Indoor_Athletic_Flooring_Waste_Characterization_-_Floyd_Little_Athletic_Center_-_DTE_3-5-2025.pdf

Down To Earth, LLC

122 Church Street

Naugatuck, CT 06770

March 5, 2025

Mr. Giovanni Zinn, PE City Engineer City of New Haven 200 Orange St. 5th Floor New Haven, CT 06510

Via email: gzinn@newhavenct.gov

Re: Waste Disposal Characterization of Indoor Track Flooring for Mercury

Floyd Little Athletic Center 480 Sherman Parkway New Haven, Connecticut

Dear Giovanni:

On February 19, 2025, Down to Earth, LLC (DTE), collected four samples of the rubberized indoor track flooring from the Floyd Little Athletic Center (FLAC) located at 480 Sherman Parkway in New Haven, CT (Site). It is our understanding the City of New Haven intends to remove and replace the track. A contractor who is familiar with this material requested it be evaluated for waste characteristics due to the presence of mercury. According to an internet review, rubber track flooring has been found to contain elevated mercury.

OBSERVATIONS AND SAMPLING

We observed two distinct colors of rubberized flooring consisting of red track lanes with white striping and green flooring inside and around the perimeter. The maintenance supervisor for the building requested that sampling of the track area be minimized due to upcoming use.

The flooring was sampled using a core bit and electric drill. Two samples were obtained northeast of the track. One sample was collected south of the track. The fourth sample was collected west of the track. Each core contained four distinct layers of flooring on top of underlying concrete. This was consistent at all the sample locations.

The samples were placed in laboratory-supplied jars and submitted under chain of custody to Phoenix Environmental Laboratories in Manchester, Connecticut. The samples were analyzed for total mercury and for extractable mercury by the Toxicity Characteristic Leaching Procedure

(TCLP).

Waste Disposal Characterization of Indoor Track Flooring for Mercury Floyd Little Athletic Center

480 Sherman Parkway, New Haven, Connecticut March 5, 2025 – Page 2

LABORATORY RESULTS

The laboratory report is attached. The laboratory results for total mercury were compared to direct exposure criteria (residential and industrial/commercial)1 as specified in the state Remediation Standard Regulations. The extractable mercury result from TCLP extraction was compared to the hazardous waste characteristic.2 The results were as follows:

Analyte Units

Regulatory Criteria Sample Designation and Result

R-DEC I/C-DEC

Haz Waste Threshold Floor-1 Floor-2 Floor-3 Floor-4

Mercury mg/Kg 20 610 NE 31.6 34.3 48.1 6.52

TCLP Mercury mg/L NA 0.002 0.2 0.0003 0.0006 <0.0002 <0.0002

• Total mercury was detected in all four samples. The concentration of total mercury in samples Floor-1 through Floor-3 exceeded the residential direct exposure criterion (R- DEC) of 20 mg/kg. The highest concentration detected (48.1 mg/kg) did not exceed the higher industrial/commercial DEC of 610 mg/kg. Removal of the flooring will mitigate potential mercury exposures.

• Low concentrations of TCLP mercury were detected in two of the four samples. The highest concentration (0.0006 mg/L) was well below the hazardous waste characteristic of 0.2 mg/L. Disposal of the track material as unregulated bulky waste would be appropriate.

If you have any questions, please contact the undersigned.

Sincerely, DOWN TO EARTH, LLC

Nathan Hicks Timothy Carr, LEP Senior Environmental Scientist Principal

Attachment: Laboratory Results

G:\SHARED DRIVES\ENVIRONMENTAL SERVICES\CITY OF NEW HAVEN\08 - FLOORING TESTING FOR HG\RESULTS OF INDOOR TRACK FLOORING WASTE

CHARACTERIZATION FOR MERCURY - FLOYD LITTLE ATHLETIC CENTER - DTE 3-5-2025.DOCX

1 Remediation Standard Regulations (RCSA 22a-133(k)-2

2 40 CFR 261.24

CS65929 - CS65932

Wednesday, February 26, 2025

Sample ID#s:

Attn: Timothy Carr, LEP Down To Earth, LLC 122 Church Street Naugatuck, CT 06770

SDG ID: GCS65929

Project ID: FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Sincerely yours, Laboratory Director Phyllis Shiller

The contents of this report cannot be discussed with anyone other than the client listed above without their written consent.

NELAC - #NY11301

CT Lab Registration #PH-0618 MA Lab Registration #M-CT007 ME Lab Registration #CT-007 NH Lab Registration #213693-A,B

NJ Lab Registration #CT-003 NY Lab Registration #11301 PA Lab Registration #68-03530 RI Lab Registration #63 VT Lab Registration #VT11301

This laboratory is in compliance with the NELAC requirements of procedures used except where indicated.

This report contains results for the parameters tested, under the sampling conditions described on the Chain Of Custody, as received by the laboratory. This report is incomplete unless all pages indicated in the pagination at the bottom of the page are included.

A scanned version of the COC form accompanies the analytical report and is an exact duplicate of the original.

All soils, solids and sludges are reported on a dry weight basis unless otherwise noted in the sample comments.

587 East Middle Turnpike, P.O. Box 370, Manchester, CT 06040

Sample Id Cross Reference February 26, 2025

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102 Fax (860) 645-0823

Environmental Laboratories, Inc.

SDG I.D.: GCS65929

Client Id Lab Id Matrix

Project ID: FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Col Date

FLOOR-1 CS65929 SOLID 02/19/25 13:50

FLOOR-2 CS65930 SOLID 02/19/25 14:00

FLOOR-3 CS65931 SOLID 02/19/25 14:20

FLOOR-4 CS65932 SOLID 02/19/25 14:30

Sample Information Custody Information Matrix:

Location Code:

Rush Request:

P.O.#:

Collected by:

Received by:

Analyzed by:

SOLID

DOWNDAS

Standard

CITY OF NEW HAVEN

02/19/25

SR1

see "By" below

Laboratory Data

FLOOR-1

Phoenix ID: CS65929

02/20/25 13:50 12:15

Parameter Result

RL/

PQL Units Date/Time By Reference

FOR: Attn: Timothy Carr, LEP Down To Earth, LLC 122 Church Street Naugatuck, CT 06770

Analysis Report February 26, 2025

Date Time

SDG ID: GCS65929

Client ID:

Project ID: FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Dilution

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102

Environmental Laboratories, Inc.

31.6Mercury 1.2 02/21/25 JM SW7471Bmg/Kg 100 0.0003TCLP Mercury 0.0002 02/25/25 ZT SW846 1311/7470mg/L 1

CompletedMercury Digestion 02/21/25 AC1/AC1 SW7471B CompletedTCLP Digestion Mercury 02/24/25 AK/GW/AKSW7470A CompletedTCLP Extraction for Metals 02/21/25 AK SW1311

Comments:

Results are reported on an ``as received`` basis, and are not corrected for dry weight.

TCLP Non-Volatile Extraction:

Sample weight was < 100 grams (the minimum requirement of the method to insure homogeneity).

All soils, solids and sludges are reported on a dry weight basis unless otherwise noted in the sample comments.

Phyllis Shiller, Laboratory Director February 26, 2025

If you are the client above and have any questions concerning this testing, please do not hesitate to contact Phoenix Client Services at ext.200.

The contents of this report cannot be discussed with anyone other than the client listed above without their written consent.

Reviewed and Released by: Ethan Lee, Project Manager

RL/PQL=Reporting/Practical Quantitation Level ND=Not Detected BRL=Below Reporting Level

Ver 1

Location Code:

Rush Request:

P.O.#:

Collected by:

Received by:

Analyzed by:

SOLID

DOWNDAS

Standard

CITY OF NEW HAVEN

02/19/25

SR1

see "By" below

Laboratory Data

FLOOR-2

Phoenix ID: CS65930

02/20/25 14:00 12:15

Parameter Result

RL/

PQL Units Date/Time By Reference

FOR: Attn: Timothy Carr, LEP Down To Earth, LLC 122 Church Street Naugatuck, CT 06770

Analysis Report February 26, 2025

Date Time

SDG ID: GCS65929

Client ID:

Project ID: FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Dilution

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102

Environmental Laboratories, Inc.

34.3Mercury 1.2 02/21/25 JM SW7471Bmg/Kg 100 0.0006TCLP Mercury 0.0002 02/25/25 ZT SW846 1311/7470mg/L 1

CompletedMercury Digestion 02/21/25 AC1/AC1 SW7471B CompletedTCLP Digestion Mercury 02/24/25 AK/GW/AKSW7470A CompletedTCLP Extraction for Metals 02/21/25 AK SW1311

Comments:

Results are reported on an ``as received`` basis, and are not corrected for dry weight.

TCLP Non-Volatile Extraction:

Sample weight was < 100 grams (the minimum requirement of the method to insure homogeneity).

All soils, solids and sludges are reported on a dry weight basis unless otherwise noted in the sample comments.

Phyllis Shiller, Laboratory Director February 26, 2025

If you are the client above and have any questions concerning this testing, please do not hesitate to contact Phoenix Client Services at ext.200.

The contents of this report cannot be discussed with anyone other than the client listed above without their written consent.

Reviewed and Released by: Ethan Lee, Project Manager

RL/PQL=Reporting/Practical Quantitation Level ND=Not Detected BRL=Below Reporting Level

Location Code:

Rush Request:

P.O.#:

Collected by:

Received by:

Analyzed by:

SOLID

DOWNDAS

Standard

CITY OF NEW HAVEN

02/19/25

SR1

see "By" below

Laboratory Data

FLOOR-3

Phoenix ID: CS65931

02/20/25 14:20 12:15

Parameter Result

RL/

PQL Units Date/Time By Reference

FOR: Attn: Timothy Carr, LEP Down To Earth, LLC 122 Church Street Naugatuck, CT 06770

Analysis Report February 26, 2025

Date Time

SDG ID: GCS65929

Client ID:

Project ID: FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Dilution

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102

Environmental Laboratories, Inc.

48.1Mercury 1.3 02/21/25 JM SW7471Bmg/Kg 100 < 0.0002TCLP Mercury 0.0002 02/25/25 ZT SW846 1311/7470mg/L 1

CompletedMercury Digestion 02/21/25 AC1/AC1 SW7471B CompletedTCLP Digestion Mercury 02/24/25 AK/GW/AKSW7470A CompletedTCLP Extraction for Metals 02/21/25 AK SW1311

Comments:

Results are reported on an ``as received`` basis, and are not corrected for dry weight.

TCLP Non-Volatile Extraction:

Sample weight was < 100 grams (the minimum requirement of the method to insure homogeneity).

All soils, solids and sludges are reported on a dry weight basis unless otherwise noted in the sample comments.

Phyllis Shiller, Laboratory Director February 26, 2025

If you are the client above and have any questions concerning this testing, please do not hesitate to contact Phoenix Client Services at ext.200.

The contents of this report cannot be discussed with anyone other than the client listed above without their written consent.

Reviewed and Released by: Ethan Lee, Project Manager

RL/PQL=Reporting/Practical Quantitation Level ND=Not Detected BRL=Below Reporting Level

Location Code:

Rush Request:

P.O.#:

Collected by:

Received by:

Analyzed by:

SOLID

DOWNDAS

Standard

CITY OF NEW HAVEN

02/19/25

SR1

see "By" below

Laboratory Data

FLOOR-4

Phoenix ID: CS65932

02/20/25 14:30 12:15

Parameter Result

RL/

PQL Units Date/Time By Reference

FOR: Attn: Timothy Carr, LEP Down To Earth, LLC 122 Church Street Naugatuck, CT 06770

Analysis Report February 26, 2025

Date Time

SDG ID: GCS65929

Client ID:

Project ID: FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Dilution

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102

Environmental Laboratories, Inc.

6.52Mercury 0.63 02/21/25 JM SW7471Bmg/Kg 50 < 0.0002TCLP Mercury 0.0002 02/25/25 ZT SW846 1311/7470mg/L 1

CompletedMercury Digestion 02/21/25 AC1/AC1 SW7471B CompletedTCLP Digestion Mercury 02/24/25 AK/GW/AKSW7470A CompletedTCLP Extraction for Metals 02/21/25 AK SW1311

Comments:

Results are reported on an ``as received`` basis, and are not corrected for dry weight.

TCLP Non-Volatile Extraction:

Sample weight was < 100 grams (the minimum requirement of the method to insure homogeneity).

All soils, solids and sludges are reported on a dry weight basis unless otherwise noted in the sample comments.

Phyllis Shiller, Laboratory Director February 26, 2025

If you are the client above and have any questions concerning this testing, please do not hesitate to contact Phoenix Client Services at ext.200.

The contents of this report cannot be discussed with anyone other than the client listed above without their written consent.

Reviewed and Released by: Ethan Lee, Project Manager

RL/PQL=Reporting/Practical Quantitation Level ND=Not Detected BRL=Below Reporting Level

QA/QC Data

Parameter Blk Blank RL

MS

MSD

MS

RPD

QA/QC Report February 26, 2025

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102

Environmental Laboratories, Inc.

SDG I.D.: GCS65929

LCS

Dup

RPD

LCSD

LCS

RPD

Rec

Limits

RPD

Limits Sample Result

Dup Result

QA/QC Batch 771777 (mg/kg), QC Sample No: CS65896 2X (CS65929, CS65930, CS65931, CS65932) Mercury - Soil 109 >125BRL NC10914.0 105 3.7 m70 - 130 300.20 0.230.02

Additional Mercury Criteria: LCS acceptance range is 80-120% for aqueous and for soils the acceptance range is set by vendor limits. MS acceptance range is 75-125% for aqueous and 80-120% for soils.

Comment:

QA/QC Batch 771978 (mg/L), QC Sample No: CS65929 (CS65929) Mercury - Water 113BRL 102NC 80 - 120 200.0003 0.00030.0002

Additional Mercury Criteria: LCS acceptance range is 80-120% for aqueous and for soils the acceptance range is set by vendor limits. MS acceptance range is 75-125% for aqueous and 80-120% for soils.

Comment:

QA/QC Batch 771979 (mg/L), QC Sample No: CS65930 (CS65930, CS65931, CS65932) Mercury - Water 119BRL 94.1NC 80 - 120 200.0006 0.00060.0002

Additional Mercury Criteria: LCS acceptance range is 80-120% for aqueous and for soils the acceptance range is set by vendor limits. MS acceptance range is 75-125% for aqueous and 80-120% for soils.

Comment:

m = This parameter is outside laboratory MS/MSD specified recovery limits.

MS

Phyllis Shiller, Laboratory Director

If there are any questions regarding this data, please call Phoenix Client Services at extension 200.

February 26, 2025

MS Dup

RPD

LCS

LCSD

NC

Intf

Matrix Spike Matrix Spike Duplicate

Relative Percent Difference Laboratory Control Sample Laboratory Control Sample Duplicate

No Criteria Interference

(ISO) Isotope Dilution-

Sample Criteria Exceedances ReportWednesday, February 26, 2025

Acode Phoenix Analyte CriteriaResult RLSampNo Analysis

UnitsCriteria

GCS65929 - DOWNDASCriteria: CT: GAM, RC

RL

Criteria

State: CT

HG-SM Mercury 2031.6 1.2 mg/KgCS65929 CT / RSR DEC RES (mg/kg) / Inorganics 20

HG-SM Mercury 2034.3 1.2 mg/KgCS65930 CT / RSR DEC RES (mg/kg) / Inorganics 20

HG-SM Mercury 2048.1 1.3 mg/KgCS65931 CT / RSR DEC RES (mg/kg) / Inorganics 20

Phoenix Laboratories does not assume responsibility for the data contained in this exceedance report. It is provided as an additional tool to identify requested criteria exceedences. All efforts are made to ensure the accuracy of the data (obtained from appropriate agencies). A lack of exceedence information does not necessarily suggest conformance to the criteria. It is ultimately the site professional's responsibility to determine appropriate compliance.

Phoenix Environmental Laboratory, Inc.

Project Manager

Yes Were all samples received by the laboratory in a condition consistent with that described on the associated chain-of-custody document(s)?

For each analytical method referenced in this laboratory report package, were all specified QA/QC performance criteria followed, including the requirement to explain any criteria falling outside of acceptable guidelines, as specified in the CT DEEP method-specific Reasonable Confidence Protocol documents?

No

Were all QA/QC performance criteria specified in the CT DEEP Reasonable Confidence Protocol documents achieved?

For each analytical method referenced in this laboratory report package, were results reported for all constituents identified in the method-specific analyte lists presented in the Reasonable Confidence Protocol documents?

Wednesday, February 26, 2025Date:

Notes: For all questions to which the response was “No” (with the exception of question #7), additional information must be provided in an attached narrative. If the answer to question #1, #1A, or #1B is “No”, the data package does not meet the requirements for “Reasonable Confidence.” This form may not be altered, and all questions must be answered.

Authorized Signature:

Project No.

Phoenix Environmental Labs, Inc.

Laboratory Name

Project Location

FLOYD LITTLE ATHLETIC CENTER NEW HAVEN

Yes No

Yes No

Yes No

Laboratory Sample ID(s):Sampling Date(s) 2/19/2025

Were samples received at an appropriate temperature (≤6° C)?

3 Yes No

Yes No

Are project-specific matrix spikes and laboratory duplicates included in this data set for applicable RCPs?

7 Yes No

Printed Name:

Position:

LIST RCP METHODS USED (e.g., 8260,8270, etc.)

YesWere the method-specified preservation and holding time requirements met? No 1A

Was the VPH or EPH method conducted without significant modifications (see respective RCPs) 1B Yes No

NA

Were reporting limits / limits of quantitation specified or referenced on the chain-of-custody? 5 Yes No

NA

RCP QA/QC Certification Form

REASONABLE CONFIDENCE PROTOCOL

LABORATORY ANALYSIS QA/QC CERTIFICATION FORM

CS65929-CS65932

VPH and EPH methods only:

Name of Laboratory

This certification form is to be used for RCP methods only.

Bureau of Water Protection and Land Reuse Remediation Division

Version 2024 Page 1 of 1

If samples were received by the laboratory on the same day of collection and were stored and transported to the laboratory on ice, cooler temperatures above 6ºC are acceptable.

Were these reporting limits / limits of quantitation met? 5a

Client Name Down To Earth, LLC

1311/1312, 7470/7471

Ethan Lee

I, the undersigned, attest under the pains and penalties of perjury that, to the best of my knowledge and belief and based upon my personal inquiry of those responsible for providing the information contained in this analytical report, such information is accurate and complete.

Certification Report

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102 Fax (860) 645-0823

Environmental Laboratories, Inc.

SDG I.D.: GCS65929

Mercury Narration Were all QA/QC performance criteria specified in the analytical method achieved? Yes.

Instrument:

CS65929, CS65930, CS65931, CS65932

PSA 02/21/25 07:22 John Maslak, Zade-Anne Taylor, Chemist 02/21/25

The initial calibration met criteria and the linear range is defined daily by the calibration range.

The Low-Level Calibration Verification (LLCV) met criteria.

The following Initial Calibration Verification (ICV) compounds did not meet criteria: None.

The following Initial Calibration Blank (ICB) compounds did not meet criteria: None.

The following Continuing Calibration Verification (CCV) compounds did not meet criteria: None.

The following Continuing Calibration Blank (CCB) compounds did not meet criteria: None.

CS65929, CS65930, CS65931, CS65932

PSA 02/25/25 07:54 John Maslak, Zade-Anne Taylor, Chemist 02/25/25

The initial calibration met criteria and the linear range is defined daily by the calibration range.

The Low-Level Calibration Verification (LLCV) met criteria.

The following Initial Calibration Verification (ICV) compounds did not meet criteria: None.

The following Initial Calibration Blank (ICB) compounds did not meet criteria: None.

The following Continuing Calibration Verification (CCV) compounds did not meet criteria: None.

The following Continuing Calibration Blank (CCB) compounds did not meet criteria: None.

QC (Batch Specific):

CS65929, CS65930, CS65931, CS65932

Batch 771777 (CS65896)

All LCS recoveries were within 70 - 130 with the following exceptions: None.

All LCSD recoveries were within 70 - 130 with the following exceptions: None.

All LCS/LCSD RPDs were less than 30% with the following exceptions: None.

Additional Mercury Criteria: LCS acceptance range is 80-120% for aqueous and for soils the acceptance range is set by vendor limits. MS acceptance range is 75-125% for aqueous and 80-120% for soils.

QC (Site Specific):

CS65929

Batch 771978 (CS65929)

All LCS recoveries were within 80 - 120 with the following exceptions: None.

All MS recoveries were within 75 - 125 with the following exceptions: None.

Additional Mercury Criteria: LCS acceptance range is 80-120% for aqueous and for soils the acceptance range is set by vendor limits. MS acceptance range is 75-125% for aqueous and 80-120% for soils.

CS65930, CS65931, CS65932

Batch 771979 (CS65930)

All LCS recoveries were within 80 - 120 with the following exceptions: None.

All MS recoveries were within 75 - 125 with the following exceptions: None.

Additional Mercury Criteria: LCS acceptance range is 80-120% for aqueous and for soils the acceptance range is set by vendor limits. MS acceptance range is 75-125% for aqueous and 80-120% for soils.

Temperature Narration

RCP Certification Report

587 East Middle Turnpike, P.O.Box 370, Manchester, CT 06045 Tel. (860) 645-1102 Fax (860) 645-0823

Environmental Laboratories, Inc.

SDG I.D.: GCS65929

The samples were received at 2.1C with cooling initiated.

(Note acceptance criteria for relevant matrices is above freezing up to 6°C)