Prepared for: Prepared by: Ransom Consulting, Inc. 400 Commercial Street, Suite 404 Portland, Maine (207)

Transcription

1 ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVES & CONCEPTUAL REMEDIAL ACTION PLAN MASKER S THEATER & THOMPSON S WHARF 45 FRONT STREET (TAX MAP 11, LOT 136) BELFAST, MAINE Prepared for: City of Belfast, Maine 131 Church Street Belfast, Maine (Using U.S. EPA Brownfields Funding Under Belfast s Assessment Grant No. BF ) Prepared by: Ransom Consulting, Inc. 400 Commercial Street, Suite 404 Portland, Maine (207) Project R March 20, 2015

2 TABLE OF CONTENTS 1.0 INTRODUCTION AND BACKGROUND Purpose and Scope Site Description Surrounding Land Use Potential Future Site Use Site Geology Site Hydrology PREVIOUS ENVIRONMENTAL INVESTIGATIONS SITE CHARACTERIZATION AND CLEANUP GOALS Impacted Surficial and Subsurface Soils Impacted Soil Vapor Impacted Groundwater Asbestos-Containing Materials (ACM) Lead-Based Paint (LBP) Universal Waste DESCRIPTION OF EVALUATION CRITERIA Overall Protection of Human Health and the Environment Technical Practicality Ability to Implement Reduction of Toxicity, Mobility, and Volume Short Term Effectiveness Resiliency to Climate Change Conditions Preliminary Cost EVALUATION OF REMEDIATION ALTERNATIVES Considered Remediation Alternatives No Action Alternative Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan Alternative Overall Protection of Human Health and the Environment Technical Practicality Ability to Implement Reduction of Toxicity, Mobility and Volume Short Term Effectiveness Resiliency to Climate Change Conditions Preliminary Cost Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil Alternative Overall Protection of Human Health and the Environment Technical Practicality Ability to Implement Reduction of Toxicity, Mobility, and Volume Short Term Effectiveness Resiliency to Climate Change Conditions Preliminary Cost Selection of Proposed Remediation Alternative CONCEPTUAL REMEDIAL ACTION PLAN Soil Cover Systems... 19

3 6.2 Green Remediation Principals Maintenance Plan Deed Restriction Asbestos Abatement/Removal Lead-Based Paint Abatement Universal Waste Removal SITE CLOSURE AND REPORTING CONCLUSIONS AND RECOMMENDATIONS SIGNATURE(S) OF ENVIRONMENTAL PROFESSIONAL(S) TABLES Table 1: Table 2: Table 3: Summary of the Evaluation and Comparison of Remedial Alternatives Summary of Estimated Remediation Costs Full Abatement and Soil Cover System Alternative Summary of Estimated Remediation Costs Full Abatement & Soil Removal Alternative FIGURES Figure 1: Figure 2: Figure 3: Site Location Map Site Plan Soil Cover System Conceptual Schematic

4 1.0 INTRODUCTION AND BACKGROUND Ransom Consulting, Inc. (Ransom) has completed this Analysis of Brownfields Cleanup Alternatives (ABCA) to evaluate various remedial alternatives for the previously identified adverse environmental conditions throughout the Masker s Theater and Thompson s Wharf property located at 45 Front Street in the City of Belfast, Waldo County, Maine (the Site ). This report summarizes the evaluation of remedial alternatives for the Site and includes a discussion of each remedial option, a cost estimate, the degree of effectiveness, and the ease of implementation for each remedial alternative. This report also contains a discussion of the recommended remedial alternative for the Site, as well as a Conceptual Remedial Action Plan (RAP) for the selected alternative. 1.1 Purpose and Scope The purpose of this report is to screen potential remedial action alternatives to mitigate previously identified adverse environmental conditions associated with the Site. Based on the information obtained during previous environmental investigations (summarized in Sections 2.0 and 3.0), including Ransom s Phase I and Phase II Environmental Site Assessments (ESAs), three remediation options were considered for the Site and evaluated based on feasibility, effectiveness, cost, required time schedule, and ability to meet the overall cleanup goal (protection of human health and the environment). Key consideration was given to eliminating or reducing, to the extent possible, the risk of exposure for existing and potential future Site occupants, Site workers, and trespassers to the identified contamination at the Site. The overall objectives of this ABCA include the following: 1. Evaluating the remedial alternatives against specific evaluation criteria (Section 4.0), including: overall protection of human health and the environment; technical practicality; ability to implement; reduction of toxicity, mobility, and volume; time required until remedial action objectives are attained; and costs. 2. Selecting the remedial alternative that best meets the cleanup and redevelopment objectives and considerations of the project. 3. Presenting a work plan (RAP) for implementing the selected remedial alternative. Remediation alternatives evaluated in this ABCA include a No Action alternative, Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative, and Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative. Section 5.0, The Evaluation of Remediation Alternatives discusses the requirements for each alternative. The alternatives are evaluated on the previously mentioned criteria, and one alternative is recommended for implementation at the Site. Furthermore, a Conceptual RAP is presented in Section 6.0 for the recommended alternative. 1.2 Site Description The Site consists of an irregular-shaped parcel of land, encompassing approximately 1.45 acres, located along the northern side of Front Street, approximately 250 feet west of the intersection of Front Street and Main Street in the City of Belfast, Waldo County, Maine. The Site is identified by the City of Belfast Assessor s Office as Tax Map 11, Lot 136, which corresponds to 45 Front Street. Refer to the attached Site Location Map (Figure 1) to view the general location of the Site in the context of a 7.5-minute topographic quadrangle. Ransom Project Page 1

5 The Site is currently improved with two buildings, which are described herein, as the Masker s Theater and Storage Building and collectively identified as (the Site Buildings ) and a marina wharf along the harbor shoreline (Thompson s Wharf). The northern portion of the Site is bisected by a concrete-paved, Harbor Walk pedestrian walkway, which was constructed during the summer of 2013 and extends along the waterfront at the former location of the Belfast and Moosehead Lake Railroad (B&MLRR) tracks. Based on available information, the Site and surrounding properties along Front Street consisted of submerged and/or partially-submerged land of Belfast Harbor, prior to circa 1870, at which time the Site and adjoining properties were developed with the B&MLRR. During its development, portions of the Site and immediate vicinity were constructed of filled land and were also reportedly utilized as a solid waste dump during the late 1800s and early 1900s. The Masker s Theater building operated as the freight house for the B&MLRR, from circa 1870 until 1985, and the Storage Building was utilized as a locomotive house by B&MLRR, from its construction circa 1951 until B&MLRR vacated the Site in Several additional railroad-related structures have historically been present at the Site, including other locomotive houses, passenger station, loading docks, a railway turntable, coal sheds, and outbuildings, which were constructed and demolished at various dates ranging from circa 1870 to circa The Site was reportedly vacant from 1985 until The Masker s Theater building was utilized as a playhouse for the Belfast Maskers Theater troupe from 1994 to 2011 and the building has remained vacant to the present date. The Storage Building has reportedly been vacant since 1985, but is occasionally utilized for miscellaneous storage by the City of Belfast. The Masker s Theater building consists of three interconnected buildings that were constructed at various stages from circa 1870 to circa The building is a one and two-storied wooden structure, occupying an approximate footprint of 4,000 square feet constructed on concrete pilings with no basement. The Storage Building is a single-story, concrete-block, warehouse-type building that was constructed circa 1951 on a dirt floor with no basement. Both buildings are currently vacant and dilapidated. 1.3 Surrounding Land Use The Site is located in a mixed residential, commercial, and working waterfront area of Belfast. The Site is bounded by Front Street to the south, Passagassawakeag River (Belfast Harbor) to the northwest, commercial/restaurant properties to the east, and shipyard/marina properties to the northeast and west. 1.4 Potential Future Site Use The potential future use of the Site is not fully defined at this time, but it is proposed to be redeveloped for office, commercial, and/or residential uses (mixed-use). 1.5 Site Geology In general, soils encountered during Ransom s Phase II Investigation were relatively consistent throughout the Site. Surficial and subsurface soil samples contained fill, which consisted of brown to dark brown and black, fine to coarse sand with varying amounts of silt and gravel. Apparent urban fill materials, including coal and bricks were encountered in surficial and subsurface fill soils at the Site. Native glacial- and/or fluvial-deposited silt and fine sand were encountered beneath the fill soils at inconsistent depths ranging from 8 to 20 feet below ground surface (bgs). A small layer of black organic soils (less than 1 foot thick) was only encountered in soils at the northwestern portion of the Site near Belfast Harbor. Groundwater was encountered in the soil borings at approximate depths ranging from 7.63 to 8.87 feet bgs. Ransom Project Page 2

6 Trace to low-level organic vapors were detected in soil samples collected at the Site at concentrations ranging from 1 to 7.5 parts per million by volume (ppmv) during the Phase II investigation. Petroleumimpacted soils were only encountered near the southwestern portion of the Site at approximate depths ranging from 12 to 16 feet bgs, which was also near the location of petroleum-impacted soils reportedly encountered during the City of Belfast s municipal subsurface utility work at the Site in No evidence of petroleum-saturated soils or evidence of free petroleum product contamination was observed in groundwater encountered during the soil boring advancements or gauging of temporary groundwater monitoring wells at the Site during the Phase II investigation. 1.6 Site Hydrology Concurrent with the Phase II investigation, a relative groundwater elevation survey was conducted in order to evaluate the local groundwater flow direction at the Site. Groundwater was measured at depths ranging from 7.63 to 8.87 feet bgs in the monitoring wells. Coupled with depth to groundwater data, relative groundwater elevations were calculated at the Site. The data indicates a hydraulic gradient and associated interpreted groundwater flow direction to the north towards Belfast Harbor. Ransom Project Page 3

7 2.0 PREVIOUS ENVIRONMENTAL INVESTIGATIONS Phase I and II ESAs were prepared by Ransom in 2013 and are summarized below. In addition, previous environmental investigations/assessments including Maine Department of Environmental Protection (MEDEP) and United States Environmental Protection Agency (U.S. EPA) funded Brownfields environmental investigations and/or remedial activities have been performed at the northeastern adjoining property (Belfast Boatyard; Front Street) and at the western adjoining/contiguous properties (Front Street Shipyard; 101 Front Street [formerly B&MLRR, Consumer Fuels, and Stinson Cannery]). These previous environmental investigations and remedial activities performed at the adjoining properties have identified adverse environmental conditions, including localized impacts to soil, groundwater, and soil vapor with various polycyclic aromatic hydrocarbon (PAH) compounds, petroleum constituents, chlorinated solvents, and metals including lead and arsenic. These properties were submitted to the MEDEP Voluntary Response Action Program (VRAP) and have been investigated and/or remediated with prior MEDEP and/or USEPA oversight/guidance. Furthermore, contamination identified at these properties has been properly mitigated with institutional and/or engineering controls. Phase I Environmental Site Assessment: Masker s Theater & Thompson s Wharf, 45 Front Street (Tax Map 11, Lot 136), Belfast, Maine. Ransom Consulting, Inc., November 13, In November 2013, Ransom prepared a Phase I ESA for the Site. The Phase I ESA identified Recognized Environmental Conditions (RECs) in connection with the Site and vicinity s former uses, including a solid waste dump, bulk fuel facility, working waterfront activities, and railroad use. These historical uses have resulted in documented adverse impacts to soil, groundwater, and soil vapor in the Site vicinity. Based on the findings from the Phase I ESA, the entire Site was targeted for additional investigation through the completion of a Phase II ESA. Phase II Environmental Site Assessment: Masker s Theater & Thompson s Wharf, 45 Front Street (Tax Map 11, Lot 136), Belfast, Maine. Ransom Consulting, Inc., January 15, In December 2013, Ransom completed a Phase II ESA for the Site. Based on the results of Ransom s Phase II ESA program, surficial and subsurface soil samples contained urban fill materials, including coal and bricks and volatile organic compounds (VOCs), volatile petroleum hydrocarbon (VPH) fractions, extractable petroleum hydrocarbon (EPH) fractions, target PAHs, and metals. One PAH [benzo(a)pyrene] and one metal (arsenic) were detected in surficial soils [less than 2 feet below ground surface (bgs)] at the property at concentrations exceeding their respective MEDEP Remedial Action Guidelines (RAGs) for Residential exposure scenarios. No contaminants of concern were detected at concentrations exceeding their MEDEP RAGs for Excavation/Construction Worker exposure scenarios for subsurface soils (deeper than 2 feet bgs) at the Site. Several petroleum- and solvent-related compounds were also detected in soil vapor samples collected at the Site at concentrations exceeding their corresponding calculated MEDEP Soil Gas Targets for Residential exposure scenarios. Based on this information, it s likely that volatile petroleum- and/or solvent-related compounds in soil vapor at the Site may present a potential vapor intrusion risk to future occupied buildings at the Site. No adverse impacts to Site groundwater were identified during the Phase II ESA; however, anecdotal evidence provided by the City of Belfast suggests that groundwater may be impacted with petroleum constituents in the vicinity of subsurface utilities at the property. Ransom Project Page 4

8 Hazardous Materials Inventory: Masker s Theater & Thompson s Wharf, 45 Front Street (Tax Map 11, Lot 136), Belfast, Maine. Ransom Consulting, Inc., January 15, Ransom also completed a Hazardous Building Materials Inventory (HMI) in December The HMI was conducted to address potentially hazardous materials observed during the Phase I ESA. The HMI identified that various hazardous building materials were prevalent throughout the Site buildings, including asbestos-containing materials (ACM), lead-based paint (LBP), components containing polychlorinated biphenyls (PCBs) or mercury, and other universal wastes. Building materials containing asbestos at concentrations greater than one percent were identified in several areas of the Site buildings and primarily included roofing materials and window caulk. The HMI included an inspection for the presence of LBP using a direct-reading x-ray fluorescence (XRF) analyzer. According to the XRF testing, several painted surfaces throughout the Site buildings were found to contain elevated levels of lead, significantly greater than 1.0 mg/cm 2, which are considered lead-based according to the U.S. Housing and Urban Development (HUD) Lead-Based Paint Guidelines. Electrical ballasts associated with fluorescent lighting fixtures, as observed throughout the Site buildings, can potentially contain PCBs in their dielectric fluid. In addition, five thermostats of the type typically utilizing mercury switches were also identified during the HMI. In accordance with local, State, and Federal laws and regulations, these hazardous building materials are required to be abated, removed, and properly disposed of off-site, prior to or during proposed demolition and redevelopment activities at the Site. Ransom Project Page 5

9 3.0 SITE CHARACTERIZATION AND CLEANUP GOALS Previous environmental investigations completed at the Site identified residual environmental contamination associated with historic Site operations. The identified contamination and appropriate cleanup goals are summarized below. Hazardous building materials, including asbestos-containing materials, lead-based paint, and universal wastes, were identified at the Site. The location, quantity, and nature of hazardous building materials and the site-specific abatement goals are addressed below. 3.1 Impacted Surficial and Subsurface Soils Currently accessible surface and subsurface soils were identified throughout the Site to contain low-levels of petroleum and solvent VOCs, VPH and EPH fractions, and target PAHs. These contaminants were detected at concentrations below their respective MEDEP RAGs for Residential, Outdoor Commercial Worker, and Excavation/Construction Worker exposure scenarios, with the exception of one PAH [benzo(a)pyrene]. The detected concentration of benzo(a)pyrene in two surface soil samples exceeded its MEDEP RAG Residential exposure scenario; however, the concentrations of benzo(a)pyrene did not exceed its respective background concentration detected in surficial soils at properties along Front Street. The presence of these low-level VOCs, VPH fractions, EPH fractions, and target PAHs detected in surficial and subsurface soils at the Site are likely associated with the identified urban fill from former railroad and/or town solid waste dumping operations at the Site and/or associated with the Site s current use as a parking lot including de minimis petroleum- and solvent-related residues, incidental to the normal operation of motor vehicles. Metals (specifically, arsenic, cadmium, chromium, and lead) were also detected in surficial and subsurface soil samples collected at the Site at concentrations below their respective MEDEP RAGs for Residential, Excavation/Construction Worker, or Outdoor Commercial Worker exposure scenarios, with the exception of arsenic detected in several surficial soil samples. The arsenic concentrations detected in surficial soils exceed its corresponding MEDEP RAG Residential exposure scenario; however, the concentrations were consistent with Site-specific and area-wide background concentrations detected during this investigation at other properties along the Front Street and also did not exceed its Undeveloped Background MEDEP RAG. Based on this information, it is inferred that the concentrations of these metals (specifically, arsenic, cadmium, chromium, and lead) detected in surficial and subsurface soils at the Site are likely representative of either naturally-occurring metals concentrations in Maine soils or urban fill resulting from coal and/or wood combustion byproducts, solid waste disposal, or residues from former railroad operations at the Site. The potential future use of the Site is not fully defined at this time, but it is proposed to be redeveloped for office, commercial, and/or residential uses (mixed-use). As such, the cleanup goal for the Site is to eliminate or reduce the risk of human contact to the contaminated surface soils throughout the Site that are impacted by arsenic and benzo(a)pyrene. Soil removal or installation of a barrier over the contaminated soils, such as an engineered cover system, could potentially eliminate human exposure through direct contact, ingestion, or inhalation. Depending on the selected remedial alternative, the deed restriction will also require proper maintenance of any cover system and prohibit excavation activities at the Site to protect future excavation/construction workers, without prior notification and approval of the MEDEP. Ransom Project Page 6

10 3.2 Impacted Soil Vapor Several petroleum- and solvent-related compounds were also detected in soil vapor samples collected at the Site. One air-phase petroleum hydrocarbon (APH) compound (naphthalene) and the VPH C 9 C 10 aromatic fraction were detected in the soil vapor samples at concentrations exceeding their corresponding calculated MEDEP Soil Gas Targets for Residential exposure scenarios; no target contaminants were detected in the soil vapor samples at concentrations exceeding their corresponding calculated Soil Gas Targets for Commercial exposure scenarios. Based on this information, vapor mitigation activities are not warranted for the existing Masker s Theater and Storage Building or nearby utility corridors. The Masker s Theater is positioned approximately 2 feet above the ground surface on pilings, which promotes sufficient ambient air flow beneath the building and likely mitigates the potential for vapor intrusion into the building. The Storage Building is not an occupied space and is only utilized for miscellaneous storage purposes. Vapor migration in utility corridors within the Site vicinity are also not likely an significant concern or risk, since the low levels of petroleum compounds will likely degrade before affecting on-site and/or offsite buildings. However, it s likely that the volatile petroleum- and/or solvent-related compounds in soil vapor at the Site may present a potential vapor intrusion risk to future occupied buildings that may be constructed with a full or partial basement and/or slab on grade foundation system at the Site. Vapor mitigation systems are similar to and/or analogous to radon mitigation systems and are relatively easy to install and incorporate into the design of new building foundations. 3.3 Impacted Groundwater No evidence of free petroleum product contamination was observed in groundwater during the soil boring advancements or collection of groundwater samples at the Site. Furthermore, no contaminants of concern were detected in groundwater samples collected at the Site at concentrations above their respective laboratory detection limits. Therefore, no remedial activities to mitigate impacted groundwater are proposed or recommended at this time. However, it is recommended that a deed restriction be imposed on the property restricting the extraction of groundwater, without prior notification and approval of the MEDEP, as a protective measure in case impacted groundwater is discovered at the Site during future redevelopment and/or subsurface utility activities. 3.4 Asbestos-Containing Materials (ACM) Based on the findings of our HMI, the following asbestos-containing building materials have been identified at the Site: 1. Window glaze- Storage Building; 2. Asphalt roof membrane- Masker s Theater- upper roof; 3. Built-up roofing- Masker s Theater main roof and upper roof; 4. Flashing sealant- Masker s Theater main roof and upper roof; 5. Asphalt rolled roofing- Masker s Theater addition roof; and 6. Rolled roofing sealant- Masker s Theater addition roof. Ransom Project Page 7

11 The cleanup goal for the Site pertaining to the ACM is to eliminate the risk of human contact to ACM during renovation or demolition activities and future Site reuse. Cleanup actions including removal and/or long-term maintenance of ACM should be completed to meet US EPA and MEDEP regulatory requirements and to eliminate human exposure through inhalation. 3.5 Lead-Based Paint (LBP) As part of the HMI, Ransom also conducted an inspection for the presence of LBP, using a direct-reading XRF analyzer manufactured by Innov-X. The inspection included XRF readings collected from walls, windows, doors, casings/jambs, and other miscellaneous surfaces on a variety of substrates including wood, metal, concrete, and drywall. Lead was detected on exterior painted surfaces of the Storage Building and Masker s Theater and interior first floor columns in the Masker s Theater building. Handling of components coated with leadcontaining paint at any concentration requires compliance with the Occupational Safety and Health Administration (OSHA) lead standard (Lead in Construction, 29 CFR ). Under the existing conditions, facility maintenance staff or contractors may perform demolition, renovation, abatement, stabilization, cleanup, and daily operations in buildings that have lead-based paint or lead-containing paint, provided that this regulatory requirement is met. Cleanup/abatement activities, such as lead removal and/or encapsulation, should be completed to meet OSHA, MEDEP, and U.S. EPA regulatory requirements, and to eliminate lead-contaminated dust exposure to contractors and the general public if the Site Buildings are to remain and renovated for future use. Since the Site Buildings are proposed to be either demolished or relocated and renovated, the cleanup goal for the Site pertaining to the LBP is to eliminate the risk of human contact to lead during proposed demolition and/or restoration activities and future Site reuse. Lead waste, including LBP waste in construction and demolition (C&D) debris, with the exception of household waste, may be subject to the hazardous waste requirements of the U.S. EPA s Resource Conservation and Recovery Act (RCRA) and Maine s Hazardous Waste Regulations. To determine the required method for the disposal of items that are coated with LBP and are not household waste, the U.S. EPA and the MEDEP require representative sampling of the debris to determine the quantity of lead that would be expected to leach into the environment if the debris were disposed of in a landfill. The representative sample(s) must be analyzed by Toxicity Characteristic Leaching Procedure (TCLP). If concentrations are 5 milligrams per liter (mg/l) or greater, the debris must be disposed of as hazardous waste. If concentrations are less than 5 mg/l, the debris is not regulated and materials may be disposed of as general construction debris. To minimize the total volume of hazardous waste (if present), segregating hazardous from non-hazardous waste is advisable. 3.6 Universal Waste Universal waste is a general term used to describe hazardous wastes that are generated by a large, diverse population. Businesses as well as unregulated households generate universal waste. This term is intended to be broad so that a wider range of wastes may be managed under the reduced requirements of the U.S. EPA s Universal Waste Rule. Ransom Project Page 8

12 U.S. EPA's universal waste regulations streamline hazardous waste management standards for federally designated "universal wastes," which include: 1. Batteries; 2. Pesticides; 3. Mercury-containing equipment; and 4. Bulbs (lamps). The State of Maine has expanded the designation of universal waste to include, in addition to those items listed above, automobile mercury switches and totally enclosed non-leaking PCB containing ballasts. The regulations govern the collection and management of these widely generated wastes, thus facilitating environmentally sound collection and proper recycling or treatment. Universal wastes present at the Site include, but are not limited to, fluorescent light bulbs and compact fluorescent lamps containing mercury, thermostat switches of the type observed on-site which may also contain mercury, and presumed fluorescent light ballasts. The clean-up goal for universal waste is to prevent these wastes from entering the general waste stream through proper removal, storage, and transport to an appropriate off-site recycling or disposal facility as universal waste. Ransom Project Page 9

13 4.0 DESCRIPTION OF EVALUATION CRITERIA The comparison of the remediation alternatives was conducted using the evaluation and threshold criteria discussed below. 4.1 Overall Protection of Human Health and the Environment Alternatives must pass this threshold criterion to be considered for implementation as the recommended alternative. The goal of this criterion is to determine whether a remediation alternative provides adequate protection of human health and the environment. It also addresses how identified risks are eliminated, reduced, or controlled. Protection of human health is assessed by evaluating how site risks from each exposure route are eliminated, reduced, or controlled through the specific alternative. 4.2 Technical Practicality The focus of this evaluation criterion is to determine technical practicality of instituting the specific alternative. This criterion evaluates the likelihood that the alternative will meet project specifications. 4.3 Ability to Implement This criterion analyzes technical feasibility and the availability of services and materials. Technical feasibility assesses the ability to implement and monitor the effectiveness of the alternative. Availability of services and materials evaluates the need for off-site treatment, storage or disposal services and the availability of such services. Necessary equipment, specialists and additional resources are also evaluated. 4.4 Reduction of Toxicity, Mobility, and Volume This criterion evaluates the ability of the remediation alternative to significantly achieve reduction of the toxicity, mobility, and volume of the hazardous substances present at the Site. This analysis evaluates the quantity of hazardous substances and/or petroleum-impacted media to be removed, the degree of expected reduction in toxicity, the type and quantity of residuals to be reduced, and the manner in which the principle threat is addressed through the remediation alternative. 4.5 Short Term Effectiveness This criterion addresses the period of time needed to complete the remediation, potential adverse impacts on human health and the environment that may exist until the clean up goals are achieved, and the time frame for accomplishing the associated reduction in the identified environmental conditions. 4.6 Resiliency to Climate Change Conditions This criterion evaluates the resilience of the remediation alternative to reasonably foreseeable changing climate conditions, such as: increasing/decreasing temperatures; increasing/decreasing precipitation; extreme weather events; rising sea level; changing flood zones; and higher/lower groundwater tables, among others. Ransom Project Page 10

14 4.7 Preliminary Cost The preliminary cost criterion for the remediation alternatives evaluates the estimated capital, operation, and maintenance costs of each alternative. Capital costs include direct capital costs, such as materials and equipment, and indirect capital costs, such as engineering, sampling contingencies, and licenses. Costs were developed as a balancing criterion for the remedial alternatives and should not be construed as bid costs or engineer s cost estimates. Cost may be used as a distinguishing factor in the selection of the remedial action. The preliminary costs developed should in no way be construed as a cost proposal, but rather a guide for selecting a remedial action. Ransom Project Page 11

15 5.0 EVALUATION OF REMEDIATION ALTERNATIVES Based on the evaluation criteria outlined in the previous section and the potential exposure pathways identified for the Site, the remedial actions selected for the Site should accomplish the following objectives: 1. Minimize the potential for direct contact, incidental ingestion, or inhalation of contaminated surficial and subsurface soils located throughout the Site; 2. Minimize the potential for inhalation of petroleum-impacted soil vapor detected on the Site; and 3. Minimize the potential for human exposure to hazardous building materials; and 4. Reduce the toxicity, mobility, and volume of hazardous building materials. To achieve these objectives, three remedial options were considered and are discussed in the following subsections. 5.1 Considered Remediation Alternatives Three remedial alternatives were considered for the Site, including the No Action alternative, Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative, and Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative. These alternatives were evaluated using the criteria described in Section 4.0 and are summarized below. The attached Table 1 includes a Summary of the Evaluation and Comparison of the Remedial Alternatives. In addition to the soil remediation activities associated with the Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative and Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative discussed below, the following additional remedial activities are proposed at the Site in conjunction with the selected alternative to address known impacted soil and soil vapor and potential impacted groundwater at the Site: 1. A deed restriction and/or institutional controls in the form of a Declaration of Environmental Covenant (DEC). As part of the DEC, on-site groundwater extraction would be prohibited and a Post-Closure Cover System Maintenance and Soil Management Plan would be developed in order to insure proper characterization, handling, and management of contaminated soils, which may be encountered and displaced during redevelopment of the Site property (e.g., displaced and/or excess soils generated during installation of new foundations/utilities may require on-site management and/or off-site disposal); and 2. Installation of a vapor mitigation system is recommended to be incorporated into the design of any new proposed Site structures in order to mitigate potential impacts to indoor air quality from potential vapor intrusion of volatile compounds identified in soil vapor samples collected at the Site. Vapor mitigation systems are similar and/or analogous to radon mitigation systems and are relatively easy to install and incorporate into the design of new building foundations. Ransom Project Page 12

16 5.2 No Action Alternative A No Action alternative signifies that no further remediation activities would be conducted at the Site. The No Action alternative does not include a means for mitigating exposure to identified adverse environmental conditions or unacceptable risks remaining from contaminated soils, soil vapor, and hazardous building materials; therefore, the potential for human exposure through direct contact, ingestion, and/or inhalation continues to exist for current trespassers and potential future Site occupants, workers, or trespassers. The No Action alternative is not protective of human health and the environment and does not meet the threshold criteria. The No Action alternative would not achieve reduction of the toxicity, mobility, and volume of the hazardous substances present at the Site. In addition, the No Action alternative would not be an effective remediation alternative, and potential impacts to human health would remain at the Site. The No Action alternative was not selected for implementation or further consideration because the contaminated soils, soil vapor, and hazardous building materials would continue to pose a health risk to existing trespassers and future Site occupants, workers, and trespassers. 5.3 Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan Alternative The second remediation alternative evaluated in this ABCA is the Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative. This alternative involves mitigating the potential for human exposure through direct contact, ingestion, and inhalation through the abatement and removal of the identified hazardous building materials in accordance to State and Federal regulations and installation of cover systems and a Post-Closure Cover System Maintenance and Soil Management Plan to mitigate contaminated surficial soils identified at the Site. Although this alternative primarily includes the implementation of on-site cover systems for impacted soils, limited removal of impacted soils may also be conducted through excavation and off-site disposal of soils that may be generated and/or displaced (i.e., excess soils) during installation of new foundations/utilities at the Site. As part of this alternative, each area where ACM and universal wastes is located is anticipated to be affected by the proposed demolition. Current federal and state regulations require the removal of friable (easily reduced to powder using hand pressure) ACM and the removal of universal wastes, prior to conducting renovation or demolition activities that impact these areas. To meet these federal and state regulations, the identified ACM and other identified universal wastes at the Site will be completely removed, and therefore, encapsulation and maintenance is not an option for asbestos or universal wastes. Due to both interior and exterior lead-based paint identified in the Site Buildings, this alternative includes the full removal and off-site disposal of all lead-based paint at the Site. In accordance with state and federal regulations, the lead content of the building materials with identified lead-based paint will be tested prior to off-site disposal. If concentrations are less than the hazardous level for lead-based paint waste, the materials may be disposed of as general construction debris. To minimize the total volume of hazardous waste (if present), segregating hazardous from non-hazardous waste will be conducted. Additional remedial activities are proposed to be conducted at the Site in conjunction with this alternative. An institutional control (deed restriction) would need to be recorded on the deed to indicate the need for a Post-Closure Cover System Maintenance and Soil Management Plan for the Site in order to prevent future Ransom Project Page 13

17 exposure to contaminated soil, unless these materials are removed and properly disposed of in the future. The Post-Closure Cover System Maintenance and Soil Management Plan would insure proper characterization, handling, and management of contaminated soils, which may be encountered and displaced during redevelopment of the Site property (e.g., displaced and/or excess soils generated during installation of new foundations/utilities may require on-site management and/or off-site disposal). The deed restriction would also prohibit the extraction of Site groundwater in order to safeguard the public and subsurface utility workers from exposure to potential contaminated groundwater. In addition, a vapor mitigation system should be installed in conjunction with the construction of any future building at the Site, which will minimize the risk of exposure to impacted soil vapor (through vapor intrusion into any future building) to future inhabitants or workers at the Site. The evaluation of this second alternative is discussed below Overall Protection of Human Health and the Environment This alternative provides adequate protection of human health and the environment through eliminating the risk of human exposure to the hazardous building materials and reducing or eliminating the risk to impacted soils outlined in this alternative, including the limited removal of impacted surficial soils and the installation of a cover system over the remaining impacted soils. Soil cover systems would be installed over soils remaining at the Site after redevelopment earthwork activities are completed. Soil cover can be in the form of a graveled or grass/landscaped area (with a geotextile fabric marker layer and a minimum of 12 inches of clean compacted soil), a paved parking lot or driveway area, concrete (such as a building floor or walkway/sidewalk), or a rip rap cover. Figure 3 presents a conceptual schematic of the various types of potential cover systems that could be installed at the Site. In addition, limited removal of impacted soils may also be conducted through excavation and off-site disposal of contaminated soils that may be generated and/or displaced (i.e., excess soils) during installation of new foundations/utilities at the Site. Implementation of institutional controls including a deed restriction and declaration of environmental covenant to prohibit groundwater extraction and preparation of a Post-Closure Cover System Maintenance and Soil Management Plan will be required in order to prevent future exposure to potential contaminated groundwater and identified contaminated soil remaining at the Site. Installation of a vapor mitigation system in conjunction with the construction of any future building will minimize the risk of exposure to impacted soil vapor (through vapor intrusion into any future building) to future inhabitants of the Site Technical Practicality Completing the remedial actions for this alternative is technically practical. The removal of hazardous building materials, limited removal of displaced impacted soil, and installation of soil cover systems could be completed utilizing accepted construction techniques. Both contractors and disposal facilities with experience with similar projects are readily available in the region. The goal of reducing or eliminating the risk of human exposure to hazardous building materials and impacted soils could be achieved through the removal and off-site disposal of the hazardous building materials, limited removal of displaced impacted soils, and installation of soil cover systems over remaining soils during Site redevelopment. Ransom Project Page 14

18 5.3.3 Ability to Implement Removal and off-site disposal of the hazardous building materials and accessible impacted soils at the Site and installation of soil cover systems is technically feasible and is an effective action for reducing or eliminating the risk of human exposure. Services and materials necessary to conduct this alternative are readily available Reduction of Toxicity, Mobility and Volume This remediation alternative can significantly achieve reduction of the toxicity, mobility, and volume of the hazardous building materials and impacted soils at the Site. Removal of the hazardous building materials and contaminated soils and installation of soil cover systems would eliminate the risk of direct contact by existing trespassers and potential future site occupants, workers, and trespassers Short Term Effectiveness The remedial action objective could be attained when the hazardous building materials and displaced (i.e., excess) impacted soils are removed and soil cover systems are installed over remaining impacted soils at the Site. Potential adverse impacts to human health from exposure to the accessible hazardous building materials and contaminated soils may exist until the clean up goals are achieved Resiliency to Climate Change Conditions Due to the nearby Belfast Harbor and Passagassawakeag River, which provide hydraulic breaks in the volume and elevation of harbor and river flows near the Site, climate change effects from rising sea level and changing flood zones are not anticipated to represent a major threat. Based on the Federal Emergency Management Agency s (FEMA s) preliminary changes to their Flood Insurance Program Map (Community Panel Number B), the 100-year flood zone at the Site and vicinity is proposed to be moved approximately 150 feet closer to Belfast Harbor and the Passagassawakeag River. Therefore, most of the Site, including the proposed new buildings, will be located outside of the 100-year flood zone. As such, the primary climate change concerns would be associated with extreme weather, increased rainfall, and rising groundwater tables. This remedial alternative meets the objectives associated with this criterion by capping impacted soils, which may come into contact with rain/stormwater; however, the cover/cap system will shed or redirect stormwater run-on and minimize infiltration within the impacted areas. Because impacted soils may remain onsite, rising groundwater tables have the potential to come into contact with impacted soils; however, the contaminants of concern are not expected to be significantly leachable, thus reducing potential groundwater impacts Preliminary Cost The estimated costs associated with this remedial alternative are outlined in the attached Table 2 - Summary of Estimated Remediation Costs Full Abatement and Soil Cover System Alternative. Capital costs include direct capital costs, such as materials and equipment, and indirect capital costs, such as engineering and sampling contingencies. For the purposes of this evaluation, Ransom Project Page 15

19 Ransom assumed that hazardous building materials would be properly removed during proposed building demolition and/or renovation, limited removal of excess impacted soils throughout the Site would be conducted during Site redevelopment activities, and a cover system would subsequently be installed over the remaining impacted soils at the Site. The costs associated with this alternative are not prohibitive. 5.4 Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil Alternative The third remediation alternative evaluated in this ABCA is the Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative. This alternative involves mitigating the potential for human exposure through direct contact, ingestion, and inhalation through the abatement and removal of the identified hazardous building materials in accordance to State and Federal regulations. This alternative also involves mitigating the potential for human exposure through the excavation and off-site disposal of impacted soils. Based on the results of the Phase II ESA, unacceptable exposure risks to future residential occupants were identified due to exposures to arsenic and benzo(a)pyrene in surficial soils (0-2 feet bgs) throughout the Site. As part of this alternative, contaminated soil throughout the Site would be excavated to a depth (estimated to be approximately 2 feet bgs) in order to eliminate the risk to future residents. Based on the size of the Site [approximately 1.45 acres (approximately 65,000 square feet)] and an estimated excavation depth of 2 feet, it is anticipated that approximately 5,700 cubic yards of contaminated soil would be removed and properly disposed off-site for this alternative. Once excavation activities are completed, the top 2 feet throughout the Site would be backfilled with clean fill and topsoil materials, based on the redevelopment scenarios for the specific areas. This Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative fulfills the evaluation criteria, as discussed below Overall Protection of Human Health and the Environment This alternative provides adequate protection of human health and the environment through eliminating the risk of human exposure to the hazardous building materials and eliminating the risk of human exposure to the identified accessible contaminated soil identified at the Site through excavation and off-site disposal of impacted soils Technical Practicality Completing the remedial actions for this alternative is technically practical. The removal of hazardous building materials and removal of impacted soil could be completed utilizing accepted construction techniques. Both contractors and disposal facilities with experience with similar projects are readily available in the region. The goal of eliminating the risk of human exposure to hazardous building materials and impacted soils could be achieved through the removal and offsite disposal of the hazardous building materials and impacted soils during Site redevelopment Ability to Implement Removal and off-site disposal of the hazardous building materials and removing contaminated soil to a depth of two feet bgs throughout the Site is technically feasible and is an effective action Ransom Project Page 16

20 for eliminating the risk of human exposure. The necessary services and materials to complete the remedial tasks are readily available, including the necessary equipment and contractors Reduction of Toxicity, Mobility, and Volume This remediation alternative can significantly achieve reduction of the toxicity, mobility, and volume of the hazardous building materials and impacted soils at the Site. Removal of the hazardous building materials and contaminated soils to a depth of 2 feet bgs would eliminate the risk of direct contact by existing trespassers and potential future site occupants, workers, and trespassers Short Term Effectiveness The remedial action objective could be attained when the hazardous building materials and top 2 feet of contaminated soils are removed throughout the Site. Potential adverse impacts to human health from exposure to the accessible hazardous building materials and contaminated soils may exist until the cleanup goals are achieved Resiliency to Climate Change Conditions Due to the nearby Belfast Harbor and Passagassawakeag River, which provide hydraulic breaks in the volume and elevation of harbor and river flows near the Site, climate change effects from rising sea level and changing flood zones are not anticipated to represent a major threat. In addition, most of the Site will be located outside of the 100-year flood zone, based on FEMA s new flood zone maps. As such, the primary climate change concerns would be associated with extreme weather, increased rainfall, and rising groundwater tables. This remedial alternative meets the objectives associated with this criterion by removing impacted soils, which may come into contact with the groundwater table and with rain/stormwater Preliminary Cost The estimated costs associated with this remedial alternative are outlined in the attached Table 3 - Summary of Estimated Remediation Costs Full Abatement and Soil Removal Alternative. Capital costs include direct capital costs, such as materials and equipment, and indirect capital costs, such as engineering and sampling contingencies. For the purposes of this evaluation, Ransom assumed that hazardous building materials would be properly removed during proposed building demolition and/or renovation, the removal of contaminated soil to a depth of two feet bgs throughout the Site, and backfilled with clean fill and topsoil materials. Given the amount of soil that would be removed and disposed off-site as part of this alternative and the associated confirmatory sampling and waste disposal characterization necessary, the implementation of this alternative is cost-prohibitive. Because of this, the Full Abatement/Removal of Hazardous Building Materials and Contaminated Soil alternative was not selected for implementation at the Site. 5.5 Selection of Proposed Remediation Alternative Based on the results of the initial screening of each alternative as shown on Table 1 and discussed above, the Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative has been selected as the preferred remediation alternative. This alternative is proven to protect Ransom Project Page 17

21 human health and the environment and is effective, technically feasible, and practical. As part of this alternative, a deed restriction will be established for the Site to: 1. Notify future Site owners and occupants of the existence of residual soil contamination throughout the Site and the need for a Post-Closure Cover System Maintenance and Soil Management Plan for the Site in order to prevent future exposure to contaminated soil, unless these materials are removed and properly disposed of in the future; and 2. Prohibit the extraction of groundwater. In addition, installation of a vapor mitigation system in any future building constructed at the Site is recommended to reduce the potential for exposure to impacted soil vapor through vapor intrusion. Ransom Project Page 18

22 6.0 CONCEPTUAL REMEDIAL ACTION PLAN The Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative protects human health and the environment and is effective, technically feasible, and practical. Because this alternative meets the evaluation criteria and is not cost-prohibitive, this alternative has been selected for implementation at the Site. Although currently undetermined or unknown at this time, the City proposes to either demolish or relocate the existing site building to another property in order to make way for new site development, depending on cost/benefit and/or preservation considerations. Following building demolition or relocation and based on the general intended future use of the Site for proposed office, commercial, and/or residential uses (mixed-use), the final cleanup goal for the Site is to eliminate the risk of human exposure to the surface soils located throughout the Site that are contaminated with arsenic and benzo(a)pyrene at concentrations exceeding their corresponding MEDEP RAGs for Residential, Excavation/Construction Worker, and/or Outdoor Commercial Worker exposure scenarios. Limited removal of impacted soils will be conducted through excavation and off-site disposal of soils that may be generated and/or displaced (i.e., excess soils) during installation of new foundations/utilities at the Site. Soil removal activities will be conducted by a qualified contractor according to local, state, and federal regulations. Contaminated soil will be characterized by means of a toxicity characteristic leaching procedure to determine classification as Special or Hazardous waste, and will be transported from the Site to an approved facility under a bill of lading. 6.1 Soil Cover Systems Soil cover systems would be installed over soils remaining at the Site after redevelopment earthwork activities are completed. Figure 3 presents a conceptual schematic of the various types of potential cover systems that may be used to accommodate future Site redevelopment plan. Soil cover can be in the form of a graveled or loam landscaped area (with a geotextile fabric marker layer and a minimum of 12 inches of clean compacted soil), a paved parking lot or driveway area, concrete (such as a building floor or foundation), which are further discussed below. Gravel or Loam Landscaped Cover Systems: gravel or loam cover systems may be incorporated into proposed landscaping plans. Areas utilizing a loam or gravel cover will be underlain with a marker layer indicating the extent of clean materials. A minimum of 6 inches of clean, compacted fill will be placed in these areas over a geotextile fabric marker layer. The clean, compacted fill will be topped with a minimum of 6 inches of loam that will be seeded or planted according to the redevelopment landscape plans. The gravel or loam cover system thickness will total a minimum of 12 inches. Asphalt or Concrete Pavement Parking, Driveway, and Sidewalk Areas: Paved parking, driveway, and sidewalk areas that may be constructed as part of the redevelopment of the Site will act as covers over contaminated soil in these areas. Parking, driveway, and sidewalk area cover systems will include a minimum of 6 inches of clean compacted structural soils (gravel sub-base materials) necessary for the structural integrity of the parking and driveway areas. Concrete will be placed in one layer and asphalt pavement will be placed in two layers, including a minimum of 2 inches of a pavement binder layer and a minimum of 1 inch of a finish pavement layer. Building Floor and Foundations: Constructed building floors and foundations, generally in the form of an eight-inch or greater concrete slab, may act as a cover over any impacted soils remaining on-site located underneath the building. Ransom Project Page 19

23 6.2 Green Remediation Principals The soil cover systems, which will be installed over contaminated soils at the Site, will be implemented in accordance with the U.S. EPA s Clean and Greener Policy for Contaminated Sites, Revised February 2012 (Green Remediation Principals). As much as feasible, the cleanup contractor will use well maintained, appropriate-sized machinery, which may reduce fuel consumption and emissions. Additionally, recycled cover materials may be incorporated into the final design, which would conserve resources. Any area of the cover system which is specified to be seeded, will be done with a seed mixture which is appropriately zoned for the central or Mid-Coast (Down-East) Maine climate, and if feasible, one which requires less water than a typical seed mixture. The cleanup will be conducted in a manner which is ultimately protective of the air (via dust control and minimizing equipment emissions), adjacent water bodies (through stringent erosion and sedimentation control measures), and human receptors (via physical barriers and restrictions to prevent human contact with the impacted areas. 6.3 Maintenance Plan As part of the deed restriction to be filed following the construction of the soil cover system, a maintenance plan will be prepared for the long-term maintenance of any cover system installed at the Site. The maintenance plan will establish routine inspection procedures and requirements for the repair and/or reconstruction of the cover systems, as necessary, to maintain the physical barriers and mitigate contact with impacted soils remaining at the Site. 6.4 Deed Restriction A deed restriction will be established for the Site which will: 1. Notify future Site owners and occupants of the existence and location of residual soil contamination at the Site; 2. Prohibit the extraction of groundwater; 3. Prohibit excavation activities within the cover systems without prior MEDEP notification and approval; and 4. Require long-term maintenance of the cover systems. 6.5 Asbestos Abatement/Removal Asbestos fibers present potential health hazards when they become airborne. ACM may be managed inplace as long as it remains intact, undamaged, and in good condition. Current regulations require that asbestos-containing building materials be removed if they will be disturbed by renovation, demolition, or other building maintenance activities. Since the Site Buildings are proposed to be either demolished or relocated and renovated, ACM identified within interior and exterior portions of these buildings will be impacted by the proposed demolition or renovation activities and will require removal prior to the initiation of these activities. ACM abatement should be performed using approved methods in accordance with applicable regulations established by the U.S. EPA, OSHA, and the State of Maine. ACM will be removed by a licensed asbestos abatement contractor and in accordance with a project design prepared by a certified Abatement Project Designer. Ransom Project Page 20

24 Key elements of any asbestos abatement include the following: 1. Notification: A notification is required to be filed prior to any removal repair, demolition, enclosure, encapsulation, or handling of more than three linear or square feet of an asbestos-containing material with the exception of demolition of single family owner-occupied residential dwellings. This notification requirement designed to provide the MEDEP with adequate information to effectively schedule compliance inspections. The notification must be postmarked at least 10 calendar days, or received by the ME DEP at least 5 working days, prior to commencement of the asbestos abatement project. The start date on the notification should encompass the set-up of the regulated area, including any pre-cleaning and the hanging of polyethylene sheeting. 2. Asbestos Abatement Contractor: a. License Requirements: A company engaged in an asbestos abatement activity must hold a valid Asbestos Abatement Contractor license. b. Personnel Requirements: A licensed Asbestos Abatement Contractor must have a certified Asbestos Abatement Project Supervisor employed on staff. Asbestos abatement work must be completed by individuals trained in accordance with OSHA, U.S. EPA and MEDEP requirements. Individuals must possess a valid MEDEP certification. 3. Asbestos Abatement Activities: Asbestos abatement activities in the state of Maine are subject to the following work practice requirements: a. All projects must be performed in accordance with a project design by a MEDEP-certified Asbestos Project Designer. b. A certified Asbestos Abatement Project Supervisor must be designated as the lead supervisor for the project and must be present at the work Site at all times personnel are within the regulated area. c. Prior to starting an asbestos abatement activity, the Asbestos Abatement Contractor must establish the regulated area. For activities where containment is not required, the regulated area must be demarcated with barrier tape marked ASBESTOS HAZARD (or equivalent wording) and OSHA warning signs, and located such that it protects persons from exposure to asbestos and minimizes the number of persons in the area. In facilities where plastic barrier tape may cause a safety hazard, red cloth tape may be used. d. The regulated area must include a polyethylene-enclosed structure formed by partitions or framing or by covering walls and ceilings with a minimum of two layers of 4-mil polyethylene sheeting or one layer of 6-mil polyethylene sheeting, and by covering the floor with a minimum of two layers of 6-mil polyethylene sheeting. The surface to be abated does not need to be covered with polyethylene sheeting. Exterior walls must have critical barriers and any seams must be fiber tight. Ransom Project Page 21

25 e. Access into the polyethylene-enclosed containment area is provided through a decontamination unit. The decontamination unit consists of aluminum, tin, fiberglass, preformed plastic, or other impervious surface, or two layers of 6-mil polyethylene sheeting. Decontamination units must have 6-mil polyethylene sheeting flaps or air-locks between each chamber. f. A ventilation system providing an exchange of at least four volumes of air per hour at a volume sufficient to establish and maintain a pressure differential within the ambient environment of negative 0.02 inches of water column. The ventilation units must be operated in accordance with U.S. EPA recommendations set forth in Appendix J of USEPA Guidance Document EPA 560/ (effective June, 1985) or in Appendix F to 29 CFR Part (effective August 10, 1994). Make-up air entering the containment must pass through the decontamination system whenever possible, or through waste loadout and/or make-up air intakes specified by the project design. The exhaust air must be high efficiency particulate air (HEPA) filtered before being discharged outside of the work area and must be discharged to the outside. g. Individuals not directly involved in the asbestos abatement activity must be excluded from the regulated area. Warning signs, meeting the requirements established by OSHA (29 CFR ), are required at all approaches to the regulated area, and at the decontamination and waste load out unit's outermost boundaries. 4. Personal Protective Equipment: An individual involved in an asbestos abatement activity or an individual who enters the regulated area, excluding the clean room, must be provided with and wear appropriate respiratory protection and personal protective clothing. Minimum respiratory protection shall be half-faced negative pressure respirator equipped with HEPA filters. Minimum protective clothing shall be disposable full body suits, including head and foot coverings. OSHA also regulates asbestos activities involving respirators and personal protective equipment. OSHA regulations may require a higher degree of respiratory protection and/or protective clothing. 5. Wetting of ACM: Prior to removal of ACM, including removal of components covered with thermal system insulation, all ACM must be adequately wetted with water. Throughout the removal, storage, transport, and disposal processes, ACM must be kept adequately wet. 6. Containerization of Asbestos Waste: Prior to removal from the regulated area, asbestos waste must be containerized in fiber-tight leak-proof packaging and properly labeled, in accordance with OSHA requirements (29 CFR ). Fiber-tight packaging must be maintained throughout the storage, transport, and landfilling processes. Friable asbestos waste that does not contain components with sharp edges must be adequately wetted and then containerized in two polyethylene bags with a 6-mil minimum thickness for each bag. Exterior cementatious asbestos-containing materials must be wetted and containerized in leak-proof containers for delivery to a landfill licensed to accept non-friable waste. Other non-friable waste may be packaged as friable or must be adequately wetted and Ransom Project Page 22

26 thoroughly wrapped in a minimum of two layers of 6-mil or one layer of 12-mil polyethylene sheeting with all joints, seams, and overlaps sealed in a fiber-tight manner. Containerization in disposable leak-proof fiber-tight containers, such as fiber-tight drums, is also acceptable. Non-friable waste also may be packaged in large containers, such as dumpster or roll-offs, as long as the container is lined with two layers of 6-mil or one layer of 12-mil polyethylene sheeting and secured fiber-tight prior to transport and the ACM is maintained in a non-friable state when placed in the dumpster. Fiber-tight packaging must be maintained throughout storage, transport, and off-loading at the landfill. 7. Close-out: Following the initial visual evaluation and receipt of acceptable air clearance sampling results from a MEDEP-Certified Asbestos Air Monitor, the contractor can remove the containment, critical barriers, and the decontamination unit from the work Site. The contractor must clean up any visible dust or debris resulting from teardown activities prior to the final inspection after removal of containment. An asbestos abatement activity is not considered complete and acceptable for regulated area release until a visual evaluation and final air clearance standards have been met. 6.6 Lead-Based Paint Abatement Lead-based paint identified in the Site Buildings will be abated in accordance with State and Federal regulations. Since the buildings are proposed to be demolished or relocated and renovated, LBP abatement conducted as part of this cleanup project will include demolition and off-site disposal of the lead-painted surfaces/materials as construction and demolition debris at an appropriate disposal facility and/or long-term maintenance of remaining lead-based paint following renovations. Lead in paint was detected on various materials throughout the Site. Handling of components coated with lead-containing paint requires compliance with the OSHA lead standard ( Lead in Construction, 29 CFR ). Under the existing conditions, demolition contractors may perform demolition, renovation, abatement, stabilization, cleanup, and daily operations in buildings that have lead-based paint or leadcontaining coatings, provided that the following regulatory requirements are met: 1. Demolition or renovation activities that disturb surfaces that contain lead must be conducted in accordance with the OSHA regulation 29 CFR Lead Exposure in Construction: Interim Final Rule. This regulation requires that a Site-specific health and safety plan be prepared before conducting activities that create airborne lead emissions such as cutting, grinding, or sanding surfaces coated with lead-containing paint. Such a plan must include the identification of lead components, an exposure assessment, and, if applicable, the required work procedures and personal protective equipment to be used. 2. The U.S. EPA and MEDEP regulate the disposal of potentially hazardous wastes. Such wastes include paint chips and residue generated during abatement or repainting work, or whole components, such as wood windows, doors, and trim coated with lead-containing paint and disposed of as a result of proposed demolition work. Metal components are not regulated if they will be recycled and not disposed of in a landfill. 3. To minimize exposure to airborne dust or fumes containing lead and avoid the requirement to implement a lead exposure assessment, torch burning, cutting, grinding, or similar high impact work on components covered by lead-containing paint should be Ransom Project Page 23

27 avoided. Such work would need to be conducted by properly trained workers using appropriate worker protection and engineering controls. For work activities that may generate airborne lead, the employer should perform an initial exposure assessment (personal air monitoring) for each individual task (e.g. demolition, abrasive blasting, and painting) that has the potential for causing worker exposure to be at or above the OSHA Action Level (30 micrograms of lead per cubic meter of air). In lieu of monitoring, recent historical data from similar operations may be used to comply with OSHA requirements. 6.7 Universal Waste Removal Universal waste will be handled, transported disposed in accordance with MEDEP regulations. Trained individuals will package the waste in appropriate containers with proper labeling. Shipment of waste will be conducted in accordance with established Maine Department of Transportation protocol. Ransom Project Page 24

28 7.0 SITE CLOSURE AND REPORTING As part of the proposed cleanup activities, the Site will be entered into the MEDEP VRAP for review of environmental conditions and proposed remedial actions. Upon agreement with the proposed work by the MEDEP, the MEDEP will issue a VRAP No Action Assurance (NAA) letter. An approved final written completion report summarizing the field activities conducted as part of the remediation of the Site will be submitted to the MEDEP. The final report will include a description of the remedial actions and field methods implemented at the Site. Upon submittal and approval of the completion documentation, the MEDEP VRAP will issue a Certificate of Completion. Ransom Project Page 25

29 8.0 CONCLUSIONS AND RECOMMENDATIONS Previous environmental investigations conducted at the Site identified residual contamination associated with historic Site operations, including contaminated soils throughout the Site, contaminated soil vapor, and the potential for contaminated groundwater. Three remediation alternatives were evaluated, including a No Action alternative, Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative, and Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative. The No Action alternative is unacceptable because it does not meet threshold criteria of the overall protection of human health and the environment. The Full Abatement/Removal of Hazardous Building Materials and Full Removal of Contaminated Soil alternative was not selected, since this alternative is cost-prohibitive. The Full Abatement/Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan alternative protects human health and the environment and is effective, technically feasible, and practical. Because this alternative meets the evaluation criteria, and is not cost-prohibitive, this is the recommended remedial alternative. In addition, a deed restriction will be established for the Site, which will provide specific notification and Site management requirements. Ransom recommends that the Site be entered into the MEDEP VRAP, and this analysis be submitted to the MEDEP VRAP for review and approval (i.e., to obtain a VRAP NAA letter). Upon acceptance, the remedial actions will be documented and the results of the actions presented in a completion report submitted to the MEDEP VRAP to obtain a final VRAP Certificate of Completion. Ransom Project Page 26

30 9.0 SIGNATURE(S) OF ENVIRONMENTAL PROFESSIONAL(S) The following Ransom personnel possess the sufficient training and experience necessary to conduct an Analysis of Brownfields Cleanup Alternatives, and from the information generated by such activities, have the ability to develop opinions and conclusions regarding remediation alternatives and a Conceptual Remedial Action Plan, as presented herein, for the Site. Environmental Professionals: Aaron R. Martin, C.G. Associate Project Manager/Environmental Scientist Peter J. Sherr, P.E. Principal/Senior Project Manager/Belfast Brownfields Program Manager Ransom Project Page 27

31 TABLE 1 SUMMARY OF THE EVALUATION AND COMPARISON OF REMEDIAL ALTERNATIVES 45 Front Street Former Masker s Theater & Thompson s Wharf Site (Tax Map 11, Lot 136) Belfast, Maine Remedial Action Alternative (RAA) Overall Protection of Human Health and the Environment 1) No Action Long-term risks to human health by direct contact, inhalation, and ingestion will remain. Potential long-term risks to the environment by stormwater runoff and/or leaching to groundwater may continue. Cleanup levels will not be met. 2) Full Abatement/ Removal of Hazardous Building Materials and Soil Cover/Soil Management Plan 3) Full Abatement/ Removal of Hazardous Building Materials and Full Removal of Contaminated Soil Risks to human health by direct contact, inhalation and ingestion of contaminated media is significantly reduced or eliminated by limited removal and covering remaining contaminated soil inplace and placing deed restrictions on future site reuse. Risks to the environment by stormwater runoff or groundwater leaching are reduced by installing an impervious barrier over the material, or placing clean fill and maintaining vegetation over the material. The proposed alternative will not achieve background concentrations or reduce concentrations below regulatory exposure guidelines, but the physical barrier and institutional controls will protect human health and the environment from direct exposure. Provides adequate protection of human health and the environment through mitigating or eliminating the risk of human exposure to the hazardous building materials identified at the Site. Risks to human health by direct contact, inhalation and ingestion of contaminated media is significantly reduced or eliminated by removing the contaminated soil and hazardous building materials from the site. Technical Practicality Ability to Implement Not applicable. Not applicable other than natural attenuation, no response action will be implemented. Soil removal and cover systems utilize standard construction techniques. Institutional controls are becoming a more common and viable alternative. Therefore, this remedial alternative is technically practical for the identified contamination. Hazardous building removal utilizes standard construction abatement techniques, and therefore, this alternative is technically practical for the identified contamination and hazardous building materials at the Site. Hazardous building removal utilizes standard construction abatement techniques and soil removal utilizes standard excavation and construction techniques for removal of the contaminated media. Therefore, this alternative is technically practical for the identified soil contamination and hazardous building materials at the Site. Limited soil removal necessary for redevelopment and covering of soil can be easily implemented; however, institutional controls may be difficult to maintain if the property ownership is transferred and future owners of the site are unwilling to abide by the restrictive covenant. This alternative is technically feasible, and is an effective action for eliminating the risk of direct human contact to hazardous building materials. The necessary services and materials to complete the remedial tasks are readily available, including the necessary equipment and contractors. This alternative is technically feasible, and is an effective action for reducing or eliminating the risk of direct human contact to impacted soils and hazardous building materials. The necessary services and materials to complete the remedial tasks are readily available, including the necessary equipment and contractors. Reduction of Toxicity, Mobility and Volume No reduction in toxicity, mobility or volume of the contaminated media. Complete Reduction of Toxicity, Mobility and Volume of the identified hazardous building materials. Impacted soils will remain at the site; however, the remaining impacted soils will be covered. Therefore, the goal of reducing or eliminating the risk of direct contact by potential future site occupants, workers, and trespassers is achieved. Complete Reduction of Toxicity, Mobility and Volume of the identified hazardous building materials and contaminated soil. Short Term Effectiveness Not applicable other than natural attenuation, no response action will be implemented. Ineffective natural attenuation due to the types of identified contaminants. This alternative significantly reduces or eliminates human contact, inhalation, and ingestion risks if the soil cover system is not disturbed. Removal of hazardous building materials is an effective and proven method of remediation. Removal of contaminated soil and hazardous building materials is an effective and proven method of remediation. Resiliency to Climate Change No resiliency to climate change will be achieved through the no action alternative. This alternative adequately achieves some level of resiliency to climate change. Impacted soils will be capped, mitigating direct contact with rain/stormwater; the cover/cap system will shed or redirect stormwater run-on and minimize infiltration within the impacted areas. Furthermore, although impacted soils may remain onsite and rising groundwater tables have the potential to come into contact with impacted soils, the contaminants of concern are not expected to be significantly leachable, thus reducing potential groundwater impacts. This remedial alternative adequately meets the objectives associated with this criterion by removing impacted soils, which may come into contact with the groundwater table and with rain/stormwater. Estimated Cost This alternative will involve ongoing security measures and maintenance and will cost approximately $1,000 per year. Hazardous building materials abatement, limited soil removal, disposal of contaminated soil, and implementation of soil cover systems will cost approximately $254,000. Capital costs include direct capital costs, such as materials and equipment, and indirect capital costs such as engineering and sampling. These cost estimates are for budgetary purposes only and in no way should be construed as a cost proposal. The costs associated with this alternative are not prohibitive. Hazardous building materials abatement, excavation and disposal of contaminated soil, and soil backfill activities will cost approximately $597,000. Capital costs include direct capital costs, such as materials and equipment, and indirect capital costs such as engineering and sampling. These cost estimates are for budgetary purposes only and in no way should be construed as a cost proposal. The costs associated with this alternative are not prohibitive. Comments This alternative does not address the recognized environmental conditions and contamination stigma at the property. Because hazardous building materials and contaminated soil will remain onsite, this alternative will require a deed restriction to limit future site use, restrict access to the buildings, and require proper management of contaminated soil remaining at the site. Because contaminated soil will remain onsite below the cover system materials, this alternative will require a deed restriction to limit the future use of the site and require the proper management of covered areas and contaminated soil remaining at the site. A deed restriction prohibiting the extraction of groundwater will also be necessary and a Post-Closure Cover Maintenance and Soil Management Plan will be required. Lower potential risk of long-term liabilities, since exposure to sensitive receptors will be reduced. Best alternative based on the majority of parameters, including cost. Eliminates potential risk of human contact with impacted soils and hazardous building materials. Contaminated soils and hazardous building materials will be removed in their entirety, resulting in significant increase in cleanup costs A deed restriction prohibiting the extraction of water will also be necessary. P:\2011\ \45 Front Street (Masker's Theater & Thompson's Wharf) - City-Owned Map 11, Lot 136\ABCA & RAP\Tables\Table 1 - Summary of Alternatives.doc Page 1 of 2

32 Table 2: Summary of Estimated Remediation Costs - Full Abatement and Soil Cover Alternative Task Description Number Units Unit Cost Total HMI Abatement Abatement 1 LS $31,475 $31,475 Contingency for Lead Disposal as Hazardous Waste (TCLP) 1 LS $25,000 $25,000 Disposal of Displaced Contamianted Soil Excavation & Disposal of Contaminated Soil 500 CY $100 $50,000 Disposal Soil Characterization Samples 1 Ea $1,500 $1,500 Clean Cover System Clean Fill 1 & 2 2,000 CY $35 $70,000 Cover Construction Excavator/Dozer & Operator 80 Hrs $150 $12,000 Engineering Design/Oversight/Closure Report Design 1 LS $7,500 $7,500 Oversight 80 Hrs $85 $6,800 Report 1 LS $7,500 $7,500 Subtotal: $211,775 Contingency 20%: $42,355 TOTAL: $254,130 NOTES: 1 - Includes material, backfill, and compaction. 2 - Includes geotextile fabric and one foot of clean fill material (gravel, loam, or rip rap), backfill, and compaction.

33 Table 3: Summary of Estimated Remediation Costs - Full Abatement & Soil Removal Alternative Task Description HMI Abatement Number Units Unit Cost Total Abatement 1 LS $31,475 $31,475 Contingency for Lead Disposal as Hazardous Waste (TCLP) 1 LS $25,000 $25,000 Excavaation, Disposal, and Transportation of Contaminated Soils Excavation & Disposal of Contaminated Soil 1 3,000 CY $100 $300,000 Disposal Soil Characterization Samples 5 Ea $1,500 $7,500 Replacement Clean Fill 2 3,000 CY $35 $105,000 Engineering Oversight/Closure Report Design 1 LS $7,500 $7,500 Oversight 160 Hrs $85 $13,600 Report 1 LS $7,500 $7,500 Subtotal: $497,575 Contingency 20%: $99,515 TOTAL: $597,090 NOTES: 1 - Includes excavation to an estimated depth of 2 feet bgs, transport, and disposal; assumes 150 CY per day and that soils are disposed as special waste (i.e., non-hazardous waste). 2 - Includes material, backfill, and compaction. Site is approximately 65,000 square feet = approximately 1.45 acres

34 Regional Locator Map Belfast SITE LOCATION Notes 1. Data Source: USGS National Map Seamless Server, 24K DRG, 1/3" NED 2. USGS Quad Name: Belfast, Searsport 3. Latitude: 44 25'43.32" N Longitude: 69 0' 23.76" W UTM Northing: mN UTM Easting: me Scale and Orientation 0 1,000 2,000 1 inch = 2,000 feet [ Prepared For City of Belfast 131 Church Street Belfast, ME Site Address Tax Map 11, Lot Front Street Belfast, ME Mar 2015 Figure 1 Copyright: 2011 National Geographic Society, i-cubed Site Location G:\Data\ME\Project\131_06015\Maps\Figure_1.mxd

35 Front Street Shipyard (Tax Map 11, Lot 132) Legend Thompson's Wharf Site Boatyard Office Approximate Location of Harborwalk Right of Way B113 Front Street Shipyard (Former Belfast Boatyard Tax Map 11, Lot 137) Spar Shed B104 Right of Way to Thompson's Wharf Former Railroad Engine House (Demolished 2012) Three Tides B105 B114 "Site" (Tax Map 11, Lot 136) SV102 B106 B110 Front Street Shipyard Building #5 (Constructed 2012) B103/TW103 Maskers Theat er Building B102/TW102 B108 B107 e Stre t n Fro BK2 Background Soil Soil SoilBoring/ Temp Well * ' Ï Soil Vapor 1. Site Plan based on Bing Orthophotography 2. Some features are approximate in location and scale 3. Property boundary taken from Tax Map provided by City of Belfast. Property boundaries are approximate. A boundary survey was not included in the scope of work for this assessment. t 4. This plan has been prepared for the City of Belfast. All other uses are not authorized unless written permission is obtained from Ransom Environmental Consultants, Inc. Right of Way to Boatyard Scale and Orientation BK inch = 50 feet [ Prepared For Storage Building Approximate Location of Petroleum-Impacted soils encountered during 2012 utility work B109 Front Street Pub B111 SV101 # * ) Ð Notes B112 B101/TW101 Front Street Shipyard (Tax Map 11, Lot 136-A) Reported Petroleum Impacted Soils Belfast Wastewater Treatment Plant City of Belfast 131 Church Street Belfast, Maine Site Address Tax Map 11, Lot Front Stret Belfast, Maine Mar 2015 Figure 2 Site Plan G:\Data\ME\Project\131_06015\Maps\Figure_2.mxd