Analysis of Brownfields Cleanup Alternatives and Remedial Action Plan Gunn Block 477 State Street Springfield, Massachusetts

Transcription

1 Analysis of Brownfields Cleanup Alternatives and Remedial Action Plan 477 State Street Springfield, Massachusetts Prepared for: DevelopSpringfield 1182 Main Street Springfield, MA Funded By: Pioneer Valley Planning Commission Regional U.S. EPA Brownfields Revolving Loan Fund Grant #: CA DRAFT February 25, 2014 In Reference to: Credere Project No Submitted by: Credere Associates, LLC 776 Main Street Westbrook, ME Community Revitalization, Economic Development, Environmental Remediation & Engineering

2 TABLE OF CONTENTS 1. INTRODUCTION Purpose and Scope SITE BACKGROUND Surrounding Land Use Future Site Use SUMMARY OF PREVIOUS ENVIRONMENTAL INVESTIGATIONS CONCEPTUAL SITE MODEL Physical Setting Current Contaminants of Concern Exposure Pathways and Potential Receptors Conceptual Site Model Summary ESTIMATE OF IMPACTED MEDIA AND CLEANUP GOALS Estimate of Impacted Media Cleanup Goals and Applicable Guidelines DESCRIPTION OF REMEDIAL ALTERNATIVES Alternative #1 No Action Alternative #2 Continued Use of HBM Alternative #3 Full Abatement of HBM Alternative #4 Combined Continued Use and Abatement of HBM COMPARISON OF ALTERNATIVES Description of Evaluation Criteria Evaluation of Alternatives Justification for the Selected Remedial Alternative PROPOSED REMEDIAL ACTION WORK PLAN SUMMARY LIST OF TABLES Table 1... Summary of Remedial Alternatives LIST OF FIGURES Figure 1... Site Location Plan Figure 2... Detailed Site Plan i

3 1. INTRODUCTION Credere Associates, LLC (Credere) has been retained by DevelopSpringfield to prepare this Analysis of Brownfields Cleanup Alternatives and Remedial Action Plan (ABCA/RAP) for the located at 477 State Street in Springfield, Massachusetts (the Site). This document was prepared using funding from the Pioneer Valley Planning Commission (PVPC) Regional Brownfields Revolving Loan Fund (BRLF) grant number CA The following report provides a technical evaluation of remedial alternatives for addressing the identified environmental conditions at the Site and presents a work plan for the selected remedial alternative. 1.1 PURPOSE AND SCOPE The purpose of this report is to: 1. Provide a summary of Site background and documented environmental impacts (including threats to public health and/or the environment) to support the need for environmental response actions. 2. Evaluate appropriate cleanup alternatives to mitigate identified environmental conditions at the Site. 3. Select the remedial alternative that best meets the objectives and considerations of the project. 4. Present a general work plan for implementing the selected remedial alternative. Information on known Site conditions is based on the results of investigations completed for DevelopSpringfield during acquisition of the Site and preliminary project planning. These investigations, which are summarized in Section 3, include the following: April 8, 2013, Phase I Environmental Site Assessment (ESA), O Reilly, Talbot & Okun Associates, Inc. (OTO) October 10, 2013, Pre-demolition/Renovation Asbestos/Hazardous Building Materials (A/HBM) Assessment, OTO Consistent with the findings of these environmental investigations, environmental conditions within the Site building that need to be addressed include the following: Asbestos-containing materials (ACM) Lead-based paint (LBP) Universal wastes Possible petroleum impacts associated with the aboveground storage tank (AST) Each considered remedial alternative was evaluated based on the following criteria: 1-1

4 Effectiveness and Reliability Feasibility and Ease of Implementation Risk Reduction and Associated Benefits Cost Effectiveness Estimated Time to reach a permanent solution Consideration was given to the following items in the development of the conceptual site model and remedial alternatives: Nature of asbestos and other hazardous building material (HBM) throughout the Site building Potential exposure to onsite and off-site human receptors from residual contamination existing prior to any remedial action and remaining after the remedial action including: o Potential onsite and off-site human receptors including high frequency children present, low frequency children present, high frequency adults only present and low frequency adults only present (i.e. future residents, commercial workers, and/or commercial patrons) Potential off-site receptors including adjoining residential properties Compatibility of any remedial alternative with the planned future reuse of the Site 1-2

5 2. SITE BACKGROUND The Site is comprised of one 0.1 acre (4,821 square feet) parcel located at 477 State Street in Springfield, Massachusetts. The Site is currently owned by Strategic Acquisitions, LLC, a subsidiary of DevelopSpringfield, and is improved with a three and a half story vacant building and parking area. The Site building adjoins an abutting building to the west. The Site building is one of Springfield s oldest and was originally constructed in 1830 as a warehouse and distribution center for imported luxuries such as rum, sugar and molasses. By the mid-1800s and throughout the rest of the Site building s history, it has been used primarily as a restaurant, club, meeting space and/or commercial storefront on the first floor and residential apartments on the second and third floors. The Site building has been vacant since 2009 due to code violations and disrepair. A second building reportedly occupied the parking lot portion of the Site that had an address of 4 to 8 Walnut Street. This building was removed sometime during the 1930s. As discussed in Section 3, a pre-purchase Phase I ESA and post-purchase A/HBM Assessment were completed in April and October, 2013, respectively. No recognized environmental conditions (RECs) were identified in the Phase I ESA and no Massachusetts Department of Environmental Protection (MassDEP) release tracking numbers (RTNs) are associated with the Site. Extensive asbestos-containing materials (ACMs), some lead-based paint (LBP), and several potential universal wastes were identified in the A/HBM Assessment. Figure 1 locates the Site on the Springfield South, Massachusetts Quadrangle prepared by the United States Geological Survey (USGS). A plan of the Site depicting pertinent features is presented as Figure SURROUNDING LAND USE The Site is located in a mixed residential, commercial, and academic area of Springfield. The Site is bound to the west by an adjoining residential and commercial building; to the north by State Street, the Springfield Armory and the Springfield Technical Community College; to the east by Walnut Street, a Burger King and commercial properties; and athletic fields to the south. 2.2 FUTURE SITE USE DevelopSpringfield plans to renovate the historic building for use as a restaurant and/or bar on the first floor and residential apartments on the second and third floors. This redevelopment effort plans to create jobs and residential space in the downtown area. This area was severely damaged by the June 2011 tornado. Site improvements will be made as part of the implementation of the 2008 State Street Corridor Improvement Program and the 2012 Rebuild Springfield Plan. 2-1

6 3. SUMMARY OF PREVIOUS ENVIRONMENTAL INVESTIGATIONS The following subsections are provided to summarize the previous environmental investigations completed at the Site. Phase I ESA, April 8, 2013, OTO OTO performed a Phase I ESA at the Site in April The ESA found that the current Site building had been used for commercial and residential purposes since its construction in the 1830s. A second commercial and residential building was present in the parking lot portion of the Site until sometime during the 1930s. No RECs were identified for the Site; however, one abandoned-in-place 1,000-gallon underground storage tank (UST) and one 300-gallon AST were located onsite. The UST was reportedly installed in 1940 and the closure permit was issued in The Phase I ESA did not indicate closure documentation was reviewed or if confirmatory sampling had been conducted. The report indicated the AST is located in the basement of the current Site building on a brick over earth floor. Speedi-dry and minor staining was observed beneath the AST; however, no releases have been reported for the Site. The staining was considered a de minimis condition because the apparent staining did not appear to impact the MassDEP reporting threshold of 2 cubic yards of soil. A/HBM Assessment, October 10, 2013, OTO OTO performed an A/HBM Assessment for the current Site building in October Bulk potential ACM samples were collected by Massachusetts licensed staff and submitted to an accredited asbestos laboratory for polarized light microscopy (PLM) analysis. A LBP survey was conducted using an X-ray fluorescence (XRF) meter. Extensive ACM was identified in the form of plaster skim coatings throughout the second and third floors, along with smaller quantities in boiler and pipe insulation, and floor mastic/tile. Roofing materials were not sampled but were also presumed to be ACM. LBP was located on plaster walls and window sills on the upper floors, and on the tin ceiling and bar counter on the first floor. The following table summarizes locations within the Site building that have been identified to contain ACM or other HBM. Location in the Site Building Material Sampled ACM/LBP/Universal Waste Ground floor (right side of bar) White flooring 6% Chrysotile Ground floor (kitchen) Yellow/brown flooring (3 rd layer) 3% Chrysotile Ground floor (kitchen) 2 Fluorescent light fixtures Possible PCBs, 2 bulbs Ground floor (behind bar) Black Paint Lead between 6.2 and 19.7 mg/cm 2 Ground floor (tin ceiling) Yellow Paint Lead between 10.5and 22.5 mg/cm 2 Through 2 nd and 3 rd floors Painted plaster and windowsills Lead between 2.1 and 41.7 mg/cm 2 Apartment 202 Wall skim coat 2% Chrysotile Apartment 203 (bathroom) Stone pattern sheet floor (bottom layer) 4% Chrysotile Apartment 201 (closet) Brown 9x9 floor tile 6% Chrysotile Apartment 302 Wall textured skim 2% Chrysotile 3-1

7 Location in the Site Building Material Sampled ACM/LBP/Universal Waste Apartment 301 (hallway) Brown 9x9 floor tile 8% Chrysotile Apartment 301 (kitchen) Yellow/green pattern sheet floor 10% Chrysotile Apartment 301 (kitchen) Black mastic <1% Chrysotile Apartment 303 (kitchen) Brown sheet floor, bottom layer 10% Chrysotile Apartment 303 (kitchen) Black mastic 2% Chrysotile Apartment 303 (closet) Brown sheet floor 15% Chrysotile Apartment 303 (closet) Black mastic 2% Chrysotile Basement Expansion tank jacket 40% Chrysotile Basement Aircell insulation 70% Chrysotile Basement 275-gallon fuel oil AST* Contain ~150 gallons fuel oil Basement Carrier air conditioner unit* Refrigerant Basement Walk-in refrigerator* Refrigerant Roof Asphaltic roofing, flashing, and Presumed asbestos underlayment* Note: Additional samples were collected for ACM and LBP with non-detect results. * - material not sampled but rather observed It should be noted that potential polychlorinated biphenyl (PCB)-containing bulk products were not inventoried and/or collected for analysis during the October 2013, A/HBM Assessment conducted by OTO. 3-2

8 4. CONCEPTUAL SITE MODEL A conceptual site model (CSM) was developed using the findings of the Phase I ESA and A/HBM Assessment. This CSM includes descriptions of the location and physical setting of the Site, contaminants of concern (COCs), exposure pathways, and potential human and environmental receptors. 4.1 PHYSICAL SETTING Site Location The Site is located in a dense urban setting characterized by commercial, residential and academic/athletic properties. Site Topography and Drainage Topography at the Site is flat with a gentle local slope to the southwest towards the Connecticut River located approximately one mile away. The portions of the Site that are not covered by the Site building, consist of an asphalt-paved parking area. The entire Site consists of impermeable surfaces and stormwater at the Site is directed via sheet flow to municipal stormwater collection basins along State Street and Walnut Street. Site Groundwater and Hydrogeology No subsurface investigations are known to have been conducted to date at the Site. Depth to groundwater and groundwater flow direction has not been assessed. Based on local topography and nearby surface water bodies, it can be presumed groundwater generally flows to the southwest toward the Connecticut River. Geological Characteristics According to the US Geological Survey (Zen, et al, 1983) Bedrock Geologic Map of Massachusetts, bedrock below the Site consists of the lower Jurassic arkose, siltstone, sandstone and black shale of the Portland Formation. The depth to bedrock at the Site is not known. 4.2 CURRENT CONTAMINANTS OF CONCERN Asbestos (in ACMs) and lead (in LBP) have been detected at concentration exceeding regulatory criteria and are considered the primary COCs under this ABCA/RAP. No soil or groundwater analytical assessments are known to have been conducted at the Site. Petroleum may be considered a COC if soil analytical results indicate soil concentrations exceeding the RCS-1 standards, or if greater than two cubic yards of petroleum impacted soil is encountered. These conditions trigger a reporting requirement under the Massachusetts Contingency Plan (MCP) 310 CMR (2) unless a Limited Removal Action (LRA) per 310 CMR is successfully conducted. 4-1

9 4.3 EXPOSURE PATHWAYS AND POTENTIAL RECEPTORS Exposure Pathways describe how a human or environmental receptor comes into contact with contaminants that may be present at the Site. Exposure pathways presented in the CSM include the following: Inhalation: This pathway is primarily associated with groundwater contamination within 30 feet of an occupied structure when groundwater elevation is less than 15 feet below surface grade, or when depth to groundwater is unknown. This pathway is applicable when receptors may inhale impacted media in the form of contaminated vapor. Dermal Absorption: Exposure via dermal absorption occurs when receptors are exposed to contaminant concentrations present in soil, groundwater, surface water, or building materials through direct contact with the skin. Active Ingestion Incidental Uptake: The active ingestion pathway represents exposure which may occur through the active ingestion of contaminant concentrations via a drinking water supply well, through agricultural products, or through direct consumption of impacted media (i.e. impacted soil, lead based paint chips, etc.). This pathway is applicable when receptors may incidentally ingest/inhale impacted media in the form of contaminated dust or airborne asbestos particulates. Potential Receptors are categorized by age, duration of exposure, and intensity of use at the Site. The receptor categories described in the CSM include the following: Child Present High Frequency: Child Present Low Frequency: Adults ONLY Present High Frequency: Adults ONLY Present Low Frequency: Terrestrial and Aquatic Biota: Receptor is defined as a child residing, attending school or daycare, or if a large number of children are present regardless of any single child s frequency of use. High frequency is defined as a period of 8 hours or more per day on a continuing basis. Receptor is defined as a child being present at a Site only as an infrequent visitor (less than two hours per day or a full day on a sporadic basis). Receptor is defined as having only adults reside or work at a Site for a period of 8 hours or more per day on a continuing basis. Receptor is defined as having only adults at the Site as infrequent visitors (less than two hours per day or a full day on a sporadic basis). These receptors include flora and fauna which may be exposed to contaminants in their respective land-based or aquatic environments. A soil and/or groundwater reportable concentration category can be selected based on the intensity of use and accessibility of soil and/or groundwater impacts (i.e. depth to contamination, 4-2

10 presence of pavement, etc.). Intensity of use is defined as high when the receptor is involved in soil disturbance, or in direct contact with the soil or soil derived dust. Intensity of use is defined as low when only passive activities such as walking or shopping are done at the Site. 4.4 CONCEPTUAL SITE MODEL SUMMARY Based on the findings of the A/HBM Assessment reviewed by Credere as a part of this ABCA/RAP, ACM and LBP are present in the Site building and may be encountered by each of the four human receptor groups (child present high frequency, child present low frequency, adult only present high frequency and adult only present low frequency receptors) and include future residents, commercial workers, and/or commercial patrons. If ACM and LBP are not properly addressed during redevelopment, primary impacted media would include indoor air and interior and exterior surfaces. The potential exposure pathways would be through incidental uptake and active ingestion of dusts generated from these materials, or through the dermal absorption of lead through direct contact with painted surfaces. 4-3

11 5. ESTIMATE OF IMPACTED MEDIA AND CLEANUP GOALS 5.1 ESTIMATE OF IMPACTED MEDIA OTO prepared estimated quantities of ACM that were identified in the Site building: ACM Quantity Textured plaster skim coating 16,500 square feet (ft 2 ) Aircell insulation 200 linear feet Water/expansion tank jacket 45 ft 2 Floor tile/mastic (various floors) 1,550 ft 2 Asphaltic roofing area 2,000 ft 2 Weil McLain boiler Regulated concentrations of LBP were identified on numerous surfaces throughout the Site building including, black paint on the back of the bar counter, yellow paint on the tin ceiling, and painted plaster and windowsills throughout the second and third floors. The approximate area of these painted surfaces has not been measured to date. The following potential universal wastes were identified in the first floor kitchen including the following: 1 unit Possible Universal/Other Wastes Quantity Mercury-containing fluorescent light tubes in the kitchen Fluorescent light ballasts 1 Refrigerants in air conditions and walk-in refrigerator Residual Fuel Oil in AST 2 Unknown volume Unknown volume (< 300 gallons) 5.2 CLEANUP GOALS AND APPLICABLE GUIDELINES To determine necessary remedial actions at the Site, the sampling results were compared to applicable state and federal standards/guidelines and/or background concentrations. These standards and/or guidelines for each sampled media are described below. The goal relative to the identified COCs is to eliminate or manage the risks to human health and to the environment through proper management, mitigation, and/or disposal of identified COCs. Asbestos Containing Materials ACMs will be managed in accordance with 310 CMR 7.15 and 453 CMR 6.00 of Massachusetts regulations and the National Emissions Standards of Hazardous Air Pollutants (NESHAP). 5-1

12 Lead-Based Paint Concentrations of lead in paint as determined through the use of an XRF analyzer were compared to a limit of 1.0 mg/cm 2 per 105 CMR Lead Poisoning Prevention and Control. Additionally, paints identified by XRF screening to contain concentrations of lead within the instrument inconclusive range of 0.60 to 1.10 mg/cm 2 are considered inconclusive for LBP. Paint that is within the inconclusive range has not been analyzed further and will likely be disturbed through either removal or repair and management during redevelopment. Consistent with these conditions, materials within the inconclusive range have been characterized as LBP. As LBP and assumed LBP were identified at the Site, construction work involving exposure or potential exposure to LBP coated materials is regulated by OSHA s Lead in Construction Standard 29 CFR , 105 CMR Lead Poisoning Prevention and Control and 454 CMR Deleading and Lead-Safe Renovation Regulations. Universal Wastes Universal waste materials have the potential to cause a release of oil and/or hazardous substances when removed from service or when not properly maintained. Materials that would be characterized as universal and/or hazardous waste materials may be removed from service during the proposed redevelopment activities. As such, the goal of the remediation is to properly remove and dispose of universal and hazardous waste materials in such a way as to prevent a release. Universal waste will be identified and managed in accordance with 310 CMR Massachusetts Hazardous Waste Regulations (specifically Section ). Petroleum Petroleum contaminated soil (if encountered) is regulated under the Massachusetts Contingency Plan (MCP), 310 CMR Reporting Category RCS-1 applies to soil at the Site as a recreational area or park and/or residential dwellings are located within 500 feet of the Site. Although groundwater impacts are not anticipated at the Site, reporting category RCGW-2 applies as the Site overlies a Non-Potential Drinking Water Source (NPDWSA) medium-yield aquifer, as shown on MassGIS s MassDEP Priority Resource Map overlay for the Site area. During removal of the current AST in the basement of the building, the floor beneath the AST will be observed for staining, and for cracks or evidence of a pathway to the subsurface. If a pathway is found to be present, soil from areas of staining (if any) will be screened with a photoionization detector (PID) using the MassDEP jar headspace method. Soil with screening results exceeding 100 ppmv will be excavated using hand tools and stored onsite pending waste characterization and offsite disposal. If soil is removed, two confirmatory soil samples will be collected from within the excavation and submitted for analysis of extractable petroleum hydrocarbons (EPH) and/or volatile petroleum hydrocarbons (VPH). If no pathway to the subsurface through the basement floor is found and no staining is observed beneath the AST, no confirmatory soil samples will be collected. If analytical results exceed RCS-1 reportable concentrations, or if greater than 2 cubic yards of petroleum impacted soil is encountered; a reportable condition exists under the MCP. The Site owner would then have 120 days to conduct a soil removal action to achieve levels less 5-2

13 than RCS-1 at the Site, or steps should be taken by the Licensed Site Professional (LSP) to be in compliance with the reporting obligation. 5-3

14 6. DESCRIPTION OF REMEDIAL ALTERNATIVES The remedial actions selected for the Site should accomplish the following objectives: Minimize the potential for exposure to and/or improper disposal of asbestos, lead, universal and hazardous waste materials, and petroleum impacted soil (if any) Meet the redevelopment goals for the Site Multiple remedial alternatives are available to address the identified COCs at the Site. However, based on our past experience at sites with similar contaminants and conditions, we have prescreened general advantages and disadvantages of various treatment options and have selected the following four remedial alternatives for further evaluation and comparison. 1.Alternative #1: No action 2.Alternative #2: Continued Use of HBM 3.Alternative #3: Full abatement and proper disposal of HBM 4.Alternative #4: Combination of continued use and abatement and proper disposal of HBM It should be noted that all alternatives with the exception of Alternative #1 include the removal of the onsite AST and any associated petroleum impacts soil (if any). These remedial alternatives were evaluated for implementation at the Site and are further discussed in the following sections. 6.1 ALTERNATIVE #1 NO ACTION A No Action alternative signifies that no remediation activities would be implemented at the Site. The No Action alternative does not include a means for mitigating or eliminating potential exposure to contaminated soil or building materials both during and following redevelopment. Therefore, the potential for human exposure continues to exist for future residents, excavation/construction workers, commercial workers and patrons. This alternative is presented and discussed through the subsequent portions of this report as a baseline comparison, and represents the existing conditions at the Site. 6.2 ALTERNATIVE #2 CONTINUED USE OF HBM This alternative would utilize standard techniques to continue to use the ACM, LBP, and universal waste building components. These techniques would consist of encapsulation, enclosure, repair, repainting, or a combination thereof to limit exposure. A Hazardous Building Material Management Plan (HBMMP) would then be developed and implemented to ensure that the hazardous building materials are managed properly in the future. 6-1

15 6.3 ALTERNATIVE #3 FULL ABATEMENT OF HBM This alternative would utilize standard techniques to remove the ACM, LBP, and universal waste building components. Removed wastes would be properly disposed at a licensed facility. The Site building would be free of hazardous building materials with this alternative. 6.4 ALTERNATIVE #4 COMBINED CONTINUED USE AND ABATEMENT OF HBM This alternative would utilize a combination of continued use and abatement. Certain LBP components (wood molding, tin ceiling tiles, etc.) are considered historically significant and will be reused/preserved as part of the redevelopment. These materials will be encapsulated, enclosed, repaired, repainted, or a combination thereof to limit exposure. The remaining materials will be abated according to standard techniques for removal. The removed wastes would be properly disposed at a licensed facility. An HBMMP would be prepared and implemented to ensure the continued use of LBP is managed properly. 6-2

16 7. COMPARISON OF ALTERNATIVES As discussed in the previous section, four remedial alternatives were evaluated to address the identified COCs at the Site. These remedial alternatives are evaluated and compared to one another in this section. The comparisons of the remedial alternatives have been conducted using the five criteria listed below: 1. Effectiveness and Reliability 2. Feasibility and Ease of Implementation 3. Risk Reduction & Green Remediation 4. Cost Effectiveness 5. Estimated Time to Reach No Further Action A brief summary of these five criteria and a discussion as to how they pertain to the available selected remedial alternatives is presented below. A comparison of remedial alternatives with respect to the above-listed criteria for each selected alternative is presented on Table 1 at the end of this Section. 7.1 DESCRIPTION OF EVALUATION CRITERIA Effectiveness and Reliability This criterion addresses the ability of the alternative to meet the cleanup standards and the longterm reliability of the alternative. Feasibility and Ease of Implementation This criterion analyzes technical feasibility and the availability of services and materials. 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. Risk Reduction and Green Remediation This criterion is categorized as a threshold criterion. Alternatives must pass this criterion to be considered for implementation as the recommended alternative. It addresses whether or not a remedy provides adequate protection and describes how the risks posed by the Site are eliminated, reduced, or controlled. Protection of human health is assessed by evaluating how risk from each exposure route is eliminated, reduced, or controlled through specific alternatives. This criterion also evaluates the extent of green remediation techniques to be employed as part of the project and their associated benefits. This criterion will be evaluated based on its consistency with EPA s Principle for Greener Cleanup policy. 7-1

17 Cost Effectiveness Cost information presented for the alternatives evaluates the estimated capital, operational and maintenance costs of each alternative. Capital costs include direct capital costs such as materials and equipment. Costs are presented as a balancing criterion such that if a number of remedial alternatives are comparable for the previously discussed criteria, cost may be used as a distinguishing factor in the selection of the remedial action. Estimated costs were developed based on prior project and contractor experience, and current estimates received from contractors. Remediation is scheduled to take place in 2014, and as such, costs presented are in year 2014 dollars. Estimated Time to Reach Permanent Solution This criterion is defined as the time it will take to achieve a permanent solution by removal of the threat of exposure to any of the applicable receptors without the need for continued management or monitoring of COCs at the Site. Estimated time includes any applicable closure reporting and confirmatory analyses as required by the Commonwealth of Massachusetts. 7.2 EVALUATION OF ALTERNATIVES Alternative #1 No Action The No Action alternative involves no remedial activities at the Site. This alternative does not include a means for mitigating or eliminating potential exposure to contaminated soil or hazardous building materials both during and following redevelopment. Therefore, the potential for human exposure continues to exist for future residents, commercial and Site workers, and visitors. As such, the No Action response is not wholly protective of human health and the environment. Additionally, without action, the toxicity, mobility, and volume of contaminants will not be reduced. Therefore, this alternative is ineffective as a permanent remedial solution. As a result, this alternative cannot be considered as a final alternative for this issue, and will not be evaluated further in this ABCA/RAP. Alternative #2 - Continued Use of HBM Effectiveness and Reliability This method would prevent exposure to HBM and petroleum impacted soil; however, this alternative would not reduce the volume of HBM COCs at the Site. This alternative is effective and is also reliable, but long-term maintenance will be required to manage the encapsulated and/or covered hazardous building materials in order to ensure reliability. Feasibility and Ease of Implementation This method would use standard and proven construction, remedial, abatement, and institutional control techniques to manage the hazardous building materials in-place. However, the Site owner, Strategic Acquisitions, LLC, has plans to remodel the interior of the Site building, which will disturb ACM, LBP, and universal waste building components. Therefore, this alternative is technically feasible, but not easily implementable because it would be very difficult to work around all the ACM, LBP and universal waste while managing potential risk of exposure to 7-2

18 various construction workers. In summary, this alternative is considered to be feasible, but not easily implementable. Risk Reduction and Green Remediation This alternative fulfills the overall protection of human health and the environmental requirement by mitigating the exposure to ACM, LBP, and universal waste. This is not a permanent solution as it requires long term management. In addition, throughout the redevelopment, significant health and safety practices would have to be employed to protect workers. An associated benefit would be that the hazardous building material would be able to be left in place eliminating the need for trucking remediation waste off-site and disposal costs. Therefore, this option will be sustainable and will likely have a smaller carbon footprint when compared to the other hazardous building material alternatives. Cost Effectiveness Based on prior project and contractor experience and current estimates contained in previous reports, the estimated cost to manage hazardous building materials in-place is as follows: Remedial Planning/Engineering $20,000 Waste Characterization $ 5,000 Encapsulation & Long-term Management of in-place ACM $40,000 Repair and Repainting of LBP $30,000 Universal Waste/AST Removal $ 3,000 Soil Assessment and Removal $ 1,000 HBMMP Preparation $ 4,000 Implementation of HBMMP (1) $40,000 Cleanup Oversight/Reporting $25,000 10% Contingency $16,700 Total $184,700 (1) Assumes $2,000 net present value for annual maintenance and operations cost over 30 years with 3% annual inflation and discount rate of 3%. Estimated Time to Reach Permanent Solution Following the installation of controls and repair of hazardous building materials, the Site would meet the conditions of a temporary solution since the implementation of the HBMMP would be required. A permanent solution is not achievable under this alternative. A temporary solution could be attained within approximately two to four months of implementation. This assumes that the HBMMP continues to be implemented into the future. Alternative #3 Full Abatement and Proper Disposal of HBM Effectiveness and Reliability This alternative relies on proper engineering controls and industry proven techniques to effectively abate and dispose of the HBM. Once the remediation is complete, this method would 7-3

19 permanently eliminate the potential exposure to HBM and petroleum impacted soil (if any). Based on these considerations, this alternative is highly effective and reliable. Feasibility and Ease of Implementation This method would use standard and proven construction, remedial, and abatement techniques to remove hazardous building materials. This alternative is technically feasible and is easily implementable, because the project can be phased such that the hazardous building materials can be removed prior to redevelopment, thereby eliminating the exposure risk to construction workers. However, this alternative does not allow for the reuse of historically significant building components that contain lead. Risk Reduction and Green Remediation This alternative fulfills the overall protection of human health and the environment requirement by eliminating the risk of exposure to hazardous building materials and eliminating the toxicity, mobility, and volume of the COCs at the Site. The associated benefits are that there will be no restrictions for future construction activities and no restrictions for future users, making this a desirable alternative. This alternative will rely on the use of local contractors as well as local disposal facilities that will reduce overall fuel consumption and greenhouse gas emissions for the project. Cost Effectiveness Based on prior project and contractor experience and current estimates received from contractors, the estimated cost to implement this alternative is as follows: Remedial Planning/Engineering $ 20,000 Waste Characterization $ 5,000 Abatement by Removal of ACM $110,000 Removal/Replacement of LBP $ 10,000 Universal Waste/AST Removal $ 3,000 Soil Assessment and Removal $ 1,000 Cleanup Oversight/Reporting $ 25,000 10% Contingency $ 17,300 Total $191,300 Estimated Time to Reach Permanent Solution Immediately following the abatement and disposal of the HBM and the receipt of any clearance sample results, the Site would meet the conditions of a permanent solution. A permanent solution could be attained within approximately three to six months of implementation. 7-4

20 Alternative #4 Combined Continued Use and Abatement of HBM Effectiveness and Reliability This method would prevent exposure to hazardous building materials and petroleum impacted soil; however, this alternative would only partially reduce the volume of COCs at the Site. This method relies on both proper engineering controls and industry proven techniques to effectively abate and dispose of the ACM and LBP and the long-term maintenance of continued use to ensure reliability. Based on these considerations, this alternative is highly effective and reliable. Feasibility and Ease of Implementation The Site owner, Strategic Acquisitions, LLC, has plans to remodel the interior of the Site building, which will disturb ACM, LBP, and universal waste building components if left in place. This alternative will be implemented in coordination with the Owner s redevelopment plans for the Site building by removing HBM, which may be disturbed and a safety concern during renovations, such as ACM, LBP, and universal wastes, but include provisions to reuse the historically significant building materials. This alternative is technically feasible and easily implementable with a good line of communication and coordination between the involved parties. The project can be phased such that the easily disturbed building materials (i.e. ACM) can be removed prior to redevelopment, thereby minimizing the exposure risk to construction workers. Risk Reduction and Green Remediation This alternative fulfills the overall protection of human health and the environmental requirement by mitigating the exposure to ACM, LBP, and universal waste. This is not a permanent solution as it requires long term management of continued use of portions of the LBP. In addition, throughout the redevelopment, health and safety practices would have to be employed to protect workers. This alternative will rely on the use of local contractors as well as local disposal facilities that will reduce overall fuel consumption and greenhouse gas emissions for the project. Cost Effectiveness Based on prior project and contractor experience and current estimates contained in previous reports, the estimated cost to manage hazardous building materials in-place is as follows: Remedial Planning/Engineering $ 20,000 Waste Characterization $ 5,000 Abatement by Removal of ACM $110,000 Repair and Repainting of LBP $ 15,000 Universal Waste/AST Removal $ 3,000 Soil Assessment and Removal $ 1,000 HBMMP Preparation $ 2,000 Implementation of HBMMP (1) $ 10,000 Cleanup Oversight/Reporting $ 25,

21 10% Contingency $ 19,000 Total $210,000 (1) Assumes $500 net present value for annual maintenance and operations cost over 30 years with 3% annual inflation and discount rate of 3%. Estimated Time to Reach Permanent Solution Immediately following the reuse/abatement of the HBM and the receipt of any clearance sample results, the Site would meet the conditions of a temporary solution since a HBMMP would be required. A temporary solution could be attained within approximately three to six months of implementation. This assumes that the HBMMP continues to be implemented into the future. 7.3 JUSTIFICATION FOR THE SELECTED REMEDIAL ALTERNATIVE Each of the alternatives and the comparison criteria are summarized below in Table 1. Based on the evaluation of the remedial alternatives presented above, the recommended alternative is Alternative #4, the combined continued use and abatement of HBM. The combined continued use and abatement alternative was selected because it eliminates exposure while allowing the project to reuse historically significant building components and will minimize the amount of waste that will be generated during redevelopment while effectively meeting all the other comparison criteria. 7-6

22 Table 1 Summary of Remedial Alternatives for Asbestos and LBP Evaluation Criteria Alternative #1 No Action Alternative #2 Continued Use Alternative #3 Full Abatement Alternative #4 Combined Continued Use and Abatement Effectiveness & Reliability Not Effective or Reliable. Management of hazardous building materials in-place has been proven to be an effective and reliable form of remediation. It does not reduce the volume of COCs and long-term maintenance is required. Removal of hazardous building materials removes the exposure pathways and has been proven to be effective and reliable forms of remediation. Long-term maintenance is not required. Combined removal and continued use is an effective and reliable form of remediation. Exposure pathway is mostly removed. Long-term maintenance is required. Feasibility & Ease of Implementation Not feasible but easily implementable. Utilizes standard construction, remedial, abatement, and institutional control techniques. Recognizing Strategic Acquisitions, LLC has plans to significantly remodel the existing Site building, this alternative is technically practical, but not easy to implement. Utilizes standard construction, remedial, abatement, and institutional control techniques and therefore, this alternative is technically practical and easily implementable. Historically significant building materials will not be able to be reused. Utilizes standard construction, remedial, abatement, and institutional control techniques. This alternative removes some safety hazards prior to construction making this alternative easier to implement than Alternative #2 but not as easy as Alternative #3. Historically significant building materials will be reused. 7-1 ASSOCIATES, LLC CREDERE

23 Table 1 Summary of Remedial Alternatives for Asbestos and LBP Evaluation Criteria Alternative #1 No Action Alternative #2 Continued Use Alternative #3 Full Abatement Alternative #4 Combined Continued Use and Abatement Risk Reduction & Green Remediation No reduction in risks to human health and the environment. No reduction in contaminant mobility or toxicity. No green remediation benefits. Risk to human health by exposure to hazardous building components reduced, but not permanently eliminated. Risks to construction workers during redevelopment. Green remediation benefits from use of local contractors and local disposal facilities. Risk to human health by exposure to hazardous building materials are permanently eliminated by abatement/removal. Risk to human health by exposure to HBM mostly reduced, but not permanently eliminated. Risk to human health by exposure to ACM is permanently eliminated by abatement/removal. Lead exposure risks to construction workers during redevelopment. Year 2014 Costs No Cost $184,700 $191,300 $210,000 Time to Reach Permanent Solution Will not be achieved. Will not be achieved, temporary solution achieved in 2 to 4 months. 3 to 6 months Will not be achieved, temporary solution achieved in 3 to 6 months Comments Does not address risk to human health, the environment. Feasible but does not allow for unrestricted modifications to the building. Risks to construction workers during redevelopment. Feasible but does not allow for reuse of historically significant building components. Selected Alternative: This technique removes the majority of HBM while reusing historically significant building components. 7-2 ASSOCIATES, LLC CREDERE

24 8. PROPOSED REMEDIAL ACTION WORK PLAN As indicated in the previous section, combined continued use and abatement is the recommended alternative to address the COCs at the Site. Credere will coordinate and direct the performance of the selected remedial activities. This section describes activities that will be completed as part of the Site abatement. A Health and Safety Plan for completion of these activities by Credere will be prepared prior to start of construction. In addition, Credere will present the proposed sampling strategies for review and approval by USEPA under a Site-specific Quality Assurance Project Plan (SSQAPP) prior to initiation of the project. Asbestos Abatement Prior to or concurrent with the renovation of the Site building, a MassDOS licensed asbestos abatement contractor will remove and dispose of identified ACM pursuant to National Emissions Standards of Hazardous Air Pollutants (NESHAP) and the 310 CMR 7.15 of Massachusetts regulations. Air clearance samples will be collected from containment areas in accordance with 40 CFR Part 763 Appendix A and 453 CMR 6.14(5) until the testing requirements indicated in 453 CMR 6.14(5)(b)1.d. and e. are met. Additionally, Credere may collect samples from addition suspect ACM encountered during renovation/abatement activities. Lead Based Paint Management During the proposed redevelopment of the Site building, a licensed Massachusetts Lead Safe Renovator (pursuant to 454 CMR & 22.05) will be present during all renovations dealing with LBP surfaces. Contractor will properly manage LBP surfaces that are located at the Site during the redevelopment effort. Work practices shall comply with 105 CMR and 454 CMR Deleading and Lead-safe Renovation Regulations. Specific work practices shall comply with 454 CMR 22.11(9) Work Practice Requirements and 454 CMR Work Practice and Other Requirements for Deleading Projects to minimize exposure to lead by future residents and other Site workers. All LBP waste will be properly handled, transported, and disposed in accordance with the 454 CMR 22.11(9)(g) and post cleaning verification samples will be collected in accordance with 105 CMR and 454 CMR Appendix 2: Procedures for Post Renovation Cleaning Verification. Universal and Hazardous Waste Removal and Disposal All identified universal and hazardous wastes in the Site building will be removed and properly disposed by qualified personnel in accordance with 310 CMR Hazardous Waste Management Regulations, specifically Section Standards for Universal Waste Management. Soil Management Plan Currently no soil is planned for removal; however, if a pathway to the subsurface is encountered and soil screening reveals the presence of volatiles, soil will be removed using hand tools and stored onsite. Excavated soil will be sampled for waste characterization purposes prior to offsite disposal. 8-1

25 Two confirmatory soil samples will be collected from within the excavation to document soil conditions. If impacted soil above the RCS-1 soil levels are encountered and a volume exceeding the de minimus quantity of 2 cubic yards exists, then a LRA may be conducted within 120 days of discovery. If impacted soil above the RCS-1 levels remains subsequent to the LRA, then water or sub-slab vapor sampling maybe warranted, and notification to the MassDEP will be required. Additional remediation under a Release Abatement Measures Plan may be conducted, unless a MCP risk characterization indicates that a Permanent Solution has been achieved. State and Federal Permits Required The Site building is listed on the National Register of Historic Places. When federal funds are used on projects that will disturb historic structures or the ground associated with these structures, the State Historic Preservation Commission must review the project under Section 106 of the National Historic Preservation Act. This Section 106 review will be submitted and approved prior to commencement of cleanup work at the Site. Remedial Action Reporting Following the initiation of remediation activities at the Site, Credere will submit status update reports to the EPA on a monthly basis. Once complete, Credere will prepare and submit a Remedial Action Completion Report to the EPA summarizing the field activities conducted as part of the remediation effort including all applicable disposal documentation. 8-2

26 9. SUMMARY Credere developed this ABCA/RAP for the building located at 477 State Street in Springfield, Massachusetts. The purpose of this study was to evaluate potential remedial action alternatives to mitigate identified environmental conditions at the Site. Based on the findings of this study, a summary of the ABCA/RAP process is presented below: 1. Remedial action is necessary to address the ACM, LBP, universal waste, and petroleum impacted soil (if any) present within the Site building. In consideration of the Conceptual Site Model, applicable guidelines, and the nature of the specific contaminants detected, Credere evaluated four alternatives to identify the most appropriate cleanup. The four evaluated remedial alternatives were compared for effectiveness and reliability, feasibility and ease of implementation, risk reduction and green remediation, cost effectiveness, and estimated time to achieve a permanent solution. 2. The combined continued use and abatement and proper disposal of building COCs alternative has been selected as the recommended alternative because it meets all of the evaluation criteria and is the best alternatives for the Site. 3. A remedial action work plan that details the execution the removal, abatement, and proper disposal of building COCs is included in Section

27 FIGURES

28 FIGURE 1 - SITE LOCATION PLAN C RE DE RE ASS OC IATE S, LLC GRAPHIC SCALE 1 inch = 2,000 ft.

29 FIGURE 2 DETAILED SITE PLAN 10