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1.0 INTRODUCTION Capaccio Environmental Engineering, Inc. (CAPACCIO) was retained by Bodycote Thermal Processing, Inc. (BODYCOTE) to complete a Phase 1 – Initial Site Investigation Report (Phase I) and Tier Classification for a release of oil at BODYCOTE’s 284 Grove Street, Worcester, MA facility, hereafter referred to as the “Site”. A Site Location Map is included as Figure 1. On May 18, 2004, the two-inch-diameter monitoring well MW-9 was installed outside of the BODYCOTE facility in the sidewalk along Brookfield Street. This monitoring well was installed as part of continuing Phase II soil and groundwater delineation activities being conducted for Massachusetts Department of Environmental Protection (MADEP) Release Tracking Number (RTN) 2-14062. A Site Plan is attached as Figure 2. Following installation, groundwater samples from monitoring well MW-9 were collected; no liquidphase hydrocarbon (LPH) was present. LPH was first recorded in monitoring well MW-9 during the August 2004 groundwater sampling event. The descriptions provided from the monitoring indicated LPH similar to that previously being remediated under Remedy Operating Status (ROS) under MADEP RTN 2-12660. Overall groundwater flow direction is to the east, toward the Mill Brook Culvert, which locates monitoring well MW-9 in the upgradient direction. However, groundwater gauging data has indicated a component of flow toward monitoring well MW-9. Based on this, it was believed that the LPH detected in monitoring well MW-9 was from the same source as that in the monitoring wells in the ROS area. The January 2005 groundwater sampling event indicated that monitoring well MW-9 was clear of LPH. However, continued groundwater monitoring after January 2005 continued to indicate the presence of LPH in thicknesses ranging from 0.27 feet to 1.87 feet. Based on this, CAPACCIO determined that it would be prudent to collect an LPH sample for comparison to LPH samples collected in 2002 from monitoring wells MW-S4, MW-S7 and MW-S11 (located in the ROS area) to ensure that the source of the LPH was consistent. The LPH sample was collected on April 7, 2005 and submitted to Worldwide Geosciences, Inc. (WGI) of Houston, Texas. On May 3, 2005, CAPACCIO received verbal notification from WGI that the LPH from monitoring well MW-9 was that of a severely biodegraded diesel/fuel oil product with a most probable exposure time of twenty years or more. Although the exposure time is consistent with the LPH in the ROS area, WGI concluded that the LPH in monitoring well MW-9 was not related to any of the 2002 Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 1 of 22 samples. Therefore, the indication of a differing source constituted a new release condition, that, in accordance with the Massachusetts Contingency Plan (MCP) 310 CMR 40.0313, met the 72-hour reportable condition requirements and, per 310 CMR 40.0412, a condition where an Immediate Response Action (IRA) is required. The MADEP assigned RTN #2-15735 and verbally approved continued manual bailing and assessment as the IRAs. BODYCOTE received a Notice of Responsibility (NOR) from the MADEP dated June 13, 2005. The following documents were submitted to DEP since release reporting: IRA Plan, July 7, 2005; IRA Plan Modification, November 3, 2005;and, IRA Status Report, May 11, 2006. This report documents the results of the Phase I in accordance with the MCP, 310 CMR 40.0480. 1.1 Purpose and Scope of Work The purpose of this Phase I investigation is to 1) evaluate the release of oil and/or hazardous materials to the soil and groundwater at the property, 2) identify source(s) or potential source(s) to the release, 3) define the general nature and extent of the release including that anticipated in order to define conceptual Phase II activities, 4) identify human and environmental receptors, and, 5) collect additional information necessary to complete a Tier Classification for the site. CAPACCIO performed the following tasks in order to accomplish this investigation: 1) The following organizations and agencies were contacted to determine past ownership of the property and whether there were any complaints or violations concerning the environmental quality of the property: a) b) c) d) e) f) g) h) i) The City of Worcester Assessor’s Office; The City of Worcester Department of Public Health; The City of Worcester Building Department; The City of Worcester City Clerk’s Office; The City of Worcester Fire Department; The City of Worcester Water Department; The City of Worcester Public Works Department; The Massachusetts Department of Environmental Protection; The Massachusetts Geographic Information System; and, Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 2 of 22 j) The Environmental Protection Agency’s CERCLIS, NPL and RCRA listings. 2) CAPACCIO conducted a visual inspection of the property and a review of neighboring properties. 3) CAPACCIO has performed field activities relating to this release since May 18, 2005, including the installation and gauging of groundwater monitoring wells and the collection of soil and groundwater samples for laboratory analyses. 4) CAPACCIO developed Site drawings and summarized analytical and gauging data. 2.0 LOCATION DESCRIPTION 2.1 Property Location, Local Land Uses and Demographics A Site Location Map is provided as Figure 1. Geographically, the Site is located at UTM coordinates northing 4,684,713.893, easting 268,621.987. The Site is located at the corner of Grove Street and Brookfield Street in an area of mixed land use with a population of greater than 4,400 people per square mile. Commercial and industrial companies are located along Grove Street. Residential homes and apartment buildings are located east of the Site along Brookfield Street. There are no public institutions located within 500 feet of the Site. The nearest school to the Site is the Worcester Center for Crafts, located approximately 0.1 mile to the southwest. 2.2 Local Natural Resources A review of MADEP Priority Resource Maps for the local area indicated that there are no Vernal Pools, Threatened or Endangered Species Habitats within a one-quarter-mile radius of the Site. The nearest is located approximately 0.09 mile southeast of the Site. The nearest Protected Open Space is located approximately 0.0.9 mile southeast of the Site. The Site is not located within a Sole Source Aquifer, an Interim Wellhead Protection Area, or a Zone A or Zone II of a public drinking water well. The nearest surface water body is the West Mill Brook Culvert, located on the Site. The culvert is a twin-box (i.e. west and east) culvert located underground having a combined dimension of 24 feet wide by seven feet high. The culvert discharges water from Indian Lake directly to Salisbury Pond. Salisbury Pond is a Class B surface water body Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 3 of 22 designated by MADEP as suitable for fish habitat and other aquatic life, wildlife, primary and secondary contact recreation, and as a public water supply source with treatment. The Worcester Department of Public Health (WDPH) reports that contact recreation, fishing and boating is not allowed at the pond and is indicated to the public by posted signs. The pond does reportedly support fish. Therefore, in accordance with 1997 MADEP guidance on completing the numerical ranking, a fish habitat is considered to be “on-site” because water in the underground culvert supports fish habitat in the pond. The Site is located over an MADEP-designated medium-yield non-potential drinking water source area. There are no drinking water supply reservoirs within a one-quarter-mile radius and no public drinking water supply wells are located within a one-quarter-mile radius of the Site. 2.3 Site Description 2.3.1 Site Structures and Land Surface Description The BODYCOTE facility occupies two parcels of land, 284 Grove Street and 280 Grove Street, which are located on either side of Brookfield Street. According to BODYCOTE and based on CAPACCIO’s inspection of both locations, lead and chlorinated solvent use were limited to 284 Grove Street. One two-story brick building, constructed on a reinforced concrete slab approximately six inches thick, is located at 284 Grove Street. Land located behind the facility is used for shipping and receiving and storage of finished and unfinished customer product. The area of land located behind the facility was not paved until approximately 1989, when it was paved with asphalt. Surface topography is relatively level at an elevation of approximately 502 feet above sea level. Hills to the north, east and west of the Site rise to an elevation of approximately 590 feet above sea level, while topography to the south slopes toward the Salisbury Pond at an elevation of approximately 492 feet above sea level. 2.3.2 Site Utilities Natural gas is used to heat the facility and run the heat treating furnaces. Water and sewer is provided by the City of Worcester. Storm water at the rear of the property flows Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 4 of 22 to two catch basins located on-site which discharge directly to the Mill Brook Culvert. The underground culvert discharges to Salisbury Pond to the south. 2.4 Site History BODYCOTE performs hardening of metal products via heat treating and employs approximately 40 on-site workers. The process strengthens the metal product for their intended use. A current floor plan is included as Figure 3. In reference to this figure, the facility contains several areas with varying types of heat treating furnaces and associated tempering units. An area at the rear of the facility is used for shot blasting and tumbling to debur metal products. The heat treating furnaces utilized fuel oil prior to 1991, when they were converted to burn natural gas. The fuel oil was stored in underground storage tanks (USTs) located beneath the facility and were properly abandoned in place from February to August 1991 (discussed further in Section 3.2.1) when the furnaces switched to natural gas. Natural gas is used to heat the facility and run the heat treating furnaces. Water and sewer is provided by the City of Worcester. Storm water at the rear of the property flows to two catch basins located on-site which discharge directly to the Mill Brook Culvert. The underground culvert discharges to Salisbury Pond to the south. Land use around the site includes: A metal stamping facility (the Thomas Smith Company) to the north; Brookfield Street to the south. The other BODYCOTE facility (280 Grove Street) is located beyond Brookfield Street; A Massachusetts Electric Company substation to the east. Residential homes are located to the southeast and apartment buildings are located beyond the substation; and, Grove Street to the west. The Worcester Regional Transit Authority’s (RTA) maintenance facility is located beyond Grove Street. Activities at 280 Grove Street include heat treating using ammonia and nitrogen atmospheres, product inspection, maintenance, shipping/receiving of customer orders, and Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 5 of 22 manual sand blasting. Liquid ammonia and liquid nitrogen above ground storage tanks are located at the rear (east side) of the property. Underground piping from the ASTs supplies ammonia and nitrogen to furnaces at both 280 and 284 Grove Street. Prior to using ammonia and nitrogen, heat treating using neutral salts such as sodium nitrate. Cold water quenching was conducted. No quench oil was used at this location and no waste storage was located here. 2.5 Database Information for Nearby Properties The Environmental FirstSearch Report, prepared by FirstSearch Technology Corporation addresses the area surrounding the Site. The FirstSearch Report is included as Appendix A. The following is a brief summary of database information for the surrounding area: No properties exist within a one-mile radius of the Site that are included on the U.S. Environmental Protection Agency’s (USEPA) National Priority List (NPL). No properties exists within a half-mile radius of the Site that is included on the Comprehensive Environmental Response Compensation and Liability Information System (CERCLIS) List. There are eight (including the BODYCOTE facility) Resource Conservation and Recovery Act (RCRA) generators located within one-quarter mile of the Site, four of which are located within 500 feet of the Site. These include the Worcester Area Transportation Company, located 0.02 mile to the northwest, the Thomas Smith Company, located 0.04 mile to the northeast, L&J of New England, Inc., located 0.06 mile to the southwest and Howard Product, Inc., located 0.06 mile to the southeast. There are fifty-eight MADEP Sites located within one mile of the BODYCOTE Site, which includes the releases at BODYCOTE’s 284 Grove Street facility (RTNs 2-12660 and 2-14062). Excluding releases reported at BODYCOTE, three of the 49 Sites are located within one-quarter mile of the BODYCOTE Site. These include petroleum releases at the Worcester Regional Transit Authority (RTA), located 0.03 mile to the northwest, which is located across Grove Street from BODYCOTE, the Health Foundation of Central Massachusetts, located 0.05 mile northwest of the Site and the Texaco service station, located 0.19 mile to the northwest. Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 6 of 22 There are seventy-seven spills reported since 1990 within a half-mile radius of the Site and sixteen spills (excluding BODYCOTE) reported between 1980 and 1990 within a quarter-mile of the Site. Nine of these spills are located within 500 feet of the Site. These include seven releases at the Worcester RTA , located 0.01 mile northwest and two releases at the Health Foundation of Central Massachusetts/Central Massachusetts Health Care, located 0.05 mile to the northwest. There are four properties (including the BODYCOTE facility) with registered USTs present within a one-quarter mile radius of the Site. These include the Worcester Regional Transit Authority (RTA), located 0.02 mile to the northwest and across Grove Street from the BODYCOTE facility, the Thomas Smith Company located 0.04 mile to the northeast and adjacent to the BODYCOTE facility, and the Shell service station, located 0.17 mile to the northwest. There are no reported leaking USTs, no solid waste landfills and no RCRA Treatment, Storage and Disposal facilities within a half-mile radius of the Site. 3.0 SITE HISTORY 3.1 Ownership and Operations Information in this section was obtained from BODYCOTE personnel and from records obtained at Worcester Municipal Offices. The property was first developed in in 1920 by Greenman Steel Treating, Inc. New England Metalurgical, Inc. purchased the property is the 1950’s and Lindberg Heat Treating, Inc. purchased the property in 1966. BODYCOTE purchased the property from Lindberg Heat Treating, Inc. in 2001. Each of the companies operated at the property and conducted similar metal heat treating operations. The building was built in 1920 and later expanded by the late 1950’s. BODYCOTE refers to the current 284 Grove Street facility as Building Numbers 1 & 2. Building Numbers 3 & 4 are located at 280 Grove Street. Information in this section was obtained from BODYCOTE personnel and from records obtained at Worcester Municipal Offices. The property was first developed in 1920 by Greenman Steel Treating, Inc.. New England Metallurgical, Inc. purchased the property in the 1950’s and Lindberg Heat Treating, Inc. purchased the property in 1966. BODYCOTE purchased the property from Lindberg Heat Treating, Inc. in 2001. Each of the companies Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 7 of 22 operated at the property and conducted similar metal heat treating operations. The building was built in 1920 and later expanded by the late 1950’s. BODYCOTE refers to the current 284 Grove Street facility as Building Numbers 1 and 2. 3.2 Oil and Hazardous Material Management CAPACCIO reviewed BODYCOTE’s use and handling of oil and hazardous material at the Site. Current and past petroleum, lead and chlorinated hydrocarbon uses are summarized below. 3.2.1 Petroleum Use BODYCOTE used petroleum products for two primary operations - fuel oil until 1991 to run furnaces, and quench oil to cool metal parts after heat treating. Quench oil in Building #1 (see Figure 2) was formerly stored in a 2,500-gallon UST and a 4,000-gallon partially below-grade open-top tank until 1986 when the 2,500-gallon tank was closed in accordance with applicable state and federal regulations. Quench oil in Building #2 was formerly stored in a 600-gallon UST and a 110-gallon partially below-grade open-top tank. The 600-gallon UST was abandoned in August of 1991. The 110-gallon tank was used until February 1991, when it was replaced with an AST. Quench oil was also stored in ASTs located at the rear of the building. Currently, quench oil is stored in an 1,800-gallon AST, as shown on Figure 2, and in ASTs located inside the facility. Waste quench oil is collected and stored in a 1,000-gallon AST located in a storage building (shown on Figure 2), along with 55-gallon drums of waste oily solids. This material is transported and disposed off-site by United Industrial Services, Inc. for disposal at United Oil Recovery, Inc. in Meriden, Connecticut as hazardous waste. Two furnace oil coolers which contain approximately 200-gallon above-ground oil circulation tanks are located in a shed attached to the facility (see Figure 2). Fuel oil was previously used to fire the furnaces. Three #2 fuel oil USTs were located on the Site. Two of these USTs (5,000 gallons and 8,000 gallons) were located at the rear of Building #2 and were closed in-place in August 1991 in accordance with applicable state and federal regulation. The third UST (2,500 gallons) was located to the north, beneath Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 8 of 22 Building #1 and was closed in-place in February 1991 in accordance with applicable state and federal regulation. Because the USTs were located beneath the facility, in-place closure was approved by the Worcester Fire Department. The USTs were closed by General Chemical Corp. in accordance with 527 CMR 9.00. According to BODYCOTE, the USTs were emptied of product, cleaned, and filled with concrete slurry. An on-line database search conducted by CAPACCIO did not reveal reported petroleum releases at BODYCOTE other than RTN #2-12660, which is associated with a release at the former 5,000-gallon and 8,000-gallon USTs, currently under Remedy Operating Status and RTN #2-14062, which is associated with a release of lead and chlorinated hydrocarbon compounds and is currently in Phase IV of the MCP. BODYCOTE reports that there have been no other significant releases at the facility. 3.2.2 Lead Use Lead was used by BODYCOTE for localized heat treatment of steel parts. Heat treating was performed using 15-inch-diameter, 24-inch-deep pots filled with molten lead. The molten lead was covered with a layer of charcoal that contained heat and splatter. Referred to by BODYCOTE as the Lead Line, this method was used by BODYCOTE on an asneeded basis from approximately 1985 to 1991 at which time the activity was discontinued. The Lead Line, which BODYCOTE reported to last operate, had one lead pot and was removed in 1993. According to BODYCOTE, lead heat treating was used more commonly in the 1950’s to 1970’s. The location and number of Lead Lines, if any, that may have been operated by Greenman Steel, New England Metallurgical, and Lindberg Heat Treating up to 1985 are not known. BODYCOTE’s former Lead Line was located in Building #2 as shown on Figure 2. BODYCOTE has no documented information regarding disposal practices of the lead/charcoal waste. However, BODYCOTE reported that unused empty lead pots where stored outside behind the 284 Grove Street facility when no longer needed. 3.2.3 Chlorinated Hydrocarbon Use Two former parts vapor degreasers were located at the 284 Grove Street BODYCOTE facility. One was located in Building #1 and the other located in Building #2; locations of Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 9 of 22 the former vapor degreasers are shown on Figure 2. Hazardous waste manifests obtained from BODYCOTE from the early 1980’s indicated the use of Trichloroethene (TCE) in the former vapor degreaser located in Building #1. This vapor degreaser was reportedly located above ground on the facility concrete floor. Solvent was added directly to the vapor degreaser from portable containers. This vapor degreaser was removed in 1986 and a new one installed at the eastern corner of Building #2 in 1988. The new vapor degreaser was larger and located in a concrete-lined pit. Solvent was supplied via a 200- to 300gallon AST located outside at the eastern corner of Building #2. The AST was located in a berm made of a concrete slab and 2-feet-high cinderblock walls that was filled via a fill pipe accessible from Brookfield Street. According to BODYCOTE, this degreaser utilized tetrachloroethene, similarly called perchloroethene (PCE), from 1986 to 1989; 1,1,1trichloroethane (TCA) was used from 1989 to 1995. Use of this degreaser was terminated and it was removed in approximately 1995. Spent solvents from both degreasers was reportedly contained and transported off-site as a hazardous waste by a licensed transporter. 3.3 Environmental Permits and Compliance BODYCOTE reports that the following permits are held for the 284 and 280 Grove Street facilities: Air Emissions: Limited Plans Approval; Small Quantity Generator of hazardous waste: #MAD046130720; Storm Water Discharge (General Multi-Sector): #MAR05B316; According to BODYCOTE, there has been one notice of non-compliance or violation issued in the last five years for environmental operating permits. In the spring of 2000, MADEP issued a non-compliance for opacity in air emissions from quench oil smoke. MADEP determined that an air permit was not required for the emission. MADEP and BODYCOTE determined maintenance procedures to reduce opacity, which BODYCOTE has since implemented. Four violations relative to Waste Site Clean Up at the property were issued by MADEP in the last five years. MADEP conducted an audit inspection of RTN 2-12660 on February 14, 2002 and September 21, 2004. The audits focused on the IRA and ROS, respectively, performed at the Site. The violations, which were identified and corrected Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 10 of 22 according to MADEP’s Notice of Audit Finding, was maintenance of the groundwater remediation system and inspection logbook for the Site. MADEP required no further action. In response to a request for an extension for report submittal relating to RTN 2-14062, on May 5, 2005, the MADEP issued an NON for failure to submit the required Phase II – Comprehensive Site Assessment Report and Phase III – Remedial Action Plan. In response to this NON, BODYCOTE submitted an incomplete Phase II and Phase III in December 2005. The MADEP subsequently issued an NON on March 10, 2006, citing deficiencies in the Phase II and Phase III report. A Revised Phase II and Phase III report was submitted to the MADEP in July 2006. 4.0 IDENTIFICATION OF APPLICABLE SOIL AND GROUNDWATER CATEGORIES 4.1 Overview As presented in 310 CMR 40.0930, groundwater and soil categories have been developed to characterize groundwater and soil in the Commonwealth of Massachusetts. Standards for each of these categories were established for comparison to concentrations of OHM present in soil and groundwater. The results of this comparison are used to determine whether these concentrations require response actions, or if they indicate a condition of No Significant Risk. 4.2 Identification of Applicable Groundwater Category Groundwater is classified as one of three categories defined in the MCP; GW-1, GW-2, and GW-3. Category GW-1 is for groundwater located within any one of the following areas: Zone II Water Supply Well Head Protection Area; Interim Water Supply Well Head Protection Area; Zone A of a Class A surface water body; Less than 500 feet from a private water supply well that was in use at the time of release notification; Potentially Productive Aquifer; Greater than 500 feet from a public water system distribution pipeline; and, Within an area designated by a municipality for the protection of groundwater quality to ensure its availability for use as a source of potable water supply. Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 11 of 22 If none of the GW-1 criteria are satisfied, then groundwater is category GW-2, if it is located within 30 feet of an occupied building or structure, and the average annual depth is 15 feet or less. Groundwater that is neither category GW-1 or GW-2, is category GW-3 by default. Groundwater categories were defined at the Site using information from MADEP’s Geographic Information Mapping System (GIS) of environmental resources. Groundwater categories were defined at the Site using information from MADEP’s Geographic Information Mapping System (GIS) of environmental resources. The Site is located within an MADEP-designated medium-yield non-potential drinking water source area. Groundwater located on Site within 30 feet of an occupied structure would be classified as GW-2 since the average annual depth to groundwater is less than 15 feet below grade. Groundwater is also category GW-3 by default. 4.3 Identification of Applicable Soil Category Three categories of soil have been identified by MADEP to determine the applicability of standards for the characterization of risk for individual compounds. These designations are S-1, S-2, and S-3, and are based upon the site, receptor and exposure information in conjunction with specific criteria for exposure potential to groups of individuals as identified in 310 CMR 40.0933. The three soil category descriptions reference potential for exposure to that soil. Category S-1 soils are associated with the highest potential for exposure, with S-3 soils having the lowest. The potential for exposure is determined by evaluating the frequency of use of the site, intensity of use of the site, and accessibility of site soil by children and adults. The evaluation of these criteria for children and adults is performed independently and the soil category with the lowest number from these two evaluations is designated for the entire site or for a specified volume of soil on the site. Frequency of use by adults is high, because adults work on-site on a continuing basis. Children are not present. Intensity of use is low, because routine site activities are passive and do not disturb soil and because impacted soil is located beneath asphalt pavement or the BODYCOTE facility. Therefore, the soil exposure category is S-3. However, S-1 Soil Standards will be utilized in the following risk characterization to evaluate the status of achieving No Significant Risk without the need for an Activity and Use Limitation. 5.0 SUBSURFACE INVESTIGATION Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 12 of 22 The following subsurface activities were conducted to fulfill MCP requirements for either this RTN (2-15735), for RTN 2-12660 and/or RTN 2-14062: A total of eighteen monitoring wells have been completed at the Site; A total of 50 soil borings have been completed at the Site; and, Quarterly groundwater gauging and sampling. A Site Plan showing the soil boring locations (S-1 through S-45 as well as B-1, B-2, B-3, B4, and B-5/MW-6) is included as Figure 2. A detailed summary of the subsurface investigation relating to petroleum hydrocarbons is discussed below. Note that LPH and the associated volatile petroleum hydrocarbons (VPH) and extractable petroleum hydrocarbons (EPH) in and around the east end of the property are being addressed under response actions conducted under RTN 2-12660. 5.1 Groundwater Gauging Weekly manual groundwater gauging and LPH recovery has been conducted from monitoring well MW-9, attached in Table 1. From November 3, 2005 through April 12, 2006, the amount of LPH recorded in monitoring well MW-9 ranged from 0.02 foot on January 11, 2006 to 1.66 feet on March 1, 2006. Through April 12, 2006, a total of approximately 8 gallons of LPH has been manually recovered from the well. Based on the gauging data, there appears to be a correlation between the amount of LPH recorded in the monitoring well and the depth to water. The thickness of LPH appears to increase as depth to water increases. This trend will continue to be evaluated. Based on these data, the overall groundwater flow direction is to the east/southeast, which is consistent with previous data. A Groundwater Data Map of the April 3, 2006 data is included as Figure 4. 5.2 Soil Sampling During the Phase I investigation, lead, VPH, EPH, polyaromatic hydrocarbon compounds (PAHs) and volatile organic compounds (VOCs) compounds in soil were detected at concentrations exceeding the MADEP RCS-2 Reportable Concentrations. Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 13 of 22 Between September 2002 and October 2005, CAPACCIO supervised the installation of an additional 21 soil borings and 4 monitoring wells. Additionally, 6 soil samples were collected during RAM activities completed from September 2003 through April 2004. Boring logs and Well Completion Reports were submitted in the Revised Phase II and Phase III submitted to the MADEP in July 2006 under RTN 2-14062. In reference to these logs, the sediments encountered typically consisted of medium to fine sand with varying amounts of silt, gravel and fill material. Continuous soil samples were collected for field screening purposes utilizing a photoionization detector (PID). PID readings are indicated on the boring logs. 5.2.1 Soil Analytical Data - VPH In May 2004, a soil sample collected from soil boring S-27, located toward the front of the facility, indicated a concentration of the C9-C10 VPH carbon chain range that exceeded the applicable MADEP Method 1 Soil Standards at a depth of 7 to 10 feet below grade. VPH and EPH data is summarized in Table 2. Between September 2002 and September 2005, additional soil samples were collected and analyzed for VPH via the MADEP Method. In reference to Table 2, no other VPH compounds exceeded the applicable MADEP Method 1 Soil Standards. None of the targeted compounds included in the VPH analysis have been detected in any of the soil samples. 5.2.2 Soil Analytical Data - EPH In September 2002, soil samples collected from soil borings S-6 and S-9, located on the northern side of the facility, indicated concentrations of the C9-C18 and C19-C36 EPH carbon chain ranges, respectively, that exceeded the applicable MADEP Method 1 Soil Standards at depths of 9 and 10 feet below grade, respectively. Additionally, soil boring S-16, located at the front of the facility along Grove Street, indicated concentrations of each of the EPH carbon chain ranges that exceeded the applicable MADEP Method 1 Soil Standards at a depth of 9 feet below grade. VPH and EPH data is summarized in Table 2. Between October 2003 and September 2005, additional soil samples were collected and analyzed Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 14 of 22 for EPH via the MADEP Method. In reference to Table 2, the C9-C18 Aliphatic and C11-C22 Aromatic carbon chain ranges were recorded at concentrations exceeding the applicable MADEP Method 1 Soil Standards in soil boring S-29. The C19-C36 EPH carbon chain range was recorded at concentrations exceeding the applicable MADEP Method 1 Soil Standards in soil borings S-22, S-23, S-29, and S-33 and in soil samples collected from Area #1A and Area #2B. Targeted compound analytical data is included in Table 3. In reference to this table, none of the targeted compounds included in the EPH analysis have been detected in any of the soil samples at concentrations exceeding the applicable MADEP Method 1 Soil Standards. 5.3 Groundwater Sampling During the Phase I investigation, lead, VPH, EPH and VOC compounds were detected in groundwater at concentrations exceeding the applicable MADEP Method 1 Groundwater Reportable Concentration. Since completion of the Phase I Report, quarterly groundwater samples have been collected from selected and accessible monitoring points and monitoring wells. Prior to sampling, a minimum of three well volumes of groundwater was purged from the wells and purged groundwater was screened in the field for pH, temperature, conductivity and dissolved oxygen. The groundwater samples were submitted to either Alpha Analytical Laboratories (Certification #M-MA086) or R.I. Analytical Laboratories (Certification #MA-RI015) and analyzed for VPH and EPH with target compounds via MADEP methods and/or volatile organics via either EPA Method 8260 or 8010. A summary of the VPH and EPH analytical data is presented in Table 4. Laboratory analytical reports were submitted along with previously submitted Phase and ROS Status Reports under RTN 2-12660 and/or RTN 2-14062. 5.3.1 Groundwater Analytical Data – VPH VPH and EPH data is summarized in Table 3. In reference to Table 3, VPH compounds exceeded the applicable MADEP Method 1 Groundwater Standard in monitoring wells MW4 (C9-C12 Aliphatics in July 2001 and April 2002 only), MW-6 (C9-C12 Aliphatics in April 2006), MW-8 (C5-C8 Aliphatics in June 2006), MW-9 (each of the VPH carbon chain ranges from Januarh 2005 through April 2006), MW-S11 (each of the VPH carbon chain ranges in April 2005), MW-12 (C9-C12 Aliphatics and C9-C10 Aromatics in April 2006) and monitoring Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 15 of 22 point S-2 (C5-C8 Aliphatics and C9-C12 Aliphatics in October 2002). None of the targeted compounds included in the VPH analysis have been detected in any of the monitoring wells. 5.3.2 Groundwater Analytical Data – EPH VPH and EPH data is summarized in Table 3. In reference to Table 3, EPH compounds exceeded the applicable MADEP Method 1 Groundwater Standard in monitoring wells MW1 (each of the EPH carbon chain ranges on varying dates), MW-3 (C19-C36 Aliphatics in October 2001 only), MW-4 (C9-C18 Aliphatics only on varying dates), MW-6 (C9-C18 Aliphatics only in January and April 2006), MW-9 (each of the EPH carbon chain ranges on varying dates) and monitoring point S-2 (each of the EPH carbon chain ranges in October 2002). 5.4 Migration Pathways Given the nature of the compounds present at the Site, the potential exists for migration of OHM via air, soil, groundwater, and surface water. A discussion of each potential migration pathway relative to the Site follows. 5.4.1 Air Migration pathways for petroleum hydrocarbon compound vapors to enter ambient or indoor air are present at the Site. Impacted groundwater from petroleum hydrocarbons is present adjacent to and beneath the Site and located less than 10 feet below the ground surface. In order to determine if there is impact to indoor air from the subsurface conditions, on May 11, 2006, three indoor air samples were collected from the facility. One sample was collected from the southeastern rear of the facility, in the vicinity of MW-S11 and the former degreaser, one sample was collected from the center of the facility, in the vicinity of S-14 and one sample was collected from the western side of the facility in the vicinity of S-15 and the former degreaser. The samples were collected in accordance with MADEP protocol over a 24-hour period. Each of the three samples was analyzed for Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 16 of 22 volatile organic compounds via Method TO15. The analytical data is presented in the revised Phase II and Phase III report, submitted to the MADEP in July 2006 under RTN 214062. In reference to this data, benzene, TCA and toluene were detected, however, at concentrations significantly below the MADEP-established indoor air background concentrations. A pathway exists for petroleum hydrocarbon vapors to migrate into, and potentially impact air quality, in the culvert or other subsurface utilities along Brookfield Streets. Migration of petroleum under RTN 2-12660 to the underground culvert had occurred in the past through a weep hole and was abated during IRA activities. Significant impact to air inside the underground culvert has not occurred by evidence of safe oxygen levels and safe lower explosive limits measured in the culvert. The underground culvert is not an occupied structure. As part of IRA activities being conducted under this RTN, utilities adjacent to the Site are routinely screened. To date, no actionable levels have been detected. 5.4.2 Soil Soil impacted with petroleum has been identified at the Site. These compounds are not particularly mobile in soil. Therefore, soil is not considered a potential migration pathway. 5.4.3 Groundwater Hydrocarbon-impacted groundwater has been identified on-site and is considered a migration pathway. However, there are no reported private water supply wells within 500 feet of the Property and the Site is not located within or near a public water supply wellhead protection area. Therefore, no exposure pathways to groundwater are present. 5.4.4 Surface Water Although the Mill Brook Culvert is underground, water in the culvert is considered surface water because it conveys surface water from Indian Lake to Salisbury Pond. The underground culvert receives surface water runoff from the Site and can receive groundwater via 4-inch-diameter weep holes in the wall to the culvert. A surface water migration pathway is present but there is no exposure pathway. The culvert discharges to Salisbury Pond, which, according to the WDPH, is not used for swimming, boating, or Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 17 of 22 fishing. Posted signs at the pond indicate that these activities are not permitted. However, the pond does support a fish habitat. There is no evidence of contamination from the Site to water in the underground culvert. LPH from the Site had discharged to the underground culvert through the weep holes and this pathway has been abated by blocking the holes and by operating a groundwater interception trench as part of ROS activities under RTN 2-12660. 5.5 Exposure Assessment The identification of potential human and environmental receptors is based upon a comparison of the physical Site characteristics with the current and reasonably foreseeable uses of the Site. There are no known documented impacts or exposures of OHM to human receptors at or in the immediate vicinity of the Site. To date, there have been no known complaints to the Site owner from neighboring residential Property owners relative to compounds detected at the site. There has been no documented offsite impact to air or surface water from the site. 5.5.1 Current and Reasonably Foreseeable Site Conditions Currently, the Property is maintained as a heat treating facility. Based on the Property location and history, reasonably foreseeable site conditions are expected to remain commercial or industrial. However, to determine the level of risk for the most conservative assumption, residential use of the Site will be evaluated. No foreseeable uses or exposures at the Site have been excluded from this assessment at this time through an Activity and Use Limitation (AUL) or by any temporary risk reduction measure. 6.0 EVALUATION FOR IMMEDIATE RESPONSE ACTIONS Per the MCP, the following conditions require Immediate Response Actions (IRAs): Sites where a release or threat of release of OHM has occurred which requires 2-hour notification; Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 18 of 22 Sites where a release or threat of release of OHM has occurred which requires 72-hour notification; Sites where a condition of Substantial Release Migration has been identified; Any other site where the Department determines that immediate or accelerated response actions are necessary to prevent, eliminate, or minimize damage to health, safety, public welfare or the environment. The presence of LPH measured at monitoring well MW-9, by definition, constitutes a condition requiring IRAs. 6.1 Critical Exposure Pathway The MCP defines Critical Exposure Pathways (CEPs) as those routes by which OHM released at a Site are transported, or likely transported, to human receptors by 1) vapor emissions of measurable concentrations into the living or working space of a pre-school, daycare, school, or occupied residential dwelling; or 2) ingestion, dermal absorption or inhalation of measurable concentrations of OHM from drinking water supply wells located at and serving a pre-school, daycare, school, or occupied residential dwelling. CAPACCIO has determined that a CEP is not present at the Site. There are no public or private drinking water supply wells located in the area for a groundwater pathway to exist. The closest residential dwelling to the Site is located approximately 300 feet to the southeast and is located potentially downgradient of the Site. The concentrations of petroleum hydrocarbon compounds have been delineated to below the Method 1 GW-2 and GW-3 water quality standards and therefore not expected to result in a measurable concentration to indoor air in the residential dwelling. 7.0 TIER CLASSIFICATION A Tier Classification has been completed for the Site. In accordance with Subpart E of the MCP, the Tier Classification consists of the following: Completion of a Phase I report; Completion of a Numerical Ranking Scoresheet; Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 19 of 22 Review of site conditions with Tier I Inclusionary Criteria; and Preparation of a Tier Classification submittal. The Tier Classification submittal includes the following documents: Tier Classification form; Licensed Site Professional (LSP) Tier Classification Opinion which includes this Phase I report, NRS score sheet, and an opinion as to whether the site should classified as Tier I or Tier II; Certification of the submittal regarding the technical, financial and legal ability to proceed with response actions at the site; and Certification of the Tier Classification submittal itself; Site conditions were reviewed relative to Tier I Inclusionary criteria as defined in the MCP and conditions at the Site do not meet any of the criteria. The NRS score was calculated at 262. This score classifies the Site as Tier II. The score sheet is included as Appendix B. The NRS score is based in part on the following conditions specific to the Site: The Site is located in a Non-Potential Drinking Source medium yield aquifer where the population density in this area of Worcester is greater than 4,400 people per square mile. A score of zero was assessed for the “aquifer” portion of the NRS score sheet, Part IV.B., in accordance with MADEP’s September 4, 1997 NRS Guidance Manual. Greater than 12 inches of LPH measured at monitoring well MW-9 resulted in an OHM human health toxicity score of 65 in Part III.A. of the NRS score sheet. 8.0 SUMMARY/CONCLUSIONS A release of petroleum hydrocarbon compounds is present at the BODYCOTE property located at 284 Grove Street in Worcester, MA. The following is a summary of findings relating to the Phase I investigation: Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 20 of 22 Extractable and volatile petroleum hydrocarbons were present in soil and groundwater beneath the property. LPH is present in the sidewalk area along Brookfield Street in the vicinity of monitoring well MW-9. Potential source(s) of LPH are being reviewed by CAPACCIO; and, The Site scored 262 points under the MCP numerical ranking score sheet which classifies it as Tier II. 9.0 PHASE I COMPLETION STATEMENT This Phase 1 Report and Tier Classification were completed to investigate a release of lead and chlorinated hydrocarbon compounds at BODYCOTE’s 284 Grove Street, Worcester, MA facility. This investigation was completed in accordance with MCP, 310 CMR 40.0480. Based on the results of the Phase I investigation, continued response actions are required; a conceptual Phase II Scope of Work is provided below in Section 10.0. 10.0 CONCEPTUAL PHASE II SCOPE OF WORK A conceptual Phase II scope of work is therefore presented for the purpose of fulfilling the Tier Classification submittal. Phase II activities are anticipated to include the following: Sampling and analysis of soil, groundwater, and LPH gauging to define the nature and extent of petroleum product at the Site. The investigation will include consideration of all potential on-site and off-site petroleum sources. Collection of additional Phase II data in accordance with 310 CMR 40.0830 which may be applicable to the Site. Documentation of findings in a Phase II report in accordance with 310 CMR 40.0835. It is estimated that the above conceptual scope of work will cost between $10,000 and $15,000 depending on findings. In accordance with the MCP, a Phase II - Comprehensive Site Assessment Report and, if necessary, a Phase III - Remedial Action Plan will be submitted to the MADEP by May 5, 2008. 11.0 LIMITATIONS Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 21 of 22 This Phase I Report is based solely on the scope of work conducted and sources referred to in this report. The data presented in this report were collected and analyzed using generally accepted industry methods and practices at the time the report was generated. This report represents the conditions, locations, and materials that were observed at the time the field work was conducted. No inferences regarding other conditions, locations, or materials, at a later date or earlier time may be made based on the contents of the report. This report was prepared for the sole use of BODYCOTE. CAPACCIO acknowledges and agrees that this report may be conveyed to BODYCOTE’s attorney, lender, title insurer, and regulatory agencies associated with the subject property. This report has been prepared in accordance with the terms and conditions set forth in our Additional Services Letter Agreement dated July 7, 2005. No other warranty, expressed or implied, is made. Capaccio Environmental Engineering, Inc. 98-021AF August 3, 2006 Page 22 of 22