Tighe&Bond

Former Photech Imaging Systems, Inc. 330 Cole Avenue Williamsburg, MA

Phase II Comprehensive Site Assessment & Phase III Remedy Implementation Plan RTN 1-11635
Prepared For: Town of Williamstown, MA August 2012

Table of Contents
Section 1 Introduction 
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Background Information ................................................................ 1-1  Conceptual Site Model ................................................................... 1-2 

Section 2 Description of Site Release 
2.1  General Site Description ................................................................ 2-1  2.1.1  Current Site Conditions ....................................................... 2-1  2.1.2  Surrounding Receptors ........................................................ 2-2  2.1.3  Site Use History ................................................................. 2-2  2.2  Site Hydrogeological Characteristics ................................................ 2-3  2.2.1  Topography and Drainage .................................................... 2-3  2.2.2  Surficial and Bedrock Geology .............................................. 2-3  2.2.3  Site Hydrogeology .............................................................. 2-4  2.3  Summary of Previous Investigations ............................................... 2-4  2.3.1  Earlier Investigations Findings .............................................. 2-5  2.3.2  Tighe & Bond’s MCP Investigations ........................................ 2-9 

Section 3 Supplemental Phase II Investigations 
3.1  Drilling Event ............................................................................... 3-1  3.1.1  Soil Boring Advancement ..................................................... 3-1  3.1.2  Monitoring Well Installations ................................................ 3-2  3.2  3.3  Soil Sampling .............................................................................. 3-2  Groundwater Sampling .................................................................. 3-3  3.3.1  Groundwater Collection ....................................................... 3-3  3.3.2  Groundwater Flow .............................................................. 3-3  3.4  3.5  Sediment and Surface Water Sampling ............................................ 3-4  Laboratory Results........................................................................ 3-5  3.5.1  Soil Results ....................................................................... 3-5  3.5.2  Groundwater Results ........................................................... 3-5  3.5.3  Sediment Results ............................................................... 3-5  3.5.4  Surface Water Results ......................................................... 3-6  3.6  Discussion ................................................................................... 3-6 

Section 4 Risk Characterization  Section 5 Phase III Remedial Action Plan 
5.1  Initial Screening of Remedial Action Alternatives ............................... 5-1  5.1.1  Soil Excavation and Off- Site Disposal.................................... 5-1  5.1.2  Soil Excavation, Stabilization and Off Site Disposal .................. 5-2  5.2  Detailed Evaluation of Remedial Action Alternatives ........................... 5-2  5.2.1  Soil Excavation and Off Site Disposal ..................................... 5-2 

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5.2.2  Soil Excavation, Stabilization, and Off Site Disposal ................. 5-2  5.3  5.4  Selection of Remedial Action Alternative .......................................... 5-3  Remedial Action Plan .................................................................... 5-3 

Section 6 Conclusions 
6.1  Public Notification ......................................................................... 6-1 

Section 7 Regulatory Limitations  Appendices
Appendix A – Figures Appendix B – Copies of Relevant Site Information Generated from Earlier Site Investigations Appendix C – Summary Data Tables Appendix D - Boring Logs and Field Sampling Sheets Appendix E – Laboratory Reports Appendix F – Method 3 Risk Characterization Appendix G – Copy of Public Notification Documents

Figures (Appendix A)
Figure 1 – USGS Site Locus Figure 2 – MassGIS Priority Resource Map Figure 3 – Orthophotograph Figure 4 – Site Plan Figure 5 – Groundwater Contour Plan

Tables (Appendix C)
Table 2-1 - Summary of Initial Phase I Soil Results Table 2-2 - Summary of Historical Cadmium and Silver Results in Soils Table 2-3 – Summary of Historical Groundwater Results Table 2-4 – Summary of Historical Petroleum Compound Results in Soils for IRA Excavation Areas Table 3-1 - Summary of Soil Borings (Supplemental Phase II Investigations) Table 3-2 – Summary of Groundwater Elevations (Supplemental Phase II Investigations) Table 3-3 – Summary of Soil Results (Supplemental Phase II Investigations) Table 3-4 – Summary of Groundwater Results (Supplemental Phase II Investigations) Table 3-5 - Summary of Sediment Results (Supplemental Phase II Investigations)
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Section 1 Introduction
On behalf of the Town of Williamstown, Tighe & Bond is submitting this Revised Phase II Comprehensive Site Assessment and Phase III Identification, Evaluation, and Selection of Comprehensive Response Action Alternatives for the former Photech Imaging Systems, Inc. (Photech) site located at 330 Cole Avenue in Williamstown, Massachusetts (the site). This submittal has been prepared for a release of oil and/or hazardous materials (OHM) at the site in conformance with the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000). A Site Locus, a Massachusetts Geographic Information Systems (MassGIS) Priority Resource Map, and an Orthophotograph are provided in Appendix A as Figures 1, 2, and 3, respectively. The Massachusetts Department of Environmental Protection (MADEP) first assigned Release Tracking Number (RTN) 1-11635 to the site in December 1996 for the threat of a release from drums of OHM at the abandoned site. Subsequent cleanup actions and assessment activities were performed by the U.S. Environmental Protection Agency (EPA) in 1997, with additional site investigations conducted by MADEP in 1998. Tighe & Bond conducted site investigations and MCP response actions between 2000 and 2004, with the Town serving as the Responsible Party (as a “Municipality with Exempt Status”) for site RTN 1-11635. The Town recently received funding for performing an evaluation to determine the remedial costs for addressing the contamination at the abandoned site. Tighe & Bond conducted supplemental Phase II investigations at the site, and based on those findings and our previous investigations we completed a site-wide Method 3 risk characterization. Site risks were evaluated assuming unrestricted activities and uses, current and future risk of harm to human health, safety, the public welfare and the environment posed by release-related conditions. In summary, a Condition of No Significant Risk does not exist for the single family residential scenario. In general, that risk is driven predominantly through consumption of homegrown produce. Under the multi-family residential scenario, a condition of No Significant Risk does exist subject to the restriction that there’s no consumption of homegrown produce (indicating that an Activity and Use Limitation will be required). Due to the presence of one site contaminant detected in sediment, at one location along the abutting Hoosic River, at a concentration above benchmark values, a risk to the environmental cannot be ruled out without additional investigation into a potential source and the limits of distribution in sediment. In order to have unrestricted site use, extensive excavation would be required to achieve a Permanent Solution under a Class A-1 or A-2 Response Action Outcome (RAO). However, placement of an AUL on the property would allow a wide-range of future uses at the site. The remedial options and associated costs are evaluated under Phase III (Section 5) of this report.

1.1 Background Information
Tighe & Bond conducted previous MCP investigations for site RTN 1-11635, which were summarized in the following submittals:

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  

Phase I - Initial Site Investigation and Tier Classification report (May 2003) Immediate Response Action (IRA) Completion Statement report (September 2003) Phase II – Comprehensive Site Assessment (CSA) report (October 2004)

The site data contained in those earlier submittals has been incorporated into this revised Phase II report, as appropriate. Since the October 2004 Phase II report submittal, no known additional investigations and/or MCP submittals have been completed for the site until our recent investigations described herein.

1.2 Conceptual Site Model
The abandoned site consists of 4.9 acres of land and is improved by an approximate 5,580 square-foot four-story building (referred to as Building #2) with a basement area. Access to the abandoned building is not currently restricted as some of the doorways to the building are open or unlocked. The site’s original three-story mill building (referred to as Building #1) was connected to Building #2 to the north/northwest, and that former building was demolished in 2005 under EPA oversight. The area of former Building #1 is now primarily covered by grass vegetation. The site entrance off Cole Avenue and the western portion of the site are covered by asphalt pavement generally in poor condition. The remaining portions of the site are generally covered by grass with tree growth along the fairly steep river embankment along the east/northeastern portion of the site and on the southern-most portion of the site. The elongated site parcel is abutted by the northwesterly flowing Hoosic River to the east/northeast, residential properties to the west/southwest and northwest, and undeveloped land to the south. Situated across Cole Avenue (to the northwest) is also a commercial property. A chain link fence and locked gate currently prevent vehicle access to the site off Cole Avenue, but currently there is no fencing between the site and the abutting residential neighborhood to the west. The site is located within a MADEP Wellhead Protection Area that is associated with three public water supply wells located within one half mile of the property. The area along the Hoosic River and its bank are mapped within Priority Habitat. When in use, the site was serviced by municipal sewer and water that are located off Cole Avenue. A 25-foot sewer line easement traverses along the western portion of the site parcel, near the abutting residential properties. A separate water line for the Hoosac Regional Water District has been abandoned on the site. A former bedrock well on the site, which was previously used for process water, was decommissioned by the Town in 2007. The site was first developed circa 1860s. The site has been occupied by several industries, including textile, paper, and photographic film manufacturing. Manufacturing of film emulsion coating and dye materials last occurred at the site circa 1988 when the property was abandoned. The Town of Williamstown has since obtained ownership of the property through non-payment of taxes. A canal system (fed by the Hoosic River) that originated south/southwest of the site property previously traversed through the south/southeastern portion of the property to Building #2, then discharged back to the river from beneath the eastern portion of the building. Based on historical mapping, the canal system existed pre-1900 to at least Revised Phase II CSA and Phase III RAP - RTN 1-11635 1-2

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the 1930s, and was filled in by the 1950s. The portion of the river bank where the canal discharged from beneath Building #2 was also apparently filled by that time. The site is underlain by fill soil that, in some areas, contains debris including metal, brick, wood, concrete, clay pipe, glass, and/or paper. Coal, coal ash, and wood ash (all MCP-exempt), as well as coal tar (not MCP-exempt) were also observed and detected through microscopic analysis in the fill. Transite pipe that contained asbestos-containing material (ACM) was also encountered in the fill on the southern portion of the site, within or near where the former canal system was located. Below the fill, the site is underlain by native alluvial deposits on a glacial outwash plain. These soils are described as an approximate 10 to 15-foot layer of fine sands to gravel (in areas where fill is not present) that is followed by a layer of silt and clay that is greater than 100 feet in thickness. A layer of sand and gravel reportedly underlies the silt/clay layer (creating artesian aquifer conditions), and dolomite bedrock is situated approximately 300 feet below grade. The depth to groundwater in the overburden aquifer is between approximately 5 feet below grade (on the upper, northwest portion of the site) and 15 feet below grade (on the eastern developed portions of the site), and groundwater flow is toward the abutting Hoosic River. A 20,000-gallon heating oil underground storage tank (UST), a 6,000-gallon methanol and heating oil UST, and a 3,000-gallon gasoline UST were removed from the site in 1986. During those removals, no releases were reportedly encountered and no significant levels of contaminants were reportedly detected in soil samples collected from the tank graves. Between 1986 and 1996, environmental investigations conducted at the site included the sampling of groundwater in the general vicinity of these former USTs, and no levels of contaminants were reported above applicable Reportable Concentrations or Method 1 standards. During former photographic film operations, industrial wastewater was processed through two concrete basins prior to their discharge to the municipal sewer system. Each basin consisted of two chambers and essentially served to settle out sludge. The sludge generated was a hazardous material, primarily based on its elevated cadmium and silver content. Sludge collected in the basins was reportedly mixed with wood chips and removed from the site by a waste hauler for recovery of the silver. One basin was located along the east/northeastern side of Building #2 (i.e., between the building and the river), and the other basin was located further to the southeast of Building #2. The basin adjacent to Building #2 reportedly overflowed or “foamed over” periodically when in operation. In 1986, approximately 30 cubic yards of discolored metals-impacted soil was removed along the length of this basin to a depth of approximately 5 feet below grade. In the late 1980s, the basin further to the southeast of Building #2 was replaced with a larger, multi-chambered concrete basin. After abandonment of the property, the wastewater and contaminated sludges that remained in the two basins were eventually removed and disposed by EPA during response actions conducted in 1997. As part of that work, EPA removed 40,000 gallons of industrial wastewater and 188 tons of contaminated wastewater treatment sludge, as well as over 500 abandoned drums of hazardous materials that were scattered mostly across the southern portions of the site. In 1997, EPA also completed 15 test pit explorations across the southern portions of the site and in the paved parking area to the west of the Building #2. EPA collected surficial soil samples from areas of concern, including adjacent to the two wastewater treatment basins and where former drum storage occurred. EPA reported elevated concentrations of cadmium and silver in surficial soil samples with the highest concentrations detected in soils adjacent to the two wastewater treatment basins. EPA also reported elevated Revised Phase II CSA and Phase III RAP - RTN 1-11635 1-3

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concentrations of polynuclear aromatic hydrocarbons (PAHs) in several subsurface soil samples with the highest PAH concentrations in a test pit sample collected in the approximate location of the former 20,000-gallon fuel oil UST. In 1998, MADEP collected soil/sediment and surface water samples from the Hoosic River along the site property boundary to assess the potential impacts to the river from the site. The samples were analyzed for RCRA 8 metals, polychlorinated biphenyls (PCBs), and semi-volatile organic compounds (SVOCs). PCBs were not detected, and the consistent levels of metals and SVOCs detected in the sediment samples were attributed to Local Conditions along the river at that time. Between 2000 and 2003, Tighe & Bond conducted Phase I investigations at the site. Soil samples were analyzed for metals of concern (cadmium, silver and lead), and select samples were analyzed for volatile organic compounds (VOCs) and extractable petroleum hydrocarbons (EPH). Silver and cadmium concentrations were detected at elevated concentrations in shallow soils (to depths of three feet below grade) in the areas of the wastewater treatment basins and in the vicinity of the former drum storage area on the southern portion of the site. Cadmium levels in three of the surficial soil samples collected in the vicinity of the former basin adjacent to Building #2 triggered an Imminent Hazard condition. Target PAHs were also detected at elevated concentrations in shallow soils near the former 20,000-gallon fuel oil UST and near a former slab ongrade barn-type building (referred to as Building #3) that was situated to the southwest of Building #2. These results were fairly consistent with the findings from EPA’s 1997 test pit program. Groundwater samples were also collected from five site monitoring wells that were located within or adjacent to the two former wastewater treatment basins, near the former 20,000-gallon fuel oil UST, near an abandoned 20,000-gallon No. 2 fuel oil UST situated immediately adjacent to the west/southwestern portion of the Building #2, and on the northeastern portion of the site near Cole Avenue. The samples were analyzed for EPH, VOCs, and dissolved metals of concern (cadmium, silver and lead). One petroleum carbon fraction was detected at an elevated concentration in a monitoring well TB-2B situated adjacent to the former 20,000-gallon fuel oil UST. As part of IRA activities conducted in June 2003, contaminated soil excavation occurred in six different areas of concern. This included the following:  Excavation of approximately 40 cubic yards (62.95 tons) of cadmium-impacted surficial soils (characterized as hazardous waste) from the area where the Imminent Hazard condition was identified. Excavation of approximately 600 cubic yards (859.99 tons) of non-hazardous metals-impacted soils in the areas of the two former wastewater treatment basins, and in the general vicinity of a former drum storage area on the southern portion of the site. The total depths of the excavations in these areas were three feet or less. In the excavation on the southern portion of the site, a drum containing asbestos containing material (ACM) was also encountered (and ultimately removed) in the fill. Excavation of approximately 300 cubic yards (447 tons) of petroleum-impacted soil from three areas of the site. This included the excavation of the surficial soils adjacent to the former Building #3, subsurface soils in the former 20,000-gallon fuel oil UST area, and subsurface soils in the area of the abandoned 20,000gallon No. 2 fuel oil UST. That abandoned tank was also removed as part of these activities.

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In July 2003, Tighe & Bond conducted follow-up Phase II investigations at the site, which included test pit explorations, soil boring advancement, installation of additional groundwater monitoring wells, and the collection of additional soil, groundwater and surface water samples for laboratory analysis. This work was performed to further delineate and characterize the remaining contamination following the completion of the IRA activities. The 2004 Phase II report concluded that a Condition of No Significant Risk did not exist at the site because exposure point concentrations (EPCs) for silver and petroleum compounds in site soils were above Method 1 standards. Since the submittal of the Phase II report in 2004, the Method 1 standards for some of the contaminants of concern for the site were modified when the “Wave 2” changes to the MCP became effective in April 2006. Of particular importance is that cadmium decreased from 30 milligrams per kilogram (mg/kg) to 2 mg/kg for the S-1 soil category. Because of the change in this standard, more site soil is now considered to be impacted by cadmium above Method 1 standards than what was described in the 2004 Phase II report submittal. At this time, the Town has preliminary plans for the demolition of the remaining site building (i.e., Building #2) and possibly re-developing the site for affordable housing use (if feasible) and/or as riverfront park area. Tighe & Bond conducted supplemental Phase II investigations at the site between June and July 2012 to update site conditions and to further evaluate impacts to environmental media across the site in preparation of future site remediation (as needed) prior to the planned redevelopment of the site. This included subsurface investigations in previously un-assessed area of the former main mill building (Building #1), further evaluation of cadmium in soils across the site since the change in MCP Method 1 standards in 2006, and a delineation of other impacts to environmental media in areas of potential concern at the site.

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Section 2 Description of Site Release
A description of the site and the background conditions associated with subject RTN 111635 were provided in previous MCP submittals. The site description is summarized and updated where appropriate in the sections below. A Phase II Site Plan is provided as Figure 4 in Appendix A for reference. [Note: The site plans provided in the earlier Phase II submittal referenced a “Project North” direction that is not shown on Figure 4 and is not being used in this revised Phase II report submittal.]

2.1 General Site Description
2.1.1 Current Site Conditions
The abandoned site is listed at 330 Cole Avenue in the Town of Williamstown, Berkshire County, Massachusetts (see Figure 1 for reference). The geographical location of the site is 4243’08” north latitude and 7312’28” west longitude. According to the Williamstown Assessor’s office, the site parcel is listed on Map 119, Block 0, Lot 18, and the parcel contains 4.90 acres of land. According to current Assessor’s card, the Town of Williamstown obtained ownership of the property in August 2001. The abandoned site is currently improved by a four-story building (Building #2) that has a basement area and a footprint of approximately 5,580 square feet. This building was built in 1941 with an addition in 1944. A separate mill building (Building #1) formerly abutted Building #2 to the north/northwest, and the footprint of that former larger mill building is now mostly covered by grass vegetation. The site entrance off Cole Avenue and the western portion of the site are covered by asphalt pavement generally in poor condition. The remaining portions of the site are primarily grass covered with tree growth along the fairly steep river embankment on the east/northeastern portion of the site, and on the southern portion of the site parcel (see Figure 3 for reference). When in use, the site was serviced by municipal sewer and water that are enters the site off Cole Avenue. A sewer line easement is located along the western portion of the site, near the abutting residential properties. A separate water line for the Hoosac Regional Water District is abandoned on the site. A bedrock water supply well was located adjacent to the southern portion of Building #2 (see Figure 4 for reference). That private well was decommissioned by the Town in 2007. The elongated site parcel is abutted by the northwesterly flowing Hoosic River to the east/northeast, residential properties to the west/southwest, and undeveloped land to the south/southeast. Situated across Cole Avenue from the site are additional residential properties and a commercial property. A chain link fence and locked gate currently prevent vehicle access to the site off Cole Avenue, but there is currently no fencing between the site and the abutting residential neighborhood to the west/southwest.

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2.1.2 Surrounding Receptors
The site is abutted by residential properties to the west/southwest and by the Hoosic River along the northeastern property line. According to MassGIS mapping (see Figure 2), the site is located within a MADEP Approved Wellhead Protection Area (i.e., Zone II) for three public water supply wells that are located within one half mile of the site. The site is also located above a NonPotential Drinking Water Source Area (High Yield). The area along the Hoosic River abutting the site is mapped within NHESP Priority Habitat for State-Protected Rare Species and Estimated Habitat for Rare Wildlife. This mapped area extends onto the subject site, on the southern portion of the site parcel.

2.1.3 Site Use History
The site was first developed circa the 1860s. The site has been occupied by several industries, including textile, paper, and photographic film manufacturing. Manufacturing of film emulsion coating and dye materials last occurred at the site until the site was abandoned circa 1988. The Town of Williamstown has since obtained ownership of the property through non-payment of taxes. A canal system (fed by the Hoosic River) that originated to the south/southwest of the site previously traversed through the southeastern portion of the property to Building #2, then discharged back to the river from beneath the northeast of Building #2. Based on Historical Sanborn Fire Insurance Mapping, that canal system was established pre1900 and its use continued through at least 1938 while the site was used for textile manufacturing. A 1959 Sanborn map of the site area no longer shows the canal system, and that the portion of the river bank where the canal previously discharged from beneath Building #2 had also apparently been filled in by that time. Previous investigations describe a sunken concrete pit floor in the basement of Building #2 which contains three oil burners. Sump pumps in that pit reportedly discharged to the Town’s storm system when in operation. During the former photographic film operations, industrial wastewater was processed through two concrete basins prior to their discharge to the municipal sewer system. Each basin consisted of two chambers and essentially served to settle out sludge. The sludge generated was a hazardous material, primarily based on its elevated cadmium and silver content. Sludge collected in the basins was reportedly mixed with wood chips and removed from the site by a waste hauler, for recovery of the silver. One basin was located on the east/northeastern side of Building #2 (i.e., between the building and the river), and the other basin was located further to the southeast of Building #2. In the late 1980s, the basin further to the southeast of Building #2 was replaced with a larger, multi-chambered concrete basin. After abandonment of the property, wastewater and contaminated sludges remained in the two basins. The contents of both basins were eventually removed and disposed by EPA during response actions conducted in 1997 (see Section 2.3 for further discussion). In 1986, a 20,000-gallon heating oil UST, a 6,000-gallon methanol and heating oil UST, and a 3,000-gallon gasoline UST were each removed from the site. A separate 20,000gallon No. 2 fuel oil UST situated along the west/southwestern portion of Building #2 was removed from the site in 2003. The approximate locations of the former tanks were shown on the site plan provided in our Phase I report submittal.

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An 8,159 square-foot building (Building #3) was situated to the south of Building #2. That former slab-on-grade barn-type building was built in the 1860s with an addition in 1944. Demolition of Building #3 was completed in 2003. The approximate footprint of former Building #3 is shown on Figure 4 for reference. Since the submittal of the Phase II report in October 2004, the larger Building #1 was demolished in 2005 under EPA oversight. That former 16,760 square-foot building was originally constructed in the 1860s as a textile mill and was connected to Building #2. According to the EPA website (http://www.epa.gov/aboutepa/region1.html), a November 29, 2005 press release regarding this demolition project stated the following: After removing more than 1,700 tons of debris containing asbestos from an abandoned mill complex, the U.S. Environmental Protection Agency has completed the cleanup work at the Photech site in Williamstown, Mass. EPA's work included the safe removal of contaminated materials, followed by off-site transport for proper disposal. EPA oversaw the removal of asbestos-containing material from the multi-story building by carefully demolishing the already partially collapsed center portion of the mill building. As part of the cleanup, 1,782 tons of the contaminated debris were removed from the building and shipped off-site for disposal at a licensed facility. In addition, 243 tons of scrap metal were transported off-site for recycling. Brick from the razed portions of the mill complex was used to backfill the open basement area where the mill building previously stood. After backfilling the area with the masonry debris, EPA placed six inches of clean fill over the brick, graded the area, and re-established or installed erosion control fence along the riverbank. The approximate footprint of the former Building #1 is shown on Figure 4 for reference.

2.2 Site Hydrogeological Characteristics
2.2.1 Topography and Drainage
The site is situated at approximately 190 meters above mean sea level. Topography across the site is generally level, but pitches toward the Hoosic River with a steeply sloped embankment adjacent to the river especially on the northern and central portions of the site parcel.

2.2.2 Surficial and Bedrock Geology
2.2.2.1 Mapping According to the U.S. Department of Agriculture, Soil Conservation Service, Berkshire County, Massachusetts Central Part Soil Atlas (Map no. 17) the site is underlain with a soil characterized as Urban Land with areas of Copake soil units. Urban land soil is made up of areas of soils that have been so altered or obscured by urban works and structures that identification of the original soil type is impossible. Structures built on the site and filling of site areas have resulted in Urban Land soil classification. The Copake soil is generally encountered in vacant lots and is used as lawns, parks, and other areas that are interspersed among buildings and streets and has few limitations to most urban uses. Typically this soil category consists of deep loamy sands that are somewhat excessively drained with 0 to 15 percent slopes. The permeability of these soils is Revised Phase II CSA and Phase III RAP - RTN 1-11635 2-3

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moderate to moderately rapid in the subsoil and very rapid in the substratum. Consequently the available water capacity in these units is moderate. According to the USGS Bedrock Geologic Map of Massachusetts, the site is underlain by the Stockbridge bedrock formation. The Stockbridge formation is described as beige, tan and dark gray weathering quartzose dolomite marble containing interbeds of black, green and maroon phyllite and weathered blue quartz pebble quartzite. 2.2.2.2 Other Information Further information on geological conditions at and immediately surrounding the subject site was obtained from the following sources:  A draft report entitled Groundwater Exploration Program at the Green River Site prepared by Camp, Dresser & McKee, Inc (CDM) for delineation of the Town of Williamstown public water supply aquifer and Zone II. A well log (dated 1944) for the on-site process water well that was ultimately decommissioned by the Town in 2007.

The existing overburden geology of the site area was shaped by glacial advance and retreat approximately 15,000 years ago and by river and stream action since that time. The site geology is comprised of four primary layers: (1) an upper layer of fine sands and gravel, bearing an unconfined aquifer; (2) a confining layer of silt and clay; (3) a lower layer of fine to coarse sand mixed with gravel, bearing a confined aquifer; and, (4) fractured dolomite bedrock, bearing a confined bedrock aquifer. The depth to bedrock within the site area is reportedly 285 feet below grade. The former process water well at the site was set to approximately 330 feet below grade within dolomite, and the well log indicates that the artesian well flowed at a rate of 700 gallons per minute. The stratigraphy for the site area (which includes the former Photech well) is shown on a cross sectional plan prepared by CDM, a copy of which is provided in Appendix B for reference. Previous structural borings advanced at the subject site to depths of up to 80 feet below ground indicated that the silt and clay confining layer was encountered to at least this depth.

2.2.3 Site Hydrogeology
In the upper unconfined aquifer, the depth to groundwater is generally between 5 and 15 feet below grade across the site, and the groundwater flow direction is generally to the east/northeast toward the abutting Hoosic River. Further site hydrogeology information is provided in Section 3.

2.3 Summary of Previous Investigations
A review of earlier site investigations conducted by others and Tighe & Bond was provided in our previous MCP submittals for the site. As part of this revised Phase II report submittal, supplemental site information was obtained from MADEP’s release lookup website for site RTN 1-11635. A summary of previous site investigations is provided below.

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2.3.1 Earlier Investigations Findings
Earlier site investigations were conducted by Rizzo Associates in 1986, by Scalise-Knysh Associates, Inc. (SKAI) in 1996, by the EPA in 1997 and 1998 (using Roy F. Weston, Inc. (Weston) as the environmental consultant), and by MADEP in 1998. 2.3.1.1 Summary of 1986 Site Investigations and Remediation In 1986, a 3,000-gallon gasoline UST, a 6,000-gallon methanol UST and a 20,000-gallon fuel oil UST were removed from the site. During the tank removals, Rizzo reported that no releases from the tanks were encountered, and that no significant levels of contaminants were detected in soil samples collected from the tank graves. Other OHM storage areas at the site that Rizzo identified included an abandoned 20,000-gallon No. 2 fuel oil UST, two concrete wastewater settling tanks, an exterior transformer vault, and a drum storage area. Rizzo collected soil samples from each of these areas of concern. In summary, Rizzo reported the following:     No PCBs were detected in soil samples collected near the transformer pad No VOCs were detected in soil samples collected beneath and adjacent to the drum storage area Some detections of “oil and grease” were reported in soil samples collected near the abandoned 20,000-gallon No. 2 fuel oil UST A release of cadmium and silver was reported to soils from the periodic overflow of the (former) wastewater treatment basin located adjacent to Building #2

A copy of a site plan prepared by Rizzo showing soil sample locations is provided in Appendix B for reference. [Note: Laboratory data and/or a summary table for this soil data were not located in previous reports or in MADEP’s on-line files.] As part of follow-up activities conducted in 1986, Rizzo excavated approximately 30 cubic yards of silver and cadmium contaminated soil from the visibly stained area around the wastewater treatment basin adjacent to Building #2 for off-site disposal as a hazardous waste. The excavation reportedly occurred along the length of this basin over a width of approximately 8 feet and to depths between 5 and 7 feet below grade (the deeper depths were excavated closer to the basin). Confirmatory soil samples analyzed by EP toxicity analysis (predecessor to the TCLP analysis) indicated concentrations had been reduced to below hazardous waste levels. However, total silver and cadmium concentrations in the remaining soils were not analyzed. As part of this follow-up investigation Rizzo also installed three monitoring wells. One well (MW-102) was installed on the upgradient portion of the property off Cole Avenue, one well (MW-101) was installed near the (former) abandoned 20,000-gallon No. 2 fuel oil UST located along the western portion of Building #2, and one well (MW-103) was installed to the east of Building #2 near the wastewater treatment basin. Rizzo collected groundwater samples from the wells for VOC analysis. The groundwater sample collected from well MW-103 was also submitted for dissolved RCRA 8 metals. Rizzo reported that one VOC (trans-1,2-dichloroethylene) was detected in well MW-103 at a low concentration of 15 micrograms per liter (µg/L), which was below the “Safe Drinking Water Act” standard of 270 µg/L at that time. [Note: This concentration is also below the current MCP Reportable Concentration of 90 µg/L for the applicable RCGW-1 groundwater category.] No other VOCs were detected in the three groundwater samples. Rizzo also reported that no dissolved RCRA 8 metals were detected. A copy of Revised Phase II CSA and Phase III RAP - RTN 1-11635 2-5

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a site plan and summary tables prepared by Rizzo for post-excavation EP soil data and for groundwater samples are provided in Appendix B for reference. 2.3.1.2 Summary of 1996 Site Investigations SKAI’s assessment included installation of three additional monitoring wells (MW-3, MW4, and MW-5) in areas to the south of Building #2, and the collection of groundwater samples from the three new wells and from two existing (Rizzo) wells located to the east and west of Building #2. [Note: These two existing wells were identified as MW-2 and MW-1 by SKAI, and correspond to Rizzo’s earlier MW-103 and MW-101, respectively.] Three of the samples were submitted for VOC analysis, and three of the samples were submitted for dissolved RCRA 8 metal analysis. SKAI also collected a surficial soil sample adjacent to the (former) wastewater treatment basin east of Building #2 for RCRA 8 metal analysis. A copy of a site plan prepared by SKAI showing approximate monitoring well locations is provided in Appendix B for reference. Copies of data tables prepared by SKAI summarizing the results for the groundwater samples and one soil sample are provided in Appendix B for reference. A summary of SKAI’s sample results is as follows:  Seven petroleum-related VOCs were detected at low concentrations (i.e., below applicable RCGW-1 groundwater values, as summarized in SKAI’s data table) in the groundwater sample collected from the existing well MW-1. No VOCs were detected above laboratory reporting limits in the other two groundwater samples submitted for VOC analysis. Low concentrations (i.e., below applicable RCGW-1 groundwater values, as summarized in SKAI’s data table) of dissolved arsenic and lead were detected in one or more of the monitoring wells. No other metal was detected above laboratory reporting limits in the three groundwater samples submitted for dissolved RCRA 8 metals analysis. Low concentrations (i.e., below applicable RCS-1 soil values, as summarized in SKAI’s data table) of arsenic, barium, cadmium, chromium (total), and silver were detected in the surficial soil sample. It should be noted that the cadmium result of 9 mg/kg in the soil sample was above the current RCS-1 value (and Method 1, S-1 standard) of 2 mg/kg. However, the surficial soils in this area were subsequently removed during IRA activities conducted by Tighe & Bond, as further reviewed below in Section 2.3.2.

2.3.1.3 Summary of EPA Response Actions and Investigations After abandonment of the property, the wastewater and contaminated sludges that remained in the two basins were removed and disposed by EPA during response actions conducted in 1997. As part of that work, EPA ultimately removed 40,000 gallons of industrial wastewater and 188 tons of contaminated wastewater treatment sludge, as well as over 500 abandoned drums of hazardous materials that were scattered across the abandoned site. Also as part of this work, oily water that was in the abandoned 20,000-gallon UST adjacent to Building #2 was pumped out and disposed off-site. As part of their site assessment, EPA completed 15 test pit explorations across the south/southeastern portions of the site and in the paved parking area to the west of Building #2. From those test pits, six soil samples were selected for laboratory analysis of RCRA 8 metals, PAHs, PCBs, VOCs, cyanide, methanol, and formaldehyde. In addition, EPA collected six surficial soil samples (including five composite samples and one grab sample) from identified areas of concern, including areas adjacent to the two Revised Phase II CSA and Phase III RAP - RTN 1-11635 2-6

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wastewater treatment basins and where former drum storage reportedly occurred. The six surficial soil samples were submitted for laboratory analysis of RCRA 8 metals and PAHs. Three of the samples were also analyzed for PCBs, and three of the samples were analyzed for cyanide. The approximate locations of where EPA conducted test pit explorations and soil sampling is shown on a site plan prepared by Weston in 1997, a copy of which is provided in Appendix B for reference. Data tables summarizing soil results were also prepared by Weston and are provided in Appendix B. A summary of EPA’s soil sample results is as follows:  Barium, chromium (total), and lead were detected at low concentrations (i.e., below current RCS-1 values of 1,000 mg/kg, 30 mg/kg, and 300 mg/kg, respectively, for these three metals), and arsenic, cadmium, mercury, selenium, and silver were not reported above method detection limits in the six test pit soil samples. Silver was detected at elevated concentrations (i.e., above the current RCS-1 and Method 1, S-1 standard of 100 mg/kg) in the surficial soil samples collected near the two former wastewater treatment basins. Cadmium was also detected above 2 mg/kg in these two samples. As further reviewed below in Section 2.3.2, the impacted surficial soils near the two former wastewater treatment basins were subsequently removed during IRA activities conducted by Tighe & Bond. Cadmium was also detected above 2 mg/kg in three of the other surficial soil samples (concentrations ranging between 3.09 mg/kg and 15.1 mg/kg). Barium, chromium (total), and lead were detected at low concentrations, and arsenic and selenium were not reported above method detection limits in the six surficial soil samples. Mercury was detected at low concentrations (i.e., below current RCS-1 value of 20 mg/kg) in two of the surficial soil samples. PAHs were reported above the method detection limits in two of the test pit samples. In the soil sample collected from approximately 10 feet below grade in a test pit excavated in the general location of the former 20,000-gallon fuel oil UST, four PAHs (including benzo(a)anthracene, benzo(b)fluoranthene, benzo(a)pyrene, and dibenzo(a,h)anthracene) were detected at elevated concentrations (i.e., above the current RCS-1 values). As further reviewed below in Section 2.3.2, the impacted subsurface soils in this area were subsequently removed during IRA activities conducted by Tighe & Bond. No other PAHs were reported at elevated concentrations in the test pit soil samples. In a surficial soil sample collected adjacent to (west of) former Building #3 and in a surficial soil sample collected near the former wastewater basin adjacent to Building #2, benzo(a)pyrene was detected above the current RCS-1 value of 2 mg/kg. As further discussed in Section 2.3.2, the impacted surficial soils in these two locations were subsequently removed during IRA activities conducted by Tighe & Bond. No other PAHs were detected at elevated concentrations in the surficial soil samples. Tetrachloroethene was detected at 0.014 mg/kg and 0.015 mg/kg (i.e., well below the current RCS-1 value 1 mg/kg) in two of the test pit soil samples. No other VOC was reported above the method detection limits in the test pit soil samples. No PCBs were reported above method detection limits in the test pit soil samples or in the surficial soil samples submitted for PCB analysis. Cyanide (total) was detected at a very low concentration of 0.29 mg/kg (i.e., well below the current RCS-1 value of 100 mg/kg) in one test pit soil sample. 2-7

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Cyanide was not reported above method detection limits in the other test pit soil samples or in the surficial soil samples submitted for cyanide analysis.  Methanol and formaldehyde were not reported above method detection limits in the test pit soil samples.

2.3.1.4 Summary of MADEP Investigations Following the conclusion of EPA’s work, MADEP collected soil/sediment and surface water from along the bank of the Hoosic River on July 14, 1998 to assess the potential impacts to the river from the site. A total of five sediment samples, four surface water samples, and one soil sample were collected for laboratory analysis. A copy of a site plan prepared by MADEP that shows the approximate locations where MADEP collected the samples is provided in Appendix B for reference. Sediment sample PR-1 was collected near the southeastern corner (upstream edge) of the property, and each of the other sediment samples was collected progressively downstream of the PR-1 location with sediment sample PR-5 being collected near the northeastern corner of the property near the Cole Avenue bridge. Sediment samples PR-3 and PR-4 were collected adjacent to the two discharge/outfall pipes located east of Building #2. At each of these sediment sample locations (except PR-1), surface water samples were also collected. Lastly, one soil sample was collected from the river bank in the same general vicinity of where EPA had collected a surficial soil sample near the former wastewater treatment basin that abutted Building #2. Each of the samples was submitted for laboratory analysis of PCBs, RCRA 8 metals, and SVOCs. A copy of a data table summarizing sample results prepared by MADEP is provided in Appendix B for reference. A summary of MADEP’s sample results is as follows:  The concentrations of metals and SVOCs (four PAHs were detected) detected in the five sediment samples were fairly consistent with each result well within the same order of magnitude. No PCBs were detected in the sediment samples. It should also be noted that silver was not detected in any of the sediment samples, and cadmium concentrations ranged between 1.2 mg/kg and 3.1 mg/kg in the sediment samples. Two metals (barium and chromium) were detected in the surface water samples with their concentrations also being consistent with one another. No SVOCs or PCBs were detected in the four surface water samples. As MADEP also reported that “although there are no MCP standards for sediment and surface water, the results were below both the MCP's Groundwater-1 and Soil-1 standards.” No PCBs, RCRA 8 metals or SVOCs were detected in the one soil sample.

2.3.1.5 Conclusions In general, the results from the previous investigations indicated the following:   Surficial soils in the vicinity of the two former wastewater treatment basins were impacted by elevated concentrations of silver and cadmium. Subsurface soils in the vicinity of the former 20,000-gallon fuel oil UST to the south of Building #2 were impacted by elevated concentrations of petroleumrelated compounds including PAHs. 2-8

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Surficial soils adjacent to (west of) former Building #3 were impacted by elevated concentrations of one PAH compound. No contaminants detected in groundwater exceeded applicable (and current) RCGW-1 values. No significant impacts from the site to sediments or surface water within the abutting Hoosic River were encountered. Furthermore, the two primary metals of concern for the site (silver and cadmium) were either not detected or were detected at consistently low concentrations from the upstream to the downstream portions of the river bank area abutting the site. These findings suggested that the contaminants identified in sediments and in the surface water body could be attributed to local conditions.

2.3.2 Tighe & Bond’s MCP Investigations
As reviewed above, the known product primarily used or stored at the site was petroleum and the known wastes primarily generated at the site were silver and cadmium-containing wastewater and sludge. Based on this history and the results of previous investigations, the primary focus of our MCP investigations was further assessment (and remediation) of petroleum contaminants (including PAHs) and silver and cadmium. 2.3.2.1 Phase I Investigations As further discussed in our May 2003 Phase I report submittal, Tighe & Bond conducted subsurface investigations at the site between August 2000 and May 2003 as part of Phase I and pre-IRA excavation activities. In general, these investigations included the following:    The advancement of 38 soil borings (identified as B-1 through B-30, B-1A, B26A, B-27A, TB-1, TB-2A, TB-2B, TB-3, and TB-4). The completion of borings TB-1, TB-2B, TB-3, and TB-4 as groundwater monitoring wells. The submittal of 75 soil boring samples and two additional surficial soil samples (identified as SS-GEN and SS-Bldg 3) for laboratory analysis. [Note: Of the 75 soil boring samples submitted for laboratory analysis, 72 of the samples were collected from shallow depth intervals of less than three feet below surface grade.] The soil samples were submitted for laboratory analysis of silver (71 samples), cadmium (71 samples), lead (26 samples), EPH with target PAHs (6 samples), and/or VOCs (1 sample). The collection of groundwater samples from the newly installed wells TB-1, TB2B, TB-3, and TB-4, and from existing well MW-2 in August 2000, and the resampling of well TB-4 in October 2000 and well TB-2B in April 2003. The groundwater samples were submitted for laboratory analysis of dissolved silver, cadmium and lead (5 samples), EPH with target PAHs (5 samples), and/or VOCs (5 samples).

The approximate locations of the Phase I soil borings, monitoring wells, and surficial soil samples are shown on Figure 4, with the exception of the following:

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Borings B-1A, B-9, B-21, B-26A, and B-30, and surficial soil sample location SSBldg 3 because these sample locations were subsequently excavated during IRA activities, as further described below. Wells TB-2 and TB-4 which were subsequently replaced by wells MW-2B and MW1, respectively, during Phase II investigations, as further described below.

In general, the significant findings from our Phase I investigations were as follows:  Silver and/or cadmium were detected at elevated concentrations (i.e., above applicable Method 1 standards at that time) in several additional shallow soil samples collected in the vicinity of the two former wastewater treatment basins (consistent with EPA findings), and in shallow soil samples collected on the southern portion of the site. A total cadmium concentration above the Imminent Hazard threshold of 60 mg/kg cadmium was also identified in select soil samples in the vicinity of the former wastewater treatment basin adjacent to Building #2. This finding triggered a 2-hour IRA condition (reported on May 5, 2003). Target PAHs were detected at elevated concentrations (i.e., above applicable Method 1 standards at that time) in shallow soils adjacent to (west of) former Building #3 (consistent with EPA findings) and in the vicinity of the former 20,000-gallon fuel oil UST. The EPH carbon fraction C11-C22 aromatics was detected at 223 µg/L in monitoring well TB-2B during the second (April 2003) sampling event. This concentration exceeded the Method 1, GW-1 standard of 200 µg/L.

Tables 2-1, 2-2, and 2-3 provided in Appendix C summarize soil results from the initial Phase I investigations (conducted in August 2000), historical results for cadmium and silver in site soils, and historical groundwater results from Tighe & Bond’s investigations, respectively. In the tables, soil and groundwater results are compared to current Method 1 standards (i.e., since the “Wave 2” changes to the MCP became effective in April 2006) for reference. It should also be noted that soil results from Tighe & Bond's earlier investigations that were ultimately removed during our subsequent IRA activities are not included in Tables 2-1 and 2-2. 2.3.2.2 IRA Completion As part of IRA cleanup activities conducted in June 2003, the excavation of contaminated soils for proper off-site disposal occurred in six different areas of concern at the site. This cleanup work included the following:  Excavation of approximately 40 cubic yards (62.95 tons) of cadmium-impacted surficial soils characterized as hazardous waste from where the Imminent Hazard condition was identified in earlier soil samples (i.e., in the vicinity of the former wastewater treatment basin adjacent to Building #2). Excavation of approximately 600 cubic yards (859.99 tons) of non-hazardous cadmium and silver-impacted soils in three areas of concern. This included the following: o Continued soil excavation in the vicinity of the former wastewater treatment basin adjacent to Building #2 on top of and along the river embankment. The excavation occurred over an approximate 4,090 2-10

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square-foot area. The depth of excavation was generally less than one foot below grade on the upper portions of this area (i.e., closer to Building #2) and up to 3.5 feet below grade along the river bank area. Excavation along the embankment was performed to the extent feasible, while maintaining stability of the slope and several of the relatively larger existing trees, in accordance with Conservation Commission requirements. Upon completion of this excavation, the embankment was re-graded to a consistent slope and covered with 0.5 to 2 feet of angular stone rip-rap also in accordance with the Conservation Commission Emergency Certification for this work. o Soil excavation across an approximate 2,530 square-foot area to the immediate south of the other former wastewater treatment basin. The total depth of the excavation across this area was between approximately 0.5 and 3 feet below grade. Soil excavation across an approximate 5,200 square-foot area on the southern portion of the site in the general vicinity of a former drum storage area. The total depth of the excavation across this area was between approximately 0.5 and 3 feet below grade. In this area, a 55gallon drum containing asbestos containing material (ACM) was also encountered and ultimately removed for off-site disposal during the IRA.

o

Excavation of approximately 300 cubic yards (total of 447 tons) of petroleumimpacted soil from three areas of concern. This included the following: o Excavation of surficial soils across an approximate 310 square-foot area adjacent to (west of) the former Building #3 location (also referred to as former “Barn B” area) where elevated PAHs were previously identified. The total depth of this excavation was approximately one foot. Excavation of subsurface soils from approximately 7 to 11 feet below grade across an approximate 400 square-foot area in the former 20,000gallon fuel oil UST area where elevated PAHs (and “oil and grease”) were previously identified. The abandoned 20,000-gallon No. 2 fuel oil UST to the west of Building #2 was removed as part of the IRA activities because there were reports that the tank previously had a leaking suction line. This included demolition of a four to five-foot thick concrete pad overlying the entire tank, removal of 122 gallons of residual oily water and sludge from the bottom of the tank, and excavation of subsurface soils from portions of the excavation where evidence of a petroleum release was encountered. Petroleum-impacted soils were removed from approximately 5 to 14 feet below grade across an approximate 1,480 square-foot area.

o

o

At the completion of the IRA excavations, the areas were backfilled to grade with clean soil, unless otherwise noted above. The approximate limits of the earlier IRA excavation areas are included on Figure 4 for reference. Subsequent “confirmatory” soil sampling and other assessment that occurred in the IRA excavation areas was completed under Phase II. 2.3.2.3 Phase II Investigations Between June and July of 2003, Tighe & Bond completed confirmatory soil sampling and/or additional investigations in each of the six IRA excavation areas. Additional Revised Phase II CSA and Phase III RAP - RTN 1-11635 2-11

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assessment occurred in areas outside of the known release areas at the site and in the Hoosic River. In general, the Phase II investigations included the following:  The collection of 28 “final” confirmatory soil samples for laboratory analysis of cadmium and silver, and the collection of 16 confirmatory soil samples for EPH analysis. [Note: Two additional confirmatory soil samples were for laboratory analysis of cadmium and silver, but those representative soils were subsequently removed during additional IRA activities, as further discussed below.] The advancement of 14 additional soil borings, with three of the borings being completed as groundwater monitoring wells identified as MW-1 (replacing earlier well TB-4), MW-2B (replacing earlier well TB-2), and MW-3. From the soil borings, 11 additional soil samples were submitted for EPH analysis for further delineation of petroleum impacts. The advancement of 21 additional shallow hand auger borings and/or exploratory test pits for further delineation of metals impacts. From those locations, 41 additional soil samples (from varying sample intervals) were submitted for analysis of cadmium and silver. The collection of three additional groundwater samples for EPH analysis. The collection of three surface water samples for total cadmium and silver analysis. The collection of three “background” soil samples for analysis of cadmium and silver.

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The approximate locations of the IRA confirmatory soil samples and other Phase II drilling, test pitting, and/or sampling locations are included on Figure 4. Laboratory results from these earlier Phase II investigations are summarized in Tables 2-2, 2-3, and 2-4 (Appendix C), as further discussed below. For details on these earlier Phase II investigations (including boring and test pit logs, complete laboratory reports, etc.), refer to the 2004 Phase II report. Former Basin Adjacent (East) to Building #2: During the IRA activities, “final” confirmatory soil samples were collected from 10 separate locations (identified as B-1B, B-24A through B-24D, B-26B, B-26C, B-27B, B-27C, and B-30A) within this excavation area. One soil sample from each location was submitted for analysis of cadmium and silver. [Note: Two additional confirmatory soil samples were collected from this area as part of IRA activities. Confirmatory soil sample B-30 (1-1.5’) was collected on June 9, 2003 from the B-30 boring location and confirmatory soil sample B-31 (6) (i.e., from six inches below grade) was collected on June 2, 2003. Soils represented by these two samples were subsequently removed during continued IRA excavation activities conducted in this area. Therefore, these sample locations are not shown on Figure 4 and those earlier cadmium and silver results are not included in Table 2-2.] Also in June 2003, hand borings were advanced at three additional locations (identified as B-32, B-33, and B-34) outside the limits of this IRA excavation area. From these hand boring location, four soil samples were submitted for analysis of cadmium and silver. In July 2003, two additional hand auger borings were advanced within the limits of this IRA excavation area in the area of earlier confirmatory sample locations B-30A and B27C. Samples B-30A(5') and B-27C(3.5') were collected below the previous IRA Revised Phase II CSA and Phase III RAP - RTN 1-11635 2-12

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confirmatory sample depths at these locations, and submitted for analysis of cadmium and silver. The cadmium and silver results for the 16 “representative” soil samples collected from this area during these earlier Phase II activities are included in Table 2-2. As summarized, cadmium and/or silver were detected at elevated concentrations (i.e., above current Method 1 standards) in several of the soil samples. Also, the cadmium concentration of 199 mg/kg in sample B-30A(3') remained above the IH threshold of 60 mg/kg. However, as described in the earlier Phase II report, this sample does not represent an IH condition as it is located beneath 2 feet of rip-rap and is not considered accessible. Former Basin Further Southeast of Building #2: During the IRA activities, confirmatory soil samples were collected from seven separate locations (identified as B20A, B-20B, and B-22A through B-22E) within this excavation area. From these locations, a total of nine soil samples (collected from varying depths) were submitted for analysis of cadmium and silver. The cadmium and silver results for the nine soil samples collected from this area during these earlier Phase II activities are included in Table 2-2. As summarized, cadmium and/or silver were detected at elevated concentrations (i.e., above current Method 1 standards) in several of the soil samples. Metals-impacted area on Southern Portion of Site: During the IRA activities, confirmatory soil samples were collected from nine separate locations (identified as B7.1, B-7.2, B-9A, B-9B, B-10A, B-10B, B-10C, B-16A, and B-16B) within the excavation conducted in this former drum storage area. From these locations, a total of 11 soil samples were submitted for analysis of cadmium and silver. In July 2003, six elongated test pits (identified as test pits B-7AB, B-7C, B-7DE, B-7.3F, B-7GH, and B-7.4I) were excavated outside the limits (to the east and south) of the IRA excavation area for further delineation of metals-impacts at varying depths between 0 to 0.5 feet, 0.5 to 3 feet and 3 to 6 feet below grade. In general, sand and gravel fill was encountered to depths of 3 to 5 feet below grade, below which gray to brown silt and sand was encountered in each of the test pits. Significant percentages of debris (including metal, bricks, wood, concrete, ash, coal, clay pipe, glass and paper) were encountered in layers within the fill in test pit sample locations B-7AB, B-7C, B-7E and B-7F. A total of 30 soil samples collected from within these six test pit exploration areas were submitted for silver and cadmium analysis. Pieces of transite board were also observed in the fill at sample locations B-7A(3') and B-7F(4'), and that suspect ACM material was submitted for analysis to determine asbestos content. In addition, samples B-7A(0.5-3') and B-7F(3-5') were collected from soil in the immediate vicinity of the ACM for asbestos analysis to evaluate potential impacts to soil. In July 2003, three test pit explorations (identified as B-9A, B-9CD, and B-16C) were also excavated through sand and gravel backfill within limits of the former IRA excavation area. Three soil samples collected from these test pits were submitted for analysis of cadmium and silver to further delineate vertical impacts. In addition, soil sample B-16C(4-5') collected from the vicinity of the former 55-gallon drum containing ACM (removed during the IRA) was submitted for asbestos analysis to evaluate potential impacts to soil.

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The cadmium and silver results for the 44 soil samples collected from this area during these earlier Phase II activities are included in Table 2-2. As summarized, cadmium and/or silver were detected at elevated concentrations (i.e., above current Method 1 standards) in several of the soil samples. It should also be noted that the suspect ACM from sample location B-7F(4') was found to contain 20% chrysotile asbestos. Asbestos was not detected in soil samples B-7A(0.53'), B-7F(3-5'), and B-16C(4-5'). Former 20,000-gallon Fuel Oil UST Area: During the IRA activities, confirmatory soil samples were collected from the four sidewalls (identified as B-21 East, B-21 South, B21 West, and B-21 North) of the excavation at separate intervals of 0 to 7 feet below grade and 7 to 11 feet below grade. A confirmatory soil sample was also collected from the base of the excavation (identified as B-21 Bottom). Each of these nine confirmatory soil samples was submitted for EPH analysis. Observation of the soils encountered in the excavation indicated the presence of fill (consisting of concrete, bricks, metal, cobbles, wood, coal and cinder/ash) in both the shallow and deeper soils in the excavation. Four of the confirmatory sidewall soil samples were subsequently submitted for microscopic analysis to confirm the presence of coal and/or ash. In addition, a test pit (identified as Basin TP) was excavated outside the limits of this IRA excavation for further soil characterization, and soil samples collected from 1 to 5 feet below grade and 7 to 11 feet below grade from this test pit were also submitted for EPH analysis. In July 2003, a total of 12 additional soil borings (identified as B-21A through B-21L) were advanced in areas outside the limits of this IRA excavation. In general, soils encountered in these borings were consistent with those found within the IRA excavation and consisted of approximately 7 feet of fill (concrete, brick, limestone cobbles, wood, coal and cinder/ash) overlying gray to dark gray silty fine sand with trace organics (wood fiber) to 11 feet below grade. Apparent native gray silty fine sand was encountered between 11 and 12 feet below grade. As shown on Figure 4, this IRA excavation area and most of these surrounding borings were located in the area of the former canal headrace that directed Hoosic River water to the mill. It appears that the top 7 feet of soil consists of fill used to backfill in the former canal, and that the dark gray organic silt and sand between 7 and 11 feet below grade may consist of river sediment that collected at the base of the former canal. From these 12 soil borings, 11 additional soil samples were submitted for EPH analysis. Four of the samples were also submitted for microscopic analysis. A summary of the EPH results is provided in Table 2-4. Within the table, soil results are compared to current Method 1 standards for reference. The target PAH results are also compared to MADEP’s identified background levels in soils containing coal, coal ash or wood ash associated with fill material. As shown, EPH carbon ranges were below Method 1 standards in each of the 11 confirmatory soil samples. Target PAHs, including acenaphthylene, benzo(a)pyrene, and/or dibenzo(a,h)anthracene, were detected above Method 1, S-1/GW-1 standards in five of the samples. Acenaphthylene and/or dibenzo(a,h)anthracene were also detected slightly above MADEP’s background values for soil containing coal and/or ash in the samples. Particles of coal, coal ash, and/or wood ash were also identified in each of the eight samples submitted for microscopic analysis. Small amounts of coal tar were also identified in two of the samples. Former Abandoned 20,000-gallon No. 2 Fuel Oil UST: Following the removal of the abandoned tank and the petroleum-impacted soils, four confirmatory samples were

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submitted for EPH analysis. The samples selected for analysis from this former “TB-3” well location were labeled TB-3 Bot-2, TB-3 NW-2, TB-3 SW-4, and TB-3 EW-3. A summary of the EPH results is provided in Table 2-4. As shown, EPH carbon ranges and target PAHs were not detected above laboratory reporting limits in any of the four confirmatory soil samples. Former “Barn B” Area: In this PAH-impacted soil area adjacent to (west of) the former Building #3 location, one confirmatory soil sample (labeled “Barn B-2”) was collected from the IRA excavation for EPH analysis. A summary of the EPH results is provided in Table 2-4. As shown, low concentrations (i.e., below Method 1 standards) of EPH carbon ranges and target PAHs were detected in the confirmatory soil sample. Surface Water Sampling: Three surface water samples were collected from the Hoosic River from locations generally upstream (sample SW-1) and downstream (samples SW-2 and SW-3) of the metals-impacted area of the site (See Figure 4 for reference). Each sample was submitted for total cadmium and silver analysis. Neither metal was detected above laboratory reporting limits in the three surface water samples. Other “Background” Sampling: Three “background” soil samples (labeled as SBKGRND1, S-BKGRND2, and S–BKGRND3) were collected from the north/northwestern portion of the site off Cole Avenue (see Figure 4 for reference). Each sample was collected from approximately 0 to 1 feet below grade and submitted for analysis of cadmium and silver. Neither metal was detected above laboratory reporting limits in the three soil samples.

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Section 3 Supplemental Phase II Investigations
Tighe & Bond conducted supplemental investigations at the site between June 2012 and July 2012. In general, the purpose of these investigations was to update site conditions and to further evaluate impacts to environmental media across the site in preparation for future site remediation (as needed) prior to the planned redevelopment of the site. This included subsurface investigations in previously un-assessed areas, and further evaluation of the cadmium in soils across the site since the change in MCP Method 1 standards in 2006.

3.1 Drilling Event
Drilling occurred at the site on July 9 and July 10, 2012. Drilling was conducted by Martin Geo-Environmental, LLC of Belchertown Massachusetts under Tighe & Bond observation. The drilling event included the following:   The advancement of eight soil borings using a truck-mounted Mobile Drill B-53 rig and the hollow stem auger (HSA) drilling method The advancement of 17 additional soil borings using a track-mounted Geoprobe® Model 6610DT vibratory direct-push probe unit.

Based on a survey completed by Tighe & Bond using Global Positioning System (GPS) equipment, the approximate locations of the borings are shown on both the Orthophotograph (Figure 3) and Site Plan (Figure 4) for reference. Further details are provided below.

3.1.1 Soil Boring Advancement
3.1.1.1 HSA Method On July 9, 2012, borings B-101, B-102, B-103, B-103A, B-104, B-105, B-106, and B107 were advanced using the HSA drilling method. During boring advancement, soil samples were collected in five foot intervals using two-foot split-spoon samplers for logging site stratigraphy. Each boring was advanced to a depth below the groundwater table interval. Boring logs prepared by Tighe & Bond are provided in Appendix D for reference. In general, fill soils were encountered to total depths of less than five feet below grade (in borings B-106 and B-107) to greater than seven feet below grade (in borings B-103 and B-104). A minor amount of brick debris was encountered in the fill in borings B101, B-102, B-105, and B-106. In general, sand and gravel were encountered below the fill in borings B-101, B-102, B-104, B-105, and B-107. In borings B-102, B-103A, B-106, and B-107, a silt layer with intervals of clay was encountered at depth. At boring B-102, advanced within the footprint of the former Building #1 (see Figure 4), auger advancement occurred through concrete at approximately five feet below grade. The concrete is presumably associated with the former building foundation. At boring location B-103 advanced between Building #2 and the river (i.e., in the area of the former wastewater treatment basin), auger refusal occurred at approximately 12 feet below grade. Boring B-103A was advanced approximately 30 feet to the north/northwest of B-103 (see Figures for reference). At boring location B-106, some Revised Phase II CSA and Phase III RAP - RTN 1-11635 3-1

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staining and little petroleum type odor were encountered in the shallow fill soils immediately beneath the paved surface area. [Note: This boring was advanced in general vicinity of the former 6,000-gallon methanol UST removed in 1986.] No significant evidence of petroleum contamination or other suspect discoloration (e.g., petroleum staining) or odors were noted in any of the other soil samples collected from these eight borings. 3.1.1.2 Direct-Push Method On July 10, 2012, borings B-108 through B-124 were advanced across the site using the vibratory direct push method. During boring advancement, soil samples were collected in four-foot increments using macro-core samplers. Each boring was advanced to four feet below grade. Borings B-111, B-112, B-114, B-117, B-121, B-122 and B-124 were advanced to eight feet below grade for further soil characterization at depth. Table 3-1 which summarizes the soil boring findings is provided in Appendix C for reference. In general, fill soils were encountered in each of the borings. In the fill, brick and/or concrete debris were encountered in 10 of the borings, and evidence of coal and/or ash were also observed in four of the borings. In boring B-124 advanced in the paved surfaced area to the northwest of Building #2 (see Figure 4), a layer of gray soil with petroleum type odor was observed in soils generally between 2 and 4 feet below grade. No significant evidence of petroleum contamination or other suspect discoloration (e.g., petroleum staining) or odors were noted in any of the other soil samples collected from these 17 borings.

3.1.2 Monitoring Well Installations
As part of the July 9, 2012 drilling event, soil borings B-101, B-103A, B-104, and B-107 were completed as groundwater monitoring wells MW-4, MW-5, MW-6 and MW-7, respectively. As shown on Figure 4, the general locations of the new wells is as follows:   Well MW-4 was installed on the north/northeastern portion of the site. Well MW-5 was installed on the eastern portion of the site within the former IRA excavation for metals-impacted soils in this area, immediately downgradient of the former Building #1 and Building #2 connection. Well MW-6 was installed on the southern portion of the site within the former IRA excavation for metals-impacted soils.

Each well was completed with two-inch diameter, Schedule 40 PVC riser and 10 feet of 0.010-inch slotted well screen set across the groundwater table as encountered during drilling. Clean, washed silica sand was placed in the boring annulus around the well screen to a depth of approximately two-feet above the well screen, and a two-foot bentonite seal was placed above the sand pack. Native backfill was placed above the bentonite seal. Wells MW-4, MW-5, and MW-6 were completed with a protective steel standpipe casing cemented in-place. Well MW-7, situated in the paved surface area, was completed at the surface with flush-mounted road box cemented in place. Monitoring well details are included on the borings logs proved in Appendix D.

3.2 Soil Sampling
During the July 9 and July 10, 2012 drilling event, soil samples collected from approximately 0 to 2 feet below grade in borings B-108, B-113, B-114, B-115, B-116, B122, and B-124 were submitted for the laboratory analysis of cadmium and silver to Revised Phase II CSA and Phase III RAP - RTN 1-11635 3-2

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further characterize the metals impacts in shallow soils across the site. In addition, soil boring samples B-103 (5-7’), B-103A (10-12'), B-113 (2-4’), B-114 (4-8’), B-117 (2-4'), B-117 (4-8'), B-121 (0-4’), and B-124 (2-4’) were submitted for analysis of cadmium and silver to further characterize the metals impacts at depth. Soil boring samples B104 (5-7’), B-105 (5-7’), B-105 (12-13’), B-106 (0-2’), and B-124 (2-4’) were submitted for analysis of EPH with target PAHs. On July 26, 2012, Tighe & Bond collected additional soil samples using a stainless steel hand auger. As part of this event, borings B-125 through B-129 were advanced along the east/southeastern portions of the site near or along the slope embankment to the river. The locations of these hand borings were also surveyed using GPS equipment and are shown on Figures 3 and 4. Soil samples collected from approximately 0 to 2 feet below grade in each hand boring were submitted for analysis of cadmium and silver to further delineate the metals impacts in shallow soils in those areas.

3.3 Groundwater Sampling
On July 26, 2012, Tighe & Bond personnel collected groundwater samples from the three newly installed monitoring wells, and from existing monitoring wells MW-1, MW-2B, and MW-3 described earlier.

3.3.1 Groundwater Collection
Groundwater samples were collected using low-flow procedures, in general compliance with U.S. Environmental Protection Agency’s Region I Low Stress (low flow) Purging and Sampling Procedure. During low flow purging of the wells, field measurements for pH, conductivity, oxidation reduction potential (ORP), dissolved oxygen (DO), and temperature were monitored using a Horiba® water quality meter and a flow-through cell. Turbidity was measured separately using a Turbidimeter. Copies of Tighe & Bond’s Well Purging – Field Water Quality Measurements Forms from this event are provided in Appendix C. Low flow purging occurred for a minimum of 30 minutes at each well prior to beginning sampling. DO and/or turbidity readings did not properly stabilize in accordance with EPA protocols before sampling occurred at many locations. When turbidity readings are high it typically overestimates the concentrations of contaminants in a well. Consequently, it is our opinion that this does not represent an issue with respect to the groundwater data collected from those wells. No sheens of odors were noted in the purged water prior to sampling. Each of the six groundwater samples was submitted for laboratory analysis of EPH with target PAHs, and dissolved cadmium and silver. Each of the water samples submitted for dissolved metal analysis was filtered in the field using separate 0.45 micron filters before preserving.

3.3.2 Groundwater Flow
On July 26, 2012, Tighe & Bond personnel surveyed the relative elevation of the top of each well based on an assumed datum. Using groundwater gauging information we collected, groundwater elevations were calculated for each well, and groundwater contours were developed for the site. Table 3-2, provided in Appendix C, summarizes the calculated groundwater elevations for the six wells. Based on these calculated elevations, a Groundwater Contour Plan was developed and is provided as Figure 5 in Appendix A. Revised Phase II CSA and Phase III RAP - RTN 1-11635 3-3

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As shown on Figure 5, the groundwater flow direction was calculated to be to the east/northeast toward the river across the northern and central portions of the site. On the portion to the south of Building #2, the groundwater hydraulics may be influenced by the former canal system that ran through this portion of the site as the calculated groundwater elevations for wells MW-1 and MW-6 (situated within or near the former canal channel) are similar to or lower than in the assumed “downgradient” wells MW-2B and MW-3 situated to the east, nearer to the river. Therefore, groundwater contours and flow direction cannot be easily deciphered for this portion of the site without further data.

3.4 Sediment and Surface Water Sampling
On July 26, 2012, Tighe & Bond personnel collected eight sediment samples from the site. Each sediment sample was collected from the observed river bank/water interface at the time of the sampling event. Sediment samples were collected using a stainless steel spoon or a stainless steel hand auger, and the sediment was homogenized in a stainless steel bowl. Sampling equipment was decontaminated with an Alconox solution between sample locations. Sediment samples were placed in laboratory-supplied containers for analysis. A brief description of the sampling locations is as follows:   Sample SED-1 was collected upstream of the site at a location off the subject property. No notable conditions were observed at this sampling location. Samples SED-2 and SED-3 were collected downstream of sample SED-1 and upgradient of Building #2. Minor debris (brick, concrete and scrap metal) were observed near these sampling locations. Samples SED-4 and SED-5 were collected below the base of two outfall pipes that were observed down slope of Building #2. These two outfall pipes were also shown on MADEP’s 1998 sediment sample location plan and our sampling locations generally correspond to MADEP’s sample locations PR-3 and PR-4, respectively (see Appendix B for reference). Moderate flow was observed discharging from both outfall pipes. A red-brown leachate was also observed seeping from the river bank at a location approximately 40 feet upstream of SED4. Sample SED-6 was collected slightly downstream of sample SED-5 at a location immediately below the former IRA soil excavation to the east of Building #2. Notable conditions were not observed at this sampling location. Sample SED-7 was collected downstream of sample SED-6 at a location east of former Building #1. No notable conditions were observed at this sampling location. Sediment sample SED-8 was collected on the downstream portion of the site, near the bridge crossing for Cole Avenue. No notable conditions were observed at this sampling location.

Each of the eight sediment samples was submitted for laboratory analysis of cadmium and silver. Also as part of this event, surface water samples SW-4, SW-5, and SW-6 were collected from sediment sample locations SED-1, SED-6, and SED-8, respectively. The three

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surface water samples were submitted for laboratory analysis of EPH and total cadmium and total silver.

3.5 Laboratory Results
The soil, groundwater, sediment and surface water samples collected during our supplemental Phase II investigations were submitted to Con-Test Analytical Laboratory (Con-Test) of East Longmeadow, Massachusetts. Laboratory reports are provided in Appendix E.

3.5.1 Soil Results
Soil results for the 24 soil samples submitted for laboratory analysis as part of our supplemental Phase II investigations are summarized in Table 3-3 provided in Appendix C. Within the table, soil results are compared to Method 1 standards. Also for reference, soil results are compared to MADEP’s identified background levels in soils containing coal, coal ash or wood ash associated with fill material. As shown, EPH was not detected above Method 1 standards in any of the five samples submitted for EPH analysis. In three of the samples, EPH carbon ranges and the target PAHs were not detected above laboratory reporting limits. In seven of the 20 samples submitted for metals analysis, cadmium was detected above the S-1 standard of 2 mg/kg. In general, those seven samples were collected from southeastern and eastern portions of the site in the general vicinity of the earlier IRA excavations of metals-impacted soils. In those samples, cadmium concentrations ranged between 2.1 mg/kg and 28 mg/kg (i.e., lower than the previous standard of 30 mg/kg prior to the “Wave 2” changes to the MCP). Cadmium was not detected above 2 mg/kg in soil samples collected from the northern portions of the site (including within the footprint of former Building #1) or in areas to the west and northwest of Building #2. In boring sample B-117 (4-8’), silver was detected at the Method 1 standard of 100 mg/kg. As shown on Figure 4, boring B-117 was advanced within the former IRA excavation for the metal-impacted soils in the former basin area adjacent to Building #2. Silver results for the other 19 soil samples were all below 100 mg/kg.

3.5.2 Groundwater Results
Groundwater results for the six groundwater samples submitted for laboratory analysis as part of our supplemental Phase II investigations are summarized in Table 3-4 provided in Appendix C. Within the table, groundwater results are compared to Method 1 standards. Table 3-4 also includes previous groundwater results for existing wells MW-1, MW-2B, and MW-3 for reference. As shown, EPH (including target PAHs) and dissolved cadmium and silver were not detected above laboratory reporting limits in any of the six groundwater samples.

3.5.3 Sediment Results
Analytical results for the eight sediment samples submitted for laboratory analysis as part of our supplemental Phase II investigations are summarized in Table 3-4 provided in Appendix C. Within the table, sediment results are compared to MADEP’s Revised Sediment Screening Values of January 2006 for reference.

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As shown, cadmium was detected above laboratory reporting limits in each of the sediment samples except SED-1, and cadmium concentrations were below MADEP’s screening value of 5 mg/kg. [Notre: Cadmium concentrations were also below Method 1 standard of 2 mg/kg.] These results are similar to MADEP’s earlier site findings from their 1998 investigation, as described earlier. Silver was detected at 10 mg/kg in sample SED-7. As indicated, there is no MADEP sediment value for silver, but this value is less than the Method 1 standard of 100 mg/kg. Silver was not detected above laboratory reporting limits in the other seven sediment samples.

3.5.4 Surface Water Results
Total cadmium and silver were not detected above laboratory reporting limits in the three surface samples. EPH carbon ranges and target PAHs were also not detected above laboratory reporting limits in the samples.

3.6 Discussion
In summary, the findings from previous site investigations and our supplemental Phase II investigations include the following:  Based on earlier site investigations conducted by others and Tighe & Bond, contaminants detected in site soils above Reportable Concentrations and/or Method 1 standards have been limited to cadmium, silver, and target PAHs. The impacts to site soils in the six areas where contaminated soil excavation occurred under IRA activities in 2003 have been delineated. In two of the former IRA excavation areas (including the former “Barn” area and the former abandoned 20,000-gallon No. 2 fuel oil UST area) the contaminants of concern (PAHs) were reduced to levels below Method 1 standards. In the “other” former 20,000-gallon fuel oil UST area, PAHs above Method 1 standards in soils remain, but those detections are attributed to the presence of coal, coal ash, and wood ash (all MCP-exempt), as well as coal tar (not MCP-exempt). In the three areas of concern where elevated cadmium and silver were detected in soils (i.e., in the two former basin areas and the former drum storage area), cadmium and silver concentrations remain above current Method 1 standards after the IRA excavations of 2003, when higher standards applied. In the metals-impacted soils in the former drum storage area on the southern portion of the site, asbestos containing debris is also present in the fill. Fill debris with potential ACM was not encountered in any other IRA excavation area or in any other test pit or drilling location across the site. Based on earlier site investigations and our supplemental Phase II investigations, no cadmium concentration above the Imminent Hazard threshold of 60 mg/kg is present in site soils within a depth of twelve inches below the ground surface. Cadmium concentrations above the current Method 1 standard of 2 mg/kg are fairly widespread in shallow soils across the south/southeastern portions of the site and in the areas of the two former wastewater treatment basins. However, cadmium was not detected above 2 mg/kg in soils across other portions of the site. Based on earlier site investigations conducted by others and Tighe & Bond, only one contaminant has historically been detected above Reportable Concentrations and/or Method 1 standards in site groundwater. In April 2003, one EPH carbon 3-6

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fraction was detected above GW-1 standards in one well location (TB-2B/MW-2B) located in the vicinity of former 20,000-gallon fuel oil UST. Subsequent sampling in July 2003 (after IRA excavation work) and during the supplemental Phase II investigations of 2012 indicate that EPH was not reported above laboratory reporting limits at that well location. In addition, EPH (including target PAHs) and dissolved cadmium and silver were not detected above laboratory reporting limits in site groundwater collected from wells across the site during these supplemental Phase II investigations.  During the site investigations conducted by MADEP in 1998, the concentrations of cadmium and PAHs detected in sediments upstream and downstream of the site release areas were fairly consistent, and those cadmium concentrations were below the MADEP’s Revised Sediment Screening Values of January 2006. Silver was not detected in MADEP’s sediment samples. During our supplemental Phase II investigations, cadmium was not detected in eight sediment samples, but silver was detected at 10 mg/kg in one downstream sediment sample. Consistent with the findings from MADEP’s site investigation of 1998, cadmium, silver and PAHs were not detected in surface water samples collected during our supplemental Phase II investigations.

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Section 4 Risk Characterization
KERA Environmental, LLC (KERA) prepared a MCP Method 3 Risk Characterization (310 CMR 40.0900) for the site. The soil, groundwater, and sediment data provided by Tighe & Bond were used in the Method 3 risk characterization, and site risks were evaluated assuming unrestricted activities and uses, current and future risk of harm to human health, safety, public welfare and the environment posed by release-related conditions. The complete Method 3 Risk Characterization report prepared by KERA is provided in Appendix F. As further stated in KERA’s separate report, cadmium, silver, EPH carbon fractions and target PAHs (except 2-methylnaphthalene) were carried through the risk characterization as compounds of concern (COC) in soil. No release-related compounds were detected in groundwater, thus groundwater was not considered a media of concern for this risk characterization. Further, there are no release-related volatiles associated with the site, therefore, vapor intrusion to indoor air was not considered a migration pathway of concern and thus no air or soil vapor samples were collected. Re-development of the site may involve construction excavation, residential use, recreational use, future landscaping and paved parking areas. Therefore, the exposure scenarios include construction and utility excavation, residential and recreational uses and trespassing. The site is located within the boundaries of a MADEP Wellhead Protection Area, however, groundwater data indicates that this drinking water resource has not been and will not be affected by the release related conditions at the site. Following a detailed exposure assessment, potential risks based on single-family residential, multi-family residential, construction workers, park visitors and trespassers who may experience contact with release-related compounds in surface and subsurface soil were quantitatively evaluated in accordance with protocols described in the MADEP Guidance for Disposal Site Risk Characterization (July 1995 and revisions). The remaining receptors, utility workers, landscapers and other visitors to the site were evaluated qualitatively based on the quantitative results and on assumptions of less intense, less frequent and shorter duration exposures. The site was considered according to potential areas of exposure. These areas were identified and are listed below, along with the corresponding soil COCs for each area:        Site-wide: The entire Disposal Site; metals and EPH Area 1: Former wastewater treatment basin adjacent to Building #2, metals (highest cadmium) Area 2: Former drum storage area; metals (second highest cadmium) Area 3: Former wastewater treatment basin south of Building #2; metals Area 4: Former 20,000 gal UST south of Building #2; metals and EPH (highest EPH) Area 5: Former 20,000 gal UST adjacent/west of Building #2; metals (lowest cadmium) and EPH Area 6: Former Barn area; EPH

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Area 7: Outside identified release areas; metals and EPH

For each area of exposure, an Exposure Point Concentration (EPC) was developed for each COC to reflect the maximum or the average concentration in soil. Averages were calculated for 0-3 feet below grade and 0-13 feet below grade, with the highest of these averages selected for the quantification of risk. Where applicable, half the reporting limit was applied in cases of COC non-detects. Each exposure scenario was then evaluated with a set of EPCs to identify worst-case conditions under which the scenario could occupy the site without risk of harm. EPCs were assigned to exposure scenarios according to the following arrangement:      Single-Family Residential: concentrations Area 5, cadmium, silver and EPH average

Multi-Family Residential: Area 1, cadmium and silver average concentrations; EPH Site Maximum concentrations Construction Workers: Area 2, cadmium and silver maximum concentrations; EPH Site Maximum concentrations Park Visitors: Area 2, cadmium and silver maximum concentrations; EPH Site Maximum concentrations Trespassers: Site Maximum concentrations, all COC

Risk at the site is driven by cadmium (predominantly through consumption of homegrown produce); therefore the maximum and average cadmium concentrations for an area were carefully considered in the final selection of EPCs for each quantitatively evaluated exposure scenario. As a conservative measure, although some areas did not include both metals and EPH, and since the cumulative effects of site maximum EPH concentrations did not present risk for some scenarios, EPH EPCs based on site maximum concentrations were included as COCs along with the metals. It should also be noted that the use of maximum concentrations for EPCs is considered highly conservative since it is unlikely that a receptor would dedicate his or her entire frequency and duration of exposure to the location of maximum COC concentration, especially for a site with no existing use patterns. For an undeveloped site, EPCs based on maximum averages provide the more realistic, though also conservative, exposure assumption. Conclusions for Human Health Cumulative cancer and non-cancer risks for each receptor were calculated as part of this risk assessment and are expressed as Excess Lifetime Cancer Risk (ELCR) and Hazard Index (HI) values, respectively. The ELCR and HI values were compared to applicable MassDEP risk criteria (1.0E-05 and 1, respectively) to evaluate cancer and non-cancer risk posed by the site. A condition of No Significant Risk exists if the HI is less than or equal to 1 for each receptor, and the ELCR is less than or equal to 1 in 100,000 (1E-05) for each receptor. These comparisons indicate that a condition of No Significant Risk does not exist for the single family residential scenario experiencing contact with soil by ingestion, dermal contact and consumption of homegrown produce, even with the lowest of EPCs (Area 5 averages).

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Quantitative evaluation of the multi-family residential scenario includes contact with soil COCs by soil ingestion and dermal contact only (i.e., no consumption of homegrown produce). This evaluation indicates that a condition of No Significant Risk exists for this scenario, assuming EPCs based on average concentrations from Area 1 (which includes the maximum average for cadmium). The condition of No Significant Risk holds even when this scenario is also subject to site maximum concentrations for EPHs (included in the results reported above). This is a conservative evaluation for this scenario since it assumes all exposure is localized in the area of worst-case metals and includes site maximum concentrations of EPH. A condition of No Significant Risk was found for construction workers assuming EPCs reflecting maximum cadmium and silver concentrations from Area 2, along with site maximum concentrations for EPH, and exposure by soil ingestion, dermal contact and inhalation of fugitive dust (particulate inhalation). The use of maximum cadmium and silver concentrations from Area 2 provides a conservative site evaluation for this scenario since these maximums are greater than the corresponding concentration averages for Area 1 (the area with the highest cadmium concentration). As with the construction worker scenario, a condition of No Significant Risk was found for park visitors (recreation scenario; soil ingestion and dermal contact) based on EPCs reflecting maximum cadmium and silver concentrations from Area 2, and site maximum concentrations for EPHs. A condition of No Significant Risk was also found for trespassers assuming EPCs based on site maximum concentrations for cadmium, silver and EPCs, and soil ingestion and dermal contact exposures. This is the most conservative site evaluation for this scenario. Conclusions for Safety, Public Welfare and the Environment No corrosive materials, drums, lagoons or other release-related conditions affecting the overall site safety remain at the site. However, Building #2 is vacant and access is not restricted. A condition of No Significant Risk of harm to safety exists at the site based on release-related conditions. The assessment concluded that no compounds are present at the site at levels that exceed the MADEP Upper Concentration Limits (UCLs), and no nuisance conditions (i.e., odors), loss of property value and restriction of the use of another person’s property due to the release are present at the site. Thus, a condition of No Significant Risk of harm to public welfare exists. Area mapping indicates that the Hoosic River abuts the site. An area of Priority Habitat of Rare Species is located in the vicinity of the site along the river. According to the conceptual site model, conditions in sediment and surface water adjacent to the site were found consistent with local conditions based on an investigation conducted by MADEP in 1998. However, a recent detection of silver (10 mg/kg; Sed-7) exceeds an available sediment quality benchmark (1 mg/kg) and a background soil concentration (5 mg/kg for fill material), which suggests that risk to the environment cannot be ruled out. There are no UCL exceedances. Comments and Recommendations 1. According to these findings, without significant remediation of soil at the site (primarily cadmium), single-family residential uses cannot be among the future plans of the Site. Revised Phase II CSA and Phase III RAP - RTN 1-11635 4-3

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2. Asbestos debris was reported in a buried drum found on the southern portion of the site (Area 2). That drum has been removed; however, asbestos containing debris (transite board) remains in fill soils in Area 2. Although results indicate that the site does not present a health risk to residents (based on multi-family use assumptions), construction workers, recreational users and trespassers, these evaluations do not account for exposure to asbestos containing debris. A condition of No Significant Risk cannot be assured without explicit evaluation of risk to asbestos, or unless subject asbestos is removed or contained to prevent contact by hypothetical residents, construction workers, park users and trespassers who may visit or occupy the site. 3. Silver detected in sediment at sample location SED-7 (10 mg/kg), exceeds an available sediment quality benchmark (1 mg/kg) and a background soil concentration for fill material (5 mg/kg) for fill material. This exceedance does not prove risk to the environment, however, because of its existence, risk to the environmental cannot be ruled out. Therefore, additional investigation into a potential source and the limits of distribution in sediment is recommended.

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Section 5 Phase III Remedial Action Plan
The MCP requires that the Phase III include the identification, evaluation and selection of one or more comprehensive Remedial Action Alternatives (RAAs) and includes a Remedial Action Plan (RAP) in accordance with 310 CMR 40.0861. The RAP includes a recommended remedial alternative that will achieve a level of No Significant Risk and constitute a Permanent or Temporary Solution for the site. Included in this plan is a determination of the feasibility of implementing the solution selected as a result of this process. A Permanent Solution means implementation of measures that attain a level of control such that no substance of concern will present a risk to health, safety, public welfare or the environment during any foreseeable period of time. A Temporary Solution means implementation of measures that eliminate any substantial hazard that is presented by oil and/or hazardous materials (OHM) at a disposal site until a Permanent Solution can be achieved.

5.1 Initial Screening of Remedial Action Alternatives
In this initial screening, remedial technologies typically utilized for the remediation of metals-impacted sites are reviewed. Groundwater at the site has not been impacted by the release and due to the non-volatile nature of the contaminants of concern, indoor air at the current or future buildings in not a concern. Consequently, RAAs considered for this initial screening focused on the remediation of metals in soil at the site. Due to the nature of the contaminants relatively few remedial options are available. RAAs considered for this initial screening consist of the following:   Soil excavation and off-site disposal Soil excavation, stabilization, and off-site disposal

In this section, each of the alternatives initially screened are evaluated for their potential feasibility at this site.

5.1.1 Soil Excavation and Off- Site Disposal
As discussed in previous sections of the report, the majority of the elevated levels of compounds of concern were identified within the upper four feet of site soils though in several areas the depth of contamination was less. Since the depth to groundwater across the majority of the site is between 10 and 14 feet below grade, dewatering would not be necessary during the excavation of these soils. (The depth to groundwater at well location MW-7 was just over 5 feet below grade.) The majority of the site is accessible to wheeled or track-mounted excavation equipment. Access to the impacted soils on the steep bank of the Hoosic River will have to be evaluated by contractors to determine the best approach to remove those soils below the rip rap. Due to the elevated concentrations of cadmium in several areas of the site a portion of site soils (if untreated) would need to be disposed as a hazardous waste. This RAA is considered a feasible remedial alternative for the site and, therefore will be retained for future consideration.

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5.1.2 Soil Excavation, Stabilization and Off Site Disposal
As discussed in the previous RAA, due to the elevated concentrations of cadmium at the site it is likely that at least a portion of excavated soils will have to be disposed as hazardous waste if they are not treated prior to transport off site. The goal of soil stabilization is to immobilize oil or hazardous materials in soils so that the compounds of concern are inaccessible to human and environmental receptors. Soil stabilization is accomplished by mixing contaminated soils with a material such as concrete or proprietary additives that decrease the leachability and availability of the hazardous materials. This technology has been utilized successfully for metals, polychlorinated biphenyls (PCBs) and polynuclear aromatic hydrocarbons (PAHs). The process is conducted ex-situ and would require the excavation of soils prior to stabilization. Once the process is complete, the stabilized mixture is either returned to the excavation or disposed off site as a non-hazardous waste. This RAA is considered a feasible remedial alternative for the site and, therefore, will be retained for future consideration.

5.2 Detailed Evaluation of Remedial Action Alternatives
Based on the initial screening of RAAs, both RAAs are considered feasible and were selected for further evaluation based on their technical viability for reducing contamination and potential feasibility for implementation.

5.2.1 Soil Excavation and Off Site Disposal
The excavation and off-site disposal of the contaminated soils without treatment would be the most expedient of the remedial alternatives. Based on the findings of the Phase II investigations, it is estimated that approximately 10,000 cubic yards of contaminated soils would need to be excavated in order to close-out the site without an Activity and Use Limitation (AUL). This volume estimate is based on the excavation of approximately two feet of soil across the majority of the site (excluding beneath the current site building). In practice, excavation in several areas of the site will be to greater depths based on the sampling data. Due to the presence of elevated concentrations of cadmium at least a portion, if not all of the site soils (if untreated) would need to be disposed as a hazardous waste. The estimated costs to perform soil excavation and to transport and dispose of the impacted soils as a hazardous waste is approximately $6,000,000. The costs are summarized in Table 5-1. Typically, confirmatory soil sampling is performed after the completion of soil excavation activities. If laboratory results indicate that EPCs for all site contaminants are below Method 1 Cleanup Standards for the most conservative S-1 soil category, then “unrestricted” future uses of the site can occur, and the site release can be closed out without the placement of an AUL. The estimated costs to perform confirmatory soil sampling and site closure without an AUL is approximately $7,000.

5.2.2 Soil Excavation, Stabilization, and Off Site Disposal
As indicated above, the use of soil stabilization would be an additional on-site treatment task used in conjunction with soil excavation. Therefore, the estimated volume of soil to be excavated would, again, be between approximately 10,000 cubic yards. The Revised Phase II CSA and Phase III RAP - RTN 1-11635 5-2

Section 5 Phase III Remedial Action Plan

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estimated cost to perform soil excavation and stabilization, and to transport and dispose of the impacted soils as a non-hazardous waste is approximately $1,900,000. As shown in Table 5-1, the total estimated cost for this remedial alternative is less than using soil excavation and off-site disposal of “untreated” soils as a hazardous waste.
Table 5-1 Cost Estimates for RAAs RAA Notice of Intent/Wetlands Permitting Excavation Contractor Stabilization of Soil, Transport & Landfill Disposal Hazardous Soil Transport & Disposal Backfill Confirmatory Sampling & Report Preparation AUL Preparation (if necessary) Totals

Soil Excavation and Off Site Disposal $10,000 $40,000 ‘-$6,000,000 $150,000 $7,000 $7,000 $6,214,000

Soil Excavation, Stabilization, and Off Site Disposal $10,000 $40,000 $1,875,000 ‘-$150,000 $7,000 $7,000 $2,089,000

5.3 Selection of Remedial Action Alternative
Based on the preceding evaluation of RAAs, soil excavation with stabilization and off site disposal was selected as the most effective means to remediate residual soil and groundwater contamination. It should be noted that an Activity and Use Limitation (AUL) could be used to reduce the amount of soil excavation required depending on the restrictions acceptable to the Town and/or future site owners.

5.4 Remedial Action Plan
The conclusions of the Method 3 risk characterization indicated that the primary risk at the site is for unrestricted residential development. In order to have unrestricted site use, extensive excavation would be required to achieve a Class A-1 or A-2 RAO. The approximate costs for that work are presented in Table 5-1 and discussed above. However, if the Town, or future site owner, decides to use the site for development of a housing complex where control of the site is retained by the site owner (such as a condominium or senior housing complex), an AUL could be utilized to restrict the growing of vegetables for human consumption across the site and restrict access to the southern portion of the property, where asbestos and the highest concentrations of cadmium were identified, without requiring removal of the impacted soils. The RAP for active site remediation is excavation of impacted soil, stabilization of the soil and off site disposal. Based on the costs for the work obtained through a competitive bidding process, limited soil excavation may be selected. (Please note that the estimates presented in Table 5-1 do not include the cost to prepare bidding documents.) If residual contamination remains at the site, an AUL will have to be implemented to restrict certain exposures and achieve a Permanent Solution. The goal of this remedial effort is to achieve a condition of No Significant Risk, or background conditions, if feasible, and a Permanent Solution for the site release, resulting in site conditions commensurate with those required for a Class A Response Revised Phase II CSA and Phase III RAP - RTN 1-11635 5-3

Section 5 Phase III Remedial Action Plan

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Action Outcome (RAO). Prior to moving to Phase IV, the potential redevelopment scenarios should be evaluated to select the best approach to meet the Town’s needs and achieve a Permanent Solution under the MCP.

Revised Phase II CSA and Phase III RAP - RTN 1-11635

5-4

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Section 6 Conclusions
On behalf of the Town of Williamstown, Tighe & Bond has prepared a Revised Phase II Comprehensive Site Assessment and Phase III Identification, Evaluation, and Selection of Comprehensive Response Action Alternatives for the former Photech site located at 330 Cole Avenue in Williamstown, Massachusetts. The site release is identified under RTN 1-11635. Previous response actions for the site have included assessment and cleanup activities performed by the EPA in 1997, with additional site investigations conducted by MADEP in 1998. Tighe & Bond completed site investigations and MCP response actions at the site between 2000 and 2004, with the Town serving as the Responsible Party (as a “Municipality with Exempt Status”). Those response actions included contaminated soil excavations in six identified areas of concern at the site under an IRA Plan, and a Phase II report submittal in October 2004. Since the last MCP submittal of October 2004, Tighe & Bond has conducted supplemental Phase II investigations to update site conditions and to further evaluate impacts to environmental media across the site in preparation for future site remediation (as needed) prior to redevelopment. Based on those findings and our previous investigations, we completed a side-wide Method 3 risk characterization for the site. In summary, a Condition of No Significant Risk does not exist at the site. A Condition of No Significant Risk does not exist for the single family residential scenario. In general, that risk is driven predominantly through consumption of homegrown produce. Under the multi-family residential scenario, a condition of No Significant Risk does exist subject to the restriction that there’s no consumption of homegrown produce. Due to the presence of one site contaminant detected in sediment along the abutting Hoosic River at a concentration above benchmark values, a risk to the environmental cannot be ruled out without additional investigation into a potential source and the limits of distribution in sediment. In order to have unrestricted site use, extensive excavation would be required to achieve a Permanent Solution under a Class A-1 or A-2 Response Action Outcome (RAO). However, other future site uses would require minimal or no site remediation other than the placement of an AUL (that restricts the growing of produce for consumption and single-family residences) on the site. Lastly, prior to site closure, further evaluation of potential risk to the environment is required.

6.1 Public Notification
In accordance with the Public Notification Procedures of the Massachusetts Contingency Plan, 310 CMR 40.1403, a public notification letter has been sent to the Williamstown Town Manager and Board of Health regarding this submittal. A copy of that public notification letter is included in Appendix F. MADEP transmittal form BWSC 108 was submitted through eDEP.

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Revised Phase II CSA and Phase III RAP - RTN 1-11635

6-1

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Section 7 Regulatory Limitations
Each report and any and all work product provided in connection with the performance of each environmental site assessment is subject to the following conditions: 1. Each report is prepared on behalf of and for the exclusive use of Town of Williamstown (Client) and is subject to and issued in accordance with the Agreement and the provisions thereof. Each report and any findings contained therein shall not, in whole or in part, be provided to or used by any other person, firm, entity or governmental agency in whole or in part, without the prior written consent of Client and Tighe & Bond. However, Tighe & Bond acknowledges and agrees that, subject to the Limitations set forth herein and prior written approval by Tighe & Bond, a report may be provided to specific financial institutions, attorneys, title insurers, lessees and/or governmental agencies identified by Client at or about the time of issuance of a report in connection with the conveyance, mortgaging, leasing, or similar transaction involving the real property which is the subject matter of a report and any work product. Use of a report for any purpose by any persons, firm, entity, or governmental agency shall be deemed acceptance of the restrictions and conditions contained therein, these Limitations and the provisions of Tighe & Bond’s Agreement with Client. No warranty, express or implied, is made by way of Tighe & Bond’s performance of services or providing an environmental site assessment, including but not limited to any warranty with the contents of a report or with any and all work product. 2. In preparing a report, Tighe & Bond, Inc. may rely on certain information provided by governmental agencies or personnel as well as information and/or representations provided by other persons, firms, or entities, and on information in the files of governmental agencies made available to Tighe & Bond at the time of the site assessment. To the extent that such information, representations, or files may be inaccurate, missing, incomplete or not provided to Tighe & Bond, Tighe & Bond is not responsible. Although there may be some degree of overlap in the information provided by these various sources, Tighe & Bond does not assume responsibility for independently verifying the accuracy, authenticity, or completeness of any and all information reviewed by or received from others during the course of the site assessment. 3. No attempt is made to assess the compliance status of any past or present Owner or Operator of a site with any Federal, state, or local laws or regulations, unless specifically indicated otherwise in writing. 4. Tighe & Bond does not assume responsibility for the impacts of any changes in environmental standards, practices, or regulations subsequent to the preparation of each report. 5. If additional environmental or other relevant information is developed at a later date, Client agrees to bring such information to the attention of Tighe & Bond promptly. Upon evaluation of such information, Tighe & Bond reserves the right to recommend modification of this report and its conclusions.

7-1

Section 7 Regulatory Limitations

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6. Chemical constituents that are not the subject of this investigation and which are not included in the list of analyzed parameters for a study may be present in soil and/or ground water at a site, and Tighe & Bond assumes no responsibility therefore. 7. If included, any database search is conducted under the Notice of Disclaimer/Waiver of Liability included in the database search report.

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APPENDIX A

SITE LOCATION

1:25,000
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Based on USGS Topographic Map for Williamstown, MA Quadrangle. Revised 1988 Circles indicate 500-foot and half-mile radii
G:\GIS\MA\SiteLocus\Williamstown\topo_ColeAve.mxd Date Saved: 7/27/2012 User: scs

FIGURE 1 SITE LOCUS MAP
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Former Photech Facility 330 Cole Avenue Williamstown, Massachusetts
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SITE LOCATION

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CHENAILLE TERRACE

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THE SPRUCES MOBILE HOME PARK

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Green River

NHESP Certified Vernal Pools

Community Public Water Supply - Surface Water Community Public Water Supply - Groundwater Non-Community Transient Public Water Supply Non-Community Non-Transient Public Water Supply Non-Potential Drinking Water Source Area - High Yield Potentially Productive Medium Yield Aquifer Potentially Productive High Yield Aquifer EPA Designated Sole Source Aquifer

Public Surface Water Supply (PSWS) Inland Wetlands (MA DEP) Waterbodies Coastal Wetlands (MA DEP) Major Drainage Basin Sub Drainage Basin Limited Access Highway Multi-Lane Highway, NOT Limited Access Other Numbered Highway Major Road - Collector Minor Street or Road Town Boundary County Boundary Track or Trail Train Powerline Pipeline Aquaduct

FIGURE 2 PRIORITY RESOURCE MAP
Former Photech Facility ro ok 330 Cole Avenue Williamstown, Massachusetts
am illi
sB

Non-Potential Drinking Water Source Area - Medium Yield

DEP Approved Wellhead Protection Area (Zone II) DEP Interim Wellhead Protection Area (IWPA) NHESP Priority Habitats for Rare Species NHESP Estimated Habitats for Rare Wildlife Protected and Recreational Open Space Solid Waste Landfill

Quad Sheet Boundary

July 2012
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0 Feet 2,000

Public Surface Water Supply Protection Area (Zone A) Area of Critical Environmental Concern (ACEC)

Data source: Office of Geographic and Environmental Information (MassGIS), Commonwealth of Massachusetts Executive Office of Environmental Affairs. Circles indicate 500-foot and half-mile radii. Data valid as of June 2012. W-0987

G:\GIS\MA\SiteLocus\Williamstown\MassGIS_ColeAve.mxd Date Saved: 7/27/2012

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CHANTILLY AV ENUE

GA LE ROAD

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W unt

FIGURE 3 ORTHOPHOTOGRAPH SITE PLAN
LE G E ND

GPS Point
Boring

Approximate Property Boundary

Monitoring Well Manhole
SED -8 /SW-6

HOOS IC
B-121 SED-7 SW-5/SED-6 B-120 B-129 MW-5/B-103A B-118 B-119 B-103 OUTFALL/SED-5

Outfall

B-122 MW-4/B-101

RIVER

SED/SW SED

OUTFALL/SED-4 SED-3

B-123

B-128 B-117 MW-3 B-105

B-102

B-127 MW-2B B-116 B-126 B-115

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L O C U S MA P

SED-1/SW-4 B-114 B-125

MW-1

MW-6

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B-124 MW-7/B-107 B-108 B-106 B-109 B-113 B-110 B-111
0 30 Feet 60

G:\GIS\MA\SiteLocus\Williamstown\siteplan_ColeAve.mxd Date Saved: 8/7/2012

COLE AVENUE

NOTE S
Based on MassGIS Color Orthophotography (April 2009) Orthophoto Sheet ID # 61739425

B-112

Former Photech Facility 330 Cole Avenue Williamstown, Massachusetts
August 2012

User: scs

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FIGURE 5 GROUNDWATER CONTOUR PLAN
LE G E ND

GPS Point

Approximate Property Boundary Monitoring Well Manhole Groundwater Elevation Measured on 7/26/2012

(88.75)

HOOS IC
MW-4/B-101 (87.81)

RIVER

88 90 92 94

MW-5/B-103A (88.57)

MW-3 (90.43)

MW-2B (89.47)

L O C U S MA P

MW-1 (89.61)

MW-6 (88.75)

96
MW-7/B-107 (98.00)
0

1":60'
30 Feet 60

G:\GIS\MA\SiteLocus\Williamstown\groundwater_ColeAve.mxd Date Saved: 8/20/2012

COLE AVENUE

NOTE S
Based on MassGIS Color Orthophotography (April 2009) Orthophoto Sheet ID # 61739425

Former Photech Facility 330 Cole Avenue Williamstown, Massachusetts
August 2012

User: scs

W-0987

APPENDIX B

APPENDIX C

TABLE 2-1 Summary of Initial Phase I Soil Results(1) Tighe & Bond's Earlier Investigations Former Photech Facility, Williamstown, MA MCP Method 1 Analysis VOCs (Method 8260) All analytes Metals(2) Lead EPH w/target PAHs C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics Acenaphthene Anenaphthylene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2-Methylnaphthalene Naphthalene Phenanthrene Pyrene 1,000 3,000 1,000 4 1 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 0.7 4 10 1,000 1,000 3,000 1,000 1,000 600 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 80 40 500 1,000 1,000 3,000 1,000 1,000 10 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 300 500 500 1,000 2 1 4 9 7 8 3 4 7 1 10 2 3 1 1 20 20 ND(3.9) ND(3.9) 17 ND(0.4) ND(0.4) 0.44 0.61 0.41 0.57 ND(0.4) ND(0.4) 0.63 ND(0.4) 1.9 ND(0.4) ND(0.4) ND(0.4) ND(0.4) 1.6 1.4 ND(3.9) 7.9 37 ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) 0.42 ND(0.4) ND(0.4) 2.2 ND(0.4) ND(0.4) ND(0.4) ND(0.4) 0.67 0.86 300 300 300 600 88 6.7 24 21 8.1 6.4 20 7.6 80 12 17 12 ND S-1/GW-1 S-1/GW-2 S-1/GW-3 MADEP Background Levels in Soils Containing Fill(3) Sample Location: Depth (feet): Date Collected: 0 to 0.5 8/8/00 TB-1 0.5 to 3 8/8/00 0 to 0.5 8/8/00 TB-2A 0.5 to 3 8/8/00 0 to 3 8/8/00 B-1 0.5 to 3 8/8/00 0 to 0.5 8/8/00 B-2 0.5 to 3 8/8/00 B-3 0.5 to 3 8/8/00 0 to 0.5 8/8/00 B-4 0.5 to 3 8/8/00 0 to 3 8/8/00 0 to 0.5 8/8/00 B-5 0.5 to 3 8/8/00

NOTES: (1) Soil results from Tighe & Bond's Phase I investigations that were ultimately removed during subsequent IRA activities are not included in this summary table. (2) Cadmium and silver results are not reported in this summary table (see Table 2-3).
(3)

MADEP identified background levels in soils containing coal ash or wood ash associated with fill material, as referenced in MADEP's Technical Update to Section 2.3 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard (effective December 14, 2007).

ND indicates that the contaminant was not detected above the laboratory reporting limit indicated.

Page 1 of 2

Table 2-1_Phase I Soil Results.xls

TABLE 2-1 Summary of Initial Phase I Soil Results(1) Tighe & Bond's Earlier Investigations Former Photech Facility, Williamstown, MA MCP Method 1 Analysis VOCs (Method 8260) All analytes Metals(2) Lead EPH w/target PAHs C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics Acenaphthene Anenaphthylene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2-Methylnaphthalene Naphthalene Phenanthrene Pyrene 1,000 3,000 1,000 4 1 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 0.7 4 10 1,000 1,000 3,000 1,000 1,000 600 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 80 40 500 1,000 1,000 3,000 1,000 1,000 10 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 300 500 500 1,000 2 1 4 9 7 8 3 4 7 1 10 2 3 1 1 20 20 ND(3.8) 30 17 ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) ND(0.4) 300 300 300 600 46 34 32 8.6 S-1/GW-1 S-1/GW-2 S-1/GW-3 MADEP Background Levels in Soils Containing Fill(3) Sample Location: Depth (feet): Date Collected: 0 to 0.5 8/8/00 B-6 0.5 to 3 8/8/00 B-7 0.5 to 3 8/8/00 B-8 0 to 0.1 8/25/00 SS-GEN 0 to 0.5 8/14/00

NOTES: (1) Soil results from Tighe & Bond's Phase I investigations that were ultimately removed during subsequent IRA activities are not included in this summary table. (2) Cadmium and silver results are not reported in this summary table (see Table 2-3).
(3)

MADEP identified background levels in soils containing coal ash or wood ash associated with fill material, as referenced in MADEP's Technical Update to Section 2.3 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard (effective December 14, 2007).

ND indicates that the contaminant was not detected above the laboratory reporting limit indicated.

Page 2 of 2

Table 2-1_Phase I Soil Results.xls

TABLE 2-2 Summary of Historical Cadmium and Silver Results in Soils (1) Tighe & Bond's Earlier Investigations Former Photech Facility, Williamstown, MA (Results in mg/kg) General Sample Depth Interval (2) Sample Sample Location TB-1 TB-2A B-1 B-1B B-2 B-3 B-4 B-5 B-6 B-7 B-8 B-7.1 B-7.2 B-7.3 B-7.4 B-7A B-7B B-7C B-7D B-7E B-7F B-7G B-7GH B-7H B-7I B-7.4I B-8 B-9A B-9B B-9C B-9D B-9CD B-10 B-10A B-10B B-10C B-11 B-12 B-13 B-14 B-15 B-16 B-16A B-16B B-17 B-18 B-19 B-20 B-20A B-20B B-22 B-22A B-22B B-22C B-22D B-22E B-23 B-24 B-24A B-24B B-24C B-24D B-25 B-26 B-26B B-26C B-27 B-27A B-27B B-27C(3) B-28 B-29 B-30A(4) B-32 B-33(5) B-34 S-bkgrnd1 S-bkgrnd2 S-bkgrnd3
Notes
(1)

0-0.5' Cadmium 0.91 1.4 (Excavated) (Excavated) 0.49 1.2 1.2 2.5 (Excavated) 0.83 ND(0.593) 4.66 2.19 28.0 1.56 2.16 9.16 0.969 1.90 2.61 1.89 0.695 1.09 0.83 (Excavated) 0.971 1.26 2.05 1.86 2.29 3.06 2.68 ND(0.59) (Excavated) 1.61 1.81 3.32 28.1 1.25 (Excavated) 0.735 ND(0.581) 2.84 7.3 0.881 1.07 3.16 12.2 3.21 7.17 13.1 ND(3.13) ND(2.91) 23.2 29.5 7.83 30.8 36.3 75.6 16.7 29.2 48.3 (Excavated) 44.6 18.6 31.1 12 8.8 14.6 16.7 50.4 36.7 29.8 6.72 51.6 4.7 7.2 ND(2.96) 83.9 230 317 21.8 44.7 59.8 15.3 38.0 44.5 36.7 8.59 16.7 7.2 ND(1) 12 31 38 (Excavated) Silver 2.4 11 Cadmium ND(0.2) 0.72 0.48 4.17 0.8 3.9 0.61 0.8 2 2.7 7.64 42.5 5.1 2.82 2.70 15.5 27.90 3.29 0.35 0.409 0.476 25.9 6.88 1.37 1.22 0.87 ND(0.59) 1.68 0.934 <0.63 0.779

0.5-3' Silver ND(1) ND(1) ND(1) 4.28 ND(1) 9 ND(1) ND(1) 18 38 127 279 165 87.2 46.3 239 233 124 ND(3.13) ND(3.23) 121 249 19.5 24.3 28.7 9.76 38.6 43.5 46.6 3.28 5.94 ND(3.18) 80.0 19.9 ND(3.15) ND(3.24) 18.3 (Excavated) 24.5 2.68 5.06 3.25 1.16 8.7 5.1 33.2 2.7 23.4 33.2 52 4.07 3.55 143 51.5 ND(3.33) ND(3.1) ND(3.09) 0.762 0.662 199 11.4 103 2.8 127 57.6 3.97 69.9 21.6 49.1 ND(3.2) 15.8 328 4.69 ND(3.29) 25.1 34.5 (Excavated) 2.35 0.655 0.595 1.19 0.425 9.58 32.8 ND(0.39) ND(0.34) ND(0.34) 0.58 ND(1.31) 9.28 0.341 6.41 48.3 Cadmium

3-6' Silver

Date 8/8/00 8/8/00 8/8/00 6/19/03 8/8/00 8/8/00 8/8/00 8/8/00 8/8/00 8/8/00 8/25/00 6/13/03 6/13/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 7/31/03 8/25/00 6/18 & 7/31/03 6/18/03 7/31/03 7/31/03 7/31/03 5/28/03 6/9/03 6/9/03 6/9/03 4/28/03 4/28/03 4/28/03 4/28/03 4/28/03 4/28/03 6/19/03 6/18/03 4/28/03 4/28/03 4/28/03 4/28/03 6/9/03 6/9/03 4/28/03 6/5/03 6/5/03 6/5/03 6/6/03 6/6/03 4/28/03 4/28/03 6/4/03 6/4/03 6/4/03 6/4/03 4/28/03 4/28/03 6/19/03 6/19/03 4/28/03 4/28/03 6/17/03 6/17 & 7/25/03 5/14/03 5/14/03 6/19 & 7/25/03 6/2/03 6/2 & 6/9/03 06/09/03 07/31/03 07/31/03 07/31/03

63.7 7.73 4.63 284 ND(1.35) 142 1460 ND(3.9) ND(3.38) ND(3.38) 11 ND(6.56) 44.5 ND(1.21) 138 82.3 -

(Excavated) ND(0.637) 1.88 0.754 ND(0.63) ND(0.648) 0.753 -

(Excavated)

(Excavated)

(Excavated) (Excavated) (Excavated) (Excavated) (Excavated) 10.5 25.1 (Excavated) (Excavated) 3.26 2.63 4.55 54.7 16.4 ND(0.33) ND(0.31) ND(0.31) (Excavated)

Cadmium and silver results from Tighe & Bond's earlier investigations that were ultimately removed during subsequent IRA activities are not included in this summary table. Soil samples were collected from a specific depth (e.g., 2.5 feet) or a depth range (e.g., 1 to 3 feet) within these intervals. Sample B-27C collected from 2 feet below grade on 6/17/03 was re-analyzed on two separate occasions and, as a conservative measure, the results reported in this summary table are the highest of the three analyses for each metal. Sample B-27C (3.5) was collected from 3.5 feet below grade on 7/25/03. Sample B-30A collected from 3 feet below grade on 6/19/03 was re-analyzed and, as a conservative measure, the results reported are the highest of the two analyses for each metal. Sample B-30A (5) was collected from 5 feet below grade on 7/25/03. Sample B-33 (6) collected from 0-0.5 feet below grade on 6/2/03 was re-sampled on 6/09/03 and, as a conservative measure, the results reported are the highest of the two analyses for each metal. Sample B-33 (1-1.5) was collected from 1 to 1.5 feet below grade on 6/09/03. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard of 2 mg/kg for cadmium or 100 mg/kg for silver.

(2) (3)

(4)

(5)

ND indicates that the analyte was not detected above the referenced laboratory reporting limit.

TABLE 2-3 Summary of Historical Groundwater Results Tighe & Bond's Earlier Investigations Former Photech Facility, Williamstown, MA (Results in µg/L) Method 1 Standards Analysis Metals (Dissolved) Cadmium Lead Silver EPH w/target PAHs
(2) (1)

Monitoring Well: Date Sampled:

TB-1 8/14/2000 2.2 <10 <5 <10 <1

TB-3 8/14/2000 <1 <10 <5 <120 <120 <120 <1.0 <1.0 <0.2 <1.0 <1.0 <1.0 <1.0 <1.0 36 0.98J

MW-2 8/25/2000 <1 <10 <5 <10 <1 8/14/2000 <1 <10 <5 <130 <130 <130 <1.0 <1.0 0.2 <1.0 1.3 <1.0 <1.0 <1.0 <10 <1

TB-2B/MW-2B 4/28/2003 146 194 223 2.0 0.8 <0.2 2.0 <1.0 1.0 1.42 2.0 7/31/2003 <100 <100 <100 <1 <0.3 <0.2 <1 <1 <1 <0.2 <1 8/14/2000 <1 <10 <5 110 130 120 1.4 <1.0 <0.2 <1.0 5.9 <1.0 2.9 5.0 <10 <1

TB-4/MW-1 10/19/2000 <100 <100 <100 <1.0 <1.0 <0.2 <1.0 <1.0 <1.0 <1.0 <1.0 7/31/2003 <100 <100 <100 <1 <0.3 <0.2 <1 <1 <1 <0.2 <1 -

MW-3 7/31/2003 <100 <100 <100 <1 <0.3 <0.2 <1 <1 <1 <0.2 <1 -

GW-1 5 15 100 700 14,000 200 20 1 0.2 2 90 140 40 80 6,300 1,000

GW-2 NA NA NA 5,000 NA 50,000 NA NA NA NA NA 1,000 NA NA 50,000 50,000

GW-3 4 10 7 50,000 50,000 5,000 6,000 1,000 500 70 200 20,000 10,000 20 50,000 40,000

C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics Acenaphthene Benzo(a)anthracene Benzo(a)pyrene Chrysene Fluoranthene Naphthalene Phenanthrene Pyrene VOCs
(2)

Acetone Toluene
NOTES:
(1) (2)

Samples submitted for analysis of cadmium, lead, and silver, only.

Only analytes detected above laboratory detection limits in one or more groundwater samples are included in table.
Boxed value indicates concentration in groundwater exceeds Method 1 standard.

< indicates not detected above the referenced laboratory reporting limit. NA indicates not applicable in accordance with the MCP.

TABLE 2-4
Summary of Historical Petroleum Compound Results in Soils for IRA Excavation Areas(1) Tighe & Bond's Earlier Investigations Former Photech Facility, Williamstown, MA (Results in mg/kg) MADEP Background Levels in Soils Containing Fill(1) 2 1 4 9 7 8 3 4 7 1 10 2 3 1 1 20 20 Sample Area: Sample Location: Depth (feet): Date Collected: B-21 North Side Wall 0-7' 6/10/2003 <3.6 32.8 99.3 1.49 <0.36 2.41 4.58 3.62 2.81 2.07 2.73 4.29 2.38 11.0 1.12 0.38 <0.36 0.56 12.3 11.8 7-11' 6/16/2003 33.1 352 312 0.94 1.24 2.31 4.49 1.97 1.31 0.82 1.84 4.90 0.81 6.28 1.16 1.01 <0.50 <0.50 5.60 8.83 B-21 West Side Wall 0-7' 6/10/2003 <4.2 25.7 25.5 <0.42 <0.42 <0.42 0.57 0.45 <0.42 <0.42 <0.42 0.57 <0.42 1.18 <0.42 <0.42 <0.42 <0.42 0.81 0.81 7-11' 6/16/2003 34.2 453 345 0.67 0.96 1.50 3.16 1.28 0.93 <0.50 1.40 3.51 0.62 4.70 0.81 1.15 <0.50 <0.50 2.46 7.02 B-21 East Side Wall 0-7' 6/10/2003 <3.8 21.1 93.6 1.09 <0.38 2.74 5.48 4.38 3.14 2.60 3.66 4.93 3.21 12.4 1.13 0.61 <0.38 0.46 12.8 13.5 7-11' 6/16/2003 37.6 406 322 <0.47 1.23 1.31 3.95 2.37 1.53 0.83 1.99 4.40 0.99 5.00 <0.47 1.31 <0.47 <0.47 1.86 7.45 B-21 South Side Wall 0-7' 6/10/2003 <3.7 46.3 38.6 <0.37 <0.37 <0.37 0.57 0.46 <0.37 <0.37 0.42 0.53 <0.37 1.17 <0.37 <0.37 <0.37 <0.37 0.87 1.20 7-11' 6/16/2003 19.8 252 142 <0.46 <0.46 0.59 1.72 1.11 0.80 0.57 0.99 1.83 0.59 2.75 <0.46 2.00 <0.46 <0.46 1.57 2.88 B-21 Bottom 11.5 6/6/2003 <4.12 ----------------------------------------1-5' 6/16/2003 6.9 39.6 32.4 <0.39 <0.39 <0.39 0.64 <0.39 <0.39 <0.39 0.41 0.65 <0.39 1.21 <0.39 <0.39 <0.39 <0.39 0.97 1.06 9.8 19.4 29.6 <0.41 <0.41 <0.41 <0.41 0.43 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 <0.41 General Area of Former 20,000-gallon fuel oil UST Basin TP 7-11' 1-3' 7/25/2003 <3.6 37.9 44.8 <0.36 <0.36 <0.36 0.85 0.67 1.07 <0.36 0.42 1.00 <0.36 2.02 <0.36 <0.36 <0.36 <0.36 1.47 2.26 13.8 204 233 <0.53 <0.53 0.55 0.81 1.37 1.60 3.29 0.63 1.50 <0.53 1.29 <0.53 <0.53 <0.53 <0.53 0.79 1.43 B-21 A 7-11' 0.5-2' 7/25/2003 <3.4 14.1 46.0 <0.34 <0.34 0.58 1.56 1.32 1.92 <0.34 0.48 1.73 <0.34 3.18 <0.34 <0.34 <0.34 <0.34 1.46 3.48 22.6 355 423 <0.52 1.01 1.46 2.22 2.38 3.18 1.30 0.72 4.84 <0.52 4.68 0.93 0.58 <0.52 <0.52 1.53 7.58 B-21B 8-11' B-21C 0.5-2' 7/25/2003 <3.4 23.2 64.6 <0.34 <0.34 <0.34 <0.34 <0.34 <0.34 <0.34 <0.34 <0.34 <0.34 0.49 <0.34 <0.34 <0.34 <0.34 <0.34 0.42 1-7' 7/25/2003 <3.8 133 176 1.41 <0.38 2.54 2.87 1.84 2.02 <0.38 1.40 3.16 <0.38 6.80 1.53 0.63 <0.38 <0.38 8.09 7.85 17.3 250 251 <0.50 <0.50 0.92 1.05 1.17 0.96 <0.50 0.70 2.49 <0.50 2.19 <0.50 <0.50 <0.50 <0.50 1.12 3.10 B-21E 8-11' 0.5-7' 7/25/2003 6.3 23.2 35.8 <0.36 <0.36 <0.36 0.65 0.52 0.81 <0.36 <0.36 0.72 <0.36 1.68 <0.36 <0.36 <0.36 <0.36 1.38 1.52 8.8 110 131 <0.48 <0.48 <0.48 0.99 1.27 1.05 7.28 <0.48 1.76 <0.48 1.55 <0.48 <0.48 <0.48 <0.48 0.69 2.21 B-21G 8-11' B-21H 8-11' 7/25/2003 <4.0 <4.0 <4.0 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 <0.40 B-21K 8-11' 7/25/2003 21.0 285 263 <0.51 0.97 0.98 1.56 1.35 1.70 1.11 0.64 3.05 <0.51 2.80 0.88 <0.51 <0.51 <0.51 0.97 4.68

MCP Method 1 Analysis TPH Total Petroleum Hydrocarbons EPH w/target PAHs C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics Acenaphthene Acenaphthylene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2-Methylnaphthalene Naphthalene Phenanthrene Pyrene
NOTES:
(1)

S-1/GW-1 1,000 1,000 3,000 1,000 4 1 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 0.7 4 10 1,000

S-1/GW-2 1,000 1,000 3,000 1,000 1,000 600 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 80 40 500 1,000

S-1/GW-3 1,000 1,000 3,000 1,000 1,000 10 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 300 500 500 1,000

Soil results from Tighe & Bond's earlier investigations that were ultimately removed during subsequent IRA activities are not included in this summary table. MADEP identified background levels in soils containing coal ash or wood ash associated with fill material, as referenced in MADEP's Technical Update to Section 2.3 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard (effective December 14, 2007).

(2)

ND indicates that the contaminant was not detected above the laboratory reporting limit indicated. indicates sample not analyzed for respective analyte.

page 1 of 2

Table 2-4_Historical Petroleum_page 1.xlsx

TABLE 2-4
Summary of Historical Petroleum Compound Results in Soils for IRA Excavation Areas Tighe & Bond's Earlier Investigations Former Photech Facility, Williamstown, MA (Results in mg/kg) Sample Area: MCP Method 1 Analysis TPH Total Petroleum Hydrocarbons EPH w/target PAHs C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics Acenaphthene Acenaphthylene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2-Methylnaphthalene Naphthalene Phenanthrene Pyrene 1,000 3,000 1,000 4 1 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 0.7 4 10 1,000 1,000 3,000 1,000 1,000 600 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 80 40 500 1,000 1,000 3,000 1,000 1,000 10 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 300 500 500 1,000 2 1 4 9 7 8 3 4 7 1 10 2 3 1 1 20 20 <4.0 12.8 37.5 <0.40 <0.40 <0.40 0.89 0.73 0.81 0.67 1.24 1.52 <0.40 2.01 <0.40 <0.40 <0.40 <0.40 1.43 1.68 <4.2 <4.2 <4.2 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <4.3 <4.3 <4.3 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <0.43 <3.9 <3.9 <3.9 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <0.39 <4.2 <4.2 <4.2 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 <0.42 1,000 1,000 1,000 S-1/GW-1 S-1/GW-2 S-1/GW-3 MADEP Background Levels in Soils Containing Fill(2) Sample Location: Depth (feet): Date Collected: Former "Barn" Building Area Barn B-2 0-0.5' 6/4/2003 14' 6/12/2003 Abandoned 20,000-gallon fuel oil UST (removed) TB-3 Bot-2 TB-3 NW-2 10-12.5' 6/12/2003 TB-3 SW-4 6-9' 6/12/2003 TB-3 EW-3 6-9' 6/12/2003
(1)

NOTES: (1) Soil results from Tighe & Bond's earlier investigations that were ultimately removed during subsequent IRA activities are not included in this summary table.
(2)

MADEP identified background levels in soils containing coal ash or wood ash associated with fill material, as referenced in MADEP's Technical Update to Section 2.3 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard (effective December 14, 2007).

< indicates that the contaminant was not detected above the laboratory reporting limit indicated. indicates sample not analyzed for respective analyte.

page 2 of 2

Table 2-4_Historical Petroleum_page 2.xlsx

TABLE 3-1 Summary of Soil Borings Supplemental Phase II Investigations Former Photech Facility, Williamstown, MA Boring ID Depth General Description

(Borings B-101 through B-107 - see Boring Logs in Appendix D for descriptions) B-108 B-109 B-110 B-111 B-112 B-113 B-114 0-2' 2'-4' 0-2' 2'-4' 0-2' 2'-4' 0-2' 2'-8' 0-4' 4'-8' 0-4' 0-2' 2'-4' 4'-8' B-115 B-116 B-117 0-2' 2'-4' 0-2' 2'-4' 0-2' 2'-4' 4'-8' B-118 B-119 B-120 B-121 B-122 B-123 B-124 0-4' 0-2' 2'-4' 0-2' 2'-4' 0-8' 0-4' 4'-8' 0-2' 2'-4' 0-2' 2'-4' 4'-8' 0-4" asphalt then fine-medium sand, some very fine sand Silt, little very fine sand Top soil and fine to very fine sand Very fine to fine sand, little medium to course sand Top soil, then very fine sand with coal ash, little brick Very fine sand and coal ash, brick Top soil then very fine to medium sand, some course sand Very fine to fine sand Very fine to fine sand, some course sand, little brick Very fine sand and silt Very fine to fine sand, little course sand Very fine to fine sand, some medium-course sand, little brick Very fine to fine sand, some medium-course sand Fine to very fine sand and silt, little medium sand Very fine to fine sand, little course sand Very fine to fine sand, little course sand with ash and brick Fine sand Fine sand with brick Fine sand some medium sand Fine to very fine sand and gravel Fine sand and gravel, some brick, little ash Fine sand, brick, and concrete Very fine to fine sand Very fine sand and brick Very find sand, little medium to course sand Fine sand and brick Fine sand Fine sand Fine sand, little medium to course sand Very fine sand, wood, little brick Very find sand and gravel, brick Fine to very fine sand and gravel 2" grey soil with petroleum odor followed by fine to very fine sand, gravel Fine sand

TABLE 3-2 Summary of Groundwater Elevations Supplemental Phase II Investigations Former Photech Facility, Williamstown, MA Gauging Date: 7/26/2012 (Boring) Well Identification MW-1 MW-2B MW-3 (B-101) MW-4 (B-103A) MW-5 (B-104) MW-6 (B-107) MW-7
(1) (2)

Ground (1) Elevation 101.31 99.58 100.33 98.19 96.86 100.23 103.30

Top of Standpipe or (1) Road Box 103.21 102.47 102.57 99.97 99.58 103.02 103.41

Top of PVC(1) 102.87 102.37 102.13 99.76 99.36 102.77 103.07

Depth to Groundwater(2) 13.26 12.90 11.70 11.95 10.79 14.02 5.07

Calculated Groundwater Elevation 89.61 89.47 90.43 87.81 88.57 88.75 98.00

Notes Surveyed on July 26, 2012 to an arbitrary elevation of 100 feet at southwest corner of remaining former Photech building. As measured from top of PVC, unless otherwise indicated.

J:\W\W0987 PHOTEC\Site Assessment_2012\Phase II_III Report\Appendix C_Summary Tables\Table 3-2_Groundwater Elevations.xlsx

TABLE 3-3 Summary of Soil Results Supplemental Phase II Investigations Former Photech Facility, Williamstown, MA (Results in mg/kg) MCP Method 1 Standards Analytes EPH carbon ranges C9-C18 Aliphatic C19-C36 Aliphatic C11-C22 Aromatic Target PAHs Acenaphthene Acenaphthylene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2-Methylnaphthalene Naphthalene Phenanthrene Pyrene Metals Cadmium Silver 2 100 2 100 2 100 3 5 0.79 3.9 1.8 4.9 0.43 2.8 0.26 ND(0.51) 0.37 ND(0.53) 0.28 ND(0.54) 12 83 0.58 16 3.3 33 7.2 52 2 13 28 230 0.39 ND(0.52) 0.36 ND(0.52) 4 1 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 0.7 4 10 1,000 1,000 600 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 80 40 500 1,000 1,000 10 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 300 500 500 1,000 2 1 4 9 7 8 3 4 7 1 10 2 3 1 1 20 20 ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.12) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) ND (0.11) 0.11 ND (0.11) 0.30 0.74 0.74 1.1 0.43 0.40 0.92 0.13 1.8 0.15 0.50 0.13 0.13 1.4 1.8 1,000 3,000 1,000 1,000 3,000 1,000 1,000 3,000 1,000 ND (12) ND (12) ND (12) ND (11) ND (11) ND (11) ND (11) ND (11) ND (11) 37 42 72 S-1/GW-1 S-1/GW-2 S-1/GW-3 MADEP Background Levels in Soils (1) Containing Fill Boring Location: Sample Depth: Sample Date: B-103 5-7' 7/9/12 B-103A 10-12' 7/9/12 B-104 5-7' 7/9/12 B-105 5-7' 7/9/12 B-105 12-13' 7/9/12 B-106 0-2' 7/9/12 B-108 0-2' 7/10/12 B-113 0-2' 7/10/12 B-113 2-4' 7/10/12 B-114 0-2' 7/10/12 B-114 4-8' 7/10/12 B-115 0-2' 7/10/12 B-116 0-2' 7/10/12 B-117 2-4' 7/10/12 B-117 4-8' 7/10/12 B-121 0-4' 7/10/12 B-122 0-2' 7/10/12

NOTES: (1) MADEP identified background levels in soils containing coal ash or wood ash associated with fill material, as referenced in MADEP's Technical Update to Section 2.3 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard (effective December 14, 2007). ND indicates that the contaminant was not detected above the laboratory reporting limit indicated. indicates sample not analyzed for respective analyte.

Page 1 of 2

J:\W\W0987 PHOTEC\Site Assessment_2012\Phase II_III Report\Appendix C_Summary Tables\Table 3-3_Additional Phase II Soil Data.xls

TABLE 3-3 Summary of Soil Results Supplemental Phase II Investigations Former Photech Facility, Williamstown, MA (Results in mg/kg) MCP Method 1 Standards Analytes EPH carbon ranges C9-C18 Aliphatic C19-C36 Aliphatic C11-C22 Aromatic Target PAHs Acenaphthene Acenaphthylene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2-Methylnaphthalene Naphthalene Phenanthrene Pyrene Metals Cadmium Silver 2 100 2 100 2 100 3 5 0.34 0.67 1.4 8.4 2.9 20 7.8 48 2.1 5.0 1.2 10 4 1 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 0.7 4 10 1,000 1,000 600 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 80 40 500 1,000 1,000 10 1,000 7 2 7 1,000 70 70 0.7 1,000 1,000 7 300 500 500 1,000 2 1 4 9 7 8 3 4 7 1 10 2 3 1 1 20 20 0.71 ND (0.11) 2.3 3.7 3.2 4.6 2.1 1.6 3.7 0.54 11 1.3 2.2 0.34 0.95 11 9.2 1,000 3,000 1,000 1,000 3,000 1,000 1,000 3,000 1,000 ND (11) ND (11) 76 S-1/GW-1 S-1/GW-2 S-1/GW-3 MADEP Background Levels in Soils (1) Containing Fill Boring Location: Sample Depth: Sample Date: B-124 0-2' 7/10/12 B-124 2-4' 7/10/12 B-125 0-2' 7/26/12 B-126 0-2' 7/26/12 B-127 0-2' 7/26/12 B-128 0-2' 7/26/12 B-129 0-2' 7/26/12

NOTES: (1) MADEP identified background levels in soils containing coal ash or wood ash associated with fill material, as referenced in MADEP's Technical Update to Section 2.3 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of MCP Method 1 Cleanup Standard (effective December 14, 2007). ND indicates that the contaminant was not detected above the laboratory reporting limit indicated. indicates sample not analyzed for respective analyte.

Page 2 of 2

J:\W\W0987 PHOTEC\Site Assessment_2012\Phase II_III Report\Appendix C_Summary Tables\Table 3-3_Additional Phase II Soil Data.xls

TABLE 3-4 Summary of Groundwater Results Supplemental Phase II Investigations Former Photech Facility, Williamstown, MA (Results in µg/L unless otherwise reported) Method 1 Standards Analysis Field Measurements
(1)

Monitoring Well: Date Sampled: 8/14/00 <1 <5 110 130 120 1.4 <1.0 <0.2 <1.0 5.9 <1.0 2.9 5.0

MW-1 10/19/00 <100 <100 <100 <1.0 <1.0 <0.2 <1.0 <1.0 <1.0 <1.0 <1.0 7/31/03 <100 <100 <100 <1 <0.3 <0.2 <1 <1 <1 <0.2 <1 7/26/12 14.64 0.383 6.94 -62 0.00 18.8 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0 8/14/00 <1 <5 <130 <130 <130 <1.0 <1.0 0.2 <1.0 1.3 <1.0 <1.0 <1.0

MW-2B 4/28/03 146 194 223 2.0 0.8 <0.2 2.0 <1.0 1.0 1.42 2.0 7/31/03 <100 <100 <100 <1 <0.3 <0.2 <1 <1 <1 <0.2 <1 7/26/12 16.53 0.372 7.02 67 0.00 9.17 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0

MW-3 7/31/03 <100 <100 <100 <1 <0.3 <0.2 <1 <1 <1 <0.2 <1 7/26/12 14.34 0.244 7.51 27 5.72 16.2 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0

MW-4 7/26/12 15.36 0.772 7.21 -55 4.74 30.7 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0

MW-5 7/26/12 19.50 0.291 7.53 -72 5.90 34.5 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0

MW-6 7/26/12 16.34 0.613 6.77 -67 0.0 12.8 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0

MW-7 7/26/12 18.14 0.295 7.19 169 4.26 14.0 <4 <5 <100 <100 <100 <2.0 <0.05 <0.10 <0.20 <2.0 <2.0 <2.0 <2.0

GW-1 5 100 700 14,000 200 20 1 0.2 2 90 140 40 80

GW-2 NA NA 5,000 NA 50,000 NA NA NA NA NA 1,000 NA NA

GW-3 4 7 50,000 50,000 5,000 6,000 1,000 500 70 200 20,000 10,000 20

Temperature (°C) Specific Conductance (mS/cm) pH ORP (mV) DO (mg/L) Turbidity (NTU) Metals (Dissolved) Cadmium Silver EPH w/target PAHs(2) C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics Acenaphthene Benzo(a)anthracene Benzo(a)pyrene Chrysene Fluoranthene Naphthalene Phenanthrene Pyrene
NOTES:
(1) (2)

Field measurement for last reading recorded at the end of low-flow purging of well.

Only analytes detected above laboratory detection limits in one or more groundwater samples are included in table.
Boxed value indicates concentration in groundwater exceeds Method 1 standard. indicates not detected above the referenced laboratory reporting limit.

<

NA indicates not applicable in accordance with the MCP.

Table 3-4_Additional Phase II Groundwater Data.xls

TABLE 3-5 Summary of Sediment Results Supplemental Phase II Investigations Former Photech Facility, Williamstown, MA (Results in mg/kg) MADEP Analytes Metals Cadmium Silver 5 <0.29 <0.58 0.35 <0.68 0.62 <0.73 0.55 <0.60 0.71 <0.66 0.47 <0.69 0.64 10 0.31 <0.60 Sediment Screening Values(1) Sample Location: Sample Date: SED-1 7/26/12 SED-2 7/26/12 SED-3 7/26/12 SED-4 7/26/12 SED-5 7/26/12 SED-6 7/26/12 SED-7 7/26/12 SED-8 7/26/12

NOTES: (1) MADEP Revised Sediment Screening Values of January 2006, as referenced in MADEP's Interim Technical Update to Section 9 of the Guidance for Disposal Site Risk Characterization. Boxed values indicates exceedance of Sediment Screening Value. ND indicates that the contaminant was not detected above the laboratory reporting limit indicated.

J:\W\W0987 PHOTEC\Site Assessment_2012\Phase II_III Report\Appendix C_Summary Tables\Table 3-5_Additional Phase II Sediment Data.xls

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