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VERIFICATION REPORT

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FORMER PAWNEE ARMORY PAWNEE COMPLEX 100 WATER STREET

PAWNEE, CT

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Prepared for:

Department of Defense

August 7, 2017

Prepared by:

Knope Inc.

1234 Swanson Highway Icetown, Connecticut

VERIFICATION REPORT

FORMER PAWNEE ARMORY

PAWNEE COMPLEX 100 WATER STREET

PAWNEE, CT

Prepared for:

Department of Defense

Prepared by:

Knope Inc.

1234 Swanson Highway Icetown, Connecticut

August 7, 2017

I Former Pawnee Complex Verification Report

I TABLE OF CONTENTS CTDEEP Demonstration of Compliance with the Remediation Standard Regulations Checklist

1.0 INTRODUCTION ......................................................................................................................................... 1

2.0 SUPPORTING DOCUMENTATION ........................................................................................................ 2

3.0 FINAL CONCEPTUAL SITE MODEL .................................................................................................... 3

QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) ................................................................................. 44

4.0 RECEPTOR ASSESSMENTS .................................................................................................................. 45

5.0 DESCRIPTION OF REMEDIAL ACTIVITIES ..................................................................................... 46

6.0 QUALITY ASSURANCE I QUALITY CONTROL ................................................................................ 48

7.1 DEMONSTRATION OF COMPLIANCE ...............· ............................................................................... 50

7.2 REGULATORY REQUIREMENTS ............................................................................................................. 50 7.2.1 Remediation Standard Regulations ................................................................................................... 50 7.2.2 RCRA Closure ..............................................................................................................................53 7.2 DEMONSTRATION OF COMPLIANCE .......................................................................................................53

VERIFICATION FORM ETPH APPROVAL FORM

I APPENDIX A -TABLES PHASE II AND PHASE III SAMPLE SUMMARY TABLES

I FIGURES WELL DRILLING COMPLETION REPORTS

POTABLE WELL SURVEY FIGURE

SITE FIGURES

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Knope Inc. Project No. 12345.01

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Former Pawnee Complex Verification Report

1.0 INTRODUCTION

On behalf of the Department of Defense (Military Department), Knope Group Inc. (Knope)

has prepared the following Verification Report for the Former Pawnee Armory Pawnee

Complex (herein referred to as the "Parcel") located at 100 Water Street in Pawnee,

Connecticut (See Figure 1 - Site Location Map). Verification of the Parcel has been

rendered pursuant to the Connecticut Department of Energy and Environmental Protection's

(CTDEEP's) Property Transfer Program, as defined in Section 22a-134a of the Connecticut

General Statutes (CGS).

An Environmental Condition Assessment Form (ECAF) in conjunction with a Form II filing for

the transfer of an establishment pursuant to Section 22a-134a( d) of the CGS was submitted for

the Parcel to the CTDEEP (referred to herein as the "Department") on June 20, 2012. The

following verification documentation has been prepared for the Parcel in accordance with the

Department's Verification Report Guidance Document dated August 1, 2008.

Knope Inc. Page 1 Project No. 12345.01


2.0 SUPPORTING DOCUMENTATION

The following supporting documentation has previously been submitted to the CTDEEP for the Parcel:

• Preliminary Assessment Report, Pawnee Complex, Pawnee, / Connecticut, Prepared by: Knope Group Inc., August 24, 2001.

• Phase II Site Investigation, Pawnee Complex, Pawnee, CT, Contract No. DAHA-07-98-0001, Prepared by: Knope Group Inc., Dated: February 10, 2004.

• Final Report -Remedial Investigation, Pawnee Complex, Pawnee, CT, Contract No. GS-11F-0234N, Prepared by: Knope Group Inc., Dated: November 27, 2006. • Final Feasibility Study, Pawnee Complex, 100 Main Street, Pawnee, Connecticut,

Prepared by: Knope Group Inc., Dated: March 13, 2007.

• RCRA Closure Report, Pawnee Complex Field Maintenance Shop (PMS) #5, 100 Water Street, Pawnee, C o n n e c t i c u t , P r e p a r e d by: Knope Group Inc., Dated: November 2007.

• 6,000 Gallon UST Removal Report, 100 Water Street, Pawnee, CT, CTR Project

#54321, Prepared by: Pawnee Tank Removal, Inc., Dated: April 4, 2008.



3.0 FINAL CONCEPTUAL SITE MODEL The Final Conceptual Site Model (FCSM) has been developed for the Parcel based on the

supporting documentation referenced in Section 2.0. The assumptions and rationale to support

the FCSM are discussed in detail below for each area of concern (AOC) and Potential Area of

Concern (PAOC) identified at the Parcel. Tables summarizing the laboratory data from the

investigations of the Parcel are included in Appendix A.

AOC-1: Empty Drum Storage Area

The empty ("new") drum storage area is located along the southern exterior wall of the Armory

and has been designated AOC-1· on the attached Figure 3. Extractable Total Petroleum

Hydrocarbons (ETPH) at a concentration of 520 ppm were detected in one (1) soil sample,

MAN-9, collected during the Phase II SI at a depth of 2-feet to 4-feet below ground surface.

This concentration slightly exceeded the Residential Direct Exposure Criteria of 500 ppm, but is

below the Pollutant Mobility Criteria for a GB area of 2,500 ppm. The petroleum hydrocarbon

chromatogram was not a perfect match with any of the standards and was quantified as an

"unknown" material with a chromatogram from Cl8 to C36. The Contaminants of Concern

(COCs) associated with the empty "new" drum storage area included ETPH, Volatile Organic

Compounds (VOCs), Polycyclic Aromatic Hydrocarbons (PAHs) and metals. Additional soil

samples were collected at a depth of 2 to 4-feet below ground surface as part of this RI to

determine if COCs associated with the empty ("new") drum storage area are present in the soils

within AOC-1. The results of the additional investigation conducted within AOC-1 did not

detect any COCs at concentrations above the applicable RSR criteria. Petroleum hydrocarbons

had previously been detected at boring MAN-9 (520 ppm) at a depth of 2 to 4-feet below ground

surface during the Phase II SI at a concentration slightly exceeding the RDEC of 500 ppm.

However, additional soil samples collected from the area during the RI did not indicate the

presence of ETPH at concentrations above analytical detection limits (BRL). Therefore, the

previously detected concentration is not indicative of a "release" and is likely due to incidental

sources associated with vehicles parked in the former unpaved parking area. The area south of

the armory building had been used for vehicle parking and was "unpaved" until 1995 at which



time both this area and the area north of the FMS #5 were paved. Prior to the paving, vehicles

were parked on soil. Remediation of AOC-1 is not required and the area is in compliance with

the Remediation Standard Regulations (RSRs).

AOC-2: Former Tank A & Tank D (Removed 2008). 6.000 Gallon Heating Oil

Underground Storage Tanks (USTs)

The former (Tank A) and (Tank D) 6,000 gallon heating oil USTs were located adjacent to the

northwest comer of the Armory and have been designated AOC-2. Tank A was removed and

replaced with Tank D in 1990 and Tank D was removed in 2008. COCs associated with the

former and existing USTs included ETPH, VOCs, and PAHs. The results of the Phase II SI

indicated that soil in the vicinity of the former and existing USTs may have been impacted by

past site usage and recommended further investigation. Further investigation of AOC-2 was conducted as part of this RI and the results did not detect any COCs at concentrations above the

applicable RSRs criteria. Arsenic (MAN-22) and PAHs (MAN-21) had previously been detected

during the Phase II at a concentration exceeding the applicable RSR criteria. However,

additional soil samples collected from the area during the RI did not indicate the presence of any

of these COCs at concentrations above analytical detection limits (BRL). Therefore, the

previously detected concentrations of Arsenic and PAHs are not indicative of a "release" due to

past site operations and are likely due to fill material (arsenic) or incidental sources (PAHs) such

as the bituminous concrete pavement. The Remediation of AOC-2 is not required and the area is

in compliance with the RSRs.

PAOC-3: Petroleum. Oil and Lubricant (POL) Shed, Used Oil Above Ground Storage Tanks

(ASTs) and Hazardous Waste Storage Shed

The POL shed, used oil ASTs, and hazardous waste storage shed were located along the

northwest exterior wall of the Armory and have been designated PAOC-3. Potential for surface

spills from the POL Shed, ASTs, and Hazardous Waste Storage Shed to the surrounding ground

exists. The COCs associated with PAOC-3 included ETPH, VOCs, PAHs and metals. The

[ results of the Phase II SI detected several PAHs at concentrations above analytical detection

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limits but below the applicable RSRs in soil at a depth of 2 to 4-feet below ground surface.

Additional soil samples at a depth of 2 to 4-feet below ground surface were collected from PAOC-3 as part of the RI. The results of the additional investigation within PAOC-3 did not

detect any COCs at concentrations above the applicable RSR criteria. Remediation of PAOC-3

is not required and the area is in compliance with the RSRs.

[ PAOC-4: Former Tank G, 1,500 Gallon Gasoline UST Location Former Tank G, 1,500 gallon gasoline UST was located adjacent to the northeast comer of the

[ FMS #5 and has been designated PAOC-4. Tank G was removed in 1995 and the COCs associated with the former UST included ETPH, VOCs, and metals. The results of the Phase II

SI did not detect any COCs associated with the former UST. Further investigation or remediation of PAOC-4 is not warranted and the area is in compliance with the RSRs.

[ PAOC-5: Oil/Water Separator Location The oil/water separator is located adjacent to the northwest comer of the FMS #5 and has been

designated PAOC-5. Potential spills from pumping of the oil/water separator exist. The COCs

associated with PAOC-5 included ETPH and metals. The results of the Phase II SI detected ETPH at concentrations above analytical detection limits but below the applicable RSRs in soil

at a depth of 1 to 4-feet below ground surface. Additional soil samples were collected from

PAOC-5 as part of the RI. The results of the RI within PAOC-5 did not detect any COCs at

concentrations above the applicable RSR criteria. Remediation of PAOC-5 is not required and

the area is in compliance with the RSRs.

PAOC-6: Former Tank B, 2,500 Gallon Diesel UST Location Former Tank B, 2,500 gallon diesel UST was located north of the FMS #5 and east of the

existing AST and has been designated PAOC-6. The COCs associated with PAOC-6 included ETPH and PAHs. The results of the Phase II SI detected several PAHs at concentrations above

analytical detection limits but below the applicable RSRs Criteria. Additional soil samples were


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collected from PAOC-6 as part of the RI. The results of the RI within PAOC-6 did not detect

any COCs at concentrations above the applicable RSR criteria. Remediation of PAOC-6 is not required and the area is in compliance with the RSRs.

PAOC-7: Former Tank F, 3,000 Gallon Gasoline UST

Former Tank F, the 3,000 gallon gasoline UST was located north of the FMS #5 and north of the_ existing AST, has been designated PAOC-7. The COCs associated with PAOC-7 include ETPH

and VOCs. The results of the Phase II SI did not detect any COCs associated with the former

UST. Further investigation or remediation of PAOC-7 is not warranted and the area is in

compliance with the RSRs.

PAOC-8: Former Tanks C & E. 2,500 Gallon Gasoline UST & 3,000 Gallon Diesel UST

Location

Former Tanks C & E, 2,500-gallon Gasoline and 3,000-gallon Diesel USTs were located north of

the FMS #5 and northwest of the former diesel AST and have been designated PAOC-8. The

COCs associated with PAOC-8 included ETPH, VOCs and PAHs. The results of the Phase II SI

detected ETPH and several PAHs at concentrations above analytical detection. limits but below

the applicable RSRs Criteria. Additional soil samples were collected from PAOC-8 as part of

the RI. The results of the RI within PAOC-R did not detect any COCs at concentrations above

the applicable RSR criteria. Remediation of PAOC-8 is not required and the area is in


PAOC-9: Drum Storage Area The, drum storage area is located adjacent to the northwest comer of the Armory and has been

designated PAOC-9. COCs associated with the drum storage area include ETPH and VOCs.

The results of the Phase II SI did not detect any COCs associated with the drum storage area.

Further investigation or remediation of PAOC-9 is not warranted and the area is in compliance

with the RSRs.



PAOC-10: Former Unpaved Parking Area

The PA indicated that a former unpaved parking area was located to the south of the Armory and

has been designated PAOC-10. According to the PA report the area was previously unpaved and

used for vehicle parking at the Armory. The PA report indicated that this area was paved in

1995 and prior to that time vehicles parked on soil. The potential exists that leakage of vehicle

fluids has impacted surficial soils in the area. COCs associated with the former unpaved parking

area included ETPH, PAHs and VOCs. The results of the Phase II SI detected several PAHs at

concentrations above analytical detection limits but below the applicable RSRs Criteria in the

soil at a depth of 2-feet to 4-feet below ground surface. Additional soil samples were collected at

a depth of 2-feet to 4-feet below ground surface from PAOC-10 as part of the RI. The results of

the additional investigation within PAOC-8 did not detect any COCs at concentrations above the

applicable RSR criteria. Remediation of PAOC-8 is not required and the area is in compliance

with the RSRs.

PAOC-11: Former Waste Oil UST

The former waste oil UST was located along the northern boundary of the Site and along the southern of edge of Armory Street and has been designated PAOC-11. The COCs associated

with the former waste oil tank included ETPH and Polychlorinated Biphenyls (PCBs). The results of the Phase II SI did not detect any COCs associated with the former waste oil UST.

However, total arsenic was detected at a concentration, which exceeded the Direct Exposure Criteria (DEC). Additional soil samples will be collected from the area containing elevated total

arsenic concentrations, MAN-20, to determine if the detected concentration is background or

associated with a release. Further investigation of PAOC-11 was conducted as part of the RI.

The results of the RI within PAOC-11 did not detect any COCs at concentrations above the

applicable RSR criteria. Arsenic (MAN-20) had previously been detected during the Phase II at

a concentration exceeding the applicable RSR criteria. However, additional soil samples

collected from the area during the RI did not indicate the presence of Arsenic at concentrations


1 Former Pawnee Complex Verification Report

above analytical detection limits (BRL). Therefore, the previously detected concentration of

Arsenic is not indicative of a "release" and likely due to fill material. The Remediation of

PAOC-11 is not required and the area is in compliance with the RSRs.

PAOC-12: Storage Area - Former Coal Room

The storage area is located to the north of the Armory's Former Coal Room and has been

designated PAOC-12. The COCs associated with the storage area - former coal room, include

ETPH and PAHs. The results of the Phase II SI did not detect any COCs associated with the

storage area - former coal room. Further investigation or remediation of PAOC-12 is not

warranted and the area is in compliance with the RSRs.

PAOC-13: Loading/Unloading Area

The loading/unloading area is located north of the FMS #5 and has been designated PAOC-13. Potential for spills to the pavement during the loading and unloading of materials exist. The

COCs associated with the loading/unloading area include ETPH, VOCs and metals. Soil

samples were collected from PAOC-13 as part of the RI. The results of the RI within PAOC-13

did not detect any COCs at concentrations above the applicable RSR criteria. Remediation of

PAOC-13 is not required and the area is in compliance with the RSRs.

PAOC-14: Hazardous Waste Satellite Accumulation Area

The hazardous waste satellite accumulation area is located within the interior of the FMS #5 and

has been designated PAOC-14. Potential for surface spills to the concrete and potential impacts

to sub-slab soil exists. The COCs associated with the hazardous waste satellite accumulation

area included ETPH, VOCs and metals. Investigation of PAOC-14 was conducted as part of this RI. The results of the RI indicated the presence of ETPH (573 ppm) in the concrete core sample

from within PAOC-14 at a concentration slightly exceeding the RDEC of 500 ppm but below the I/C-DEC and GB PMC of 2,500 ppm. No other COCs associated with the Hazardous Waste


Fonner Pawnee Complex Verification Report

Satellite Accumulation Area were detected in the concrete core sample. No COCs were detected

in the sub-slab soil sample collected from PAOC-14 at concentrations above analytical detection

limits (BRL). The concentration of ETPH detected was quantified as "other oil" and its presence

in the concrete is likely due to surface spills from site operations, which based on the analytical

results have not impacted sub-slab soils. Laboratory results for the sub-slab soil sample

collected from the same location did not contain ETPH at concentrations above analytical

detection limits. Given that the surface spills have not been released to the soil beneath the FMS

#5, the industrial/commercial nature of the facility and the concentration detected in the concrete

is below the I/C-DEC and GB PMC, additional investigation and remediation is not warranted at

this time. The FMS #5 was closed in 2008 and all hazardous materials and wastes were removed

from the building at that time. The RCRA Closure Report dated November 2007 indicated that

no further action was required for closure of the site in accordance with CTDEEP guidance;

PAOC-15: Parts Washing Station Location The parts washing station is located within the interior of the FMS #5 and has been designated

PAOC-15. Potential for surface spills to the concrete and potential impacts to sub-slab soil

exists. The COCs associated with the parts washer include ETPH, VOCs and metals.

Investigation of PAOC-15 was conducted as part of this RI. The results of the RI indicated the

presence of ETPH, Toluene, and Xylenes in the concrete core sampe from within PAOC-15 but

at concentrations below the applicable RSR criteria. No other COCs associated with the Parts

Washing Station Location were detected in the concrete core sample. The COCs detected in the

concrete are likely due to surface spills from site operations, which have not impacted sub-slab

soils. Laboratory results for the sub-slab soil sample collected from the same location did not

captain COCs at concentrations above analytical detection limits. Given that the surface spills

have not been released to the soil beneath the FMS #5 and the concentrations detected in the

concrete are below the applicable RSR criteria, additional investigation and remediation is not

warranted. The RCRA Closure Report dated November 2007 indicated that no further action

was required for closure of the site in accordance with CTDEEP guidance.



PAOC-16: Raw Material Storage Area The raw material storage area, virgin motor oil and anti-freeze, is located within the interior of

the FMS #5 and has been designated PAOC-16. Potential for surface spills to the concrete and

potential impacts to sub-slab soil exist. The COCs associated with the raw material storage area

included ETPH, VOCs, PAHs and metals. Investigation of PAOC-16 was conducted as part of

this RI. The results of the RI indicated the presence of ETPH and Xylenes in the concrete core

sample from within PAOC-16 but at a concentration below the applicable RSR criteria. No other

COCs associated with the Raw Material Storage Area were detected in the concrete core sample.

The COCs detected in the concrete are likely due to surface spills from site operations, which

have not impacted sub-slab soils. Laboratory results for the sub-slab soil sample collected from

the same location did not contain COCs at concentrations above analytical detection limits.

Given that the surface spills have not been released to the soil beneath the FMS #5 and the

concentrations detected in the concrete are below the applicable RSR criteria, additional

investigation and remediation is not warranted. The RCRA Closure Report dated November

2007 indicated that no further action was required for closure of the site in accordance with

CTDEP guidance.

PAOC-17: Battery Storage Area

The battery storage area is located within the interior of the FMS #5 and has been designated

PAOC-17. Potential for surface spills to the concrete and potential impacts to sub-slab soil exist.

The COCs associated with the battery storage area include lead and petroleum hydrocarbons.

Investigation of PAOC-17 was conducted as part of the RI. The results of the RI did not indicate

the presence of lead at concentrations above analytical detection limits. The results of the RI

indicated the presence of ETPH (640 ppm) in the concrete core sample from within PAOC-17 at

a concentration slightly exceeding the RDEC of 500 ppm but below the I/C-DEC and GB PMC

of 2,500 ppm. No other COCs associated with the Battery Storage Area were detected in the

concrete core sample. The concentration of ETPH detected was quantified as "other oil" and its



presence in the concrete is likely due to surface spills from site operations, which have not

impacted sub-slab soils. Laboratory results for the subslab soil sample collected from the same

location did not contain ETPH at concentrations above analytical detection limits (BRL). No

other COCs associated with PAOC-17 were detected in the sub-slab soil sample at

concentrations above an8:lytical detection limits (BRL). Given that the surface spills have not

been released to the soil beneath the FMS #5, the industrial/commercial nature of the facility and

the concentration detected in the concrete is below the I/C-DEC and GB PMC, additional

investigation and remediation is not warranted at this time. The RCRA Closure Report dated

November 2007 indicated that no further action was required for closure of the site in accordance

with CTDEEP guidance.

Site Groundwater

Three (3) monitoring wells were installed to determine if past site operations have impacted the

water quality at the Site. Monitoring well MW-1 was installed in the area of the former 2,500

gallon UST (Tank C) removed in 1990. Monitoring well MW-2 was installed downgradient of

the former 6,000 gallon UST (Tank A) removed in 1990. Monitoring well MW-3 was installed

south of the Armory in the area of the former unpaved parking lot. Groundwater ranged in depth

from 21-feet (MW-2) to 22.5-feet (MW-1) below ground surface and flows south-southwest

across at the Site. Groundwater was not encountered in any of the direct push borings advanced

during the various investigations and was not encountered during the numerous UST removals at the Site.

The results of the RI detected Chloroform in the one (1) monitor well, MW-1, at the Site, but at a

concentration below both the SWPC and RVC. Chloroform is a common laboratory chemical and its presence in the groundwater sample collected from MW-1 is likely due to laboratory

contamination as it was also detected in the laboratory blank and is not a substances associated with past site operations. Total Thallium, Dissolved Copper, and Zinc were detected in the

groundwater samples, but at concentrations below the applicable RSR criteria and are not

associated with historic site operations. No other substances were detected in the groundwater

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at the site at concentrations above analytical detection limits. The results of the investigation

indicated that a "plume" is not present at the Site and therefore compliance monitoring is not

required. The groundwater at the Site is in compliance with the RSRs and remediation is

not required.

3.1 Phase I Environmental Site Assessment Finding and Conclusions

A Phase I - Preliminary Assessment Report (Phase I) dated August 24, 2001 was prepared by

Knope Group Inc., Icetown, CT for the Parcel. Information from the 2001 Phase I as well as current

Parcel information is summarized below.

Site History

The Former Pawnee Complex is located at 100 Water Street in Pawnee,

Connecticut. The State of Connecticut (State) purchased the Parcel in 1923.

Prior to purchase by the State in 1923, the Parcel was owned by the Pawnee

Athletic Association (1912-1923) and by private citizens prior to 1912. A review of historic Sanborn Fire Insurance Maps for 1911 and 1919 show that the Parcel was undeveloped land

prior to purchase by the State in 1923.

The Parcel rectangular shaped and is approximately 1.6 acres in size. It is identified as Lot 330

on Map 2, Block 3760 on the town of Pawnee assessor maps. The Parcel is located at the

intersection of Water Street and Armory Street and is approximately 1,500-feet south of the

intersection of Connecticut Routes 27 and 11A.

The Pawnee Armory was constructed in 1923 and was used primarily for office space,

military training, and storage. The Armory building was utilized by military recruiters until its

closure in October 2011 and is currently unoccupied. The Field Maintenance Shop #5 (FMS #5)

was constructed in 1932 and was used for routine maintenance (vehicle fluid changes and light

repairs) on military vehicles. (See Phase I, pages 5-8).

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The Armory is a 3-story brick building and was used primarily for office space, military training,

and storage. A "Rifle Range" had been located in the basement of the Armory. According to

personnel the "Rifle Range" was remediated (See Section 5.0 of this report for further discussion

of these remedial activities) and at the time of the Phase I ESA that area was being used as the

Mess Hall. The boiler room is located in the northwest comer of the basement level and no

floor drains or pits were observed in the Armory building.

The FMS #5 contained a shop area, supply room, office, battery room, mechanical room and

locker rooms. A parts washing machine, hazardous waste satellite accumulation area, virgin

motor oil (55-gallon drum) and antifreeze (55-gallon drum) storage, and flammable storage

cabinets existed within the shop area. Solvent waste from the parts washer was stored in

containers with secondary containment in the hazardous waste satellite accumulation area and

was recycled by a private contractor. Small quantities of paints and lubricants were stored in the

flammable storage cabinets within the FMS #5. A floor drain in the mechanical room was piped

to an oil/water separator, which discharged to the municipal sanitary sewer. A hazardous waste

storage shed, containing battery acid, paint cans, parts cleaning solvents, and oil waste bin were

located on the Site until closure of the FMS #5 in 2008. The Armory building was used by the

military recruiters until its closure in October 2011. The retained the maintenance of the Parcel

until its transfer to the State of Connecticut Department of Administrative Services

(DAS) in June 2012. The Site is currently unoccupied and surrounded by a chain-link fence and

a locked gate.

Regulatory Compliance History

The Pawnee Complex included office space in the Armory and a maintenance shop in the

FMS #5. The FMS #5 building functioned primarily as a maintenance shop for general servicing

of military vehicles. Typical activities conducted at the FMS #5 included

maintenance services such as oil changes, minor part replacement, and minor "touch-up"

painting on military vehicles. During its occupancy of the Parcel, they had


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the following plans developed and implemented at the Site, an Integrated Contingency Plan

(ICP), Spill Prevention, Control and Countermeasure Plan (SPCCP) and Stormwater Pollution

Prevention Plan (SWPPP). They had implemented Best Management Practices (BMPs) and

utilized trained personnel for activities involving the handling and management of hazardous

wastes and materials.

The FMS #5 was a Resource Conservation and Recovery Act (RCRA) Small Quantity Generator

(SQG) with State Permit ID Number CTD892968696 and the waste stream consisted mainly of

ignitable waste (DOOl) such as parts cleaning solvents. All hazardous wastes, raw materials,

storage sheds, drums and containers used to store hazardous wastes and raw materials were

removed by in 2008 when the FMS #5 was closed. They notified the CTDEEP on January

17, 2008 of the status change of the FMS #5 from a SQG to a Conditionally

Exempt Small Quantity Generator of Hazardous Waste (CESQG). Closure of the RCRA storage

areas and tank systems that have been used to store hazardous waste for less than one hundred

and eighty (180) days was performed in accordance with the self-implementing requirements

pursuant of Section 22a-449(c)-102a of the Regulation of State Agencies, and by reference, 40

CFR Parts 262.34(a), 265.11, and 265.114. A RCRA Closure Report dated November 2007 was

prepared by Knope Group, Inc. for the and submitted with the

change of status notification to the CTDEEP.

Seven (7) underground storage tanks (USTs) and three (3) above ground storage tanks (ASTs)

have historically been on the parcel as detailed in the table below.



TABLE 1 - PETROLEUM STORAGE TANKS

Environmental Setting

The Parcel is located in located south of the intersection of Water Street (Route 27) and Little

Turnpike (Route 11) in the Town of Pawnee, Connecticut. The property is approximately 1.6-

acres in size and geographically is located at 41.264264 North latitude and -72.919919 West

longitude on the Pawnee, Connecticut United States Geological Survey (USGS) 7.5 minute topographic quadrangle. The Parcel is generally flat and located at an approximate elevation of

230-feet National Geodetic Vertical Datum (NGVD).

Groundwater

Groundwater beneath the site is classified by the CTDEEP as GB. The GB classification

indicates groundwater within a historically highly urbanized area or an area of intense industrial

activity and where public water supply service is available. Groundwater with this classification

may not be suitable for human consumption without treatment due to waste discharges, spills or

leaks of chemicals or land use impacts. Groundwater was encountered at a depth of 21.0 feet to

21.7 feet below grade and is assumed to flow in a southwestern direction across the site.


Tank ID Tank Type Capacity (Gallons)

Contents Installation Date

Removal Date

A UST 5,000 Heating Oil 1955 1990

B UST 2,500 Diesel 1973 1990

c UST 2,500 Gasoline 1973 1990

D UST 6,000 Heating Oil 1990 2008

E UST 3,000 Diesel 1990 2005

F UST 3,000 Gasoline 1990 2005

G UST ±1,500 Gasoline Prior to 1967 1995

H & I AST (2) 275 Waste Oil ± mid-1990s 2008

--- AST 2,000 Diesel 2005 2008


The Site is currently connected to and draws on-site water from the municipal supply,

administered by the Pawnee Water Department. According to the "Community Water

Systems in Connecticut" map, there are four (4) public water supply wells located within four (4)

miles of the subject site (See attached "Potable Well Survey Figure"). All four (4) wells are part

of the well field located approximately 3 1/2 miles west of the subject site and are operated by

the Town of Pawnee Public Works Department.

Surface Water

The Parcel is located within the Connecticut River Regional Basin and the Wamapoke River Sub-

Regional Drainage Basin. Site drainage is primarily via overland flow directed towards the

stormwater collection system that drains to the municipal stormwater sewer, which ultimately

discharges to Roblowe Brook. The Roblowe Brook, a Class "A" surface water body, is located

approximately 1,200 feet southwest of the site. The "A" classification indicates that the waters

are "presumed to meet.water quality criteria, which supports potential drinking water supply, fish

and wildlife habitat, recreational use, agricultural, industrial supply and other uses including

navigation." Roblowe Brook eventually discharges to the Wamapoke River, which has a Class

"C/B" surface water designation. A "C/B" designation indicates that the waters are "presently

not meeting Water Quality Criteria or not supporting one or more assigned designated uses due to pollution." The water quality goal is achievement of Class B Criteria and attainment of Class

B designated uses. No wetlands or surface water bodies are present on or in close proximity to the Site.

Geology

According to the Surficial Materials Map of Connecticut, the site is underlain by areas of sand

and gravel overlying sand. The matrix of these materials is composed of mixtures of gravel and

sand within individual layers and as alternating layers. A red-brown coarse to fine sand and silt

and fill material (approximately 2 to 4-feet below grade) was encountered in borings advanced at

the Site during the 2006 RI. According to the Bedrock Geologic Map of Connecticut, the site is

within the Hartford Basin of the Central Lowlands, which is underlain by Portland Arkose

Knope Inc. · Page 16 Project No. 12345.01


bedrock. Portland Arkose is described as a reddish brown arkose and is also known as

brownstone. Bedrock was not encountered at the Site during any of the environmental

investigations.

Description of Areas of Concern

PAOCs identified in the PA included former underground storage tank locations; above ground

storage tank (AST) locations; former unpaved parking and wash rack; outdoor waste storage

areas and; site spills. The report recommended limited soil sampling in these areas if transfer of

the property were to occur or if future construction activities at the site are planned.

Constituents of Concern The Constituents of Concern (COCs) associated with the historic uses at the Parcel identified

during the Phase I include; petroleum hydrocarbons, metals, volatile organic compounds

(VOCs), semi-volatile organic compounds (SVOCs) , and polychlorinated biphenyls (PCBs).

Conclusions

Recognized on-site environmental concerns that had the potential to impact site soil and

groundwater were identified at the Parcel including hazardous materials and waste storage areas;

present and former underground storage tank (UST) and AST locations; and site spills. These

recognized on-site environmental concerns associated with the have been fully

investigated and characterized as discussed below. A Phase II Environmental Site Investigation

was conducted at the site in accordance with applicable guidelines and industry standards to

document compliance with the RSRs.



3.2 Phase II Environmental Site Investigation Finding and Conclusions Knope Group Inc. conducted a Phase II Environmental Site Investigation (ESI) of the

Pawnee Armory in accordance with the Work Plan dated June 2, 2003. The purpose of this

investigation was to confirm the presence or absence of a "Release" of hazardous waste on-site

within the PAOC identified in the Phase I and determine the status of the site under the "Transfer

Act". The environmental investigation consisted of the advancement of thirty (30) direct push borings

to a maximum depth of twelve (12) feet or the groundwater interface, whichever was

encountered first. Soil samples were collected continuously, utilizing a 4-foot long (2-inch

diameter) Macro Core Sampler with dedicated acetate liners. The soil samples were visually inspected in the field for staining, and were described as to physical characteristics and soil types

and soil boring logs were generated in the field by the on-site qualified technician. In addition,

the soil samples were screened in the field for total VOCs utilizing a Photovac photoionization

detector (PID). Based upon field screening results and visual observations, one (1) soil sample

from each boring was collected and submitted for laboratory analyses.

The surficial soil sample (2 to 4 feet below the pavement or concrete) was selected, in the areas

adjacent to hazardous materials storage areas, above ground storage tanks, and equipment

storage areas. The subsurface soil sample (6 to 8 feet - approximate depth of tank bottom) was

selected, in the areas of former USTs, for laboratory analyses if field screening and visual

observations did not indicate the presence of contaminants. Soil samples were analyzed for the

following parameters, based on the potential contamination source and sample depth:

POL Storage Shed, Former UST G Location, AST Locations; Hazardous Waste Storage Shed

and Drum Storage Area

Direct push borings MAN-1 through MAN-10 were advanced proximate to the existing waste

ASTs; POL Storage Shed and Hazardous Waste Storage Shed; Drum Storage Area and Former

UST G located to the southwest and along the southern edge of the Armory. Soil samples

collected from these locations and analyzed for the following parameters based on past storage



practices: Extractable Total Petroleum Hydrocarbons (CT ETPH); Volatile Organic Compounds

(EPA Method 8260); Polynuclear Aromatic Hydrocarbons (EPA Method 8270); SPLP Priority

Pollutant 13 (PP-13) Metals; Polychlorinated Biphenyls (EPA Method 8082). · The potential

contamination sources were the waste ASTs, hazardous waste storage shed, drum and equipment

storage and the target analytes were metals, solvents, PCBs and petroleum hydrocarbons (based

on potential contamination sources and PA report).

Former USTs; Diesel AST; and Wash Rack

Direct push borings MAN-11 through MAN-30 were advanced in the area of former USTs A, B,

C, D, E and F; the fuel pump, diesel AST and wash rack located to north of the FMS Building

and west-northwest of the Armory. Soil samples collected from these locations were analyzed

for the following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH);

Polynuclear Aromatic Hydrocarbons (EPA Method 8270); SPLP Priority Pollutant 13 Metals;

Volatile Organic Compounds (EPA Method 8260). The potential contamination sources were the

former gasoline, diesel and heating oil USTs, oil/water separator and piping, former wash rack

and diesel AST. The target analytes were lead; diesel and gasoline range organics; and

petroleum hydrocarbon compounds (based on potential contamination sources).

The direct push borings were advanced to a depth of 12-feet below grade. Groundwater was not

encountered in any of the boring locations and groundwater samples were not collected as part

of the Phase II ESI.

The licensed driller for the project was Environmental Solutions (ES) of Bloomington, Connecticut and the Laboratory Contractor was Flax Environmental Laboratories, Inc. of

Pawnee and Environmental Analytical, Inc. of Haverford, Massachusetts. The fieldwork for the Phase II ESI investigation was conducted on June 26 and 27, 2003. The results from the Phase II

ESI are summarized below.



POL Storage Shed. Former UST G Location, AST Locations: Hazardous Waste Storage

Shed and Drum Storage Area

Soil samples MAN-1 through MAN -10 were collected and analyzed from these areas.

Laboratory results did not indicate the presence of PCBs at concentrations above analytical

detect limits in any of the soil samples collected. VOCs were not detected in any of the

soil samples analyzed, with the exception of methylene chloride, a common laboratory

contaminant

not associated with site operations, in sample, MAN-6 (2'-4') at a concentration well below

standards. ETPH was not detected in any of the samples analyzed, with the exception of one (1)

soil sample MAN-9 collected at a depth of 2' to 4'below grade within the former unpaved

parking area. The area was paved in 1995 and prior to paving vehicles parked on soil. The

concentration of ETPH (520 ppm) detected in soil sample MAN-9 (2'-4') slightly exceeded the

Residential Direct Exposure Criteria (RDEC). The petroleum hydrocarbon chromatogram was

not a perfect match with any of the standards and was quantified as an "unknown" material

with a chromatogram from C18 to C36. Various polycyclic aromatic hydrocarbons (PAHs) were

also detected in this soil sample, MAN-9 (2'-4') at concentrations slightly exceeding the

applicable criteria. Various total and leachable metals were detected in the soil samples,

but at concentrations below the applicable criteria.

Former USTs: Diesel AST: and Wash Rack

Soil samples MAN-11 through MAN-30 were collected and analyzed from these areas.

Laboratory results did not indicate the presence of PCBs at concentrations above analytical

detect limits in any of the soil samples collected. VOCs were not detected in any of the· soil

samples analyzed, with the exception of Naphthalene in soil sample MAN-18 (2'-4') at a low

concentration of 0.09 ppm, which is below the applicable criteria. Low concentrations of ETPH

were detected in three (3) soil samples, MAN-18 (2'-4'), MAN-21 (2'-4'), and MAN-27 (1'-4'),

collected from the below the pavement, at concentrations below the applicable criteria. Various

PAHs were detected in soil sample MAN-21 (2'-4') at concentrations exceeding the applicable

criteria. Various total and leachable metals were detected in the soil samples, but at

concentrations below the applicable criteria, with the exception of arsenic. Arsenic was detected



in two (2) soil samples, MAN-20 -2'-4' (11.9 ppm) and MAN-22-2'-4' (11.1 ppm) at

concentrations slightly exceeding the applicable criteria.

Conclusions and Recommendations Arsenic was detected in two (2) soil samples, MAN-20 and MAN-22, at concentrations

exceeding the RDEC and I/C-DEC of 10.0 ppm. These samples were collected from the fill

material at the Site at a depth of two (2) to four (4) feet below grade. In 1995 a Site

Improvements Project was conducted by the Defense Department. The project included placement

of fill material below the pavement section as part of the grading and drainage improvements to

the Site. The RSRs state that, "compliance with a direct exposure criterion is achieved when, the ninety-five percent upper confidence level (95% UCL) of the arithmetic mean of all sample

results of laboratory analyses of soil from the subject release area is equal to or less than such criterion, provided that the results of no single sample exceed two times the applicable direct

exposure criterion." Calculation of the 95% UCL for Arsenic concentrations within the 2'-4' stratigraphy (fill material encountered at the Site) indicate that compliance with the direct

exposure criterion for Arsenic has been achieved. The value calculated for the twenty-two (22)

samples collected from this depth is 5.55 ppm, which is below the RDEC of 10.0 ppm and

compliance with the RSRs has been achieved for arsenic at the site. · One (1) soil sample, MAN-9 (2'-4'), contained petroleum hydrocarbons at a concentration of

520 ppm, which slightly exceeds the RDEC of 500 ppm. The sample was collected from beneath

the former unpaved parking area to the south of the Armory building. The petroleum

hydrocarbon was quantified as "unidentified" by the laboratory and is likely from an incidental

source, such as parked motor vehicles, and not the result of a "release" of hazardous materials at

the site. The area was paved in 1995 and prior to that vehicles parked on soil.

One (1) soil sample, MAN-21 (2'-4'), contained PAHs at concentrations exceeding applicable

standards. The concentrations of PAHs detected are greater than two (2) times the applicable standards and calculation of the 95% UCL for comparison to the RSRs does not apply. Sample,


r Former Pawnee Complex Verification Report

MAN-21 is located in the beneath the pavement in the area of Former UST A and Former UST D

(removed in 2008 subsequent to the Phase II investigation). Based on the results of the Phase I

and Phase II investigations, data gaps were identified and additional investigation of the Parcel

was recommended to determine if detected substances are indicative of a "release" or due to

"incidental sources" and if remediation to achieve compliance with the RSRs is required. The

Phase II SI recommended collection and analysis of additional soil samples from the AOC's in

which substances were detected above analytical detection limits to determine the source and

extent of impacted soil, potential remedial actions if required and status of the Site with regard to

the Transfer Act. A Phase III Remedial Investigation (RI) of the site was conducted and is

discussed below.

3.3 Phase III Remedial Investigation Finding and Conclusions

'

Knope Group Inc. conducted a Phase III RI in the AOCs requiring further investigation based

on the Phase II results and the PAOCs detailed in the Conceptual Site Model (CSM) below.


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[ The RI consisted of a soil vapor screening survey and the collection of soil, groundwater, and

concrete samples as detailed in the Sampling and Analysis Plan (SAP) contained in the Phase III

Remedial Investigation Work Plan dated October 3, 2006 prepared by Knope Group.

[ The following preliminary CSM was developed based on the Phase I and Phase II results.

I AOC-1: Empty ("New'') Drum Storage Area The empty ("new" drum storage area was located along the southern exterior wall of the Armory

l and was designated AOC-1. ETPH was detected in soil sample MAN-9 (2'-4') during the Phase

II ESI collected beneath the pavement section. Prior to 1995 the area south of the Armory was

[ unpaved and vehicles parked on soil. Additional soil samples were collected at a depth of 2 to 4- feet below ground surface from this area during the RI to determine if the ETPH detected was

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Project No. 12345.01

AOC/PAOC # Description 1 Empty ("New") -Drum Storage Area 2 Former Tank A & Tank D (Removed 2008), 6,000 Gallon Heating

Oil Undrground Storage Tanks (USTs) 3 POL Shed, Used Oils Above Ground Storage Tanks (ASTs) and

Hazardous Waste Storage Shed 4 Former Tank G, 1,500 Gallon Gasoline UST Location 5 Oil/Water Separator Location 6 Former Tank B, 2,500 Gallon Diesel UST Location 7 Former Tank F, 3,000 Gallon Gasoline UST 8 Former Tanks C & E, 2,500 Gallon Gasoline UST & 3,000 Gallon

Diesel UST Location 9 Drum Storage Area 10 Former Unpaved Parking Area 11 Former Waste Oil UST 12 Storage Area -Farmer Coal Room 13 Loading/Unloading Area 14 Hazardous Waste Satellite Accumulation Area 15 Parts Washing Station Location 16 Raw Material Storage Area 17 Battery Storage Area 18 Site Groundwater

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associated with incidental sources from the former unpaved parking area and not due to a release

from the empty ("new") drum storage area.

r AOC-2: Former Tank A & Existing Tank D, 6,000 Gallon Heating Oil Underground Storage Tanks (USTs) The former (Tank A) and existing (Tank D) 6,000 gallon heating oil (removed 2008) USTs were

ri located adjacent to the northwest comer of the Armory and were designated AOC-2. Tank A

was removed and replaced with Tank D in 1990 and Tank D was removed in 2008 subsequent to

( the Phase III RI. COCs associated with the former and existing USTs included ETPH, VOCs,

and PAHs. The results of the Phase II ESI indicated that soils in the vicinity of the tanks may

r have been impacted. Further investigation to determine if the PAHs detected in soil

sample MAN-21 (2'-4') were associated with the tanks or incidental source (pavement section) was recommended and conducted as part of the remedial investigation.

PAOC-3: Petroleum, Oil and Lubricant (POL) Shed, Used Oil Above Ground Storage Tanks (ASTs) and Hazardous Waste Storage Shed The POL shed, used oil ASTs and hazardous waste storage shed are located along the northwest

[ exterior wall of the Armory and have been designated PAOC-3. Potential for surface spills from the POL Shed, ASTs, and Hazardous Waste Storage Shed to the surrounding ground exists. The

I COCs associated with PAOC-3 include ETPH, VOCs, PAHs and metals. The results of the Phase II SI detected several PAHs at concentrations above analytical detection limits but below

1 the applicable RSRs Criteria in soil at depths of 2 to 4-feet below grade. Additional soil samples were collected at the same depth from PAOC-3 as part of the RI to determine if impacts to soil

have occurred within the area.

PAOC-4: Former Tank G, 1,500 Gallon Gasoline UST Location Former Tank G, 1,500 gallon gasoline UST was located adjacent to the northeast comer of the

FMS #5 and has been designated PAOC-4. Tank G was removed in 1995 and analytical results

from the tank removal did not detect any COCs at concentrations above analytical detection

I limits. COCs associated with the former UST include ETPH, VOCs, and metals. The results of


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the Phase II SI did not detect any COCs associated with the former UST and further investigation

of the area was not conducted as part of the RI. Additional investigation or remediation of

I PAOC-4 is not warranted and the area is in compliance with the RSRs.

PAOC-5: Oil/Water Separator Location

The oil/water separator is located adjacent to the northwest comer of the FMS #5 and has been

designated PAOC-5. Potential spills from pumping of the oil/water separator exist. The COCs [ associated with PAOC-5 include ETPH and metals. The results of the Phase II SI detected

ETPH and pyrene in soil at a depth of 1 to 4-feet below grade at concentrations above analytical [ detection limits but below the applicable RSRs Criteria. Additional soil samples were collected

at the same depth from PAOC-5 as part of the RI to determine if impacts to soil have occurred

within the area.

[, PAOC-6: Former Tank B, 2,500 Gallon Diesel UST Location Former Tank B, 2,500 gallon diesel UST was located north of the FMS #5 and east of the

1 existing AST and has been designated PAOC-6. The COCs associated with PAOC-6 include

ETPH and PAHs. The results of the Phase II SI detected several PAHs at concentrations above

analytical detection limits but below the applicable Remediation Standard Regulations (RSRs)

Criteria in soil at a depth of 6 to 8-feet below grade. Additional soil samples were collected at

[ the same depth from PAOC"".6 as part of the RI to determine if impacts to soil have occurred within the area.

[ PAOC-7: Former Tank F, 3,000 Gallon Gasoline UST

Former Tank F, 3,000 gallon gasoline UST was located north of the FMS #5 and north of the

existing AST and has been designated PAOC-7. The COCs associated with PAOC-6 include

ETPH and VOCs. The results of the Phase II SI did not detect any COCs associated with the 1f 1 former UST and further investigation of the area was not conducted as part of the RI. Additional

( investigation or remediation of PAOC-7 is not warranted and the area is in compliance with the

RSRs.

i PAOC-8: Former Tanks C & E, 2,500 Gallon Gasoline UST & 3,000 Gallon Diesel UST


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Location

Former Tanks C & E, 2,500-gallon Gasoline and 3,000-gallon Diesel USTs were located north of

the PMS #5 and northwest of the existing AST and have been designated PAOC-8. The COCs r associated with PAOC-8 include ETPH, VOCs and PAHs. The results of the Phase II SI

r - detected ETPH and several PAHs at concentrations above analytical detection limits but below

the applicable RSRs Criteria in soil at a depth of 2 to 4-feet below grade. Additional soil

samples at the same depth were collected from PAOC-8 as part of the RI to determine if impacts

to soil have occurred within the area. In addition, a groundwater monitoring well was installed

[ in the area of the former tanks to determine if impacts to groundwater have occurred.

PAOC-9: Drum Storage Area The drum storage area is located adjacent to the northwest comer of the Armory and has designated PAOC-9. COCs associated with the drum storage area include ETPH and VOCs.

I The results of the Phase II SI did not detect any COCs associated with the drum storage area and

further investigation of the area was not conducted as part of the RI. Additional investigation or

[ remediation of PAOC-9 is not warranted and the area is in compliance with the RSRs.

PAOC-10: Former Unpaved Parking Area The PA indicated that an unpaved parking area was formerly located to the south of the Armory

and has been designated PAOC-10. According to the PA the area was paved in 1995. The

potential exists that leakage of vehicle fluids has impacted surficial soils in the area. COCs

( associated with the former unpaved parking area include ETPH, PAHs and VOCs. The results of the Phase II SI detected several PAHs at concentrations above analytical detection limits but

below the applicable RSRs Criteria in soil at a depth of 2 to 4-feet below grade. Additional soil

samples were collected at the same depth from PAOC-10 as part of the RI to determine if

·[ impacts to soil have occurred within the area.

PAOC-11: Former Waste Oil UST

The former waste oil UST was located along the northern boundary of the Site and along the

southern of edge of Armory Street and has been designated PAOC-11. The COCs associated

with the former waste oil tank include ETPH and Polychlorinated Biphenyls (PCBs). The results


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I" of the Phase II SI did not detect any COCs associated with the former waste oil UST. However,

total arsenic was detected in the fill material beneath the pavement section at a concentration,

[ which exceeds the DEC. Additional soil samples were collected at the same depth from the area

of the elevated total arsenic concentration, MAN-20, to determine if the detected concentration is

[ associated with a release from site operations or due to fill material beneath the pavement section

from site improvements to the area. Further investigation of PAOC-11 was conducted as part of

r the RI.

PAOC-12: Storage Area - Former Coal Room The storage area is located to the north of the Armory's Former Coal Room and has designated PAOC-12. The COCs associated with the storage area - former coal room, include ETPH and

I PAHs. The results of the Phase II SI did not detect any COCs associated with the storage area - former coal room and further investigation of the area was not conducted as part of the RI.

"

Additional investigation or remediation of PAOC-12 is not warranted and the area is in


PAOC-13: Loading/Unloading Area

[ " The loading/unloading area is located north of the FMS #11 and has been designated PAOC-13. Potential for spills to the pavement during the loading and unloading of materials exist. The

I COCs associated with the loading/unloading area include ETPH, VOCs and metals. Additional soil samples were collected from PAOC-13 as part of the RI to determine if impacts to soil have

II occurred within the area.

PAOC-14: Hazardous Waste Satellite Accumulation Area The hazardous waste satellite accumulation area is located within the interior of the FMS #5 and

has been designated PAOC-14. Potential for surface spills to the concrete and potential impacts

to sub-slab soil exists. The COCs associated with the hazardous waste satellite accumulation area include ETPH, VOCs and metals. Investigation of PAOC-14 was conucted as part of the

( RI to determine if impacts to concrete and sub-slab soil have occurred within the area.

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I PAOC-15: Parts Washing Station Location The parts washing station is located within the interior of the FMS #5 and has been designated

I PAOC-15. Potential for surface spills to the concrete and potential impacts to sub-slab soil

exists. The COCs associated with the parts washer include ETPH, VOCs and metals.

Investigation of PAOC-15 was conducted as part of the RI to determine if impacts to

concrete and sub-slab soil have occurred within the area. -

PAOC-16: Raw Material Storage Area

The raw material storage area, virgin motor oil and anti-freeze, is located within the interior of

the FMS #5 and has been designated PAOC-16. Potential for surface spills to the concrete and

potential impacts to sub-slab soil exist. The eoes associated with the raw material storage area

include ETPH, VOCs, PAHs and metals. Investigation of PAOC-16 was conducted as part

of the RI to determine if impacts to concrete and sub-slab soil have occurred within the area.


I The battery storage area is located within the interior of the FMS #5 and has been designated PAOC-17. Potential for surface spills to the concrete and potential impacts to sub-slab soil exist.

I The COCs associated with the lead battery storage area include ETPH and lead. Investigation

of PAOC-17 was conducted as part of the RI to determine if impacts to concrete and sub-slab

soil have occurred within the area.

SAMPLING AND ANALYSIS PLAN The following Sampling and Analysis Plan . (SAP) was developed and conducted as part of the

I Phase III Remedial Investigation of the Parcel.

Soil Vapor Screening

I Knope conducted a soil vapor screening of the Site in accordance with the CTDEEP Guidance Document for Soil Vapor Sampling, dated June 12, 2000 and as detailed below. Twenty (20)

I vapor probes were installed at the Site proximate to the building, former USTs and fuel island as shown on the attached Figure 3 and designated SG-#. A representative soil vapor sample was

I collected from each location, stored in a tedlar bag and analyzed for volatile organic compounds

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Page 28 Project No. 12345.01

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(VOCs), particularly Benzene, Toluene, Ethyl Benzene and Xylenes (BTEX) by a portable gas

chromatograph (GC).

r Soil Sampling Twenty (20) direct push borings were advanced within the AOC's and PAOC's identified in the

r preliminary CSM requiring further investigation and as detailed below.

r A OC-1: Empty Drum Storage Area Three (3) direct push borings were advanced within AOC-1, Empty Drum Storage Area based

l upon the results of previous investigations. The borings were advanced in the area of the documented ETPH exceedance in soil at a depth of 2 to 4-feet below grade. Based on field

r observations, one (1) soil sample (2 to 4-feet below grade) was collected from each boring

location for a total of three (3) soil samples which were analyzed for the following parameters:

Extractable Total Petroleum Hydrocarbons (CT ETPH); Volatile Organic Compounds ( EPA

Method 8260); Polycyclic Aromatic Hydrocarbons (EPA Method 8270); and Synthetic r Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals.

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I AOC-2: Former Tank A & Existing Tank D, 6,000 Gallon Heating Oil USTs

Three (3) direct push borings were advanced and one (1) monitor well, MW-2, was installed

I within AOC-2, Former Tank A & Existing Tank D (removed 2008), 6,000 Gallon Heating Oil

USTs. The boring locations and monitor well location were chosen based upon a review of

previous investigations. The borings were advanced in the area of documented PAH

exceedances in soil at a depth of 2 to 4-feet below grade. The monitor well was located within

the area to determine if the water quality in the area had been impacted. A total of four (4) soil

,- samples were collected from AOC-2 and submitted to the laboratory for analyses for the

following parameters: Total Petroleum Hydrocarbons (8100 Modified, with Professional Opinion

,- of "Weathered" Heating Oil vs. "New Release"), Volatile Organic Compounds (EPA Method

8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270), Synthetic Precipitation

Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals.

r PAOC-3: POL Shed, Used Oil ASTs and Hazardous Waste Storage Shed

I Two (2) direct push borings were advanced within PAOC-3, POL Shed, Used Oil ASTs and

Hazardous Waste Storage Shed as shown on the attached Figure 3. The boring locations were

I chosen based upon a review of previous investigations which indicated PAHs at concentrations

above analytical detection limits but below RSR criteria in soil at a depth of 2 to 4-feet below

I grade. The borings were advanced in the area to determine if soils have been impacted by past

and present site usage. A total of two (2) soil samples were collected from PAOC-3 at a depth of

I 2 to 4-feet below grade and submitted to the laboratory for analyses for the following

parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile Organic

I .Compounds (EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270),

Synthetic Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals, and

I Polychlorinated Biphenyls (PCBs) (EPA Method 8082).

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[ - PAOC-5: Oil/Water Separator Location

Two (2) direct push borings were advanced within PAOC-5, Oil/Water Separator Location as

[ shown on the attached Figure 3. The boring locations were chosen · based upon a review of previous investigations which indicated ETPH and pyrene in soil at a depth of 2 to 4-feet below

[ grade at concentrations above analytical detection limits but below the applicable RSR criteria. The borings were advanced in the area to determine if subsurface soils have been impacted by

past and present site usage. A total of two (2) soil samples were collected from PAOC-5 and

submitted to the laboratory for analyses for the following parameters: Extractable Total

[ Petroleum Hydrocarbons (CT ETPH), Volatile Organic Compounds (EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270), Synthetic Precipitation Leaching

[ Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals, and Polychlorinated Biphenyls (PCBs) (EPA Method 8082).

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PAOC-6: Former Tank B, 2,500 Gallon Diesel UST Location

[ One (1) direct push boring was advanced within PAOC-6, Former Tank B, 2,500 Gallon Diesel

UST Location as shown on the attached Figure 3. The boring location was chosen based upon a

l review of previous investigations which indicated the presence of PAHs in soil at a depth of 6 to 8-feet below grade at concentrations above analytical detection limits but below the applicable

[ RSR criteria. The boring was advanced in the area to determine if subsurface soils have been impacted by past and present site usage. One (1) soil sample was collected from PAOC-6 and

l submitted to the laboratory for analyses for the following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile Organic Compounds (EPA Method 8260),

[ Polycyclic Aromatic Hydrocarbons (EPA Method 8270), Synthetic Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals.

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I I - Former Pawnee Complex Verification Report

PAOC-8: Former Tanks C & E, 2,500 Gallon Gasoline UST & 3,000 Gallon Diesel UST Location

I Two (2) direct push borings were advanced and one (1) monitor well, MW-1, was installed

within PAOC-8, Former Tanks C & E, 2,500-gallon Gasoline UST & 3,000-gallon Diesel UST

Location as shown on the attached Figure 3. The boring locations and monitor well location

were chosen based upon a review of previous investigations which indicated the presence of

r ETPH and PAHs at concentrations above analytical detection limits but below the applicable RSR criteria in soil at a depth of 2 to 4-feet below grade. The borings were advanced in the area

I to determine if subsurface soils and groundwater have been impacted by past and present site

usage. Four (4) soil samples were collected from PAOC-8 and submitted to the laboratory for

I analyses for the following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH),

Volatile Organic Compounds (EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA

I Method 8270), and Synthetic Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP- 13) Metals.

I PAOC-10: Former Unpaved Parking Area

Two (2) direct push borings were advanced and one (1) monitor well, MW-3, was installed

within PAOC-10, Former Unpaved Parking Area as shown on the attached Figure 3. The boring

locations and monitor well location were chosen based upon a review of previous investigations

which indicated the presence of PAHs at concentrations above analytical detection limits but

below the RSR criteria in soil at a depth of 2 to 4-feet below grade. The borings were advanced

in the area to determine if subsurface soils and groundwater have been impacted by past and

present site usage. Three (3) soil samples were collected from PAOC-10 and submitted to the

laboratory for analyses for the following parameters: Extractable Total Petroleum Hydrocarbons

(CT ETPH), Volatile Organic Compounds (EPA Method 8260), Polycyclic Aromatic

Hydrocarbons (EPA Method 8270), Synthetic Precipitation Leaching Procedure (SPLP) Priority

Pollutant 13 (PP-13) Metals, and Polychlorinated Biphenyls (PCBs) (EPA Method 8082).

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r Fonner Pawnee Complex Verification Report

r PAOC-11: Former Waste Oil UST

Three (3) direct push borings were advanced adjacent to PAOC-11, Former Waste Oil UST as

r shown on the attached sample location Figure 3. The boring locations were chosen based upon a

review of previous investigations, which indicated the presence of arsenic a a concentration

r exceeding the RSR criteria and PAHs at concentrations above analytical detection limits but below the applicable RSR criteria in soil at a depth of 2 to 4-feet below grade. The borings were

r advanced in the area of the documented exceedance to determine if the detected contaminant (arsenic) is associated with the fill material beneath the pavement section or a release. Three (3)

r soil samples were collected from PAOC-11 and submitted to the laboratory for analyses for the

r - following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile Organic

Compounds (EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270),

Synthetic Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals, and r Polychlorinated Biphenyls (PCBs) (EPA Method 8082).

r PAOC-13: Loading/Unloading Area

Two (2) direct push borings were advanced adjacent to PAOC-13, Loading/Unloading as shown

on the attached Figure 3. The borings were advanced in the area to determine if subsurface soils

have been impacted by past and present site usage. Two (2) soil samples were collected from

PAOC-13 at a depth of 2 to 4-feet below grade and submitted to the laboratory for analyses for

r the following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile

Organic Compounds (EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method

[ 8270), Synthetic Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals, and Polychlorinated Biphenyls (PCBs) (EPA Method 8082).

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I PAOC-14: Hazardous Waste Satellite Accumulation Area

The concrete slab in the area of the Hazardous Waste Satellite Accumulation Area was cored to

allow collection of both a concrete core/chip sample and sub-slab soil sample from PAOC-14, as

shown on the attached Figure 3. The concrete and soil samples collected at this location were

analyzed for the following parameters: Extractable Total. Petroleum Hydrocarbons (CT ETPH),

Volatile Organic Compounds ( EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA

Method 8270), Polychlorinated Biphenyls (PCBs) (EPA Method 8082), and Synthetic

Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals.

I PAOC-15: Parts Washing Station Location

The concrete slab in the area of the Parts Washing Station was cored to allow collection of both a

concrete core/chip sample and sub-slab soil sample from PAOC-15, as shown on the attached

Figure 3. The concrete and soil samples collected at this location were analyzed for the

following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile Organic

Compounds ( EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270),

Synthetic Precipitation Leaching Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals, and

I Polychlorinated Biphenyls (PCBs) (EPA Method 8082).

I PAOC-16: Raw Material Storage Area

The concrete slab in the area of the Raw Material Storage was cored to allow collection of both a



following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile Organic

Compounds ( EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270),

Polychlorinated Biphenyls (PCBs) (EPA Method 8082), and Synthetic Precipitation Leaching

l Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals.


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r PAOC-17: Battery Storage Area

I The concrete slab in the area of the Battery Storage Area was cored to allow collection of both a



following parameters: Extractable Total Petroleum Hydrocarbons (CT ETPH), Volatile Organic r Compounds ( EPA Method 8260), Polycyclic Aromatic Hydrocarbons (EPA Method 8270),

Polychlorinated Biphenyls (PCBs) (EPA Method 8082), and Synthetic Precipitation Leaching

. Procedure (SPLP) Priority Pollutant 13 (PP-13) Metals.

I Groundwater Sampling

Groundwater samples- were collected from the three (3) groundwater monitor wells installed as

part of the RI. The monitor wells were installed within AOC-2, PAOC-8 and PAOC-10

(downgradient from AOC-1) as shown on the attached Figure 3. The wells were constructed of

2-inch PVC and were screened ten (10) feet into the groundwater table (See attached Well

I Drilling Completion Reports). Following well stabilization, groundwater samples were collected from the three (3) wells in accordance with CTDEEP's low flow sampling procedures and

I analyzed for the following parameters: Extractable. Total Petroleum Hydrocarbons (CT-ETPH

Method); Volatile Organic Compounds (EPA Method 8270); Priority Pollutant Metals (EPA

I Methods 7471 and 6010); and Polycyclic Aromatic Hydrocarbons (EPA Method 8270).

I Phase III Remedial Investigation Results

Soil Vapor Screening Results Knope conducted a soil vapor survey of the areas of environmental concern identified at the

Site on October 19 and 20, 2006. Twenty (20) vapor probes, SG-1 through SG-20, were

installed at the Site proximate to the building and former USTs as shown on the attached Figure

[ 3. The survey was conducted to determine if soil vapors are present at concentrations exceeding


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the RSRs for soil vapor. The soil vapor survey was conducted by Logical Environmental

Solutions under the supervision of Knope. A one (1) inch solid steel probe rod with an

expendable point was driven into the ground to a depth of approximately five (5) feet below

grade at the proposed sample locations. The sample rod was retracted to approximately 4.5 feet

below grade and the expendable point was disengaged. The annular space did not need filling

because the drive point was smaller than the probe rod diameter. A stainless steel sampling port

with dedicated neoprene tubing was attached to the probe rod. The tubing was connected to a

Geoprobe vacuum/volume air sampling pump. A minimum of 3 liters of soil vapor was purged

from _each borehole location prior to sample collection. After purging the borehole, the sample

tubing was connected to a vacuum box containing a dedicated 1 liter tedlar sampling bag. The

tedlar sampling bag was allowed to fill with soil vapor under a vacuum and was sealed. A soil

vapor sample was extracted from the tedlar bag utilizing a dedicated stainless steel syringe. Each

tedlar bag sample was screened in the field for total VOCs utilizing a Photovac photoionization

detector (PID). Total VOCs were detected at concentrations ranging from 0.0 vapor parts per

million (vppm) to 2.6 vppm using the PID.

Soil Sample Results

AOC-1: Empty ("New'') Drum Storage Area

Three (3) direct push borings, MAN-48 through MAN-50 were advanced within AOC-1, Empty

("New") Drum Storage Area as shown on the attached Figure 3. One (1) soil sample was

collected from each boring location at a depth of 2 to 4-feet below grade and submitted to the

laboratory for analysis. The laboratory results did not indicate the presence of ETPH, VOCs, and

SPLP PP-13 Metals at concentrations above analytical detection limits (BRL) in any of the soil

samples. Two (2) PAH compounds, Fluoranthene (0.15 ppm) and Pyrene (0.146 ppm) were

detected at low concentrations in soil sample MAN-48 (2'-4') below the applicable RSR criteria. .

No other PAHs were detected at concentrations above analytical detection limits (BRL). The

presence of these compounds and the previously detected PAHs in the soil is not indicative of a

"release" due to site operations. The compounds were detected beneath the pavement section

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and their presence is likely due to an incidental release from motor vehicle parking in the area.

Prior to 1995 the area was unpaved and vehicles parked on soil.

AOC-2: Former Tank A & Tank D (Removed 2008), 6,000 Gallon Heating Oil USTs Three (3) direct push borings, MAN-32, MAN-33 and MAN-43 and one (1) monitoring well

MW-2 were advanced within AOC-2, Former Tank A & Tank D, 6,000 Gallon Heating Oil

USTs as shown on the attached Figure 3. Two (2) soil samples, 2'-4' (depth of previous ETPH

and PAH exceedances) and 4'-8' (bottom of tank) below grade were collected. In addition a soil

sample MW-2 (10'-'12') was collected during the monitoring well installation. The soil samples

were collected from each boring location and submitted to the laboratory for analysis for ETPH, VOCs, PAHs, and SPLP PP-13 Metals. The laboratory results did not indicate the presence of

I ETPH, VOCs, PAHs and SPLP PP-13 Metals at concentrations above analytical detection limits

(BRL) in any of the soil samples collected from within AOC-2.

PAOC-3: POL Shed, Used Oil ASTs and Hazardous Waste Storage Shed

I: Two (2) direct push borings, MAN-45 and MAN-46, were advanced within PAOC-3, POL Shed, Used Oil ASTs and Hazardous Waste Storage Shed as shown on the attached sample location

[ Figure 3. One (1) soil sample was collected from each boring location at a depth of 2 to 4-feet

below grade and submitted to the laboratory for analysis for ETPH, VOCs, PAHs,

I Polychlorinated Biphenyls (PCBs) and SPLP PP-13 Metals. The laboratory results did not

indicate the presence of VOCs, PCBs and SPLP PP-13 Metals at concentrations above analytical

I detection limits (BRL) in any of the soil samples. ETPH (80.8 ppm) and the PAH compound,

Fluoranthene (0.137 ppm) were detected in soil sample MAN-45 (2'-4') but at concentrations

I below the applicable RSR criteria. ETPH and PAHs were not detected at concentrations above

analytical detection limits (BRL) in soil sample MAN-46 (2'-4'). The presence of these

I compounds and the previously detected PAHs in the soil is not indicative of a "release" due to site operations. The compounds were detected beneath the pavement section and their presence

r is likely due to an incidental release from motor vehicle parking in the area. Prior to 1995 the area was unpaved and vehicles parked on soil.

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PAOC-5: Oil/Water Separator Location Two (2) direct push borings, MAN-38 and MAN-39, were advanced within PAOC-5, Oil/Water

Separator Location as shown on the attached sample location Figure 3. One (1) soil sample was

collected from each boring location at a depth of 4 to 8-feet below grade and submitted to the

laboratory for analysis for ETPH, VOCs, PAHs, PCBs and SPLP PP-13 Metals. The laboratory

results did not indicate the presence of ETPH, PAHs, PCBs and SPLP PP-13 Metals at

concentrations above analytical detection limits (BRL) in any of the soil samples. Toluene

(0.0076 ppm) was detected in soil sample MAN-38 (4'-8') but at a concentration below the

applicable RSR criteria. No other VOCs were detected in either soil sample at concentrations

above analytical detection limits (BRL).

I PAOC-6: Former Tank B, 2,500 Gallon Diesel UST Location One (1) direct push boring, MAN-42, was advanced within PAOC-6, Former Tank B, 2,500

I Gallon Diesel UST Location as shown on the attached sample location Figure 3. One (1) soil sample was collected from the boring location and submitted to the laboratory for analysis for

I ETPH, VOCs, PAHs, and SPLP PP-13 Metals. The laboratory results did not indicate the

presence of ETPH, VOCs, PAHs, and SPLP PP-13 Metals at concentrations above analytical

detection limits (BRL) in the soil sample, MAN-42 (4'-8').

PAOC-8: Former Tanks C & E, 2,500 Gallon Gasoline UST & 3,000 Gallon Diesel UST Location Two (2) direct push borings, MAN-36 and MAN-37, were advanced and one (1) monitor well,

MW-1, was installed within PAOC-8, Former Tanks C & E, 2,500-gallon Gasoline UST

& 3,000-gallon Diesel UST Location as shown on the attached sample location Figure 3. One

(1) shallow soil sample was collected from each boring and well location and one (1) deeper

sample (4'-8') was also collected from boring location MAN-36 and submitted to the

laboratory for analysis for ETPH, VOCs, PAHs, and SPLP PP-13 Metals. The laboratory

results did not indicate the presence of ETPH, PAHs, and VOCs at concentrations above

analytical detection limits (BRL) in any of the soil samples. SPLP Zinc (0.0064 ppm) was

detected in soil sample

I MW-1 (10'-12') but at a concentration below the applicable RSR criteria No other SPLP PP-13


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I Metals were detected in any of the soil samples at concentrations above analytical detection

limits (BRL).

PAOC-10: Former Unpaved Parking Area Two (2) direct push borings, MAN-44 and MAN-47, were advanced and one (1) monitor well,

MW-3, was installed within PAOC-10, Former Unpaved Parking Area as shown on the

attached Figure 3. One (1) soil sample was collected from each boring at a depth of 2 to 4-

feet below grade and well location and submitted to the laboratory for analysis for ETPH,

VOCs, PAHs, PCBs and SPLP PP-13 Metals. The laboratory results did not indicate the

presence of ETPH, PAHs, VOCs, and PCBs at concentrations above analytical detection

limits (BRL) in any of the soil samples. SPLP Zinc (0.0061 ppm) was detected in soil

sample MW-1 (10'-12') but at a concentration below the applicable RSR criteria. No other

SPLP PP-13 Metals were detected in any of the soil samples at concentrations above analytical

detection limits (BRL). The presence of the previously detected PAHs in the soil is not

indicative of a "release" due to site operations.

I_ The compounds were detected beneath the pavement section and their presence is likely due to

an incidental release from motor vehicle parking in the area. Prior to 1995 the area was unpaved

I and vehicles parked on soil.

I PAOC-11: Former Waste Oil UST Three (3) direct push borings, MAN-31, MAN-34 and MAN-35 were advanced adjacent to

I PAOC-11, Former Waste Oil UST as shown on the attached Figure 3. One (1) shallow soil sample (2'-4' below grade) was collected from each boring and one (1) deeper sample (4'-8'

r below grade) was also collected from boring location MAN-31 and submitted to the laboratory

for analysis for ETPH, VOCs, PAHs, PCBs, and SPLP PP-13 Metals. The laboratory results did

I not indicate the presence of ETPH, VOCs, and PCBs at concentrations above analytical detection limits (BRL) in any of the soil samples. SPLP Lead (0.0112 ppm) was detected in soil sample

I MAN-35 (2'-4') but at a concentration below the applicable RSR criteria. No other SPLP PP-13 Metals were detected in any of the soil samples at concentrations above analytical detection

I limits (BRL). The PAH compounds, Fluoranthene (0.189 ppm) and Pyrene (0.168 ppm) were


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detected in soil sample MAN-35 (2'-4') but at concentrations below the applicable RSR criteria.

No other PAH compounds were detected in any of the soil samples at concentrations above

analytical detection limits (BRL). The presence of these compounds and the previously detected

PAHs not indicative of a release from the tank and is likely due to incidental releases associated

with the paving operations conducted in the area as part of the Site Improvements Project in

1995.

PAOC-13: Loading/Unloading Area Two (2) direct push borings, MAN-40 and MAN-41, were advanced adjacent to PAOC-13,

Loading/Unloading as shown on the Figure 3. One (1) soil sample at a depth of 2 to 4-feet below

[ grade was collected from each boring location and submitted to the laboratory for analysis for

ETPH, VOCs, PAHs, PCBs, and SPLP PP-13 Metals. The laboratory results did not indicate the

[ presence of ETPH, VOCs, PAHs, PCBs and SPLP PP-13 Metals at concentrations above

analytical detection limits (BRL) in either of the soil samples.

PAOC-14: Hazardous Waste Satellite Accumulation Area One (1) concrete core/chip sample, C-3, and one (1) sub-slab soil sample, SS-3, were collected

l from PAOC-14, Hazardous Waste Satellite Accumulation Area as shown on the attached Figure 3. The concrete core/chip and sub-slab soil samples were analyzed for ETPH, VOCs, PAHs,

[ PCBs and SPLP PP-13 Metals. The results of the laboratory analyses detected a concentration of

ETPH (573 ppm) in concrete sample C-3, which slightly exceeds the RDEC of 500 ppm but is

below the I/C-DEC of 2,500 ppm. VOCs and PCBs were not detected in C-3 at concentrations

above analytical detection limits (BRL). The PAH compound, 2-Methylnaphthalene (0.144

ppm) was detected in sample C-3, but at a concentration below the RSR criteria. No other PAH

compounds were detected in sample C-3 at concentrations above analytical detection limits

(BRL). SPLP Chromium (0.0176 ppm) and Zinc (0.0065) were detected in sample C-3 but at

concentrations below the applicable RSR criteria. No other SPLP PP-13 Metals were detected in

sample C-3 at concentrations above analytical detection limits (BRL). ETPH, VOCs, PAHs, and

PCBs were not detected in sub-slab soil sample SS-3 at concentrations above analytical detection

limits (BRL). SPLP Zinc (0.0058 ppm) was detected in sample SS-3 but at a concentration


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below the RSR criteria. No other SPLP PP-13 Metals were detected in sample SS-3 at

concentrations above analytical detection limits (BRL).

I PAOC-15: Parts Washing Station Location

One (1) concrete core/chip sample, C-2, and one (1) sub-slab soil sample, SS-2, were collected r from PAOC-15, Parts Washing Station Location as shown on the Figure 3. The concrete

core/chip and sub-slab soil samples were analyzed for ETPH, VOCs, PAHs, PCBs and SPLP PP- 13 Metals. The results of the laboratory analyses detected a concentration of ETPH (232 ppm) in concrete sample C-2, which is below both the RDEC and IC-DEC. PAHs and PCBs were not

r detected in C-2 at concentrations above analytical detection limits (BRL). The VOC

compounds, Acetone (0.139 ppm), Toluene (0.0137 ppm) and Xylenes (0.0196 ppm) were

detected in sample C-2, but at a concentration below the RSR criteria. The production of

Acetone commonly occurs when utilizing the VOC Method SW 846 5035A extraction

technique and its presence in sample C-2 is likely due to laboratory contamination. No other

VOCs were detected in sample C-2 at concentrations above analytical detection limits

(BRL). SPLP Chromium (0.0179 ppm) was detected in sample C-2 but at concentrations

below the applicable RSR criteria. No other SPLP PP-13 Metals were detected in sample C-2 at

concentrations above analytical detection limits (BRL). ETPH, VOCs, PAHs, and PCBs were

not detected in sub-slab soil sample SS-2 at concentrations above analytical detection limits

(BRL). SPLP Zinc (0.0064 ppm) was detected in sample SS-2 but at a concentration below the

RSR criteria. No other SPLP PP-13 Metals were detected in sample SS-2 at concentrations

above analytical detection limits (BRL).

l PAOC-16: Raw Material Storage Area

One (1) concrete core/chip sample, C-4, and one (1) sub-slab soil sample, SS-4, were collected

from PAOC-16, Raw Material Storage Area as shown on the attached Figure 3. The concrete

core/chip and sub-slab soil samples were analyzed for ETPH, VOCs, PAHs, PCBs and SPLP

PP- 13 Metals. The results of the laboratory analyses detected a concentration of ETPH (477

ppm) in concrete sample C-4, which is below both the RDEC and I/C-DEC. PCBs were not

detected in C-4 at concentrations above analytical detection limits (BRL). The VOC

compounds, 4-Methyl-


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I 2-Pentanone [MIBK (0.0872 ppm)], and Xylenes (0.0171 ppm) were detected in sample C-4, but

at a concentration below the RSR criteria. The production of ketones commonly occurs when

utilizing the VOC Method SW 846 5035A extraction technique and the presence of MIBK

in sample C-2 is likely due to laboratory contamination. No other VOCs were detected in

sample C-4 at concentrations above analytical detection limits (BRL). The PAH

compounds, 1- Methylnaphthalene (0.172 ppm) and 2-Methylnaphthalene (0.175 ppm) were

detected in sample C-4, but at concentrations below the RSR criteria. No other PAH

compounds were detected in sample C-4 at concentrations above analytical detection limits

(BRL). SPLP Zinc (0.0086 ppm) was detected in sample C-4 but at a concentration below the

applicable RSR criteria. No other SPLP PP-13 Metals were detected in sample C-4 at

concentrations above analytical detection limits (BRL). ETPH, VOCs, PAHs, and PCBs were

not detected in sub-slab soil sample SS-4 at concentrations above analytical detection limits

(BRL). SPLP Zinc (0.0058 ppm) was detected in sample SS-4 but at a concentration below the

RSR criteria. No other SPLP PP-13 Metals were detected in sample SS-4 at concentrations above

analytical detection limits (BRL).


One (1) concrete core/chip sample, e-1, and one (1) sub-slab soil sample, SS-1, were collected

from PAOC-17, Battery Storage Area as shown on the Figure 3. The concrete core/chip and sub-

slab soil samples were analyzed for ETPH, VOCs, PAHs, PCBs and SPLP PP-13 Metals.

The results of the laboratory analyses detected a concentration of ETPH (640 ppm}in

concrete sample C-1, which slightly exceeds the RDEC of 500 ppm but is below the I/C-DEC

of 2,500 ppm. PAHs, PCBs, and SPLP PP-13 Metals were not detected in e-1 at

concentrations above analytical detection limits (BRL). The VOC compounds, Acetone (0.11

ppm) and 4-Methyl-2-Pentanone [MIBK (0.0669 ppm)], were detected in sample C-1, but at

concentrations below the RSR criteria. The production of Acetone and ketones commonly

occurs when utilizing the VOC Method SW 846 5035 A extraction technique and the presence of

Acetone and MIBK in sample C-1 is likely due to laboratory contamination. No other VOCs

were detected in sample e-1 at concentrations above analytical detection limits (BRL).

ETPH, VOCs, PAHs, and PCBs were not detected in sub-slab soil sample SS-1 at

concentrations above analytical detection limits

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(BRL). SPLP Copper (0.0052 ppm) and Zinc (0.0058 ppm) were detected in sample SS-1 but at

a concentration below the RSR criteria. SPLP Lead was not detected in either the sub-slab soil

[ or concrete at concentrations above analytical detection limits (BRL<0.0075 ppm). No other SPLP PP-13 Metals were detected in sample SS-1 at concentrations above analytical detection

I limits (BRL).

[ Groundwater Sample Results

[ Groundwater samples were collected from the three (3) monitor wells, MW-1, MW-2 and MW-3

installed during the 2006 Phase III RI. Groundwater samples were collected from each well in

[ accordance with the CTDEEP' s "Low Flow Sampling Procedures" and were submitted to the

laboratory for analysis for ETPH, VOCs, SVOCs, Total and Dissolved PP-13 Metals. The

[ temperature, pH, specific conductance and turbidity for each groundwater sample were measured

in the field. ETPH and VOCs were not detected above analytical detection limits (BRL) in the

[ groundwater samples collected from wells, MW-1, MW-2 and MW-3. Chloroform was detected in the both groundwater samples collected from well MW-1 at concentrations of 1.3 ppb (MW-1)

[ and 1.2 ppb (MW-1 DUP) which are below both the Surface Water Protection Criteria (SWPC) of 14,100 ppb and the Residential Volatilization Criteria of 287 ppb. Chloroform is a common

[ laboratory contaminant and its presence in the groundwater samples from MW-1 is likely due to laboratory contamination as it is not a substance that was used at the Pawnee facility. No

[ other VOCs were detected in any of the groundwater samples at concentrations above analytical detection limits (BRL). Total Thallium (0.0052 ppm & 0.0054 ppm) was also detected in the

[ groundwater samples collected from MW-1 but at concentrations below the SWPC of 0.063 ppm. No other total PP-13 Metals were detected in any of the groundwater samples at

[ concentrations above analytical detection limits (BRL). Dissolved Copper (0.01 ppm) was

detected in the groundwater sample from well MW-2 but at a concentration below the SWPC of

0.048 ppm. Dissolved Zinc was detected in the groundwater samples collected from monitor

wells MW-1 (0.011 ppm & 0.0157 ppm) and MW-3 (0.0076 ppm) but at a concentration below

I the SWPC of 0.123 ppm. No other dissolved metals were detected in any of the groundwater


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r samples at concentrations above analytical detection limits (BRL).

Quality Assurance/Quality Control (QA/QC) To assess the collection of samples in the field in terms of the sampling techniques and decontamination procedures followed, quality control and quality assurance samples were

[ collected. Duplicate soil (GP-2 DUP and GP-16 DUP) and groundwater (MW-2 DUP) samples, field blanks and trip blanks were collected and . submitted for laboratory analyses as part of the

[ assess QA/QC procedures for the project. The results of the duplicate sample analyses were within the acceptable laboratory QC control limits. The trip blank samples (TB-1, TB-2, TB-3,

[ and TB-4) and field blanks (FB-1 and FB-2) did not contain detectable concentrations of any

contaminants of concern.

Environmental investigations consisting of the collection and analysis of soil, groundwater, soil

vapor and concrete samples were conducted within the AOCs and PAOCs identified at the Site.

The results of the environmental investigations indicated that active remediation of the Site was

not required to achieve compliance with the RSRs.

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[ 4.0 RECEPTOR ASSESSMENTS

A review of sensitive receptor land uses in the vicinity of the Parcel was conducted as part of the

investigations. The Parcel and surrounding properties have been historically connected to a

public water supply and municipal sanitary sewers and draw water from the municipal supply,

administered by the Pawnee Water Department. According to the "Community Water

[ - Systems in Connecticut" map, there are four (4) public water supply wells located within four (4)

miles of the subject site (See Attached Potable Well Figure). All four (4) wells are part of the

[ well field located approximately 3 1/2 miles west of the subject site and are operated by the

Town of Pawnee Public Works Department.

( The Parcel is located within the Connecticut River Regional Basin and the Wamapoke River Sub-

Regional Drainage Basin. Roblowe Brook, which eventually discharges to the Wamapoke River.

The Site is not located within a floodplain and there are no wetlands or surface water bodies

located on the property.

( The Site is surrounded by a mixture of commercial and residential properties. Pawnee

Memorial Hospital is located to the west of the facility across Guard Street. There are no

[ schools, which adjoin the site and no day care facilities or playgrounds are adjacent to the Site. Based on the inferred groundwater flow direction, it does not appear that downgradient

[ properties would be impacted by releases from the former Pawnee Complex.

Significant Environmental Hazard Threshold Criteria

Data collected as part of the investigation and remediation was compared to the CTDEEP's

Significant Environmental Hazard Threshold Criteria (SEHC) to determine if a hazard exists at

the Parcel. None of the data collected exceeds the SEHC for the compounds analyzed.

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r 5.0 DESCRIPTION OF REMEDIAL ACTIVITIES

r Based on the results of the environmental investigations, remediation of the AOCs and PAOCs

identified in the CSM is not required to achieve compliance with Sections 22a-133k-1 through 3

of the Regulations of Connecticut State Agencies (RCSA), herein referred to as the RSRs.

Substances detected during the environmental investigations conducted at the Site did not

indicate the presence of "release" conditions associated with historic site operations. The substances detected in the soil at the Site during the investigations are associated with the fill

[ material (arsenic) present beneath the pavement section and incidental sources from asphalt paving and motor vehicles (ETPH and PAHs). The concentrations detected in the soil· do not

[ warrant remediation and a groundwater plume is not present at the Site. Therefore, active remediation is not warranted and the Site is in compliance with the RSRs.

[ The former rifle range in the interior of the armory was remediated by the prior to

( 2001. The 6,000 gallon #2 fuel oil UST was removed in 2008 in accordance with the Underground Storage Tank Regulations, RCSA Sections 22a-449(d)-101 through 22a-449(d)-

[ 113 (Tank Regulations). These activities are described further below.

[ Rifle Range

Remediation of the rifle range within the interior of the Armory was conducted prior to the

Preliminary Assessment conducted by ABC in 2001. The remedial activities included the

removal of all raw and waste materials from the rifle range. The area and all surfaces were

cleaned to remove any residual contamination from these surfaces. Wipe samples were collected

from surfaces to verify that the areas were properly cleaned and that no residual contamination

remained. The results of the wipe sample analysis confirmed that the area was properly

[ remediated. Following remediation of the rifle range the area was used a mess hall until closure

of the armory.

I Tank D (6,000 Gallon UST Removal -2008)


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[" In 2008 the 6,000 gallon heating oil UST was removed from the Pawnee Facility by Dwyer Tank Removal, Inc. for the .Prior to removal approximately 1,600

r gallons of #2 fuel oil was removed from the tank, transported to and disposed at Soil

Recycling, Inc. in Eagleton, Connecticut. Following removal of the fuel the concrete slab

[ and clean overburden soil was removed to expose the tank. The clean overburden soil was

stockpiled on site and tested for total petroleum hydrocarbons (TPH). The TPH results for this

[ stockpiled material were below RSR criteria. The contractor cleaned the inside of the tank

utilizing water and a vacuum truck. Approximately 238 gallons of residual #2 fuel oil and

[ wastewater were collected during the cleaning of the tank. All contaminated liquid was collected

using a vacuum truck and disposed at Soil Recycling, Inc. in Eagleton, Connecticut.

[ The UST was then removed from the ground and loaded onto a trailer for transportation and removed off site. The Pawnee Fire Marshal was onsite for the inspection of the tank grave.

[ Upon removal of the tank the contractor conducted final composite soil sampling to document the closure in accordance with the Tank Regulations. Soil samples were collected from the

[ sidewalls and bottom of the tank grave and in the area of the feed and return lines. The soil samples were analyzed for TPH, SVOCs and VOCs. Groundwater was not encountered in the

[ tank grave and was not sampled as part of the UST closure. Following receipt of the analytical results indicating appropriate closure levels, the contractor backfilled the tank grave with the

[ clean overburden soil, thirty-six (36) tons of bank run gravel and eighteen (18) tons of processed stone to bring the tank grave to grade on March 21, 2008 to complete closure in accordance with

[ the Tank Regulations.

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[ 6.0 QUALITY ASSURANCE I QUALITY CONTROL

[ The CTDEEP's Quality Assurance and Quality Control (QA/QC) Guidance was used to ensure

[ that the analytical results generated during the investigation and remediation are of known and

appropriate quality. The Laboratory Quality Assurance and Quality Control, Data Quality

[ Assessment and Data Usability Evaluation (DQA/DUE) Guidance were utilized to ensure that

the analytical data used is of known and sufficient level of quality for the intended purpose.

[ Investigation

[ Sixty-three (63) soil, seven (7) groundwater, and four (4) concrete samples were collected during

investigation of the Parcel and submitted to a state-certified analytical laboratory, Environmental

r Analytical, Inc., for the following analyses using Reasonable Confidence Protocols (RCPs): • Extractable Total Petroleum Hydrocarbons -CT-ETPH Method; • Volatile Organic Compounds -EPA Method 8260; • Polycyclic Aromatic Hydrocarbons -EPA Method 8270; • Polychlorinated Biphenyls -EPA Method·8082; • Total Priority Pollutant Metals -EPA Method SW846 6000/7000 Series • Dissolved Priority Pollutant Metals -EPA Method SW846 6000/7000 Series • SPLP Priority Pollutant Metals -EPA Method SW846 1312/6000 Series

The samples were collected to confirm the presence and extent of release areas at the Parcel. A

f data quality assessment and data usability evaluation was performed for the data generated

during the investigations in accordance with CTDEEP guidance and noted the following quality

l · control non-conformances.

l Acetone and chloroform were found in the laboratory blanks and in groundwater samples at

concentrations less than the Surface Water Protection Criteria (SWPC) as a result of laboratory

l contamination. Therefore, the detection of these compounds in samples collected during the investigation is the result of laboratory contamination and not indicative of a "release".

l I Knope Inc. Page 48 Project No. 12345.01

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[ Laboratory Control Samples, Surrogate recoveries, Continuing Calibration, Matrix Spike/Matrix

Spike Duplicates exhibited bias for poor performing compounds and several other compounds

[ that are not constituents of concern at the Parcel.

Soil and groundwater data did not indicate the presence of releases of contaminants of concern

from historic operations conducted at the site by the Defense Department. Based on these

findings from the DQA and DUE, the analytical data is of adequate quality and of sufficient

accuracy, precision and sensitivity to confirm that remediation of the Parcel is not required to

achieve compliance with the RSRs.

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7.0 DEMONSTRATION OF COMPLIANCE

r The following sections detail the regulatory requirements and methods used to achieve

compliance with these regulatory requirements relevant to the verification of the Former [ Pawnee Complex located at 100 Water Street in Pawnee, Connecticut.

[ 7.1 Regulatory Requirements

7.1.1 Remediation Standard Regulations

[ The CTDEEP Remediation Standard Regulations (Regulations of Connecticut State Agencies, Section 22a-133k-1 to 3 and 22a-133q-l) adopted as of January 31, 1996 are the regulatory

[ requirements applicable to this Site. The RSRs apply to any site undergoing voluntary remediation under Public Acts 95-183 or 95190, a transfer of an "establishment" under Public

[ Act 95-183, or any site as ordered by the CTDEEP Commissioner. An ECAF and Form II for Transfer of an Establishment were submitted to the CTDEEP Property Transfer Program (PTP)

l on June 18, 2012 an the RSRs are applicable to the Former Pawnee Complex. Substances detected during the environmental investigations conducted at the Site did not

indicate the presence of "release" conditions associated with historic site operations. The

substances detected in the soil at the Site during the investigations are associated with the fill

material (arsenic) present beneath. the pavement section and incidental sources from asphalt

paving and motor vehicles (ETPH and PAHs). Remediation of these areas is not warranted and

compliance with the RSRs is achieved.

Soil Remediation Requirements

r Section 22a-133k-2 of the RSRs specifies that "polluted soil at a release area" shall be

[ remediated to a concentration, which meets the (1) Direct Exposure Criteria (DEC) and the

Pollutant Mobility Criteria (PMC) or (2) the background concentration of soil provided that

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r - notice has been submitted to the Commissioner.

1 Direct Exposure Criteria The purpose of the DEC is to protect human health from risks associated with the direct contact

r or ingestion of various common soil contaminants. The RSRs require that polluted soils at a

release area shall be remediated to at least that concentration at which the RDEC for each

r substance is met. The RSRs also allow for polluted soil at a release area to be remediated to at

least that concentration at which the I/C-DEC for each substance is met. The use of the less

( stringent industrial/commercial standards requires the placement of an Environmental Land Use Restriction (ELUR) on the property in accordance with RCSA Section 22a-133-q-l.

Pollutant Mobility Criteria The purpose of the Pollutant Mobility Criteria (PMC) is to evaluate the potential for

l contaminants to leach from the soil in concentrations that may degrade groundwater quality.

Different numerical criteria are established based on the groundwater classification of the area.

[ The RSRs require that polluted soil from a release area shall be remediated to at least that concentration at which the results of a mass analysis of such soil for each substance does not

L exceed the pollutant mobility criterion applicable to the groundwater classification of the area at which such soil is located. Since the Site is located in a GB groundwater area, the less stringent

I criteria is applicable.

r Groundwater Remediation Requirements

Section 22a-133k-3 of the RSRs specifies that remediation of a groundwater 'plume" shall result r in the attainment of the requirements concerning surface water protection and the requirements

concerning volatilization or the background concentration for groundwater for each substance in r such plume. The results of the environmental investigation did not indicate the presence of a

"plume" at the Site and therefore compliance monitoring is not required. Also, remediation to r achieve compliance with the RSRs has not been conducted at the Site, therefore post-remediation

r monitoring is not required.

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Groundwater Protection Criteria The purpose of the Groundwater Protection Criteria (GWPC) is to protect the groundwater

quality in areas that have the potential to use groundwater as a drinking water resource (GA,

GB/GA & GAA groundwater classification areas). Since the Parcel is located in a GB

I groundwater area the GWPC do not apply.

Volatilization Criteria

The purpose of the Volatilization Criteria (VC) standard is to ensure that volatile organic

compounds (VOCs) in groundwater do not pose an unacceptable risk to human health due to the

inhalation of VOCs that may enter into a structure on the property. The Volatilization Criteria

I only apply when impacted groundwater is located within 15 feet of the ground surface or any structure. Different criteria exist for residential and industrial/commercial properties. The use of

I the less stringent commercial/industrial standards requires the placement of an ELUR on the

property. Compliance with the volatilization criteria is achieved when the ninety-five percent

I upper confidence level of the arithmetic mean of all the results are equal to or less than the

criterion for such substance for four consecutive quarterly sampling periods and that no single

I sample exceeds two times the applicable criterion for such substance or the results of all

laboratory analyses of samples for· such substance are equal to or less than the volatilization

I criterion. Since groundwater at the Parcel is not located within 15-feet of the ground surface the VC is not applicable to the Parcel.

I Surface Water Protection Criteria

I The purpose of the Surface Water Protection Criteria (SWPC) standards are to ensure that

groundwater discharging to a surface water body will not adversely effect surface water quality.

I Compliance with a surface water protection criterion for a substance in groundwater is achieved when the average concentration of such substance in such plume is equal to or less than the

l applicable surface water protection criterion for at least four consecutive quarterly sampling periods . or the concentration of such substance in that portion of such plume which is

I immediately upgradient of the point at which such groundwater discharges to the receiving

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r I Former Pawnee Complex Verification Report

surface water body is equal to or less than the applicable surface water protection criterion.

Since groundwater at the Parcel discharges to the Roblowe Brook and eventually the

Wamapoke River, the SWPC is applicable to determine compliance with the RSRs.

I 7.1.2 RCRA Closure

I In January 2008, submitted a RCRA Closure Report to CTDEEP to close out the EPA Generator

Permit ID Number for FMS # 7 and to change the generator status from SQG to

r CESQG. The RCRA Closure Report was prepared to document closure of FMS # 7 in

accordance with CTDEEP's "Draft Closure Guidance for Generators Who Store Less Than 90

I Days, Container Storage Areas and Tank Systems" prepared by the CTDEEP Waste Engineering

and Enforcement Division (WEED). The Closure Report indicated that no Contaminants of

I Concern associated with the Former FMS #5 existed at concentrations exceeding hazardous

levels. Based on these results, closure of the "Former FMS #5" in accordance with the RCRA

I guidance was achieved. CTDEEP approved the request and sent an "Acknowledgement of

Receipt of Status Change Request from Small Quantity Generator to Conditionally Exempt

I Small Quantity Generator of Hazardous Waste for the Connecticut Military Department Field

Maintenance Shop 5, 100 Water Street, Pawnee, CT, EPA ID No. CTD123456789" on

I February 26, 2008. Upon receipt of CTDEP's approval to withdraw the EPA Generator ID

status, the self-implementing closure of the "Former FMS #5" in accordance with the RCRA

guidance has been achieved.

7.2 Demonstration of Compliance

The results of the numerous investigations of the soil and groundwater within the AOCs and

PAOCs indentified in the CSM indicate that the Parcel is in compliance with the RSRs (Section

[ 22a-133k-1 through 22a-133k-3) and that remediation of the soils and groundwater at the Parcel is not required. Substances detected during the environmental investigations conducted at the

l Site did not indicate the presence of "release" conditions associated with historic site operations.

I Knope Inc. Page 53. Project No. 12345.01

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The substances detected in the soil at the Site during the investigations are associated with the fill

material (arsenic) present beneath the pavement section and incidental sources from asphalt

paving and motor vehicles (ETPH and PAHs). The concentrations detected in the soil do not

warrant remediation and a groundwater plume is not present at the Site.

The following table summarizes the demonstration of compliance for each identified

PAOC/AOC at the Parcel:

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TABLE 3 -DEMONSTRATION OF COMPLIANCE

PAOC/A OC #

Description Release Detected

Detected Constituents of Concern (COCs)

Area Remediated

Applicable Criteria Compliance Achieved

1 Empty Drum Storage Area No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133 k-2(c)(2)(A)

Yes

2 Former USTs A & D - heating oil No - Not Required Sections 22a-133k-2(c)(l)(A) and Yes 22a-133k-2(c)(2)(A)

3 POL Shed, ASTS & Haz Waste Shed

No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2(c)(2)(A)

Yes

4 Former UST G - gasoline No -- Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2( c)(2)(A)

Yes

5 Oil/water separator No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2( c)(2)(A)

Yes

6 Former UST B - diesel No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2( c)(2)(A)

Yes

7 Former UST F - gasoline No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2( c)(2)(A)

Yes

8 Former USTs C & E - gasoline & No -- Not Required Sections 22a-133k-2(c)(l)(A) and Yes diesel 22a-133k-2( c)(2)(A)

9 Drum Storage Area No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2(c)(2)(A)

Yes

10 Former unpaved parking area No - Not Required Sections 22a-133k-2(c)(l)(A) and Yes 22a-133k-2( c)(2)(A)

11 Former Waste Oil UST No -- Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2(c)(2)(A)

Yes

1 2 Former Coal Room No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2(c)(2)(A)

Yes

1 3 Loading & Unloading Area No -- Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2( c)(2)(A)

Yes

1 4 Hazardous Waste Satellite Accumulation Area

No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2( c)(2)(A)

Yes

1 5 Parts Washing Station No - Not Required Sections 22a-133k-2(c)(l)(A) and Yes 22a-133k-2( c)(2)(A)

- - - - - - - - - -·,

1 6 Raw Material Storage Area No - Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2(c)(2)(A)

Yes

1 7 Battery Storage Area No -- Not Required Sections 22a-133k-2(c)(l)(A) and 22a-133k-2(c)(2)(A)

Yes

Site Groundwater No -- Not Required Sections 22a-133k-3(a)(3) and 22a-133k-3(b)(l)

Yes

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[ VERIFICATION FORM

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Department of Environmental Protection Bureau of Water Protection and Land Reuse

I LICENSED ENVIRONMENTAL PROFESSIONAL FORM IIVERIFICATION (PROPERTY)

The following verification must be signed by a Connecticut Licensed Environmental Professional. Print or type unless otherwise noted. Retain a copy for your records.

I I I I

"I verify in accordance with Sections 22a-134(11) and 22a-134(19) of the Connecticut General Statutes and Section 22a-133v-1(z) of the Regulations of Connecticut State Agencies (RCSA), that an investigation has been performed at the parcel in accordance with prevailing standards and guidelines, and that

(check only one of the following)

__ any pollution caused by a discharge, spillage, uncontrolled loss, seepage or filtration of hazardous waste or a hazardous substance which has occurred from the establishment has been remediated in accordance with the remediation standards (RCSA Sections 22a-133k-1 through 22a-133k-3) , and that since any such verification, including a verification previously submitted to the commissioner for a 'portion' of the establishment, no discharge, spillage, uncontrolled loss, seepage or filtration of a hazardous waste or a hazardous substance has occurred at any portion of the establishment."

X no remediation is necessary to achieve compliance with the remediation standards (RCSA Sections 22a-133k-1 through 22a-133k-3)."

_ _ no discharge, spillage, uncontrolled loss, seepage or filtration of a hazardous waste or a hazardous substance has occurred at the establishment since a "Form IV Verification" was previously submitted to the commissioner."

The 'Rules of Professional Conduct' (RCSA Section 22a-133v-6) apply to evety LEP and to all professional service . provided by a LEP.

I __________________________________ Signature of Licensed Environmental Profession al

Date: August 7, 2017 I Name of Licensed Environmental Professional (print or type)

I License Number: 007

. Phone No.: 860-555-3158

Affix Seal Here

This completed form must be submitted to: REMEDIATION DIVISION, 2nd FLOOR

BUREAU OF WATER PROTECTION AND LAND REUSE DEPARTMENT OF ENVIRONMENTAL PROTECTION 79 ELM STREET HARTFORD, CT 06106-5127

Part I- Site Information

Establishment now or formerly known as: CTARNG Pawnee Complex

Establishment Address: 100 water street

City/Town: Pawnee

Description in Property Deed:

Recorded on page 460

land records, as lot 330,

State: CT Zip Code: 06000

of volume 076,

block 3760

of the Town of Pawnee

on map 77 in the Tax Assessor's Office.

Part II - Verification

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[ ETPH APPROVAL FORM

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Department of Energy & Environmental Protection Bureau of Water Protection and Land Reuse Remediation Division

79 Elm Street, Hartford, CT 06106m5127

DEEP USE ONLY (Date Stamp)

WATER PtOTECTJON AND ),,}\i\iO F HSF REMEWll\lJOl"J DJVl§;\()f"l

(860) 424m3705 www.ct.gov/deep/remediation · $.IT'E; hJAIVi13··=··,.....'""'""·'"."'"'"'.,,, ,,,..,,_,.•,..,··=·" -

, i\0..PFE:SS= --.-..···-"·'""....,,,....,,,,·'""'"···'· .·..··-"··.. ""··· 'fOWl\l == .....,......,,...... .,...,.

FILE TYP£.. "" '·'"'"''·""'= 71!10.,"...."'=-=-=.,.,_..,.., ""

REQUEST FOR APPROVAL FOR USE OF CT...ETPH METHOD AND ASSOCIATED CRITERIA AS AN ADDITIONAL POLLUTING SUBSTANCE

I I n accordance with Sections 22a-133k-1 through k-3 (RSRs) Please submit this completed form when requesting the Commissioner's approval to use site specific clean-up criteria for extractable total petroleum hydrocarbons (ETPH), as recommended in the July 2012 Technical Support Document titled, "Extractable Petroleum Hydrocarbon Fractions Using the ETPH Analytical Method and Criteria Development". The Commissioner's approval is required pursuant to the Remediation Standard Regulations, Sections 22a-133k-1 through k-3 (RSRs) of the Regulations of Connecticut State Agencies (RCSA), for use of the ETPH Method and criteria listed below, at the below-referenced site.

The use of this form will expedite the review process of the established methodology and criteria. Upon approval or disapproval, this form will be returned to the sender to document such decision. If an alternative methodology and/or criteria is proposed, it should be submitted using the "Approval Request or Notice Transmittal Form" along with all information required by the applicable paragraph(s) in the RSRs for each proposed criteria.

All sections of this form must be filled out, as applicable.

Check the box to indicate the program for which this form is being submitted:

X Connecticut General Statutes (CGS) Section 22a-134a(a)-(e), Property Transfer Program _ CGS section 22a-133x, Voluntary Remediation Program · _ CGS section 22a-133y, Voluntary Remediation Program _ Other (specify)

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Contact Information

Person Submitting Request: Leslie Knope, LEP Business Name: Knope Group Inc. Mailing Address: 1234 Swanson H i g h w a y City/Town: Icetown

[ Business Phone:

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Title: Principal Engineer E-mail Address: leslie.knope@knope. com

State: CT Zip Code: 06000 Fax: 86 0 - 555 -318 8

l DEP-REM_ETPH Page 1 of 3 Rev.8/6/12

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Site Identification Rem lD#ll111

Name of Site: Former Pawnee Complex

Street Address: 100Water City/Town: Pawnee

Groundwater Classification:

Street State: CT Zip Code: 0 6 000

GB

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http://www.ct.gov/deep/remediation

Signature of Person Requesting Approval

Signature 00/00/0000

Date

Leslie Knope, LEP Principal Engineer Printed Name of Signatory Title (if applicable)

I IRem ID# 11111 "I hereby request approval, in accordance with Sections 22a-133k-2(b)(4), 22a-133k-2(c)(5), and/or 22a-133k-3(h) of the RCSA, to:

)> use the CT-ETPH method titled "Analysis of Extractable Total Petroleum Hydrocarbons (ETPH) Using Methylene Chloride Gas Chromatograph/Flame Ionization Detection/' prepared by the Environmental Research Institute, University of Connecticut (dated March 1999); and

)> use the CT-ETPH Method in accordance with the "State of Connecticut Department of Energy and Environmental Protection, Recommended Reasonable Confidence Protocols, Quality Assurance and Quality Control Requirements for Extractable Petroleum Hydrocarbons by the State of Connecticut, Department of Public Health ETPH Method" (July 2006); together with

)> the criteria listed in the table below for petroleum hydrocarbons in soil and/or groundwater as additional - polluting substances at the site identified above."

Check the box indicating the criteria for which approval is requested. Selection of criteria must correspond to the groundwater classification of the site.

Remediation Criteria for use with the CT ETPH Method

I I I I I I I

I This completed form should be submitted to: REMEDIATION DIVISION, 2"d Floor

BUREAU OF WATER PROTECTION AND LAND REUSE DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 79 ELM STREET HARTFORD, CT 06106-5127

DEP-REM_ETPH Page 2 of 3 Rev.8/6/12

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Criteria Units Value

X Direct Exposure Criteria: Residential mg/kg 500

X Direct Exposure Criteria: Industrial/Commercial mg/kg 21500

Pollutant Mobility Criteria: GA Areas mg/kg 500

X Pollutant Mobility Criteria: GB Areas mg/kg 21500

Groundwater Protection Criteria ug/I 250

X Surface Water Protection Criteria ug/I 250

X Groundwater Volatilization Criteria: Residential ug/I 250

X Groundwater Volatilization Criteria: Industrial/Commercial ug/I 250

Using CT-ETPH Method on SPLP extract (per SW-846 Method 1312)

Pollutant Mobility Criteria: GA Areas ug/I 250

Pollutant Mobility Criteria: GB Areas ug/I 21500

Section Below Reserved for DEEP Approval

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l DEP-REM_ETPH Page 3 of 3 Rev.8/6/12

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-the Request received by DEEP on 8/6/12 L is hereby approved.

Nothing in this approval shall affect the Commissioner's authority to institute any proceeding, or take any action to prevent or abate pollution, to recover costs and natural resource damages, and to impose penalties for violations of law, if any. If at any time the Commissioner determines that the approved actions have not fully characterized the extent and degree of pollution or have not successfully abated or prevented pollution, the Commissioner may

in this approval d/ any person of his or her obligations under applicable federal, state and local law.

institute any proceeding, or take any action to require further investigation or further action to prevent or abate pollution. This approval applies only to the methodology and criteria identified in this request. In addition, nothing

(signature) Patrick F. Bowe Director Remediation Division Bureau of Water Protection and Land Reuse

8/6/12

Section Below Reserved for DEEP Disapproval

0 The Request received by DEEP on I I is hereby disapproved.

Rationale:

Patrick F. Bowe Director Remediation Division Bureau of Water Protection and Land Reuse

Date Disapproved

You may re-submit the request when the reason(s) for disapproval have been adequately addressed.

I

r APPENDIX A -TABLES

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[ Phase II and Phase III Sample Summary Tables

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TABLE l (a): Results of Geoprobe Boring Soil Sample Analyses · Pawnee Armor y -100 Water Street

Pawnee, Connecticut

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( ND -Not Detected (see laboratory reports for compound specific detection limits)

I BDL -Below Detectable Limits (see laboratory reports for compound specific detection limits)

The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds and their specific detection limits.

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VOCs - EPA Method 8260 (ppm)

PAHs - EPA Method 8270 (ppm)

PCBs EPA Method 8082 (ppb)

Priority Pollutant Metals (ppm)

Arsenic Chromium

Copper

Lead

Nickel

Zinc

SPLP Priority Pollutant Metals (ppm)

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

1.3

7.9

11.4

20.4

6.8

176

1.4

7.5

8.3

21.7

6.0

16.1

BDL

7.4

4.2

4.4

5.6

13.5

1.5

8.8

9.9

13.8

6.9

20.9

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Antimony BDL BDL BDL O.01 Lead 0.029 BDL BDL BDL

Zinc 0.08 BDL BDL 0.01

r TABLE 1 (b): Results of Geoprobe Boring Soil Sample Analyses

Pawnee Armory -100 Water Street Pawnee, Connecticut

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ND -Not Detected (see laboratory reports for compound specific detection limits)

BDL ·-Below Detectable Limits (see laboratory reports for compound specific detection limits)

[ The compounds listed above are those that were detected - please see laboratory repo1is for full lists of compounds and their specific detection limits.

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TPH -CT ETPH (ppm) ND ND ND ND


Methylene Chloride ND

0.019

ND

ND

PAHs .EPA Method 8270 (ppm) Benzo(a)anthracene

0.43 ND

ND

ND Benzo(b)fluoranthene 0.42 ND ND ND

Chrysene 0.41 ND ND ND

Fluoranthene 0.85 0.39 0.46 ND

Phenanthrene 0.61 ND ND ND

Pyrene 0.67 0.38 0.4 ND

Total PAHs 3.39 0.77 0.86 ND

PCBs EPA Method 8082 (ppb) ND ND ND ND

Prio1ity Pollutant Metals (ppm)

.AJ.'Senic 1.2 1.1 1.6 1.2

Chromium 7.2 8.0 9.3 6.9

Copper 6.3 9.0 20.6 8.7

Lead 30.9 6.9 20.9 7.3

Nickel 5.6 6.0 7.1 5.6

Zinc 24.4 20.0 24.1 20.8


Copper BDL BDL O.01 BDL

Lead BDL BDL 0.021 BDL

Zinc O.01 0.01 0.02 O.01

TABLE 1(c): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

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[ NA - Not Analyzed for this procedure

BDL -Below Detectable Limits (see laboratory reports for compmmd specific detection limits)


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TPH -CT ETPH (ppm)

VOCs - EPA Method 8260 (ppm) PAHs EPA Method 8270 (ppm)

Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Fluoranthene Indeno( 1,2,3-cd)pyrene Phenanthrene Pyrene

Total PAHs

PCBs - EPA Method 8082 (ppb) Priority Pollutant Metals (ppm)

Arsenic

Chromium Copper Lead Nickel

Zinc SPLP Priority Pollutant Metals (ppm)

Beryllium

Chromium Copper

Lead Nickel Thallium Zinc

520 ND

ND

ND ND ND

ND

ND

0.81 1.7 1.1 1.6 0.42 1.2 1.5 3.6 0.47 2.7

3.0 18.l

ND

ND ND ND ND ND ND ND 0.33 ND

ND ND 0.33

ND

ND ND ND ND ND ND ND ND ND ND 0.33 0.33

NA

ND ND ND ND ND ND ND ND ND ND ND ND

NA

1.6 10.8 14.9 38.9 8.9

34.0

1.6 11.2 13.5 21.4 8.4

27.7·

1.9 7.9 7.0 13.9 6.3 19.6

3.0 7.0

6.4 8.3

6.1 22.9

0.001 0.03 0.05

0.182

0.02 0.02 0.12

BDL BDL BDL BDL BDL BDL 0.02

BDL BDL BDL BDL BDL BDL BDL

BDL BDL BDL BDL BDL BDL BDL

I

l

TABLE 1(d): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

I

r TABLE l (e): Results of Geoprobe Boring Soil Sample Analyses


I I r I I I I [

I [


[ NA -Not Analyzed for this procedure

BDL -Below Detectable Limits (see laboratory reports for compound specific detection limits)

The compounds listed above are those that were detected - please see laboratory rep01is for full lists of compounds and their specific detection limits.

VOCs - EPA Method 8260 (ppm) Naphthalene

PAHs - EPA Method 8270 (ppm) Antlrracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)pery lene Benzo(k)fluoranthene Chrysene Fluorantheue Indeno{l ,2,3-cd)pyrene Phenanthrene Pyrene Total PAHs

PCBs - EPA Method 8082 (ppb)


Arsenic Beryllium Chromium Copper Lead

Nickel Zinc

SPLP Priority Pollutant Metals (ppm) Chromium Copper Lead Nickel Zinc

ND 0.09 ND ND

ND ND ND ND ND ND ND ND ND ND ND ND ND

0.42 0.86 0.66 0.64 0.53 0.43 0.96 1.9 0.4 1.2 1.7 9.7

NA

ND ND ND ND

ND ND ND ND ND ND ND ND NA

ND ND ND ND ND ND ND ND ND ND ND ND ND

1.0 BDL 6.6 5.1 3.9 5.8 14.4

BDL 0.559 29.7 18.8 48.l 11.3 59.9

1.4 BDL 7.1 5.8 6.0 5.5 16.9

7.7 BDL 11.2

4.9 2.1 10.1 23.4

BDL BDL BDL BDL BDL

0.0065 BDL

BDL 0.003 BDL

0.01 0.02 0.018 O.Ql 0.11

BDL BDL BDL BDL

0.01

r

I

TABLE l (t): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

I I I I I L I I


I NA -Not Analyzed for this procedure

BDL -Below Detectable Limits (see laboratory reports for compound specific detection limits)


I l

I

I

, -

TABLE l (g): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

r I I I I I I I I



I BDL -Below Detectable Limits (see laboratory reports for compound specific detection limits)

TI1e compounds listed above are those that were detected p l e a s e see laboratory reports for full lists of compounds

I and their specific detection limits.

I

VOCs - EPA Method 8260 (ppm) ND ND ND ND

PAHs - EPA Method 8270 (ppm) ND

ND

0.6

ND

Benzo(a)anthracene

Benzo(a)py:rene ND ND 0.59 ND

Benzo(b)fluoranthene ND ND 0.79 ND

Benzo(k)fluorant11ene ND ND 0.52 ND

Chrysene ND ND 0.66 ND Fluoranthene ND ND 1.0 ND

Phenanthrene ND ND 0.49 ND

Pyrene ND ND 0.91 ND

Total PAHs ND ND 5.56 ND

PCBs - EPA Method 8082 (ppb) NA NA ND ND


1.9 BDL

2.1

1.1 Arsenic

Chromium 7.1 5.4 8.7 5.6

Copper 7.1 5.5 8.3 5.3

Lead 12.4 4.4 12.4 8.9

Nickel 5.7 5.2 7:4 4.5

Zinc 18.8 11.0 33.1 13.4


Thallium

Zinc

BDL

BDL

BDL

BDL

BDL O.Ql

O.01

O.01

TABLE l (h): Results of Geoprobe Boring Soil Sample Analyses


[ [ [

[

[

[

[

[

[ ND -Not Detected (see laboratory rep01ts for compound specific detection limits)

NA -Not Analyzed for this procedure

[ BDL -Below Detectable Limits (see laboratory reports for compound specific detection limits)


[

[


[

Arsenic BDL 1.6 1.1 1.5

Beryllium 0.456 BDL BDL BDL

Chromium 4.41 5.4 5.8 6.2

Copper 6.81 4.3 4.9 9.3

Lead 6.13 3.0 3.3 14.5

Nickel 3.6 5.4 5.4 5.7

Zinc 14.2 10.5 11.9 17.0

TABLE l (I): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

I I I I I I I ND -Not Detected (see laboratory reports for compound specific detection limits)



I I

I

I

TPH -CT ETPH (ppm)


pAHs - EPA Method 8270 (ppm)

PCBs - EPA Method 8082 (ppb)


Arsenic Chromium

Copper

Lead

Nickel

Zinc


Lead

Zinc

ND

ND

ND

NA

1.3 7.0

5.0

4.1

5.8

13.6 0.053

0.08

I

1'ABLJE 1(a): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

I I r r

BRL -Below Reporting Limits (see laboratory reports for compound specific detection limits)



I I I

TABLE: ll. (b): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

I


I NA -Not Analyzed for this procedure The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds and their specific detection limits.

I

I

I

Boring I.D.: MAN-31 MAN-31 MAN-32 MAN-32 CTDEP PMC GB CTDEP DEC AOCIPAOC 11 11 2 2 Groundwater Residential/Commercial Sample Depth: 2'-4' 4'-8' 2'-4' 4'-8' Area & Industrial TPH -CT ETPH (ppm) BRL BRL NA NA 2,500 ppm 500/2,500 ppm

TPH -Method 8100 NA NA BRL BRL 2,500 ppm 500/2,500 ppm

VOCs - EPA Method 8260 {ppm) BRL BRL BRL BRL PAHs - BPA Method 8270 {ppm) BRL BRL BRL BRL PCBs - EPA Method 8082 {ppb) BRL BRL NA NA Not Applicable 1/lO ppm

SPLP Priority Pollutant Metals (ppm) BRL BRL BRL BRL

TABLJE l(c): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

I Pawnee, Co n n ec t i c u t

I I I I


I NA -Not Analyzed for this procedure The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds

I and their specific detection limits.

TAJBLJE l (d): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -330 Main Street

Pawnee, Connecticut

I



I I L

Boring I.D.: MAN-35 MAN-36 MAN-36 AOCIPAOC 11 8 8 Sample Depth: 4'-8' 2'-4' 4'-8' TPH -CT ETPH (ppm) BRL BRL BRL

VOCs - EPA Method 8260 (ppm) BRL BRL BRL

PAHs - EPA Method 8270 (ppm) BRL BRL BRL

PCBs - EPA Method 8082 (ppb) BRL NA NA

SPLP Priority Pollutant Metals (ppm) BRL BRL BRL

MAN-37 8

2'-4' BRL

BRL

BRL

NA

BRL

CTDEP PMC GB Groundwater

Area 2,500 ppm

CTDEP DEC Residential/Commercial

& Industrial 500/2,500 ppm

Not Applicable 1/10 ppm

I

I

Boring I.D.: MAN-38 MAN-39 MAN-40 MAN-41 CTDEP PMC GB CTDEP DEC AOCIPAOC 5 5 13 13 Groundwater Residential/Commercial Sample Depth: 4'-8' 4'-8' 2'-4' 2'-4' Area & Industrial

. TPH -CT ETPH (ppm) BRL BRL BRL BRL 2,500 ppm 500/2,500 ppm

VOCs - EPA Method 8260

(ppm) Toluene

0.0076

BRL

BRL

BRL

67 ppm

500/1,000 ppm

PAHs - EPA Method 8270 (ppm) BRL BRL BRL BRL

PCBs - EPA Method 8082 (ppb) BRL BRL BRL BRL Not Applicable 1/10 ppm


TABLE: U. (e): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

[


NA -Not Analyzed for this procedure


[ TABLE l (t): Results of Geoprobe Boring Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

[

[

[

[

[


[ NA -Not Analyzed for this procedure The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds and their specific detection limits.

[

I

[

Boring I.D.: AOCIPAOC Sample Depth:

MAN-45 3

2'-4'

MAN-46 3

2'-4'

MAN-47 10

2'-4'

MAN-48 1

2'-4'


Area


& Industrial TPH -CT ETPH (ppm) 80.8 BRL BRL BRL 2,500 ppm 50012,500 ppm

VOCs - EPA Method 8260 (ppm) BRL BRL BRL BRL

PAHs - EPA Method 8270 (ppm)

0.137

BRL

BRL

0.15

56 ppm

1,000/2,500 ppm Fluoranthene

Pyrene BRL BRL BRL 0.146 40 ppm 1,000/2,500 ppm

Total PAHs 0.137 BRL BRL 0.296

PCBs - EPA Method 8082 (ppb) BRL BRL BRL NA Not Applicable 1/10 ppm


Boring I.D.: AOCIPAOC Sample Depth:

MAN-42 6

4'-8'

MAN-43 2

2'-4'

MAN-43 2

4'-8'

MAN-44 10

2'-4'


Area


& Industrial TPH -CT ETPH (ppm) BRL NA NA BRL 2,500 ppm 50012,500 ppm

TPH -Method 8100 NA BRL BRL NA 2,500 ppm 500/2,500 ppm

VOCs - EPA Method 8260 (ppm) BRL BRL BRL BRL PAHs - EPA Method 8270 (ppm) BRL BRL BRL BRL PCBs - EPA Method 8082 (ppb) NA NA NA BRL Not Applicable 1/10 ppm


r TABLE l (g): Results of Geoprobe Boring Soil Sample

Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

r


r NA -Not Analyzed for this procedure

r The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds

and their specific detection limits.

r

r r

r

r

r

r l

I Boring I.D.: MAN-49 MAN-50 CTDEP PMC GB CTDEP DEC AOC/PAOC 1 1 Groundwater Residential/Commercial Sample Depth: 2'-4' 2'-4' Area & Industrial TPH -CT ETPH {ppm) BRL BRL 2,500 ppm 500/2,500 ppm

VOCs - EPA Method 8260 {ppm) BRL BRL PAHs - EPA Method 8270 (ppm) BRL BRL SPLP Priority Pollutant Metals (ppm) BRL BRL

TABLE 2: Results of Monitoring Well Soil Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

r

r

r

r

r BRL -Below Reporting Limits (see laboratory reports for compound specific detection limits)

r NA -Not Analyzed for this procedure

r The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds and their specific detection limits.

r

r

r

r I l l

r Boring I.D.: MW-1 MW-2 MW-3 CTDEP PMC GB CTDEP DEC AOCIPAOC 8 2 10 Groundwater Residential/Commercial Sample Depth: 10'-12' 10'-12' 5'-7' Area & Industrial TPH -CT ETPH (ppm) BRL BRL BRL 2,500 ppm 500/2,500 ppm

VOCs - EPA Method 8260 (ppm) BRL BRL BRL PAHs - EPA Method 8270 (ppm) BRL BRL BRL PCBs - EPA Method 8082 (ppb) NA NA BRL Not Applicable 1/10 ppm


BRL

0.0104

BRL

0.06 ppm

Not Applicable

Antimony

Zinc 0.0064 0.0077 0.0061 50 ppm

TAIBLE 3: Results of Sub-Slab Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

[

ERL -Below Reporting Limits (see laboratory reports for compound specific detection limits)

[ The compounds listed above are those that were detected - please see laboratory reports for full lists of compounds and their specific detection limits.

[

l [

[

[

[ [

Sample I.D.: AOCIPAOC

SS-1

17

SS-2

15

SS-3

14

SS-4 16


Area

CTDEP DEC Residential/Commercial .

& Industrial TPH -CT ETPH (ppm) BRL BRL BRL BRL 2,500 ppm 50012,500 ppm

VOCs - BPA Method 8260 (ppm) BRL BRL BRL BRL PAHs - EPA Method 8270 (ppm) BRL BRL BRL BRL PCBs - BPA Method 8082 (ppb) BRL BRL BRL BRL Not Applicable 1110 ppm


0.0052

BRL

BRL

BRL

13 ppm

Not Applicable

Copper

Zmc 0.0084 0.0064 0.0102 0.0058 50 ppm

r TABJLE 4: Results of FMS #5 foterior Floor Sample Analyses Pawnee Armory -100 Water Street

Pawnee, C o n n e c t i c u t

[

I [

[ [


* The production of acetone and other ketones commonly occurs when utilizing the VOC Method SW 846 5035A extraction technique. The samples were reanalyzed and the results produced similar results (acetone 0.114 ppm & MIBK 0.0592 ppm)

** The production of acetone and other ketones commonly occurs when utilizing the VOC Method SW 846 5035A extraction technique.


[

[

[

l l

[

[

Sample I.D.: AOCIPAOC Matrix:

C-1 17

Concrete

C-2 15

Concrete

C-3 14

Concrete

C-4 16

Concrete


Area


& Industrial TPH -CT ETPH (ppm) 640 232 573 477 2,500 ppm 500/2,500 ppm VOCs - EPA Method 8260 (ppm)

0.11*

0.139**

BRL

BRL

140 ppm

500/1,000 ppm Acetone 4-Methyl-2-Pentanone (MIBK) 0.0669* BRL BRL 0.0872** 14 ppm 500/1,000 ppm Toluene BRL 0.0137 BRL BRL 67 ppm 500/1,000 ppm Xylenes (total) BRL 0.0196 BRL 0.0171 19.5 ppm 500/1,000 ppm

PAHs - EPA Method 8270 (ppm) 1-Methylnaphthalene 2-Methylnaphthalene

-

Total PAHs

BRL BRL BRL

BRL BRL BRL

BRL 0.144 0.144

0.172 0.175 0.347

No Standard

9.8 ppm

No Standard

474/2,500 ppm

PCBs - EPA Method 8082 (ppb) BRL BRL BRL BRL Not Applicable 1/10 ppm SPLP Priority Pollutant Metals (ppm)

BRL

0.0179

0.0176

BRL

0.5 ppm Not Applicable

Chromium Zinc BRL BRL 0.0065 0.0086 50 ppm

TABLE 5(a): Results of Groundwater Sample Analyses Pawnee Armory - 100 Water Street

Pawnee, Connecticut

I I I I I I


I The compounds listed above are those that were detected - please see laboratory reports for full lists of

I compounds and their specific detection limits.

I I I l l

r

I

Sample I.D.:

AOCIPAOC

MW-1

8

MW-1 DUP

8

MW-2

2

CTDEP Surface Water

Protection Criteria

CTDEP Volatilization Criteria:

Residential/Commercial & Industrial

Depth to Water (feet) 21.5' 21.5' 21.7'

Field Parameters:

51.10

51.10

51.0°

Temperature (°F)

pH 6.12 6.12 6.25

Specific Conductance uS/cm 477 477 312

Turbidity (NTU) 3.11 3.11 3.22

TPH - CT ETPH (ppm)

BRL

BRL

BRL None

Established

Not Applicable

VOCs -BPA Method 8260 (ppb)

Chloroform

1.3

1.2

BRL

14,100 ppb

287/710 ppb

SVOCs -EPA Method 8270 (ppb) BRL BRL BRL Total PP 13 Metals -ppm

Thallium

0.0052

0.0054

BRL

0.063 ppm

Not Applicable

Dissolved PP 13 Metals -ppm

BRL

BRL

0.0066

0.048 ppm

Not Applicable

Copper

Zinc 0.011 0.0157 0.01 0.123 ppm

[ TABLE 5(b): Results of Groundwater Sample Analyses Pawnee Armory -100 Water Street

Pawnee, Connecticut

[

[

[

[

[

[ [

r BRL -Below Reporting Limits (see laboratory reports for compound specific detection limits)


[

[

[ l l

Sample I.D.: AOC!PAOC

MW-3

10

CTDEP Surface Water Protection

Criteria

CTDEP Volatilization Criteria:

Residential/Commercial & Industrial Depth to Water (feet) 21.0' Field Parameters:

51.3°

Temperature (°F)

pH 6.3

Specific Conductance uS/cm 297

Turbidity (NTU) 2.65

TPH -CT ETPH (ppm) BRL None Established Not Applicable

VOCs -EPA Method 8260 (ppb) BRL SVOCs -EPA Method 8270 (ppb) BRL Total PP 13 Metals -ppm BRL Not Applicable

Dissolved PP 13 Metals -ppm

Zinc

0.0076

0.123 ppm

Not Applicable

TABLE 6: Soil Gas Survey Summary October 19 & 20, 2006


I r I I I I

I I [

I I I [

I l

r

Total VOCs (PID)

Blank O ppm

SG-1 1.6 ppm

SG-2 2.0 ppm

SG-3 2.4 ppm

SG-4 2.7 ppm

SG-5 1.1 ppm

SG-6 0.9 ppm

SG-7 2.6 ppm

SG-8 1.7 ppm

SG-9 0.9 ppm

SG-10 1.8 ppm

SG-11 1.5 ppm

SG-12 1.9 ppm

SG-13 2.0 ppm

SG-14 1.8 ppm

SG-15 1.2 ppm

SG-16 0.8 ppm

r r -

r

r r -

r FIGURES

r

r r

r

r

r

r

r

I r

I I I I I

Well Drilling Completion Reports

I I I r I I I I I l I l [

I r .

Potable Well Survey Figure

I I I I l I

1 - r , -

I I I I I Site Figures

I I I I I I

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