Executive Summary. 1. Introduction Background 2

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2 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 Table of Contents Executive Summary ii 1. Introduction 1 2. Background 2 3. Inspection and Monitoring (310 CMR [2]) Type and Frequency of Operation, Maintenance and/or Monitoring Activities [310 CMR (2)(a)] Significant Modifications of the Operation, Maintenance and/or Monitoring Program [310 CMR (2)(b)] Evaluation of Performance of Remedial Action [310 CMR (2)(c)] 3 Field Investigation Activities 4 Soil Gas Sampling Results 4 Human Health Risk Characterization Measures Taken to Correct Conditions Affecting Remedial Action Performance [310 CMR (2)(d)] Name, License Number, Signature, and Seal of Licensed Site Professional [310 CMR (2)(e)] 6 4. Limitations 7 5. References 8 Tables 1. Sub-slab Soil Gas Sampling Results 2. Sub-slab Soil Gas Exposure Point Concentrations and Modeled Indoor Air Concentrations Figures 1. Site Location Map 2. Site Plan Appendices A. DEP Transmittal Form (BWSC108) and Notification to Property Owner B. Laboratory Data Report C. Human Health Risk Characterization Documentation SEO/ISG:csh M:\PROJECT\2008\08333\Reports\Post-Class C RAO SR No 2\Post-Class C RAO SR No 2 - Dedham.docx GEI Consultants, Inc. i

3 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 Executive Summary GEI prepared this Post-Class C Response Action Outcome (RAO) Status Report No. 2 for the former Hersey Products Facility at 250 Elm Street in Dedham, Massachusetts (the Site). The Massachusetts Department of Environmental Protection (DEP) issued release tracking number (RTN) for this Site. GEI has prepared the report on behalf of Grinnell LLC (Tyco), a subsidiary of Tyco International Management Company to meet the requirements specified in Section 310 CMR of the Massachusetts Contingency Plan (MCP). The 250 Elm Street property was first developed in the 1950s as a foundry and manufacturing facility for the production of brass and iron valves (Tighe & Bond, 2008). The facility operated until the mid 1980s, when the facility was closed and the property sold. A previous Site owner had the former foundry and manufacturing buildings demolished in 2001 to ready the property for proposed commercial redevelopment as an office park. The property is currently owned by Fairfield Dedham Limited Partnership and is being redeveloped as a residential apartment complex. The surrounding properties are currently commercial or residential. Remedial activities at the Site were performed by Grinnell Corporation and subsequently Grinnell LLC. Tighe & Bond of Westfield, Massachusetts on behalf of Tyco submitted a Class C-2 RAO-P for the chlorinated solvent release at the Site to the DEP on June 26, The steps required to reach a Permanent Solution at the Site are ongoing, and Tighe & Bond included a Tier II Permit Extension with their June 26, 2008 Class C-2 RAO-P statement. The steps to achieve a Permanent Solution include collecting two additional rounds of sub-slab soil gas data to represent fall and winter conditions. One round of sub-slab soil gas samples was collected in December 2008 and a second round was collected in March On May 22, 2009, DEP issued a letter to Tyco stating that DEP determined that indoor air sampling is necessary at the property. Tyco is preparing a response to DEP s letter which will be provided separately. GEI characterized the health risk to a typical first-floor resident at the Site due to potential exposure to volatile organic compounds (VOCs) in indoor air that could be emanating from beneath the building slab. Indoor air exposure point concentrations (EPC) were modeled from maximum VOC concentrations detected in sub-slab soil gas in May 2008, December 2008, and March GEI concluded there is no significant risk to a resident at the Site from exposure to VOCs modeled from sub-slab soil gas to indoor air. GEI Consultants, Inc. ii

4 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, Introduction GEI Consultants, Inc. (GEI) prepared this Post-Class C Response Action Outcome (RAO) Status Report No. 2 for the former Hersey Products Facility at 250 Elm Street in Dedham, Massachusetts (the Site) (Fig. 1). The Massachusetts Department of Environmental Protection (DEP) issued release tracking number (RTN) for this Site. The Site boundary and the Class C-2 RAO-P boundary, as delineated by Tighe & Bond of Westfield, Massachusetts, are presented on Fig. 2. This report applies to the Class C-2 RAO-P portion of the Site. The Site consists of approximately 10 acres that was previously a foundry. The Site has been redeveloped into a residential apartment complex, comprised of ten 4-story apartment buildings designated as buildings 1A, 1B, 1C, 1D, 2A, 2B, 2C, 2D, 2E, and 2F, each containing multiple single-floor apartment units. Related site improvements include a pool, cabana, surface parking, and a multi-story precast concrete parking structure located in the center of the property. GEI has prepared this report on behalf of Grinnell LLC (Tyco), a subsidiary of Tyco International Management Company to meet the requirements specified in Section 310 CMR of the Massachusetts Contingency Plan (MCP). This Report and the DEP transmittal form (BWSC108) were submitted electronically, via edep and a copy of the form is included in Appendix A. GEI Consultants, Inc. 1

5 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, Background The Site was a foundry and manufacturing facility used for the casting and production of brass and iron valves from about 1955 to Grinnell Corporation (which became Grinnell LLC) purchased the Site in 1986 and sold the property in Fairfield acquired the Site in October 2006 and has redeveloped the property for residential apartments, some of which are now occupied. Chlorinated volatile organic compounds (VOCs) were measured in Site groundwater and reported to DEP in Other contaminants were detected in soil and have been addressed through previously filed RAOs, and are not discussed further in this report. Tyco operated an air sparging and soil vapor extraction (SVE) system from December 2001 to January 2006 (Tighe & Bond, 2008). As of November 2006, the level of VOCs in groundwater was below MCP Method 1 GW2 standards with the exception of trichloroethylene (TCE) which was slightly above MCP Method 1 GW2 standards. In June 2007 a Class A-2 RAO was prepared and filed for Tyco (Tighe & Bond, 2007). In response to concerns raised by DEP, including an audit of the 2007 RAO Report, additional soil gas analyses were conducted and the risk characterization was revised to more thoroughly assess the potential for an indoor air pathway. A June 2008 Class C-2 RAO was prepared and filed for Tyco by Tighe & Bond, concluding that: (a) based on modeling of sub-slab soil gas data, a condition of No Significant Risk (NSR) exists; and (b) additional sub-slab soil gas data were necessary to validate the initial results. Tyco s current consultant, GEI, conducted sub-slab soil gas sampling on December 10, 2008 and March 5, 2009, and results of this sampling are presented in this report. On May 22, 2009, DEP issued a letter to Tyco stating that DEP determined that indoor air sampling is necessary at the property. Tyco is preparing a response to DEP s letter which will be provided separately. GEI Consultants, Inc. 2

6 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, Inspection and Monitoring (310 CMR [2]) This section summarizes the inspection and monitoring activities performed at the Site since filing the Post-Class C Status Report No. 1 on December 23, Type and Frequency of Operation, Maintenance and/or Monitoring Activities [310 CMR (2)(a)] The Class C-2 RAO was filed because additional sub-slab soil gas data were deemed to be warranted to evaluate a potential indoor air pathway at the Site. On March 5, 2009, GEI collected sub-slab soil gas samples from the 12 sub-slab ports at the Site. A total of three rounds of sub-slab soil gas data have been collected from these points: May 2008, December 2008, and March The buildings are equipped with vapor barriers and sub-slab ventilation systems which were part of the developer s typical construction design, but these systems are not required to maintain a condition of NSR to a resident at the Site from exposure to VOCs based upon the modeled potential migration of sub-slab soil gas to indoor air. The Permanent Solution Plan included in the June 2008 RAO C, stated that building occupancy and active venting status of the buildings would be presented in status reports. As of December 1, 2008, four buildings (1A, 1B, 1C, and 1D) were reported by Fairfield to be occupied, and those buildings were reported by Fairfield to have been actively vented starting prior to tenant occupancy. 3.2 Significant Modifications of the Operation, Maintenance and/or Monitoring Program [310 CMR (2)(b)] No modifications have been made to the Operation, Maintenance, and/or Monitoring (OMM) plan for the Site. DEP issued a letter to Tyco dated May 22, 2009, in which it stated indoor air sampling is necessary at the Site to demonstrate No Significant Risk and No Substantial Release Migration at the residential units at the site. 3.3 Evaluation of Performance of Remedial Action [310 CMR (2)(c)] This section discusses the additional work done by GEI, including collecting a round of sub-slab soil gas samples, and characterizing risk to a resident from potential exposure to indoor air using the May 2008, December 2008, and March 2009 sub-slab soil gas data. GEI Consultants, Inc. 3

7 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 Field Investigation Activities Prior to conducting the sub-slab soil gas sampling, the sub-slab venting system was capped and the blowers turned off. This work was done by the Site owner (Fairfield) on February 26, 2009 and observed by GEI personnel. On March 5, 2009, GEI conducted soil gas sampling at the 12 sub-slab sampling ports using the following procedure at each sampling location: 1) Open road box. 2) Record ambient VOC concentrations using a PhoCheck 5000 photoionization detector (PID) calibrated to 100 ppm isobutylene. 3) Connect sample tubing to soil gas point. 4) Measure sub-slab vacuum pressure using a digital manometer. 5) Connect PID to sample tubing for 2 minutes and record sub-slab VOC reading. 6) Connect 6-liter Summa canister to sample tubing, record time, and begin sampling. 7) Finish sampling before the canister reaches ambient pressure (approximately 1 hour). Although the flow rate through the PID sample pump was not measured, we estimated that greater than 10 volumes of tubing and screen were purged from the soil gas point prior to sampling. GEI submitted the soil gas samples to Accutest Laboratories (Accutest) in Marlborough, Massachusetts, for analysis by U.S. Environmental Protection Agency (EPA) Method TO-15 for a modified list of analytes. On February 26, 2009, GEI personnel observed Fairfield cap the vent system and turn off the blowers. During that visit, it was noted that certain vents had not yet been completed as designed. Fairfield has continued the completion of the residential units and Fairfield reports that the venting system has been completed as intended in all of the residential buildings at the Site. Soil Gas Sampling Results The laboratory results for the soil gas samples collected on March 5, 2009, are presented in Table 1, along with the results for samples collected by GEI on December 10, 2008, and by the Johnson Company of Montpelier, Vermont in May Samples were analyzed for selected chlorinated VOCs and 1,4-dioxane. The laboratory data report is included in Appendix B. The March 2009 sub-slab soil gas sample measurements were generally similar to or higher than the May and December 2008 measurements. The laboratory had to dilute many of the samples collected in March 2009 due to the presence of a tentatively identified compound (TIC), 1-chloro-1,1-difluoroethane in many of the samples at GEI Consultants, Inc. 4

8 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 concentrations that resulted in interference. GEI requested the laboratory quantify the results for this TIC in both the December 2008 and March 2009 samples. These results are in Table 1. Estimated concentrations of 1-chloro-1,1-difluoroethane in the samples ranged from non-detect to 7,800 micrograms per cubic meter (µg/m 3 ). The highest concentration was detected in the sample from JCO-1C-2. 1-Chloro-1,1-difluoroethane, also known as hydrochlorofluorocarbon 142b (HCFC-142b), is not associated with the disposal Site; it is likely associated with the recent and ongoing building construction. This compound has low inhalation toxicity and the maximum estimated concentration (7,800 µg/m 3 ) does not result in significant health risk from this compound. According to the EPA's Integrated Risk Information System (IRIS) database, HCFC-142b has a No Observed Adverse Effects Level of 82,620,000 µg/m 3. Human Health Risk Characterization GEI characterized risk to a resident aged 1 to 31 years old at the Site from potential exposure to VOCs in indoor air because there is potential for VOCs detected in sub-slab soil gas samples to migrate to indoor air via subsurface vapor intrusion. The EPA Johnson & Ettinger (J&E) advanced soil gas model (2004) was used to estimate potential indoor air concentrations of VOCs. Indoor air exposure point concentrations (EPC) were modeled from maximum VOC concentrations detected in sub-slab soil gas in May 2008, December 2008, and March Modeled indoor air EPCs were based on slab construction with a slab thickness of 5 inches and an enclosed space measuring 33 feet by 33 feet by 9 feet based on the 1-story units currently present at the Site. All other model inputs were conservatively set equal to DEP model inputs used to develop the MCP Method 1 GW2 groundwater standards. Table 2 presents the maximum sub-slab soil gas exposure point concentrations and modeled indoor air concentrations for the December 2008, May 2008, and March 2009 sampling rounds. Three compounds (1,1-dichloroethylene, trans-1,2-dichloroethylene, and 1,1,2-trichloroethane) which were previously detected in sub-slab soil gas in May and December 2008 were not detected in March For these three compounds, indoor air concentrations for March 2009 were modeled using one-half the maximum detection limit shown in Table 2. Compounds that were not detected in at least one sub-slab soil gas sample were not included as chemicals of potential concern. GEI conservatively assumed that a resident was present indoors at the Site for 24-hours per day for up to 30 years to evaluate non-cancer and cancer risk. GEI concluded there is NSR to a resident at the Site from exposure to VOCs modeled from sub-slab soil gas to indoor air. Human health risk estimates based on the March 2009 sub-slab soil gas data and supporting documentation are provided in Appendix C. Excess Lifetime Cancer Risk (ELCR) to a resident is 3.4E-6 based on maximum VOC concentrations measured in sub-slab soil gas in March The Non-cancer Total Hazard Index (THI) for a resident is 0.02 based on maximum VOC GEI Consultants, Inc. 5

9 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 concentrations measured in sub-slab soil gas in March Therefore, risk estimates are below DEP cumulative risk limits of 1E-5 for ELCR and 1 for THI. Human health risk estimates based on the May and December 2008 sub-slab soil gas data and supporting documentation are provided in Appendix D of the Post-Class C RAO Status Report No. 1 (GEI, 2008). In this report, GEI concluded that there was NSR to a resident at the Site from exposure to VOCs modeled from May and December 2008 sub-slab soil gas to indoor air. ELCR to a resident was 2.2E-6 based on maximum VOC concentrations measured in sub-slab soil gas in May 2008 and 6.6E-6 based on maximum VOC concentrations measured in sub-slab soil gas in December The Non-cancer THI for a resident was 0.01 based on maximum VOC concentrations measured in sub-slab soil gas in May 2008 and 0.04 based on maximum VOC concentrations measured in sub-slab soil gas in December Residential buildings at the Site are equipped with vapor barriers and sub-slab ventilation systems. However, these systems are not required to maintain a condition of NSR because the risk characterization was based on sub-slab soil gas samples collected below the vapor barrier while the ventilation system had been capped and turned off for 7 days prior to sampling. Subslab soil gas samples collected below the vapor barrier were modeled to indoor air assuming that no vapor barrier was present. 3.4 Measures Taken to Correct Conditions Affecting Remedial Action Performance [310 CMR (2)(d)] No measures have been taken or were necessary during this reporting period to correct conditions affecting remedial action performance. 3.5 Name, License Number, Signature, and Seal of Licensed Site Professional [310 CMR (2)(e)] The Licensed Site Professional (LSP) for the Site is Ileen S. Gladstone, P.E., LSP, LEED AP (LSP License No. 9719). The signature and seal of the LSP are provided in DEP transmittal form BWSC108 (Appendix A). GEI Consultants, Inc. 6

10 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, Limitations This report was prepared for the use of Tyco, exclusively. The conclusions presented in this report are based solely on the information reported in this document and previous reports prepared for this Site by GEI. Additional quantitative information regarding the Site, not available to GEI, may result in a modification of the findings herein. This submittal has been prepared in accordance with generally accepted geohydrological practices. No warranty, expressed or implied, is made. GEI Consultants, Inc. 7

11 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, References Tighe & Bond, Phase V Completion and Response Action Outcome Report, Former Hersey Products, 250 Elm Street, Dedham, MA, RTN , prepared for Tyco International formerly Grinnell Corporation, June 11. Tighe & Bond, Revised Response Action Outcome Report, Former Hersey Products, 250 Elm Street, Dedham, MA, RTN , prepared for Tyco International formerly Grinnell Corporation, June 26. GEI Consultants, Inc. 8

12 Table 1 Sub-slab Soil Gas Sampling Results 250 Elm Street Dedham, Massachusetts Sample Location: Sample ID: JCO-1A-1 JCO-1A-1 JCO-1A-2 JCO-1A-2 JCO-1A-2R JCO-1A-2R JCO-1B-1 JCO-1B-1 JCO-1C-1 JCO-1C-1 Screen Depth (inches): Well Diameter (inches): Slab Thickness for JCO Points (inches): Date Installed: 5/22/ /22/08 12/04/08 5/22/2008 5/22/2008 Sample Date: 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 Method: TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 Analyte Unit Volatile Organic Compounds (VOCs) µg/m 3 Chloroethane NT < 0.53 NT NT < 0.53 NT NT < 0.53 NT NT < 0.53 NT Carbon tetrachloride NT < 1.3 NT NT < 1.3 NT NT < 1.3 NT NT < 1.3 NT 1,1-Dichloroethane 0.34 < 0.81 < < < < 0.81 < 1.6 1,1-Dichloroethylene 0.14 < 0.79 < < 0.79 < < 0.79 < < 0.79 < 1.6 1,2 Dichloroethane NT < 0.81 < 8.1 NT < 0.81 < 8.1 NT < 0.81 < 8.1 NT < 0.81 < 1.6 1,4-Dioxane < 0.57 < 1.8 < 18 < 2.9 < 1.8 < 18 < 1.0 < 1.8 < 18 < 0.93 < 1.8 < 3.6 trans-1,2 Dichloroethylene NT < 0.79 < 7.9 NT < 0.79 < 7.9 NT < 1.3 < 7.9 NT < 0.79 < 1.6 cis-1,2-dichloroethylene 0.25 < 0.79 < 7.9 < 0.64 < 0.79 < < < 0.79 < 1.6 1,1,1-Trichloroethane (TCA) < ,1,2-Trichloroethane < 0.17 NT < 11 < 0.88 NT < 11 < 0.31 NT < 11 < 0.28 NT < 2.2 Tetrachloroethylene (PCE) Trichloroethylene (TCE) < < Vinyl Chloride < 0.4 < 0.51 < 5.1 < 0.20 < 0.51 < < 0.51 < < 0.51 < 1.0 Tentatively Indentified Compounds (TICs) ppbv 1-chloro-1,1-difluoro-ethane NT 10 J 4100 J N NT 10 J 3100 J NT 190 J 3700 J NT 410 J 670 J N General Notes: 1. Detected analytes shown in bold. 2. NT = sample not tested for this analyte. 3. ND = Not detected. 4. µg/m 3 = micrograms per cubic meter 5. ppbv = parts per billion by volume 6. < 2.0 = Analyte not detected at reporting limit shown. 7. Screen depths are shown as depth beneath bottom of slab in inches. 8. Samples in May 2008 collected by the Johnson Company. Samples in December 2008 and March 2009 collected by GEI Consultants, Inc. 9. Other TICs were identified by the laboratory but are not shown on this table. For details refer to laboratory report. Qualifying Notes: J Estimated value. N Presumptive evidence of compound. GEI Consultants, Inc. Project Page 1 of 3 June 2009 M:\PROJECT\2008\08333\Tables & Lab Data\T1 JCOpts soil gas data xls

13 Table 1 Sub-slab Soil Gas Sampling Results 250 Elm Street Dedham, Massachusetts Sample Location: Sample ID: Screen Depth (inches): Well Diameter (inches): Slab Thickness for JCO Points (inches): Date Installed: Sample Date: Method: Analyte Unit Volatile Organic Compounds (VOCs) µg/m 3 Chloroethane Carbon tetrachloride 1,1-Dichloroethane 1,1-Dichloroethylene 1,2 Dichloroethane 1,4-Dioxane trans-1,2 Dichloroethylene cis-1,2-dichloroethylene 1,1,1-Trichloroethane (TCA) 1,1,2-Trichloroethane Tetrachloroethylene (PCE) Trichloroethylene (TCE) Vinyl Chloride Tentatively Indentified Compounds (TICs) 1-chloro-1,1-difluoro-ethane ppbv JCO-1C-2 JCO-1C /22/2008 JCO-1C-2 JCO JCO-1D-1 JCO-1D JCO-1D-2 JCO-1D JCO-2B-1 JCO-2B /22/08 5/22/2008 5/22/2008 5/22/ /30/08 12/10/08 03/05/09 03/05/09 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 TO-15 Mod. TO-15 TO-15 TO-15 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 NT 0.79 NT NT NT 3.2 NT NT < 0.53 NT NT < 0.53 NT NT < 1.3 NT NT NT < 1.3 NT NT < 1.3 NT NT < 1.3 NT < 8.1 < < 0.81 < < < 0.79 < 7.9 < < 0.79 < < 0.79 < < 0.79 < 7.9 NT < 0.81 < 8.1 < 8.1 NT < 0.81 < 8.1 NT < 0.81 < 4.0 NT < 0.81 < 8.1 < 0.37 < 1.8 < 18 < 18 < 0.75 < 1.8 < 18 < 2.5 < 1.8 < 9.0 < 1.4 < 1.8 < 18 NT < 0.79 < 7.9 < 7.9 NT < 0.79 < 7.9 NT < 0.79 < 4.0 NT < 0.79 < < 7.9 < < 0.79 < 7.9 < 0.54 < 0.79 < < 0.79 < < < 0.41 NT < 11 < 11 < 0.23 NT < 11 < 0.75 NT < 5.5 < 0.43 NT < < < < 0.51 < 5.1 < < 0.51 < 5.1 < 0.17 < 0.51 < 2.6 < 0.10 < 0.51 < 5.1 NT 160 J 7800 J N 4200 J NT 420 J 130 J NT 390 J 50 J NT 10 J 4800 J General Notes: 1. Detected analytes shown in bold. 2. NT = sample not tested for this analyte. 3. ND = Not detected. 4. µg/m 3 = micrograms per cubic meter 5. ppbv = parts per billion by volume 6. < 2.0 = Analyte not detected at reporting limit shown. 7. Screen depths are shown as depth beneath bottom of slab in inches. 8. Samples in May 2008 collected by the Johnson Company. Samples in December 2008 and March 2009 collected by GEI Consultants, Inc. 9. Other TICs were identified by the laboratory but are not shown on this table. For details refer to laboratory report. Qualifying Notes: J Estimated value. N Presumptive evidence of compound. GEI Consultants, Inc. Project Page 2 of 3 June 2009 M:\PROJECT\2008\08333\Tables & Lab Data\T1 JCOpts soil gas data xls

14 Table 1 Sub-slab Soil Gas Sampling Results 250 Elm Street Dedham, Massachusetts Sample Location: Sample ID: Screen Depth (inches): Well Diameter (inches): Slab Thickness for JCO Points (inches): Date Installed: Sample Date: Method: Analyte Unit Volatile Organic Compounds (VOCs) µg/m 3 Chloroethane Carbon tetrachloride 1,1-Dichloroethane 1,1-Dichloroethylene 1,2 Dichloroethane 1,4-Dioxane trans-1,2 Dichloroethylene cis-1,2-dichloroethylene 1,1,1-Trichloroethane (TCA) 1,1,2-Trichloroethane Tetrachloroethylene (PCE) Trichloroethylene (TCE) Vinyl Chloride Tentatively Indentified Compounds (TICs) 1-chloro-1,1-difluoro-ethane ppbv JCO-2D-1 JCO-2E-1 JCO-2E-1 JCO-2F-1 JCO-2F-2 JCO-2D-1 JCO-2F-1 JCO-2F /22/2008 5/22/2008 5/22/2008 5/22/ /30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 05/30/08 12/10/08 03/05/09 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 TO-15 Mod. TO-15 TO-15 NT < 0.53 NT NT 1.8 NT NT 0.95 NT NT 6.1 NT NT < 1.3 NT NT < 1.3 NT NT < 1.3 NT NT < 1.3 NT < < < < 0.79 < < < 0.79 < < 7.9 NT < 0.81 < 8.1 NT < 0.81 < 8.1 NT < 0.81 < 8.1 NT < 0.81 < 8.1 < 6.0 < 1.8 < 18 < 3.8 < 1.8 < 18 < 0.52 < 1.8 < 18 <2.3 < 1.8 < 18 NT < 0.79 < 7.9 NT 15 < 7.9 NT 1.5 < 7.9 NT 5.2 < < < 1.8 NT < 11 < 1.2 NT < 11 < 0.16 NT < NT < < 0.51 < < < < 5.1 NT 500 J 1100 J NT 490 J 3200 J NT 110 J 4000 J NT 230 J 3700 J General Notes: 1. Detected analytes shown in bold. 2. NT = sample not tested for this analyte. 3. ND = Not detected. 4. µg/m 3 = micrograms per cubic meter 5. ppbv = parts per billion by volume 6. < 2.0 = Analyte not detected at reporting limit shown. 7. Screen depths are shown as depth beneath bottom of slab in inches. 8. Samples in May 2008 collected by the Johnson Company. Samples in December 2008 and March 2009 collected by GEI Consultants, Inc. 9. Other TICs were identified by the laboratory but are not shown on this table. For details refer to laboratory report. Qualifying Notes: J Estimated value. N Presumptive evidence of compound. GEI Consultants, Inc. Project Page 3 of 3 June 2009 M:\PROJECT\2008\08333\Tables & Lab Data\T1 JCOpts soil gas data xls

15 Table 2 Sub-slab Soil Gas Exposure Point Concentrations and Modeled Indoor Air Concentrations 250 Elm Street Dedham, Massachusetts Maximum Sub-slab Soil Gas Concentration from May 2008 Modeled Indoor Air Concentration For Slab Construction May 2008 Maximum Sub-slab Soil Gas Concentration from December 2008 Modeled Indoor Air Concentration For Slab Construction December 2008 Maximum Sub-slab Soil Gas Concentration from March 2009 Sample Depth Below Slab: 6.7 inches (17 cm) 6.7 inches (17 cm) 6.7 inches (17 cm) Modeled Indoor Air Concentration For Slab Construction March 2009 MADEP Indoor Air Threshold Values Analytical Reporting Limits Depth Below Enclosed Space: 11.7 inches includes 5 inch slab (30 cm) 11.7 inches includes 5 inch slab (30 cm) 11.7 inches includes 5 inch slab (30 cm) Analyte µg/m 3 µg/m 3 µg/m 3 µg/m 3 µg/m 3 µg/m 3 µg/m 3 µg/m 3 Volatile Organic Compounds (VOCs) Chloroethane NT NT NT NT NA NA 1,1-Dichloroethane ,1-Dichloroethylene < cis-1,2-dichloroethylene trans-1,2-dichloroethylene NT NT < Tetrachloroethylene (PCE) ,1,1-Trichloroethane (TCA) ,1,2-Trichloroethane NT NT < Trichloroethylene (TCE) Vinyl chloride General Notes: 1. NT = Samples not tested for this analyte. 2. NA = No Standard established for this analyte. 3. µg/m 3 = micrograms per cubic meter. 4. cm = centimeters. 5. "<" = The analyte was not detected at a concentration above the specified reporting limit. 6. Indoor air concentrations were modeled using maximum detected sub-slab soil gas concentrations in May 2008, December 2008 and March Tighe & Bond (2008) included soil vapor samples collected outside the building in their dataset therefore modeled sub-slab soil gas concentrations for May 2008 for cis-1,2-dce and 1,1,2 TCA are different than values modeled in the Tighe & Bond report. 7. In March 2009, three compounds (1,1-dichloroethylene, trans-1,2-dichlorothylene, and 1,1,2-trichloroethane) were not detected and maximum detection limits are presented. For these three compounds, indoor air concentrations were modeled using one-half the maximum detection limit shown. 8. Indoor air concentrations were modeled using the Johnson & Ettinger (J&E) advanced soil gas model (February 2004). 9. Using the J&E model, we assumed slab construction and enclosed space dimensions of 33 ft X 33 ft X 9 ft. All other model inputs were set equal to Massachusetts Department of Environmental Protection (DEP) GW2 inputs. The only inputs to the J&E model that are different than inputs presented by Tighe & Bond are the slab thickness. Tighe & Bond used 8.3 inches for slab thickness and we conservatively used 5 inches, which is the average slab thickness for the sample locations with maximum concentrations detected in sub-slab soil gas in Dec As a result of different inputs for slab thickness, the Tighe & Bond attenuation factor for PCE is 2.5E-3 and our calculated attenuation factor is 2.6E DEP Indoor Air Threshold Values and Laboratory Reporting Limits from Draft Technical Update June 26, GEI Consultants, Inc. Project Page 1 of 1 June 2009 M:\PROJECT\2008\08333\Tables & Lab Data\T2 EPCs soil gas data MayDecMarch.xls

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18 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 Appendix A DEP Transmittal Form (BWSC108) and Notification to Property Owner GEI Consultants, Inc.

19 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR (Subpart D) and (Subpart H) BWSC108 Release Tracking Number A. SITE LOCATION: 1. Site Name: HERSEY PRODUCTS INC 2. Street Address: 250 ELM ST 3. City/Town: DEDHAM 4. ZIP Code: Check here if a Tier Classification Submittal has been provided to DEP for this disposal site. a. Tier IA b. Tier IB c. Tier IC d. Tier II 6. If applicable, provide the Permit Number: B. THIS FORM IS BEING USED (check all that apply) 1. Submit a Phase I Completion Statement, pursuant to 310 CMR Submit a Revised Phase I Completion Statement, pursuant to 310 CMR Submit a Phase II Scope of Work, pursuant to 310 CMR Submit an interim Phase II Report. This report does not satisfy the response action deadline requirements in 310 CMR Submit a final Phase II Report and Completion Statement, pursuant to 310 CMR Submit a Revised Phase II Report and Completion Statement, pursuant to 310 CMR Submit a Phase III Remedial Action Plan and Completion Statement, pursuant to 310 CMR Submit a Revised Phase III Remedial Action Plan and Completion Statement, pursuant to 310 CMR Submit a Phase IV Remedy Implementation Plan, pursuant to 310 CMR Submit a Modified Phase IV Remedy Implementation Plan, pursuant to 310 CMR Submit an As-Built Construction Report, pursuant to 310 CMR Submit a Phase IV Status Report, pursuant to 310 CMR Submit a Phase IV Completion Statement, pursuant to 310 CMR and Specify the outcome of Phase IV activities: (check one) a. Phase V Operation, Maintenance or Monitoring of the Comprehensive Remedial Action is necessary to achieve a Response Action Outcome. b. The requirements of a Class A Response Action Outcome have been met. No additional Operation, Maintenance or Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report (BWSC104) will be submitted to DEP. c. The requirements of a Class C Response Action Outcome have been met. No additional Operation, Maintenance or Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report (BWSC104) has been or will be submitted to DEP. d. The requirements of a Class C Response Action Outcome have been met. Further Operation, Maintenance or Monitoring of the remedial action is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution. A completed Response Action Outcome Statement and Report (BWSC104) has been or will be submitted to DEP. Revised: 4/1/2009 Page 1 of 5

20 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR (Subpart D) and (Subpart H) BWSC108 Release Tracking Number B. THIS FORM IS BEING USED TO (cont.):(check all that apply) 14. Submit a Revised Phase IV Completion Statement, pursuant to 310 CMR and Submit a Phase V Status Report, pursuant to 310 CMR Submit a Remedial Monitoring Report. (This report can only be submitted through edep.) a. Type of Report: (check one) i. Initial Report ii. Interim Report iii. Final Report b. Frequency of Submittal: (check all that apply) i. A Remedial Monitoring Report(s) submitted monthly to address an Imminent Hazard. ii. A Remedial Monitoring Report(s) submitted monthly to address a Condition of Substantial Release Migration. iii. A Remedial Monitoring Report(s) submitted concurrent with a Status Report. c. Status of Site: (check one) i. Phase IV ii. Phase V d. Number of Remedial Systems and/or Monitoring Programs: iii. Remedy Operation Status iv. Class C RAO A separate BWSC108A, CRA Remedial Monitoring Report, must be filled out for each Remedial System and/or Monitoring Program addressed by this transmittal form. 17. Submit a Remedy Operation Status, pursuant to 310 CMR Submit a Status Report to maintain a Remedy Operation Status, pursuant to 310 CMR (2). 19. Submit a Transfer and/or a Modification of Persons Maintaining a Remedy Operation Status (ROS), pursuant to 310 CMR (5) (check one, or both, if applicable). a. Submit a Transfer of Persons Maintaining an ROS (the transferee should be the person listed in Section D, "Person Undertaking Response Actions"). b. Submit a Modification of Persons Maintaining an ROS (the primary representative should be the person listed in Section D, "Person Undertaking Response Actions"). c. Number of Persons Maintaining an ROS not including the primary representative: 20. Submit a Termination of a Remedy Operation Status, pursuant to 310 CMR (6).(check one) a. Submit a notice indicating ROS performance standards have not been met. A plan and timetable pursuant to 310 CMR (6)(b) for resuming the ROS are attached. b. Submit a notice of Termination of ROS. 21. Submit a Phase V Completion Statement, pursuant to 310 CMR Specify the outcome of Phase V activities: (check one) a. The requirements of a Class A Response Action Outcome have been met. No additional Operation, Maintenance or Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC104) will be submitted to DEP. b. The requirements of a Class C Response Action Outcome have been met. No additional Operation, Maintenance or Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report (BWSC104) will be submitted to DEP. c. The requirements of a Class C Response Action Outcome have been met. Further Operation, Maintenance or Monitoring of the remedial action is necessary to ensure that conditions are maintained and/or that further progress is made toward a Permanent Solution. A completed Response Action Outcome Statement and Report (BWSC104) will be submitted to DEP. 22. Submit a Revised Phase V Completion Statement, pursuant to 310 CMR Submit a Post-Class C Response Action Outcome Status Report, pursuant to 310 CMR Revised: 4/1/2009 Page 2 of 5

21 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR (Subpart D) and (Subpart H) BWSC108 Release Tracking Number C. LSP SIGNATURE AND STAMP: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR 4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief, > if Section B indicates that a Phase I, Phase II, Phase III, Phase IV or Phase V Completion Statement and/or a Termination of a Remedy Operation Status is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR , (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR , and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal; > if Section B indicates that a Phase II Scope of Work or a Phase IV Remedy Implementation Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR , (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR , and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal; > if Section B indicates that an As-Built Construction Report, a Remedy Operation Status, a Phase IV, Phase V or Post-Class C RAO Status Report, a Status Report to Maintain a Remedy Operation Status, a Transfer or Modification of Persons Maintaining a Remedy Operation Status and/or a Remedial Monitoring Report is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR , (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR , and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal. I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete. 1. LSP #: First Name: ILEEN S 3. Last Name: GLADSTONE 4. Telephone: (781) Ext.: 6. FAX: 7. Signature: 8. Date: (mm/dd/yyyy) 9. LSP Stamp: Revised: 4/1/2009 Page 3 of 5

22 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR (Subpart D) and (Subpart H) BWSC108 Release Tracking Number D. PERSON UNDERTAKING RESPONSE ACTIONS: 1. Check all that apply: a. change in contact name 2. Name of Organization: TYCO INTERNATIONAL (US) INC b. change of address c. change in the person undertaking response actions 3. Contact First Name: ROBERT 4. Last Name: FRANTZ 9 ROSZEL RD VICE PRESIDENT-EHS 5. Street: 6. Title: 7. City/Town: PRINCETON NJ State: 9. ZIP Code: 10. Telephone: (609) Ext.: 12. FAX: E. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTIONS: 1. RP or PRP a. Owner b. Operator c. Generator e. Other RP or PRP Specify: OTHER PRPS d. Transporter Check here to change relationship 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2) 3. Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s. 5(j)) 4. Any Other Person Undertaking Response Actions Specify Relationship: F. REQUIRED ATTACHMENT AND SUBMITTALS: 1. Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof. 2. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of any Phase Reports to DEP. 3. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the availability of a Phase III Remedial Action Plan. 4. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the availability of a Phase IV Remedy Implementation Plan. 5. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of any field work involving the implementation of a Phase IV Remedial Action. 6. If submitting a Transfer of a Remedy Operation Status (as per 310 CMR (5)), check here to certify that a statement detailing the compliance history for the person making this submittal (transferee) is attached. 7. If submitting a Modification of a Remedy Operation Status (as per 310 CMR (5)), check here to certify that a statement detailing the compliance history for each new person making this submittal is attached. 8. Check here if any non-updatable information provided on this form is incorrect, e.g. Site Name. Send corrections to: BWSC.eDEP@state.ma.us. 9. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached. Revised: 4/1/2009 Page 4 of 5

23 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR (Subpart D) and (Subpart H) G. CERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTIONS: BWSC108 Release Tracking Number I,, attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information. >if Section B indicates that this is a Modification of a Remedy Operation Status (ROS), I attest under the pains and penalties of perjury that I am fully authorized to act on behalf of all persons performing response actions under the ROS as stated in 310 CMR (5)(d) to receive oral and written correspondence from MassDEP with respect to performance of response actions under the ROS, and to receive a statement of fee amount as per 4.03(3). I understand that any material received by the Primary Representative from MassDEP shall be deemed received by all the persons perform ing response actions under the ROS, and I am aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate or incomplete information. 2. By: Signature 3. Title: VICE PRESIDENT-EHS 4. For: TYCO INTERNATIONAL (US) INC (Name of person or entity recorded in Section D) 5. Date: (mm/dd/yyyy) 6. Check here if the address of the person providing certification is different from address recorded in Section D. 7. Street: 8. City/Town: 9. State: 10. ZIP Code: 11. Telephone: 12. Ext.: 13. FAX: YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE. Date Stamp (DEP USE ONLY:) Revised: 4/1/2009 Page 5 of 5

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28 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 Appendix B Laboratory Data Report GEI Consultants, Inc.

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78 Post-Class C RAO Status Report No. 2 Former Hersey Products, 250 Elm Street, Dedham, MA Tyco International Management Company June 24, 2009 Appendix C Human Health Risk Characterization Documentation GEI Consultants, Inc.

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