ROUX ASSOCIATES, INC. Environmental Consulting & Management

Transcription

1 February 28, 2012 PARTIAL RESPONSE ACTION OUTCOME STATEMENT (RAO) 17 Central Street Property Peabody Essex Museum RTN Prepared for PEABODY ESSEX MUSEUM East India Square Salem, Massachusetts ROUX ASSOCIATES, INC. Environmental Consulting & Management 67 South Bedford Street, Suite 101W, Burlington, MA PEM M /RCV

2 TABLE OF CONTENTS 1.0 INTRODUCTION Site Description Site History Central Street Property History Conceptual Site Model Report Contents STRATEGY TO ACHIEVE A RESPONSE ACTION OUTCOME PARTIAL RESPONSE ACTION OUTCOME STATEMENT Control of Sources of Oil LNAPL Thickness on the 17 Central Street Property Required Operation, Maintenance, Monitoring and Future Remediation Evaluation of the Feasability of Achieving Background RISK CHARACTERIZATION REPRESENTATIVENESS EVALUATION AND DATA USABILITY ASSESSMENT Representativeness Evaluation Conceptual Site Model Use of Field Screening Data Sample Locations, Depths, Spatial Distribution, and Collection Conflicting and Disregarded Information Data Usability Assessment Analytical Data Reporting Limits Laboratory Performance Criteria and Quality Control Field Data Usability Data Rejection Data Representativeness and Usability Conclusions CONCLUSIONS AND LSP CERTIFICATION...20 TABLES 1. Well LNAPL Gauging Results 2. Soil Analytical Data Summary 3. LNAPL Viscosity Data 4. Data Usability Summary Table FIGURES 1. Site Location Map ROUX ASSOCIATES, INC. - i - PEM M /R

3 TABLE OF CONTENTS (Continued) APPENDICES A. Risk Assessment B. Capillary Fringe Thickness Calculation C. BWSC Transmittal Forms D. Public Notification Letters PLATES 1. Site Plan 2. Soil Excavation and Sampling Locations ROUX ASSOCIATES, INC. - ii - PEM M /R

4 1.0 INTRODUCTION Roux Associates, Inc. (Roux Associates) on behalf of the Peabody Essex Museum (PEM) has prepared this Partial Response Action Outcome Statement (RAO) for the 17 Central Street portion of the PEM Site originating at 161 Essex Street in Salem, Massachusetts (the Site). The Site is tracked by the Massachusetts Department of Environmental Protection (MassDEP) under Release Tracking Number (RTN) This RTN was assigned for the discovery of No. 4 fuel oil (oil) which was released from three former 10,000 gallon underground storage tanks (USTs) located on the PEM property. Remedial actions performed at the Site have achieved a condition of No Significant Risk for the portion of the Site located on the 17 Central Street property, which is located to the west and downgradient of the PEM property. A site location map has been provided as Figure 1 and a Site plan has been provided as Plate 1. This report contains a Partial Class A-2 Response Action Outcome Statement (RAO) for the 17 Central Street portion of the Site. Currently, Roux Associates anticipates conducting further remedial actions that will result in the achievement of a Site-wide Class A-2 RAO by the end of Site Description The Site is located within an urbanized section of Salem and the surrounding land is zoned for residential and commercial use. The majority of the Site is located on the PEM property at 161 Essex Street. A small portion of the Site extends to the neighboring property located at 17 Central Street and owned by Museum Place Condominiums. The impacted portion of the 17 Central Street property is confined to a common area driveway, and to a small portion of the footprint of the condominium units located within the so-called "Carriage House" structure. A figure depicting the current conditions of the Site is included as Plate 1. The 161 Essex Street property covers approximately 137,000 square feet and includes walkways, a landscape garden area, loading dock area and three separate buildings, including the main part of the museum, the boat house and the boiler plant. The largest structure on this property is the museum itself, which consists of several interconnected buildings that were constructed at various times over the last 150 years. Most of the northern and western portions of the interconnected complex contain one occupied level below grade. The boiler plant houses three boilers used to supply steam heat for the museum. The boilers currently use No. 2 fuel oil to ROUX ASSOCIATES, INC PEM M /R

5 generate steam. An active 20,000-gallon underground storage tank (UST) containing No. 2 fuel oil located to the east of the boiler plant provides fuel for the boilers. The portion of the 17 Central Street property that is within the Site boundary consists of a common area driveway, parking lot, the land situated under the Carriage House, and a portion of the Museum Place Condominium Building. During redevelopment of the condominium property, Web Engineering, Inc. (Web) installed a clay barrier wall below the ground surface along the property boundary between the 161 Essex Street and the 17 Central Street properties. Web's stated intent was to prevent further migration of LNAPL from 161 Essex Street onto the 17 Central Street Property. Web conducted this work as a Release Abatement Measure (RAM), as discussed further in Section Site History On November 24, 2003, a release to the environment was discovered at the 161 Essex Street property during a Phase I Initial Site Investigation conducted in response to the filing of a Downgradient Property Status (DPS) Opinion by Heritage Plaza Enterprises, LLC (Heritage Plaza). Web Engineering filed the DPS Opinion on the behalf of Heritage Plaza in August, Web was providing MCP consulting services to Heritage Plaza, which at the time was redeveloping the 17 Central Street property into the Museum Place Condominiums. During the Phase I investigation, LNAPL at a thickness greater than 1/2-inch was discovered in a monitoring well (MW-03) installed on the PEM property. The condition triggered a 72-hour reporting condition, and MassDEP assigned RTN to the site. MassDEP also provided verbal approval for an assessment only immediate response action (IRA). The results of the IRA investigations concluded that the IRA conditions at the Site have stabilized and that a current or future immediate threat of risk to human health, public welfare, or the environment was unlikely. Consequently, the IRA was closed out with the submission of an IRA Completion Report to MassDEP on September 24, In the fall of 2003, Heritage Plaza performed a RAM at the 17 Central Street property in conjunction with construction of a condominium development. The RAM, as overseen by Web Engineering, included the excavation of approximately 1,577 tons of fuel oil-impacted soil and the installation of a clay barrier along the property line. The barrier, as conceived by Web, ROUX ASSOCIATES, INC PEM M /R

6 was intended to bridge the water table and LNAPL-smear zone along the property boundary between the 161 Essex Street property and the 17 Central Street property and prevent future migration of No. 4 fuel oil onto the 17 Central Street property. Subsequent investigations suggest that it did not achieve its design objectives (see Section 1.3). In November 2004 ENSR Corporation (ENSR) submitted a Phase I Initial Site Investigation (ISI) and Tier Classification Report and the Site was classified as a Tier II site. The Phase I ISI indicated that LNAPL thicknesses on the 161 Essex Street property ranged from 0 to 8 feet thick. The source of the oil is believed to be three former 10,000-gallon No.4 fuel oil USTs located on the 161 Essex Street property (Plate 1). The Phase I ISI also indicated that the concentrations of dissolved phase OHM in groundwater were below applicable standards. In November 2006 ENSR submitted a Phase II Comprehensive Site Assessment (CSA) and Method 3 Risk Characterization for the Site. The Method 3 risk characterization concluded that there is no significant risk to human health and safety at the Site. However, the presence of LNAPL greater than ½ inch is an upper concentration limit (UCL) exceedance, which by definition constitutes risk to public welfare and the environment. The Phase II CSA also indicated that it appeared as though the LNAPL elevation in monitoring well MW-3 on the PEM property had periodically been higher than the top and lower than the bottom elevation of the clay barrier located between the 161 Essex Street and the 17 Central Street properties, which suggested the possibility that LNAPL could migrate beyond the hanging clay barrier. In November 2007 ENSR submitted a Supplemental Phase II CSA. Further investigations had confirmed that, despite the clay barrier, LNAPL was migrating to the 17 Central Street property from the 161 Essex Street property. ENSR implemented passive LNAPL recovery (periodic bailing) on the PEM property. Remedial Monitoring Report #1 (September 2008) indicated that a total of 42 gallons of oil and water had been recovered. In November 2008 Roux Associates submitted a Revised Phase III RAP and Phase IV RIP. The remedy for the Site was changed to thermally enhanced LNAPL recovery. The treatment system was designed to recover oil in order to achieve a Class A RAO for the 17 Central Street property and control the source of oil on the PEM property, resulting in a Class C RAO for the remainder of the Site. The treatment system was constructed during the winter and spring of 2009 and ROUX ASSOCIATES, INC PEM M /R

7 included an electric resistance heating system (ERH) to increase subsurface temperatures (thus decreasing oil viscosity) on the PEM and 17 Central Street properties, groundwater depression on the 17 Central Street property, and oil recovery using skimming pumps on the 17 Central Street and PEM properties. The treatment system operated from the summer of 2009 until April 2011, recovering approximately 5,000 gallons of oil. The system was shut down when oil recovery declined substantially and the treatment objectives were achieved Central Street Property History The 17 Central Street property was the location of a Police Station owned by the City of Salem, Massachusetts. In 2003 the Salem Redevelopment Authority contracted Heritage Plaza Enterprises, LLC (Heritage) to redevelopment the property for use as a residential condominium. Heritage contracted Web Engineering (Web) to perform a Site investigation in preparation for construction of the condominium. The investigation included the installation of soil borings and collection of soil and groundwater samples. Laboratory analysis detected gasoline and heavy fuel oil constituents in these samples. The gasoline was attributed to a former 1,000 gallon gasoline UST that had been located near the eastern (upgradient) edge of the property prior to removal in Fuel oil was attributed to an upgradient off-site source. A Release Notification and Downgradient Property Status opinion was submitted to MassDEP on August 3, 2003 and assigned RTN Prior to construction of a new building on the property (the Carriage House ), Web excavated approximately 1,600 tons of oil contaminated soil from the eastern side of the property as a Release Abatement Measure (RAM). Contaminated soil was shipped off-site for recycling. Dewatering was performed during the excavation with the water discharged on-site following backfilling of the excavation. In their January 2004 RAM Completion Report Web reported that Along the upgradient property line, delineated by a chain link fence at the site, clay backfill was placed and compacted to prevent any further migration of contaminants onto the subject property [17 Central Street]. The clay was placed in a 3-foot wide trench from 16 feet below grade to 9 feet below grade. This depth interval was selected to extend from below the zone of contaminated soil to above the seasonal high water table. ROUX ASSOCIATES, INC PEM M /R

8 In 2007 ENSR discovered that oil was seeping over, under, and or through the barrier and began passive recovery of oil to prevent further migration. By 2008 it was apparent that passive measures were not working, and that more active control measures were required. As described in Section 1.2, Roux Associates installed an ERH enhanced oil recovery system on both the PEM and 17 Central Street property during 2008 and This system operated until April 2011 and successfully reduced LNAPL thickness on the 17 Central Street property to less than ½ inch and recovered approximately 5,000 gallons of oil from the Site. In January and March 2011, Roux Associates conducted a focused investigation along the clay barrier on the upgradient side of the 17 Central Street property. Several discrete seeps of oil through the barrier (in addition to the seep near the southern end of the barrier identified by ENSR in 2007) were identified. During June and July 2011 the impacted soil on the 17 Central Street property was excavated. Examination of the barrier indicated that the barrier was constructed of silt, rather than clay. Following excavation, the seeps were sealed through the use of low-permeability controlled fill (concrete) during backfilling of the excavations. No LNAPL was observed in the excavations, and end point samples confirmed that cleanup standards were achieved at each of the excavation locations. 1.4 Conceptual Site Model The Site is comprised of sand and silt deposits, with groundwater located 12 to 15 feet below the ground surface. Groundwater flow is generally to the west southwest at an estimated 175 feet per year. During the 1960s and 1970s, the museum maintained underground storage tanks (USTs) containing No. 4 fuel oil for the museum s boilers near the western edge of their property. These tanks are believed to have released between 8,000 and 10,000 gallons of fuel oil. Migration of the oil was limited to the PEM and 17 Central Street properties due to the high viscosity of the fuel oil. Since its release, the oil has become weathered, losing the more soluble and volatile fractions. The remaining oil has a very high viscosity, low solubility, and very low volatility. Remediation has successfully recovered approximately 5,000 gallons of the oil. Remaining contamination includes LNAPL, primarily on the PEM property, and residual phase contamination in soil. Although vapor phase and dissolved phase contamination have been detected, they are not significant due to the low volatility and solubility of the oil. ROUX ASSOCIATES, INC PEM M /R

9 Due to the depth if oil below ground surface, receptors are limited to construction and utility workers. 1.5 Report Contents This Partial Response Action Outcome Statement summarizes the Response Action conducted at the Site, current conditions, and risks associated with the site. This report further describes the area for which this Partial RAO pertains, and plans for achieving an RAO for the remainder of the Site. The remainder of this report is formatted as follows: Section 2.0 includes a description of the strategy to achieve a Site-wide RAO; Section 3.0 is a Partial RAO Statement for the 17 Central Street Property; Section 4.0 is an updated Method 3 Risk Assessment supporting the Partial RAO; Section 5.0 is a Data Usability and Representativeness Evaluation Section 6.0 is an LSP Opinion and Certification of the RAO. ROUX ASSOCIATES, INC PEM M /R

10 2.0 STRATEGY TO ACHIEVE A RESPONSE ACTION OUTCOME As described herein, remedial actions conducted at the Site have controlled the oil remaining in the subsurface on the PEM property and have reduced the thickness of LNAPL on the 17 Central Street property to less than ½-inch in the environment. A Method 3 Risk Characterization (Section 4.0 and Appendix A) has determined that a condition of No Significant Risk exists for the 17 Central Street property and the requirements of a Partial Class A-2 RAO for that property have been met. In the Phase IV Remedy Implementation Plan (November, 2008), the remedial goal selected for the 17 Central Street property was a Class A-2 RAO. At that time, a Class A RAO for the PEM property was not feasible due to buildings and utilities present in the Site footprint, so a Class C-1 RAO was selected as a remedial goal for the PEM property. However, PEM has recently obtained funding for a major facility expansion, which is expected to include the demolition of buildings and utilities that were preventing further remediation. During this construction, it will be feasible to excavate remaining contamination from the PEM property to the extent that achievement of a Class A RAO is expected. PEM anticipates that these additional remedial activities will be performed during the second and third quarters of 2013, and that a Site-wide Class A RAO will be achieved before the end of Detailed plans for the performance of additional remediation and changes to the anticipated schedule will be described in future Phase V Status Reports. ROUX ASSOCIATES, INC PEM M /R

11 3.0 PARTIAL RESPONSE ACTION OUTCOME STATEMENT This Partial Class A-2 RAO Statement is for the portion of the PEM Site (RTN ) located on the 17 Central Street Property (aka the Heritage Plaza property). Contamination came to be located on the 17 Central Street property through migration of No. 4 fuel oil from the adjacent upgradient PEM property located at 161 Essex Street in Salem, Massachusetts. The Site location is shown on Figure 1, the boundaries of the 17 Central Street property, which are the limits of this Partial RAO, are shown on Plate 1. As described herein, sources of oil have been eliminated or controlled, contaminants on the 17 Central Street property have been reduced to below upper concentration limits (UCLs), and a condition of No Significant Risk has been achieved. 3.1 Control of Sources of Oil In accordance with the MCP [310 CMR (5)] sources of oil that may result in increased concentrations in environmental media need to be eliminated or controlled for the achievement of a Class A RAO. As has been documented in the 17 Central Street Risk Characterization (Section 4.0 and Appendix A) and Supplemental Phase II report (ENSR, 2007), there is No Significant Risk associated with dissolved phase petroleum concentrations in groundwater or vapor phase petroleum concentrations in indoor air or soil gas. Testing has demonstrated that despite the historic presence of LNAPL with apparent thickness of several feet in monitoring wells on the PEM property, the oil present has minimal soluble and volatile fractions. Additionally, since the release is believed to be over 30 years old (releases are believed to have occurred during the 1960s and/or 1970s), contaminant conditions have stabilized and have been significantly improved as a result of remediation. Therefore, the presence of LNAPL and absorbed petroleum is not likely to result in increased concentrations in other environmental media. Oil remaining in the subsurface could migrate onto the 17 Central Street property contaminating additional soil if sufficient thicknesses were present to provide a driving head for migration. However, oil migration has been controlled or eliminated through: Reducing the quantity of oil present on the Site; Continued oil recovery (pumping and bailing) upgradient of the PEM/17 Central Street property line; and ROUX ASSOCIATES, INC PEM M /R

12 Sealing of seeps through the barrier wall near the PEM/17 Central Street property line with controlled density fill (concrete) following excavation of these seeps (see the September 2011 Phase V Status and Remedial Monitoring Report, Section 3). As described in Section 1.2, over 5,000 gallons of oil has been recovered to date through the operation of the LNAPL recovery system. This oil recovery has decreased the head driving LNAPL migration. The ERH system was deactivated because oil migration had decreased to the point that, even at elevated temperature/reduced viscosity, the recovery rate for the whole system had decreased significantly, and no measurable recovery was occurring on the 17 Central Street property. Since the deactivation of the ERH system, subsurface temperatures have decreased to ambient temperatures and oil viscosity has increased. At ambient temperatures, the viscosity of the residual No. 4 fuel oil is sufficient to render the oil nearly immobile. The limited remaining mobility is controlled through the continued recovery of oil upgradient of the 17 Central Street property and by the sealing migration pathways with controlled density fill (concrete) in Control of the LNAPL will be maintained in this manner pending further remediation as described in Section LNAPL Thickness on the 17 Central Street Property To achieve a Class A-2 RAO for the 17 Central Street Property, the thickness of LNAPL in the environment on the 17 Central Street property must be below ½ inch (the UCL). In 2011, an investigation was conducted to determine the extent of oil contamination remaining on the 17 Central Street property (see the September 2011 Phase V Status and Remedial Monitoring Report, Section 3). Data from the January and March 2011 investigation, ERH remediation monitoring program, and 2011 excavation program were combined to provide a weight of evidence test to demonstrate that LNAPL had been reduced to less than the UCL. Evidence supporting a conclusion that LNAPL has been reduced to less than the UCL on the 17 Central Street property includes: LNAPL was not observed during soil excavation in areas in which the highest petroleum concentrations were detected in soil borings; Following remediation, the area where residual contamination is present at the 17 Central Street property is insufficient to represent a continuous separate phase of oil > 1/2-inches in the environment; ROUX ASSOCIATES, INC PEM M /R

13 Maximum thickness of LNAPL observed in wells has been at a thickness less than the capillary fringe thickness; Concentrations of oil remaining in soil are substantially below the mobility limits predicted in published literature; The remaining oil has returned to ambient temperature (as compared to greater than 150 F during ERH operation) and as a result the viscosity is significantly higher; and The head pressure is reduced due to the substantial recovery of oil in the source area. The oil s mobility is therefore substantially reduced and not likely sufficient to allow for significant migration. The absence of LNAPL in the 2011 excavation and on the water table is a line of evidence that the oil at the 17 Central Street property was primarily residual saturation and that minimal LNAPL was present. Prior to the 2011 excavation, oil staining was observed in soil cores at levels ranging from slight staining to visibly saturated. In particular, boring HS-07 was visibly saturated across the water table (Plate 2). Laboratory results for HS-07 (12-14 feet below ground surface) demonstrated an oil concentration (combined EPH ranges) of 40,860 mg/kg. This was the highest concentration detected, with HS-03 ( feet below ground surface, also logged as petroleum saturated) being the next highest concentration of 25,020 mg/kg for the combined EPH ranges. As a conservative measure, all borings with oil concentrations above 10,000 mg/kg were excavated. During excavation, however, oil present on groundwater in the excavation was limited to a sheen (at most) in each cell. No measurable thickness was observed, and the sheens were removed using absorbent pads. The excavations are described in more detail in the September 2011 Phase V Status and Remedial Monitoring Report. Following the excavations, residual contamination on the 17 Central Street property was limited to the vicinity of wells EX-01 and EX-02. This area is bounded by: boring HS-08 and HS-09 (where oil staining was observed but not oil saturation) to the north, HS-10 (no contamination observed) to the south, MW-20 (sheens observed) to the west, and ROUX ASSOCIATES, INC PEM M /R

14 the PEM property to the east. The total size of this area is approximately 15 feet (north to south) by 25 feet (east to west). The LNAPL thickness in wells EX-01 and EX-02, being consistently less than the capillary fringe thickness, provides a line of evidence that oil is not present in sufficient quantity or thickness to be considered a continuous separate phase. It is widely documented in published literature and guidance documents that the thickness of LNAPL present in a monitoring well is substantially greater than that present in the environment. Literature published over the past several years indicates that LNAPL thicknesses must be greater than the capillary fringe thickness in order for oil to be present as a continuous separate phase. Roux Associates calculated the capillary fringe thickness to be greater than four-feet based on soil grain size distribution and standard geotechnical methods (Appendix B). Since the shutdown of the ERH system, the thickness of LNAPL in well EX-02 on the 17 Central Street property has been less than half the calculated capillary fringe thickness, with the thicknesses measured in EX-01 and MW-17 being even less. LNAPL gauging data for the 17 Central Street property is presented on Table 1. The measured LNAPL thickness in wells EX-01 and MW-17 has further decreased as the subsurface has approached ambient temperature and the oil mobility has decreased. Additionally, the American Petroleum Institute (API) has published estimated concentrations of oil in soil that would be indicative of the presence of LNAPL (API Bulletin No. 9, Non-Aqueous Phase Liquid Mobility Limits in Soil, June 2000). For fuel oils, API s suggests an oil concentration of 17,000 mg/kg is the minimum mobility limit in sandy soil types (as observed at the Site), below which LNAPL would not be present (with a 95% confidence). As shown on Table 2, concentrations greater than 17,000 mg/kg mobility limit were detected in borings HS-03, HS-04, HS-07, HS-15, and HS-16. Each of these locations was removed during the June 2011 excavation. However, despite detected oil concentrations greater than the API published conservative mobility limits, LNAPL was not observed during excavation. Roux Associates has concluded, therefore, that the API published mobility limit is an appropriately conservative screening level for the presence of LNAPL for the soil type and oil type present at this Site. Of the boring locations that were not excavated, boring HS-09 has the highest detected oil concentration of 5,850 mg/kg. This is several times lower than both the API mobility limit ROUX ASSOCIATES, INC PEM M /R

15 and the concentrations of other boring locations where LNAPL was not observed during excavation. This provides an additional line of evidence that LNAPL is not present at HS-09 and is not present as a continuous separate phase on the 17 Central Street property. The Site ERH system was deactivated in April 2011 because LNAPL recovery on the 17 Central Street property had virtually stopped. Since that time the subsurface temperatures have returned to ambient temperatures and the LNAPL viscosity has increased from approximately 24 cs at 65 C to over 140cS at 15 C (Table 3). The increase in oil viscosity results in less mobility for the remaining contamination, and thus further decreases the amount of oil that could constitute a continuous separate phase. Since multiple lines of evidence suggest that LNAPL present on the 17 Central Street property is minimal and discontinuous, Roux Associates has concluded that the preponderance of the evidence demonstrates that the UCL is not exceeded on the 17 Central Street property. 3.3 Required Operation, Maintenance, Monitoring and Future Remediation No remediation is necessary to maintain the Partial RAO on the 17 Central Street property. Pumping and/or bailing of LNAPL from wells on the downgradient (west) side of the PEM property will continue under Phase V Remedy Operation Status (ROS) in order to prevent the migration of additional oil onto the 17 Central Street property. Periodic monitoring of LNAPL thickness will be conducted to confirm the continued effectiveness of the oil migration control program. In addition, excavation of the remaining oil on the PEM property is expected to be conducted as part of a facility expansion project in the second or third quarter of Detailed plans for those remedial activities will be presented in an upcoming Phase V Status Report. Excavation activities are expected to result in a condition of No Significant Risk for the entire Site, and achievement of a Site-wide Class A-2 RAO is expected by the end of Evaluation of the Feasability of Achieving Background Remediation has resulted in a condition of No Significant Risk for the 17 Central Street property, however, petroleum compounds are present in soil in this portion of the Site at concentrations ROUX ASSOCIATES, INC PEM M /R

16 above background. The feasibility of achieving or approaching background was presented in the Phase III/IV Report (Roux, 2008). Although site cleanup goals have changed, the feasibility assessment results have not changed for the 17 Central Street property because: Additional excavation required to remove oil from beneath the parking area of the property to levels approaching background would have increased the excavation costs by over 20%; Remediation conducted to address oil beneath the property driveway has been performed to the point of diminishing returns and the cost of additional in-situ remediation necessary to approach background was greater than 20% of the costs already expended; It is categorically infeasible to attempt to excavate in the driveway or beneath buildings on the property due to the proximity to the existing building; and Remediation was not required for groundwater, therefore it was categorically infeasible to achieve or approach background in that media. In accordance with MassDEP Policy WSC , it is not feasible to achieve or approach background conditions on the 17 Central Street property once a condition of No Significant Risk was achieved. ROUX ASSOCIATES, INC PEM M /R

17 4.0 RISK CHARACTERIZATION Risks at the 17 Central Street property were assessed in 2006 (ENSR, 2006), 2007 (ENSR, 2007), and a Supplemental Method 3 Risk Characterization (RC) included as Appendix A to this report. A risk characterization was prepared for the Site in the 2006 Phase II Comprehensive Site Assessment (CSA) (ENSR, 2006), which evaluated risks to current and future Site receptors, including museum workers, museum visitors, construction workers, utility workers and residents. A supplemental risk assessment was included in the Supplemental Phase II CSA (ENSR, 2007), and included an evaluation of risks for the following receptors at 17 Central Street: On-site resident: Surface soil (ingestion/dermal contact) Indoor air (inhalation) Construction Worker: Subsurface/surface soil (ingestion, dermal contact and inhalation) Groundwater (ingestion and dermal contact) Trench air (inhalation) Utility Worker: Subsurface/Surface soil (ingestion, dermal contact and inhalation of particulates) Human health risks were determined to be less than MCP risk limits (ENSR, 2007). No significant risk to safety was concluded, but a condition of No Significant Risk to public welfare and the environment had not been achieved, due to the presence of LNAPL in excess of ½-inch in the environment. As described in Section 3, since the 2007 Supplemental Phase II CSA, remediation has occurred at the Site, which has resulted in source removal. The Supplemental RC re-evaluated risks based upon information provided in the reports issued in 2006 and 2007, and the recently-collected ROUX ASSOCIATES, INC PEM M /R

18 data. The Supplemental RC relied upon the hazard identification, dose-response assessment, exposure assessment, environmental risk characterization and the characterization of risk to safety presented in the 2006 Method 3 risk characterization, and evaluation of construction worker risks associated with groundwater and excavation trench air presented in the 2007 Supplemental human health risk characterization (HHRC). The RC in Appendix A includes updates to the 2007 Supplemental risk assessment and assesses: 1. Risks based on current (post-remediation) soil conditions; 2. Metals in groundwater, which were detected in 2007 as part of permitting operations; 3. Potential vapor intrusion impacts, consistent with recently revised MassDEP guidance; and 4. Risks to public welfare and the environment, given the removal of LNAPL on the 17 Central Street property. Based upon the information provided in the RC, and considering the 2006 and 2007 risk characterizations prepared for the Site, a condition of No Significant Risk exists at the portion of the Site located on the 17 Central Street property under current and unrestricted future uses. ROUX ASSOCIATES, INC PEM M /R

19 5.0 REPRESENTATIVENESS EVALUATION AND DATA USABILITY ASSESSMENT Roux Associates performed a Representativeness Evaluation and Data Usability Assessment (REDUA) Policy WSC This REDUA generally follows the sections recommended in Appendix V of that policy. 5.1 Representativeness Evaluation A representativeness evaluation was conducted for the data used to support this partial RAO for the 17 Central Street property. The evaluation was conducted in general conformance with the REDUA guidance and as documented below. The evaluation concluded that the data used to support this partial RAO is representative of conditions in the subject area of the site Conceptual Site Model The PEM Site is located in Salem, Massachusetts. The area has been developed and used for a variety of residential and commercial uses for hundreds of years. The PEM property is currently used as a museum. The 17 Central Street property, which is the subject of this partial RAO, is a residential condominium. The Site is comprised of sand and silt deposits, with groundwater located 12 to 15 feet below the ground surface. Groundwater flow is generally to the west southwest at an estimated 175 feet per year. During the 1960s and 1970s the museum maintained underground storage tanks (USTs) containing No. 4 fuel oil for the museum s boilers near the western edge of their property. These tanks are believed to have released between 8,000 and 10,000 gallons of fuel oil over that period. Migration of the oil was limited to the PEM and 17 Central Street properties due to the high viscosity of the fuel oil. Since its release, the oil has become weathered, losing the more soluble and volatile fractions. The remaining oil has a very high viscosity, low solubility, and very low volatility. Remediation has successfully recovery approximately 5,000 gallons of the oil. Remaining contamination includes LNAPL, primarily on the PEM property, and residual phase contamination in soil. Although vapors phase and dissolved phase contamination have been detected, they are not significant due to the low volatility and solubility of the oil. ROUX ASSOCIATES, INC PEM M /R

20 5.1.2 Use of Field Screening Data Field screening data used to support this partial RAO is limited to field measurements of LNAPL thickness. The high LNAPL viscosity can cause an interface probe to become coated making detection of the water interface difficult. This would likely result in over-quantification of the LNAPL thickness Sample Locations, Depths, Spatial Distribution, and Collection Continuous soil cores were collected from the ground surface to a depth of five to ten feet below the water table to evaluate the presence of LNAPL in soil. Monitoring wells used for groundwater sampling and LNAPL measurement were screened across the water table and were installed up gradient, down gradient, cross gradient, and within the 17 Central Street plume area. Samples were collected using standard methodologies. Due to the age and stability of the plume, temporal sampling was not used. There is no evidence of hot spots or preferential pathways for oil migration on or onto the 17 Central Street property. A clay barrier installed by Web (Section 1.3) and further sealed by Roux Associates restricts migration of oil onto the subject property. The locations and distribution of sample locations used were adequate for the purpose of supporting this partial RAO Conflicting and Disregarded Information Soil data collected from the 17 Central Street property prior to remedial actions (ERH enhanced LNAPL recovery and excavation) are not representative of current conditions and were disregarded in the risk assessment. Three groundwater samples were collected from the LNAPL recovery system influent for compliance with NPDES permit requirements. These samples were analyzed for compounds not related to fuel oil and not measured in other samples. These results are discussed in the risk assessment (Appendix A, Section ). Because these samples were collected from active pumping wells shortly after (within several days) the commencement of pumping, these samples contained suspended solids (silt) at concentrations that would not have been present in groundwater samples collected using standard environmental sampling procedures (i.e. low flow sampling) and are not representative of groundwater conditions. These samples were excluded the Risk Assessment. ROUX ASSOCIATES, INC PEM M /R

21 5.2 Data Usability Assessment A data usability assessment was conducted for the data used to support this partial RAO for the 17 Central Street property. The assessment was conducted in general conformance with the REDUA guidance and as documented below. The assessment concluded that the data used to support this partial RAO is of sufficient precision and accuracy for the intended use Analytical Data Analytical data used to support this RAO is listed on Table 4 and is presented in the RC (Appendix A). Analytical data was produced in general conformance with the MassDEP Compendium of Analytical Methods (CAM) laboratory methods. Non-CAM methods were used for the analysis of groundwater samples analyzed for compliance with the NPDES surface water discharge program, which prescribes the use of non-cam methods. Measurements of Site contaminants and soil physical properties (e.g. temperature, viscosity, grain size) were relied upon for this RAO, and were performed using standard laboratory and field methods Reporting Limits Reporting limits used were generally the lowest reporting limits achievable using standard methods. Elevated reporting limits resulted from dilution of some samples due to high contaminant concentrations. The reporting limits of the samples used to support this partial RAO were adequate for the RC and definition of the Site boundaries Laboratory Performance Criteria and Quality Control Laboratory data used to support this RAO generally met the CAM performance criteria. Several samples were flagged as biased high due to high spike recovery or the presence of non-target interferences. As a conservative measure these results were treated as un-biased results. One laboratory package was flagged as estimated due to the poor repeatability in the laboratory control sample, however this poor precision did not affect the outcome of analysis using this data Field Data Usability Sample collection, preservation, and handling followed established sampling techniques and method requirements. ROUX ASSOCIATES, INC PEM M /R

22 5.2.5 Data Rejection As discussed in the Risk Assessment (Appendix A), samples were collected for compliance with a NPDES discharge permit for water discharged from a Site remediation system. Because these samples were collected from active remediation system pumping wells, laboratory analytical data for these samples are not comparable to data collected using low-flow sampling techniques and are not considered representative of groundwater at the Site. These data were, therefore, rejected. 5.3 Data Representativeness and Usability Conclusions The data set that was relied upon to support this RAO is scientifically valid and defensible, and of sufficient accuracy, precision, and completeness for the purpose. The data is representative with regards to the spatial and temporal distribution of sampling points. ROUX ASSOCIATES, INC PEM M /R

23 6.0 CONCLUSIONS AND LSP CERTIFICATION As documented herein, the Portion of the PEM Site located on 17 Central Street, as shown on Plate 2, meets the requirements for a Class A-2 Partial Response Action Outcome. Comprehensive response actions have been performed as required by the MCP and under the oversight of the Licensed Site Professional (LSP) of record for the Site, Mr. Glen P. Gordon (LSP No. 1553). Mr. Gordon has signed this report and electronically signed and sealed the transmittal form (BWSC-104) that accompanies the submittal of this report. A copy of this form is included in Appendix C. Copies of letters to the Chief Municipal Officer and Board of Health of the Town of Salem, notifying them of the availability of this Partial RAO Statement, are provided in Appendix D. ROUX ASSOCIATES, INC PEM M /R

24 Respectfhlly Submitted, ROUX ASSOCIATES, inc., Senior Scientist Glen P. Gordon, P.E., LSP Principal Engineer ROUX ASSOCIATES, INC. PEM1673.ooolMoo21971R

25 TABLES

26 Table 1: Well LNAPL Gauging Results Peabody Essex Museum Salem, Massachusetts EX-01 EX-01 LNAPL Thickness LNAPL Thickness Depth to LNAPL Depth To Water Depth to LNAPL Depth To Water Date (Feet) Date (Feet) 13-May Oct Jun Oct Jun Nov Jul Nov Jul Nov Jul Nov Jul Nov Aug Nov Aug Nov Aug Dec Aug Dec Sep Dec Sep Jan Sep Jan Sep Jan Oct Feb Oct Feb Oct Feb Oct Feb Oct Mar Oct Mar Nov Mar Nov Mar Nov Apr Nov Apr Nov Apr Dec May Dec Jun Dec Jul Dec Jul Dec Aug Jan Aug Jan Aug Jan Aug Jan Sep Jan Sep Jan Sep Feb Sep Feb Oct Feb Oct Feb Nov Feb Nov Feb Nov Feb Dec Mar Mar Mar Mar Mar Apr Apr Apr Apr May May May May May May General Notes: 28-May = LNAPL not detected in well 04-Jun All depth to measurements are in feet below the top of casing 11-Jun Jun Jun Jun Jun Jul Jul Jul Jul Aug Aug Aug Aug Aug Sep Sep Sep Sep Sep Oct Oct Oct ROUX ASSOCIATES, INC. 1 of 6 PEM M /T1

27 Table 1: Well LNAPL Gauging Results Peabody Essex Museum Salem, Massachusetts EX-02 EX-02 LNAPL Thickness LNAPL Thickness Depth to LNAPL Depth To Water Depth to LNAPL Depth To Water Date (Feet) Date (Feet) 05-Feb Oct May Oct Jun Oct Jun Oct Jul Nov Jul Nov Jul Nov Jul Nov Aug Nov Aug Nov Aug Nov Aug Dec Aug Dec Sep Dec Sep Jan Sep Jan Sep Jan Sep Feb Oct Feb Oct Feb Oct Feb Oct Mar Oct Mar Oct Mar Oct Mar Nov Apr Nov Apr Nov Apr Nov May Nov Jun Dec Jul Dec Jul Dec Aug Dec Aug Dec Aug Jan Aug Jan Sep Jan Sep Jan Sep Jan Sep Jan Oct Feb Oct Feb Nov Feb Nov Feb Nov Feb Dec Feb Feb Mar Mar Mar Mar Mar Apr Apr Apr Apr May May General Notes: 10-May = LNAPL not detected in well 18-May All depth to measurements are in feet below the top of casing 21-May May May Jun Jun Jun Jun Jun Jun Jul Jul Jul Jul Aug Aug Aug Aug Aug Sep Sep Sep Sep Oct ROUX ASSOCIATES, INC. 2 of 6 PEM M /T1

28 Table 1: Well LNAPL Gauging Results Peabody Essex Museum Salem, Massachusetts MW-17 MW-17 LNAPL Thickness LNAPL Thickness Depth to LNAPL Depth To Water Depth to LNAPL Depth To Water Date (Feet) Date (Feet) 28-Jun Oct Jul Oct Sep Oct Oct Nov Nov Nov Dec Nov Jan Nov Jan Nov Apr Nov Sep Nov Feb Dec Jun Dec Jul Dec Jul Jan Aug Jan Aug Jan Aug Jan Aug Feb Sep Feb Sep Feb Sep Feb Sep Mar Sep Mar Oct Mar Oct Mar Oct Mar Oct Apr Oct Apr Oct Apr Oct May Nov Jun Nov Jul Nov Jul Nov Aug Nov Aug Dec Aug Dec Aug Dec Sep Dec Sep Jan Sep Jan Sep Jan Oct Jan Oct Feb Nov Feb Nov Feb Nov Feb Dec Mar Mar Mar Apr Apr Apr Apr May May May May May General Notes: 25-May = LNAPL not detected in well 28-May All depth to measurements are in feet below the top of casing 04-Jun Jun Jun Jun Jun Jul Jul Jul Jul Aug Aug Aug Aug Aug Aug Sep Sep Sep Sep Sep Oct Oct Oct ROUX ASSOCIATES, INC. 3 of 6 PEM M /T1

29 Table 1: Well LNAPL Gauging Results Peabody Essex Museum Salem, Massachusetts MW-18 MW-18 LNAPL Thickness LNAPL Thickness Depth to LNAPL Depth To Water Depth to LNAPL Depth To Water Date (Feet) Date (Feet) 28-Jun Mar Jul Mar Sep Apr Oct Apr Oct Apr Nov May Dec Jun Jan Jul Apr Jul Apr Aug Sep Aug Feb Sep Jun Sep Jul Dec Jul Aug Aug Aug Sep Oct Oct Oct Oct Oct Oct Nov Nov Nov Dec Dec Dec Dec Jan Jan Jan Jan Feb Feb Feb Mar Apr Apr Apr Apr May May May May Jun Jun Jun Jun Jun Jul Jul Jul Jul Jul Aug General Notes: 10-Aug = LNAPL not detected in well 18-Aug All depth to measurements are in feet below the top of casing 23-Aug Aug Sep Sep Sep Sep Oct Oct Oct Oct Oct Nov Nov Nov Nov Nov Dec Dec Dec Jan Jan Jan Mar ROUX ASSOCIATES, INC. 4 of 6 PEM M /T1

30 Table 1: Well LNAPL Gauging Results Peabody Essex Museum Salem, Massachusetts MW-19 MW-19 LNAPL Thickness LNAPL Thickness Depth to LNAPL Depth To Water Depth to LNAPL Depth To Water Date (Feet) Date (Feet) 28-Jun Apr Jul Apr Oct Apr Oct May Nov Jun Dec Jul Jan Jul Apr Aug Apr Aug Sep Sep Feb Sep Jun Dec Jul Jul Aug Aug Aug Sep Oct Oct Oct Oct Oct Oct Nov Nov Nov Dec Dec Dec Dec Jan Jan Jan Feb Feb Feb Mar Mar Apr Apr Apr Apr May May May May Jun Jun Jun Jun Jun Jul Jul Jul Jul Jul Aug Aug General Notes: 18-Aug = LNAPL not detected in well 23-Aug All depth to measurements are in feet below the top of casing 31-Aug Sep Sep Sep Sep Oct Oct Oct Oct Oct Nov Nov Nov Nov Nov Dec Dec Dec Jan Jan Mar Mar Mar ROUX ASSOCIATES, INC. 5 of 6 PEM M /T1

31 Table 1: Well LNAPL Gauging Results Peabody Essex Museum Salem, Massachusetts MW-20 Date Depth to LNAPL Depth To Water LNAPL Thickness (Feet) 15-Oct Oct Nov Dec Jan Apr Apr Feb Jul Nov Jan May Aug Nov MW-06 Date Depth to LNAPL Depth To Water LNAPL Thickness (Feet) 04-Aug Oct Jan Apr Apr Jun Nov Apr Jul Oct Apr Jul Oct Dec Jan Apr Apr Sep Feb Aug Nov Dec Jan May Aug Nov MW-16 Date Depth to LNAPL Depth To Water LNAPL Thickness (Feet) 20-Jul Oct Apr Jul Oct Dec Jan Apr Sep Feb Aug Nov Dec Jan May Aug Nov General Notes: -- = LNAPL not detected in well All depth to measurements are in feet below the top of casing ROUX ASSOCIATES, INC. 6 of 6 PEM M /T1

32 Table 2: Soil Analytical Data Summary Peabody Essex Museum Salem, Massachusetts Soil Boring Samples Designation HS-01 HS-02 HS-03 HS-04 HS-07 HS-08 HS-09 HS-11 Date Sampled 26-Jan Jan Jan Jan Jan Jan Jan Jan-11 Sample Depth Solids, Total (%) Methylnaphthalene U Acenaphthene U Acenaphthylene 2.12 U U 7.33 U 14.3 U 2 U 1.88 U U Anthracene 2.12 U U 7.33 U U Benzo(a)anthracene 2.12 U U U 14.3 U 2 U 1.88 U U Benzo(a)pyrene 2.12 U U U 14.3 U 2 U 1.88 U U Benzo(b)fluoranthene 2.12 U U U 14.3 U 2 U 1.88 U U Benzo(ghi)perylene 2.12 U U 7.3 U 7.33 U 14.3 U 2 U 1.88 U U Benzo(k)fluoranthene 2.12 U U 7.3 U 7.33 U 14.3 U 2 U 1.88 U U Chrysene 2.12 U U 14.3 U 2 U 1.88 U U Fluoranthene 2.12 U U U 1.88 U U Fluorene Indeno(1,2,3-cd)Pyrene 2.12 U U 7.3 U 7.33 U 14.3 U 2 U 1.88 U U Naphthalene U Phenanthrene U Pyrene 2.12 U U U U 1.88 U U C11-C22 Aromatics, Adjusted 2,140 1,480 9,140 6,780 14,300 2,020 2, C9-C18 Aliphatics 2,240 1,170 11,100 7,400 17,300 2,050 2, C19-C36 Aliphatics 1, ,780 3,110 9, , General Notes: 1. Units are mg/kg. 2. BOLD = detected above laboratory reporting limit. 3. U = Compound not detected above the laboratory reporting limit. 4. Only compounds with at least one detection above a minimum laboratory reporting limit are presented. 5. Samples were analyzed using the CAM method, and laboratory analytical report is included with Appendix C. 6. Highlighted Samples were removed during 2011 excavation. ROUX ASSOCIATES, INC. 1 of 3 PEM M /T2

33 Table 2: Soil Analytical Data Summary Peabody Essex Museum Salem, Massachusetts Soil Boring Samples Designation HS-12 HS-13 HS-14 HS-15 HS-16 HS-17 HS-18 HS-19 HS-19DUP Date Sampled 30-Mar Mar Mar Mar Mar Mar Mar Mar Mar-11 Sample Depth Solids, Total (%) Methylnaphthalene U U Acenaphthene U U U U Acenaphthylene 12 U 7.72 U 11.6 U 14.1 U 22.6 U 1.55 U 1.49 U 1.14 U U Anthracene 12 U 7.72 U 11.6 U 14.1 U 22.6 U 1.55 U U U Benzo(a)anthracene 12 U 7.72 U 11.6 U 14.1 U 22.6 U U U Benzo(a)pyrene 12 U 7.72 U 11.6 U 14.1 U 22.6 U U U Benzo(b)fluoranthene 12 U 7.72 U 11.6 U 14.1 U 22.6 U 1.55 U U U Benzo(ghi)perylene 12 U 7.72 U 11.6 U 14.1 U 22.6 U 1.55 U U U Benzo(k)fluoranthene 12 U 7.72 U 11.6 U 14.1 U 22.6 U 1.55 U U U Chrysene 12 U 7.72 U 11.6 U 14.1 U 22.6 U U U Fluoranthene 12 U 7.72 U 11.6 U 14.1 U 22.6 U U U Fluorene U 11.6 U U U Indeno(1,2,3-cd)Pyrene 12 U 7.72 U 11.6 U 14.1 U 22.6 U 1.55 U U U Naphthalene U U U Phenanthrene U 11.6 U U U Pyrene 12 U 7.72 U 11.6 U 14.1 U 22.6 U U U C11-C22 Aromatics, Adjusted 4,290 2,680 3,320 6,010 10,300 1,010 2, C9-C18 Aliphatics 6,520 3,500 4,250 7,930 10,200 1,260 1, C19-C36 Aliphatics 2,660 1,410 1,790 3,430 4, , General Notes: 1. Units are mg/kg. 2. BOLD = detected above laboratory reporting limit. 3. U = Compound not detected above the laboratory reporting limit. 4. Only compounds with at least one detection above a minimum laboratory reporting limit are presented. 5. Samples were analyzed using the CAM method, and laboratory analytical report is included with Appendix C. 6. Highlighted Samples were removed during 2011 excavation. ROUX ASSOCIATES, INC. 2 of 3 PEM M /T2

34 Table 2: Soil Analytical Data Summary Peabody Essex Museum Salem, Massachusetts Endpoint Samples Designation N.CELL 2/2-S BOTTOM M. CELL 1/4- NE BOTTOM M.CELL 4/4-SW BOTTOM Date Sampled 20-Jun Jun Jun-11 Sample Depth 7.0 (a) 6.5 (a) 6.5 (a) Solids, Total (%) Methylnaphthalene U U U Acenaphthene U U U Acenaphthylene U U U Anthracene U U U Benzo(a)anthracene U U U Benzo(a)pyrene U U U Benzo(b)fluoranthene U U U Benzo(ghi)perylene U U U Benzo(k)fluoranthene U U U Chrysene U U U Fluoranthene U U U Fluorene U U U Indeno(1,2,3-cd)Pyrene U U U Naphthalene U U U Phenanthrene U U U Pyrene U U U C11-C22 Aromatics, Adjusted U 7.95 U C9-C18 Aliphatics U 7.95 U C19-C36 Aliphatics U 7.95 U General Notes: 1. Units are mg/kg. 2. BOLD = detected above laboratory reporting limit. 3. U = Compound not detected above the laboratory reporting limit. 4. Only compounds with at least one detection above a minimum laboratory reporting limit are presented. 5. Samples were analyzed using the CAM method, and laboratory analytical report is included with Appendix C. 6. Highlighted Samples were removed during 2011 excavation. Footnotes (a) Endpoint sample depths reported as feet of site elevaton ROUX ASSOCIATES, INC. 3 of 3 PEM M /T2

35 Table 3: LNAPL Viscosity Data Peabody Essex Museum Salem, Massachusetts Well ID Date Temp 1 Method 2 Viscosity ( C) (Centistokes) EX-02 3/19/ Analytical Method ASTM D445/ /3/ Viscosity Cup # /2/ Viscosity Cup # /2/ Viscosity Cup # EX-03 8/3/ Viscosity Cup # EX-04 8/3/ Viscosity Cup # EX-05 5/18/ Viscosity Cup # /3/ Viscosity Cup # EX-07 3/19/ Analytical Method ASTM D445/ /3/ Viscosity Cup # EX-08 3/19/ Analytical Method ASTM D445/ EX-09 8/3/ Viscosity Cup # EX-11 5/18/ Viscosity Cup # MW-10 8/18/ Viscosity Cup # /3/ Viscosity Cup # MW-14 10/31/ Analytical Method ASTM D /31/ Analytical Method ASTM D /19/ Analytical Method ASTM D445/ MW-17 5/18/ Viscosity Cup # Peabody Essex Museum LNAPL Viscosity Data Compared to Reference Fuel Oil Curves #5 Range #6 Range MW-14 EX-03 Viscosity (Centistokes) #4 Range MW-17 EX-07 MW-10 EX-05 EX-02 EX-02 EX-04 MW-10 EX-09 EX #2 Range EX-07 EX-02 EX-05 MW-14 EX-11 MW-14 EX Temperature (Celsius) Viscosity Curve Data Source: NOAA Technical Memorandum ERL MESA 17 Notes: 1. In some cases, viscosities were measured at different temperatures in the same day to establish a temerature/viscosity relationship. The temperature listed is the temperature at wich viscosity was measured, not the in-sites oil temperature. 2. ASTM D44516 Method was performed in a laboratory, viscosity Cup #2 measurements were performed in the Field. 3. Reference curves from NOAA Technical Memorandum ERL MESA-17 "Chemical and Physical Properties of Refined Petrolium", October ROUX ASSOCIATES, INC. Page 1 of 1 PEM M /T3

36 Table 4: Data Usability Summary Table Peabody Essex Museum Salem, Massachusetts Media Sampled Type of Analytical Data Data Qualification Action Taken (if applicable) Date Used to: Sample Delivery Group Laboratory ID Sample ID Analytes Analytical Method Date Data Acquired Soil Ground Water Surface Water Sediment Soil Vapor Air Reporting Limits Support RAO? CAM Compliant CAM Non- Compliant Laboratory QA/QC Data Qualification (if applicable) Non-CAM High Bias Low Bias L Metals NPDES 5/27/2009 X Y X Non-CAM methods required by USEPA, all QC requirements met X RPD high for Zinc X X L VOCs, SVOCs, Metals, TPH, TSS NPDES 7/20/2009 X Y X Non-CAM methods required by USEPA, all QC requirements met X Samples used for metals only. X X L VOCs, SVOCs, Metals, TPH, TSS NPDES 7/22/2009 X Y X Non-CAM methods required by USEPA, all QC requirements met X L VOCs, SVOCs, Metals, TPH, TSS NPDES 7/27/2009 X Y X Non-CAM methods required by USEPA, all QC requirements met X Samples used for metals only. X X L EPH EPH 2/3/2011 X Y X Q - MS spike recovery problems X Data consistent with near samples, accepted for use. X X X Data Flagged as Estimated Data Rejected Data Used as Reported Data Qualification Notes Characterize Site Conditions Define Background Conditions Calculate Exposure Point Concentrations Support RAO L EPH EPH 3/31/2011 X Y X Q - high spike recovery X X X X X L EPH EPH 6/20/2011 X Y X X X X X EPH, VPH EPH, VPH 4/7/2005 X Y X X X X X L EPH, VPH EPH, VPH 4/7/2005 X Y X X Low LCS recovery low X X X L VPH VPH 4/27/2006 X Y X X X X X L VOCs 8260B 10/6/2006 X Y X X No QC issues related to site contaminants X X X L EPH, VPH EPH, VPH 4/26/2007 X Y X X X X X L EPH, VPH EPH, VPH 10/17/2007 X Y X X Some EPH targets - high RPD on lab control sample X X X L APH APH 10/5/2006 X Y X QC Compliant with the draft method X X X P APH APH 4/19/2007 X Y X QC Compliant with the draft method X X non-target peak resulted in high bias X X P APH APH 10/16/2007 X Y X QC Compliant with the draft method X X non-target peak resulted in high bias X X ROUX ASSOCIATES, INC. Page 1 of 1 PEM M /T4

37 FIGURES

38 SITE LOCATION T:GIS:Peabody_Essex_Museum/PEM QUADRANGLE LOCATION SOURCE: USGS: 1985 Salam, Massachusetts 7.5 Minute Topographic Quadrangle Contour Interval 3 Meters ³ 0 1,000 2,000 Feet Title: Prepared For: ROUX SITE LOCATION MAP 161 ESSEX STREET SALAM, MASSACHUSETTS PEABODY ESSEX MUSEUM Compiled By: JW Prepared By: CRS ROUX ASSOCIATES, INC. JW Environmental Consulting Project Mgr.: & Management File No.: PEM Date: 11/14/08 Scale: AS SHOWN Office: MA Project: M02 FIGURE 1

39 APPENDICES

40 APPENDIX A Risk Characterization ROUX ASSOCIATES, INC. PEM M /AP-CV

41 TABLE OF CONTENTS 1.0 INTRODUCTION BACKGROUND CHARACTERIZATION OF THE RISK OF HARM TO HUMAN HEALTH Hazard Identification Summary of Analytical Data by Medium Soil Groundwater Soil Gas Identification of Contaminants of Concern (COCs) Dose-Response Assessment Exposure Assessment Determination of Exposure Point Concentrations Risk Characterization Comparison to Applicable or Suitably Analogous Standards Human Health Risk Characterization Conclusions Uncertainty Analysis Analytical Database Receptor Exposures Complex Interactions of Uncertainty Elements CHARACTERIZATION OF THE RISK OF HARM TO PUBLIC WELFARE SUPPLEMENTAL ASSESSMENT OF THE RISK OF HARM TO THE ENVIRONMENT CONCLUSIONS REFERENCES...19 TABLES 1. Soil Data Used in Supplemental Risk Characterization 2. Release-Related Groundwater Data for 17 Central Street 3. Metals Groundwater Data for 17 Central Street 2. Soil Gas Data for 17 Central Street ATTACHMENTS A. Toxicological Factors B. Exposure Assumptions C. Equations to Calculate Risk D. Risk Tables ROUX ASSOCIATES, INC. - i - PEM M App.A./R

42 TABLE OF CONTENTS (Continued) E. Uncertainties Tables for Metals in Groundwater F. Uncertainties Tables for SG-3 ROUX ASSOCIATES, INC. - ii - PEM M /App.A/R

43 1.0 INTRODUCTION On behalf of the Peabody Essex Museum, Roux Associates, Inc. (Roux Associates) has prepared this Massachusetts Contingency Plan (MCP) Supplemental Method 3 Human Health Risk Characterization (RC) for the Museum Place Condominiums property, located at 17 Central Street. This HRC was prepared to determine whether a condition of No Significant Risk exists at the 17 Central Street property, supplements two risk characterizations prepared by ENSR for the Site (ENSR, 2006 a nd ENSR, 2007), and reflects current soil conditions, additional understanding of groundwater impacts, and current guidance on vapor intrusion. In performing this Supplemental RC, Roux Associates adhered to MCP procedures (310 CMR ), MassDEP guidance, and scientifically acceptable risk assessment practices. This document supports the Class A-2 Partial Response Action Outcome with which it is being submitted. Currently, Roux Associates anticipates conducting further remedial actions that will result in the achievement of a Site-wide Class A-2 RAO by the end of Based upon the information presented herein and considering the 2006 and 2007 risk assessments prepared by ENSR for the Site, a Condition of No Significant Risk exists at the portion of the Site located on the 17 Central Street property under current and future uses. ROUX ASSOCIATES, INC PEM M /App.A/R

44 2.0 BACKGROUND The 17 Central Street property is in the downgradient portion of the disposal Site (RTN ) with the source located at 161 Essex Street in Salem, MA. A Method 3 Risk Characterization was prepared for the Site in the 2006 Phase II Comprehensive Site Assessment (CSA) (ENSR, 2006), which evaluated risks to current and future receptors, including museum workers, museum visitors, construction workers, utility workers and residents. A supplemental risk assessment was included in the Supplemental Phase II CSA (ENSR, 2007), and included an evaluation of risks for the following receptors at 17 Central Street: On-site resident: Surface soil (ingestion/dermal contact) Indoor air (inhalation) Construction Worker: Subsurface/surface soil (ingestion, dermal contact and inhalation) Groundwater (ingestion and dermal contact) Trench air (inhalation) Utility Worker: Subsurface/Surface soil (ingestion, dermal contact and inhalation of particulates) Human health risks were determined to be less than MCP risk limits (ENSR, 2007). No significant risk to safety was concluded, but a condition of no s ignificant risk to public welfare and the environment had not been achieved, due to the presence of LNAPL in excess of ½ inch in the environment. Since the 2007 Supplemental Phase II CSA, remediation has occurred at the Site, which has resulted in source removal. A s described in Roux Associates Phase V Status and Remedial Monitoring Report (Roux, 2011), LNAPL has been removed by a t hermally-enhanced LNAPL recovery system. In addition, during June and July 2011 three spot excavations were performed on ROUX ASSOCIATES, INC PEM M /App.A/R

45 the 17 C entral Street property. These excavations resulted in the removal of oil that existed in discrete areas on the 17 Central Street property. Detailed information on remedies implemented at the Site is provided in the Phase V Status and Remedial Monitoring Report (Roux, 2011). S ince 2007, s oil and groundwater have been collected and analyzed for Site contaminants. This Supplemental RC re-evaluated risks based upon information provided in the previously-submitted reports, and the recently-collected data. The Supplemental RC relies upon the hazard identification, dose-response assessment, exposure assessment, environmental risk characterization and the characterization of risk to safety presented in the 2006 Phase II CSA, and evaluation of risks associated with groundwater and excavation trench air presented in the 2007 Supplemental Phase II CSA. This report includes updates to the risk characterization presented in the 2007 Supplemental Phase II CSA to assess: 1. Current (post-remediation) soil conditions; 2. Metals in groundwater, which were detected as part of permitting operations; 3. Potential vapor intrusion impacts, as MassDEP screening values were recently updated; and 4. Risks to public welfare and the environment, given the removal of LNAPL on t he 17 Central Street property. ROUX ASSOCIATES, INC PEM M /App.A/R

46 3.0 CHARACTERIZATION OF THE RISK OF HARM TO HUMAN HEALTH Pursuant to the MassDEP s Guidance for Disposal Site Risk Characterization in Support of the Massachusetts Contingency Plan (MassDEP 1995), this Supplemental RC summarizes the five steps to the human health RC: Hazard Identification; Dose-Response Assessment; Exposure Assessment; Risk Characterization; and Uncertainty Analysis. Each of these risk assessment steps is discussed in detail in the following sections of this report. 3.1 Hazard Identification The Hazard Identification portion of an MCP Method 3 Risk Characterization identifies which OHM at the Site are considered COCs, summarizes the analytical data for these COCs (by medium), and describes the potential health effects that may be associated with exposure to each COC Summary of Analytical Data by Medium Recent (since 2007) Site data have been generated for soil and groundwater. A discussion of analytical results is presented in the Remediation General Permit - Notice of Intent (Roux, 2009) and Notice of Termination (Roux, 2009a) for groundwater and the Phase V Status Report (Roux 2011) for soil. The data are summarized in the sections that follow Soil Soil samples collected from the 17 Central Street property in June and September 2007 were described previously by ENSR in the Supplemental Phase II CSA (ENSR, 2007). As described in the Phase V Status Report (Roux 2011), eleven soil borings (HS-01 through HS-11) were advanced in January, 2011, and to a depth of 20 feet below ground surface (bgs). On March 30, 2011, eight additional borings were advanced on the 17 Central Street property (HS-12 through HS-19). Sixteen soil samples (collected between 11 and 17 feet below ground ROUX ASSOCIATES, INC PEM M /App.A/R

47 surface) were analyzed for extractable petroleum hydrocarbons (EPH). All three EPH fractions were detected in each sample, and numerous polynuclear aromatic hydrocarbons (PAHs) were detected in a subset of samples. Soil sampling results for these samples are provided in the Phase V Status Report (Roux, 2011). Following three spot excavations in June 2011, one sample was collected from the bottom of each excavation and analyzed for EPH. R esidual concentrations of EPH fractions were detected in one of the three endpoint samples. No PAH was detected in any of the three samples. Results of this sampling are provided in the Phase V Status Report (Roux, 2011). The Supplemental RC retained data from soil samples collected in June and September 2007, and in January, March and June 2011, which were shallower than 15 feet, in which petroleum hydrocarbons and/or PAHs were detected, and in areas collected in areas which were not excavated. These locations include: MW-17 (10-11 ), MW-17 (14-15 ), MW-18 (13-14 ), MW-19 (12-13 ), MW-20 (7 ), MW-20 (9 ), SB-25 (8 ), SB-25 (10 ), SB-25 (15 ), and SB-27 (11 ) advanced in 2007, and HS-02, HS-08, HS-09, HS-11, HS-17, HS-18 and HS-19, advanced in Soil sampling results included in the Supplemental RC are provided in Table 1. While a range of results were detected for EPH fractions and PAHs, no hot spot was identified, as contaminated soils were removed from three areas. In addition, LNAPL has been pumped from the area in the vicinity of SB-25 (where elevated petroleum fractions were detected in 2007). Therefore, while concentrations of petroleum fractions were elevated at the 10 foot depth interval at SB-25, remediation has likely resulted in a decrease in concentration at this location. We conservatively retained the 2007 results from this location in the Supplemental RC Groundwater Three groundwater wells (MW-18, MW-19, and MW-20) are located on the 17 Central Street property, and were sampled in October Two additional wells, MW-6 and MW-16, are located near the 17 Central Street property boundary and were sampled in 2006 and Sampling results were described in the Supplemental Phase II CSA (ENSR, 2007); 2007 sampling results are also provided in Table 2. Briefly, petroleum hydrocarbon fractions and/or PAHs were detected at least once in each well. In addition, volatile organic compounds (VOCs, including benzene, ethylbenzene, naphthalene and xylenes) were detected at least once in either MW-19 or MW-20. ROUX ASSOCIATES, INC PEM M /App.A/R

48 No additional groundwater monitoring data to support MCP compliance have been collected on the 17 Central Street property since the Supplemental Phase II CSA. Four samples were collected and analyzed for site-related constituents and metals in conformance with the requirements of a National Pollution Discharge Elimination System (NPDES) permit for the discharge of water for a Site remediation system. These samples include EX-01 (5/27/2009), IN1D720 (7/20/2009), IN3D722 (7/22/2009), and IN7D27 (7/27/2009). These samples were collected from either EX- 01 only (on 5/27/2009) or from the combined flow of EX-01 and EX-02 (IN samples). The sample collected from EX-01 on 5/27/09 was collected with a bailer following purging the well. The other samples were collected at the influent to the remediation system during operation of the groundwater depression and active LNAPL recovery system. G roundwater depression during remediation system operation resulted in suspended sediment in treatment system influent samples, and demonstrated by the high suspended solids concentrations. These samples represented influent concentrations to the remediation system, but were not intended to accurately reflect concentrations of contaminant dissolved in groundwater. The combined samples have therefore been rejected from the groundwater data. The purge and bail sampling technique results in higher suspended solids concentrations than low-flow sampling, and the metals concentrations for the EX-01 sample collected on 5/ 27/09 are likely biased high. However, this sample has been retained in the risk assessment for metals since these compounds were not analyzed in any other retained sample, and as a co nservative measure the concentrations have been accepted as reported. Elevated concentrations of some reduction-oxidation (redox) sensitive metals were detected in groundwater. It has been well documented that the presence of biodegradable oil in the environment will cause a change in the natural redox conditions, making the environment highly reducing. U nder these artificial reducing conditions some naturally occurring redox sensitive metals will dissolve from soil into groundwater. The groundwater concentrations do not constitute a reportable condition, 1 and this secondary groundwater quality problem will selfcorrect as water returns to its natural aerobic state and the metals oxidize and re-precipitate. Because the presence of the metals in groundwater is likely due to the presence of the oil plume, 1 Lead was detected at concentrations of mg/l, mg/l and mg/l in influent samples collected at EX01 between 7/20/2009 and 7/27/2009. One result exceeded the RC GW-2 of 0.01 mg/l. A reportable condition was not identified, however, as the elevated lead concentration was attributed to suspended particulates in the sample, which had a total suspended solids result of 22 mg/l, more than 3 times higher than the remaining two samples. ROUX ASSOCIATES, INC PEM M /App.A/R

49 they have been considered in the Supplemental RC. T he groundwater metals data for the 17 Central Street property are presented in Table 3. While results from four samples are presented in Table 3, as described above, only results from EX-01 are considered quantitatively in the Supplemental RC Soil Gas One soil gas sample, SG-5, was collected on the 17 Central Street property. S G-5 was collected in October 2007 from beneath the parking garage (lowest) floor of the Carriage House and analyzed for petroleum-related volatile constituents. As described in the Supplemental Phase II CSA (ENSR, 2007), and as shown in Table 4, C9 C12 aliphatic hydrocarbons were detected in this sample at 1600 ug/m 3, which is 3 times lower than the current MassDEP Residential Soil Gas Screening Level (MassDEP, 2011). No other compound was detected in soil gas. 2 Because soil gas sampling results were less than screening levels, additional remediation has decreased subsurface contamination since 2007, groundwater concentrations are less than 10% of GW-2 standards, and no preferential pathway was identified for vapor intrusion into the Carriage House building, the vapor intrusion pathway was considered to be incomplete at this location. Soil gas sampling location SG-3 is located in the public sidewalk, near the apartment building located at 17 Central Street. Soil gas samples were collected from this location on four occasions between 2004 and 2007, and analyzed by the draft Air-phase Petroleum Hydrocarbon (APH) method. As shown in Table 4, petroleum fractions were not detected at the laboratory reporting limits on two occasions (1/25/2005 and 10/16/2007) and only the C5-C8 and C9-C12 aliphatic hydrocarbon fractions were detected on a t hird event (4/22/2004). R esults for the remaining event (10/5/2006) included detection of all three hydrocarbon ranges at concentrations up to two orders of magnitude higher than the non-detect reporting limits reported during the other sampling rounds, with the reported concentration of the C9-C10 aliphatic hydrocarbons having the highest concentration of the ranges. This result appears anomalously high based on the other results for this location. Additionally, The closest observed soil contamination to this location was in MW-20, located approximately 75 feet upgradient of this sampling location; 2 Detection limits provided on Table 2-7 of the Supplemental Phase II CSA were all below MassDEP Soil Gas Screening Levels. ROUX ASSOCIATES, INC PEM M /App.A/R

50 Results of groundwater samples collected within 100 feet of this location are less than 10% of the Method 1 GW-2 hydrocarbon fraction standards; LNAPL has not been observed closer than in well MW-17, located approximately 85 feet upgradient of this location; There are no know preferential pathways between areas impacted with LNAPL and this location; and Due to the age and oil type located at the Site (No. 4 fuel oil released in the 1960s or 1970s), volatile compounds are not expected to be present in proportions that would likely result in soil gas concentrations that are reported for this sample on this date. For these reasons, Roux Associates considers sample SG-3, collected on 10 /5/2006, to be anomalously high and not representative of soil gas conditions at this location. The results from this date were excluded from further evaluation. The remaining sampling results for SG-3 (from 2004, 2006 a nd 2007) are less than the 2011 MassDEP Residential Soil Gas Screening Level (MassDEP, 2011). Based on the concentrations of constituents in soil gas in these samples and the surrounding subsurface conditions described above, Roux Associates concludes that the indoor air pathway is insignificant, and no f urther evaluation of vapor intrusion is included in this Supplemental RC Identification of Contaminants of Concern (COCs) The COC selection process was described in the Phase II CSA (ENSR, 2006), and was retained for the Supplemental RC. S pecifically, the C9 C12 aliphatic hydrocarbon fraction was eliminated as a COC because this range is included in the C9 C18 aliphatic hydrocarbon range. C9-C18 aliphatic hydrocarbon fraction, as well as all other compounds detected in soil, were retained as COCs. Groundwater influent samples collected as part of NPDES permitting identified numerous metals. The Supplemental RC includes metals that were detected in EX-01 (arsenic, chromium III, copper, nickel, selenium and zinc) as COCs. Iron was also detected in groundwater at a concentration of 12 ug/l. It was not included as a COC, as it is considered an essential nutrient and the potential for groundwater exposure is low. ROUX ASSOCIATES, INC PEM M /App.A/R

51 3.2 Dose-Response Assessment The Dose-Response portion of an MCP Method 3 Method 3 Risk Characterization describes the observed effects in humans and/or laboratory animals associated with exposures to Site COCs. The dose-response assessment was included in the 2006 Phase II CSA. Similar to the earlier risk assessment, Roux Associates employed the MassDEP Shortforms for residential and construction workers to assess risk. Roux Associates used MassDEP s Vlookup Version of toxicity information for assess risk, including risk associated with construction worker exposure to groundwater. Dose-response data for COCs assessed herein are provided on Tables A-1 and A-2 in Attachment A. MassDEP does not present toxicity information for copper in the Shortforms. Roux Associates used a copper RfD of 0.04 to assess construction worker exposure to copper in groundwater, which was derived based upon the MCL presented by MassDEP in May, 2004 i n the Current Regulatory Limit: Copper documentation. As described in that document, copper is not classifiable to carcinogenicity, so it was not assessed as a carcinogen in the Supplemental RC. 3.3 Exposure Assessment The Exposure Assessment describes the contact between OHM at the Site and the potential receptors. Specifically, the exposure assessment involves the development of exposure profiles (i.e., descriptions of the exposures that may occur at the Site) and quantitative estimates of exposure. Exposures at the 17 Central Street property were described in the Supplemental Phase II CSA risk assessment (ENSR, 2007), which identified three receptors the resident, construction worker and utility worker, and quantitatively assessed risks to the resident and construction worker. No additional potential receptors were identified, and Roux Associates quantitatively evaluated the resident and construction worker. Similar to the 2007 Supplemental Phase II CSA risk assessment for 17 Central Street, Roux Associates used exposure assumptions, equations and chemical-specific parameters for calculating soil exposures for residents and construction workers using the MassDEP Shortforms. Soil-related exposure assumptions for these receptors are provided in Attachment B in Tables B-1 and B-2 for residents and construction workers, respectively. The equations used to quantify exposures associated with each of the soil-related exposure ROUX ASSOCIATES, INC PEM M /App.A/R

52 pathways identified are presented in Attachment C in Tables C-1 through C-3 (resident), and C-4 and C-5 (construction worker). Roux Associates also assumed that construction workers could be exposed to metals in groundwater via dermal contact. R oux Associates incorporated the exposure assumptions regarding skin surface area, exposure time and exposure frequency used by ENSR in 2006 and 2007 to assess this pathway. Groundwater-related exposure assumptions for the construction worker, and the equations used to quantify groundwater exposures are provided in Attachment D in Tables D-1 and D Determination of Exposure Point Concentrations Exposure point concentrations (EPCs) are, in theory, the average concentrations of COCs contacted by a receptor at the exposure point over the period of exposure (310 CMR [3]). Per MassDEP guidance (MassDEP 1995), the arithmetic mean concentration of a particular COC in soil may be used as the EPC for soil direct-contact exposures. Because no hot spot was identified in 17 Central Street soil, average soil concentrations on the 17 Central Street property in the 0-15 foot depth interval were calculated to assess potential future conditions at the Site. 3 The soil EPC for the property is provided on Table Risk Characterization Risk Characterization integrates the results of the Hazard Identification, Dose-Response Assessment, and Exposure Assessment to yield quantitative estimates of cancer and non-cancer risks. The results are used to determine whether a condition of no significant risk to harm to human health exists or has been achieved at the 17 Central Street property. The Supplemental RC was conducted following MassDEP methodology, and as described in the Supplemental Phase II CSA risk assessment (ENSR, 2007). Cumulative non-cancer risks (hazard indices, or HIs) and cancer risks estimates (excess lifetime cancer risks, or ELCRs) are provided on Tables D-1 and D-2 for construction worker groundwater exposures, on Table D-3 for construction worker soil exposures, and on Table D-4 for residential soil exposures. Total 3 Contaminated soil is not located within the shallowest 3 feet of the Site. In addition, Site soil is covered by a building or parking lot. Therefore, no soil EPC was developed for current site use. ROUX ASSOCIATES, INC PEM M /App.A/R

53 receptor risks, including those previously calculated for groundwater exposures, are summarized below. ROUX ASSOCIATES, INC PEM M /App.A/R

54 Receptor Medium HI ELCR Resident Construction Worker Soil (subchronic) 1.3E-01 NA Soil (chronic) 4.6E E-06 Soil 3.6E E-08 Groundwater 3.4E E-08 Trench Air 1.1E E-10 Groundwater (metals) 5.9E E-09 CUMULATIVE: 4.7E E-08 *obtained from Table 4-5 and 4-6 of ENSR 2007 Cumulative residential noncancer risks equal 0.1 for subchronic exposures, and 0.5 for chronic exposures. Construction worker cumulative noncancer risk equals Because all noncancer risks are less than the MCP risk limit of 1.0, there is no unacceptable level of risk of harm to human health resulting from exposure to noncarcinogenic compounds at the 17 Central Street portion of the Site. Cumulative ELCRs were calculated as 2E-6 for residents and 6E-8 for the construction worker. The cumulative ECLRs are below their benchmark, the MCP Cumulative Cancer Risk Limit, an ELCR equal to 1E-5. Thus, there is no unacceptable level of risk of harm to human health resulting from the presence of carcinogenic compounds at the 17 Central Street portion of the Site Comparison to Applicable or Suitably Analogous Standards There are no applicable or suitably analogous human health standards against which to compare Site soil or supplemental groundwater data Human Health Risk Characterization Conclusions Based on t he results of this characterization of risk of harm to human health and the criteria specified at 310 CMR (7), it can be concluded that a condition of no significant risk of harm to human health has been achieved at the Site, since: No EPC of OHM is greater than an applicable or suitably analogous public health standard; No Cumulative Receptor Cancer Risk calculated is greater than the MCP Cumulative Cancer Risk Limit; and No Receptor Non-cancer Risk is greater than the MCP Cumulative Receptor Non-cancer Risk Limit. ROUX ASSOCIATES, INC PEM M /App.A/R

55 3.5 Uncertainty Analysis Uncertainty analysis is the fifth and final component of an MCP Method 3 risk characterization of the risk of harm to human health, and places the calculated numerical risk estimates into the overall context of what is known and what is not known about the Site. Uncertainties with the risk characterizations prepared by ENSR were discussed in the 2006 Phase II CSA (ENSR, 2006). Uncertainties regarding the dose-response assessment, risk characterization, and Stage I environmental risk characterization also apply to this Supplemental RC. Additional uncertainties are described below Analytical Database Soil analytical data used to assess supplemental risks are expected to be reflective of conditions at 17 Central Street. Soil data were collected in source area of the Site and beyond, from the depth interval of contamination, and are representative of Site conditions. There is uncertainty with metals groundwater data, as the groundwater samples were collected for purposes other than MCP compliance, and were not collected using low-flow sampling techniques. T his uncertainty likely biases results high, and was countered by excluding data collected from active remediation wells containing LNAPL under high-stress pumping conditions. The exclusion of this data is not expected to affect the conclusions of the risk assessment. As shown in Attachment E, if an average of all four groundwater samples was used to assess construction worker risks, estimated risks associated with exposure to metals in groundwater would equal a hazard index of 6E-3, and an excess lifetime cancer risk of 2E-8, and risks associated with all routes of exposure would remain less than risk limits. Soil gas data used to evaluate the potential for vapor intrusion was presented in the Supplemental Phase II CSA (ENSR, 2007). As described in Section , sampling results from sample SG- 3 collected on 10/5/2006 were excluded from the Supplemental RC, and results were inconsistent with results collected from this location on other occasions, and uncharacteristic of the source material, weathered fuel oil. There is uncertainty in excluding this sample from the RC, as concentrations of the C9 to C10 aromatic fraction and naphthalene exceeded MassDEP Residential Soil Gas Screening Levels (MassDEP, 2011). This uncertainty was assessed by conservatively estimating residential risk including all samples collected at SG-3. This assessment was not included in the risk characterization, because, based on t he weight of ROUX ASSOCIATES, INC PEM M /App.A/R

56 evidence approach, there is no evidence that a significant Site-related vapor intrusion pathway is present. The indoor air uncertainty assessment risk tables are provided in Attachment F. Indoor air concentrations were estimated by applying the default MassDEP attenuation factor of 70 (MassDEP, 2011) to the average concentration of constituents detected at SG-3 between 2004 and The average soil gas concentration was calculated using one-half of the detection limit as a surrogate concentration if a compound was not detected in a sample. All four soil gas samples were used in this analysis, rather than the maximum concentrations, as maximum concentrations are considered to not be representative of Site conditions. E stimated average indoor air concentrations are shown on Table F-1. Estimated average indoor air concentrations were incorporated into the MassDEP Residential Shortforms for the inhalation of indoor air to calculate risk. This approach is conservative, as the basement level of the building at 17 Central Street is used as storage space, and is not currently inhabited. Shortform tables are included as Tables F-2 through F-5 in Attachment F. No cancer risk was calculated, as detected compounds are not considered by MassDEP to be carcinogenic. Cumulative noncancer indoor air risks equal a hazard index of 1.3; however, target organ-specific risks were all less than 1.0. In addition, as shown in Table F-6, the maximum target-organ specific noncancer HI, considering both indoor air exposures and calculated soil exposures equals 0.9 (kidney exposures), which is less than the MassDEP risk limit of 1.0. Because target organ-specific risks are less than risk limits, while incorporating conservative assumptions regarding soil gas concentration, attenuation, and exposure, the exclusion of sample SG-3 (10/5/2006) is not considered significant Receptor Exposures Construction workers and residents were considered in the Supplemental RC. These receptors are appropriate, considering the current and likely future residential use of the property. Utility worker exposure assumptions were not developed. R ather than evaluate a separate utility worker, construction worker exposures were used as a surrogate. This uncertainty represents an overestimate of the utility worker risk, as utility workers have a shorter exposure period than construction workers, and as concentrations of constituents are located deeper than typical utility depths. ROUX ASSOCIATES, INC PEM M /App.A/R

57 Roux Associates relied upon risks presented by ENSR in the Supplemental Phase II CSA for construction worker exposure to petroleum-related constituents in groundwater encountered in a construction trench; therefore, the uncertainties described in ENSR s Supplemental Phase II CSA (ENSR, 2007) apply herein. R oux Associates estimated risks from exposure to metals in groundwater in a construction trench using similar exposure assumptions as those used by ENSR (skin surface area exposed, number of days and hours exposed, etc). Roux Associates did not assess risk to a construction worker ingesting groundwater in a construction trench, as this exposure is considered negligible. Given that cumulative construction worker risks are at least 20 times lower than risk limits, this exclusion does not affect the conclusion of the Supplemental RC Complex Interactions of Uncertainty Elements A human health risk characterization for a specific site is ultimately an integrated evaluation of historical, chemical, analytical, environmental, and toxicological data that are as site-specific as possible. To minimize the chances of underestimating risk due to uncertainties in the evaluation, each step is biased toward health-protective estimations. In addition, the risk characterization is not intended to represent currently existing exposures or actual health risks. R ather, the risk characterization generates risk estimations that may occur only if all the conservative assumptions are realized. ROUX ASSOCIATES, INC PEM M /App.A/R

58 4.0 CHARACTERIZATION OF THE RISK OF HARM TO PUBLIC WELFARE The MCP requires that the risk of harm to public welfare be characterized to identify and evaluate nuisance conditions and significant community effects that may result from the presence of residual contamination at the Site. The risk of harm to public welfare was assessed in the Phase II CSA (ENSR, 2006). No nuisance condition, loss of active or passive property use, or non-pecuniary effect was identified in the report. However, risk of harm to public welfare was identified at the entire Site, due an Upper Concentration Limit (UCL) exceedance of C9-C18 aliphatic hydrocarbons in soil, and NAPL at a thickness greater then ½ inch in the subsurface. Subsurface remediation was completed in 2011, which resulted in decreased concentrations of constituents in soil, and removal of NAPL. NAPL is no longer present in the environment at 17 Central Street at a thickness of greater than ½ inch. In addition, as shown on Table 1, average soil concentrations of constituents at the 17 C entral Street property are all less than UCLs. Further, concentrations of metals in groundwater at EX-01 are less than their respective UCLs. 4 Therefore, based upon t he 2006 a ssessment and considering additional remediation that has occurred since that time, a condition of no significant risk to public welfare has been achieved at the 17 Central Street property. 4 Groundwater concentrations in EX-01 were used in the risk assessment, as results collected from the treatment system are not considered representative of groundwater conditions, and are considered to be biased high. ROUX ASSOCIATES, INC PEM M /App.A/R

59 5.0 SUPPLEMENTAL ASSESSMENT OF THE RISK OF HARM TO THE ENVIRONMENT The MCP requires that the risk of harm to the environment be characterized for all current and foreseeable Site uses and activities. Characterization of the risk of harm to the environment entails the evaluation of biota and habitats at and in the vicinity of the Site, as well as comparison to MCP UCLs. A Stage I Environmental Screening (ES), presented in the Phase II CSA determined that no c omplete exposure pathways were present for terrestrial, aquatic, or semi-aquatic receptors (ENSR, 2006). However, a condition of significant risk was identified for the Site, due to the presence of C9-C18 aliphatic hydrocarbon concentration in soil in excess of UCLs, and site NAPL thickness greater than the NAPL UCL of ½ inch. As described above in Section 4.0, there are no longer UCL exceedances in the environment. Since the ES, metals have been detected in groundwater at the Site, due to subsurface anaerobic conditions. 5 This finding does not change the conclusions of the ES. Site groundwater is expected to become aerobic within one-year of downgradient travel (approximately 175 feet) through this process. Since the closest surface water body (a channel connected to Salem Harbor) is approximately 600 feet cross-gradient, metals will have re-precipitated before groundwater is discharged. Also, as groundwater discharges to Salem Harbor the dilution will be near infinite (and further mixed with aerobic water) making these secondary impacts insignificant. Based upon the 2006 assessment and considering additional remediation that has occurred since that time, a condition of no s ignificant risk to the environment has been achieved at the 17 Central Street property. 5 Concentrations of metals in groundwater at EX-01 are less than Method 1 GW-3 standards. ROUX ASSOCIATES, INC PEM M /App.A/R

60 6.0 CONCLUSIONS A condition of No Significant Risk has been achieved at the 17 Central Street property. This means that a level of control has been achieved for each COC at the Site, such that no such COC shall present a significant risk of harm to health, safety, public welfare, or the environment during the foreseeable future. ROUX ASSOCIATES, INC PEM M /App.A/R

61 7.0 REFERENCES ENSR, Phase II Comprehensive Site Assessment and Method 3 Risk Characterization, Charter Street Site, Salem, MA. November. ENSR, S upplemental Phase II Comprehensive Site Assessment and Phase IV Remedy Implementation Plan, Charter Street Site, Salem, MA. November 26. MassDEP, Spreadsheets for Development of MCP Risk-Based Levels for Soil and Groundwater. Office of Research and Standards. MassDEP, R isk Assessment for Resident Exposed to Chemicals in Soil - Shortform (sf06rs.xls). MassDEP, Interim Final Vapor Intrusion Guidance. WSC December. Roux Associates, Inc Remediation General Permit Notice of Intent, including supplemental information, June 9. Roux Associates, Inc. 2009a. letter. RE: Notice of Termination. F rom Glen Gordon to Shelley Puleo, United States Environmental Protection Agency. October 16. Roux Associates, Inc Phase V Remedy Status Report. ROUX ASSOCIATES, INC PEM M /App.A/R

62 TABLES

63 Table 1: Soil Data Used in Supplemental Risk Characterization Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Sample ID HS-02 HS-08 HS-09 HS-11 HS-17 HS-18 HS-19 HS-19DUP MW-17 MW-17 MW-18 MW-19 MW-20 MW-20 SB-25 SB-25 SB-25 SB-27 Date sampled 26-Jan Jan Jan Jan Mar Mar Mar Mar Jun Jun Jun Jun Sep Sep Sep Sep Sep Sep-07 Sample Depth Top (fbg) Sample Depth Bottom (fbg) Chemical Name Methylnaphthalene, < < 1.14 < < < < 1.96 < < < Acenaphthene < < 1.14 < < < < 1.96 < < < ,000 Acenaphthylene 2.38 < 2 < 1.88 < < 1.55 < 1.49 < 1.14 < < 2.06 < < < 1.96 < 1.81 < 2.01 < < 9.47 < ,000 Anthracene < < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < ,000 Benzo(a)anthracene < < 2 < 1.88 < < 1.14 < < 2.06 < < 1.96 < < < 9.47 < < ,000 Benzo(a)pyrene < < 2 < 1.88 < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < Benzo(b)fluoranthene < < 2 < 1.88 < < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < ,000 Benzo(g,h,i)perylene < < 2 < 1.88 < < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < ,000 Benzo(k)fluoranthene < < 2 < 1.88 < < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < ,000 Aromatics C11 to C < ,000 Aliphatics C19 to C < ,000 Aliphatics C5 to C8 NT NT NT NT NT NT NT NT 131 NT < 6.4 NT < NT NT NT NT ,000 Aromatics C9 to C10 NT NT NT NT NT NT NT NT 673 NT 6.91 NT < NT NT NT NT 238 5,000 Aliphatics C9 to C12 NT NT NT NT NT NT NT NT 620 NT 11.9 NT < NT NT NT NT NA NA Aliphatics C9 to C < < < ,000 Chrysene 1.25 < 2 < 1.88 < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < ,000 Fluoranthene 1.53 < 2 < 1.88 < < 1.14 < < 2.06 < < < 9.47 < < ,000 Fluorene < 1.14 < < < < 1.96 < < < ,000 Indeno(1,2,3-cd)Pyrene < < 2 < 1.88 < < < 1.14 < < 2.06 < < 1.96 < 1.81 < 2.01 < < 9.47 < < ,000 Naphthalene < < 1.14 < < < < 1.96 < < < ,000 Phenanthrene < < 1.14 < < < < < ,000 Pyrene < < 2 < 1.88 < < 1.14 < < 2.06 < < < < 9.47 < < ,000 Exposure Point Concentration Method 3 UCL in Soil General Notes: fbg = feet below ground surface all units are in mg/kg ROUX ASSOCIATES, INC. 1 of 1 PEM M /App.A/T-1

64 Table 2: Release-Related Groundwater Data for 17 Central Street Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts MCP Method 1 Standards Sample ID MW-6 MW-6 MW-16 MW-16 MW-18 MW-19 MW-20 CHEMICAL NAME Unit GW-2 GW-3 Sample Date 4/26/ /16/2007 4/26/ /16/ /15/ /15/ /15/ /15/2007 SVOC 2-METHYLNAPHTHALENE ug/l 2,000 20,000 < < < < < < ACENAPHTHENE ug/l NA 6, < < < FLUORANTHENE ug/l NA 200 < < < < < < < FLUORENE ug/l NA < < NAPHTHALENE ug/l 1,000 20, < < < PHENANTHRENE ug/l NA 10,000 < < < < < < < TPH C11-C22 AROMATICS ug/l 50,000 5, < 100 < 110 < 108 < 108 < C9-C10 AROMATIC HYDROCARBONS ug/l 7,000 50, < 50.0 < < C9-C12 ALIPHATIC HYDROCARBONS ug/l 5,000 50,000 < 50.0 < 50.0 < 50.0 < 50.0 < 50.0 < VOC BENZENE ug/l 2,000 10,000 < 2.00 < 2.00 < 2.00 < 2.00 < ETHYLBENZENE ug/l 20,000 5,000 < 2.00 < 2.00 < 2.00 < 2.00 < < 2.00 NAPHTHALENE ug/l 1,000 20,000 < 10.0 < 10.0 < 10.0 < 10.0 < 10.0 < 10.0 < XYLENE (O) ug/l 9,000 5,000 < 2.00 < 2.00 < 2.00 < 2.00 < 2.00 < 2.00 < 2.00 < 2.00 XYLENE (M,P) ug/l 9,000 5,000 < 2.00 < 2.00 < 2.00 < 2.00 < < 2.00 General Notes: µg/l = micrograms per liter < = Below laboratory detection limit MCP Method 1 Standards = MCP Method 1 Groundwater Standards as found in 310 CMR (2), Table 1 Listed Xylenes (O) and Xylene (M,P) MCP Method 1 Standards are Xylenes (Totals) Data Source: "Table 2-6: Summary of Groundwater Analytical Results" from "Supplemental Phase II Comprehensive Site Assessment and Phase IV Remedy Implementation Plan Charter Street Site, Salem, MA" prepared by ENSR Corporation, dated November 26, ROUX ASSOCIATES, INC. 1 of 1 PEM M /App.A/T-2

65 Table 3: Metals Groundwater Data for 17 Central Street Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Method 1 GW- 3 Standard EX-01 IN1D720 IN3D722 IN7D27 Exposure Point Concentration Method 3 UCL in Groundwater CHEMICAL NAME Unit 5/27/2009 7/20/2009 7/22/2009 7/27/2009 Metals Antimony ug/l 8,000 < 0.5 NT NT NT NA 80,000 Arsenic ug/l ,000 Cadmium ug/l 4 < 0.2 NT NT NT NA 50 Chromium ug/l < ,000 Copper ug/l NS NS Iron ug/l NS NS Lead ug/l 10 < NA 150 Mercury ug/l 20 < 0.2 NT NT NT NA 200 Nickel ug/l ,000 Selenium ug/l ,000 Silver ug/l 7 < 0.4 NT NT NT NA 1,000 Zinc ug/l ,000 Other Total Suspended Solids ug/l NS NT < NA NA General Notes: µg/l = micrograms per liter NA = Not Applicable. Compound was not detected in groundwater at EX-01, or, in the case of iron, the compound was not assessed quantitatively. NS = No Standard Available. NT= Not Tested < = Below laboratory detection limit Method 1 GW-3 Standard = MCP Method 1 Groundwater Standards as found in 310 CMR (2), Table 1 Exposure Point Concentration equals the concentration of detected constituents in EX-01. Method 3 UCL in Groundwater = MCP Method 3 Upper Concentration Limits (UCLs) in Groundwater and Soil as found in 310 CMR (7), Table 6 Data Source: Analytical Reports "L ", "L ", "L ", and "L " from ALPHA Analytical. ROUX ASSOCIATES, INC. 1 of 1 PEM M /App.A/T-3

66 Table 4: Soil Gas Data for 17 Central Street Peabody Essex Museum 17 Central Street Property Salem, Massachusetts Sample ID SG-3 SG-3 SG-3 SG-3 SG-5 Unit Residential SS Soil Gas Screening Sample Date 4/22/2004 1/25/ /5/ /16/ /16/2007 CHEMICAL NAME Values 2-METHYLNAPHTHALENE µg/m < 20 < < 0.63 < 24 C5-C8 ALIPHATIC HYDROCARBONS µg/m 3 4,100 2,200 < < 63 < 2400 C9-C10 AROMATIC HYDROCARBONS µg/m < 400 < < 13 < 480 C9-C12 ALIPHATIC HYDROCARBONS µg/m 3 4,800 1,700 < < 290 J 1600 BENZENE µg/m < 20 < 20 < 2.00 < 0.63 < 24 ETHYLBENZENE µg/m < < 0.63 < 24 METHYL TERT-BUTYL ETHER (MTBE) µg/m 3 2,700 < 20 < 20 < 2.00 < 0.63 < 24 NAPHTHALENE µg/m 3 43 < 20 < <0.63 < 24 O-XYLENE µg/m 3 1, < < 0.63 < 24 TOLUENE µg/m 3 3, < < 24 XYLENE (M,P) µg/m 3 1, < < 1.3 < 48 General Notes: µg/m 3 = micrograms per cubic meter < = Below laboratory detection limit J = Estimated value Residential SS Soil Gas Screening Values are as listed in "Table II.2: Residential Sub-Slab Soil Gas Screening Values" from "Interim Final Vapor Intrusion Guidance (WSC# ). Listed Xylenes (O) and Xylene (M,P) MCP Method 1 Standards are Xylenes (Totals) Data Source: "Table 2-7: Summary of Groundwater Analytical Results" from "Supplemental Phase II Comprehensive Site Assessment and Phase IV Remedy Implementation Plan Charter Street Site, Salem, MA" prepared by ENSR Corporation, dated November 26, ROUX ASSOCIATES, INC. 1 of 1 PEM M /App.A/T-4

67 ATTACHMENTS

68 ATTACHMENT A Toxicological Factors ROUX ASSOCIATES, INC. PEM M /AP-CV

69 Table A-1: Residential ShortformToxicity Factors Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Soil: Table RS-7 Chemical-Specific Data Vlookup Version v0808 Chronic Subchronic Chronic Chronic Subchronic Subchronic Oil or CSF RAF c-ing RAF c-derm RAF c-prod RfD RfD RAF nc-ing RAF nc-derm RAF nc-ing RAF nc-derm RAF nc-prod PUF Target Hazardous Material (mg/kg-day) -1 mg/kg-day mg/kg-day Organ Methylnaphthalene, 2-4.0E E lung Acenaphthene 6.0E E liver Acenaphthylene 3.0E E kidney Anthracene 3.0E E no effects Benzo(a)anthracene 7.3E E E kidney Benzo(a)pyrene 7.3E E E kidney Benzo(b)fluoranthene 7.3E E E kidney Benzo(g,h,i)perylene 3.0E E kidney Benzo(k)fluoranthene 7.3E E E kidney Aromatics C11 to C22 3.0E E kidney Aliphatics C19 to C36 2.0E E liver Aliphatics C5 to C8 4.0E E CNS Aromatics C9 to C10 3.0E E kidney Aliphatics C9 to C18 1.0E E liver, blood Chrysene 7.3E E E kidney Fluoranthene 4.0E E kidney, liver, blood, and clinical effects Fluorene 4.0E E blood Indeno(1,2,3-cd)Pyrene 7.3E E E kidney Naphthalene 2.0E E body weight Phenanthrene 3.0E E kidney Pyrene 3.0E E kidney Target organ information was not provided on the MassDEP shortform, but were included by Roux Associates such that target organ hazard indices could be evaluated within the uncertainties section of the risk characterization. ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.A/TA-1

70 Table A-2: Construction Worker Shortform Toxicity Factors Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Construction Worker - Soil: Table CW-5 Chemical-Specific Data Vlookup Version v0808 Oral Inhalation Subchronic Subchronic Subchronic Subchronic Subchronic Oil or CSF RAF c-ing RAF c-derm RAF c-inh CSF Oral RfD RAF nc-ing RAF nc-derm RAF nc-inh Inhalation RfD Hazardous Material (mg/kg-day) -1 (mg/kg-day) -1 mg/kg-day Methylnaphthalene, 2-4.0E E-01 Acenaphthene 6.0E E-01 Acenaphthylene 3.0E E-01 Anthracene 3.0E E-01 Benzene 5.5E E E E-02 Benzo(a)anthracene 7.3E E E E-01 Benzo(a)pyrene 7.3E E E E-01 Benzo(b)fluoranthene 7.300E E E E-01 Benzo(g,h,i)perylene 3.0E E-01 Benzo(k)fluoranthene 7.3E E E E-01 Aromatics C11 to C22 3.0E E-01 Aliphatics C19 to C36 6.0E Aliphatics C5 to C8 4.0E E-02 Aromatics C9 to C10 3.0E E-01 Aliphatics C9 to C18 1.0E E-01 Chrysene 7.3E E E E-01 Fluoranthene 4.0E E-01 Fluorene 4.0E E-01 Indeno(1,2,3-cd)Pyrene 7.3E E E E-01 Naphthalene 2.0E E-04 Phenanthrene 3.0E E-01 Pyrene 3.0E E-01 Arsenic 1.5E E E E-07 Chromium(VI) 4.2E E E-05 Nickel 1.7E E E-04 Selenium 5.0E E-04 Zinc 3.0E E-04 MassDEP does not present toxicity information for copper in the Shortforms. Roux Associates used the subchronic copper RfD of 0.04, derived based upon the MCL presented by MassDEP in MADEP, Current Regulatory Limit: Copper, May, 2004 which was derived based on non-cancer effects. Available at: to assess groundwater risks from copper exposure. As described in that document, copper is not classifiable to carcinogencity, so it was not assessed as a carcinogen. ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.A/TA-2

71 ATTACHMENT B Exposure Assumptions ROUX ASSOCIATES, INC. PEM M /AP-CV

72 Table B-1: Residential Shortform Exposure Assumptions Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Soil: Table RS-5 Definitions and Exposure Factors Vlookup Version v0808 Parameter Value Units Notes ELCR - Excess Lifetime Cancer Risk chemical specific dimensionless Pathway specific (ing =ingestion, derm=dermal, inh=inhalation) CSF - Cancer Slope Factor chemical specific (mg/kg-day) -1 see Table RS-7 LADD - Lifetime Average Daily Dose chemical specific mg/kg-day Pathway specific LADE - Lifetime Average Daily Exposure chemical specific µg/m 3 HQ - Hazard Quotient chemical specific dimensionless Pathway specific (ing =ingestion, derm=dermal, inh=inhalation) RfD - Reference Dose chemical specific mg/kg-day see Table RS-7 ADD - Average Daily Dose chemical specific mg/kg-day Pathway specific ADE - Average Daily Exposure chemical specific mg/m 3 EPC - Exposure Point Concentration chemical specific mg/kg PUF - Plant Uptake Factor chemical specific (mg/mg)(mg/mg) -1 See Table RS-7; (mg OHM /mg plant )/(mg OHM /mg soil ) -1 IR (1-2) - Soil Ingestion Rate for age group mg/day MADEP Technical Update: Calculation of an Enhanced Soil Ingestion Rate. ( IR (1-8) - Soil Ingestion Rate for age group mg/day Ibid IR (8-15) - Soil Ingestion Rate for age group mg/day Ibid IR (15-31) - Soil Ingestion Rate for age group mg/day Ibid PIR (1-2) = Produce Ingestion Rate for age group ,900 mg/day see Table RS-6 PIR (1-8) = Produce Ingestion Rate for age group ,099 mg/day see Table RS-6 PIR (8-15) = Produce Ingestion Rate for age group ,809 mg/day Ibid PIR (15-31) = Produce Ingestion Rate for age group ,420 mg/day Ibid RAF c - Relative Absorption Factor for Cancer Effects chemical specific dimensionless EF subchronic - Exposure Frequency for subchronic ingestion or dermal exposure event/day 5 days/week EF chronic - Exposure Frequency for chronic ingestion or dermal exposure event/day 5 days/week, 30 weeks/year EF cancer - Exposure Frequency for cancer, ingestion or dermal exposure event/day 5 days/week, 30 weeks/year EF produce - Exposure Frequency for produce ingestion, cancer and noncancer 1.00 event/day EF cyanide - Exposure Frequency for subchronic and chronic non-cancer cyanide 1.00 event/day ED - Exposure Duration 1 day/event EP (1-2) - Exposure Period for age group years 30 weeks EP (1-8) - Exposure Period for age group years EP (8-15) - Exposure Period for age group years EP (15-31) - Exposure Period for age group years EP cyanide - Exposure period for cyanide exposure 1 day MADEP Guidance for Disposal Site Risk Characterization. Page 5-5. BW (1-2) - Body Weight for age group kg U.S. EPA Exposure Factors Handbook. Table 7-7, females. BW (1-8) - Body Weight for age group kg Ibid BW (8-15) - Body Weight for age group kg Ibid BW (15-31) - Body Weight for age group kg Ibid AP subchronic - Averaging Period for subchronic noncancer years 30 weeks AP chronic - Averaging Period for chronic noncancer 7 years AP cancer - Averaging Period for lifetime 70 years AP cyanide - Averaging period for assessing cyanide exposure 1 day MADEP Guidance for Disposal Site Risk Characterization. Page 5-5. SA (1-2) - Surface Area for age group cm 2 / day 50th percentile of face (1/3 head), forearms, hands, lower legs, and feet for females MADEP Guidance for Disposal Site Risk Characterization. Appendix Table B-2. SA (1-8) - Surface Area for age group cm 2 / day Ibid SA (8-15) - Surface Area for age group cm 2 / day Ibid SA (15-31) - Surface Area for age group cm 2 / day Ibid SAF (1-2) - Surface Adherence Factor for age group mg/cm 2 All SAFs developed for ShortForm according to procedure outlined in MA DEP Technical Update: SAF (1-8) - Surface Adherence Factor for age group mg/cm 2 Weighted Skin-Soil Adherence Factors, April 2002 SAF (8-15) - Surface Adherence Factor for age group mg/cm 2 SAF (15-31) - Surface Adherence Factor for age group mg/cm 2 ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.B/TB-1

73 Table B-2: Construction Worker Shortform Exposure Assumptions Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Construction Worker - Soil: Table CW-4 Definitions and Exposure Factors Vlookup Version v0808 Parameter Value Units Notes ELCR - Excess Lifetime Cancer Risk chemical specific dimensionless Pathway specific (ing =ingestion, derm=dermal, inh=inhalation) HI - Hazard Index chemical specific dimensionless Pathway specific (ing =ingestion, derm=dermal, inh=inhalation) CSF - Cancer Slope Factor chemical specific (mg/kg-day) -1 see Table CW-5. RfD - Reference Dose chemical specific mg/kg-day see Table CW-5. LADD - Lifetime Average Daily Dose chemical specific mg/kg-day Pathway specific. See Table CW-2. ADD - Average Daily Dose chemical specific mg/kg-day Pathway specific. See Table CW-3. EPC - Exposure Point Concentration chemical specific µg/l see Table CW-1. IR - Soil Ingestion Rate 100 mg/day MADEP Technical Update: Calculation of an Enhanced Soil Ingestion Rate. ( RAF c - Relative Absorption Factor for Cancer Effects chemical specific dimensionless Pathway specific - see Table CW-5. RAF nc - Relative Absorption Factor for Noncancer Effects chemical specific dimensionless Pathway specific - see Table CW-5. EF - Exposure Frequency event/day 5 events (days) / 7 events (days) in a week; MADEP 1995 Guidance for Disposal Site Risk Characterization pg B-38. EF cyanide - Exposure Frequency for Cyanide Exposures 1.00 event/day MADEP Guidance for Disposal Site Risk Characterization. Page 5-5. ED ing,derm - Exposure Duration for ingestion or dermal exposure 1 day/event ED inh - Exposure Duration for inhalation exposure day/event Represents 8 hours / event. EP - Exposure Period 182 days 6 months; MADEP 1995 Guidance for Disposal Site Risk Characterization. EP cyanide - Exposure period for cyanide exposure 1 day MADEP Guidance for Disposal Site Risk Characterization. Page 5-5. BW - Body Weight 58.0 kg U.S. EPA Exposure Factors Handbook. Table 7-7, Females, ages AP (lifetime) - Averaging Period for lifetime 25,550 days Represents 70 years AP (noncancer) - Averaging Period for noncancer 182 days 6 months; MADEP 1995 Guidance for Disposal Site Risk Characterization. AP cyanide - Averaging period for assessing cyanide exposure 1 day MADEP Guidance for Disposal Site Risk Characterization. Page 5-5. AF - Adherence Factor 0.29 mg/cm 2 MA DEP Technical Update: Weighted Skin-Soil Adherence Factors. ( VR work - Ventilation Rate during work (heavy exertion) 60 L/min Table B-4 MADEP 1995 Guidance for Disposal Site Risk Characterization. SA - Surface Area 3473 cm 2 /day MADEP Guidance for Disposal Site Risk Characterization. 50th percentile for females. Appendix Table B-2. RCAF inh-gi - Relative Concentration Adjustment Factor, gastrointestinal 1.5 dimensionless MADEP Characterization of Risks Due to Inhalation of Particulates by Construction Workers RCAF inh - Relative Concentration Adjustment Factor, inhalation 0.5 dimensionless MADEP Characterization of Risks Due to Inhalation of Particulates by Construction Workers PM10 - Concentration of PM µg/m 3 MADEP 1995 Guidance for Disposal Site Risk Characterization pg B-11 ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.B/TB-2

74 ATTACHMENT C Equations to Calculate Risk ROUX ASSOCIATES, INC. PEM M /AP-CV

75 Table C-1: Residential Shortform Cancer Risk Equations Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Soil: Table RS-2 Equations to Calculate Cancer Risk for Resident (Age 1-31 years) Parameter Value Units Vlookup Version v0808 CSF OHM specific (mg/kg-day) -1 Cancer Risk from Ingestion LADD age/ohm specific mg/kg-day [OHM] soil OHM specific mg/kg ELCR ing = LADD ing(1-31) * CSF IR (1-8) 100 mg/day IR (8-15) 50 mg/day LADD ing (1-31) = LADD ing (1-8) + LADD ing (8-15) + LADD ing (15-31) IR (15-31) 50 mg/day PIR (1-8) 12,099 mg/day LADD ing (age group x) = [OHM] soil * IR x * RAF c-ing * EF ing * ED * EP x * C PIR (8-15) 17,809 mg/day BW x * AP lifetime PIR (15-31) 24,420 mg/day RAF c-ing OHM specific dimensionless Cancer Risk from Dermal Absorption RAF c-derm OHM specific dimensionless RAF c-produce OHM specific dimensionless ELCR derm = LADD derm * CSF EF ing,derm event/day EF produce 1.00 event/day LADD derm (1-31) = LADD derm (1-8) + LADD derm (8-15) + LADD derm (15-31) ED 1 day/event EP (1-8) 7 years LADD derm(age group x) = [OHM] soil * SA x * RAF c-derm * SAF x * EF derm * ED * EP x * C EP (8-15) 7 years BW x * AP lifetime EP (15-31) 16 years C kg/mg BW (1-8) 17.0 kg Cancer Risk from Homegrown Produce BW (8-16) 39.9 kg BW (16-31) 58.7 kg ELCR produce = LADD produce(1-31) * CSF AP (lifetime) 70 years SA (1-8) 2431 cm 2 / day LADD produce(1-31) = LADD produce(1-8) + LADD produce(8-15) + LADD produce(15-31) SA (8-15) 4427 cm 2 / day LADD produce(age x) = SA (15-31) 5653 cm 2 / day [OHM soil ] * PUF * PIR x * RAF produce * EF produce * ED * EP x * C SAF (1-8) 0.35 mg/cm 2 BW x * AP lifetime SAF (8-15) 0.14 mg/cm 2 SAF (15-31) 0.13 mg/cm 2 PUF OHM specific (mg/mg)(mg/mg) -1 ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.C/TC-1

76 Table C-2: Residential Shortform Chronic Noncancer Risk Equations Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Soil: Table RS-3 Equations to Calculate Chronic Noncancer Risk for Resident Child (Age 1-8 years) Chronic Noncancer Risk from Ingestion HQ ing = ADD ing = Vlookup Version v0808 Parameter Value Units ADD ing RfD OHM specific mg/kg-day RfD ADD OHM specific mg/kg-day [OHM] soil OHM specific mg/kg [OHM] soil * IR * RAF nc-ing * EF ing * ED * EP * C IR 100 mg/day BW * AP PIR 12,099 mg/day RAF nc-ing OHM specific dimensionless Chronic Noncancer Risk from Dermal Absorption RAF nc-derm OHM specific dimensionless HQ derm = ADD derm = RAF nc-produce OHM specific dimensionless ADD ing,derm EF ing,derm event/day RfD EF produce 1.00 event/day EF cyanide 1.00 event/day [OHM] soil * SA * RAF nc-derm * SAF * EF derm * ED * EP * C ED 1 day/event BW * AP EP 7 years EP cyanide 1 day Chronic Noncancer Risk from Homegrown Produce C kg/mg BW 17.0 kg HQ produce = ADD produce AP 7 year RfD AP cyanide 1 day ADD produce = SA 2431 cm 2 / day [OHM soil ] * PUF * PIR * RAF produce * EF produce * ED * EP * C SAF 0.35 mg/cm 2 BW * AP PUF OHM specific (mg/mg)(mg/mg) -1 Cyanide can cause a significant health risk from one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.C/TC-2

77 Table C-3: Residential Shortform Subchronic Noncancer Risk Equations Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Soil: Table RS-4 Equations to Calculate Subchronic Noncancer Risk for Resident Child (Age 1-2 years) Subchronic Noncancer Risk from Ingestion HQ ing = ADD ing = Vlookup Version v0808 Parameter Value Units ADD ing RfD OHM specific mg/kg-day RfD subchronic ADD OHM specific mg/kg-day [OHM] soil OHM specific mg/kg [OHM] soil * IR * RAF nc-ing * EF ing * ED * EP * C IR 100 mg/day BW * AP PIR 10,900 mg/day RAF nc-ing OHM specific dimensionless Subchronic Noncancer Risk from Dermal Absorption RAF nc-derm OHM specific dimensionless RAF nc-produce OHM specific dimensionless HQ derm = ADD derm EF ing,derm event/day RfD subchronic EF produce 1.00 event/day EF cyanide 1.00 event/day ADD derm = [OHM] soil * SA * RAF nc-derm * SAF * EF derm * ED * EP * C ED 1 day/event BW * AP EP cyanide 1 day EP years Subchronic Noncancer Risk from Homegrown Produce C kg/mg BW 10.7 kg HQ produce = ADD produce AP year RfD subchronic AP cyanide 1 day ADD produce = SA 1670 cm 2 / day [OHM soil ] * PUF * PIR * RAF produce * EF produce * ED * EP * C SAF 0.35 mg/cm 2 BW * AP PUF OHM specific (mg/mg)(mg/mg) -1 Cyanide can cause a significant health risk from one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.C/TC-3

78 Table C-4: Construction Worker Shortform Cancer Risk Equations Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Construction Worker - Soil: Table CW-2 Equations to Calculate Cancer Risk for Construction Worker Vlookup Version v0808 Cancer Risk from Ingestion Parameter Value Units CSF OHM-specific (mg/kg-day) -1 ELCR ing = LADD ing * CSF oral LADD age/ohm-specific mg/kg-day EPC OHM-specific mg/kg LADD ing = EPC * IR * RAF c-ing * EF * ED ing * EP * C1 IR 100 mg/day BW * AP lifetime RAF c-ing OHM-specific dimensionless RAF c-derm OHM-specific dimensionless Cancer Risk from Dermal Absorption RAF c-inh OHM-specific dimensionless EF event/day ELCR derm = LADD derm * CSF oral ED ing & derm 1 day/event ED inh day/event LADD derm = EPC * SA * AF * RAF c-derm * EF * ED derm * EP * C1 EP 182 days BW * AP lifetime C1 1.0E-06 kg/mg C2 1.0E-09 kg/µg Cancer Risk from Particulate Inhalation - Gastrointestinal Absorption C min/days C4 1.0E-03 m 3 /L ELCR inh-gi = LADD inh-gi * CSF oral BW 58.0 kg AP (lifetime) 25,550 days LADD inh-gi = EPC * RCAF inh-gi * PM 10 * VR work * RAF c-ing * EF * ED inh * EP * C2 * C3 * C4 VR work 60 L/min BW * AP lifetime AF 0.29 mg/cm 2 SA 3473 cm 2 /day Cancer Risk from Particulate Inhalation - Pulmonary Absorption RCAF inh-gi 1.5 dimensionless RCAF inh 0.5 dimensionless ELCR inh = LADD inh * CSF inhalation PM µg/m 3 LADD = EPC * RCAF inh * PM 10 * VR work * RAF c-inh * EF * ED inh * EP * C2 * C3 * C4 BW * AP lifetime ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.C/TC-4

79 Table C-5: Construction Worker Shortform Noncancer Risk Equations Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Construction Worker - Soil: Table CW-3 Equations to Calculate Noncancer Risk for Construction Worker Vlookup Version v0808 Noncancer Risk from Ingestion Parameter Value Units HQ ing = ADD ing = RfD OHM-specific mg/kg-day ADD ing ADD OHM-specific mg/kg-day RfD oral-subchronic EPC OHM-specific mg/kg IR 100 mg/day EPC * IR * RAF nc-ing * EF * ED ing * EP * C1 RAF nc-ing OHM-specific dimensionless BW * AP noncancer RAF nc-derm OHM-specific dimensionless RAF nc-inh OHM-specific dimensionless Noncancer Risk from Dermal Absorption EF event/day HQ derm = EF cyanide 1 event/day ADD derm ED ing & derm 1 day/event RfD oral-subchronic ED inh day/event EP 182 days ADD dermal = EPC * SA * AF * RAF nc-derm * EF * ED dermal * EP * C1 EP cyanide 1.00 day BW * AP noncancer C1 1.0E-06 kg/mg C2 1.0E-09 kg/µg Noncancer Risk from Particulate Inhalation - Gastrointestinal Absorption C min/days HQ inh-gi = ADD inh-gi = C4 1.0E-03 m 3 /L ADD inh-gi BW 58.0 kg RfD oral-subchronic AP noncancer 182 days EPC * RCAF inh-gi * PM 10 * VR work * RAF nc-ing * EF * ED inh * EP * C2 * C3 * C4 BW * AP noncancer AP cyanide 1 day VR work 60 L/min AF 0.29 mg/cm 2 SA 3473 cm 2 /day Noncancer Risk from Particulate Inhalation - Pulmonary Absorption RCAF inh-gi 1.5 dimensionless RCAF inh 0.5 dimensionless HQ inh = ADD PM10 60 µg/m 3 RfD inhalation-subchronic ADD inh = EPC soil * RCAF inh * PM 10 * VR work * RAF nc-inh * EF * ED inh * EP * C2 * C3 * C4 BW * AP noncancer Cyanide can cause a significant health risk from a one-time exposure to concentrations that are often found in the environment. As such, risk is calculated for a single exposure. Thus, for cyanide, the exposure frequency (EF) is 1 event/day, while both the exposure period (EP) and averaging period (AP) are 1 day. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.C/TC-5

80 ATTACHMENT D Risk Tables ROUX ASSOCIATES, INC. PEM M /AP-CV

81 Table D-1: Estimated Hazard Indices (HIs) Future Construction Worker Exposure Scenario - Groundwater Exposure Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Dermal Permeability Constant Subchronic Oral Reference Dose Groundwater Concentration Average Daily Intake Hazard Index ANALYTE CASRN (µg/l) (cm/hour) (mg/kg/day) (mg/kg/day) (GW) (Kp) (DA) (RfD) (QDA) (a) (b) (c) (d) (e) METALS Arsenic E+1 1.0E-3 1.8E-7 3.0E-4 6E-4 Chromium E-1 2.0E-3 6.0E-9 2.0E-2 3E-7 Copper E+0 1.0E-3 8.5E-9 4.0E-2 2E-7 Nickel E+1 2.0E-4 1.1E-8 2.0E-2 5E-7 Selenium E+0 1.0E-3 5.0E-9 5.0E-3 1E-6 Zinc E+1 6.0E-4 3.0E-8 3.0E-1 1E-7 TOTAL HI: 5.9E-4 Assumptions Used for Estimating Intakes and Exposures Body weight (kg) (BW) = 71.8 Body surface area exposed to groundwater (cm2) (SA gw ) = 2535 Exposure duration for groundwater (hours/event) (ED gw ) = 2 Exposure frequency for groundwater (events/year) (EF gw ) = 13 Exposure period - noncarcinogens (years) (EP) = 0.5 Averaging period - noncarcinogens (years) (AP nc ) = 0.5 Total hours in a day (hours/day) (HR) = 24 Conversion factor (days/6 mos) (C) = 183 Conversion factor (mg/µg) (X) = Volumetric conversion factor (L/cm 3 ) (V) = Notes: MassDEP, Workbook for the Development of MCP Risk-Based Levels for Soil and Groundwater. May USEPA, Risk Assessment r Guidance for Superfund Volume I: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment). Final. EPA/540/R/99/005. July. t (a) Concentration is equal to the concentration detected at EX-01 on May 27, (µg/l) (GW). (b) Dermal permeability constant (chemical-specific) for absorption of chemical across skin (Kp) in cm/hour. Obtained from MassDEP, 2009, when wavailable. Copper 's dermal permeability constant equal the default for metals, as provided in USEPA, x (c) Estimated average xdaily intake (mg/kg) via dermal absorption (DA). DA = ( GW * Kp * SA gw * ED gw * X * EF gw * V * EP ) / ( C * AP nc * BW ). y (d) Subchronic reference dose (RfD) (mg/kg/day). Values are from the MassDEP construction worker shortform (vlookup version v0808). The shortform does not provide an RfD for copper. The copper RfD was derived was derived from the MCL presented by MassDEP in May, 2004 in the Current Regulatory Limit: Copper documentation. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.D/TD-1

82 Table D-2: Estimated Excess Lifetime Cancer Risk (ELCR) Future Construction Worker Exposure Scenario - Groundwater Exposure Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Groundwater Concentration Dermal Permeability Constant Lifetime Average Daily Intake Oral Cancer Slope factor ANALYTE CASRN (µg/l) (cm/hour) (mg/kg/day) (mg/kg/day) -1 Excess Lifetime Cancer Risk (ELCR) (GW) (Kp) (DA) (CPFo) (ERDA) (a) (b) (c) (d) (e) METALS Arsenic E+1 1.0E-3 1.3E-9 1.5E+0 1.9E-09 Chromium E-1 2.0E-3 4.3E-11 NC NC Copper E+0 1.0E-3 6.1E-11 NC NC Nickel E+1 2.0E-4 7.8E-11 NC NC Selenium E+0 1.0E-3 3.6E-11 NC NC Zinc E+1 6.0E-4 2.2E-10 NC NC TOTAL ELCR: 1.9E-9 Assumptions Used for Estimating Intakes and Exposures Body weight (kg) (BW) = 71.8 Body surface area exposed to groundwater (cm2) (SA gw ) = 2535 Exposure duration for groundwater (hours/event) (ED gw ) = 2 Exposure frequency for groundwater (events/year) (EF gw ) = 13 Exposure period - carcinogens (years) (EP) = 0.5 Averaging period - carcinogens (years) (AP c ) = 70 Total hours in a day (hours/day) (HR) = 24 Conversion factor (days/6 mos) (C) = 183 Conversion factor (mg/µg) (X) = Volumetric conversion factor (L/cm 3 ) (V) = Relative absorption factor (unitless) (RAF) = 0 Notes: NC indicates that MassDEP has not determined the compound to be carcinogenic via the dermal pathway. MassDEP, Workbook for the Development of MCP Risk-Based Levels for Soil and Groundwater. May USEPA, Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment). Final. EPA/540/R/99/005. July. (a) Concentration is equal to the concentration detected at EX-01 on May 27, (µg/l) (GW). (b) Dermal permeability constant (chemical-specific) for absorption of chemical across skin (Kp) in cm/hour. Obtained from MassDEP, 2009, when available. Copper 's dermal permeability constant is the default for metals, as provided in USEPA, (c) Estimated lifetime average daily intake (mg/kg) via dermal absorption (DA). DA = ( GW * Kp * SA gw * ED gw * X * EF gw * V * EP ) / ( C * AP c * BW ). (d) Oral cancer slope factor (CPFo) (mg/kg/day) -1. Values are from the MassDEP construction worker shortform (vlookup version v0808). (e) Excess lifetime cancer risk from dermal exposure (ERDA). ERDA = DA * CPFo ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.D/TD-2

83 Table D-3: Construction Worker Shortform Risk Table Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Construction Worker - Soil ShortForm Version Exposure Point Concentration (EPC) and Risk Vlookup Version v0808 Based on Construction Worker years of age ELCR (all chemicals) = 4E-08 **Do not insert or delete any rows** HI (all chemicals) = 4E-02 Click on empty cell below and select OHM using arrow. Oil or Hazardous EPC ELCR ELCR ELCR ELCR Subchronic Material (OHM) (mg/kg) ingestion dermal inhalation GI inhalation pulmonary ELCR total HQ ing HQ derm HQ inh-gi HQ inh HQ total Methylnaphthalene, 2-2.1E E E E E E-03 Acenaphthene 4.5E E E E E E-05 Acenaphthylene 9.8E E E E E E-06 Anthracene 1.2E E E E E E-07 Benzo(a)anthracene 1.1E E E E E E E E E E E-06 Benzo(a)pyrene 1.1E E E E E E E E E E E-06 Benzo(b)fluoranthene 9.6E E E E E E E E E E E-06 Benzo(g,h,i)perylene 9.3E E E E E E-06 Benzo(k)fluoranthene 9.8E E E E E E E E E E E-06 Aromatics C11 to C22 1.6E E E E E E-03 Aliphatics C19 to C36 7.5E E E E E-04 Aliphatics C5 to C8 4.8E E E E E E-03 Aromatics C9 to C10 2.4E E E E E E-03 Aliphatics C9 to C18 1.2E E E E E E-03 Chrysene 1.3E E E E E E E E E E E-06 Fluoranthene 1.9E E E E E E-06 Fluorene 3.4E E E E E E-05 Indeno(1,2,3-cd)Pyrene 9.1E E E E E E E E E E E-06 Naphthalene 5.3E E E E E E-04 Phenanthrene 5.9E E E E E E-05 Pyrene 1.7E E E E E E-06 The C9-C12 aliphatic hydrocarbon range was not evaluated, as risks to these constituents are evauated within the C9-C18 aliphatic fraction. The EPC was developed using data collected from: MW-17 (10-11 ), MW-17 (14-15 ), MW-18 (13-14 ), MW-19 (12-13 ), MW-20 (7 ), MW-20 (9 ), SB-25 (8 ), SB-25 (10 ), SB-25 (15 ), and SB-27 (11 ) advanced in 2007, and HS-02, HS-08, HS-09, HS-11, HS-17, HS-18 and HS-19, advanced in ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.D/TD-3

84 Table D-4: Residential Shortform Risk Table Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Soil: ShortForm Version 4-06 Exposure Point Concentration (EPC) Vlookup Version v0808 Based on Resident Ages 1-31 (Cancer), 1-8 (Chronic Noncancer), and 1-2 (Subchronic Noncancer) ELCR (all chemicals) = 2E-06 Chronic HI (all chemicals) = 5E-01 **Do not insert or delete any rows** Subchronic HI (all chemicals) = 1E-01 Click on empty cell below and select OHM using arrow. Oil or EPC Chronic Subchronic Hazardous Material (mg/kg) ELCR ingestion ELCR dermal ELCR vegetable ELCR total HQ ing HQ derm HQ vegetable HQ total HQ ing HQ derm HQ vegetable HQ total Methylnaphthalene, 2-2.1E E E E E E E-02 Acenaphthene 4.5E E E E E E E-05 Acenaphthylene 9.8E E E E E E E-05 Anthracene 1.2E E E E E E E-06 Benzo(a)anthracene 1.1E E E E E E E E E E-06 Benzo(a)pyrene 1.1E E E E E E E E E E-06 Benzo(b)fluoranthene 9.6E E E E E E E E E E-06 Benzo(g,h,i)perylene 9.3E E E E E E E-05 Benzo(k)fluoranthene 9.8E E E E E E E E E E-06 Aromatics C11 to C22 1.6E E E E E E E-02 Aliphatics C19 to C36 7.5E E E E E E E-03 Aliphatics C5 to C8 4.8E E E E E E E-03 Aromatics C9 to C10 2.4E E E E E E E-02 Aliphatics C9 to C18 1.2E E E E E E E-02 Chrysene 1.3E E E E E E E E E E-05 Fluoranthene 1.9E E E E E E E-05 Fluorene 3.4E E E E E E E-05 Indeno(1,2,3-cd)Pyrene 9.1E E E E E E E E E E-06 Naphthalene 5.3E E E E E E E-04 Phenanthrene 5.9E E E E E E E-04 Pyrene 1.7E E E E E E E-05 The C9-C12 aliphatic hydrocarbon range was not evaluated, as risks to these constituents are evauated within the C9-C18 aliphatic fraction. The EPC was developed using data collected from: MW-17 (10-11 ), MW-17 (14-15 ), MW-18 (13-14 ), MW-19 (12-13 ), MW-20 (7 ), MW-20 (9 ), SB-25 (8 ), SB-25 (10 ), SB-25 (15 ), and SB-27 (11 ) advanced in 2007, and HS-02, HS-08, HS-09, HS-11, HS-17, HS-18 and HS-19, advanced in ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.D/TD-4

85 ATTACHMENT E Uncertainties Tables for Metals in Groundwater ROUX ASSOCIATES, INC. PEM M /AP-CV

86 Table E-1: Uncertainties Analysis - Groundwater Exposure Point Concentration Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts EX-01 IN1D720 IN3D722 IN7D27 Exposure Point Concentration CHEMICAL NAME Unit 5/27/2009 7/20/2009 7/22/2009 7/27/2009 Metals Antimony ug/l 0.25 NT NT NT NA Arsenic ug/l Cadmium ug/l 0.1 NT NT NT NA Chromium ug/l Copper ug/l Iron ug/l NA Lead ug/l Mercury ug/l 0.1 NT NT NT NA Nickel ug/l Selenium ug/l Silver ug/l 0.2 NT NT NT NA Zinc ug/l General Notes: µg/l = micrograms per liter Concentrations shown equal the concentration detected, or one-half of the detection limit. Iron was not considered a COC. NA = Not Applicable, as constituent was not detected in any sample. NT= Not Tested Exposure Point Concentration equals the average concentration of detected constituents, using one-half the detection limit as a surrogate concentration if the constituent was not detected in the sample. Data Source: Analytical Reports "L ", "L ", "L ", and "L " from ALPHA Analytical. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.E/TE-1

87 Table E-2: Uncertainties Analysis - Estimated Hazard Indices (HIs) Future Construction Worker Exposure Scenario - Groundwater Exposure Peabody Essex Museum Site 17 Central Street Property Salem, MA Dermal Permeability Constant Subchronic Oral Reference Dose Groundwater Concentration Average Daily Intake Hazard Index ANALYTE CASRN (µg/l) (cm/hour) (mg/kg/day) (mg/kg/day) (GW) (Kp) (DA) (RfD) (QDA) (a) (b) (c) (d) (e) METALS Arsenic E+2 1.0E-3 1.7E-6 3.0E-4 6E-3 Chromium E-1 2.0E-3 6.4E-9 2.0E-2 3E-7 Copper E+1 1.0E-3 4.1E-7 4.0E-2 1E-5 Lead E+0 1.0E-4 4.6E-9 7.5E-4 6E-6 Nickel E+0 2.0E-4 6.5E-9 2.0E-2 3E-7 Selenium E+0 1.0E-3 5.0E-9 5.0E-3 1E-6 Zinc E+1 6.0E-4 1.7E-7 3.0E-1 6E-7 TOTAL HI: 5.8E-3 Assumptions Used for Estimating Intakes and Exposures Body weight (kg) (BW) = 71.8 Body surface area exposed to groundwater (cm2) (SA gw ) = 2535 Exposure duration for groundwater (hours/event) (ED gw ) = 2 Exposure frequency for groundwater (events/year) (EF gw ) = 13 Exposure period - noncarcinogens (years) (EP) = 0.5 Averaging period - noncarcinogens (years) (AP nc ) = 0.5 Total hours in a day (hours/day) (HR) = 24 Conversion factor (days/6 mos) (C) = 183 Conversion factor (mg/µg) (X) = Volumetric conversion factor (L/cm 3 ) (V) = Notes: MassDEP, Workbook for the Development of MCP Risk-Based Levels for Soil and Groundwater. May USEPA, Risk Assessment r Guidance for Superfund Volume I: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment). Final. EPA/540/R/99/005. July. t (a) Concentration is equal to the average concentration, as shown on Table E-1 (µg/l) (GW). (b) Dermal permeability constant (chemical-specific) for absorption of chemical across skin (Kp) in cm/hour. Obtained from MassDEP, 2009, when w available. Copper 's dermal permeability constant equal the default for metals, as provided in USEPA, x (c) Estimated average x daily intake (mg/kg) via dermal absorption (DA). DA = ( GW * Kp * SA gw * ED gw * X * EF gw * V * EP ) / ( C * AP nc * BW ). y (d) Subchronic reference dose (RfD) (mg/kg/day). Values are from the MassDEP construction worker shortform (vlookup version v0808). The shortform does not provide an RfD for copper. The copper RfD was derived was derived from the MCL presented by MassDEP in May, 2004 in the Current Regulatory Limit: Copper documentation. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.E/TE-2

88 Table E-3: Uncertainties Analysis - Estimated Excess Lifetime Cancer Risk (ELCR) Future Construction Worker Exposure Scenario - Groundwater Exposure Peabody Essex Museum Site 17 Central Street Property Salem, MA Groundwater Concentration Dermal Permeability Constant Lifetime Average Daily Intake Oral Cancer Slope factor ANALYTE CASRN (µg/l) (cm/hour) (mg/kg/day) (mg/kg/day) -1 Excess Lifetime Cancer Risk (ELCR) (GW) (Kp) (DA) (CPFo) (ERDA) (a) (b) (c) (d) (e) METALS Arsenic E+2 1.0E-3 1.2E-8 1.5E+0 1.8E-08 Chromium E-1 2.0E-3 4.6E-11 NC NC Copper E+1 1.0E-3 2.9E-9 NC NC Lead E+0 1.0E-4 3.3E-11 NC NC Nickel E+0 2.0E-4 4.7E-11 NC NC Selenium E+0 1.0E-3 3.6E-11 NC NC Zinc E+1 6.0E-4 1.2E-9 NC NC TOTAL ELCR: 1.8E-8 Assumptions Used for Estimating Intakes and Exposures Body weight (kg) (BW) = 71.8 Body surface area exposed to groundwater (cm2) (SA gw ) = 2535 Exposure duration for groundwater (hours/event) (ED gw ) = 2 Exposure frequency for groundwater (events/year) (EF gw ) = 13 Exposure period - carcinogens (years) (EP) = 0.5 Averaging period - carcinogens (years) (AP c ) = 70 Total hours in a day (hours/day) (HR) = 24 Conversion factor (days/6 mos) (C) = 183 Conversion factor (mg/µg) (X) = Volumetric conversion factor (L/cm 3 ) (V) = Notes: NC indicates that MassDEP has not determined the compound to be carcinogenic via the dermal pathway. MassDEP, Workbook for the Development of MCP Risk-Based Levels for Soil and Groundwater. May USEPA, Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment). Final. EPA/540/R/99/005. July. (a) Concentration is equal to the average concentration, as shown on Table E-1 (µg/l) (GW). (b) Dermal permeability constant (chemical-specific) for absorption of chemical across skin (Kp) in cm/hour. Obtained from MassDEP, 2009, when available. Copper 's dermal permeability constant is the default for metals, as provided in USEPA, (c) Estimated lifetime average daily intake (mg/kg) via dermal absorption (DA). DA = ( GW * Kp * SA gw * ED gw * X * EF gw * V * EP ) / ( C * AP c * BW ). (d) Oral cancer slope factor (CPFo) (mg/kg/day) -1. Values are from the MassDEP construction worker shortform (vlookup version v0808). (e) Excess lifetime cancer risk from dermal exposure (ERDA). ERDA = DA * CPFo (k) Total excess lifetime cancer risk for the exposure scenario is the sum of the ELCRs for individual chemicals. ROUX ASSOCIATES, INC. 1 of 1 PEM M Att.E/TE-3

89 ATTACHMENT F Uncertainties Tables for SG-3 ROUX ASSOCIATES, INC. PEM M /AP-CV

90 Table F-1 Estimated Indoor Air Concentrations Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Public Sidewalk Estimated Indoor Air Concentration SG-3 SG-3 SG-3 SG-3 SG SG SG SG /22/2004 1/25/ /5/ /16/2007 CHEMICAL NAME Unit Methylnaphthalene, 2- ug/m Aliphatics C5 to C8 ug/m3 2, Aromatics C9 to C10 ug/m Aliphatics C9 to C12 ug/m3 1, Ethylbenzene ug/m Naphthalene ug/m o-xylene ug/m Toluene ug/m m,p-xylenes ug/m Xylenes (mixed isomers) ug/m Concentrations shown in this table represent the detected concentration, or one-half of the detection limit, if the compound was not detected in the sample. The estimated indoor air concentration was calculated as the average concentration of the compound in SG-3, divided by an attenuation factor of 70, as presented by MassDEP in the Interim Final Vapor Intrusion Guidance, December ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.F/TF-1

91 Table F-2: Toxocity Factors For Inhalation of Indoor Air Peabody Essex Museum Site 17 Central Street Property Salem Massachusetts Resident - Indoor Air: Table RA-5 Chemical-Specific Data Vlookup Version v0808 Oil or URF RfC Target Hazardous Material (ug/m 3 ) -1 mg/m 3 Organ Methylnaphthalene, E-02 liver, kidney, developmental and body weight reduction Aliphatics C5 to C8 2.00E-01 CNS Aromatics C9 to C E-02 liver, kidney, developmental and body weight reduction Aliphatics C9 to C E-01 CNS Ethylbenzene 1.0E+00 developmental effects Naphthalene 3.0E-03 nasal, lung Toluene 5.0E+00 CNS Xylenes (mixed isomers) 1.0E-01 CNS CNS - central nervous system ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.F/TF-2

92 Table F-3: Exposure Assumptions for Inhalation of Indoor Air Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Indoor Air: Table RA-4 Definitions and Exposure Factors Vlookup Version v0808 Parameter Value Units Notes ELCR - Excess Lifetime Cancer Risk chemical specific dimensionless URF - Unit Risk Factor chemical specific (µg/m 3 ) -1 see Table RA-5 LADE - Lifetime Average Daily Exposure chemical specific µg/m 3 see Table RA-2 HQ - Hazard Quotient chemical specific dimensionless RfC - Reference Concentration chemical specific mg/m 3 see Table RA-5 ADE - Average Daily Exposure chemical specific µg/m 3 see Table RA-3 EPC - Exposure Point Concentration chemical specific µg/l see Table RA-1 EF - Exposure Frequency 1.00 event/day ED - Exposure Duration 1 day/event EP (1-8) - Exposure Period age group 1-8 (noncancer) 7 years EP (1-31) - Exposure Period for age group 1-31 (cancer) 30 years AP (noncancer) - Averaging Period for noncancer 7 years AP (lifetime) - Averaging Period for lifetime 70 years ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.F/TF-4

93 Table F-4: Risk Equations for Inhalation of Indoor Air Peabody Essex Museum Site 17 Central Street Property Salem, Massachusetts Resident - Indoor Air: Table RA-3 Equations to Calculate Noncancer Risk for Resident Child (Age 1-8 years) Vlookup Version v0808 Noncancer Risk from Inhalation Parameter Value Units HQ air = ADE = RfC OHM specific mg/m 3 ADE * C ADE OHM specific µg/m 3 RfC [OHM] soil OHM specific µg/m 3 EF 1.00 event/day [OHM] air * EF * ED * EP ED 1 day/event AP EP 7 years C mg/ug AP 7 year ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.F/TF-4

94 Table F-5: Calculation of Indoor Air Risk Peabody Essex Museum Site 17 central Street Property Salem, Massachusetts Resident - Indoor Air: Table RA-1 ShortForm Version 4-06 Exposure Point Concentration (EPC) Vlookup Version v0808 Based on Resident Ages 1-31 (Cancer) and 1-8 (Noncancer) ELCR (all chemicals) = **Do not insert or delete any rows** HI (all chemicals) = 1.3E+00 Click on empty cell below and select OHM using arrow. Oil or EPC Hazardous Material (µg/m 3 ) ELCR air HQ air Methylnaphthalene, 2-3.5E E-03 Aliphatics C5 to C8 1.2E E-02 Aromatics C9 to C10 3.4E E-01 Aliphatics C9 to C12 3.4E E-01 Ethylbenzene 1.5E E-04 Naphthalene 1.1E E-01 Toluene 1.9E E-05 Xylenes (mixed isomers) 5.3E E-03 The EPC equals the average concentration of constituents detected in SG-3 between 2004 and 2007, divided by an attenuation factor of 70. ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.F/TF-5

95 Table F-6: Target Organ-Specific Risk Summary Peabody Essex Museum Site Salem, Massachusetts 17 Central Street Property Salem, Massachusetts Soil Oil or Hazardous Material HQ total Target Organ HQ air Target Organ or Health Effect Lung Liver Kidney Blood liver, kidney, developmental and Methylnaphthalene, 2-1.6E-02 lung 6.9E-03 body weight reduction 1.6E E E-03 Acenaphthene 2.2E-04 liver NA 2.2E-04 Acenaphthylene 9.6E-05 kidney NA 9.6E-05 Anthracene 1.2E-05 no effects NA Benzo(a)anthracene 4.0E-05 kidney NA 4.0E-05 Benzo(a)pyrene 3.9E-05 kidney NA 3.9E-05 Benzo(b)fluoranthene 3.5E-05 kidney NA 3.5E-05 Benzo(g,h,i)perylene 9.1E-05 kidney NA 9.1E-05 Benzo(k)fluoranthene 3.6E-05 kidney NA 3.6E-05 Aromatics C11 to C22 1.6E-01 kidney NA 1.6E-01 Aliphatics C19 to C36 1.7E-03 liver NA 1.7E-03 Central Nervous System Aliphatics C5 to C8 2.8E-02 central nervous system 5.8E-02 central nervous system 8.6E-02 liver, kidney, developmental and Aromatics C9 to C10 1.0E-01 kidney 6.8E-01 body weight reduction 6.8E E-01 Aliphatics C9 to C12 NA 1.7E-01 central nervous system 1.7E-01 Aliphatics C9 to C18 1.6E-01 liver, blood NA 1.6E E-01 Chrysene 4.6E-05 kidney NA 4.6E-05 Fluoranthene 1.4E-04 kidney, liver, blood NA 1.4E E E-04 Fluorene 2.5E-04 blood NA 2.5E-04 Indeno(1,2,3-cd)Pyrene 3.3E-05 kidney NA 3.3E-05 Naphthalene 7.7E-04 body weight 3.7E-01 nasal, lung 3.7E-01 Phenanthrene 5.8E-04 kidney NA 5.8E-04 Pyrene 1.6E-04 kidney NA 1.6E-04 Ethylbenzene NA 1.5E-04 developmental effects Toluene NA 3.8E-05 central nervous system 3.8E-05 Xylenes (mixed isomers) NA 5.3E-03 central nervous system 5.3E-03 Total Target Organ-Specific HI: 3.90E E E E E-01 NA = Not assessed, as compound was not considered a COC in that medium. Inhalation Target Organ-Specific Hazard Index ROUX ASSOCIATES, INC. 1 of 1 PEM M /Att.F/TF-6

96 APPENDIX B Capillary Fringe Thickness Calculation ROUX ASSOCIATES, INC. PEM M /AP-CV

97 Capillary Fringe Thickness Calculation Peabody Essex Museum, Salem, MA Capillary Rise is calculated: h c = -0.03/eD 10 * where h c capillary rise in meters dimensionless coefficient (Terzaghi, 1996) e void ratio effective grain size, screen size (mm) with 10% passing D 10 * Terzaghi, K., Peck, R.B., and Mesri, G. (1996), Soil Mechanics in Engineering Practice, 3rd ed.wiley, New York Assuming conservatively that site soil (medium dense silt and sand) has 40% porosity e= v v /v s = 0.67 where v v volume of voids, 40% v s volume of solids, 100%-40% From boring GB-01 (14-16 ft): D 10 = mm capillary rise (m) h c = -0.03/eD 10 = -0.03/(0.67) x (0.0339) = 1.33 m = 4.36 ft porosity 40% void ratio 0.67 D mm rise (m) h c = -0.03/eD m 4.36 ft Calculated capillary rise at 40% porosity by effective grain size: D 10 mm US sieve m ft h c h c ROUX ASSOCIATES, INC. Page 1 of 2 PEM M /App.B

98 Capillary Fringe Thickness Calculation Peabody Essex Museum, Salem, MA D 10 mm US sieve m ft h c h c ROUX ASSOCIATES, INC. Page 2 of 2 PEM M /App.B

99 APPENDIX C BWSC Transmittal Forms ROUX ASSOCIATES, INC. PEM M /AP-CV

100

101

102

103

104

105

106

107 APPENDIX D Public Notification Letters ROUX ASSOCIATES, INC. PEM M /AP-CV

108 EN IRONMENTAI. CONSULTING & MANAGEMENT ROUX ASSOCIATES INC 67 South Bedford Sweet, Suite 101W Burlington, Massachusetts TEL FAX V66 February 28, 2012 Mr. David Greenbaum Acting Health Agent Board of Health 120 Washington Street, 4th Floor Salem, Massachusetts Re: Notice of Availability: Partial Response Action Outcome -17 Central Street RTN Peabody Essex Museum Site 161 Essex Street Salem, Massachusetts Dear Mr. Greenbaum: In accordance with the public notification requirements established by the Massachusetts Contingency Plan (310 CMR ) and on behalf of Peabody Essex Museum (PEM); Roux Associates, Inc. (Roux Associates) is notif~ ing you of the availability of a Partial Response Action Outcome (R.AO) for the 17 Central Street portion of the site located on 161 Essex St. in Salem, Massachusetts. The report summarizes remedial actions which have resulted in conditions which demonstrate No Significant Risk for the 17 Central Street portion of the site, which is located west and downgradient of the PEM property. This report contains a Partial Class A-2 Response Action Outcome Statement (RAO) for that portion of the Site. The referenced submittal is available for public review by contacting the Massachusetts Department of Environmental Protection Northeast Regional Office located at 205 Lowell Street, Wilmington, Massachusetts or through edep Online. You may request a free copy of the report by contacting Glen Gordon of Roux Associates at (781) Sincerely, ROUX ASSOCIATES, INC. Glen P. Gordon PE, LSP Principal Engineer cc: MassDEP, NERO Mr. R. Monk, PEM PEM M /App,D-t1

109 ENVIRONMENTAL CONSULTING & MANAGEMENT ROUX ASSOCIATES INC. 67 South Bedford Street, Suite 101W Burlington, Massachusetts TEL78I FkX February 28, 2012 Ms. Kimberly Driscoll Mayor 96 Washington Street Salem, Massachusetts Re: Notice of Availability: Partial Response Action Outcome -17 Central Street RTN Peabody Essex Museum Site 161 Essex Street Salem, Massachusetts Dear Ms. Driscoll: In accordance with the public notification requirements established by the Massachusetts Contingency Plan (310 CMR ) and on behalf of Peabody Essex Museum (PEM); Roux Associates, Inc. (Roux Associates) is noti~ing you of the availability of a Partial Response Action Outcome (R.AO) for the 17 Central Street portion of the site located on 161 Essex St. in Salem, Massachusetts. The report summarizes remedial actions which have resulted in conditions which demonstrate No Significant Risk for the 17 Central Street portion of the site, which is located west and downgradient of the PEM property. This report contains a Partial Class A-2 Response Action Outcome Statement (RAO) for that portion of the Site. The referenced submittal is available for public review by contacting the Massachusetts Department of Environmental Protection Northeast Regional Office located at 205 Lowell Street, Wilmington, Massachusetts or through edep Online. You may request a free copy of the report by contacting Glen Gordon of Roux Associates at (781) Sincerely, ROUX ASSOCIATES, INC. S len ordon PE, LSP Principal Engineer cc: MassDEP, NERO Mr. R. Monk, PEM PEM M002 lo7iapp.d.t2

110 ENVIRONMENTAL CONSULTING & MANAGEMENT ROUX ASSOCIATES INC 67 Souih Bedf&d Street Suite 101W Burlington, Massachusetts TEL FAX February 28, 2012 Mr. Peter Kitsokos Gemini Property Management 89 West Main St Merrimack, Massachusetts Re: Notice of Availability: Partial Response Action Outcome -17 Central Street The Residences at Museum Place 17 Central Street, Salem, Massachusetts RUN Dear Mr. Kitsokos: In accordance with the public notification requirements established by the Massachusetts Contingency Plan (310 CMR ) and on behalf of Peabody Essex Museum (PEM); Roux Associates, Inc. (Roux Associates) is noti{~ ing you of the availability of a Partial Response Action Outcome (RAO) for the 17 Central Street portion of the site located on 161 Essex St. in Salem, Massachusetts. The report summarizes remedial actions which have resulted in a Condition of No Significant Risk for unrestricted current and future uses of the 17 Central Street property portion of the site. This report contains a Partial Class A-2 Response Action Outcome Statement (RAO) for that portion of the Site. A copy of a map showing the extent of the Site and the area that the RAO applies and a copy of MassDEP form BWSC 122 are attached. The referenced submittal is available for public review by contacting the Massachusetts Department of Environmental Protection Northeast Regional Office located at 205 Lowell Street, Wilmington, Massachusetts or through edep Online. You may request a free copy of the report by contacting Mr. Robert Monk of the Peabody Essex Museum at (978) ext or the Site Licensed Site Professional (LSP) Mr. Glen Gordon of Roux Associates at (781) Sincerely, ROUX ASSOCIATES, INC. Glen P. Gordon PE, LSP Principal Engineer Attachments: Site Map Form BWSC 122 cc: MassDEP, NERO Mr. R. Monk, PEM PEM M002197L4pp.D.L3

111 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup INFORMATIONAL NOTICE TO PROPERTY OWNERS As Required by 310 CMR of the Massachusetts Contingency Plan (MCP) A. DISPOSAL SITE ADDRESS: (associated with Release Tracking Number provided above) 1. Street Address: 161 Essex Street Salem City/Town: 3. ZIP Code: BWSC122 This notice is related to: Release Tracking Number B. THIS NOTICE IS BEING PROVIDED TO THE FOLLOWING PROPERTY OWNER: 1. Name of Property Owner: a. Street Address: The Residences at Museum Place 2. Address of Property For Which This Notice is Being Provided Owned by Property Owner named in B1: 17 Central Street Salem b. City/Town: c. ZIP Code: C. THIS NOTICE IS BEING GIVEN : (check one) 1. Upon Completion of a Phase II Comprehensive Site Assessment. 2. Upon Submittal of a Response Action Outcome (i.e., Site Closure Report). 3. Upon Completion of Additional Investigation showing that Oil or Hazardous Material is not Present at the Property. D. DESCRIPTION OF OIL AND/OR HAZARDOUS MATERIAL PRESENT OR LIKELY TO BE PRESENT AT THE PROPERTY : (check all that apply) AFFECTED ENVIRONMENTAL MEDIA PRINCIPAL CHEMICAL(S) PRESENT 1. Soil Oil 2. Groundwater 3. Surface Water 4. Sediment 5. Indoor Air 6. Other: (specify) E. ATTACHMENTS PROVIDED WITH THIS NOTICE, AS REQUIRED BY 310 CMR : 1. A Copy of the Map Showing or a Description Describing the Area where the Oil and/or Hazardous is or is likely to be Present. 2. A Copy of the Phase II Completion Site Assessment or Response Action Outcome Conclusions. F. CONTACT INFORMATION RELATED TO THE PARTY PROVIDING THIS NOTICE: 1. Contact Name: 3. City/Town: 6. Telephone: Robert Monk 2. Street: 4. State: Essex Street Salem MA ZIP Code: x3149 robert_monk@pem.org Revised: 05/02/2006 Page 1 of 2

112 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup INFORMATIONAL NOTICE TO PROPERTY OWNERS As Required by 310 CMR of the Massachusetts Contingency Plan (MCP) BWSC122 This notice is related to: Release Tracking Number MASSACHUSETTS REGULATIONS THAT REQUIRE THIS NOTICE This notice is being provided pursuant to the Massachusetts Contingency Plan and the notification requirement at 310 CMR The Massachusetts Contingency Plan is a state regulation that specifies requirements for parties who are taking actions to address releases of chemicals (oil or hazardous material) to the environment. THE PERSON(S) PROVIDING THIS NOTICE This notice has been sent to you by the party(ies) who is/are addressing a release of oil or hazardous material to the environment at the location listed in Section A on the reverse side of this form. PURPOSE OF THIS NOTICE Parties who are taking actions to respond to releases of oil or hazardous material to the environment are required by state regulations (referred to above) to notify the owners of property where the oil or hazardous material is or is likely to be present. These same parties are also required to notify property owners upon completion of actions to address the oil or hazardous material, or if additional investigations show that the oil or hazardous material is not, as previously suspected, present at a property. Section C on the reverse side of this form indicates the circumstance under which you are receiving this notice at this time. INFORMATION RELATED TO YOUR PROPERTY Section D on the reverse side of this form indicates the type(s) of oil or hazardous material that is or is likely to be present at your property, and the environmental medium (e.g., soil or groundwater) where it is or is likely to be present. Please note when an investigation indicates that the oil or hazardous material is or is likely to be present at your property, this does not mean that the oil or hazardous material is posing a health risk to you. Parties who are taking actions to address oil and hazardous material releases are required by state regulations to adequately investigate these releases and take necessary actions to ensure that affected properties meet standards that are protective of human health and the environment. ATTACHED MAP OR DESCRIPTION AND REPORT CONCLUSIONS The party providing this notice to you is required to attach a map or description that indicates the boundaries of the area where the oil or hazardous material is or is likely to be present, and the conclusions of the site investigation or closure report (Section E). These attachments should give you additional information about the nature and location of the oil or hazardous material with respect to your property. FOR MORE INFORMATION Information about the general process for addressing releases of oil or hazardous material under the Massachusetts Contingency Plan and related public involvement opportunities may be found at For more information regarding this notice, you may contact the party listed in Section F on the reverse side of this form. Information about the disposal site identified in Section A is also available in files at the Massachusetts Department of Environmental Protection. See if you would like to make an appointment to see these files. Please reference the Release Tracking Number listed in the upper right hand corner on the reverse side of this form when making file review appointments Revised: 05/02/2006 Page 2 of 2