Environmental Review and Status Report prepared by GeoQuest dated June 2019.pdf

, inc.

3 Barnard Lane C P.O. Box 85 C Bloomfield, Connecticut 06002 C (860) 243-1757 C FAX: (860) 243-9414

June 8, 2019

Alan Lazowski LAZ Investments 15 Lewis Street Hartford, CT 06103

Re: Environmental Review & Status Report 180 Allyn Street, Hartford, Connecticut GeoQuest Project No. 3327

Dear Mr. Lazowski:

GeoQuest Inc. (GeoQuest) has reviewed a January 2018 Phase I Environmental Site Assessment report, a January 2018 Phase II Site Investigation report, and an April 2019 Phase II/III Site Investigation report prepared by BL Companies (BL) 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 180 Allyn Street. According to the BL reports, the site consists of ten contiguous parcels of land totaling approximately 2.67-acres. The site 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 Phase I report conducted by BL, 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 the site that generated hazardous waste or constituted a “listed activity” and are 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 with Form III filings. In addition, The Atlas Oil Company at 112 and 122 High Street was identified as an Establishment in 1997 with a Form III filing. BL also identified correspondence indicating that 128-164 Allyn Street, 84-110 High Street, and 317 to 331 Church Street may also be Establishments. 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 Site. In addition, several spills of gasoline and oil were identified in municipal records by BL, but were never reported to the Connecticut Department of Energy and Environmental Protection (CTDEEP). BL

Environmental Review & Status Report 180 Allyn Street, Hartford, Connecticut GeoQuest Project No. 3327 June 8, 2019 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 2019 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 Repair and Body Shop, Former Car Rental Facility, Dress Factory and Printing Operation, Former Gengras Motor Cars, Universal Auto Co., and Clothing Factory, Former Battery Station, Sheet Metal works, and 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 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, 2019 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. Soil samples collected at the site indicated 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). 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.

GeoQuest Project No. 3327 June 8, 2019

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 was 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 cost prohibitive), BL recommended the possibility of implementing an Environmental Land Use Restriction (ELUR) to address contamination in the urban fill.

Notwithstanding the potential costs associated with remediating this material, it should be noted that the presence of urban 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; the site is a paved parking lot where there is no potential for exposure; and the groundwater is known to be degraded throughout this area (the groundwater classification is GB).

Based on a review of the above reports, it appears that 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 a number of factors. It should also be noted that this property is to remain a parking lot for the foreseeable future. With this in mind, GeoQuest recommends that the following actions be taken after the property has been transferred:

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).

GeoQuest Project No. 3327 June 8, 2019

GeoQuest estimates that the cost to implement the above recommendations is between $125K and $150K. Once these activities are completed, GeoQuest sees no indications that further actions will be warranted at this site at this time.

If you have any questions, or if you need anything further from our office, please do not hesitate to call me at 860.243.1757 or email me at mcasslar@geoquestinc.com.

Very truly yours

GEOQUEST, INC.

Marc I. Casslar President