 River St. with a total area of approximately

0.78 acres. According to the City of New Haven Tax Assessor’s Card, the site is currently owned by the City, which acquired the parcel on November 20, 2006, from 198 River Street, LLC. The Assessor’s office identifies the parcel as Map/Block/Lot 175/608/202. The site is zoned as Light Industry/Light Industry-Marine (IL/IM) and has a surface elevation ranging from approximately 5.5 to 9 feet above the National Geodetic Vertical Datum.

In June 2023, the current 0.78-acre parcel (the “subject Site”), previously identified as proposed parcel 198RS-C River St.) was legally subdivided from the larger 3.25-acre original parcel also addressed as 198 River St., the entirely of which was occupied by the Bigelow Boiler Manufacturing Company.

The site is located in a mixed commercial/industrial area. Public water and sanitary sewer are currently available to the site and site vicinity. The site is abutted by:

• To the north by River Street, beyond which is a large warehouse

• To the east by a vacant city-owned parcel currently address as 194 River St.

(formerly identified as proposed Parcel 198RS-B River St.)

• To the west by Phoenix Press, a commercial printing facility

• To the south by a vacant city-owned parcel currently address as 200 River St.

(formerly identified as proposed Parcel 198RS-E River St.)

Until recently, the current subject Site was occupied by a deteriorating, vacant, approximately 4,000 square foot, three story, slab-on-grade, brick former factory building along the south side of River St. The exact construction date of the portion of the building formerly located at the site is unknown but historical records indicate it was constructed as early as 1869. Nearly the entire site consists of concrete slabs from former buildings that were demolished in phases between 2010 and 2015. The concrete slabs are currently overgrown with vegetation and partially covered with accumulated building debris and soil. On September 5, 2023, the remaining portion of the building was demolished.

Prior to initial development, the site was a low-lying area that was filled with polluted fill material reportedly originating from the Coppers Coke facility, which was also placed throughout the vicinity of the site on surrounding and nearby parcels along the Quinnipiac River, River St., and associated intersecting streets. Several parcels affected by the placement of this fill material have historically received approval of Widespread Polluted Fill (WPF) Variance requests from DEEP.

According to an Existing Facilities Condition Report, dated July 12, 2004, and Sanborn fire insurance maps, the original 3.25-acre 198 River St. parcel operated as a boiler and engine manufacturing company beginning in approximately 1869. The western and southern portions of the current site were historically used as a plate iron works and boiler shop.

The central portion of the former on-site building was used for storage on the upper levels and as part of the plate iron works on the first floor. The eastern portion of the recently demolished building was used for pattern storage and a woodworking shop. The former building that occupied the eastern portion of the current site housed the engine and boiler rooms. The specific processes conducted within the former on-site buildings are unknown but may have included metal working such as stamping, fabrication, and finishing associated with the plate iron works and boiler shop.

The site was most recently operated by Rockwell Heat Treatment Company (metal processing and heat-treating). All manufacturing activities reportedly ceased at the site

1-3 sometime around 2005. The majority of the site is covered by concrete slabs associated with former portions of the building that were demolished in phases from circa 2010 to 2023. The remaining areas of the site are partially vegetated or bare ground, with several small debris/soil piles littering the property.

1.4 Project Background

In June 2021 the City was awarded a $646,500 Dept. of Economic & Community

Development (DECD) Brownfield Municipal Grant for remediation of the subject parcel, which includes excavation of three PCB soil and two concrete “hotspots” and restoration of the historic building. Unfortunately, due to severe deterioration, the building was determined to be unrestorable, and the City requested additional funds to cover costs for additional fill material that will be required to construct the finished floor of the new building to at least two feet above the base floor elevation, utility installations in clean corridors, and paving needed to cap contaminated soil that will remain in place (<10 mg/kg PCB). In May 2023, DECD awarded the project supplement assistance of 50% of the initial award ($323,500) to cover these additional costs.

To support the funding award, the City plans to enroll the site in the DEEP Voluntary Remediation Program (VRP), pursuant to CGS Section 22a-133x, through submittal of an

Environmental Condition Assessment Form (ECAF). Public Notice of the proposed remediation was completed with no comments received.

1.5 Remediation Criteria

The soil and groundwater analytical results for all investigations were compared to the numeric criteria listed in the RSRs, Sections 22a-133k-1 through -3 of the Regulations of Connecticut State Agencies (RCSA) with revision effective on February 16, 2021. The RSRs apply to any action taken to remediate polluted soil, surface water, or groundwater at or emanating from a release area, which action is required pursuant to Chapter 445, Chapter 446k, or Section 22a-208a(c)(2) of the Connecticut General Statutes (CGS), including, but not limited to, any such action required to be taken or verified by a Licensed Environmental Professional (LEP). This includes parcels under an administrative order from DEEP, subsequent to a transfer of an “Establishment” under the CT Property Transfer Act (PTA) CGS Section 22a-134a, sites that are enrolled in a VRP under CGS Sections 22a-

133x or 22a-133y, and to remediation of certain solid waste disposal areas.

The site is not currently regulated under any state regulatory program; however, it is our understanding that the City will enroll the parcel in the VRP under CGS Section 22a-133x.

Based on the findings of the 2021 Phase I ESA Update, the site appears to meet the definition of an “Establishment”, therefore, a future transfer of ownership of the parcel could potentially be subject to the PTA.

PCBs have been released to the concrete slabs and soil at the site and are present at concentrations ≥50 mg/kg in both media. PCBs were also detected in debris observed in the shallow fill material (to a maximum depth of 3.75 fbg) at concentrations >1 mg/kg but all <10 mg/kg in soil from grade to 3.75 fbg. The debris is associated with the former scrapyard and is entrained in the fill material present only within the southeast corner of the site, which is the only area not covered by concrete slabs.

Pursuant to 40 CFR 761, PCB-contaminated soil, concrete, and scrapyard debris at the site are considered PCB-remediation waste. Due to the presence of PCB-remediation waste, the site is regulated under TSCA. In addition, the RSRs do not apply to the remediation of concrete and debris materials present in fill material.

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The RSR numeric criteria are based on post-remediation property usage (industrial/ commercial or residential) and the DEEP groundwater quality designation (“GA” or “GB”).

The site is located in an area designated as “GB” quality groundwater. The site is zoned as Light Industry. The current plan is to redevelop the site for commercial uses (assembly, light manufacturing and/or warehouse), which will include construction of a new building, filling the area of the site where the proposed building will be located to achieve an FFE elevation of 13 ft above MSL, and construction of a paved entrance from River St. and a parking lot to the south of the new building. The City indicated that an Environmental Use

Restriction (EUR) to render impacted soil inaccessible is an acceptable remedial option.

The 2021 RSRs do not provide soil and groundwater criteria for all substances detected at the site. In accordance with the RSRs, criteria may be developed and used for such Additional Polluting Substances (APSs) with the approval of DEEP. The criteria for the APSs detected at the site as listed in the data summary tables included with this report were obtained from Table 10: DEEP Recommended Criteria Values for Common Additional Polluting Substances and Alternative Criteria Requests, dated September 2018.

For all detected COCs without 2021 RSR soil and groundwater criteria, a request for approval to utilize the DEEP’s pre-evaluated APS “Fast-track” numeric criteria will be submitted to DEEP for formal approval after the site has been enrolled in the VRP(x) program upon submittal of the RAP to DEEP and once a Remediation Site Identification

Number (REM ID) is assigned by DEEP.

The following is a summary of the RSR and TSCA numeric regulatory criteria that were used to evaluate COC concentrations in site soil, concrete, debris, and groundwater.

Soil Criteria

Impacts to soil were compared to the following RSR and TSCA numeric regulatory criteria:

• The RSR Direct Exposure Criteria (DEC) to protect human health from potential risks associated with direct exposure to contaminated soil.

• The RSR GB Pollutant Mobility Criteria (GB PMC) to protect groundwater quality from contaminants that could potentially migrate or leach from the soil to groundwater.

In a “GB” groundwater classification area, the GB PMC apply to soil located above the seasonal high-water table. Based on gauging completed by Tighe & Bond and previous consultants, the depth to the seasonal high-water table across the site ranges from approximately 2.4 to 3.5 fbg.

The RSR soil criteria do not apply to concrete and debris, however, the remediation requirements of TSCA do apply to the PCB-contaminated concrete slabs and the scrapyard debris materials present in the fill material, along with PCB-impacted soil.

PCB concrete, soil, and debris analytical data were compared to the following TSCA cleanup criteria:

• ≤1 mg/kg – TSCA Unrestricted Use Criteria (also equals the RES DEC)

• ≤10 mg/kg – TSCA High Occupancy Use Criteria for soil below a cap or building (also equals the I/C DEC)

• ≤25 mg/kg – TSCA Low Occupancy Use Criteria for soil below a cap or building

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In addition, PCB concentrations were also compared to the two following TSCA PCB waste classifications:

• PCB Remediation Waste <50 mg/kg

• PCB Remediation Waste ≥50 mg/kg

Groundwater Criteria

Impacts to groundwater were compared to the following RSR numeric regulatory criteria applicable to sites located in “GB” classified groundwater areas:

• Groundwater Volatilization Criteria (GWVC) to protect human health from contaminants that may volatilize from contaminated groundwater into overlying buildings. Depth to groundwater at the site is less than 10 feet bgs, therefore, the GWVC apply to groundwater at the site. Different GWVC may apply to a property, depending on land use, either “residential” or “industrial/commercial”, as defined by the RSRs. The less stringent I/C GWVC can only be used if an EUR has been recorded on the property deed restricting the site to industrial/commercial uses, which will be the case for the site. Therefore, the I/C GWVC will apply to groundwater at the site.

The analytical data tables include both the RES and I/C GWVC.

• Surface Water Protection Criteria (SWPC) to protect surface water bodies into which groundwater discharges. The only surface water body in the vicinity of the site is the Quinnipiac River, which is located approximately 350 feet south of the site.

Therefore, the groundwater analytical results were compared to the SWPC.

Non-Aqueous Phase Liquids

In accordance with Section 22a-133k-2(g)(1), the RSRs require removal of NAPL to the “maximum extent practicable,” which is defined as the greatest degree of remediation that can be achieved using sound engineering and hydrogeologic practices without taking cost into consideration. However, DEEP may approve a request for a variance from the requirement to remove NAPL to the maximum extent practicable. If approved, an ELUR must be filed on the land records. Per the RSRs, all NAPL for which a variance is sought has been contained or removed to the maximum extent “prudent,” such that:

1. There is no migration of NAPL,

2. NAPL containing PCBs shall be remediated in compliance with 40 CFR 761,

3. Compliance with applicable groundwater criteria has been achieved, and

4. Compliance with the Soil Vapor Volatilization Criteria has been achieved for NAPL containing VOCs that is below a building.

1.6 Remedial Action Objectives & Selected Strategy

The section outlines the proposed plan to achieve compliance with the RSRs and 40 CFR 761 in a cost-effective and timely manner. The remediation plan/strategy has been developed based on the proposed future commercial use of the parcel and uses the proposed redevelopment (significant quantities of fill required to raise grade, a new building, and site-wide pavement) as integral components of the remedial strategy.

As shown on Sheet C-101, an approximately 12,000 square foot, single story, slab-on-grade building will be constructed, fronting along River St. The building will have a Finished Floor Elevation (FFE) of approximately 13 ft, requiring significant fill material across the entire site. The remainder of the site will be paved, with an entranceway from River St.

and an asphalt parking lot south of the building. At this time, four trees are proposed to

1-6 the west and south of the building, which will be planted in standard 8 ft by 8 ft tree pits.

There will be a minimum of four feet of clean (RSR compliant) fill material at the location of each tree pit.

Remedial Objectives

Based on the findings of the Supplemental Phase III ESA, concrete, soil, and groundwater remedial actions (both active, through excavation/removal coupled with a sitewide cap [new building and side-wide pavement], and passive, through implementation of institutional controls including an ELUR) are required to achieve compliance with the RSRs and/or 40 CFR 761 at each of the seven Release Areas identified at the site.

The remedial objectives for soil include RSR compliance with the I/C DEC and GB PMC for all COCs. For PCBs, the remedial objective is to achieve compliance with 40 CFR 761.61(a) for PCBs (detected in concrete, soil, and entrained debris) for a High Occupancy Use Site

(PCBs ≤10 mg/kg in all media).

The remedial objectives for groundwater includes compliance with the SWPC and the I/C GWVC for PCBs, VOCs, SVOCs, and ETPH.

Selected Remedial Strategy

Tighe & Bond evaluated options commonly utilized to remediate concrete, soil, and groundwater impacted with the various COCs detected at the site, including the presence of PCBs in concrete, soil, and scrapyard debris entrained in shallow soil. The selected remedial option includes:

• Removal/excavation and off-site disposal of concrete and soil with PCBs >10 mg/kg Coupled with Institutional Controls (Use Restricted by ELUR and TSCA Deed Restriction). Scrapyard debris entrained in shallow fill material at the site is not known to contain PCBs >10 mg/kg (all results <10 mg/kg to date). However, the fill and entrained scrapyard debris will be excavated and disposed off-site as a conservative measure because similar scrapyard material present at the remediated

190 River Street parcel to the east contained PCBs above 10 mg/kg, along with significant variability in PCB concentrations between debris samples. Other COCs will be remediated in soil through excavation and/or capping with an ELUR to achieve full compliance with the RSRs and 40 CFR 761 applicable to an industrial / commercial parcel located in an area with “GB” classified groundwater.

1.7 Plan Organization

This Plan is organized into the following sections:

Section 2: Previous Investigations

The site environmental history and previous investigations section provides a summary of investigations completed prior to and after the City’s acquisition of the site in November 2006. Data collected during these investigations are being used to support characterization of the proposed PCB excavation areas for this Plan.

This section includes reference to the sample location drawings provided in Appendix A, laboratory analytical data summary tables provided in Appendix B, soil borings and monitoring well completion logs in Appendix C, and laboratory analytical reports provided in Appendix D.

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Section 3: Supplemental Site Characterization

The site characterization section provides a summary of the sampling performed by Tighe & Bond to further characterize and delineate the nature and extent of PCBs in concrete, soil, and groundwater within and in areas surrounding the proposed concrete removal and soil excavation areas. This section also includes a summary of sample locations, sample collection methods, the results of the characterization data, and the location and extent of the identified areas of PCB contaminated concrete, soil, and groundwater.

Section 4: Conceptual Site Model

The Conceptual Site Model (CSM) section provides a summary of nature and current understanding of the probable sources of PCB impact to site concrete, soil, and groundwater.

Section 5: Remediation Plan

The Remediation Plan section includes a discussion of how the remedial objectives identified in Section 1.6 will be met and the remediation approach selected to meet the objectives. This section includes reference to figures in Appendix A that depict the areas of proposed remediation work.

Section 6: Post-Remediation Verification Sampling Plan

The post-excavation verification sampling plan includes a discussion of applicable remediation goals and the verification sampling approach for concrete, soil, and scrapyard debris that will be used.

Section 7: Schedule and Certification

The proposed schedule for implementation and reporting is provided. In accordance with 40 CFR 761.61(a)(3)(E), this section includes the written certification signed by the City, which is the party responsible for executing this Plan.

198 River Street, New Haven, CT 2-1

Section 2

Previous Investigations

Multiple environmental investigations have been completed by the City for the site. The following is a summary of the previous environmental investigations, which focuses on documenting the site history and releases of PCBs.

Phase I ESA, TAQ, June 1996

TAQ completed a Phase I ESA for the “rear” portion (approximately 1.7 acres) of the overall 198 River St. parcel, which included the central and southern portion of the current subject site. The site was used continuously by the Bigelow Company from the 1880s until transfer to Etherington Industries in 1981. All manufacturing processes ceased in 1985.

The site was occupied by a 3-story building (southern wing of the factory) at the time of the Phase I ESA. The floor of the building was concrete, and “many” floor drains were observed. The concrete floor was observed to be heavily stained with petroleum. TAQ observed several openings and pits in the slabs that contained liquids and debris.

The site was being leased to Lloyd Terminal, Inc. at 34 Lloyd St. at the time of the Phase

I, but the site building was vacant. The parcel was slightly overgrown and littered with debris except for the eastern portion of the current subject site adjacent to the adjoining scrapyard, which had been encroached upon by storage of scrap metal. TAQ observed widespread scrap and rubble mixed into the surface soil.

Manufacturing processes involved cutting, welding, shaping, and drilling metal. Industrial lubricants and coolants were used, and drill cuttings were stockpiled on site. Solvents (acetone and tetrachloroethylene (PCE)) were used to clean and degrease metal parts.

The report indicated that 198 River St. was registered as a hazardous waste RCRA Treatment, Storage, and Disposal Facility in 1983. The classification was later changed to RCRA Generator of Hazardous Waste. 198 River St. was again reclassified as a RCRA Non-handler in 1985 when manufacturing terminated.

A December 1983 DEEP inspection report indicated that steel was being degreased outdoors in a 650-gallon tank containing PCE. Storage of waste PCE was not observed by DEEP at that time. A March 1985 DEEP inspection report indicated that the tank was empty. The PCE tank was located on the portion of the original 198 River St. parcel, to the east of the current subject site.

Cutting oils were reportedly recirculated through the machines. Etherington Industries stated that waste oil was not generated at the site. Although, a DEEP March 1985 inspection report noted that several drums of waste oil were observed stored outside, apparently generated during dismantling of machines.

TAQ also observed four partially full 55-gallon drums labeled “522 oil 19” and one 55-gallon drum labeled ethylene glycol. One drum was observed on its side, which was bulging and apparently ruptured. TAQ noted that this drum may have contained a corrosive liquid. TAQ noted an additional nine 55-gallon drums labeled “used oil” were stored within the southwestern portion of the building, along with a 275-gallon fuel oil above ground storage tank (AST).

Section 2 Previous Investigations Tighe&Bond

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Phase I ESA, FSS, September 2001

FSS completed this Phase I ESA for the City for the entire original 198 River St. parcel.

Other street addresses associated with 198 River St. at this time included 190, 190½, 192, and 194 River St., and 58 & 60 Lloyd St. The 198 River St. parcel was occupied by an approx. 70,000 square foot, 1 to 3-story building and a 1,000 square foot storage garage located within the far eastern portion of the 198 River St. parcel.

Approximately half of the 198 River St. building (eastern, off-site portion) was being used for manufacturing, including metal processing/heat treating (Rockwell Metals

Manufacturing) and warehouse storage space (L & E Steel). The remainder of the building was unoccupied, with the southern portion of the building in a dilapidated state. Several large piles of scrap metal occupied most of the open areas of the southern and eastern portions of the 198 River St. parcel, east of the site.

198 River St. was listed as a RCRA Large Quantity Generator of hazardous waste until 1985, and then a RCRA Small Quantity Generator until 1989 when its status changed to a RCRA Non-handler of hazardous waste.

The report states that New Haven Fire Marshall records indicate that the former scrapyard removed wire coatings by open burning in exterior portions of the 198 River St. parcel, the exact locations of which are unknown, but are likely not within the limits of the current subject site.

Rev. Phase II ESA Work Plan, GEI, March 2003

This report indicated that the abutting 34 Lloyd St. parcel was owned by Lloyd Terminal & KC Metals, shipper and scrap metal operation, and scrap metals were observed to surround the building at 34 Lloyd St. Bigelow reportedly ceased manufacturing at the site about 1985/86. Several tenants have occupied the buildings from 1973 to 2003 (including Rockwell Metals Manufacturing and L&E Steel).

DEEP inspection reports from December 1983, March 1985, and June 1986 indicated that

198 River St. was not operating as a TSDF for hazardous waste. This report identified the following AOCs across the entire 198 River St. parcel. Only AOCs 5, 6, and 7 appear to be located on the current 198 River St. parcel and are bolded below:

AOC 1 – Former PCE AST (Located on a “carve-off” area of the original 198 River St.

parcel, which has since transferred to and combined with 34 Lloyd St.)

AOC 2 – Several Interior & Exterior Fuel Oil ASTs

AOC 3 – Former Gasoline USTs & Dispenser (Far Eastern Portion of the original 198 River

St. Parcel, now 190 River St.)

AOC 4 – Drill Cutting Scrap Piles with Oil-Stained Areas (Including Scrap Metal Piles)

AOC 5 – Engine Room, Boiler Room, & Former Chimney/Furnace (Currently AOC 4/RA-2)

AOC 6 – Press & Rolling Machine Pits, Floor Trenches, & Manhole (Currently AOC 5/RA-3)

AOC 7 – Transformers & Capacitors (Currently AOCs 2, 3, & 7/RA-5)

AOC 8 – Machine Shop (Located Directly East of the Current Site)

AOC 9 – Recycling & Disposal of Ash (Located South of the current Site)

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Draft Phase II ESA, GEI, April 2004

This investigation evaluated the potential for releases at the AOCs listed in the GEI Work Plan. KC Metals was leasing the open portion of the original 198 River St. parcel for expanded storage and management of scrap metal. The majority of the areas used by KC Metals are located beyond the footprint of the current Site; however, scrapyard debris was found by DTC and Tighe & Bond within the southeast corner of the site, where there is bare soil (as discussed later in this report).

GEI noted that, due to ongoing scrap metal operations and the collapse of the southern portion of the building, many of the borings proposed in the work plan could not be completed. GEI indicated that a licensed land surveyor conducted a site survey and located all sampling points. Well MW-9S, located directly east of the eastern boundary of the current Site, was found to be full of petroleum product (medium viscosity black oil), with no groundwater observed. The results of this investigation for the AOCs located within the current 198 River St. site (AOCs 5, 6, and 7) are summarized below:

AOC 5 – Engine Room, Boiler Room, & Former Chimney/Furnace (Currently AOC 4/RA-2)

The Bigelow Company’s process machinery was powered by steam, generated in large boilers. GEI noted that no evidence of significant oil staining was observed on the visible portions of the concrete floors in the boiler/engine rooms. GEI could not test soil within AOC 5 due to the unsafe, deteriorated state of the building.

AOC 6 – Press Pits, Rolling Machine Pits, Floor Trenches, Cutting Oil Tanks, & Manhole (Currently AOC 5/RA-3)

GEI noted the locations of several of these features on their site plan; however, the previous Phase I ESAs seemed to indicate that there may have been many more of these features throughout the western and southern portions of the former Bigelow building.

The press pits and rolling machine pits were not accessible due to the dilapidated condition of the building; however, GEI noted that significant oil staining was not observed in those areas. The floor trenches and manhole cited in the DEEP inspection report were located in the far southern wing of the building, beyond the limits of the current Site, which had been previously demolished. GEI did not observe any indication of those features.

Since access to the locations of these specific features was restricted, GEI advanced one boring within the general vicinity of these features. One boring (SB-33) was advanced adjacent to one of the former cutting oil tanks. Other borings were placed around the downgradient side of the building footprint (to screen for general site impacts). PCBs were not detected in sample SB-33 (1-3’).

AOC 7 – Transformers & Capacitors (Currently AOC 2)

GEI noted that a “transformer vault” was present along the north wall of the machine shop, which was being used by a tenant at the time of the Phase II ESA. All other electrical equipment had been removed. GEI stated that no borings were located to specifically target existing or former electrical equipment.

Supplemental Phase II ESA, GEI, December 2005

The buildings were not in use at the time of this assessment. GEI noted that PCB remediation was being conducted by Triton Environmental, Inc. (Triton) in an interior area of the existing building (now AOC 7 / RA-5), which is located within the southeastern portion of the current Site. This report indicated that scrap metal operations to the east of the current site terminated in 2005 and most of the scrap had been removed. GEI noted that recycled demolition fill (depth of approximately 1 to 2 feet of primarily brick and

2-4 concrete) had been placed over the existing ground surface in the southern portion of the original 198 River St. parcel, south of the current Site in mid-2005. This fill was known to be polluted with PCBs based on testing completed by FSS at the 34 Lloyd St. property.

This investigation included the entire original 198 River St. parcel with the scope of work including 44 borings, 8 of which were converted to 2-inch diameter wells. GEI indicated that a licensed land surveyor conducted a site survey and located all sampling points.

GEI stated that primary COCs included ETPH, semi-volatile organic compounds (SVOCs), metals (arsenic & lead), and PCBs at concentrations exceeding the I/C DEC and the GB

GB PMC. Low level VOCs, below RSR criteria were detected in groundwater samples collected within the current Site.

Depths to groundwater ranged from approximately 3 feet near the river to about 6 feet near River St. Groundwater was calculated to flow in a west southwesterly direction. GEI noted that several wells installed during the initial Phase II ESA had been destroyed, including: MW-1, MW-3S & 3D, MW-4, MW-5, and MW-6.

The results of this investigation for the AOCs located within the footprint of the current

Site (AOCs 5, 6, and 7) are summarized below:

AOC 2 – Interior & Exterior Fuel Oil ASTs (275, 500, 1,000, 1,500, & 10,000-gallon ASTs)

As shown on Figure 2, the 1,500-gallon fuel oil AST was located directly along the eastern boundary of the current Site, on the abutting parcel to the east (currently addressed as

194 River St.). GEI could not test soil within the immediate vicinity of the 1,500-gallon AST due to the dilapidated condition of the building. The other ASTs were located to the south, and downgradient, of the current Site.

AOC 5 – Engine Room, Boiler Room, & Former Chimney/Furnace (Currently AOC 4/RA-2)

GEI noted that no evidence of significant oil staining was observed on the visible portions of the concrete floors in the boiler/engine rooms. GEI could not test soil within AOC 5 due to the dilapidated condition of the building.

AOC 6 – Press Pits, Rolling Machine Pits, Floor Trenches, Cutting Oil Tanks, & Manhole (Currently AOC 5 / RA-3)

GEI noted that significant oil staining was not observed in the areas of the press pits and rolling machine pits. The floor trenches and manhole cited in the DEEP inspection report were located in the far southern wing of the building, to the south of the current Site, which had been previously demolished. GEI did not observe any indication of those features.

GEI advanced multiple borings throughout the footprint of the former western and southern wing of the building, several of which were on the current Site. Boring MW-12 was advanced adjacent to the northern rolling machine pit. PCBs were detected at a trace level in sample MW-12 (0-4’). Low levels of ETPH were detected in samples MW-12 (0-4’

& 6-8’). One boring (SB-33) was advanced adjacent to one of the former cutting oil tanks.

PCBs were not detected in sample SB-33 (1-3’).

A significant petroleum and PCB release area was identified within the northwestern portion of the former building at the locations of borings SB-54 and SB-55. ETPH was detected in sample SB-54 (3.5-5.5’) at 17,500 mg/kg and sample SB-55 (4-6’) at 3,380 mg/kg, above the RSR criteria.

According to the boring log for SB-55, GEI observed oily black sand with a slight but sharp solvent odor at 4-5’ and oily sludge at 5-6’. PCBs were detected at 718 mg/kg in the SB-

2-5

55 (4-6’) sample, and leachable PCBs were detected at 16.1 mg/l, exceeding the GB PMC of 0.005 mg/l. Also, the AVOC 1,2,4-trichlorobenzene was detected well above the GB PMC in that sample.

AOC 7 – Transformers & Capacitors (Currently AOCs 2, 3, & 7/RA-5)

GEI noted that a transformer vault was present along the north wall of the machine shop, which was in use by a current tenant at the time of the Supplemental Phase II ESA. All other electrical equipment had been removed. GEI stated that no borings were located to specifically target existing or former electrical equipment.

PCB Spill Response & Characterization Report, Triton, October 2006

Triton was retained by Rockwell Heat Treating, LLC to conduct concrete, brick wall, and soil sampling and to oversee a cleanup of impacts resulting from a spill of transformer fluid within the southeast portion of the former building, which is currently AOC 7/RA-5.

The spill was caused by vandals attempting to remove scrap metal from two transformers that had been temporarily stored in the area. Triton could not determine the original location of the transformers within the factory building.

The spill was discovered in July 2005 when representatives of DEEP observed two transformers within the building, one of which was overturned. Fluid had been released to the concrete floor from the overturned transformer. The other transformer was open but upright, with no apparent leakage. DEEP conducted preliminary sampling of the spilled fluid and confirmed that PCBs were present.

Before beginning work on July 20, 2005, Triton coordinated with the EPA and DEEP PCB units to determine the appropriate course of action. Since the portion of the building within which the spill occurred was planned for future demolition, complete remediation of the spill was deferred until demolition. The objective of Triton’s work was to clean up the liquid spill and contaminated debris, remove and dispose of the transformer units, characterize impacts to the concrete floor, the soil below, and adjacent brick walls, and to secure the area to minimize potential exposure to residual PCBs.

The spill area encompassed an area measuring approximately 55 by 65 feet of concrete floor. The floor was observed to be mostly intact, but some cracks in the concrete were observed. Triton also observed a small, exposed area of soil to the west of the spill area.

The fluid in the upright transformer contained PCBs at 1,800 mg/kg. The fluid still contained within the overturned transformer contained PCBs at 950,000 mg/kg, the spilled fluid contained PCBs at 470,000 mg/kg. All PCB detections were for Arochlor 1260.

The initial response measures included collecting the spilled oil with Speedi-Dry along with contaminated debris in an area measuring approximately 30 by 30 feet. The impacted concrete was swabbed with detergent rags. All wastes were placed in a lined dumpster for disposal.

After cleaning, Triton conducted additional characterization sampling of the spill area between July 2005 and April 2006. Triton did not collect any concrete or soil samples within the spill area that was visually impacted with transformer fluid.

Triton’s sampling indicated that the concrete had some level of pre-existing background

PCB contamination with total PCBs of 1.77 mg/kg (Arochlor 1254 at 0.67 mg/kg & Arochlor 1260 at 1.1 mg/kg) in one background sample (this was later confirmed by DTC and Tighe & Bond). Triton collected concrete samples on a 1.5-meter grid from the top ½ inch, and at select locations another ½ inch interval from the midpoint of the concrete slab, and from soil “immediately” below the concrete. The concrete slab was found to be

2-6 approximately six inches thick, and the specific soil sampling interval was not indicated.

Tighe & Bond assumes the samples likely represent the upper 3 inches (or less) of soil immediately below the slab.

Brick samples were obtained from the adjacent walls from locations 6 inches above the floor. In total, Triton submitted 246 samples for PCB analysis. PCBs were detected in the upper ½ inch of concrete at levels above 1 mg/kg. No PCBs were detected in the mid-slab samples; however, PCBs were detected in several soil samples from below the concrete.

Aroclor 1260 was the only Aroclor detected in the samples.

As shown on Figure 6 approximately 750 square feet of concrete contains PCBs ≥50 mg/kg, and approximately 2,750 square feet of concrete contains PCBs >1 mg/kg. PCBs were also detected in the brick wall, existing at the time, in the vicinity of the spill area at levels up to 2,500 mg/kg, however, the brick wall appears to have been completely removed.

As shown on Figure 5A, within the immediate vicinity of the spill area, PCBs were detected in soil (0-3 inches) beneath the slab at concentrations up to 15,000 mg/kg. A limited area of exposed soil, west of the spill area, appeared to have been impacted by the spill. A surficial soil sample from this area of exposed soil contained PCBs at 21,000 mg/kg, however, the depth of impact was not noted. Figure 5A includes soil sample locations with PCBs concentrations ≥1 mg/kg.

As shown on Figure 5B, soil “immediately” below the slab (0-3 inches), measuring approximately 40 feet north to south and 55 feet east to west, was found to be impacted with PCBs at concentrations >1 mg/kg (approximately 2,200 square feet). Note, DTC later investigated these areas and collected samples in 1-foot vertical intervals, which indicated that the area of soil with PCBs >1 mg/kg is limited to the immediate area of the spill.

Pre-Demolition Hazardous Building Materials Inspection Eagle, November 2007

This report provides results of surveys for asbestos, lead-based paint (LBP), PCB wipe and paint chip sampling, PCB containing equipment, chlorofluorocarbons, and Universal Waste products. PCB wipe samples were collected from metal components of machinery and in areas of “extensive” floor staining surrounding machinery. Wipe samples were not collected from within the most recently demolished portion of the building.

Note, the report indicates that samples were collected from buildings designated by Eagle as “C” and “E”. However, according to the drawing in the report, Building “C” comprised the far western wing of the Bigelow building complex. Site sketches provided to DTC by

Eagle indicate that the samples were actually collected from Building “D” (not “C”), which is the former machine shop that contained four furnaces, including a Holden furnace, and large plating machine.

PCBs (Aroclor 1260) were detected at 45 ug/100 cm2 in a wipe sample taken from adjacent to the transformer that existed in the engine room (currently AOC 3). It is not clear if the sample was collected from the surface of the transformer or from the surrounding concrete slab. The report indicates that the transformer was present at the time, it was not labeled, and liquids had spilled out onto the adjoining wall panel (since removed) and the surrounding concrete floor.

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Building Stabilization – Hazardous Materials Removal Plans, Eagle, dated June, A partial set of drawings and emails depicting areas of the building to be abated prior to demolition were provided by Eagle. The plans noted locations of building materials containing asbestos, LBP, and PCBs requiring abatement and disposal.

The information provided indicates that a PCB contaminated transformer was located within the northwest corner of the former engine room, which is now located on an exposed concrete floor slab, along the former south exterior wall of the recently demolished portion of the building (currently identified as AOC 3). Eagle had completed sampling of debris, concrete, and soil/sediment on top of the slab in the area of the transformer, all of which except the concrete has since been removed.

Three drawings were included as part of this documentation that showed the sample locations and the PCB analytical results. Debris in this area contained PCBs at 11 mg/kg.

The debris was reportedly removed. Five concrete samples were obtained in this area.

PCBs were detected in two concrete samples at 2 and 8.6 mg/kg. This concrete remains in place. Five samples of “soil” were collected, which were representative of sediment type material located on top of the concrete slab. PCBs were detected in the five samples at 2.4, 2.8, 24, 28, and 39 mg/kg. Eagle stated that the debris and soil/sediment on top of the slab was removed during the building stabilization project. Eagle indicated that samples of soil from below the concrete slab were not obtained.

In-situ Waste Characterization Sampling – Engine Room Transformer Area, Eagle, July 2014

Eagle provided four drawings depicting the locations of additional samples of soil/ sediment atop concrete and brick/mortar. Eagle obtained these samples from the area of the former transformer that had been located in the northwest corner of the Engine Room (currently identified as AOC 3) and identified these samples as final waste characterization samples.

Eagle collected samples of soil/sediment in 11 locations up to 25 feet to the south from the former transformer. One sample located approximately 20 feet southeast of the transformer detected PCBs at 2.4 mg/kg. The remaining samples detected PCBs at <1 mg/kg.

Eagle collected samples of brick and mortar from walls adjacent to the former transformer, including a former wall that divided the Engine Room from the adjacent room to the west

(4 samples), and from the southern exterior wall of the existing building located to the north of the transformer (10 samples). A sample was also collected from a former stone panel dividing wall that was located immediately south of the former transformer.

All brick and mortar samples were non-detected for PCBs. However, PCBs were detected at 1.4 mg/kg in the sample from the former dividing wall.

Building Demolition Abatement & Closures – Partial Floor & Roof Plans, Spiegel

Zamecnick, & Shah, Inc., September 10, 2014

This partial set of drawings and emails depicted areas of the building to be demolished.

The plans showed an existing, brick-lined pit in the…