Allyn Street Data Gap Review prepared by Solve March 2024.pdf

March, 2024

GSA Subject Matter Experts Review (Internal Only) Initials, Date, Time

Bob Herman, Project Manager RFH 4/17/24 10:22

Carey Bergeron, NEPA SME - FYSA

Missy Mertz, NEPA SME MMM 4/11/24 9:21AM

Liz Mees, RHPO - FYSA EHM 4/17/2024

Sara Massarello, Site SME SEM 4/16/2024 12:37pm

Sheri DeMartino, Site Team - FYSA

Nicole Katz, Site Team NEK 4/22/24 9:30 AM

Judie Bowen, Regional Chief Architect, Site Team JHB, 2024/4/12, 2:49 pm

Carol Chirico, Senior Assistant Regional Counsel CHC 4/16/24

Solv, LLC 8201 Greensboro Drive Suite 700 McLean, Virginia 22102

Re: Environmental Review

Allyn Site, Hartford, Connecticut GeoQuest Project No. 4363b

To Whom It May Concern:

GeoQuest, Inc. (GeoQuest) has reviewed the following documents for the assemblage of properties located at 329 Church Street, 339 Church Street, 98 High Street, 106 High Street, 112 High Street, 122 High Street, 108 Allyn Street, 112 Allyn Street, 128 Allyn Street, and 154 Allyn Street, in Hartford, Connecticut (the “site” or “subject property”), and herein referred to as the Allyn Site:

• Phase I Environmental Site Assessment, prepared by BL Companies (BL), dated December 13, 2018

• Phase II Site Investigation (Draft), prepared by BL, dated January 23, 2018

• Phase II/III Site Investigation, prepared by BL, dated April 2019

• Environmental Review & Status Report, prepared by GeoQuest, Inc., dated

June 8, 2019

The purpose of the reviews was to determine the environmental status of the site, document any data gaps, provide a risk analysis, and make a determination as to what additional investigations, if any, are necessary. Additionally, the Phase I Environmental Site Assessment (ESA) was reviewed for compliance in accordance with the American Society for Testing and Materials (ASTM) Standard Practices of Environmental Site Assessments: Phase I/II/III, the All Appropriate Inquiry Final Rule (40 Code of Federal Regulations [CFR] Part 32 [AAI]), and the Connecticut Site Characterization Guidance Document (SCGD). The reports were completed in general accordance with ASTM guidelines and the current standards of practice.

Site Description and History

The subject property consists of ten contiguous parcels of land totaling approximately

2.19 acres. The subject property is currently being utilized as a parking lot, with the only structures consisting of three parking access gate buildings entering the site from Allyn, Church, and High Streets.

According to the 2018 BL Phase I ESA report, the site was historically utilized for multiple commercial and residential purposes from at least 1885, which include a blacksmith, auto sales/repair, gasoline filling station, auto body repair shop, printing operations, woodworking, a machine shop, restaurants, clothing manufacturing, steam laundry, a YMCA and associated parking, and residential structures. BL identified various operations at specific parcels that generated hazardous waste or constituted a “listed activity” and would therefore be considered “Establishments” under the Connecticut Property Transfer Act (Transfer Act). The Hertz Corporation and Gadell's Repair & Body Shop, Inc. at 98 High Street, ISS Prudential Maintenance Services, Inc. at 100 High Street, and Driscoll Motors, Inc. at 132 Allyn Street were identified in 1986 as Establishments, and therefore, Form III Transfer Act filings were submitted to the Connecticut Department of Energy and Environmental Protection (CTDEEP) when the parcels were transferred. In addition, The Atlas Oil Company at 112 and 122 High Street was identified as an Establishment in 1997 and therefore, Form III filings were submitted to the CTDEEP when they were transferred. BL also identified correspondence indicating that 128-164 Allyn Street, 84-110 High Street, and 317-331 Church Street may also be Establishments. In addition, several hazardous waste manifests associated with the auto body shop and gas station activities were identified between 1986 and 1991.

All on-site buildings were demolished between 1986 and 1988 for redevelopment that subsequently never occurred. The site remained vacant for 17 years until it was redeveloped into its current use as a paved parking lot in 2005. No property uses were identified between 1988 and 2005. Several underground storage tanks (USTs) and aboveground storage tanks (ASTs) including gasoline, diesel, waste oil, and heating oil were identified as being used at the subject property. In addition, several spills of gasoline and oil were identified in municipal records by BL but were never reported to the CTDEEP. BL concluded that a ground-penetrating radar (GPR) survey and a Phase II Site Investigation should be conducted at the site.

BL subsequently conducted a GPR survey and Phase II Site Investigation in January

2018 to determine the presence of former USTs and any potential contamination associated with former property uses. BL identified eight Areas of Concern (AOCs) based on former property uses at the site that required further investigation. The former uses of concern included: a former gasoline service station, former steam laundry facility, former auto repair/sales and machine shop, former auto repair and body shop, former car rental facility, dress factory, printing operation, former Gengras Motors Inc., Universal Auto Co., clothing factory, former battery station, sheet metal works, woodworking facility, and urban fill of unknown origin (site wide).

The GPR survey identified the presence of several subsurface “anomalies” consistent with USTs and a former gasoline filling pump pad; they also identified several other anomalies of potential interest. On January 2-4, 2019, BL advanced 39 soil borings between 5-15 feet below ground surface (fbgs) and installed five groundwater monitoring wells between 13-18 fbgs throughout the eight AOCs at the site.

The laboratory results indicated the presence of Volatile Organic Compounds (VOCs), Extractable Total Petroleum Hydrocarbon (ETPH), Polynuclear Aromatic Hydrocarbon (PAH), lead, and arsenic contamination in soil and groundwater samples at concentrations in excess of the Connecticut Remediation Standard Regulations (RSR) criteria at several locations across the site. The contamination was indicative of a release from the former and potentially existing USTs, a gasoline filling station, and manufacturing activities. Urban fill containing contamination in excess of RSR criteria was also identified throughout the site. Based on the results of the Phase II, BL recommended a supplementary Phase II in conjunction with a Phase III Site investigation to delineate the extent of contamination at the site.

In April 2019, BL conducted a Phase III investigation to delineate the contamination identified during the January 2018 Phase II site investigation. The Phase III investigation consisted of digging 11 test pits, advancing an additional 35 borings, and installing an additional three groundwater monitoring wells to delineate the contamination identified across the site. The laboratory results for the soil samples collected at the site indicated that ETPH and PAH contamination was present across all ten parcels ranging from 3-10 fbgs. Some soil samples had contamination in excess of the Residential Direct Exposure Criteria (RES DEC), the Industrial/Commercial DEC (I/C DEC), and the GB groundwater Pollutant Mobility Criteria (GB PMC) (as this is an area where groundwater is classified as “GB”, which indicates it is known or presumed to be degraded). VOCs were limited to the vicinity of the former gasoline filling station in the northwest corner of the site, and although some were in excess of RSR criteria, they were limited to near or below the water table. PCBs were identified at one location at the site. Metals were mostly restricted to “background” or naturally occurring levels with the exception of lead in the vicinity of the former gasoline filling station.

With regards to groundwater, ETPH was identified in the northwest corner of the site where the former gasoline station was located. However, BL could not conclude whether the plume was from the gasoline station, or if it originated from an off-site source. In addition, several VOCs, lead, and arsenic were detected at levels in excess of regulatory standards in selected wells across the site. BL concluded that the lead and VOCs were likely related to the former gasoline filling station, while the arsenic was likely due to the presence of “urban fill” across the site.

Regarding the presence of urban fill, BL estimated that the total volume of potentially contaminated fill across the site could range from 15,000 - 20,000 cubic yards. Given that the cost of removal and off-site disposal for such volumes would be impractical (and potentially cost prohibitive), BL recommended the possibility of implementing an Environmental Land Use Restriction (ELUR) to address contamination in the urban fill.

Significant Data Gaps

No significant data gaps were identified in the reports reviewed.

Transfer Act Applicability

As noted above, various operations at specific parcels that generated hazardous waste or constituted a “listed activity,” and would therefore be considered “Establishments” under the Connecticut Property Transfer Act (Transfer Act), were identified for the site. The Hertz Corporation and Gadell's Repair & Body Shop, Inc. at 98 High Street, ISS Prudential Maintenance Services, Inc. at 100 High Street, and Driscoll Motors, Inc. at 132 Allyn Street were identified in 1986 as Establishments, and therefore, Form III Transfer Act filings were submitted to the CTDEEP when the parcels were transferred. In addition, The Atlas Oil Company at 112 and 122 High Street was identified as an Establishment in 1997 and therefore, Form III filings were submitted to the CTDEEP when they were transferred in 2019. BL also identified correspondence indicating that 128-164 Allyn Street, 84-110 High Street, and 317 to 331 Church Street may also be Establishments; a Form III filing for these parcels was submitted in 2019, when the properties were transferred. In addition, several hazardous waste manifests associated with the auto body shop and gas station activities were identified between 1986 and 1991. Legal counsel should be consulted to make the final Transfer Act determination.

It should be noted that 1) the need for compliance with the Transfer Act is dependent upon how the buyer acquires the property as there are exemptions for different types of acquisitions/transfers; and 2) if compliance is required, who complies with the Transfer Act (buyer v/s seller) is dependent upon the deal that is struck between the parties. There is no legal “requirement” that the seller be the “certifying” party. Assuming the parties can quickly agree on what entity will be the certifying party, conveyance should not be hindered by the Transfer Act.

Conclusions/Recommendations

Based on a review of the above reports, contamination has been identified on the subject property and additional work will be needed to bring the site into compliance with applicable regulations. Though it should be noted that much of the contamination is urban fill and as noted above, the presence of this fill is mitigated by the fact that the site is located in downtown Hartford, where many of the sites exhibit the exact same fill; this is a fully developed urban area; and the groundwater is known to be degraded throughout this area (the groundwater classification is GB). Therefore, it may be possible to reuse the fill material onsite, as once this site is redeveloped, the presence of a building (or buildings), paved parking areas, and landscaping would further mitigate this contamination, as it could be rendered environmentally isolated and inaccessible (both of which would be protective of the environment and human health and safety). Any fill material that cannot be reused onsite, would need to be disposed off-site (and GeoQuest is aware that a significant volume may be taken off-site). GeoQuest recommends that once plans for site development have begun, a plan for follow-up assessment and an Environmental Land Use Restriction, if necessary, can be developed; to be followed by completion of a Remedial Action Plan (RAP), and ultimately site remediation. GeoQuest believes that the following actions will need to be taken prior to the site remediation for the redevelopment:

1) conduct a more thorough GPR survey to better define the potential for USTs to be present at the site;

2) proper removal and closure of any USTs (if identified);

3) remediation of any contaminated soil “hot spots” in the vicinity of any tanks identified;

4) conduct some additional assessment in the northwest corner of the property where the former gasoline filling station was located to determine whether or not the contamination is from an on-site or off-site source and to see what, if any, remediation is warranted (it should be noted that under Connecticut regulations, contamination from an off-site source is not the responsibility of the property owner and, as indicated above, the groundwater in this area is known to be degraded).

Regulatory Compliance Cost Estimate

Based on the information reviewed, GeoQuest estimates that the cost to bring this parcel into compliance with the Connecticut RSRs (if needed [regardless of whether the site is enrolled in the Transfer Act program or is enrolled in a Connecticut Voluntary Remediation or Brownfields Redevelopment program]), and/or to render a parcel usable for its intended purpose in accordance with Connecticut regulatory programs, is currently estimated to be between $250,000 and $300,000, exclusive of any remedial costs (see below). This includes approximately $75,000 to $100,000 for regulatory reporting and filing obligations, and $175,000 to $200,000 in additional assessments, which would include Phase III investigations, deep aquifer analysis, supplemental Phase III (if necessary), hydraulic conductivity analysis, four quarters of seasonal groundwater monitoring, four quarters of post remedial compliance groundwater monitoring, etc.

Remediation Cost Estimate

Based on the proposed development plan, which you indicated consists of a 2-acre building footprint with up to two stories of underground parking, and the information available at this time, GeoQuest anticipates that approximately 8 feet to 10 feet of soil (on average) will need to be managed as "contaminated". However, GeoQuest is aware that the General Services Administration is assuming that 74K to 100K cubic yards of soil may need to be taken offsite.

For costing purposes, GeoQuest assumes that at least 50 percent of this soil will need to be managed as “contaminated” or “urban fill” (which are similar, but not exactly the same [typically, this is determined by laboratory analysis of the material being taken offsite]). This results in approximately 37K cubic yards (or approximately 48K tons) to 50K cubic yards (65K tons) of contaminated soil (or “unsuitable urban fill”) which would likely need to be removed and disposed of off-site, if it cannot be re-used onsite. The cost differential between the fill required to be removed during construction activities and the disposal cost for the contaminated soil is estimated to be around $60 to $80/ton, for an estimate cost of $2.8M to $5.2M to manage this contaminated soil. GeoQuest has provided a cost differential as it does not know how much GSA will be charged for the excavation, loading, transportation, and management of clean soil, as this is very project dependent. It should also be noted that GeoQuest is aware that contractors have charged developers significantly higher cost differentials for management of contaminated soil.

GeoQuest estimates that the cost of remediating this site would range from approximately $3.1M to $5.5M. These estimates can be fine-tuned once additional assessment and a site development plan are completed. GeoQuest recommends adding 20 percent contingency to the budget until site plans and the additional assessments are completed.

Please feel free to contact me at (860) 243-1757 or pprey@geoquestinc.com if you have any questions or would like to discuss this report.

Very truly yours, GEOQUEST, INC.

Peter J. Prey Senior Associate

Marc. I Casslar, LEP President mailto:pprey@geoquestinc.com

Remediation Cost Estimate