Phase_I_ESA_Report_311_Valley_Street_New_Haven_-_Draft-_20251020.pdf

EKI A80038.00 i Error! Reference source not found.

Phase I Environmental Site Assessment

311 Valley Street New Haven, Connecticut

18 November 2025 Valid 26 August 2025 to 22 February 2025

EKI C50249.00

EKI ENVIRONMENT & WATER, INC. www.ekiconsult.com 80 Eastern Boulevard, Suite 5 • Glastonbury, CT 06033

PHASE I ENVIRONMENTAL SITE ASSESSMENT

311 Valley Street, New Haven, Connecticut

Report Date:

18 November 2025

User of Report:

Ms. Helen Rosenberg City of New Haven Office of Economic Development 165 Church Street New Haven, CT 06510

Prepared by:

EKI Environment & Water, Inc.

80 Eastern Boulevard, Suite 5 Glastonbury, Connecticut 06033

(860) 325-7771 www.ekiconsult.com

Environmental Professionals Statements:

We declare that, to the best of our professional knowledge and belief, we meet the definition of Environmental Professional as defined in 40 CFR Section 312.10.

We have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the Subject Property. We have developed and performed all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

Nayantara Joseph, PhD Timothy O. Myjak, LEP Environmental Engineer Project Manager Key Phase I Task Dates:

Date of Environmental Database Report: 26 August 2025 Date Environmental Lien Search was Performed: 28 August 2025 Date Site Reconnaissance was Performed: 23 September 2025 Date Interviews were Performed/Questionnaire: 23 September 2025 Date Online Regulatory Databases were Searched: 26 August 2025 Date Agency File Reviews were Performed: 28 August 2025 http://www.ekiconsult.com/ i EKI C50249.00

Phase I Environmental Site Assessment 311 Valley Street

New Haven, Connecticut

1 INTRODUCTION .................................................................................................................. 1-1

1.1 Phase I ESA Tasks Performed ........................................................................................... 1-1

1.2 Limitations, Deviations, and Exceptions of Assessment .................................................... 1-2

1.3 Additional Services ......................................................................................................... 1-2

2 DESCRIPTION OF SUBJECT PROPERTY .................................................................................. 2-1

2.1 Subject Property Location, Setting, Current Uses and Ownership ..................................... 2-1

2.2 Topography and Surface Water Characteristics ................................................................ 2-1

2.3 Geology and Hydrogeology ............................................................................................. 2-1

2.4 Natural Diversity and Radon ........................................................................................... 2-2

2.5 Adjoining Properties ....................................................................................................... 2-2

3 HISTORICAL USE OF THE SUBJECT PROPERTY ....................................................................... 3-1

3.1 Historical City Directory Listings for Subject Property ....................................................... 3-1

4 OBSERVATIONS MADE DURING SITE RECONNAISSANCE ....................................................... 4-1

4.1 Adjoining Properties ....................................................................................................... 4-3

5 REVIEW OF PRIOR ENVIRONMENTAL REPORTS AND OTHER DOCUMENTS ............................ 5-1

6 INFORMATION PROVIDED BY OWNER AND USER ................................................................. 6-1

6.1 Summary of Owner Questionnaire .................................................................................. 6-1

6.2 Summary of User Questionnaire ...................................................................................... 6-1

6.3 Interviews with Key Site Persons ..................................................................................... 6-1

7 RESULTS OF REGULATORY AGENCY DATABASE SEARCH AND FILE REVIEWS .......................... 7-1

7.1 Results of EDR Database Search for Subject Property ....................................................... 7-1

7.2 Offsite, Nearby and Upgradient Chemical Release Sites ................................................... 7-2

7.3 Search and Review of Online Environmental Regulatory Databases .................................. 7-2

7.4 Results for Off-Site Upgradient Properties ....................................................................... 7-2

7.5 Review of Agency Files for Subject Property .................................................................... 7-2

7.6 Results of Environmental Lien Search .............................................................................. 7-3

8 NON-ASTM SCREENING ....................................................................................................... 8-1

8.1 Hazardous Building Materials .......................................................................................... 8-2

8.2 Per- and Polyfluoroalkyl Substances (PFAS) ..................................................................... 8-2

9 SUMMARY OF PHASE I ESA FINDINGS AND OPINIONS .......................................................... 9-1

9.1 Identified Phase I ESA Gaps ............................................................................................. 9-2

10 REFERENCES ..................................................................................................................... 10-1 ii EKI C50249.00

FIGURES

Figure 1 Subject Property Location Figure 2 Subject Property Site Plan and Adjacent Properties

APPENDICES

Appendix A Historical Sources of Information Appendix B Selected Photographs Taken During Site Reconnaissance Appendix C Prior Reports for Subject Property Appendix D Completed User and Owner Questionnaire Appendix E EDR Radius MapTM Report Appendix F Environmental Regulatory Agency File Information Appendix G EDR Lien Search Report Appendix H Resumes for Preparers of Phase I ESA Report

Phase I Environmental Site Assessment

Executive Summary New Haven, Connecticut

18 November 2025

ES1 EKI C50249.00

EXECUTIVE SUMMARY

EKI Environment & Water, Inc. (EKI) prepared this Phase I Environmental Site Assessment (ESA) for the City of New Haven (Client) regarding the property located at 311 Valley Street in New Haven, Connecticut (Subject Property; see Figure 1). The Subject Property consists of one parcel of land, identified by the City of New Haven Tax Assessor’s Office as parcel ID: 402/ 1183/ 01700. The Subject Property is an approximately 4.6-acre property that is currently improved with one commercial one-story building (former school) approximately 33,605 square feet in size. It is our understanding that the City of New Haven may redevelop the Subject Property in the near future.

This Phase I ESA was performed by EKI in general conformance with the scope and limitations of ASTM International (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, Designation: E1527-21 and the requirements issued by the U.S. Environmental Protection Agency (U.S. EPA) in 40 CFR Part 312, Standards and Practices for All Appropriate Inquiries, Final Rule (Final EPA AAI Rule). The ASTM E1527-21 standard and the Final EPA AAI Rule similarly prescribe accepted reasonable efforts to identify conditions indicative of releases and threatened releases of hazardous substances on, at, in, or to the Subject Property, e.g., Recognized Environmental Conditions (RECs). ASTM E1527-21 also prescribes measures to identify historical RECs, controlled RECs, Business Environmental Risks, and de minimis conditions at a property. On 15 December 2022, the U.S. EPA approved the use of ASTM E1527-21 to achieve “all appropriate inquiries”, the investigation required to establish diligence-based defenses to liability under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Findings

RECs: ASTM E1527-21 defines a REC as “(1) the presence of hazardous substances or petroleum products in, on, or at the Subject Property due to a release to the environment; (2) the likely presence of hazardous substances or petroleum products in, on, or at the Subject Property due to a release or likely release to the environment; or (3) the presence of hazardous substances or petroleum products in, on, or at the Subject Property under conditions that pose a material threat of a future release to the environment.”

Additionally, this Phase I ESA was conducted in general accordance with the protocols included in the Connecticut Department of Energy and Environmental Protection’s (CTDEEP’s) Site Characterization Guidance Document (SCGD) (2007, updated December 2010) including the identification of Areas of Concern (AOC). Note that not all AOCs meet the definition of RECs, nor do all RECs meet the definition of AOCs. This Phase I ESA also provides information that may be used to evaluate whether the Subject Property may be an “Establishment”, as the term is defined in the Connecticut Property Transfer Act.

AOCs: CTDEEP’s SCGD defines AOCs as locations or areas where hazardous waste and/or hazardous substances (including petroleum products) have been or may have been used, stored, treated, handled, disposed of, spilled, and/or released into the environment.

One REC was identified at the Subject Property in the performance of this Phase I ESA, which also meets the definition of an AOC as summarized below.

• 7,500-gallon Abandoned Heating Oil Underground Storage Tank (UST): A suspect underground storage tank (UST) vent pipe was observed along the west side of the building. The EDR database indicates that a 7,500-gallon steel heating oil UST was permanently closed and abandoned in-place at the Subject Property. According to the

Executive Summary New Haven, Connecticut

18 November 2025

ES2 EKI C50249.00

database, this UST was installed on 1 December 1950. The date the tank was abandoned was not available, and no records are available to document if the tank was properly closed in accordance with CTDEEP UST Closure requirements. Given that steel USTs typically have a service life of approximately 30 years and the tank's installation date was over 75 years ago, it is reasonable to assume that the service life was likely exceeded before it was abandoned. There is a material threat of release of fuel oil due to the potential for the steel tank to corrode beyond its design life; thus, this abandoned UST represents both a REC and an AOC for the Site.

Historical RECs: ASTM E1527-21 defines an HREC as “a previous release of hazardous substances or petroleum products affecting the Subject Property that has been addressed to the satisfaction of the applicable regulatory authority or authorities and meeting unrestricted use criteria established by the applicable regulatory authority or authorities without subjecting the Subject Property to any controls (for example, activity and use limitations or other property use limitations).”

• No HRECs were identified for the Subject Property in the performance of this Phase I ESA.

Controlled RECs: ASTM E1527-21 defines a Controlled REC (CREC) as a “recognized environmental condition affecting the Subject Property that has been addressed to the satisfaction of the applicable regulatory authority or authorities with hazardous substances or petroleum products allowed to remain in place subject to implementation of required controls.”

• No CRECs were identified for the Subject Property in the performance of this Phase I ESA.

Business Environmental Risks: ASTM E1527-21 defines a business environmental risk (BER) as “a risk which can have a material environmental or environmentally-driven impact on the business associated with the current or planned use of a parcel of commercial real estate.” The following BERs were identified for the Subject Property:

• Based on the date of construction of the Subject Property building (1950), asbestos-containing materials (ACMs) are likely to be present. Based on available records, manifests available indicate that ACMs have been abated and disposed of from the Subject Property building between 2000 and 2013. However, no documentation was available to determine if additional ACM still exists within the building.

• Based on the age of the Subject Property building (1950), polychlorinated biphenyls (PCBs) and lead-based paint may be present in and on the Site building.

• The Subject Property is in a Radon Zone 1 area, which is predicted to have indoor radon levels above the Action Level that the United States Environmental Protection Agency (EPA) recommends mitigation.

de minimis conditions: ASTM E1527-21 defines a de minimis condition as “condition related to a release that generally does not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.”

• No de minimis conditions were identified for the Subject Property in the performance of this Phase I ESA.

Executive Summary New Haven, Connecticut

18 November 2025

ES3 EKI C50249.00

Other Findings:

• Connecticut Property Transfer Act: A review of the subject Property’s history and manifests available from the CTDEEP indicates that the Subject Property does not meet the definition of an “Establishment” under the Connecticut Transfer Act. However, a final determination or opinion as to whether any future transaction is subject to the Connecticut Transfer Act should be reviewed by legal counsel.

Data Gaps

According to ASTM E1527-21, a “data gap” is a lack of or inability to obtain information required by the ASTM standard that affects the ability of the environmental professional to identify conditions indicative of releases or threatened releases to the Subject Property, despite good faith efforts made by the environmental professional. The following data gaps were identified:

• Lack of access to the interior of the two portable classrooms;

• Lack of access to the basement crawlspace;

• Lack of documentation describing the closure of the 7,500-gallon fuel oil UST; and

• As of the writing of this report, a response has not been received by EKI from the Health

Department.

Of these data gaps, the lack of documentation describing the closure of the 7,500-gallon fuel oil UST is considered significant, as it affects the ability to assess when and whether the tank was properly closed and whether releases occurred during operation or removal. However, given the likelihood that the UST exceeded its 30-year service life prior to removal, EKI nonetheless considers the former UST a REC. The lack of access to the basement crawlspace is also considered a significant data gap, as it limits the ability to observe conditions that could indicate RECs, including staining, odors, stored materials, or compromised underground utilities. The remaining data gaps are not considered significant, as additional information was available that allowed for the evaluation of RECs at the Subject Property.

No other data gaps were identified in the performance of this Phase I ESA.

This Executive Summary does not contain all of the information, including observations, findings, and opinions, presented in the full Phase I ESA report. This Phase I ESA report should be read in its entirety to obtain a more complete understanding of the information and issues identified regarding the Subject Property and to aid in the evaluation of risks, decision-making, and/or actions taken by Client based on this information.

Section 1 311 Valley Street Introduction New Haven, Connecticut

18 November 2025

1-1 EKI C50249.00

1 INTRODUCTION

EKI Environment & Water, Inc. (EKI) prepared this Phase I Environmental Site Assessment (ESA) for the City of New Haven (Client) regarding the property located at 311 Valley Street in New Haven, Connecticut (Subject Property; see Figure 1). The Subject Property consists of one parcel of land, identified by the City of New Haven Tax Assessor’s Office as parcel ID: 402/ 1183/ 01700. The Subject Property is an approximately 4.6-acre parcel of land that is currently improved with one commercial one-story building (former school) that is approximately 33,605 square feet. It is our understanding that the City of New Haven may redevelop the Subject Property in the near future.

The Subject Property is bordered by one commercial property and several residential properties to the west; several residences to the north and east; and Valley Street and several residences to the south (see Figure 2).

1.1 Phase I ESA Tasks Performed

EKI performed the following tasks as part of this Phase I ESA:

• Reviewed available historical land use information for the Subject Property, adjoining properties, and surrounding area (e.g., historical Sanborn maps, if available), historical aerial photographs, historical USGS topographic maps, and historical City Directories obtained from Environmental Data Resources, Inc. (EDR) (see Appendix A);

• Performed a reconnaissance of the Subject Property to observe the current conditions and setting of the Subject Property and adjoining properties (see photographs in Appendix B), and to interview a User representative;

• Reviewed available reports and documents prepared for the Subject Property provided by the User (see report in Appendix C);

• Reviewed the responses to a User Questionnaire, completed by a representative of the User of this Phase I ESA report, and an Owner Questionnaire, completed by a representative of the current owner of the Subject Property (see Appendix D);

• Purchased and reviewed an environmental regulatory agency database report for the Subject Property and surrounding area, prepared by LightBox EDR (referred to as an EDR Radius Map Report; see Appendix E);

• Searched for environmental reports for the Subject Property and selected nearby hydraulically upgradient reported chemical release sites (if reported) on the CTDEEP online databases, and reviewed available files;

• Requested publicly available files for the Subject Property from certain environmental regulatory and public agencies and reviewed files provided to EKI (see agency responses and files received in Appendix F); and

• Purchased and reviewed an Environmental Lien Search report for the Subject Property, prepared by EDR (see Appendix G).

1.2 Non-Scope Considerations

As part of this Phase I ESA, EKI collected information for the evaluation of whether the Subject Property may be an “Establishment” as defined in the Connecticut Property Transfer Act. Additionally, a screening-level, desktop assessment of the potential presence of hazardous building materials at the Subject

Section 1 311 Valley Street Introduction New Haven, Connecticut

18 November 2025

1-2 EKI C50249.00

Property was conducted. No other additional services beyond those required by ASTM E1527-21 and outlined within the SCGD were performed by EKI as part of this Phase I ESA.

1.3 Limitations, Deviations, and Exceptions of Assessment

This assessment did not include an audit of current facility operations for compliance with hazardous material usage laws, regulations, or permits, including occupational health and safety requirements. This Phase I ESA by EKI did not include an assessment of “non-scope considerations” as listed in Section 13.1.5 of ASTM E1527-21, other than a screening-level, desktop assessment of the potential presence of hazardous building materials at the Subject Property. In addition, an evaluation of whether the Subject Property may be an “Establishment” as the term is defined in the Connecticut Property Transfer Act was also conducted as part of this assessment.

1.4 Reliance On Phase I ESA

This report was prepared pursuant to the Agreement between EKI and the Client and, as such, is for the sole benefit, use, and reliance of the Client. Unless specifically authorized in writing in an agreement acceptable to EKI in its reasonable discretion, reliance on this report by any other entity is not permitted or authorized. Reliance on the information contained in this report by any third party without authorization by EKI does not make such entity a third-party beneficiary of EKI’s work product. Any such unauthorized reliance on, modification of, or use of this report, including any of its information or conclusions, will be at such third party’s sole risk. The User of this report, as defined by ASTM E1527-21, is the City of New Haven (Client).

The conclusions and recommendations presented herein are our professional opinion. They are not a warranty or guaranty as to the presence, absence, or extent of contamination on the Subject Property or of releases from or near the Subject Property. The facts presented herein are based on available information obtained by EKI and represent existing conditions at the Subject Property at the time the information was collected.

Section 2 311 Valley Street Description of Subject Property New Haven, Connecticut

18 November 2025

2-1 EKI C50249.00

2 DESCRIPTION OF SUBJECT PROPERTY

2.1 Subject Property Location, Setting, Current Uses and Ownership

EKI Environment & Water, Inc. (EKI) prepared this Phase I Environmental Site Assessment (ESA) for the City of New Haven (Client) regarding the property at 311 Valley Street in New Haven, Connecticut (Subject Property; see Figure 1). The Subject Property consists of one parcel of land, identified by the City of New Haven Tax Assessor’s Office as parcel ID: 402/ 1183/ 01700. The Subject Property is an approximately 4.6-acre parcel of land that is currently improved with one commercial one-story building (former school) that is approximately 33,605 square feet in size.

Surrounding the Subject Property building were landscaped areas on the north, south, and east sides, asphalt parking to the west, two portable classrooms to the south, and a children’s playscape area to the southeast. The Subject Property building was previously occupied by the West Rock Stream Academy, which closed in 2021, and has remained vacant since. The Subject Property is bordered by one commercial property and several residential properties to the west; several residences to the north and east; and Valley Street and several residences to the south (see Figure 2).

The Subject Property is connected to both municipal water and sewer service from the City of New Haven.

Electricity is supplied to the Subject Property by United Illuminating (UI). The Subject Property building is currently heated by natural gas. Additional information regarding the Subject Property building and setting is included in Section 4 of this report.

2.2 Topography and Surface Water Characteristics

The Subject Property slopes moderately from the north to the south at a surface elevation of approximately 65 feet above mean sea level (ft msl) based on the EDR database report. The closest waterbody to the Site is the West River, located approximately 900 feet south of the Subject Property (FWS, 2025). Based on the local topography and the location of the nearby river, the inferred groundwater flow direction is towards the south. The State of Connecticut classifies the West River as a Class SB surface water. Class SB surface waters are coastal and marine waters designated for high-quality uses, including marine fish, shellfish, and wildlife habitat; commercial shellfish harvesting for transfer to approved areas for purification; recreation; industrial water supply; and navigation (CTDEEP, 2022).

EKI did not observe any surface water or wetland features on the Subject Property during the Site reconnaissance.

2.3 Geology and Hydrogeology

In a review of the “Surficial Material Maps of Connecticut”, the Site is shown to be underlain by thin glacial till deposits, generally less than 10 to 15 feet thick (Stone, 1992). According to the “Bedrock Geology Map of Connecticut”, bedrock beneath the Subject Property and vicinity is mapped as the New Haven Arkose, a reddish, poorly sorted arkosic sandstone (Rodgers, 1985).

According to the CTDEEP Water Classification Map for New Haven, Connecticut (CTDEEP, 2018), groundwater beneath the Subject Property is classified as GA. Class GA designated groundwater uses include existing private and potential public or private supplies of water suitable for drinking without treatment, and baseflow for hydraulically connected surface water bodies.

The current CTDEEP Aquifer Protection Area map also indicates that this Subject Property is not situated within an Area of Contribution to any Public Water Supply Wells, nor is it located in an Aquifer Protection Area (CTDEEP, 2022).

Section 2 311 Valley Street Description of Subject Property New Haven, Connecticut

18 November 2025

2-2 EKI C50249.00

According to the Federal Emergency Management Agency Flood Insurance Rate Map online search and the EDR Database report, the Subject Property is not located in a designated flood zone area (FEMA, 2025).

2.4 Natural Diversity and Radon

According to the CTDEEP Natural Diversity Data Base Areas for New Haven, Connecticut map (CTDEEP, 2024), the Subject Property is listed on the State and Federal Listed Species area (CTDEEP, 2024).

According to the EDR report, the Subject Property is in a Federal EPA Radon Zone 1. The average indoor radon level in Zone 1 areas is expected to exceed four picocuries per liter (pCi/L). The EPA recommends mitigation when the radon level exceeds four pCi/L.

2.5 Adjoining Properties

From the Subject Property and publicly accessible areas, EKI observed the following adjoining properties and uses at the time of the site reconnaissance.

• To the north: Residences listed as 2, 6, 10, 14, 18, 22, and 26 Rock Creek Road.

• To the south: Residences listed as 295 and 299 Valley Street.

• To the east: Residences listed as 2, 21/2, 4, 6, 8, and 12 Strong Street.

• To the west: Several residences listed as 9, 7, and 1 Valley Place South, and a commercial building containing a community activity center called “The Shack” listed as 333 Valley Street.

Section 3 311 Valley Street Historical Use of the Subject Property New Haven, Connecticut

18 November 2025

3-1 EKI C50249.00

3 HISTORICAL USE OF THE SUBJECT PROPERTY

Information on historical uses of the Subject Property and the immediate vicinity was obtained from the following sources, which are included in Appendix A of this report:

• Historical aerial photographs for the Subject Property and vicinity provided by EDR for available years between 1934 and 2023;

• Sanborn Mapping for the Subject Property and vicinity provided by EDR for available years between 1924 and 1973;

• Historical USGS topographic maps for the Subject Property and vicinity provided by EDR for available years between 1892 and 2021; and

• Historical City Directory information provided by EDR for available years between 1941 and 2022.

Time Period Historical Land Use – Subject Property Historical Land Use – Adjoining Properties 1934-1951 The Subject Property is shown as being undeveloped on the 1934 and 1943 aerial photographs. The Site appears as open fields, possibly associated with agricultural use. By 1950, Sanborn mapping shows the Subject Property building present and is listed as being occupied by a school (West Hills Elementary), constructed on the north portions of the Subject Property.

In 1934, the area surrounding the Subject Property seems relatively undeveloped except for a few residences to the east. Additional development in the form of residences are shown in aerial photographs to the east, west, and south of the Subject Property in the 1949 aerial photograph. By 1950, both Sanborn mapping and aerial photographs show additional residential structures present on adjacent properties to the north, south, and east and an administrative building and several residential structures to the west of the Subject Property.

1954-2010 Between 1954 and 1985, the former school structure located in the northern portion of the Subject Property remains relatively unchanged. From the 2006 aerial photograph, one portable classroom is shown constructed to the south of the Subject Property building. From the 2010 aerial photograph, the second portable classroom is shown constructed to the southeast of the Subject Property building, similar to the present-day building configuration.

No significant changes were observed for adjacent or surrounding properties.

2012-Present The Subject Property remains essentially unchanged and is observed in its present-day configuration.

No significant changes were observed for adjacent or surrounding properties.

3.1 Historical City Directory Listings for Subject Property

The EDR City Directory listings (Appendix A) provides listings for 311 Valley Street between 1941 and 2022.

The City Directory listings for the Subject Property are detailed below:

Section 3 311 Valley Street Historical Use of the Subject Property New Haven, Connecticut

18 November 2025

3-2 EKI C50249.00

2022:

Alan Frishman Gabby’s School Isabel Senes New Haven Indiana New Haven Public Schools Rosalyn Bannon West Rock Stream Academy

2017:

No listing

2014:

City of New Haven

2010:

Microsociety Magnet School Sheridan Middle School

2005:

Beecher Elementary School

2000:

New Haven City of Education Department

1995:

West Hills School

1992:

West Hills School

1988:

West Hills School

1974:

West Hills School

1967:

West Hills School

1962:

West Hills School

1957:

West Hills School

1954:

West Hills School

1949:

Not listed

1945:

Not listed

1941:

Not listed

Residential listings were reported for surrounding properties located along Rock Creek Road, Strong Street, and Valley Place South, and several residences, a nursery school, City of New Haven administrative offices, and other small professional offices were listed for adjacent properties along Valley Street between 1941 and 2022. The EDR City Directory does not have listings available for years prior to 1941.

Section 4 311 Valley Street Observations Made During Site Reconnaissance New Haven, Connecticut

18 November 2025

4-1 EKI C50249.00

4 OBSERVATIONS MADE DURING SITE RECONNAISSANCE

On 23 September 2025, Mr. Don Wilson and Ms. Nayantara Joseph of EKI conducted a walk-through visual reconnaissance of the Subject Property. Accompanying Mr. Wilson and Ms. Joseph were Mr. Jeffrey Moreno and Mr. James Wankowicz of the City of New Haven. Mr. Wilson is an Environmental Professional as defined in 40 CFR Section 312.10, and as defined by ASTM 1527-21 (see professional resumes in Appendix H).

Key observations of the Subject Property and adjoining areas are discussed below. Selected photographs taken during the walk-through of the Subject Property by EKI are presented in Appendix B of this report.

Subject Property Reconnaissance Observations

Bu ild in g

Co ns tr uc tio n

General Building Uses

There is one, one-story commercial building (former school) located on the Subject Property, constructed primarily of brick, steel, and concrete. The approximately 33,605 square-foot building is currently vacant. Surrounding the Subject Property building were landscaped areas on the north, south, and east sides, asphalt parking to the west, two portable classrooms and a fenced community garden to the south, and a children’s playscape area to the southeast. The Subject Property is currently connected to both municipal water and sewer and is heated by natural gas.

Number of building stories

One.

Ancillary Structures Two portable classrooms were observed to the south of the former school building.

The portable classrooms were locked, and City personnel did not have a key, preventing interior access; therefore, observations were limited to exterior conditions only. The lack of access to the interior of the portable classrooms represents a data gap in the performance of this Phase I ESA.

Basement floor The Subject Property building is primarily slab on grade construction; however, one subgrade basement utility room and crawl space is located in the northern portion of the building. The utility crawl space was obstructed, allowing only partial entry and limited observations. The lack of access to the full interior of the crawlspace represents a data gap in the performance of this Phase I ESA.

Basement conditions The concrete floor in both the subgrade basement utility room and crawlspace was observed to be in good condition with no visible staining or cracking.

However, stagnant water pooling was observed in the basement.

In te rio r a nd E xt er io r

Hazardous Substances and Petroleum

Products in connection with identified uses

No bulk storage of hazardous or petroleum chemical products was observed during site reconnaissance. However, EKI observed small quantities of building maintenance products and cleaning and disinfecting products within the building maintenance storage closets. No evidence of leaks or spills from these containers and products was observed during the Site reconnaissance.

Storage Tanks None observed.

Unusual Odors

(strong, noxious, or pungent)

None observed.

Pools of Liquids None observed.

Drums, Totes, other

Bulk Containers (conditions, leaks, None observed.

Observations Made During Site Reconnaissance New Haven, Connecticut

18 November 2025

4-2 EKI C50249.00

staining) Sumps, clarifiers, drains Floor drains were observed in the kitchen and restroom areas throughout the building. In addition, several trench drains were also observed in the concrete floor of the basement boiler room. According to Mr. Wankowicz, all drains are connected to the sanitary sewer system.

Hazardous Substances and Petroleum Product

Containers not in Connection with Identified Uses

None observed.

Unidentified Substance Containers

None observed.

Hydraulic equipment (elevators, lifts)

None observed.

Polychlorinated Biphenyl (PCB)-containing equipment

None observed.

Transformers (pad-mounted or pole)

None observed.

In te rio r a nd E xt er io r Stains or Corrosion of

Walls or Floors None observed.

Ventilation of Sub- Grade Parking Levels (if any)

NA

Pits, Ponds, or Lagoons associated with Waste

Disposal

None observed.

Other Key Observations

Ex te rio r

Stained Soil or Pavement

None observed.

Stressed Vegetation None observed.

Obvious Fill Areas or

Debris Dumping None observed

Solid Waste None observed.

Aboveground Storage Tanks

None observed.

Underground Storage Tanks (vents, fill pipes)

A suspect underground storage tank (UST) vent pipe was observed along the west side of the building. No evidence of staining was observed beneath this pipe.

Historical records indicate that a 7,500-gallon steel heating oil UST was installed in 1950 and subsequently abandoned, though the date of abandonment is unknown (see Section 7.1 for further discussion). No documentation confirming proper UST closure was identified during this assessment. As with any former UST system, there is the potential for releases to have occurred that may have impacted site soil and/or groundwater due to overfills or subsurface releases from the tank/piping

Observations Made During Site Reconnaissance New Haven, Connecticut

18 November 2025

4-3 EKI C50249.00

systems. Thus, the suspect UST is considered to be a REC and AOC for the Site.

Wastewater (Industrial/ Domestic)

None observed.

Wells (Water Supply or

Monitoring)

None observed.

Septic/Leach Field Systems; Cesspools

None observed.

Storm Water Drainage (Municipal, dry wells)

A catch basin was observed in the southern portions of the Subject Property.

According to Mr. Wankowicz, all catch basins are connected to the municipal stormwater system.

Other Key Observations

Ad jo in in g Ar ea s

Manufacturing, industrial, or bulk chemical storage or distribution?

None observed.

Chemical use, storage or disposal?

None observed.

Ad jo in in g Ar ea s

Groundwater monitoring wells, grouted boreholes or other indicators of past investigations/ remedial actions?

None observed.

Observed current or indications of past gasoline service stations, dry cleaners, machine shops, or auto repair facilities?

None observed.

Other Key Observations None observed

4.1 Adjoining Properties

From the Subject Property and publicly accessible areas, EKI observed the following adjoining properties and uses at the time of the site reconnaissance.

• To the north: Residences listed as 2, 6, 10, 14, 18, 22, and 26 Rock Creek Road.

• To the south: Residences listed as 295 and 299 Valley Street.

• To the east: Residences listed as 2, 21/2, 4, 6, 8, and 12 Strong Street.

• To the west: Several residences listed as 9, 7, and 1 Valley Place South, and a commercial building containing a community activity center called “The Shack” listed as 333 Valley Street.

Section 5 311 Valley Street Review of Prior Environmental Reports and Other Documents New Haven, Connecticut

18 November 2025

5-1 EKI C50249.00

5 REVIEW OF PRIOR ENVIRONMENTAL REPORTS AND OTHER DOCUMENTS

EKI was not provided with, nor identified, any previously prepared environmental assessment, investigation, or remediation reports for the Subject Property during this Phase I assessment.

However, the User provided EKI with the building plans, parcel sketch, and property boundaries for the Subject Property. Copies of these documents are included in Appendix C of this report.

Section 6 311 Valley Street Information Provided by Owner and User New Haven Connecticut

18 November 2025

6-1 EKI C50249.00

6 INFORMATION PROVIDED BY OWNER AND USER

6.1 Summary of User Questionnaire

Mr. Carlos Eyzaguirre of the City of New Haven completed the User Questionnaire, dated 17 October 2025, a copy of which is included in Appendix D of this report. A summary of the key information provided in the User Questionnaire is presented below.

• The User representative is unaware of any environmental cleanup liens or activity and land use limitations (e.g., institutional or engineering controls) filed or recorded against the Subject Property).

• The User representative noted that they have no specialized knowledge or experience related to chemicals or chemical processes used at the Subject Property or on adjacent properties.

• The User representative noted that the purchase price reasonably reflects the fair market value.

• The User representative noted that a past use of the Subject Property was as a school.

• The User representative noted they do not have any knowledge of past uses or chemicals that are present or formerly present at the Subject Property.

• The User is not aware of spills or chemical releases that have taken place at the Subject Property.

6.2 Summary of Owner Questionnaire

Mr. Carlos Eyzaguirre of the City of New Haven completed the Owner Questionnaire, dated 17 October 2025, a copy of which is included in Appendix D of this report. A summary of the key information provided in the Owner Questionnaire is presented below.

• Mr. Eyzaguirre states a school formerly occupied the building located on the Subject Property.

• Mr. Eyzaguirre is not aware of any chemical waste generated or stored on the property.

• Mr. Eyzaguirre is not aware of any current or former USTs on the Subject Property.

• Mr. Eyzaguirre is not aware of or has any knowledge of any chemicals on the property stored in drums, or if any drums or other containers leak or have leaked in the past.

• Mr. Eyzaguirre is not aware of any current or former water supply wells on the property.

• Mr. Eyzaguirre is not aware of any air emissions or air discharge points on the property.

• Mr. Eyzaguirre is not aware of any past or current applications of pesticides, herbicides, or other agricultural chemicals to the property.

• Mr. Eyzaguirre is not aware of any equipment on the Subject Property that may contain PCBs, or if any transformer fluid or PCB-related spills or leaks on the property.

• Mr. Eyzaguirre is not aware of any asbestos and lead-in-paint surveys that have been conducted on the Subject Property.

• Mr. Eyzaguirre is not aware of any current or former landfills, waste disposal, or debris dumping areas on the Subject Property.

• Mr. Eyzaguirre is not aware of any known or suspected water supply wells on the Subject Property.

• Mr. Eyzaguirre is not aware of former railroad spurs or tracks on the Subject Property.

6.3 Interviews with Key Site Persons

During the Subject Property walk-through visual reconnaissance, EKI conducted interviews with Mr.

Moreno and Mr. Wankowicz of the City of New Haven. Information provided by Mr. Moreno and Mr.

Wankowicz is provided throughout the various sections of this report.

Section 7 311 Valley Street Results of Regulatory Agency Database Search and File Reviews New Haven, Connecticut

18 November 2025

7-1 EKI C50249.00

7 RESULTS OF REGULATORY AGENCY DATABASE SEARCH AND FILE REVIEWS

To identify conditions indicative of releases and threatened releases of hazardous substances on, at, in, or to the Subject Property (i.e., known or potential contamination of soil, soil vapor, or groundwater, or reported chemical use), EKI retained EDR to perform a search of available, selected federal, state, and local environmental regulatory agency databases. EDR searched for the Subject Property and properties located within selected radii of the Subject Property, consistent with ASTM E1527-21. A copy of the resulting “Radius Map Report” provided by EDR (EDR report), dated 26 August 2025, is provided in Appendix E. The EDR report provides a complete list of the federal, state, and tribal databases searched.

7.1 Results of EDR Database Search for Subject Property

According to the EDR Report, the Subject Property is listed in the following environmental regulatory databases:

Entity Name Database(s) Chemical Use / Release Notes Years Listed New Haven BOE

New Haven, CT

CT Asbestos The Subject Property is listed on the CT Asbestos database for the abatement and disposal of asbestos waste from the Subject Property building between 2005.

2000-2005, 2007, 2010 and 2013, West Hills School 311 Valley Street New Haven, CT

CT UST A suspect underground storage tank (UST) vent pipe was observed along the west side of the building. The EDR database indicates that a 7,500-gallon steel heating oil UST was permanently closed and abandoned in-place at the Subject Property. According to the database, this UST was installed on 1 December 1950. The date the tank was abandoned was not available, and no records are available to document if the tank was properly closed in accordance with CTDEEP UST Closure requirements. Steel USTs typically have a service life of approximately 30 years. Given the installation date of the tank, its anticipated service life was likely exceeded before it was abandoned. There is a material threat of release of fuel oil due to the potential for the steel tank to corrode beyond its design life; thus, this abandoned UST represents both a REC and an AOC for the Site.

West Hills Elementary School

CT Manifest The EDR database indicates that approximately 650 pounds of fluorescent lights (D009 mercury-containing hazardous waste) were disposed of off-site to Northeast Lamp Recycling Inc., on 2 February 1998.

West Hills School

CT SPILLS The EDR database indicates that a spill of “0” gallons of an unknown substance were released on the Subject Property due to construction. No further details or information were available in the database or from the CTDEEP online portal with respect to this spill.

Results of Regulatory Agency Database Search and File Reviews New Haven, Connecticut

18 November 2025

7-2 EKI C50249.00

Entity Name Database(s) Chemical Use / Release Notes Years Listed West Hills School 311 Valley Street New Haven, CT

FINDS The Subject Property is listed on the FINDS database. No chemical wastes or releases were reported in this listing.

N/A

The EDR listing describes a 7,500-gallon heating oil UST that was permanently closed and abandoned-in-place on the Subject Property; however, the date the tank was abandoned was not available. According to the EDR, the tank was constructed of steel and was installed in 1950. The Subject Property has since converted to gas heating; however, the exact timing of this conversion is unknown. Given that the tank's anticipated service life could have been exceeded prior to it being abandoned. Further, no documentation was available to confirm that proper closure was performed in accordance with CTDEEP UST Closure requirements. Due to the steel tank’s age exceeding its design life, the potential for corrosion-related material release, and the lack of documentation confirming proper closure, this abandoned UST represents both a REC and an AOC for the Site as it represents a condition that poses a material threat of a release of petroleum products to the Subject Site. The lack of documentation describing the tank's condition at the time of closure is a data gap. However, it is not significant, as additional information was available, allowing this finding to be evaluated as a REC.

The remaining EDR listings (CT Manifest, CT Asbestos, and FINDS) do not represent RECs for the Subject Property. The CT Manifest listings for fluorescent light disposal reflect the proper off-site management of regulated materials and therefore do not indicate a release to the environment. The CT Asbestos listing pertains to the abatement and disposal of asbestos-containing materials (ACM), which are outside the scope of an ASTM E1527-21 Phase I ESA.

7.2 Offsite, Nearby and Upgradient Chemical Release Sites

As discussed in Section 2.3, based on the topography of the overall Subject Property and the topography of the surrounding area, the inferred groundwater flow direction is southward. Thus, upgradient properties are generally to the north of the Subject Property. According to the EDR report, there are no chemical release listings located adjacent to or upgradient of the Subject Property within approximately one-quarter mile.

7.3 Search and Review of Online Environmental Regulatory Databases

EKI searched the CTDEEP online database for additional information about the Subject Property and nearby reported releases.

7.3.1 Results for Subject Property

EKI searched for the Subject Property in the CTDEEP online file database. There was one hazardous waste manifest and a spill incident report for the Subject Property (see Section 7.1 for further discussion).

7.4 Results for Off-Site Upgradient Properties

EKI searched the CTDEEP online file database for information on the adjacent properties. No files were available from the CTDEEP online database for any of these adjacent properties.

7.5 Review of Agency Files for Subject Property

EKI submitted online Freedom of Information Act (FOIA) requests on 28 August 2025 to the following environmental regulatory and public agencies for publicly available information concerning the Subject

Results of Regulatory Agency Database Search and File Reviews New Haven, Connecticut

18 November 2025

7-3 EKI C50249.00

Property: City of New Haven Assessors Office, Building and Planning Department, Fire Department, and the Health Department.

Assessor’s Office:

• EKI obtained the Assessors Cards for the Subject Property from the online database.

Fire Department:

• EKI reviewed the available files at the City of New Haven Fire Department for the Subject Property and found no relevant environmental files or concerns contained in any of the files reviewed. The Fire Department also informed EKI in an email dated 10 September 2025 that there were no records related to USTs for the Subject Property.

Building Department:

• EKI reviewed available online building permits for the Subject Property, and no relevant environmental files or concerns were contained in any of the permits reviewed.

Health Department:

• As of the writing of this report, a response has not been received from the Health Department.

The lack of response from the Health Department is considered to be a data gap in the performance of this Phase I.

Copies of documents obtained from the City of New Haven are provided in Appendix F.

7.6 Results of Environmental Lien Search

EKI purchased from EDR an Environmental Lien Search report for the Subject Property. A copy of the EDR Lien Search report, 28 August 2025, is included in Appendix G of this Phase I ESA report. According to the Environmental Lien Search report, there are no records of environmental cleanup liens, or activity or use limitations (AULs) filed or recorded against the Subject Property.

Section 8 311 Valley Street Non-Scope Consideration New Haven, Connecticut

18 November 2025

8-1 EKI C50249.00

8 NON-SCOPE CONSIDERATION

As part of this Phase I ESA, the following non-scope considerations were evaluated through a desktop screening of available historical information.

8.1 Connecticut Property Transfer Act

Available information was evaluated as to whether the Subject Property is an “Establishment” as the term is defined in the Connecticut Property Transfer Act (Section 22a-134). An Establishment means any real property at which or any business operation from which:

(A) on or after November 19, 1980, there was generated, except as the result of remediation of polluted soil, groundwater, or sediment, more than one hundred kilograms of hazardous waste in any one month;

(B) hazardous waste generated at a different location was recycled, reclaimed, reused, stored, handled, treated, transported, or disposed of;

(C) the process of dry cleaning was conducted on or after May 1, 1967;

(D) furniture striping was conducted on or after May 1, 1967; or

(E) a vehicle body repair facility was located on or after May 1, 1967.

Effective October 1, 2019, "Establishment" does not include any business operation from which more than one hundred kilograms of hazardous waste was generated in any one month solely as a result of either:

(i) The one-time generation of hazardous waste in any one month, as a result of either the first time such waste was generated or such a one-time generation since the last time a Form I, Form II, Form III or Form IV was required to be submitted; or

(ii) One or more of the following:

(I) Remediation of polluted soil, groundwater or sediment;

(II) The removal or abatement of building materials or the removal of materials used for maintaining or operating a building;

(III) The removal of unused chemicals or materials as a result of the…