SECOND FIVE-YEAR REVIEW REPORT FOR
FLETCHER'S PAINT WORKS & STORAGE FACILITY SUPERFUND SITE
HILLSBOROUGH COUNTY, NEW HAMPSHIRE
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Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS 2
I. INTRODUCTION 4
FIVE-YEAR REVIEW SUMMARY FORM 7
II. RESPONSE ACTION SUMMARY 7
Basis for Taking Action 7
Response Actions 8
Status of Implementation 13
Institutional Controls 15
Systems Operations/Operation & Maintenance (O&M) 18
III. PROGRESS SINCE THE PREVIOUS REVIEW 19
IV. FIVE-YEAR REVIEW PROCESS 21
Community Notification. Community Involvement and Site Interviews 21
Data Review 21
Site Inspection 25
V. TECHNICAL ASSESSMENT 26
QUESTION A: Is the remedy functioning as intended by the decision documents'.' 26
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid'.' 29
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy'.' 37
VI. ISSUES/RECOMMENDATIONS 37
Other Findings 38
VII. PROTECTIVENESS STATEMENT 39
VIII. NEXT REVIEW 40
APPENDIX A - REFERENCE LIST A-l
APPENDIX B - SITE CHRONOLOGY B-l
APPENDIX C - PRESS RELEASE C-l
APPENDIX D - INTERVIEW FORMS D-l
APPENDIX E - DATA REVIEW SUPPORTING DOCUMENTATION E-l
APPENDIX F - SITE INSPECTION CHECKLIST F-l
APPENDIX G - SITE PHOTOGRAPHS G-l
APPENDIX H - ARARS REVIEW H-l
APPENDIX I - VISL CALCULATOR OUTPUT I-1
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LIST OF ABBREVIATIONS & ACRONYMS
ADAF
Age-Dependent Potency Adjustment Factor
ACQS
Ambient Groundwater Quality Standard
ALM
Adult Lead Methodology
ARAR
Applicable or Relevant and Appropriate Requirement
ATSDR
Agency for Toxic Substances and Disease Registry
BLL
Blood Lead Level
CASRN
Chemical Abstracts Service Registry Number
CERCLA
Comprehensive Environmental Response. Compensation, and Liability Act
CFR
Code of Federal Regulations
CIC
Community Involvement Coordinator
COC
Contaminant of Concern
CSF
Cancer Slope Factor
DNAPL
Dense Non-Aqueous Phase Liquid
EMP
Environmental Monitoring Plan
EMR
Environmental Monitoring Report
EPA
United States Environmental Protection Agency
ESD
Explanation of Significant Differences
ESV
Ecological Screening Value
ETBE
Ethyl Tertiary Butyl Ether
FS
Feasibility Study
FYR
Five-Year Review
GE
General Electric
GMP
Groundwater Management Zone Permit
GMZ
Groundwater Management Zone
HA
Health Advisory
HFPO-DA
Hexafluoropropylene Oxide Dimer Acid (Gen-X)
HHRA
Human Health Risk Assessment
IC
Institutional Control
ICL
Interim Cleanup Level
ILCR
Increased Lifetime Cancer Risk
IRIS
Integrated Risk Information System
IIJR
Inhalation Unit Risk
Hg/dL
Micrograms per Deciliter
PLg/L
Micrograms per Liter
MCL
Maximum Contaminant Level
MCLG
Maximum Contaminant Level Goal
mg/kg
Milligrams per Kilogram
mg/kg-day
Milligrams per Kilogram per Day
mg/L
Milligrams per Liter
MNA
Monitored Natural Attenuation
MRL
Minimal Risk Level
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NA
Not Applicable
ND
Not Detected
ng/L
Nanograms per Liter
NHDES
New Hampshire Department of Environmental Services
NPL
National Priorities List
NTCRA
Non-Time-Critical Removal Action
O&M
Operation and Maintenance
OHHRRAF
OLEM's Human Health Regional Risk Assessment Forum
OLEM
Office of Land and Emergency Management
OU
Operable Unit
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PAH
Polycyclic Aromatic Hydrocarbon
PCB
Polychlorinated Biphenyl
PFAS
Per- and Polyfluoroalkyl Substances
PFBS
Perfluorobutajie Sulfonic Acid
PFHxS
Perfluorohexane Sulfonate
PFNA
PerfluorononaJioic Acid
PFOA
Perfluorooctanoic Acid
PFOS
Perfluorooctanesulfonic Acid
PPb
Parts per Billion
PPm
Parts per Million
PPRTV
Provisional Peer Reviewed Toxicity Value
PRC
Preliminary Removal Goal
ppt
Parts per Trillion
RAO
Remedial Action Objectives
RDX
Hexahydro-1,3,5 -trinitro-1,3,5 -triazine
RfC
Reference Concentration
RfD
Reference Dose
RI
Remedial Investigation
ROD
Record of Decision
RPM
Remedial Project Manager
RSL
Regional Screening Level
SL
Screening Level
TBC
To Be Considered
TCE
T richloroethylene
TCL/TAL
Target Compound List/Target Analyte List
UAO
Unilateral Administrative Order
USAGE
U.S. Army Corps of Engineers
UU/UE
Unlimited Use and Unrestricted Exposure
VISL
Vapor Intrusion Screening Level
VOC
Volatile Organic Compound
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I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR reports such as this one. In addition. FYR reports
identify issues found during the review, if any, and document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response. Compensation, and Liability Act (CERCLA) Section 121. consistent with the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section
300.430(f)(4)(ii)) and considering EPA policy.
This is the second FYR for the Fletcher's Paint Works & Storage Facility Superfund site (Site). The triggering
action for this statutory review is the completion date of the previous FYR. The FYR has been prepared because
hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and
unrestricted exposure (UU/UE).
The Site consists of two operable units (OlJs). OU 1 consists of the primary source areas of contamination and
groundwater under these areas. It includes:
• The former Fletcher's Paint Works at 39 Elm Street (Elm Street Area).
• The former Fletcher's Paint Works storage facility, on the north side of Mill Street (Mill Street Area).
• A drainage ditch/culvert system that extends north from the Mill Street Pond, past the Mill Street Area
and through the Elm Street Area to the Souhegan River.
• Groundwater contamination that extends from the Mill Street Area through the Elm Street Area to the
Souhegan River.
OU2 focuses on areas where contamination has migrated from the OlJ 1 areas. It includes:
• The portion of the Souhegan River adjacent to the Reyes Memorial Park (Keyes Field) and Elm Street
Area downstream to the Goldman Dam.
• Groundwater under the Keyes Field.
This FYR Report addresses both OlJs.
EPA remedial project manager (RPM) Emma Forbes led the FYR. Participants from EPA included risk assessors
Valerie Bataille and Paulina Do. attorney RuthAnn Sherman and community involvement coordinator (CIC)
Ashlin Brooks. Other participants included Andrew Hoffman, P.E. and Brian Thornton, from the New Hampshire
Department of Environmental Services (NHDES). kirby Webster and Jill Billus from EPA support contractor
Skeo. The responsible party. General Electric (GE). was notified of the initiation of the FYR. The review began
on June 30, 2022.
Appendix A includes a list of documents reviewed for this FYR. Appendix B provides a chronology of site
events.
Site Background
The Site is in the town of Milford in Hillsborough County. New Hampshire (Figure 1). Fletcher's Paint Works
made and sold paints and stains on site from 1949 to 1991. The former Fletcher's Paint Works operation consisted
of two areas, considered the primary source areas of contamination: a paint manufacturing plant and retail outlet
on Elm Street (Elm Street Area) and a storage shed area on Mill Street (Mill Street Area) (Figure 1). During
operations, hundreds of drums of hazardous substances were stored outside at both the Elm Street Area and the
Mill Street Area. Spills, leaks, manufacturing operations and dust suppression activities contaminated soil.
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groundwater and nearby sediments in the Souhegan River primarily with polychlorinated biphenyls (PCBs) and
volatile organic compounds (VOCs).1
The Site is less than a quarter mile from downtown Milford. in a densely populated residential, commercial and
industrial area (Figure 1). Homes and businesses closest to the Site use the municipal water supply.
The Elm Street Area, currently ow ned by the tow n of Milford (the Tow n), covers about 1.6 acres of land along the
south bank of the Souhegan River. A historic cemetery is to the east. Route 101A (Elm Street) is to the south, and
Reyes Drive, the entrance to the Reyes Field, a recreation complex, is to the west (Figure 1). Across the river
from the Elm Street Area is the Boys and Girls Club of Souhegan Valley. A pedestrian footbridge extends across
the river from Reyes Field to the Boys and Girls Club property. After cleanup of the Elm Street Area (consisting
of soil and river sediment removal and the construction of an engineered cap), the area was redeveloped with a
parking lot for Reyes Field and a granite amphitheater.
The 0.25-acre Mill Street Area is 700 feet south of the Elm Street Area. It is bounded by an active railroad line to
the north, by Cottage Street to the east, by Mill Street to the south, and the former Draper Fuel Company coal
yard (now a gravel covered, undeveloped lot) to the west. Residences are to the south and west. Commercial areas
are to the north, east and northwest. The Mill Street Area is a grassed open space. Boulders used as visual barriers
line the southern border of the area. The Town currently owns the Mill Street Area property.
Mill Street Pond is about 250 feet southwest of the Mill Street Area. Surface water and storm water are conveyed
from the Mill Street Pond to the Souhegan River via a drainage ditch and series of culverts under Mill Street,
under the railroad tracks to the north of the Mill Street Area, and under Elm Street and the eastern part of the Elm
Street Area, where the system discharges to the Souhegan River via an outfall. This drainage system is part of
OU1.
Groundwater at the Site occurs in an unconfined overburden water-bearing unit, a permeable shallow bedrock
zone, and a low-permeability deep bedrock unit. The unconfined overburden contains both a thick outwash layer
containing dense, stratified sand and gravel with silty layers and occasional cobbles and boulders, overlain by fill
material, consisting of loose to medium dense silty sand with gravel zones and occasional layers of organic silt. In
the Mill Street Area, the outwash layer is approximately 10-16ft thick, overlain by 6-10ft of fill material. In the
Elm Street Area, the outwash layer is approximately 12-28 ft thick, overlain by 14-26 ft of fill material.
Groundwater flow direction in the overburden and shallow bedrock units near the Site is generally north to
northwest, toward the Souhegan River. The river is the primary groundwater discharge point near the Site. The
Souhegan River is used for recreational purposes including sw imming, fishing, canoeing, and kayaking.
1 PCBs were brought to the Site from about 1948 to 1967 from GE facilities in Pittsfield, Massachusetts, and Hudson Falls and Fort
Edward, New York, in a material called scrap pyranol.
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Goldman
Cemetery
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is
not a survey. The map is for informational purposes only regarding EPA's response actions at the Site. Sources:
Maxar. the 2017 Long-Term Monitoring Plan and the 2018 Five-Year Review.
Fletcher's Paint Works & Storage Facility Superfurid Site
Town of Milford, Hillsborough County, New Hampshire
Last Modified: 10/25/2022
® Keyes Well (OU2)
Drainage Culvert (OU1)
I I Mill Street Area (OU1)
I I Elm Street Area (OU1)
Sediment Removal Area
(OU2)
Engineered Soil Cover
Mill Street Pond
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FIVE-YEAR REVIEW SUMMARY FORM
NPL Status: Final
Multiple OUs?
Yes
Lead agency: EPA
Has the site achieved construction completion?
Yes
REVIEW S I A I I S
Author name (federal or state project manager): Emma Forbes
Author affiliation: EPA
Review period: 2/21/2018 - 11/7/2022
Date of site inspection: 9/13/2022
Type of rev iew: Statutory
Review number: 2
Triggering action date: 2/27/2018
Due date (five years after triggering action date): 2/27/2023
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
In 1984, NHDES (formerly the New Hampshire Water Supply and Pollution Control Commission), first detected
VOCs in the Reyes Well (Figure 1), a drinking water supply well in Reyes Field. The discovery triggered the
removal of the Reyes Well from service and prompted investigations that determined the Site was a source of the
contamination. EPA proposed listing the Site on the Superfund program's National Priorities List (NPL) in June
1988. EPA finalized the Site's listing on the NPL in March 1989.
EPA conducted the Site's remedial investigation and feasibility study (RI/FS) from 1990 to 1996. EPA completed
human health and ecological risk assessments using data from the RI/FS investigations.
OU1
The Site's 1998 OU1 Record of Decision (ROD) summarized the results of a baseline human health risk
assessment (HHRA). completed in 1994 and amended in 1996. The HHRA assumed that future land use for the
Elm Street Area was recreational, with a designated utility worker area, and future land use at the Mill Street Area
was commercial. The HHRA evaluated risks associated with the ingestion of and dermal contact with surface and
subsurface soils; the ingestion of and dermal contact with surface soil and sediment and surface water in the
drainage ditch; the ingestion of garden vegetables grown near the drainage ditch; and the potential ingestion of
groundwater. The HHRA determined exposure to surface and subsurface soils and ingestion of groundwater
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resulted in unacceptable potential cancer and non-cancer risks. PCBs were the primary risk driver in surface and
subsurface soils. Benzene. 1,2-dichloroethane, trichloroethylene (TCE) and PCBs were the primary risk drivers in
groundwater. The compounds contributing to most non-cancer effects in groundwater included ethylbenzene.
manganese, and PCBs. Table 1 and Table 2 in the Cleanup Levels section of this FYR Report present the OU1
contaminants of concern (COC) identified in site decision documents.
A Preliminary Ecological Risk Assessment conducted as part of the 1994 Rl determined that there were areas of
the Site with potential for ecological impacts. As a result of the preliminary assessment. EPA identified the
Souhegan River Study area as part of OU2.
OU2
An HHRA conducted as part of the 2011 OU2 Rl and summarized in the 2012 OU2 ROD evaluated potential
risks as a result of exposure to contaminated groundw ater. The OU2 HHRA indicated there were no current
human risks related to Reyes Field groundwater on site. However, the HHRA clarified that if pumping of
groundw ater from the Reyes Well resumes, there is the potential that unacceptable levels of contamination could
be pulled into the groundwater under Reyes Field and the Reyes Well from the upgradient OU 1 areas of the Site.
These areas are being addressed under the OU 1 ROD. Therefore, the OU2 ROD did not require a response action
for OU2 groundwater. Additionally, surface water data collected and evaluated in the Rl did not indicate an
unacceptable risk from surface water.
EPA conducted supplemental human health and ecological risk assessments for Souhegan River sediment in
2011. The supplemental HHRA found elevated potential risks to human health from the ingestion of PCB-
contaminated fish and from exposure to PCB-contaminated sediment located near the Elm Street part of the Site.
The ecological risk assessment noted that PCBs. the primary contaminants at the Site, have the potential to
bioaccumulate and be transferred through the aquatic food web to upper trophic level receptors. Therefore, the
ecological risk assessment determined that PCBs in sediment may present risk to wildlife, as well as fish and
invertebrates, from multiple exposure routes. Table 3 in the Cleanup Levels section of this FYR Report presents
the OU2 COCs.
Response Actions
Removal Actions
Between 1988 and 2001, various parties led removal actions at the Site to protect human health and the
environment, to remove hazardous substances and to stabilize the Site:
• In 1988, EPA characterized and disposed of 863 drums of hazardous substances from the Elm Street Area
and placed temporary caps over contaminated soils at the Elm Street and Mill Street Areas.
• In 1991, EPA installed a fence at the Elm Street Area.
• In 1993, EPA characterized and disposed of wastes found in the Elm Street and Mill Street Area
buildings, demolished the Mill Street storage facility structures, and repaired the temporary caps at the
Elm Street and Mill Street Areas.
• In 1995, GE removed PCB-contaminated soils with PCBs greater than 1 milligram per kilogram (mg/kg)
from three residential properties across from the Mill Street location.
• In 1996, GE removed PCB-contaminated soil from a small area next to the Fletcher's Paint Works
building to allow the Town to construct a Korean War Memorial (along Elm Street just south of the
cemetery).
• From 2000 to 2001, the U.S. Army Corps of Engineers (USACE) demolished and disposed of the former
Fletcher's Paint Works building, covered the area with a temporary liner and sand, and constructed a
fence.
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Remedy Selection
QUI
EPA selected the OU1 remedy in the Site's 1998 ROD and modified the remedy with a 2001 Explanation of
Significant Differences (ESD), a 2009 ROD Amendment and a 2010 ESD.
The 1998 ROD identified remedial action objectives (RAOs) for the OlJ 1 remedy. The 2009 ROD Amendment
and ESDs did not change the RAOs. The OlJ 1 RAOs are to:
• Prevent the ingestion of groundw ater contaminated in excess of drinking water standards (maximum
contaminant levels (MCLs) and maximum contaminant level goals [MCLGs]) or. in their absence, which
produces an incremental cancer risk greater than 1 x 10"6, for each carcinogenic compound. Also prevent
ingestion of contaminated groundw ater that produces an incremental cancer risk level greater than 1 x 10"4
to 1 x 10"6 for all carcinogenic compounds together.
• Prevent ingestion of groundwater contaminated in excess of drinking water standards for each non-
carcinogenic compound that produces a hazard quotient greater than 1 and a total hazard index of 1 to 10.
• Restore the groundw ater to drinking water standards, or in their absence, the more stringent of an
incremental cancer risk of greater than 1 x 10"6, for each carcinogenic compound, or a hazard quotient of
1 for each non-carcinogenic compound. Also restore the aquifer to the more stringent: of 1) a total
incremental cancer risk level of 1 x 10"4 to 1 x 10"6 for all carcinogenic compounds: or 2) a hazard index
of 1.
• Prevent contact with soil contamination through ingestion or dermal contact that produces an incremental
cancer risk of greater than 1 x 10"6 for each carcinogenic compound. Also prevent dermal contact with
and ingestion of contaminated soil that produces a total incremental cancer risk level of 1 x 10 4 to 1x10"
6 for all carcinogenic compounds.
• Prevent contact with soil contamination which, through ingestion or dermal contact, produces a hazard
quotient greater than 1 for each non-carcinogenic compound and a total hazard index of 1 to 10.
• Prevent the leaching of contaminants from the soil to the groundw ater that would result in groundw ater
contamination in excess of drinking water standards.
• Prevent or mitigate the release of contaminants to the Souhegan River in excess of surface water
standards.
The 2009 ROD Amendment clarified that the R AO of a "total hazard index of 1 to 10" means "a total hazard
index of 1 to 10 without regard to target tissue".
The 1998 ROD originally selected excavation and on-site treatment of contaminated soils using thermal
desorption. backfilling of excavated areas with treated soils and placement of an asphalt cap over the Elm Street
part of the Site. The 2009 ROD Amendment replaced the excavation and on-site treatment of contaminated soils
with excavation and off-site treatment or disposal, and placement of a cover over less-contaminated soils. The
groundw ater and institutional controls components of the OU 1 remedy selected in the 1998 ROD did not change.
Final OU 1 remedy components, as presented in the 1998 ROD as modified by the 2009 ROD Amendment,
include:
Mill Street Area (including the Drainage Ditch/Culvert System)
• Excavation of surface soils to a depth of 1 foot, wherever PCB concentrations are greater than 1 mg/kg.
• Excavation of subsurface soils (1 foot to 20 feet below surface (bedrock)), wherever PCB concentrations
exceed 1 mg/kg.
• Off-site treatment/disposal of excavated soil and debris at appropriately permitted facilities in accordance
with Resource Conservation and Recovery Act and Toxic Substances Control Act regulations.
• On-site treatment of water collected from dew ate ring of the excavated soils and water collected as a result
of lowering the water table during excavation, with discharge to the Souhegan River or off-site treatment
of collected water.
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• Backfilling of clean materials into the excavated areas to restore the property consistent with the
anticipated future use of the Site. Part of the Mill Street Area would be paved, physically realigning Mill
Street.
• Regrading and repair of the storm drainage system, as necessary, to promote surface flow away from the
Site. Incorporation of erosion control measures to prevent erosion or debris from restricting future
stormwater flow from the Mill Street Area or filling in of the drainage ditch.
Elm Street Area
• Excavation of surface soils to a depth of 1 foot, wherever PCB concentrations are greater than 1 mg/kg.
• Excavation of subsurface soils within utility corridors wherever PCB concentrations are greater than 25
mg/kg.
• Off-site treatment/disposal of excavated soil and debris at appropriately permitted facilities, in accordance
with Resource Conservation and Recovery Act and Toxic Substances Control Act regulations.
• Excavation of remaining subsurface soils to the seasonally low water table, wherever PCB concentrations
exceed 100 mg/kg.
• Removal and disposal of three remaining underground storage tanks.
• Final grading, restoration, and landscaping of the Site (including placement of a 40-inch engineered soil
cover). The final cover will promote drainage and further minimize infiltration through the residual
contamination at the Site and be part of the final restoration and landscaping plan.2 Incorporation of
erosion control measures to prevent erosion of the cover materials off-site and into the Souhegan River.
• Implementation of institutional controls to prevent unauthorized access into the subsurface at the Elm
Street location. Issuance of deed restrictions/notices to restrict future use of the Site, or the modification
of the cover or surface drainage structures in ways inconsistent with the remedy or anticipated future use
of the Site.
Groundwater
• Establishment of a Groundw ater Management Zone (GMZ) under New Hampshire's Comprehensive
Groundw ater Policy and implementation of institutional controls to restrict groundw ater use in the GMZ.
• Natural attenuation and long-term monitoring of contaminant concentrations in groundw ater to ensure the
cleanup levels are met within the GMZ and that contamination is not migrating beyond the boundaries of
the GMZ, or impacting the Souhegan River (i.e., monitored natural attenuation [MNA]).
OU1 Cleanup Levels
Soil
Table 1 presents the OU1 soil cleanup levels. Cleanup levels for surface soil in the Elm Street and Mill Street
Areas and subsurface soil in the utility corridor in the Elm Street Area were risk-based levels protective of the
incidental ingestion and dermal contact exposure pathways. Cleanup levels for subsurface soil were based on
protection of groundw ater.
2 The 2009 ROD Amendment specified a 40-inch-thick engineered soil cover at Elm Street, covering about 1 acre. The cover
meets NHDES capping requirements and allows for recreational use of the surface and installation of several utility and tree
corridors and limited parking spaces.
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Table 1: QUI Soil Cleanup Levels
coc
Soil Cleanup Levels (mg/kg)
Elm Street Area
Mill Street Area
Surface Soil
(0 Feet to 1
Foot3)
Utility
Corridor
Subsurface
Soil
(1 Foot to 10
Feet3)
Subsurface
Soil
(1 Foot to
Seasonally
Low Water
Tablebc)
Surface Soil
(0 Feet to 1
Foot3)
Subsurface
Soil
(1 Foot to 20
Feet/
Bedrock0)
Arsenic
0.9
--
--
0.9
--
Benzo(a)anthracene
2.1
--
--
2.1
--
Benzo(a)pyrene
0.2
--
--
0.2
--
Benzo(b)fluoranthene
2
—
—
2
—
Total PCBs
1
25
100
1
1
Notes:
a) Cleanup levels are risk-based, based on incidental ingestion and dermal contact with soil. PCB cleanup levels also
considered PCB Spill Policy (40 CFR 761.60(d)) and EPA's 1990 Guidance on Remedial Actions for Superfund
Sites with PCB Contamination.
b) Applies to soil outside the utility corridor.
c) Cleanup levels are for the prevention of leaching to groundwater for the protection of human health. The 1998
ROD, pdf page 99, clarified that the results of modeling indicated that 1 mg/kg PCB could remain in the soils at the
Mill Street Area, with only a soil cover, and not result in an exceedance of the groundwater MCL for PCBs in the
future. The 1 mg/kg cleanup level is also consistent with the Toxic Substances Control Act Spill Policy for
unrestricted access in residential areas (1998 ROD, pdf page 237).
- = cleanup level not established.
Source: 1998 ROD, pdf pages 96 and 100 and the 2018 Remedial Action Completion Report, pdf pages 23 and 24.
EPA made three clarifications to the soil cleanup levels, as documented in EPA's August 2018 Preliminary Close-
Out Report:
• In March 2001, EPA issued an ESD, which stated that, if a cleanup value described in the ROD cannot be
detected with good precision and accuracy or is below background values, then either the practical
quantification limit or a background value will be used for the soil cleanup level.
• In April 2004, EPA clarified that the 1 mg/kg soil cleanup level for PCBs is applicable to both surface
and subsurface soils west of Keyes Drive as the soils in this area were not considered part of the Elm
Street Area.
• As documented in EPA's March 31, 2005 approval letter for the OU1 Pre-Design Investigation Report,
EPA indicated that the observed concentrations of total PCBs at sampling location MSSBC01 (located
along the rail line) were consistent with EPA's Spill Policy (40 CFR 761.125) for commercial areas.
Therefore, those soils would not be subject to the 1 mg/kg soil cleanup level specified for total PCBs in
surface and subsurface soils at the Mill Street Area.
Groundwater
Table 2 presents the OU1 interim groundwater cleanup levels.3 Cleanup levels were set based on applicable or
relevant and appropriate requirements (ARARs) (MCLs, non-zero MCLGs, New Hampshire ambient groundwater
quality standards (AGQS) as available, or other criteria such as a health advisory or state guideline).
3
The 1998 ROD clarifies, on page 94, that the interim groundwater cleanup levels must be achieved and maintained for three consecutive
years. A risk assessment will be performed on residual groundwater contamination to determine protectiveness of the remedy. If EPA
determines that the remedy is not protective, the remedial action shall continue until protective levels are achieved and not exceeded for
three years or until the remedy is deemed protective or is modified.
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Table 2: QUI Interim Groundwater Cleanup Levels
coc
Interim Groundwater
Cleanup Level Oig/L)"
Arsenic
10h
Benzene
5
1.2-Dichlorocthanc
5
Ethvlbcn/cnc
700
Manganese
300°
PCBs
0.5
Toluene
1,000
1.2.4-T richlorobcn/cnc
70
TCE
5
Notes:
a) Cleanup levels arc the federal MCLs for all COCs except for
manganese. The cleanup level for manganese is based on an
EPA lifetime health advisory level for manganese,
b) The 2010 ESD established arsenic as a COC and specified its
cleanup level as the MCL or background, whichever is
higher.
c) The 2010 ESD increased the manganese cleanup level from
180 ng/L to 300 ng/L.
Source: 1998 ROD. pdf pages 93 and 94.
p,g/L = micrograms per liter
QU2
EPA issued a ROD for OU2 in September 2012. It selected a no action remedy for groundw ater under Reyes
Field and called for a second OU2 ROD to address PCB-contaminated sediments in the Souhegan River adjacent
to Reyes Field and the Elm Street Area dow nstream to Goldman Dam.
In October 2015, EPA decided to address the Souhegan River sediments with a non-time-critical removal action
(NTCRA). This decision was based on site conditions and cleanup schedule. There was an opportunity to
accelerate the OU2 sediment cleanup by taking advantage of the infrastructure that existed at the Site while the
OU 1 soil cleanup was in progress. EPA issued the NTCRA Action Memorandum in June 2016.
Because EPA decided that no action was warranted for OU2 groundwater. EPA did not establish RAOs for
groundwater.
EPA established the follow ing RAOs for the OU2 NTCRA to address the unacceptable risks posed by PCB-
contaminated sediments in the Souhegan River:
• Prevent direct contact by recreational receptors with sediment having total PCB concentrations that result
in risks in excess of EPA"s cancer risk range (increased lifetime cancer risk [ILCR] = 1 x 10"4 to 1 x 10"6)
and/or that have a target non-cancer hazard index greater than 1.
• Prevent consumption of fish with total PCB concentrations that result in risks in excess of EPA's cancer
risk range (ILCR =1x10 4 to 1 x 10"6) and/or that have a target non-cancer hazard index greater than 1.
• Reduce the amount of PCBs in sediment to ensure that PCB concentrations in fish tissue no longer result
in risks in excess of EPA"s cancer risk range (ILCR = 1 x 10"4 to 1 x 10"6) and/or that have a target non-
cancer hazard index greater than 1.
• Prevent upper trophic-level wildlife receptors from consuming fish and benthic invertebrates that contain
total PCB concentrations that result in an ecological hazard quotient greater than 1.
• Prevent direct contact by benthic invertebrates with sediment having total PCB concentrations that result
in ecological hazard quotient greater than 1.
• Reduce potential transport of PCBs by minimizing the dow nstream movement of PCBs during the
implementation of the removal action or future high energy storm events.
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The 2016 NTCRA Action Memorandum identified the foil owing major components of the NTCRA:
• A pre-design investigation to refine the nature and extent of PCB contamination in sediment.
• Construction of 500-year floodplain mitigation measures.
• Site preparation activities (preparation of staging areas, sediment management areas, river diversion).
• Excavation of contaminated sediment, dewatering of the excavated sediment and subsequent transport of
the sediment off site for disposal.
• On-site treatment of water from dewatered sediments and groundwater seepage with on-site discharge to
the river, or off-site treatment and disposal.
• Site restoration, as needed, along the riverbanks and river bottom.
• Signs and other short-term institutional controls to minimize the consumption of PCB-contaminated fish
until fish consumption risks are addressed.
OU2 Cleanup Levels
EPA selected a sediment PCB cleanup level of 0.5 mg/kg for the sediment NTCRA.4 The cleanup level was
expected to allow for the reduction of PCBs in fish tissue to acceptable levels and be protective of human health
due to direct contact with river sediments. The fish tissue goal established in the 2016 NTCRA Action
Memorandum was 0.34 mg/kg PCBs. The sediment cleanup level and fish tissue goal were also protective of
ecological receptors. EPA's February 2016 Engineering Evaluation/Cost Estimate and the June 2016 NTCRA
Action Memorandum have more detailed information on the sediment cleanup level.
Status of Implementation
The Town signed a Consent Decree with EPA in 1998 and agreed to pay part of the past and future response costs
at the Site and provide in-kind services. EPA also signed a Consent Decree in 2002 with two de minimus
contributors to the contamination at the Site. EPA issued a Unilateral Administrative Order (UAO) to GE on July
16. 2001, to perform the OU1 remedial design and remedial action. GE has conducted remedial activities at the
Site pursuant to the U AO. as amended on August 15, 2007, and June 11, 2010.
The follow ing sections describe the remedial actions implemented at OU 1 and OU2.
OU1
Soil
GE led excavation activities at the Elm Street Area and the Mill Street Area from October 2015 to November
2016. About 22,210 cubic yards of contaminated soil were removed from the Elm Street Area and sent off site
for disposal at a permitted waste facility. About 9,945 cubic yards of contaminated soil were removed from the
Mill Street Area and sent off site for disposal at a permitted waste facility. GE also removed three registered
underground storage tanks and one unregistered stormwater tank at the Elm Street Area, installed a replacement
storm sewer (after maintenance and clearing of debris from the drainage ditch) and dew atered work areas as
needed. A temporary water treatment system at the Mill Street Area treated groundwater extracted in support of
the excavations extending below the water table at the Mill Street Area.
GE completed site restoration activities, including backfilling of the excavated areas, placement of the final
cover on the Elm Street Area, installation of a stormwater detention basin, demobilization of the temporary water
treatment system, vegetative restoration, replacement of monitoring wells, and other restoration activities by July
2017. Erosion control measures, including installation of riprap along the riverbank and cemetery embankment
and placement of steel sheeting and a gabion basket retaining wall at the base of the riverbank, were incorporated
into the final grading to prevent erosion of the cover materials off site and into the Souhegan River.
4 The June 2016 NTCRA Action Memorandum, pdf page 10, describes the sediment PCB cleanup level. It indicates that it
was derived using the fish tissue preliminary removal goal of 0.34 mg/kg and a site-specific biota sediment accumulation
factor for any species of fish caught in the study area.
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The final cover at the Elm Street Area is a 40-inch, low -permeability cover system, which consists of an 18-inch
layer of lower permeability soils, overlain by an 18-inch layer of sand and a 4-inch layer of vegetated topsoil.
EPA approved the Final Remedial Action Report for OU 1 in April 2018. EPA issued the Preliminary Close-Out
Report in August 2018 to document the completion of remedial construction activities. The completed
remediation activities achieved the soil cleanup levels established in the ROD.
Institutional controls associated with the soil remedy are discussed in the Institutional Controls section of this
FYR Report.
Groundwater
The OU 1 groundwater remedy includes MNA and institutional controls. As noted in the 2009 ROD Amendment.
EPA estimated that the interim cleanup levels for VOC contamination in the overburden will be achieved within
20 to 25 years after completion of an active source control component. EPA expected that the PCB contamination,
particularly in the Mill Street Area bedrock, could persist for more than 100 years.
GE prepared an Environmental Monitoring Plan (EMP) in 2017 and conducted the first monitoring event in
October 2017. Progress toward achieving groundwater cleanup levels is evaluated periodically using the data
collected in accordance with the EMP. The 2018 Preliminary Close-Out Report noted that groundwater
monitoring is expected to continue for decades. Institutional controls associated with the groundwater remedy are
addressed in the Institutional Controls section of this FYR Report.
OU2
The 2012 OU2 ROD required no further action for OU2 groundwater under Reyes Field. GE implemented the
OU2 sediment cleanup pursuant to a July 2016 Statement of Work for OU2 and July 2016 Administrative
Settlement Agreement and Order on Consent for Removal Actions.
GE's contractor conducted the OU2 sediment NTCRA from August 2016 to October 2016. Major activities
included construction of access roads from the Elm Street Area to the river, vegetation clearing, installation of a
river diversion structure, and sediment excavation and backfilling. GE's contractor excavated about 1,500 cubic
yards of sediment and transported it off site for disposal. Details of the sediment removal activities are
documented in the 2017 Final Remedial Action Report. Operable Unit 2 - Souhegan River Sediments. Non-Time-
Critical Removal Action, approved by EPA in April 2017.
The sediment remediation activities achieved the sediment target cleanup concentration of 0.5 mg/kg for PCBs.
However, as noted in the first FYR Report for the OU2 remedial action, the fish tissue goal of 0.34 mg/kg
established by the NTCRA Memorandum will need to be achieved for the remedy to be considered protective
over the long term. GE prepared and submitted a work plan to conduct fish tissue sampling in March 2021 and
completed the sampling in August 2021. The Data Review section of this FYR Report discusses the fish tissue
sampling results.
In November 2021, EPA notified GE that representatives of EPA and NHDES had posted several new fish
advisory signs along the riverbanks of the Souhegan River. EPA requested the addition of the locations of the
signs to site figures and sign inspections as part of future monitoring events.
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Institutional Controls
The 1998 OU 1 ROD required institutional controls to limit groundwater and land use. The follow ing sections
describe the institutional controls implemented at the Site. Table 3 presents a summary of the implemented
institutional controls at the Site. Figure 2 show s the parcels subject to restrictive covenants and the Tow n's GMZ.
Groundwater Use Institutional Controls
The 1998 OlJ 1 ROD and U AO/Scope of Work (as modified) for OlJ 1 required the establishment of a GMZ via
issuance of a NHDES Groundw ater Management Zone Permit (GMP). Instead of a state-issued GMP, the Tow n
issued an ordinance establishing a GMZ that covers about 36 properties (Figure 2). EPA agreed to rely on the
ordinance in lieu of issuing a GMP and recording notices in the chain of title for each property, as would be
required by a state GMP.
Groundwater within the Town's GMZ is monitored in accordance with the requirements of the EMP. Each annual
report includes a discussion of GMZ compliance monitoring, including an evaluation of the potential need for
modifications to the GMZ boundaries. Further discussion of groundwater contamination in relation to the GMZ is
in the Data Review section of this FYR Report.
Land Use Institutional Controls
The ROD as amended required institutional controls restricting land use and access to subsurface soils at the Elm
Street Area (parcel 25-12). Additionally, as noted in Section 5.4.2 of the Institutional Controls and Access
Restrictions Plan (included as Appendix B to the OU 1 Remedial Action Work Plan) and Section 5.3 of the 2018
Remedial Action Report, it was anticipated that institutional controls would also be needed for other town-owned
properties and two private properties near the Mill Street Area, including:
Tow n-ow ned parcels
• Part of parcel 25-13, a cemetery, located immediately east of the Elm Street Area parcel.
• Part of parcel 25-133, Reyes Field (including Reyes Drive), located immediately west of the Elm Street
Area parcel.
• Parcel 25-11 1. the primary Mill Street Area parcel.
Privately owned parcels
• Parcel 25-110, former Draper Fuel Company property, located immediately west of the Mill Street Area
parcel.
• Part of the railroad property, located immediately north of parcels 25-110 and 25-111.
The Tow n adopted an ordinance in July 2019 that implements land use restrictions for the Elm Street Area
property (parcel 25-12) and adjacent cemetery (parcel 25-13).
There are currently no land use controls on the additional Tow n ow ned properties, parcels 25-133 and 25-11 1.
EPA has determined that land use controls are not necessary for these properties due to the nature of the final
remedial action. For both parcels, the remedial action met the cleanup level of 1 mg/kg for PCBs in soil, allow ing
for UU/UE.
Although not required by the 1998 ROD as amended. GE implemented environmental protection easements and
declarations of restrictive covenants for the two privately owned parcels, parcel 25-110 and the railroad property,
in May 2012 and January 2013, respectively. As documented in EPA's March 31, 2005 approval letter for the
OU 1 P re-Design Investigation Report. EPA indicated that the observed concentrations of total PCBs at sampling
location MSSB-C01 (located along the rail line) were consistent with EPA's Spill Policy (40 CFR 761.125) for
commercial areas. Therefore, those soils would not be subject to the 1 mg/kg soil cleanup level specified for total
PCBs in surface and subsurface soils at the Mill Street Area. Since the 1 mg/kg PCB cleanup level was not
required for these parcels. UU/UE is not supported near parcel 25-110 and the railroad property, and therefore
these recorded ICs are appropriate.
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Table 3: Summary of Planned and/or Imp
em en ted institutional Controls (ICs)
Media,
Engineered
Controls and
Areas That Do
Not Support
IJIJ/UE Based on
Current
Conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented and
Date (or planned)
Groundwater
Yes
Yes
36 parcels, shown
on Figure 2
Prohibit groundwater use.
Milford Municipal
Code - Title 5,
Chapter 5.34
Fletcher Paint
Superfund Site
Groundwater
Management Zone.
April 2018-'
Limit use of Lot 25-12 (Elm
Street Area) to recreation
Soil/cover area on
town-owned
Elm Street Area
and adjacent
cemetery
Yes
Yes
25-12 (Elm Street
Area parcel)
25-13 (cemetery)
use.
Prohibit disturbance of
surface and subsurface soil
without first contacting EPA
and NHDES (except for
areas designated as
"vegetative
restoration/planting area"
outside of the engineered
soil covers).
Milford Municipal
Code - Title 5,
Chapter 5.34
Fletcher Site Land
Use Restrictions
Ordinance. July
2019a
Soil on
privately-owned
property
Yes
Nob
25-110 (former
Draper Fuel
property)
Railroad property
Prohibit residential use or
youth-related uses of any
kind.
Restrict soil disturbance
without EPA and GE
approval.
Prohibit groundwater use.
Environmental
Protection
Easements and
Declarations of
Restrictive
Covenants
Parcel 25-100:
May 2012
Railroad property:
Januarv 2013
Notes:
a) Town ordinances available at: https://www.milford.nh.gov/municipal-coderules/pages/title-5-health-and-safety.
b) The IC and Access Restrictions Plan and the 2018 Remedial Action Report call for institutional controls on these
properties, but these land use controls arc not required by the 1998 ROD. as amended. The 1 ppm PCB soil clean up level
was not required for these parcels, consistent with EPA's PCB spill policy (40 CFR 761.125). Therefore, UU/UE is not
supported, and the institutional controls arc appropriate.
16
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Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map
is not a survey. The map is for informational purposes only regarding EPA's response actions at the Site.
Sources: Maxar and the 2018 Five-Year Review.
Fletcher's Paint Works & Storage Facility Superfund Site
Town of Milford, Hillsborough County, New Hampshire
Last Modified: 10/25/2022
Figure 2: Institutional Controls
Mill Street Area (OU1)
Elm Street Area (OU1)
Groundwater
Management Zone
Parcel subject to 2019
Town of Milford Land Use
Restrictions Town
Ordinance
Parcel within
Groundwater
Management Zone
Parcel subject to 2012
Restrictive Covenant
Area subject to 2013
Restrictive Covenant
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Systems Operations/Operation & Maintenance (Q&M)
Site Inspections and Maintenance - OJJ1 and OU2
The Site's October 2017 Long-Term Monitoring Plan, included as Appendix Q in the 2018 Remedial Action
Report, presents the post-construction inspection, maintenance and reporting activities for OU 1 and OU2. The
Long-Term Monitoring Plan indicates that GE is responsible for the first phase of long-term monitoring that
includes four semi-annual inspections from fall 2017 to spring 2019. The Town is responsible for the second
phase of long-term monitoring, which includes annual inspections. The Town is also responsible for mow ing of
the restored vegetation areas and routine repairs/sealing of the restored Reyes Drive parking area.
The follow ing elements are subject to inspection and maintenance:
• Engineered soil cover at the Elm Street Area.
• Reyes Drive parking area.
• Stormwater retention basin next to the Reyes Drive parking area.
• Gabion basket retaining wall installed along the toe of the riverbank at the Elm Street Area.
• Riprap protected slopes along the riverbank at the Elm Street Area and along the drainage ditch at the
Mill Street Area.
• Vegetative restoration/planting areas, which include areas outside the engineered soil cover at the Elm
Street Area, a portion of the mid-channel island in the Souhegan River, a portion of the riverbank on the
Boys & Girls Club property (along the riverbank of the Souhegan River across from the Elm Street
Area), and the Mill Street Area.
• Asphalt pavement restoration areas.
• Stormw ater conveyance features.
• Railroad property restoration area.
• Ancillary components.
GE's final inspection as part of the first phase of long-term monitoring occurred in August 2019. It was
documented in the Summary of August 2019 Site Inspection and September 2019 Maintenance/Repair Activities
Report, dated November 2019. GE identified erosion and settlement of topsoil. displacement of riprap and/or
exposure of geotextile in certain locations along the top of the riverbank and at the stormwater retention basin.
Vegetative growth was also observed at certain locations along the riverbank riprap, the perimeter berm of the
retention basin, the gabion basket retaining wall, cemetery embankments and other areas of the Site. GE
mobilized to the Site to address the maintenance concerns and install drainage enhancement features along the top
of the riverbank in the Elm Street Area in September 2019.
The Tow n is responsible for the second phase of long-term monitoring but has not yet submitted documentation
of the inspections. It is unclear if the Town is conducting the inspections.
Long-Term Groundwater and Surface Water Monitoring - OU1
GE implements a post-construction groundwater and surface water monitoring program in accordance with the
2017 EMP. The EMP will take place in two phases:
• Phase I: a long-term annual monitoring phase to document constituent concentrations until groundwater
cleanup levels are achieved at all wells in the monitoring network.
• Phase II: a three-year semi-annual monitoring phase to document that the groundwater cleanup levels
have been achieved and that the groundwater remedy is complete.
The monitoring network at the Site includes 62 monitoring wells in three groups: upgradient of the Mill Street
Area, the Mill Street Area and upgradient of the Elm Street Area, and the Elm Street Area and downgradient. The
monitoring network also includes two surface water sampling locations in the Souhegan River.
The 2017 EMP specifies sampling of all wells in the monitoring netw ork and the surface water locations for the
full target compound list/target analyte list (TCL/TAL) every five years. GE completed the first baseline
TCL/TAL monitoring event in fall 2017.
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In other years, the EMP requires annual collection of samples in September/October and analysis of the samples
for the nine groundw ater COCs. During these events, only monitoring wells with an exceedance of at least one
COC in at least one of the three most recent monitoring events will be sampled. GE submits annual reports to
EPA and NHDES. Data from the recent groundwater and surface water sampling events are discussed in the Data
Review section of this FYR Report.
III. PROGRESS SINCE THE PREVIOUS REVIEW
Table 4 includes the protectiveness determinations and statements from the 2018 FYR Report. Table 5 includes
the recommendations from the 2018 FYR Report and the current status of those recommendations.
Table 4: Protectiveness Determinations/Statements from the 2018 FYR Report
OIJ #
Protectiveness Determination
Protectiveness Statement
1
Short-term Protective
The remedy at OU1 currently protects human health and the
environment. All of the construction activities required by the 1998
OU 1 ROD (as amended) have been completed. Contaminated soils
have been excavated to EPA's selected cleanup levels and
transported off site. The OU 1 groundwater is not currently being
used for drinking water since public water is available. However, in
order for the remedy to be protective in the long term, the following
actions need to be taken to ensure protectiveness:
• All required institutional controls must be in place.
• The cleanup levels for OU 1 groundwater must be achieved.
2
Short-term Protective
The remedy at OU2 currently protects human health and the
environment. Contaminated sediments in the Souhegan River have
been excavated and transported off site. Signs warning anglers not to
consume fish caught from the Souhegan River have been posted.
The OU2 groundwater is not currently being used since public water
is available. However, in order for the remedy to be protective in the
long term, the following actions need to be taken to ensure
protectiveness:
• Institutional controls to prevent future use of OU2
groundwater, as required by the 1998 OU 1 ROD.
• The cleanup levels for OU 1 groundwater, a potential source
to OU2 groundwater, must be achieved.
• The remedial action objective for fish tissue will need to be
achieved.
Table 5: Status of Reconimendations from the 2018 FYR Report
OU#
Issue
Recommendation
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1,2
Not all of the
institutional controls
required by the 1998
OU 1 ROD (as
amended) are in
place (see Section
11. Table 1 of the
2018 FYR Report).
Work with the Town of
Milford, New Hampshire
to create a Town
Ordinance that prohibits
the use of groundwater
within the proposed GMZ
until drinking water
standards arc met. Also
work with the Town of
Milford to ensure that the
appropriate land use
restrictions for Town-
owned property at the Site
arc in place.
Completed
The Town adopted an
ordinance in April 2018
establishing a GMZ.
The Town adopted a
second ordinance in July
2019 that implements land
use restrictions for the Elm
Street Area and adjacent
cemetery (parcels 25-12
and 25-13
7/9/2019
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OU#
Issue
Recommendation
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1,2
The potential exists
for an ongoing flux
of PCBs from the
OU 1 groundwater
areas to the
Souhegan River that
may, in the future,
recontaminate the
remediated OU2
sediments above the
0.5 mg/kg PCB
cleanup level.
An evaluation of OU 1
groundwater data per the
OU 1 Environmental
Monitoring Plan will be
performed to determine if
there is a need for
additional investigations
into the ongoing flux of
PCBs from the OU 1
groundwater areas, and
the potential for
recontaminating the
remediated OU 2
sediments above the 0.5
mg/kg PCB cleanup level.
Ongoing
An evaluation of the OU 1
groundwater data is
performed as part of the
annual Environmental
Monitoring Reports
(EMRs). However, further
site-specific evaluation of
the potential for PCBs in
OU 1 groundwater to re-
contaminate remediated
OU2 sediments is
recommended.
Not
applicable
In addition to the formal issues and recommendations, the 2018 FYR Report also identified recommendations as
Other Findings. The Other Findings and the status of the recommendations are below.
• The possible presence of per- and polyfluoroalkyl substances (PFAS) has not been determined at the Site.
PFAS have been used widely since the 1940s in industrial applications and in consumer products,
including paints. Given the history of the Site as a paint manufacturing facility, testing for the presence of
PFAS may be warranted.
GE performed PFAS sampling in fall 2019, in accordance with a September 2019 Proposal for PFAS
Screening Investigation (revised October 2019). The Data Review section of this FYR Report presents the
sampling results.
• The recent OU1 remedial action for overburden soils did not directly address the contaminant mass
present in bedrock (i.e., relatively small quantities of dense non-aqueous phase liquid [DNAPL] observed
in certain bedrock monitoring wells). While the high concentrations of PCBs found in the shallow surface
soils were indicative of residual DN APL. free phase DN APL was never identified in any soil sampling or
exploratory boring event during the 1994 Rl. Therefore. EPA was unaware of the presence of free phase
DNAPL in bedrock at the time of the 1998 OU 1 ROD or the 2009 OU 1 ROD Amendment. The
significance of this contaminant source in bedrock will be assessed as part of ongoing groundwater
sampling and assessment conducted as part of the OU 1 EMP.
GE continues to perform groundwater monitoring as part of the OU 1 EMP. The 2020 Environmental
Monitoring Report (EMR) also includes a discussion regarding DNAPL observation and collection
activities performed at the Site. Groundwater monitoring and DNAPL gauging at the Site since
implementation of the OU 1 soil remedy has not resulted in the identification of any measurable
thicknesses of DN APL in monitoring well MW-2 1CR or other well. GE further noted that quantifying the
volume of potential DNAPL remaining in bedrock at the Mill Street Area and the potential impact of such
residual DNAPL on estimated cleanup timeframes at the Site is not currently feasible with any
meaningful degree of accuracy. DNAPL will continue to be assessed as part of ongoing groundwater
sampling and assessment conducted as part of the OU 1 EMP.
• Fish tissue data will need to be collected periodically until the RAOs for fish tissue have been achieved.
GE collected fish tissue data in 2021. Results are discussed in the Data Review section of this FYR
Report. Fish tissue sampling should continue to occur, at a minimum, every five years, prior to the FYR.
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IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Community Involvement and Site Interviews
EPA issued an online news release in January 2022 to announce that the FYR was underway. A copy of the news
release is included in Appendix C. The results of the review and the completed FYR Report will be made
available on EPA's site profile page at www.epa.gov/superfund/fletclier.
During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy that has been implemented to date. The results of these interviews are summarized below. Appendix D
includes the completed interview forms. EPA's CIC also reached out to a local business owner on Cottage Street
and a resident on Mill Street but did not receive a response. EPA's CIC conducted an interview with a GE
representative, but they asked that their name and responses to the questions not be included in the FYR.
The NHDES representative noted that completion of the OU1/OU2 removal activities and implementation of
institutional controls have eliminated direct contact risk for approved uses of the affected parcels. Ongoing
monitoring and evaluation of the extent of site contaminants above site ICLs and state ambient groundwater
quality standards ( ACQS) may necessitate the need to adjust the GMZ and groundwater monitoring network.
Exceedances of state indoor air screening levels for TCE in overburden monitoring well MW-18B also support
the need for a vapor intrusion assessment for the structure on lot 25-11. The NHDES representative also noted
that additional review of existing institutional controls may be warranted considering the town's plans for site
reuse. Additional recommendations of NHDES include continued DNAPL gauging in the Mill Street area,
assessment of PCBs with depth in remediated sediment of the Souhegan River, continued evaluation and upkeep
of institutional controls (including a postcard survey to evaluate potential groundwater use within the GMZ), and
coordination of a timely response addressing the Site's maintenance issues. The NHDES site manager also noted
changes to the state's AGQSs for manganese, arsenic, several PFAS and 1.4-dioxane.
The Director of Community Development for the town of Milford feels well-informed regarding the Site's
activities and remedial progress. The town continues to work with EPA. NHDES and GE regarding the granite
stage project (i.e., amphitheater) and associated landscaping around the site perimeter. Vandalism has occurred
recently on site, primarily associated with the granite stage and other areas of Keyes Memorial Park. The director
noted that it would be beneficial if EPA and the town could work collaboratively to provide updates to post on the
town's web site and related social media outlets.
A representative from the Souhegan River Local Advisory Committee feels well-informed about the Site's
activities and remedial progress. She noted the best way to provide site-related information is to keep the Site's
webpage up to date with new information and data. She is interested in learning more about the fish tissue
analyses in the hopes that declining PCB levels in fish will allow the fish advisory on that stretch of the Souhegan
River to end.
Data Review
Data reviewed for this FYR included OU 1 groundwater and surface water data in the 2018 to 2020 EMRs,
preliminary groundwater data in the October 2021 and November 2021 Monthly Progress Reports, and OU2 fish
tissue data in the March 2022 Data Summary Report - Fish Tissue Sampling. Operable Unit 2. Supplemental
sampling results for PFAS and an evaluation of the potential for vapor intrusion, originally included in the 2019
EMR. were also reviewed.
General findings from this review are:
• Sampling detected six of the nine groundwater COCs specified in the 1989 ROD above their respective
cleanup levels between 2018 and 2021. Total PCBs. TCE and manganese were detected most often above
cleanup levels. Concentrations in most wells are stable or declining. However, some wells have variable
concentrations with no clear declining trends.
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• The highest concentrations of total PCBs in groundwater remain in the Mill Street Area, in shallow
bedrock well MW-21CR. PCB concentrations in this well have been variable since implementation of the
OU 1 soil remedy. Residual DNAPL observed in MW-21CR in 2019 may be acting as an ongoing source
of groundwater contamination.
• The lateral extent of site-related groundw ater contamination above cleanup levels may extend outside the
established GMZ near the MW-11 well cluster and in upgradient Mill Street Area well MW-35C.
However, more data will be needed to confirm this possibility.
• PFAS was detected in site groundwater in 2019. None of the PFAS constituents were detected above
applicable state ACQS. However, perfluorooctanesulfonic acid (PFOS) was detected above the EPA
regional screening level (RSL) in one well and perfluorooctanoic acid (PFOA) was detected above the
EPA RSL in four wells.
• Shallow water table well MW-18B adjacent to the property at the corner of Elm St and Reyes Drive had a
TCE concentration of 30 (.ig/L in 2021 that exceeds the NHDES Groundw ater to Indoor Air screening
level of 20 (ig/L. Using the EPA VISL calculator, it was determined that the TCE concentration in
shallow groundw ater could result in indoor air levels of TCE that exceed EPA's residential and
commercial RSLs for indoor air (0.48 ug/m3 and 3 ug/m3, respectively). Evidence of residential use at the
property was observed during the FYR site inspection. Further evaluation of the potential for vapor
intrusion is included in Question B of this FYR Report.
• Fish tissue sampling took place in August 2021. PCB concentrations in all fish tissue samples were below
the preliminary removal goal of 0.34 mg/kg specified in EPA's NTCRA Action Memorandum.
• Manganese was the only constituent detected in surface water samples during the 2020 monitoring event.
VOCs and PCBs were not detected in surface water samples collected between 2018 and 2020.
More information on the data reviewed is presented below .
OU1
Groundwater
GE's contractor collected groundwater samples annually from 2018 to 2021. The 2017 EMP indicates that the
monitoring network at the Site includes 62 monitoring wells. Two more wells (MW-41B and MW-42B) were
installed at the Site in November 2019 to assess potential vapor intrusion concerns in certain occupied structures
along Elm Street. The additional wells were sampled in 2019 and 2021 but have not officially been included in
the EMP monitoring network. In 2019, TCE was detected below the groundwater cleanup level of 5 (ig/L in MW-
41B and TCE was not detected in MW-42B. In 2021, TCE was not detected in either MW-41B or MW-42B.
Well MW-42B is located near 5 1 Elm Street. Figure E-l in Appendix E show s the locations of site monitoring
wells.
Groundwater flow direction in both the shallow overburden and bedrock is generally north-northwest from the
Mill Street Area and north-northeast across the Elm Street Area toward the Souhegan River. Figures E-2 and E-3
in Appendix E are a water table contour map and bedrock potentiometric surface contour map. respectively, from
the 2021 EMR.
Sampling detected six of the nine groundwater COCs specified in the 1998 ROD above their respective cleanup
levels from 2018 to 2021. Table E-1 in Appendix E presents the number of monitoring wells with a COC cleanup
level exceedance and the COC s maximum detected concentration for years 2018 to 2021. Ethylbenzene. toluene
and 1,2-dichloroethane were below cleanup levels in all wells sampled between 2018 and 2021. Total PCBs and
TCE are primary groundwater COCs at the Site because they are detected most frequently above their cleanup
levels of 0.5 jig/L and 5 (ig/L, respectively, and at the highest concentrations. They are the primary focus of this
data review. Manganese is also detected frequently in site groundwater above its cleanup level of 300 (ig/L, but it
is naturally occurring. Benzene. 1.2.4-trichlorobenzene and arsenic were detected in three or fewer wells above
their respective cleanup levels between 2018 and 2021 (Table E-l). The 2020 EMR provides a comprehensive
summary of groundwater analytical results from 2010 to 2020. The October 2021 Monthly Progress Report and
the November 2021 Monthly Progress Report present the 2021 data.
22
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Figure E-4 in Appendix E shows detected concentrations of COCs during the 2021 sampling event in the Elm
Street Area. Figure E-5 shows detected COC concentrations in the Mill Street Area in 2021. Figures E-6 and E-7
in Appendix E show the 2021 extent of TCE and total PCB contamination in the overburden and bedrock
aquifers, respectively.
The highest concentrations of total PCBs in groundwater remain in the bedrock groundwater in the Mill Street
Area, with a maximum detected PCB concentration of 160 (.ig/L in shallow bedrock well MW-21CR in 2020.
MW-2 ICR is a replacement well for MW-21C, which was destroyed during the soil remedial action.
Concentrations of total PCBs in MW-21 CR have fluctuated since the completion of the soil remedial action in
July 2017 with concentrations of 460 (ig/L in fall 2017, 190 (ig/L in 2018, 33 (ig/L in 2019, 160 (ig/L in 2020 and
64 (ig/L in 2021. Except for the fall 2017 total PCB concentration, the detected concentrations are generally the
same as or lower than historical total PCB concentrations in MW-2 1C (Table E-2, Appendix E). During the 2019
sampling event, DNAPL was observed in purge water from the bottom of well MW-2 ICR. DNAPL was not
detected in MW-2 ICR during the 2020 sampling event. Residual DNAPL may still be present in the fractured
shallow bedrock at the Mill Street Area and could be acting as an ongoing source of groundwater contamination
at the Site. Well MW-21 CR is also the only well to have exceedances of 1.2.4-trichlorobenzene between 2018 and
2021. Also in 2021, well MW-35C, the most upgradient well in the Mill Street Area, had a total PCB
concentration of 0.73 (ig/L. This well is also located near the southern boundary of the GMZ. Total PCBs
increased in MW-35C since the last time this well was sampled in 2017 (total PCBs were below the cleanup goal
in 2017). More actions may be warranted to delineate the extent of PCB contamination and potentially outside the
GMZ near MW-35C (Figure E-7).
The total PCB concentration in well MW-11B (0.52 (ig/L), located along the western GMZ boundary, exceeded
the PCB cleanup level in 2021 (Figure E-5). MW-11A, also along the western GMZ boundary, had manganese
concentrations above the cleanup level in 2020 and 2021. More actions may be warranted to delineate the extent
of COC contamination to the west and potentially outside the GMZ.
The highest concentrations of TCE in 2020 were observed in shallow bedrock well MW-33C, located
downgradient of the Mill Street Area and upgradient of the Elm Street Area. The highest TCE concentration in
2021 was at MW-08C. also located downgradient of the Mill Street Area (Figure E-6). TCE has also been
detected above the cleanup level (5 (ig/L) in Elm Street Area wells at similar but slightly lower concentrations
(e.g., 30 (ig/L TCE in well MW-18B in 2021).
Since the OU1 soil remedial action in 2017, groundwater concentrations have generally been stable or decreasing
at most wells. Some wells reported an increase in concentrations in the first two years of post-construction
monitoring but declined thereafter. The 2020 EMR describes exceptions to the stable or decreasing trends, with
some of the exceptions noted below:
Mill Street Area and Upgradient of Elm Street Area Wells
• MOBIL-04 - All four post-construction benzene concentrations were greater than the highest pre-
construction concentration for this constituent and greater than the cleanup level of 5 (ig/L. The increase
in post-construction concentrations in this well suggests an ongoing source of groundw ater
contamination, unrelated to the Site, may be emanating from the gasoline station near the Site.
• MW-08A - The post-construction concentrations for TCE and PCBs have indicated significant
variability. TCE was detected in two of the four events at concentrations greater than the cleanup level of
5 (ig/L (both concentrations were also greater than the highest pre-construction concentration for this
constituent). PCBs were detected in three of the four events at concentrations greater than the cleanup
level of 0.5 (ig/L (however, only one concentration was greater than the highest pre-construction
concentration for this constituent).
• MW-11A - The manganese concentrations for the last three post-construction monitoring events were all
greater than the cleanup level of 300 (ig/L and were slightly greater than the highest preconstruction
concentration for this constituent.
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• MW-2 1CR - All four post-const ruction 1,2,4-trichlorobenzene concentrations were greater than the
cleanup level of 70 (ig/L. with three of the four concentrations slightly greater than the highest p re-
construction concentration for this constituent.
Elm Street Area and Downgradient Wells
• MW-03BR - The concentrations of arsenic and manganese were above the cleanup levels of 10 (ig/L and
300 (ig/L, respectively, for all four post-construction monitoring events.
Groundwater data will continue to be collected to monitor long-term trends over time, in accordance with the
EMP.
Surface Water
GE's contractor collected two surface water samples (SW-1 and SW-2) annually from 2018 to 2020. Samples
were also collected in 2021, but the 2021 data were not yet available for review. Figure E-l in Appendix E shows
the sample locations. Table E-3 in Appendix E includes the most recent data from 2020. During the 2020
sampling event, manganese was the only constituent detected in either sample at concentrations of 95.9 (ig/L
(SW-1) and 37 jig/L (SW-2). Decision documents did not select cleanup levels for surface water. However, an
RAO for the Site is to prevent or mitigate the release of contaminants to the Souhegan River above surface water
standards. The national recommended water quality criteria for manganese in surface water for protection of
human health are 50 (ig/L for the consumption of both water and organisms and 100 (ig/L for the consumption of
organisms5, which is consistent with NHDES Surface Water Criteria for Toxic Substances (Env-Wq 1700).
Table E-4 in Appendix E presents a cumulative summary of the surface water sample data collected since
implementation of the OU1 and OU2 remedial actions. No VOC or PCB impacts to surface water have been
observed during the post-construction monitoring events, except for TCE (1.9 (ig/L) and PCBs (1.0 (ig/L) in the
2017 upstream sample. For inorganics, low levels of arsenic were detected in both upstream and dow nstream
samples in 2018. Low levels of manganese were detected in all upstream and downstream samples collected since
2017.
Supplemental PFAS Sampling and Vapor Intrusion Investigations
PFAS Data
During the 2019 annual sampling event, GE collected groundwater samples from 17 wells across the Site and
analyzed the samples for perfluorohexanesulfonic acid (PFHxS). perfluorononanoic acid (PFNA), PFOA and
PFOS. which represent the compounds for which NHDES has established state MCLs and AGQS.
Table E-5 in Appendix E summarizes the PFAS data. None of the constituents were detected above the state
AGQS. PFOS was detected above the EPA RSL of 0.004 (ig/L (4 ppt). in well MW-03BR at a concentration of
0.0147 (ig/L. PFOA was detected above the EPA RSL of 0.006 jig/L in four wells (MW-06B, MW-2 ICR, MW-
23C and MW-25B) at concentrations ranging from 0.00609 (ig/L to 0.011 (ig/L.
Supplemental TCE Data for Vapor Intrusion Evaluation
In an August 2019 letter. EPA requested that GE install two new shallow groundwater monitoring wells to
investigate TCE concentrations and the potential for vapor intrusion near two occupied structures along Elm
Street.
Monitoring wells MW-41B and M W-42B were installed and sampled for TCE concurrently with the fall 2019
monitoring event and sampled again during the fall 2021 monitoring event. Depth to groundwater at MW-41B
and MW-42B is approximately 26ft and 27ft below ground surface, respectively. Figure E-l in Appendix E shows
the locations of MW-41B and M W-42B near residential areas along Elm Street. In 2019, TCE was detected below
the groundwater cleanup level of 5 (ig/L in MW-41B and TCE was not detected in MW-42B. In 2021, TCE was
5 Fromwww.epa.gov/wqc/natioiial-recoiiimeiided-water-aiiaJitY-criteria-hiimaii-health-criteria-table (accessed 9/2/2022). The
50 (ig/L criterion is for consumption of water and organisms. The 100 (ig/L criterion is for consumption of organisms only.
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not detected in either MW-41B or MW-42B. For both wells, TCE was not found at a concentration greater than
the NHDES Groundw ater to Indoor Air GW-2 screening level of 20 (ig/L. or at a concentration greater than the
TCE groundwater cleanup level of 5 (ig/L.
Although TCE was not detected above the NHDES screening level in the new ly installed wells, deep overburden
well MW-18A and shallow water table well MW-18B adjacent to the mixed use 51 Elm Street property next to
Reyes Drive periodically have TCE concentrations greater than the NHDES screening value. In 2021, a TCE
concentration of 30 (ig/L was detected in shallow water table well MW-18B, in exceedance of the 20 jig/L
NHDES GW-2 Groundwater to Indoor Air Screening Level. Depth to groundwater at MW-18B is approximately
22ft below ground surface.
Previous vapor intrusion investigations related to the Site were conducted by EPA in 2009 and 2010, and by GE
in 2016. In 2009 and 2010, EPA collected soil gas. basement/craw l space air samples, first floor air samples, and
sub-slab soil gas samples from select homes located above the groundwater plume. Of the nine locations sampled.
TCE was only found above reporting limits in one location. 15 Cottage St. with TCE slightly above EPA
residential screening levels but below EPA commercial screening levels. Since the building on site, the American
Legion, is inferred to not be used as a residence, the commercial indoor air screening level is the most appropriate
value to apply at this location. In 2016, GE completed an indoor air assessment for 21 Cottage Street. TCE was
not detected at 21 Cottage Street, and none of the compounds detected in soil gas sub-slab air. indoor air or
ambient air samples at 21 Cottage Street exceeded their NHDES commercial indoor air values.
5 1 Elm Street was included in the initial scope of the 2009/2010 investigations, but EPA was not permitted access
to complete an evaluation at this property, and therefore sampling has not occurred at the multi-use building at 51
Elm Street.
The Question B section of this FYR Report provides further evaluation of the vapor intrusion pathway.
Oil2
2021 Fish Tissue Sampling
In August 2021, GE contractors collected fish samples from three locations (A, B and C), for a total of 54 samples
consisting of 18 samples each of redbreast sunfish (fillet), yellow bullhead (fillet) and white sucker (whole body).
Figure E-8 in Appendix E shows the approximate sample locations. The 2021 fish tissue sampling locations and
species were designed to replicate the sampling locations and species sampled in 2006 prior to the OU1 remedial
action. The fish tissue samples were analyzed for PCB Aroclors and percent lipids.
PCBs were detected in 51 of the 54 samples collected during the study. Results of the study ranged from non-
detect (w ith a detection limit of 0.0082 mg/kg) to an estimated concentration of 0.27 mg/kg. All detected
concentrations were less than the preliminary removal goal of 0.34 mg/kg specified in EPA's NTCRA Action
Memorandum. The implemented remedial actions were successful in reducing PCB concentrations in fish tissue
below the RAO of 0.34 mg/kg for all samples.
Table E-6 in Appendix E compares 2006 mean PCB concentrations in fish tissue samples to the 2021 mean PCB
concentrations. The data indicate a decrease in fish tissue PCB concentrations adjacent to the Elm Street Area
(location A) and downstream (location B) of the Site.
Site Inspection
The site inspection took place on 9/13/2022. In attendance were EPA RPM Emma Forbes. EPA CIC Ashlin
Brooks. Andrew Hoffman (NHDES). Andrew Ashton (NHDES contractor). Matthew Calacone (GE). Evan Green
(GE contractor). Mark Bender and Lincoln Daley (Tow n of Milford). and Kirby Webster and Jill Billus from FYR
support contractor Skeo. The purpose of the inspection was to assess the protectiveness of the remedy. Appendix
F includes the completed site inspection checklist. Appendix G includes photographs from the site inspection.
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Site inspection participants met at 39 Elm Street, the location of Keyes Memorial Park. Participants discussed the
status of the remedy. Participants walked the Site, including the groundwater area, the Elm Street Area and the
Mill Street Area. Site inspection observations are below, organized by OU.
OU1 - Elm Street Area
Part of the Elm Street Area is paved and part is used for outdoor entertainment, with a band stand. The paved
parking lot is in good condition. No cracks or bulges were noted in the pavement. The vegetated area around the
band stand is sparse in vegetation, with some areas that are not well vegetated (appeared to have sparse weeds).
It is unclear whether there is not enough material for vegetation to grow, or if foot traffic hindered growth. While
this is not indicative of a current protectiveness issue, it should be monitored closely to ensure that it does not
become an issue. Erosion control measures, including installation of riprap along the riverbank and cemetery
embankment and placement of steel sheeting and a gabion basket retaining wall at the base of the riverbank. are
all present. They appear to be generally in very good condition.
Observation of some small areas near the top of the riprap slope along the Souhegan River show signs of early-
stage slope failure, where storm water runoff has eroded subsurface soils allowing subsidence or repositioning of
the rip rap surface. Some small weeds are also starting to grow up in the riprap. The weeds should be addressed,
and the low areas in the riprap should be addressed before they become bigger issues. Tow n plans for continued
redevelopment of Keyes Memorial Park include adding landscaping to the bandstand area. The Town would like
to ensure that the design plans are completed with state and EPA approval, to make sure the remedy is not
affected, and also to make sure that the Town can use trees and other landscaping product donations in the park.
As the bandstand remains in use. the Tow n may want to consider including a historical plaque highlighting the
Site's history. The plaque would help in ensuring the remedy's long-term protectiveness. given that the cap
underneath this area is necessary to maintain protectiveness.
OU1 - Mill Street Area
The Mill Street Area is vegetated with recently cut grass. The grass is well established. Boulders are present along
the roadside of the area.
OU1 - Drainage Ditch from the Mill Street Pond to the Souhegan River
Site inspection participants observed the drainage ditch culvert system as it runs past the Mill Street Area. It is
still present, with some vegetation. No obvious issues with water flow were observed in this area.
OU1 - Groundwater Contamination from the Mill Street Area through the Elm Street Area to the Souhegan
River
Site inspection participants walked down Keyes Drive toward the groundwater contamination area under Keyes
Field. Not all groundw ater monitoring wells could be located. The 2022 groundwater monitoring event is planned
for October 2022. It will use a metal detector to locate wells. All groundw ater wells in this area appeared to be in
good condition. Participants discussed vapor intrusion concerns and current and past activities to monitor the
potential for vapor intrusion.
OU2 - Souhegan River and Groundwater Under Keyes Field (no action)
Fish advisory signs are posted along both the northern and southern sides of the Souhegan River by the Boys and
Girls Club. One sign was observed on the south side of the river abutting the downtown Milford area, next to a
canoe launch near the Elm Street Area parking lot.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents'.'
Question A Summary:
Yes. As implemented, the OlJ 1 and OU2 remedies are functioning as intended by the decision documents, with
exceptions noted below .
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Remedial Action Performance
0U1
All required construction activities associated with the 1998 ROD. as amended, finished by July 2017.
Contaminated soil at the Elm Street Area and Mill Street Area was excavated and transported off site for disposal
at approved disposal facilities. The Mill Street Area was cleaned up to residential use standards (with one
exception near the railroad tracks) and re vegetated. The Elm Street Area was cleaned up to allow for recreational
use. The engineered soil cover and asphalt parking lot at the Elm Street Area are functioning as designed and
prevent exposure to remaining subsurface soil contamination. The cleanup has allowed the Tow n to redevelop the
Elm Street Area with an amphitheater for community events. The Tow n has additional plans for the Elm Street
Area, including landscaping and addition of a barrier along the top of the riverbank to limit access to the riprap.
The Tow n should continue to share future redevelopment plans with EPA and the state to ensure the ongoing
integrity of the remedial components and the long-term protectiveness of the remedy.
The selected remedial action for OU 1 groundwater is MNA. Groundwater and surface water monitoring are
ongoing as part of the Site's long-term EMP. While COC concentrations in many wells across the Site are low er
than pre-construction concentrations, other wells, such as MW-CR21 in the Mill Street Area, have reported
variable concentrations with no clear declining trends. Monitoring has identified the presence of residual DN APL
at the Mill Street Area that may be acting as an ongoing source of groundwater contamination. The significance of
this contaminant source in bedrock, including its impact on achieving cleanup levels in the timeframe estimated in
the ROD. should continue to be assessed as part of ongoing groundwater sampling and assessment conducted as
part of the OU 1 EMP. There is additional concern that PCBs in groundwater could re-contaminate sediments in
the Souhegan River. Further evaluation of the potential for ongoing flux of PCBs from the OlJ 1 groundwater
areas into the river is recommended.
PFAS was detected in groundwater during the 2019 sampling event. PFOS and PFOA were detected above EPA
RSLs. but below the state's ACQS. Further investigation of PFAS is warranted to determine if PFAS is related to
the Site.
OU2
All OU2 NTCRA construction activities required by the NTCRA Action Memorandum finished by October 2016.
The cleanup achieved the sediment cleanup level of 0.5 mg/kg. To determine if the fish tissue RAO has been
achieved, fish tissue sampling took place in 2021. All detected concentrations of PCBs were below the
preliminary removal goal of 0.34 mg/kg specified in EPA's NTCRA Action Memorandum. Fish tissue sampling
should continue to occur, at a minimum, every five years prior to the FYR to ensure long-term protectiveness.
The NHDES Environmental Health Program reviewed the 2021 fish tissue sampling results and noted that
concentrations of PCBs in redbreast sunfish and yellow bullhead are high enough to present an increased risk
from dietary exposure and their consumption should be limited.' Fish advisory signs are in place along the banks
of the Souhegan River near the site to limit fish consumption. EPA considers the 0.34 mg/kg Preliminary
Removal Goal (PRC) established in the 2016 NTCRA Action Memorandum to be protective of human health
based on EPA risk assessment methods. Fish tissue sampling should continue to occur, at a minimum, every five
years prior to the FYR to ensure long-term protectiveness. and the fish advisory signs will remain in place until
such time as EPA and NHDES determine it is appropriate for them to be removed.
System Operations/O&M
The Long-Term Monitoring Plan indicates that GE was responsible for the first phase of long-term monitoring,
which included semi-annual inspections from fall 2017 to spring 2019. The Tow n is responsible for the second
phase of long-term monitoring, which includes annual inspections. The annual inspections include visually
inspecting for evidence of erosion throughout the cover system. These erosion inspection activities ensure that the
6 Human Health Risk Assessment of Fish Consumption and Detected PCBs at the Fletcher's Paint Works and Storage
Facility Site (OU-2) - Souhegan River, dated April 15, 2022.
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remedy is functioning as intended. Additionally, the annual inspections address concerns with cover system
erosion resulting from increased storm frequency and precipitation resulting from climate change impacts in New-
England.
The Town has not yet submitted documentation of the inspections to EPA and the state. It is unclear if the Town
has been conducting the inspections as outlined in the Long-Term Monitoring Plan.
During the FYR site inspection, minor erosion and settlement of topsoil and riprap was observed in two locations
along the top of the riverbank. These areas have continued to erode throughout the end of 2022. During site
inspections at the end of 2022, NHDES observed signs of early-stage slope failure, where storm water runoff has
eroded subsurface soils allow ing subsidence or repositioning of the rip rap surface. Based on notification of the
early-stage stope failure, and at the request of the Agencies. GE is evaluating the cause of the erosion and slope
failure and are planning to repair the erosion in 2023. During the FYR site inspection participants also observed
areas of the cap with sparse vegetation near the amphitheater. Weeds were observed grow ing in the riprap along
the riverbank. Maintenance issues should be addressed as they are identified to ensure the long-term integrity of
the cap.
Implementation of Institutional Controls and Other Measures
Institutional controls in place include a tow n ordinance to restrict land uses and protect the integrity of the cap at
the town-owned Elm Street Area and the adjacent cemetery. Institutional controls also include a town ordinance
that establishes a GMZ prohibiting groundwater use in an area covering about 36 properties. The GMZ may need
to be expanded if COC concentrations above cleanup levels are found outside the current GMZ boundary.
EPA has determined that land use controls are not necessary for the tow n ow ned parcels 25-133 and 25-111 due
to the nature of the final remedial action. For both parcels, the remedial action met the cleanup level of 1 mg/kg
for PCBs in soil, allow ing for UU/UE.
Although not required by the 1998 ROD as amended. GE implemented environmental protection easements and
declarations of restrictive covenants for the two privately owned parcels (parcel 25-110 and the railroad property)
in May 2012 and January 2013, respectively. As documented in EPA's March 31, 2005 approval letter for the
OU1 P re-Design Investigation Report. EPA indicated that the observed concentrations of total PCBs at sampling
location MSSB-C01 (located along the rail line) were consistent with EPA's Spill Policy (40 CFR 761.125) for
commercial areas. Therefore, those soils would not be subject to the 1 mg/kg soil cleanup level specified for total
PCBs in surface and subsurface soils at the Mill Street Area. Since the 1 mg/kg PCB cleanup level was not
required for these parcels. UU/UE is not supported near parcel 25-110 and the railroad property, and therefore
these recorded ICs are appropriate.
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QUESTION B: Arc the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid'.'
Question 6 Summary:
No. There have been changes in toxicity values, exposure assumptions, exposure pathw ays, methods of evaluating
risk and potential standards since EPA issued the Site's RODs. as discussed below. The changes are not expected
to alter the protectiveness of the remedy because:
• The cleanup levels and RAOs used at the time of the 1998 OU1 ROD and subsequent decision documents
(2001 ESD. 2009 ROD Amendment and 2010 ESD) are still valid. Although the state standard for arsenic
in groundwater (5 (ig/L) is now more stringent than the arsenic cleanup level of 10 (ig/L. this change does
not affect the protectiveness of the remedy because no one is consuming contaminated groundwater and
institutional controls are in place to prevent future exposures.
• Site COCs exceed the groundwater cleanup levels and, while not a COC. the presence of PFAS in
groundwater was confirmed above EPA RSLs. However, groundw ater docs not pose a health concern
because businesses and residents near the Site are connected to a public water supply and institutional
controls that prohibit groundw ater use are in place.
The vapor intrusion pathway requires further evaluation at the Site, particularly near the multi-use building at the
corner of Elm Street and Reyes Drive (5 1 Elm Street). The 2021 TCE concentration in water table well MW-18B
(30 (ig/L) corresponds to a carcinogenic risk of 2.53 x 10"5 and a hazard quotient of 5.8 for a residential indoor air
scenario and corresponds to a carcinogenic risk of 4.04 xlO"6 and a hazard quotient of 1.38 for a commercial
indoor air scenario, both exceeding EPA's point of departure (hazard index = 1) (See Appendix I for VISL
calculations). A multiple lines of evidence approach is necessary to determine if vapor intrusion is occurring at
potentially harmful levels. More discussion is provided below .
Changes in Standards and To Be Considered Criteria Concentrations (THCs)
New standards should be considered during the FYR process as part of the protectiveness determination. Under
the NCP. if a new requirement is promulgated after ROD signature, and. as part of the FYR process it is
determined that the requirement needs to be attained to ensure that the remedy is protective of human health and
the environment, then the FYR should recommend issuing a future decision document that adds the new
requirement as an ARAR to the remedy.
EPA guidance states:
"Subsequent to the initiation of the remedial action new standards based on new scientific information or
awareness may be developed and these standards may differ from the cleanup standards on which the
remedy was based. These new ... | standards | should be considered as part of the review conducted at
least every five years under CERCLA §121 (c) for sites where hazardous substances remain on-site. The
review requires EPA to assure that human health and the environment are being protected by the remedial
action. Therefore, the remedy should be examined in light of any new standards that would be applicable
or relevant and appropriate to the circumstances at the site or pertinent new |standards|. in order to ensure
that the remedy is still protective. In certain situations, new standards or the information on which they
are based may indicate that the site presents a significant threat to health or environment. If such
information comes to light at times other than at the five-year reviews, the necessity of acting to modify
the remedy should be considered at such times." (See CERCLA Compliance with Other Laws Manual:
Interim Final (Part 1) EPA/540/G-89/006, August 1988, pages 1-56.)
As part of this FYR. ARARs and TBC guidance for the Site set forth in the decision documents were review ed to
identify any newly promulgated or modified standards that may affect the protectiveness of the remedy.
Groundwater cleanup levels were set based on ARARs (MCLs, non-zero MCLGs, state AGQSs as available, or
other criteria such as a health advisory or state guideline). Table H-l in Appendix H compares the groundwater
cleanup levels to current MCLs and state AGQSs. The current state standard for arsenic (5 (ig/L) is more stringent
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than the cleanup level of 10 (.ig/L. All other standards were either less stringent or the same as the cleanup levels.
The PCB cleanup levels, which considered the PCB Spill Cleanup Policy, also remain valid.
The change to the arsenic state standard is not expected to affect protectiveness of the remedy because there is no
current exposure to contaminated groundwater and institutional controls are in place to prevent future exposure.
• PFAS
Federal
In May 2022, EPA issued updated noncancer reference dose (RfD) values for several PFAS compounds,
which result in the follow ing RSLs at hazard quotient target 0.1:
o PFOA: 6 nanograms per liter (ng/L) (ppt)
o PFOS: 4 ng/L
o PFNA: 6 ng/L
o PFHxS: 40 ng/L
o Hexafluoropropylene oxide dimer acid (HFPO-DA) (Gen-X): 6 ng/L
The RfD values for PFOA. PFOS. PFNA and PFHxS are based on Agency for Toxic Substances and
Disease Registry (ATSDR) minimal risk levels (MRLs) for ingestion exposure.
The RfD value for HFPO-DA (Gen-X) is based on a chronic oral RfD from EPA Office of Water, which
is 3E-06.
In May 2021, EPA issued an updated noncancer RfD for PFBS. PFBS has a chronic oral RfD of 3E-04.
As show n in the Data Review section of this FYR Report. 17 wells were sampled for PFO A. PFOS.
PFHxS and PFNA in Fall 2019. The wells were not analyzed for HFPO-DA. PFOS was detected above
the EPA RSL in one well (MW-03BR) and PFOA was detected above the EPA RSL in four wells (MW-
06B, MW-21CR. MW-23C and MW-25B). Although there are exceedances of the PFO A and PFOS
RSLs. the remedy remains protective because no one is drinking the groundwater and institutional
controls are in place to prohibit use of groundw ater. Further evaluation of PFAS is recommended.
State of New Hampshire
In July 2020, New Hampshire promulgated state MCLs for the follow ing four PFAS. individually or
combined, into the state's Safe Drinking Water Act:
o PFOA: 12 ppt
o PFOS: 15 ppt
o PFHxS: 18 ppt
o PFNA: 1 1 ppt
(Current state law requires that AGQSs be the same value as any MCL established by NHDES. and also
that they be at least as stringent as health advisories set by EPA)
At this time. EPA has made no determination of whether these state standards will need to be added as an
ARAR for the Site. They should, however, be used as screening values for PFAS compounds without
more conservative RSLs. For purposes of this FYR. EPA has evaluated the PFAS data collected against
EPA's RSLs and the State's PFAS MCLs.
As show n in the Data Review section of this FYR Report. 17 wells were sampled for PFOA. PFOS.
PFHxS and PFNA in fall 2019. All detected concentrations were below the state's PFAS MCLs.
Summary
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The Fall 2019 annual sampling event included sampling for PFOA. PFOS. PFHxS and PFNA in
groundwater at 17 representative monitoring wells. The wells were not analyzed for HFPO-DA. PFOS
was detected above the EPA RSL in one well (MW-03BR) and PFOA was detected above the EPA RSL
in four wells (MW-06B, MW-2 ICR. MW-23C and MW-25B). All detected concentrations were below
the state's MCLs. Although there are exceedances of the PFOA and PFOS RSLs. the remedy remains
protective because there are no exposures to groundwater and institutional controls are in place to prohibit
use of groundwater until cleanup levels are met. Due to the exceedances of PFOA and PFOS above
EPA's RSLs. EPA recommends further evaluation of PFAS.
• 1,4-Dioxane
Federal
Using 2013 updated Integrated Risk Information System (IRIS) toxicity information and the standard
Superfund risk assessment approach. EPA's carcinogenic risk range of 10"6 to 10"4 for 1.4-dioxane
equates to a concentration range of 0.46 (ig/L (parts per billion |ppb|) to 46 (.ig/L (ppb).
State of New Hampshire
In September 2018, NHDES modified its ACQS for 1,4-dioxane from 3.0 (ig/L (ppb) to 0.32 (ig/L (ppb).
Summary
1.4-Dioxane is not a COC at the Site. Waste characterizations samples and water samples from the
temporary water treatment system collected during the OU1 remedial action and reported in the 2018
Remedial Action Report were analyzed for 1,4-dioxane; 1.4-dioxane was not detected above laboratory
detection limits.
• Floodplain
Federal floodplain management: Federal regulations at 40 CFR Part 6. Appendix A, identified in the 2009
ROD Amendment were withdrawn. Furthermore, these regulations, and therefore the current CERCLA
remedy, only addressed potential floodplain impacts up to the 100-year flood elevation. Current federal
floodplain regulations at 40 CFR Part 9 require a greater assessment of potential floodplain impacts,
including preventing the release of contamination from waste management units and other remedial
infrastructure up to the 500-year floodplain elevation. The NTCRA for sediment considered the 500-year
floodplain and included construction of 500-year floodplain mitigation measures.
EPA has assessed potential floodplain impacts from a 500-year flood event on the remedial infrastructure
in the floodplain. such as monitoring wells and the soil caps in the Elm Street and Mill Street Areas. EPA
has not identified any protectiveness issues at this time.
Changes in Toxicity and Other Contaminant Characteristics
• 2022 PFOA Noncancer Toxicity Value
In May 2022, EPA released an updated oral RfD of 3E-06 mg/kg-day for PFOA. based on the ATSDR
MRL. The new value indicates that PFOA is more toxic from non-cancer health effects and would result
in an increased non-cancer risk.
PFOA was detected above the EPA RSL in four wells (MW-06B, MW-21CR. MW-23C and MW-25B)
during the fall 2019 sampling event. Although there are exceedances of the PFOA RSL. the remedy
remains protective because no one is drinking the groundwater and institutional controls are in place to
prohibit use of groundwater.
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• 2022 PFOS Noncancer Toxicity Value
In May 2022, EPA released an updated oral RfD of 2E-06 mg/kg-day for PFOS. based on the ATSDR
MRL. The new value indicates that PFOS is more toxic from non-cancer health effects and would result
in an increased non-cancer risk.
PFOS was detected above the EPA RSL in one well (MW-03BR) during the fall 2019 sampling event.
Although there is an exceedance of the PFOA RSL. the remedy remains protective because no one is
drinking the groundwater and institutional controls are in place to prohibit use of groundwater.
• 2022 PFNA Noncancer Toxicity Value
In May 2022, EPA released an oral RfD of 3E-06 mg/kg-day for PFNA, based on the ATSDR MRL.
Previously, no RfD was available for PFNA.
Sampling for PFN A in fall 2019 did not identify PFN A above its RSL in any of the 17 wells sampled.
• 2022 PFHxS Noncancer Toxicity Value
In May 2022, EPA released an oral RfD of 2.0E-05 mg/kg-day for PFHxS. based on the ATSDR MRL.
Previously, no RfD was available for PFHxS.
Sampling for PFHxS in fall 2019 did not identify PFHxS above its RSL in any of the 17 wells sampled.
• 2022 HFPO-DA (Gen-X) Noncancer Toxicity Value
In May 2022, EPA released an oral RfD of 3.0E-06 mg/kg-day for HFPO-DA. also known as Gen-X.
based on an oral RfD available from EPA Office of Water. Previously, no RfD was available for HFPO-
DA
The 2019 sampling event did not evaluate the presence of HFPO-DA.
• 2021 PFBS Noncancer Toxicity Value
PFBS has a chronic oral RfD of 3E-04 mg/kg-day based on an EPA provisional peer reviewed toxicity
value (PPRTV) (EPA. 2021a). This RfD value should be used when evaluating potential risks from
ingestion of contaminated groundw ater at Superfund sites where PFBS might be present based on site
history. Potential estimated health risks from PFBS. if identified, would likely increase total site risks
due to groundw ater exposure. Further evaluation of potential risks from exposure to PFBS in other
media at the Site might be needed based on site conditions and may also affect total site risks.
The 2019 sampling event did not evaluate the presence of PFBS.
• 2021 Updated Recommendations on the Use of Chronic or Subchronic Noncancer Values
In 2021, a memorandum was released from EPA's Office of Land and Emergency Management (OLEM)
regarding the use of subchronic toxicity values rather than the chronic noncancer value for 19 chemicals.
This recommendation is based on OLEM's Human Health Regional Risk Assessment Forum's
(OHHRRAF) Toxicity Workgroup evaluation of the toxicity of 32 chemicals. The OHHRRAF Toxicity
Workgroup identified 21 oral and 1 1 inhalation noncancer toxicity values where a subchronic toxicity
value was low er than its corresponding chronic toxicity value. After review of relevant information, the
OHHRRAF recommended use of the subchronic toxicity value rather than the chronic value for 19 of the
32 chemicals, as follows below .
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Subchronic inhalation RfC selected for the follow ing chemicals (Chemical Abstracts Service Registry
Number [CASRN]):
• Acrylic acid (79-10-7)
• 2-Ethoxyethanol (110-80-5)
• Ethyl-chloride (75-00-3)
• 2-Methoxyethanol (109-86-4)
• Vinyl chloride (75-01-4)
Subchronic oral RfD selected for the follow ing chemicals (CASRN):
• Acrylonitrile (107-13-1)
• Allyl alcohol (107-18-6)
• Atrazine (1912-24-9)
• Bromodichloromethane (75-27-4)
• Cadmium (7440-43-9)
• p-Chloroaniline (106-47-8)
• p-Cresol (106-44-5)
• Ethyl acetate (141-78-6)
• Ethylbenzene (100-41-4)
• Ethylene glycol (107-21-1)
• Heptachlor (76-44-8)
• Hexachlorobenzene (118-74-1)
• Hexachlorocyclohexane, gamma (58-89-9)
• 1.2.4.5-Tetrachlorobenzene (95-94-3)
OHHRRAF recommended the chronic inhalation noncancer value for the follow ing chemicals: ammonia,
chlordane, 1.1-DCE. methyl tert-buty 1 ether, nitromethane and vinyl acetate.
OHHRRAF recommended the chronic oral noncancer value for the following chemicals: aery lam ide.
acrylic acid. 1.1-biphenyl. cyclohexanone, endosulfan, ethylene glycol monobutyl ether and
pentachlorophenol.
Ethylbenzene is a COC in groundwater at the site. Ethylbenzene levels are decreasing and were below
cleanup level of 700 ug/L in all wells sampled between 2018 and 2021. Although the toxicity value was
updated for ethylbenzene from 1E-01 mg/kg-day to 5E-02 mg/kg-day. the remedy remains protective
because groundwater is not used for drinking water, and institutional controls are in place to prohibit use
of groundwater.
• 2020 Trans-1,2-Dichloroethylene Noncancer Toxicity Value
In November 2020, EPA finalized a new RfC for trans- 1,2-dichloroethylene based on a new PPRTV.
Previously, there was no RfC for trans-1.2-dichloroethylene.
Trans 1.2-dichloroethylene is not a site COC. However, it was analyzed for and not detected in site
monitoring wells during the 2017 comprehensive TCL/TAL groundwater sampling event.
• Lead in Soil Cleanups
EPA continues to examine the science around lead exposure. Updated scientific information indicates that
adverse health effects are associated with blood lead levels (BLLs) at less than 10 micrograms per
deciliter ((.ig/dL). Several studies have observed "clear evidence of cognitive function decrements in
young children with mean or group BLLs between 2 and 8 (.ig/dL".
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Based on this updated scientific information. EPA is including an evaluation of potential lead risks, with a
goal to limit exposure to residential and commercial soil lead levels such that a typical (or hypothetical)
child or group of similarly exposed children would have an estimated risk of no more than 5% of the
population exceeding a 5 (.ig/dL BLL. This is based on evidence indicating cognitive impacts at BLLs
below 10 (ig/dL. A target BLL of 5 (ig/dL reflects current scientific literature on lead toxicology and
epidemiology that provides evidence that the adverse health effects of lead exposure do not have a
threshold.
EPA's 2017 OLEM memorandum Transmittal of Update to the Adult Lead Methodology's Default
Baseline Blood Lead Concentration and Geometric Standard Deviation Parameters provides updates on
the default baseline blood lead concentration and default geometric standard deviation input parameters
for the Adult Lead Methodology (ALM). These updates are based on the analysis of the National Health
and Nutrition Examination Survey 2009-2014 data, with recommended the updated value for baseline
blood lead concentration being 0.6 (ig/dL and the updated geometric standard deviation being 1.8.
Using updated default Integrated Exposure Uptake Biokinetic Model for Lead in Children and ALM
parameters at a target BLL of 5 (ig/dL, site-specific lead soil screening levels (SLs) of 200 parts per
million (ppm) and 1,000 ppm are developed for residential and commercial/industrial exposures,
respectively.
Given the ongoing review of information, the above SLs are considered in this FYR for informational
purposes. The Rl included analysis of lead and other metals during the on site soil assessment. The
average concentration of lead in soil was found to be below 100 ppm. Therefore, these updates do not
impact the protectiveness of the remedy.
The excavation and off-site disposal of contaminated soil from the Elm Street Area and the Mill Street
Area finished in 2017. The Elm Street Area has been backfilled with clean fill, and a protective cover has
been installed. Institutional controls limit the use of the Elm Street Area to recreational uses only, and no
disturbance of the protective cover is allowed without EPA notification. The Mill Street Area has also
been backfilled with clean fill and a grass cover has been installed. Residential use of the Mill Street Area
is permitted but there are no current plans for redevelopment. The remedial actions taken to date at the
Elm and Mill Street Areas have eliminated any potential exposures to lead-contaminated soils at these
two areas of the Site.
In 1995, as part of a removal action, soil with high levels of PCBs was excavated from a small number of
residential properties along Mill Street. The extent of excavation was based on PCB data but lead
concentrations in the soil on these properties was also obtained. Based on pre-excavation soil data, the
average lead concentration at these Mill Street properties was lower than 200 mg/kg. Most of the lead
contaminated soil was removed along with the PCB-containinated soil during the 1995 excavations, and
excavations were backfilled with clean fill. Lead analysis of the clean fill showed an average lead
concentration less than 20 mg/kg. Since the pre-excavation average lead concentration in residential soil
was less than 200 mg/kg. and the average lead concentration in the clean backfill was less than 20 mg/kg.
lead in soil is not an issue at these residential properties.
• 2017 Polycyclic Aromatic Hydrocarbons (PAHs) Cancer and Noncancer Toxicity Values
On January 19, 2017, EPA issued revised (less carcinogenic) cancer toxicity values and new non-cancer
toxicity values for benzo(a)pyrene. Benzo(a)pyrene did not have non-cancer toxicity values prior to
January 19, 2017. Benzo(a)pyrene is now considered to be carcinogenic by a mutagenic mode of action;
therefore, cancer risks must be evaluated for different human developmental stages using age-dependent
potency adjustment factors (ADAFs) for different age groups. The cancer potency of other carcinogenic
PAHs is adjusted by the use of relative potency factors, which are expressed relative to the potency of
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benzo(a)pyrene. The non-cancer effects of benzo(a)pyrene were not evaluated in the past due to the
absence of non-cancer values.
The soil cleanup levels for three carcinogenic PAHs are 0.2 mg/kg benzo(a)pyrene, 2.1 mg/kg for
benzo(a)anthracene and 2.0 mg/kg for benzo(b)fluoranthene. respectively. The changes in toxicity values
do not affect the protectiveness of the remedy because the soil has been removed wherever PCB soil
cleanup levels were exceeded and replaced with clean fill. Although the existing soil cleanup levels for
the three carcinogenic PAHs are about twice as high as the current residential soil RSLs based on cancer
risk of 1 x 10"6, the existing soil cleanup levels would still have acceptable cancer risk (i.e., 2 x 10"6) at the
soil cleanup level concentrations. For non-carcinogenic effects, the soil cleanup level for benzo(a)pyrene
(0.2 mg/kg) is much lower than the residential soil non-carcinogenic RSL for children (18 mg/kg).
Therefore, the soil cleanup level of 0.2 mg/kg is protective for non-carcinogenic effects. There are no
non-carcinogenic toxicity factors for benzo(a)anthracene or benzo(b)fluoranthene.
Changes in Risk Assessment Methods
Since the 2018 FYR. there have not been changes to human health risk assessment methodology with respect to
exposure estimates and risk calculation. In May 2022, EPA updated toxicity values that are incorporated into its
Vapor Intrusion Screening Level (VISL) calculator. The VISLs can be found on EPA's vapor intrusion webpage
(www.epa.gov/vaporintmsion). EPA also updated the RSL tables with the most current version, updated in May
2022. The most current RSLs are available on EPA's RSLs webpage (www.epa.gov/risk/regional-screening-
levels-rsls-generic-tables).
Changes in Exposure Pathways
Since completion of the OU1 remedy, the Town requested construction of a granite amphitheater on top of the
engineered soil cover at the Elm Street Area. EPA approved the request in 2019 and the Town constructed the
amphitheater in 2019. Use of the property for an amphitheater is consistent with the recreational use of the
property anticipated in the OlJ 1 ROD and ROD Amendment. The Town is interested in further redevelopment
activities at the Site, to include additional landscaping and a barrier wall or fence at the top of the riverbank in the
Elm Street Area. There are no current plans for redevelopment of the Mill Street Area, though the Town of
Milford expressed an interest during the Five-Year Review site inspection in potentially using this area as a dog
park in the future.
• 2021 Development of the Ecological Screening Values (ESVs) for PFAS
Ecological screening values (ESVs) have been developed to support screening-level ecological risk
assessments at sites where PFAS have been detected in soils and surface waters. The ESVs. developed for
eight PFAS. represent PFAS concentrations in soil and surface water at or below which chronically
exposed biota are not expected to be adversely affected and ecological risks or other impacts are
unlikely.7
The ESVs support the screening-level steps (steps 1 and 2 of eight steps) of EPA's Ecological Risk
Assessment Guidance for Superfund and may be applied at sites undergoing investigation for the historic
release or disposal of PFAS. to identify whether PFAS levels pose potential unacceptable ecological risks.
Sites that have concentrations of PFAS that exceed ESVs may require further investigation in a baseline
ecological risk assessment, which in turn may support risk-management decisions and actions to reduce
risks. These ESVs are solely for use in conducting screening-level ecological risk assessments and are not
recommended or intended for use as default cleanup values.
The ESVs were developed for the follow ing media and receptors:
7 ESVs can be found in Derivation of PFAS Ecological Screening Values. M. Grippo. J. Hayse. I. Hlohowskyj
and K. Picel. Environmental Science Division. Argonne National Laboratory. September 2021.
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o Soils for invertebrates,
o Soils for plants.
o Soils for avian and mammalian wildlife,
o Surface water for freshwater and marine aquatic biota,
o Surface water for aquatic-dependent avian and mammalian wildlife.
Surface water samples have not been analyzed for PFAS. However, due to the exceedances of PFOA and
PFOS above EPA's RSLs in groundwater, further evaluation of PFAS in surface water may be warranted.
• 2018 EPA VISL Calculator
In February 2018, EPA launched an online VISL calculator, which can be used to obtain risk-based
screening level concentrations for groundwater, sub-slab soil gas and indoor air. The VISL calculator
uses the same database as the RSLs for toxicity values and physiochemical parameters and is updated
automatically during the semi-annual RSL updates. The User's Guide provides more details on how to
use the VISL calculator: www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator.
Shallow water table well MW-18B had a TCE concentration of 30 (.ig/L in 2021. The TCE concentration
is greater than the NHDES Groundwater to Indoor Air screening level of 20 ng/L. MW-18B well is
located along Reyes Drive and within 100 feet of a multi-use building at 51 Elm Street. 5 1 Elm St is
zoned "C" commercial by the Town of Milford. However, based on observations during the five-year
review site inspection, there is a potential that the building may also be used as a residence. Since
construction of the OU1 remedy. TCE concentrations in MW-18B have fluctuated above and below the
NHDES Groundwater to Indoor Air screening level (26 (.ig/L in 2017, 27 (.ig/L in 2018, 22 (.ig/L in 2019
and 15 (.ig/L in 2020). The post-construction concentrations are greater than the TCE concentrations
observed before remedy construction (8.6 (.ig/L in 2016). It is inferred that the depth to groundwater at
5 1 Elm Street is consistent with depth to groundwater at MW-18B and MW-42B, approximately 22 -27ft
below ground surface.
Therefore, data from water table well MW-18B were selected for vapor intrusion screening with EPA's
VISL calculator. Both residential and commercial use scenarios were selected for the screening. VISL
screening results indicate the 2021 groundwater TCE concentration in water table well MW-18B (30
(.ig/L) corresponds to a carcinogenic risk of 2.53 x 10-5 and a hazard quotient of 5.8 for a residential
indoor air scenario and corresponds to a carcinogenic risk of 4.04 x 10-6 and a hazard quotient of 1.38 for
a commercial indoor air scenario, both exceeding EPA's point of departure (hazard index = 1) (See
Appendix I for VISL calculations).
More assessment of the potential for vapor intrusion at the building adjacent to MW-18B is warranted to
determine if vapor intrusion to indoor air of the building is occurring at potentially unacceptable levels.
A multiple lines of evidence approach, consistent with EPA's Technical Guide for Assessing and
Mitigating the Vapor Intrusion Pathw ay from Subsurface Vapor Sources to Indoor Air
(www.epa.gov/sites/default/files/2015-09/documents/oswer-vapor-intrusion-technical-guide-final.pdf)
should be implemented.
Expected Progress Toward Meeting RAOs
The RAOs for soil and groundwater described in the 1998 OlJ 1 ROD (as amended), and the RAOs for sediments
and fish tissue described in the OU2 NTCRA Action Memorandum, remain valid. These RAOs are summarized
in the Response Actions section of this FYR Report.
Soil and sediment RAOs have been met through the soil and sediment remediation and removal activities
completed by 2017. Institutional controls in place also prevent exposure to contaminated groundwater and
remaining soil contamination under the engineered cover at the Elm Street Area. Progress is being made toward
restoration of groundwater to drinking water standards. However, residual DNAPL in bedrock may be acting as a
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continuing source of groundwater contamination and possibly recontamination of remediated river sediment.
Long-term monitoring continues to document the quality of groundwater and surface water over time.
Fish sampling data collected in 2021 confirmed PCB concentrations in fish tissue have been reduced to levels less
than the 0.34 mg/kg PCB goal set in the 2016 NTCRA Action Memorandum. The potential exists for an ongoing
flux of PCBs from the OU 1 groundwater areas to the Souhegan River that may, in the future, re-contaminate
remediated OU2 sediments above the 0.5 mg/kg PCB cleanup level.
QUESTION C: Has any other information come to light that could call into question the protectiveness of
the remedy?
The impacts of climate change in New England continue to pose increasing risks to some contaminated sites.
Increases in air and water temperature, precipitation, flooding and periods of drought can result in altered fate and
transport pathw ays and exposure assumptions, impaired aquatic habitats, increased dispersal of contaminants,
damage to remediation related structures, and, ultimately, ineffective remedies.
The risks posed by climate change in New England could impact the protectiveness of the remedy at the Site.
Most of the land at the Site is classified as upland. How ever, a portion of the Site, namely Kcycs Memorial Park
and the Elm Street Area adjacent to the Souhegan River, is within the 500-year and 100-year flood zone. The
impacts of increased frequency of extreme weather events could cause flooding of the Souhegan River, which
may adversely affect components of the remedy including damage to the engineered cap in the Elm Street Area
through erosion. Additionally, increased precipitation events could lead to erosion of the engineered cap in the
Elm St area. Damage to the engineered cap could ultimately result in the remobilization of contaminants. To date,
significant flooding from the Souhegan River has not occurred on site, and therefore no flooding has impacted the
remedy. There have been periods of heavy rainfall that appear to be contributing to the erosion observed during
the five-year review site inspection and throughout the end of 2022, along the top of slope at the Elm Street
parcel. The erosion will be repaired, and future cover system erosion will continue to be monitored and remedied
during site O&M. The site Long Term Monitoring plan addresses erosional concerns with the requirement of
annual erosion inspection of the cover system. Climate change-related impacts to the remedy will continue to be
monitored through the FYR process.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OlJ(s) without Issues and Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): OU1
Issue Category: Other
Issue: PFOA and PFOS were detected in groundwater above EPA RSLs. It is
unknown if PFAS is related to the Site.
Recommendation: Conduct further evaluation of PFAS to determine if it is
related to the Site.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
2/27/2025
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OU(s): OU1
Issue Category: Operations and Maintenance
Issue: The Site's 2017 O&M Plan indicates that the Town is responsible for the
second phase of O&M activities, beginning in 2019. It is unclear if the Town has
been conducting all necessary O&M activities and annual inspections. EPA and
the state have not received O&M reports.
Recommendation: The Town needs to conduct O&M activities and annual
inspections, as specified in the O&M Plan (if not done already) and submit
required documentation to EPA and the state.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
2/27/2024
OU(s): OU1
Issue Category: Monitoring
Issue: TCE concentrations in water table monitoring well MW-18B, located
within 100 feet of a multi-use commercial/residential building, resulted in
potentially unacceptable risks via the vapor intrusion pathway using EPA's VISL
calculator. More information is needed to determine if vapor intrusion is
occurring at potentially unacceptable levels.
Recommendation: Conduct further evaluation of the vapor intrusion pathway at
the multi-use commercial/residential building near MW-18B, using a multiple-
lines-of-cvidence approach consistent with EPA guidance.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
PRP
EPA/State
4/26/2024
OU(s): OU1,
OU2
Issue Category: Remedy Performance
Issue: The potential exists for an ongoing flux of PCBs from the OU 1
groundw ater areas to the Souhegan River that may. in the future, re-contaminate
remediated OU2 sediments above the 0.5 mg/kg PCB cleanup level.
Recommendation: Evaluate the flux of PCB-contaminated groundwater into the
Souhegan River, impacts to sediment, and impacts to sediment cleanup level
based on the fish consumption pathway.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
2/27/2025
Other Findings
In addition, the follow ing recommendations were identified during the FYR:
• Continue to maintain the fish advisory signs along the banks for the Souhegan River and collect fish
tissue samples at least every five years.
• Conduct routine maintenance at the Site. Repair the areas of erosion observed at the top of the riverbank
riprap during the FYR site inspection that have continued eroding throughout the end of 2022 and
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evaluate the early-stage slope failure. Repair monitoring well MW09 where standing water was observed
in the road box.
• The Town should continue to implement their Institutional Control on the Elm Street parcel (the 2019
Town Ordinance) and notify EPA and NHDES of site work that will involve interaction with subsurface
soils. Lack of proper notification regarding disturbance of subsurface soils could impact site
protectiveness by potentially exposing PCB-contaminated soils located beneath the engineered cap.
• Residual DNAPL was observed in Mill Street Area bedrock well MW-CR21 in 2019. Continue to assess
the significance of DN APL in bedrock, including its impact on achieving cleanup levels in the timeframe
estimated in the ROD. as part of ongoing groundw ater sampling and assessment under the OU1 EMP.
• The lateral extent of site-related groundw ater contamination above cleanup levels may extend outside the
established GMZ near the MW-11 well cluster and in upgradient Mill Street Area well MW-35C.
Additional data and further review is needed to determine if the GMZ needs to be expanded.
• A postcard survey and water use assessment should be conducted to evaluate potential groundwater use
within the GMZ.
VII. PROTECTIVENESS STATEMENT
IVolCCtiMMK'SS Sl;ilcmcnl(s)
Operable Unit:
Protectiveness Determination:
Planned Addendum
OU1
Short-term Protective
Completion Date:
N/A
Protectiveness Statement: The remedy at OU 1 currently protects human health and the environment. All
construction activities required by the 1998 OlJ 1 ROD (as amended) have been completed.
Contaminated soils have been excavated to EPA's selected cleanup levels and transported off-site. All
OU 1 land and groundwater institutional controls are in place. However, in order for the remedy to be
protective in the long-term, the follow ing actions need to be taken to ensure protectiveness:
• Conduct further evaluation of the vapor intrusion pathway at the property near MW-18B, using
a multiple-lines-of-ovidence approach consistent with EPA guidance
• Conduct further evaluation of PFAS
• Ensure the Town conducts O&M activities and annual inspections, as specified in the O&M
Plan and submit required documentation to EPA and the state
IVolCCtiMMK'SS Sl;ilcmcnl(s)
Operable Unit:
Protectiveness Determination:
Planned Addendum
OU2
Short-term Protective
Completion Date:
N/A
Protectiveness Statement: The OU2 remedy currently protects human health and the environment.
Contaminated sediments in the Souhegan River have been excavated and transported off site. Signs
warning anglers not to eat fish caught from the Souhegan River have been posted. Results from a recent
fish tissue monitoring event found that PCBs in fish tissue were below the PRG specified in the 2016
NTCRA Action Memorandum. For the remedy to be protective over the long term, the follow ing action
needs to be taken:
• Evaluate the flux of PCB-contaminated groundwater into the Souhegan River, impacts to
sediment, and impacts to sediment cleanup level based on the fish consumption pathway.
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Sitewide I'rolccliMMicss Stiitoment
Protectiveness Determination:
Short-term Protective
Planned Addendum
Completion Date:
N/A
Protectiveness Statement: Both the OU1 and 0U2 remedies currently protect human health in the short
term. However, in order for the remedy to be protective in the long-term, the follow ing actions need to
be taken to ensure protectiveness:
• Conduct further evaluation of the vapor intrusion pathway at the property near MW-18B, using
a multiple-lines-of-cvidence approach consistent with EPA guidance.
• Conduct further evaluation of PFAS
• Ensure the Town conducts O&M activities and annual inspections, as specified in the O&M
Plan and submit required documentation to EPA and the state
• Evaluate the flux of PC B-contam mated groundwater into the Souhegan River, impacts to
sediment, and impacts to sediment cleanup level based on the fish consumption pathway.
VIII. NEXT REVIEW
The next FYR for the Fletcher's Paint Works & Storage Facility Superfund site is required five years from the
completion date of this review.
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APPENDIX A - REFERENCE LIST
Arcadis. 2016. 21 Cottage Street Vapor Intrusion Assessment. Fletcher's Paint Works and Storage Facility
Superfund Site. Milford. New Hampshire. Prepared for General Electric Company, Albany, New York. July 11.
2016.
Arcadis. 2017a. Remedial Action Report. Operable Unit 2 - Souhegan River Sediments. Non-Time Critical
Removal Action. Fletcher's Paint Works and Storage Facility Superfund Site. Milford. New Hampshire. Prepared
for General Electric Company, Albany, New York. April 2017.
Arcadis. 2017b. Environmental Monitoring Plan, Fletcher's Paint Works and Storage Facility. Superfund Site -
Operable Unit 1. Milford. New Hampshire. Prepared for General Electric. Albany. New York. December 2017.
Arcadis. 2018. Remedial Action Report. Fletcher's Paint Works and Storage Facility. Superfund Site - Operable
Unit 1. Milford. New Hampshire. Prepared for General Electric Company, Albany, New York. April 2018.
Arcadis. 2019a. Environmental Monitoring Report - Fall 2018, Fletcher's Paint Works and Storage Facility
Superfund Site. Milford. New Hampshire 03055. Prepared for GE Corporate One EHS. August 2019.
Arcadis. 2019b. Summary of August and September 2019 Site Inspection. Fletcher's Paint Works and Storage
Facility Superfund Site - Operable Units OU1 and OU2, Milford. New Hampshire 03055. Prepared for GE
Corporate One EHS. November 15, 2019.
Arcadis. 2020. Environmental Monitoring Report - Fall 2019, Fletcher's Paint Works and Storage Facility
Superfund Site. Milford. New Hampshire 03055. Prepared for GE Corporate One EHS. July 31, 2020.
Arcadis. 2021. Environmental Monitoring Report - Fall 2020, Fletcher's Paint Works and Storage Facility
Superfund Site. Milford. New Hampshire. Prepared for General Electric Company. December 2021.
Arcadis. 2022a. Data Summary Report - 2021 Souhegan River Fish Tissue Sampling. Fletcher's Pain Works and
Storage Facility Superfund Site - Operable Unit 2, Milford. New Hampshire. Prepared for General Electric
Company. March 2022.
Arcadis. 2022b. Environmental Monitoring Report - Fall 2021, Fletcher's Paint Works and Storage Facility
Superfund Site. Milford. New Hampshire. Prepared for General Electric Company. November 2022 Draft for
EPA Review.
ATS DR. 2021. Toxico logical Profile for Perfluoroalkyls. www.atsdr.cdc.gov/toxprofiles/tp200.pdf.
EPA. 1988. CERCLA Compliance with Other Laws Manual: Interim Final (Part 1). EPA/540/G-89/006. August
1988.
EPA. 2010. Indoor Air Soil Vapor Intrusion Study Report. Fletcher's Paint Superfund Site. Milford NH.
December 2009. Prepared for the Office of Site Remediation & Restoration. Remedial Program. U.S.
Environmental Protection Agency. New England. December 3, 2010.
EPA 2010. Indoor Air Soil Vapor Intrusion Study Report. Fletcher's Paint Superfund Site. Milford NH.
September 2010. Prepared for the Office of Site Remediation & Restoration. Remedial Program. U .S.
Environmental Protection Agency. New England. October 6. 2010.
EPA. 2014. Human Health Evaluation Manual, Supplemental Guidance: Update of Standard Default Exposure
Factors Memorandum. OSWER Directive 9200.1-120. February 6. 2014.
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EPA. 2017. Transmittal of Update to the Adult Lead Methodology's Default Baseline Blood Lead Concentration
and Geometric Standard Deviation Parameters Memorandum. OLEM Directive 9285.6-56. May 17. 2017.
EPA. 2018. Vapor Intrusion Screening Level (VISL) Calculator. Office of Land and Emergency Management.
Office of Superfund Remediation and Technology Innovation (OSRTI). May 2018.
www.epa.gov/vaporintaision/vapor-intmsion-screening-level-calculator.
EPA. 2021. Provisional Peer-Reviewed Toxicity Values for Perfluorobutane Sulfonic Acid (PFBS) and Related
Compound Potassium Perfluorobutane Sulfonate. Office of Research and Development. Center for Public Health
and Environmental Assessment. EPA/690/R-21/001F. 2021.
EPA. 2021. Recommendations on the Use of Chronic or Subchronic Noncancer Values for Superfund Human
Health Risk Assessments Memorandum, May 26. 2021. Office of Land and Emergency Management,
Washington. D C. 2021.
EPA. 2021. Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its
Ammonium Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as "Gen-X Chemicals." Office of
Water. Health and Ecological Criteria Division. Washington. D C. October 2021.
EPA. Integrated Risk Information System (IRIS). Available at www.epa.gov/iris.
EPA. Provisional Peer-Reviewed Toxicity Values. Available at www.epa.gov/pprtv.
EPA. Regional Screening Level Tables. Available at www.epa.gov/risk/regional-screening-levels-rsls-generic-
tables.
EPA Region 1. 1998. Record of Decision. Fletcher's Paint Works and Storage Facility Superfund Site. Milford.
New Hampshire. September 30. 1998.
EPA Region 1. 2001. Explanation of Significant Differences. Fletcher's Paint Works and Storage Facility
Superfund Site. Milford. New Hampshire. March 14, 2001.
EPA Region 1. 2009. Amended Record of Decision. Fletcher's Paint Works and Storage Facility Superfund Site.
Milford. New Hampshire. June 15, 2009.
EPA Region 1. 2010. Second Explanation of Significant Differences. Fletcher's Paint Works and Storage Facility.
Superfund Site. OU1. Milford. New Hampshire. September 30, 2010.
EPA Region 1. 2012. Record of Decision. OU2 Groundwater (Keyes Field). Fletcher's Paint Works and Storage
Facility Superfund Site. Milford. NH. September 28, 2012.
EPA Region 1. 2016. Request for Non-Time Critical Removal Action at the Fletcher's Paint Works and Storage
Facility Superfund Site. Milford. New Hampshire - Action Memorandum. June 6. 2016.
EPA Region 1. 2018. First Five-Year Review Report for Fletcher's Paint Works and Storage Facility Superfund
Site. Milford. New Hampshire. February 27. 2018.
EPA Region 1. 2018. Preliminary Close Out Report. Fletcher's Paint Works and Storage Facility Superfund Site.
Tow n of Milford. New Hampshire (NHD001079649). August 2018.
M. Grippo. J. Hayse. I. Hlohowskyj. and K. Picel. 2021. Derivation of PFAS Ecological Screening Values.
Environmental Science Division. Argonne National Laboratory. September 2021.
A-2
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APPENDIX B - SITE CHRONOLOGY
Table B-l: Site Chronology
Event
Date
NHDES identified VOC contamination in the Keves Well
1984
EPA led a removal action at the Elm Street Area and the Mill Street Area (drum
disposal and placement of temporary caps at the areas)
1988
EPA added the Site to the NPL
March 1989
EPA began the Rl
My 1990
EPA installed a fence at the Elm Street Area
1991
EPA led a removal action (waste disposal, demolition of Mill Street facility structures
and tempo rarv cap repairs)
1993
GE led a removal action at three residential properties across from the Mill Street
location
1995
GE removed PCB-contaminated soil from a small area next to the old Fletcher's Paint
Works building to allow for construction of a town Korean War Memorial
1996
EPA completed the Site's RI/FS
EPA issued a ROD (OU1)
September 1998
EPA and the Town signed a Consent Decree
November 1998
USAGE led a removal action, demolishing the former Fletcher's Paint Works building,
covering the area with a tempo rarv liner and constructing a fence
2000 to 2001
EPA issued an ESD (OU 1)
March 2001
EPA issued a UAO to GE
July 2001
EPA issued a ROD Amendment (OU 1)
June 2009
EPA issued a second ESD (OU 1)
September 2010
A restrictive covenant was recorded for parcel 25-100
Mav 2012
EPA issued the OU 2 ROD
September 2012
GE began the OU 1 remedial action
November 2012
A restrictive covenant was recorded for the railroad property north of parcels 25-110
and 25-111
January 2013
EPA issued a NTCRA Action Memorandum for OU2 sediment
June 2016
EPA completed the sediment removal action
April 2017
EPA issued the Site's first FYR Report
February 2018
Actions since last Five-Year Review
The Town established a GMZ to prohibit groundwater use in affected areas
April 2018
EPA considered the OU 1 remedy construction complete
August 2018
The Town adopted a Land Use Restriction ordinance for tax parcels 25-12 and 25-13;
the Site achieved EPA's Sitewide Readv for Anticipated Reuse performance measure
July 2019
The Town constructed an amphitheater on the Elm Street Area cap
2019
GE completed fish tissue sampling (OU2)
August 2021
B-l
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APPENDIX C - PRESS RELEASE
5/3/22, 12:10 PM EPA to Review Cleanups si 14 New England Superfund Sites this Year { US EPA
**- '>n GUiru1ebc>>e ol the United States government
Hf'h slip., tn' Lnt.",,
A FQA United States
Environmental Protection menu
^Jr ILbJI Agency
Search EPA.gov
News Releases: Region 01 : < iopa.gov/newsreleases/seaich• pi ess_offic#/rs$on-01-
226161>
CONTACT US
EPA to Review Cleanups at 14 New
England Superfund Sites this Year
January 19,2022
Contact. Information
Mikayta Rumph {rumph.mikayla@epa.gov)
(61?) 913-1016
BOSTON (Jan, It, 2022} - The U.S. Environmental Protection Agency (ERA) will
conduct comprehensive reviews of completed cleanup work at 14 National Priority List
(NPL) Superfund sites, including three federal facilities, in New England this year. The
sites, located in Connecticut, Maine, Massachusetts, New Hampshire, and Rhode Island,
will undergo a legally required Five-Year Review to ensure that previous remediation
efforts at the sites continue to protect public health and the environment.
"Ensuring completed Superfund site cleanup work remains protective of human health
and the environment is a priority for EPA," said EPA New England Acting Regional
Administrator Deb Szaro. "By completing reviews of the cleanups every five years, EPA
fulfills its duty to remain vigilant so that these communities continue to be protected."
The Superfund Sites where EPA will conduct Five-Year Reviews in 2022 are listed below.
The web links provide detailed information on site status as well as past assessment
and cleanup activity. Once the Five-Year Review is complete, its findings will be posted
https7Avww.epa.gov/newsreleases/epa-revjew-cleanups-14-new-engiand-superfund-sftes-ye8r 1/5
C-l
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5/3/22, 12:10 PM
EPA to Review Cleanups at 14 New England Superfund Sites this Year | US EPA
to the website in a final report,
Five-Year Reviews of Superfund sites in New England to be completed in 2022:
Auburn Road Landfill, Londonderry, New Hampshire
WWW.epa.gov/superfurid/aubumroad
Beede Waste Oil, Plaistow, New Hampshire
www.epa.gov/superfund/beede
Dover Municipal Landfill, Dover, New Hampshire
WWW.epa.gov/snperfund/dover
Gallup's Quarry, Plainfield, Connecticut
www.epa.gov/superfund/gallup
Kellogg-Deering Well Field, Norwalk, Connecticut
www.epa.gov/superfund/kellogg
O'Connor Co., Augusta, Maine
WWW.epa.gov/superfund/ocon nor
Peterson/Puritan, Inc., Lincoln/Cumberland, Rhode Island
www.epa.gov/su perfu nd/peterson
Union Chemical Co., Inc., South Hope, Maine
WWW.epa.gov/superfund/union
Winthrop Landfill, Winthrop, Maine
WWW.epa.gov/superfund/winthrop
Federal Facilities
Hanscom Field/Hanscom Air Force Base, Bedford, Massachusetts
WWW.epa.gov/superfund/hanscom
Natick Laboratory Army Research, Development and Engineering Center, Natick,
Massachusetts
WWW.epa.gov/superfund/naticklab
https://www.epa.gov/newsreieases/epa-review-cieanups-14-new-engiand-superfund-sites-year
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5/3/22, 12:10 PM
EPA to Review Cleanups at 14 New England Superfund Sites this Year | US EPA
Portsmouth Naval Shipyard, Kittery, Maine
www.epa.gov/su perfund/portsmouth
Five-Year Reviews of Superfund sites in New England to start In 2022 and to be
completed in 2023:
Fletcher's Paint Works & Storage, Milford, New Hampshire
WWW. epa. gov/sil pe rfll nd/fletche r
Background
Throughout the process of designing and constructing a cleanup at a hazardous waste
site, EPA's primary goal is to make sure the remedy will be protective of public health
and the environment. At many sites, where the remedy has been constructed, EPA
continues to ensure it remains protective by requiring reviews of cleanups every five
years. It is important for EPA to regularly check on these sites to ensure the remedy is
working properly. These reviews identify issues (if any) that may affect the
protectiveness of the completed remedy and, if necessary, recommend action(s)
necessary to address them.
There are many phases of the Superfund cleanup process including considering future
use and redevelopment at sites and conducting post cleanup monitoring of sites. EPA
must ensure the remedy is protective of public health and the environment and any
redevelopment will uphold the protectiveness of the remedy into the future.
The Superfund program, a federal program established by Congress in 1980,
investigates and cleans up the most complex, uncontrolled or abandoned hazardous
waste sites in the country and endeavors to facilitate activities to return them to
productive use. In total, there are 123 Superfund sites across New England.
More information:
Superfund and other cleanup sites in New England:
https://www.epa.gov/cleanups/deaning-new-england
https://www.epa.gov/newsreleases/epa-review-cieanups-14-new-england-superfund-sites-year
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APPENDIX D - INTERVIEW FORMS
FLETCHER'S PAINT WORKS & STORAGE FACILITY SUPERFIJND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Fletcher's Paint Works & Storage Facility
EPA ID: NHDOO1079649
Interviewer name: Ashlin Brooks
Interviewer affiliation: EPA
Subject name: Brian Thornton
Subject affiliation: New Hampshire
Department of Environmental Services
Subject contact information: Brian.P.Thornton@des.nh.gov
Interview date: October 21 -November 4, 2022 Interview time: October 21 -November 4, 2022
Interview location: Virtual
Interview format (circle one): In Person Phone Mail Email Other:
Interview category: State Agency
1. What is your ov erall impression of the project, including cleanup, maintenance and reuse activ ities (as
appropriate)?
Soil and sediment removal activities associated with OU 1 and OU2 were completed by July 2017 according to the
2012 approved Remedial Design. In accordance with the remedy, institutional controls were put in place
historically and in years subsequent to RA completion that include: (1) activity and use restrictions (AUR) on
certain Mill Street area parcels; (2) Elm Street parcel AUR. (3) Town of Milford ordinance governing
groundw ater use within the defined Groundw ater Management Zone; and (4) publication of a fish consumption
advisory for one segment of the Souhegan River near the Site that has historically been impacted by PCB
contamination. Completion of OlJ 1/OU2 soil and sediment removal activities, implementation of ICs. and on-
going site monitoring constitute substantial completion of ROD-defined remedial components.
Annual inspections of the restored areas of what are now an extension of the eastern end of Reyes Park, have
revealed incipient slope failure near the top of the restored rip rap slope in two locations that will required further
evaluation and remedial effort. O&M responsibilities for the restored areas were transferred to the Tow n of
Milford (Tow n) one year follow ing 100 percent completion of remedial components (2018). Therefore, repairs to
the restored areas will need to be addressed by the Tow n in a timely manner that ensures cap integrity in affected
areas.
The Town has entered an evolving planning process for the recreational development of the Elm
Street area of the site. Construction of a stone amphitheater, in part built from a local granite source, has already
occurred, following review and comment on the plans by NHDES and EPA (collectively the agencies). The Town
has submitted plans for further development that includes the addition of clean fill for grade adjustment,
installation of fencing, curbing, signing, lighting and associated electrical conduit, construction of walkways and
benches, and planting of trees and shrubs. As a result of the Town's planning efforts, it has become apparent to
the agencies that a revision to the existing Elm Street-area AUR may be warranted. If needed. NHDES will work
with EPA to review and revise AlJRs and continue coordinated review, comment, and oversight of the Town's
plans and ultimately construction of enhanced reuse site improvements.
2. What is your assessment of the current performance of the remedy in place at the Site?
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Implemented remedial components have eliminated direct contact risk for approved uses of the affected parcels.
On-going monitoring and evaluation of the extent of site contaminants above site ICLs and NH Ambient
Groundwater Quality Standards in groundwater may necessitate the need to adjust the existing GMZ and
associated monitoring netw ork. Exceedances of State Indoor Air Screening Levels for TCE in overburden
groundwater monitoring well MW-18B support moving forward with an assessment of possible indoor air
impacts, given its proximity to existing commercial/residential structures on parcel 25-11. As previously noted,
review of existing institutional controls may be warranted in light of the Town's plans for site modifications to
enhance recreational reuse.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial
activities from residents in the past five years?
No residents have communicated concerns or complaints regarding environmental issues or remedial activities in
the past five years.
4. Has your office conducted any site-related activities or communications in the past five years? If so,
please describe the purpose and results of these activities.
The agencies have taken action or had communications with the following entities in the last five years:
1. EPA and NHDES reposted signage (previously posted signs had disappeared) in areas upgradient.
near, and downgradient of the site advising anglers not to consume locally caught fish due to PCB
contamination.
2. The agencies had communication with the Souhegan River Local Advisory Committee regarding
the 2021 fish tissue sampling program and subsequent report of findings. The 2021 fish tissue
sampling program found a decrease in total PCB concentrations to below Preliminary Removal
Goals of 0.34 mg/kg as specified in the EPA's NTCRA Action Memorandum. Since this data set
represents fish tissue PCB levels at one point in time, these findings will not result in the removal
of the existing fish consumption advisory. Future data collection efforts will be necessary to
confirm these results. In addition. NHDES is currently evaluating the possible implementation of
a broader sampling program to assess PCB levels in freshw ater fish of New Hampshire. The
results of this study may further inform site-related decisions.
3. The agencies had communications with the Tow n regarding reuse plans for both the Elm Street
and Mill St areas of the site. The agencies evaluation of reuse plans is on-going.
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?
In March 2021, NHDES revised the AGQS for Manganese from 840 (.ig/L to 300 (ig/L. This new value is
consistent with the 1998 ROD ICLs and should not have an effect on the protectiveness of the site's remedy. In
July 2021, NHDES revised the AGQS for arsenic from 10 (ig/L to 5 (ig/L. If the outcome of actions defined under
Question 6 below confirm consumption of impacted groundw ater within the GMZ, this AGQS revision for
arsenic may affect remedy protectiveness. In July 2020, NHDES established AGQS for PFOA. PFOS. PFHxS and
PFNA of 12, 15, 18 and 11 ng/L. respectively. As of yet, 17 wells have been tested for PFAS during the Fall
2019 monitoring round and none of the results exceeded the relevant AGQS. so the 2020 PFAS AGQS are not
expected to affect the remedy's protectiveness. In September 2018, NHDES revised the AGQS for 1.4-Dioxane to
0.32 (ig/L from 3.0 (ig/L. In 2012, 10 samples were collected, five from the Mill Street area and five from the Elm
Street area. There were no detections of 1,4-Dioxane above the reporting limit of 0.2 (ig/L in any of the samples
collected therefore this change in not expected to have an effect on the remedy protectiveness.
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the
associated outstanding issues?
D-2
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As previously noted, review of existing institutional controls may be warranted considering the Town's plans for
site modifications to enhance recreational reuse. In addition, the agencies have discussed with representatives of
the Town of Milford the need for additional measures to ensure no one is consuming site-impacted groundwater,
as defined by the existing GMZ established via a 2018 Town Ordinance. The measures would include a postcard
survey to seek voluntary feedback on possible groundwater usage in conjunction with a review of water utility
billing records for properties within the GMZ.
7. Are you aware of any changes in projected land use(s) at the Site?
As noted in response to Question 1. the Tow n of Milford has proposed improvements to the Elm Street area.
These proposed changes will result in an end use that is consistent with planned uses if actions are taken to ensure
protection of workers during construction and to ensure the improvements and plantings of trees and shrubs will
not pose a risk of exposure in the long-term (e.g., root mass size that doesn't exceed planting corridor
dimensions).
The Tow n has initiated some discussions about potential re-use of parcels 25-11 1 and 25-112 (the former Draper
Fuel property) in the Mill Street area as a dog park/dog walking area. The agencies have begun evaluation of the
potential to make adjustments to these properties" ICs to accommodate the Town's interest in this beneficial reuse
of the properties.
8. Do you have any comments, suggestions or recommendations regarding the management or operation of
the Site's remedy?
NHDES recommends a VI evaluation on the structure associated with lot 25-11 based on the concentrations of
TCE in nearby water table monitoring well MW-18B. The TCE concentrations in MW-18B have exceeded the
NHDES GW-2 Vapor Intrusion Screening Level (20 (.ig/L as of 2013) in three of the last four sampling events and
has exhibited elevated (relative to previous data) levels of TCE since the 2017 OU-1 remedial action was
completed.
In addition. NHDES recommends the continuation of DN APL gauging in the Mill Street area well MW-2 ICR.
based on the presence of DN APL noted in this monitoring well during the Fall 2019 Phase 1 ICL monitoring
event. It is recommended that nearby shallow bedrock monitoring wells MW-07CR. MW-21CR. MW-23C, and
MW-24C are also gauged for the presence of DNAPL. Gauging of these wells is consistent with General
Comment #2 of the EPA's Fall 2019 EMR
Comment Letter's request of DN APL gauging during the Fall 2021 monitoring event. Continued DN APL gauging
of these wells will help further evaluate the potential presence of DN APL in the shallow bedrock of this portion
of the site.
The agencies have discussed the possibility of recontamination of remediated sediments in the Souhegan River
due to migration and discharge of PCB-contaminated groundwater from the site. It is recommended that the
agencies further consider requiring the PRP to submit a work plan to assess PCB levels with depth in remediated
sediment of the Souhegan River through the placement of passive PCB measuring devices or other means.
NHDES also recommends the continued evaluation and upkeep of ICs and maintenance of the remedy to ensure
its protectiveness. This includes: (1) review of existing institutional controls in light of the Town's plans for site
modifications to enhance recreational reuse; and (2) the evaluation of potential groundwater use within the
Town's GMZ via a postcard survey conducted by the Town to seek voluntary feedback on possible groundwater
usage in conjunction with a review of water utility billing records for properties contained within the GMZ. In
addition, it is recommended that the agencies coordinate a timely response for addressing the maintenance issues
of the noted incipient slope failure features near the top of the rip rap slope in at least two locations that will
require further evaluation and remedial effort.
D-3
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9. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report?
Yes
FLETCHER'S PAINT WORKS & STORAGE FACILITY SIJPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Fletcher's Paint Works & Storage Facility
EPA ID:NHD001079649
Interviewer name: Ashlin Brooks
Interviewer affiliation: EPA
Subject name: Celeste Barr
Subject affiliation: Souhegan River Local
Advisory Committee
Subject contact information: eelestepbarr@gmai 1.com
Interview date: October 2 lh -November 9, 2022
Interview time: October 21 -November 9, 2022
Interview location: Virtual
Interview format (circle one): In Person
Phone
Mail
Email
Other:
Interview category: Local Advisory Committee
1. Are you aware of the former env ironmental issues at the Site and the cleanup activ ities that hav e taken
place to date?
Yes. I am in the unusual position of having grow n up on the street of Fletcher Paint Works and having worked
for USEPA Reg. I.
2. Do you feel well-informed regarding the Site's activities and remedial progress? If not, how might EPA
convey site-related information in the future?
Yes- I seek it out and when I cannot find answers or updates I contact the site manager from EPA or NHDES.
3. Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing?
I checked with the DPW Director and he said no. There has been vandalism in the adjacent Reyes Recreation
Field but not on the Fletcher site.
4. Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy?
No.
5. Are you aware of any changes in projected land use(s) at the Site?
No.
6. Has EPA kept inv olved parties and surrounding neighbors informed of activ ities at the Site? How can
EPA best provide site-related information in the future?
D-4
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Keeping online status and data up to date for the site.
7. Do you have any comments, suggestions or recommendations regarding the project?
I am anxiously follow ing the fish tissue analyses in the hopes that declining PCB levels in fish will allow the fish
advisory on that particular stretch of the Souhegan River to end.
8. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report?
Yes
FLETCHER'S PAINT WORKS & STORAGE FACILITY SUPERFIJND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Fletcher's Paint Works & Storage Facility
EPA ID:NHD001079649
Interviewer name: Ashlin Brooks
Interviewer affiliation: EPA
Subject name: Lincoln Daley
Subject affiliation: Director of Community
Development
Subject contact information: 1 dalev@mi 1 ford.nh.gov
Interview date: October 21 -November 15, 2022 Interview time: October 21-November 15, 2022
Interview location: Virtual
Interview format (circle one): In Person
Phone
Mail
Email
Other:
Interview category: Local Government - Town of Milford
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken
place to date?
Yes.
2. Do you feel well-informed regarding the Site's activities and remedial progress? If not, how might EPA
convey site-related information in the future?
I feel well informed. Both EPA and NHDES officials have been very helpful in educating and assisting the Tow n
throughout the site activities and remedial process.
3. Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing?
Unfortunately, there has a been recent rash of vandalism on the property involving the new stage project and
throughout Reyes Memorial Park. The testing shed and surrounding fence has been impacted/damaged. Other
than vandalism, the Tow n has not experienced any unusual activities or problems.
4. Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy?
No.
D-5
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5. Are you aware of any changes in projected land use(s) at the Site?
No. The Town continues to work with EPA, NHDES, and GE regarding the granite stage project and associated
landscaping around the perimeter of the site.
6. Has EPA kept inv olved parties and surrounding neighbors informed of activ ities at the Site? How can
EPA best provide site-related information in the future?
Yes. the EPA has kept involved parties and surrounding neighbors informed of activities at the Site. It would be
beneficial if the EPA and the Town could work collaboratively to provide updates (when needed) to post on the
Town's website and Town related social media outlets.
7. Do you have any comments, suggestions or recommendations regarding the project?
None.
8. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report?
Yes.
D-6
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APPENDIX E - DATA REVIEW SUPPORTING DOCUMENTATION
LEGEND
m APPROXIMATE SURFACE WATER SAMPLE APPROXIMATE LOCATION OF STORM SEWER
• LOCATION " " " CULVERT
PHASE 1 MONITORING WELL LOCATION DRAINAGE DITCH/CULVERT SYSTEM
/ PHASE II MONITORING WELL LOCATION MILL STREET PROPERTY BOUNDARY
j, MONITORING WELL NOT INCLUDED IN f~~l ELM STREET PROPERTY BOUNDARY
* MONITORING NETWORK UNDER THE EMP QAS STATION PROPERTY BOUNDARY
~ SURFACE WATER STAFF GAUGE 0 200 400
GENERAL ELECTRIC COMPANY
FLETCHER S PAINT WORKS AND STORAGE FACILITY
SUPERFUND SITE - M1LFORD. NEW HAMPSHIRE
ENVIRONMENTAL MONITORING REPORT
MONITORING WELL NETWORK
^ARCADIS IT
1 2015 AERIAL IMAGERY DOWNLOADED FROM 1 ^ 1
NH GRANIT HTTP//WWW GRANIT UNH EDU/ GRAPHIC SCALE
Source: 2020 EMR. prepared by Arcadis.
E-l
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E-2
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Figure E-3: Bedrock Potentiometric Surface Contours - Fall 2021
GENERAL ELECTRIC COMPANY
FLETCHER'S PAINT WORKS AND STORAGE FACILITY
SUPERFUND SITE - MILFORD. NEW HAMPSHIRE
ENVIRONMENTAL MONITORING REPORT
BEDROCK POTENTIOMETRIC SURFACE
CONTOURS - FALL 2021
£ ARCADIS
DRAFT
FOR EPA REVIEW
IXG.ND:
WA~ER
RAILROAD
PROPERT" I NFS (SEE NOTE 1}
APPROXIMATE ELM/WLL STREET AREA BOJtOARIES
(Sit mo it i)
PHASE MOnSTORIWC *EU
PHASE I M ON TOR INS VCO.
MONITORING WELL NOT INCLUDED IN VC1MT0-"?UC NETWORK
UNDER THE EMP
INFERRED CROUNDWATES ELEVATION IN FJE". ABOVE MEAN
SEA -EVEL (n. WSJ
INFERRED CSOUNDWATE8 ELEVATIOM CONTOUR (FT. AMSL)
CROUMJVW7ER F-OW ORECHON
Source: 2021 EMR, prepared by Arcadis.
E-3
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onstrtu»nts
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h"nchlCTocttien»
0 7SJ|0rej|
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l-rJW
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nd
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Figure E-4: Elm Street Area Groundwater Analytical Results with Comparison to Cleanup Levels
NVY-04B
CcosUusnt
PPB
ad 1 onsmuecrts
NO
MW-I8B
Consftmfit
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16 [16]
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15011511
36
LEGEND:
PHASE I MONITORING WELL
PHASE II MONITORING WELL
SURFACE WATER MEASUREMENT
LOCATION (BRIDGE NAIL)
~ ELM STREET PROPERTY BOUNDARY
(SEE FIGURE 2, NOTE 1)
DRAINAGE DITCH/CULVERT SYSTEM
APPROXIMATE CURRENT/FORMER GAS STATION
TAX WVRCEL BOUNDARY (SEE FIGURE Z NOTE 1)
NOTES:
t SEPTEMBER 2017 IMAGERY OBTAINED FROM GOOGLE EARTH
2 AIL LOCATIONS/BOUNDARIES ARE APPROXIMATE
3 ONLY p€ TEC TED CONSTITUENTS FOR WHICHAN
INTERIM CUEA&UP LEVEL (ICL)EXISTS ARE PRESENTED
5 FONT WITH
OFANtCL
S DUPLICATE RESULTS ARE PRESENTED W BRACKETS
8 J-ESTIMATED VALUE
8 " - PER SECTION 53 I OF TWE EMP, THIS WELL WAS RE SAMP LED FOR THE
CONSTITUENT NOTEO TO CONFIRM THE ICL EXCEEDANCE IN THE ORIGINAL SAMPLE
El WELL WA5 DRY, NO SAMPLE WAS COLLECTED
10 MA : NOT APPLICABLE, THE SAMPLE WAS NOl
THIS CONSTITUENT
11 ND * CONSTITUENTS WERE NOTOETECTED
GENERAL ELECTRIC COMPANY
FLETCHER'S PAINT WORKS AND STORAGE FACILITY
SUPERFUND SITE - MILFORD, NEW HAMPSHIRE
ENVIRONMENTAL MONITORING REPORT
ELM STREET AREA GROUNDWATER
ANALYTICAL RESULTS WITH COMPARISON
TO ICLS - FALL 2021
ftARCADIS
- 2021
Source: 2021 EMR. prepared by Arcadis.
E-4
-------
Figure E-5: Mill Street Area Groundwater Analytical Results with Comparison to Cleanup
Const* uont
[Toluene
Constituent
t*W-41B
Ccusliiiiefii
|Trichloio«ter.e
|TotaiPCBs
CcostituBni
Tnciiiwoaihane
'.J. .-if
• 'n ii
|fotaiPCBs
W»D|1J4')
Tduana
riicMo»i»ffiefw
Constituent
MW-C3AR
Constituent
ll.^-tTnchlctotienzecie
rriirhloioaiwne
Ccnstituwnt
Tduene
Ccuslitu-rit
T m; 11 lawmen*
2i:
•1 Tnchiixci-«n;6rf)e
11,2 4-Tncti IOfc-t»nzene
chloroetlWK
Ccn slim em
.-'•l-Tm-hlwotxmzfrfi*
CtrsMuail
|l,2.4-Tn6n;en»
[Tnchlcroethgoe
Ettiyt)*nz«ne
zjH D. NOTES:
I SEPTEMBER 2017 IMAGERY OBTAINED FROM GOOGLE EARTH
PHASE . MONITORING WELL f ^L0WTI0NS;B0UMDAR1ES AR£
3 ONLY DETECTED CONSTITUENTS FOR WHICH AN
INTERIM CLEANUP LEVEL |ICL) EXISTS ARE PRESENTED
DRAINAGE DITCH/CULVERT SYSTEM HIGHLIGHT REPRESENT AN EXCEEDANCE OF THE ARSENIC AGOS
MILL STREET PROPERTY BOUNDARY 5 ***** «"Ults are presented in brackets
(SEE FIGURE 2. NOTE t) • J - estimated value
AI¦mnnvi.i.Tr « .Dnc»,T/r«D.icD „ . _ 7 • - THE SECOND ESD ESTABLISHED AN ICL OF I0PP8 FOR ARSENIC
APPROXIMATE CURRENT/FORMER GAS STATION oNiUlv I 3071 THE NHDES AGOS FOR ARSENIC w AS REVISED TO 6 PPB
TAX PARCEL BOUNDARY (SEE FIGURE 2, NOTE 1)fl perfection 63 i OF tmEEMP THIS WELL WASRESAMPLEDFOR THE
CONSTITUENT NOTED TOCOHFIRM THE iCL EXCEEDANCE >N THE ORIGINAL SAMPLE
B NA = NOT APPLICABLE THE SAMPLE WAS NOT SUBMITTED FOR ANALYSIS OF
THIS CONSTITUENT
10 ND = CONSTITUENT(S) WAS(WERE)NOT DETECTED
PHASE II MONITORING WELL
j, MONITORING WELL NOT INCLUDED IN
** MONITORING NETWORK UNDER THE EMP
GENERAL ELECTRIC COMPANY
FLETCHER'S PAINT WORKS AND STORAGE FACILITY
SUPERFUND SITE - MILFORD, NEW HAMPSHIRE
ENVIRONMENTAL MONITORING REPORT
MILL STREET AREA ANALYTICAL RESULTS WITH
COMPARISON TO ICLS - FALL 2021
^ARCADIS I
Levels - 2021
Source: 2021 EMR, prepared by Arcadis.
E-5
-------
Figure E-6: TCE and PCB Distribution in Overburden Groundwater - 2021
Source: 2021 EMR, prepared by Arcadis.
E-6
-------
Figure E-7: TCE and PCB Distribution in Bedrock Groundwater - 2021
Source: 2021 EMR. prepared by Arcadis.
E-7
-------
Figure E-8: Fish Collection Locations - 2021
GOLDMAN DAM
LOCATION B •
ELM STREET AREA
LEGEND:
FISH COLLECTION AREA
GRAPHIC SCALE
GENERAL ELECTRIC COMPANY
FLETCHER'S PAINT WORKS AND STORAGE FACILITY
SUPERFUND SITE - MILFORD, NEW HAMPSHIRE
2021 SOUHEGAN RIVER DATA SUMMARY REPORT
FISH COLLECTION LOCATIONS
£ ARCADIS
LOCATION C
LOCATION A
Source: 2021 Souhegan River Data Summary Report, prepared by Arcadis.
E-8
-------
Table E-1: Summary of Groundwater Cleanup Level Exceedances - 2018 to 2021
2018
2019
2020"
2021
coc
Cleanup
Level
Exceed anees/T otal
Wells Sampled
Exceedances/Total
Wells Sampled
Exceedances/Total
Wells Sampled
Exceedances/Total
Wells Sampled
mm: 1.1
Max.
Concentration
(Well)
Max.
Concentration
(Well)
Max.
Concentration
(Well)
Max.
Concentration
(Well)
Arsenic
10
1/39
2/37
1/34
1/63
23.5 ng/L
(MW-03BR)
59 ng/L
(MW-03BR)
64.8 ng/L
(MW-03BR)
63.8 ng/L
(MW-03BR)
Benzene
5
2/39
3/37
2/32
3/63
63 ng/L
(MOBIL-04)
180 ng/L
(MW-38B)
110 |ig/L
(MW-38B)
35 ng/L
(MVV-38B)
1.2-
Dichloroethane
5
0/39
ND
0/37
ND
0/34
ND
0/63
ND
Ethylbcn/ene
700
0/39
0/37
0/32
0/63
450 ng/L
(MW-03BR)
210 ng/L
(MW-03BR)
240 |ig/L
(MW-03BR)
73 ng/L
(MW-03BR)
Manganese
300
11/39
8/39
6/34
7/63°
1,800 ng/L
(MW-03BR)
3,260 p,g/L
(MW-03BR)
2,450 |ig/L
(MW-03BR)
2,300 ng/L
(MW-03BR)
PCBs
0.5
13/39
7/37
12/34
20/63
530 |ig/Lb
(MW-23C)
33 ng/L
(MW-21CR)
160 ng/L
(MVV-2 ICR)
64 ng/L
(MVV-2 ICR)
Toluene
1,000
0/39
0/37
0/32
0/63
89 ng/L
(MOBIL-04)
20 ng/L
(MOBIL-04)
15 ng/L
(MOBIL-04)
12 ng/L
(MVV-32D)
1.2.4-Trichloro-
benzene
70
1/39
170 |ig/L
(MW-21CR)
1/37
85 ng/L
(MVV-2 ICR)
0/34
20 ng/L
(MW-18)
1/63
100 ng/L
(MVV-2 ICR)
TCE
5
9/39
11/37
9/32
12/63
110 |ig/L
(MW-08C)
41 ng/L
(MW-33D)
59 ng/L
(MW-33C)
34 ng/L
(MW-08C)
Notes:
a) The 2020 sampling event included the collection of two samples for analysis of VOCs from each of the wells, one
collected by peristaltic/bladder pump and one collected by bailer. Results from the samples collected by
peristaltic/bladder pump arc shown.
b) From a duplicate sample. The parent sample had a result of 60 ng/L.
c) Total manganese results only.
ND = not detected
NA = not applicable
Sources: 2018, 2019 and 2020 EMRs and the October 2021 Monthly Progress Report and the November 2021 Monthly
Progress Report.
E-9
-------
Table E-2: Groundwater Monitoring Results for MW-21C/MW-21CR - 2013 to 2020
Monitoring Wril
MW-21C
MW-21CR
Monitoring Program111
W**P
WMP
WMP
WMP
EMP
EMP
EMP
EMP
Para mater
ICL ipofri
i"2S-SEPT-13l
{22-JAN-146
I2S-APR-14)
(25-JUL-14)
f31-OCT-17)
(1-OCT-18]
(M-NOV-13)
(23-OCT-20|
Volatile Organ lea
1,2-DfcNoroeiharie
5.0
-
*
P re-
-H
-
Benzene
5.0
.
-H
.
Elnvlaenzene
7DQ
construction
-H
Toliiene
1.G0C
-
-
¦H
1.2
-
2.6
TUcnioroemene
5.0
210
310
400
230
Poet-
22 [16]
11
5.6
3.0
PCBa
Conatructkm
Total PCBs
0.5
210 JN
ISO
160
100
===>»»
450 [50C]
130
33
160
Inorganics
Margarese
3M
45.0
5D.5
55.5
49.3
257 [25fl
256
220
251
Margarese-fliierec
-
44.0
MA
NA
NA
21D [2151
NA
NA
NA
Arsenic™
10
NA
NA
NA
5.4 [4.91
-
Arsenic-filtered
-
-
HA
NA
NA
-H
NA
NA
NA
Source: 2020 EMR. prepared by Arcadis.
Table E-3: Surface Water Analytical Results - Fall 2020
SURFACE WATER ANALYTICAL RESULTS
ENVIRONMENTAL MONITORING REPORT - FALL 2020
FLETCHER'S PAINT WORKS AND STORAGE FACILITY 5UPERFUND SITE
GENERAL ELECTRIC COMPANY- MILFORD, NEW HAMPSHIRE
(Results are presented in parts per billion, ppbf
Location ID:
Date Collected:
SW-1
11 i'02i'20
SW-2
11j'02<20
Volatile Organic*
1,2,4-T richlorobenze-e
ND.;l.0'l
ND 11.01
1,2-Dchlcrcethane
ND(1-0)
NDfl.Ql
Benzene
NOfO.SOl
nd.;q 50i
Ethyl benzene
ND.;1 0)
NDfl.Ql
Toluene
ND(I.O)
NDfl.Ql
Tricidwoethene
ND(1.(J)
NDfl.Ql
PCBs
Aroclcr 1016
NDfO.33;
ND.;a 331
Aroclcr t221
ND (0.331
ND{0-33
Aroclcr 1232
ND [0.331
ND(Q.33
Aroclcr 1242
NDfO.331
ND.;Q-33
Aroclcr 1245
NDfO-331
ND{Q.33
Aroclcr 1254
NDj0.33}
ND{0-33
Aroclcr 1260
ND (0.331
ND(Q.33
Arcclor 1262
NDlO.331
ND.:033
Aroclcr 1265
NDI0.331
ND.;a.33
Tota PCBs
NDf0.33)
ND.;0 33
Inorganics
Manganese
95.0
37.a
Arsenic
ND(3.0)
NDf3.Ql
Notes:
1. Samples we'e collected fey Arcadis a-c siibrritted to SGS Aocubest -"or
labo'alory analysis.
2- ND - Compound was analyzed for, but not selected The value in pare-thes«5
reo»esenCs the associates detector: limit
Source: 2020 EMR Table 6, prepared by Arcadis.
E-10
-------
Table E-4: Surface Water Analytical Results for Multiple Monitoring Events
SURFACE WATER ANALYTICAL RESULTS FOR MULTIPLE MONITORING EVENTS
ENVIRONMENTAL MONITORING REPORT - FALL 2020
FLETCHER'S PAINT WORKS AND STORAGE FACILITY SUPERFUND SITE
GENERAL ELECTRIC COMPANY - MILFORD, NEW HAMPSHIRE
(Results are presented in parts per billion, ppb)
Sampling Location
SW-01
Parameter/Date
ICL
(18-OCT-17)
(27-SEP-18)
(11-NOV-19)
(Q2-NOV-20)
Volatile Organics
Trichloroethene
5.0
1.9
NA
-
-
PCBs
Total PCBs
0.5
1.0 | - | - | -
Inorganics
Calcium
-
21,300
NA
NA
NA
Iron
-
280
NA
NA
NA
Manganese
300
112
134
51.7
95.9
Sodium
-
51,100
NA
NA
NA
Zinc
369
NA
NA
NA
Arsenic
10
-
3.00
-
-
Inorganics-Filtered
Calcium
-
15.000
NA
NA
NA
Manganese
300
71.1
NA
NA
NA
Sodium
-
39,900
NA
NA
NA
Zinc
-
J 93
NA
NA
NA
Sampling Location
SW-02
Parameter/Date
ICL
(02-NOV-17I
(27-SEP-18)
[11-NOV-19]
(02-NOV-201
Semivolatile Organics
Caprolactam
-
1.4 J
NA
NA
NA
Inorganics
Aluminum
-
409
NA
NA
NA
Iron
-
608
NA
NA
NA
Manganese
3O0
62.5
45.9
33.7
37.0
Arsenic
10
-
3.00
-
-
Inorganics-Filtered
Aluminum
-
228
NA
NA
NA
Iron
—
317
NA
NA
NA
Manganese
300
46.4
NA
NA
NA
Notes:
1- Samples were collected by Arcadis and submitted to SGS Month America Inc. for laboratory analysis.
2. Data are presented only for constituents that were detected in at least one sample.
3. - = Not Detected
4. NA = Not analyzed
5. J = The compound/anatyte was positively identified; however, the associated numerical value is an estimated concentration only.
Source: 2020 EMR Table 7, prepared by Arcadis.
E-ll
-------
Table E-5: PFAS Groundwater Data, 2019
NHDES
AGQS
EPA
RSL'
Units
MW-03BR
MW-03C
MW-06A
MW-06B
MW-06C
MW-18A
MW-18B
MW-21CR
MW-23C
PFHxS
0.018
0.04
Hg/L
0.00868
ND (0.0034)
ND (0.0036)
ND (0.0036)
ND (0.0036)
ND (0.0034)
0.00406
ND (0.0033)
[ND (0.0033)1
ND (0.0042)
[ND (0.004)1
PFNA
0.011
0.006
Hg/L
ND (0.0034)
ND (0.0034)
ND (0.0036)
ND (0.0036)
ND (0.0036)
ND (0.0034)
ND
(0.0034)
ND (0.0033)
[ND (0.0033)1
ND (0.0042)
[ND (0.004)1
PFOS
0.015
0.004
Ug/L
0.0147
ND (0.0034)
0.00395
ND (0.0036)
ND (0.0036)
0.00207 J
0.00176 J
0.0022 J
[0.00205 J1
0.00253 J
[0.00199 J]
PFOA
0.012
0.006
Hg/L
0.00502
0.00223 J
0.00518
0.00727
ND (0.0036)
0.00468
0.00486
0.00609
[0.005791
0.0102
[0.009411
Notes:
a) May 2022 tap water RSLs based on a HO of 0.1, available at www.epa.gov/risk/regional-screening-levels-rsls-generic-tables (accessed 9/14/2022).
ND = analyte not detected. The number in parentheses is the associated detection limit.
Field duplicate sample results are presented in brackets.
J = The compound was positively identified. However, the associated numerical value is an estimated concentration only.
Bold result indicates an exceedance of the NHDES AGQS or EPA RSL.
Source: 2019 EMR, Table 7.
NHDES
ACQS
EPA
RSL'
Units
MW-24A
MW-24B
MW-24C
MW-25B
MW-25C
MW-34C
MW-38B
MW-38C
PFHxS
0.018
0.04
Hg/L
0.00107 J
ND (0.0036)
0.00115 J
ND (0.0033)
ND (0.0033)
ND (0.0038)
0.00363
0.00266 J
PFNA
0.011
0.006
Hg/L
ND (0.0036)
ND (0.0036)
ND (0.0036)
ND (0.0033)
ND (0.0033)
ND (0.0038)
ND (0.0034)
ND (0.0033)
PFOS
0.015
0.004
Hg/L
0.00142 J
ND (0.0036)
0.00195 J
0.0021 J
ND (0.0033)
ND (0.0038)
0.00308 J
0.00311 J
PFOA
0.012
0.006
0.00511
0.00206 J
0.00464
0.011
ND (0.0033)
ND (0.0038)
0.00438
0.00456
Notes:
a) May 2022 tap water RSLs based on a HQ of 0.1, available at www.epa.gov/risk/regional-screeiiing-levels-rsls-generic-tables (accessed 9/14/2022).
ND = analyte not detected. The number in parentheses is the associated detection limit.
Field duplicate sample results are presented in brackets.
J = The compound was positively identified. However, the associated numerical value is an estimated concentration only.
Bold result indicates an exceedance of the NHDES AGQS or EPA RSL.
Source: 2019 EMR, Table 7.
E-12
-------
Table E-6: Fish Tissue Mean PCB Concentrations - 2006 and 2021
2021 SOUHEGAN RIVER DATA SUMMARY REPORT
OPERABLE UNIT 2 (OU-2)
FLETCHER'S PAINT WORKS AND STORAGE FACILITY SUPERFUND SITE
GENERAL ELECTRIC COMPANY - MILFORD. NEW HAMPSHIRE
Area
Edible Fillet Samples
Whole-body Composite Samples
Redbreast sunfish
(skin-on fillets!
Yellow bullhead
{skin-off fillets]
White sucker
2006 Mean Total PCB Results (mg/kgj
Area A
I 38
1.1
: 48
Area 3
u8 ¦
0.14
0.87
Area C
" ""
50
2021 Mean Total PCB Results (mg.kg)
Area A
0 085
0.059
0.14
Area B
0 046
0.061
0.11
Area C
0 0 38
0.041
0.085
Notes;
1. The 2006 data include only the samples analyzed by NEA Inc. to be consistent with the preparation
and analysis used in 2021.
2. To calculate mean PCB results, one-Half of the method detection limit < MQL) was used
for non-cfeteet samples.
3. mg/kg - milligrams per kilogram.
Source: 2021 Souhegan River Fish Tissue Data Summary Report, Table 2.
E-13
-------
APPENDIX F - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: Fletcher's Paint Works & Storage Facility
Date of Inspection: 09/13/2022
Location and Region: Milford, New Hampshire; Region 1
EPA ID: NHD001079649
Agency, Office or Company Leading the FYR:
EPA Region 1
Weather/Temperature: Cloudy, 60s °F
Remedy Includes: (check all that apply)
Landfill cover/containment
~ Access controls
Institutional controls
~ Groundwater pump and treatment
~ Surface water collection and treatment
m. Other: Fish advisory signs
Monitored natural attenuation
~ Groundwater containment
~ Vertical barrier walls
Attachments: EH Inspection team roster attached
~ Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager
Name
Title
Date
Interviewed ~ at site ~ at office ~ by phone
Problems, suggestions ~ Report attached:
2. O&M Staff
Name
Title
Date
Interviewed ~ at site ~ at office ~ by phone
Problems/suggestions ~ Report attached:
3.
Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.
Agency.
Contact
Name
Problems/suggestions ~ Report attached:.
Title
Date
Phone
Agency.
Contact
Name
Title
Problems/suggestions ~ Report attached:.
Date
Phone
Agency
Contact
Name Title
Problems/suggestions ~ Report attached:
Date
Phone
Agency
Contact
Name Title
Problems/suggestions ~ Report attached:
Date
Phone
Agency.
Contact
F-l
-------
Name Title
Problems/suggestions [~~| Report attached:
Date
Phone
4.
Other Interviews (optional) HI Report attached:
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
13 O&M manual |3 Readily available |3 Up to date ~ N/A
13 As-built drawings [3 Readily available [3 Up to date ~ N/A
13 Maintenance logs ~ Readily available ~ Up to date ~ N/A
Remarks: The Town has not submitted O&M inspection logs since O&M responsibilities transferred
to the Town in 2019.
2.
Site-Specific Health and Safety Plan
~ Contingency plan/emergency response plan
Remarks:
~ Readily available
~ Readily available
~ Up to date
~ Up to date
§N/A
13 n/a
3.
O&M and OS HA Training Records
Remarks:
1^ Readily available
~ Up to date
~ n/a
4.
Permits and Service Agreements
~ Air discharge permit
~ Effluent discharge
~ Waste disposal. POTW
n Other permits:
Remarks:
~ Readily available
~ Readily available
~ Readily available
~ Readily available
~ Up to date
~ Up to date
~ Up to date
~ Up to date
13 n/a
13 n/a
El n/a
13 n/a
5.
Gas Generation Records
Remarks:
~ Readily available
~ Up to date
13 n/a
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
13 n/a
7.
Groundwater Monitoring Records
Remarks:
13 Readily available
^ Up to date
~ n/a
8.
Leachate Extraction Records
Remarks:
~ Readily available
~ Up to date
13 n/a
9.
Discharge Compliance Records
~ Air ~ Readily available
~ Water (effluent) ~ Readily available
Remarks:
~ Up to date
~ Up to date
|N/A
13 n/a
10.
Daily Access/Security Logs
~ Readily available
~ Up to date
13 n/a
F-2
-------
Remarks:
IV. O&M COSTS
(MM Organization
~ State in-house
53 PRP in-housc (Town of Milford)
l~l Federal facility in-house
~
~ Contractor for state
Kl Contractor for PRP (GE contractor)
HH Contractor for Federal facility
2.
O&M Cost Records
~ Readily available O Up to date
53 Funding mechanism/agreement in place Kl Unavailable
Original O&M cost estimate: __ ____ ~ Breakdown attached
Total annual cost by year for review period if available
From: To:
Date
Date
Total cost
From:
To:
Date
Date
Total cost
From:
To:
Date
Date
Total cost
From:
To:
Date
Date
Total cost
From:
To:
~ Breakdown attached
~ Breakdown attached
~ Breakdown attached
~ Breakdown attached
~ Breakdown attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons: None.
V. ACCESS AND INSTITUTIONAL CONTROLS g] Applicable ~ N/A
A. Fencing
1. Fencing Damaged ~ Location shown on site map ~ Gates secured N/A
Remarks:
B. Other Access Restrictions
1. Signs and Other Security Measures
Remarks:
~ Location shown on site map N/A
C. Institutional Controls (ICs)
F-3
-------
Implementation and Enforcement
Site conditions imply ICs not properly implemented
l~l Yes
M No
~ n/a
Site conditions imply ICs not being fully enforced
~ Yes
M No
~ n/a
Tvpe of monitoring (e.g.. self-reporting, drive bv): self-reporting
Frcauencv:
Responsible partv/agencv: Town/GE
Contact
Name Title
Date
Phone
Reporting is up to date
K Yes
~ No
~n/a
Reports arc verified by the lead agency
M Yes
~ No
~ n/a
Specific requirements in deed or decision documents have been met
l~l Yes
IXlNo
~ n/a
Violations have been reported
l~l Yes
13 No
~ n/a
Other problems or suggestions: ~ Report attached
2. Adequacy ~ ICs arc adequate ICs arc inadequate ~ N/A
Remarks: The town ordinance may not satisfy the requirements set forth in the 1998 ROD and Consent
Decree. The Institutional Controls section of the FYR Report provides more information.
D. General
1. Vandalism/Trespassing ~ Location shown on site map m No vandalism evident
Remarks:
2. Land Use Changes On Site ~ N/A
Remarks: The Town of Milford constructed a granite amphitheater at the Elm Street Area in 2019. with
EPA and NHDES approval. The Town of Milford would like to further redevelop the Elm Street Area
with additional landscaping.
3. Land Use Changes Off Site ~ N/A
Remarks: None.
VI. GENERAL SITE CONDITIONS
A. Roads ~ Applicable N/A
1. Roads Damaged ~ Location shown on site map ~ Roads adequate ~ N/A
Remarks:
B. Other Site Conditions
Remarks:
VII. LANDFILL COVERS ^ Applicable (Engineered Cover at the Elm Street Area) ~ N/A
A. Landfill Surface
1. Settlenient (low spots) ~ Location shown on site map ~ Settlement not evident
Area extent: Depth:
Remarks: Two areas at the top of the riverbank riprap shows signs of settlement/erosion.
2. Cracks ~ Location shown on site map [53 Cracking not evident
Lengths: Widths: Depths:
F-4
-------
Remarks:
3.
Erosion ~ Location shown on site map Q Erosion not evident
Area extent: Depth:
Remarks: Two areas at the too of the rivcrbank riprap show signs of settlement/erosion.
4.
Holes ~ Location shown on site map Holes not evident
Area extent: Depth:
Remarks:
5.
Vegetative Cover Grass K Cover properly established
PI No signs of stress Q Trees/shrubs (indicate size and locations on a diagram)
Remarks: Some areas of sparse grass coverage near the amphitheater.
6.
Alternative Cover (e.g., armored rock, concrete) Q N/A
Remarks: Paved parking lot at the Elm Street Area was in good condition.
7.
Bulges ~ Location shown on site map Bulges not evident
Area extent: Height:
Remarks:
8.
Wet Areas/Water Damage K Wet areas/water damage not evident
["I Wet areas PI Location shown on site map Area extent:
n Ponding PI Location shown on site map Area extent:
PI Seeps PI Location shown on site map Area extent:
PI Soft subgrade PI Location shown on site map Area extent:
Remarks:
9.
Slope Instability O Slides ~ Location shown on site map
No evidence of slope instability
Area extent:
Remarks:
B.
Benches ~ Applicable N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1.
Flows Bypass Bench Q Location shown on site map Q N/A or okay
Remarks:
2.
Bench Breached ~ Location shown on site map O N/A or okay
Remarks:
3.
Bench Overtopped ~ Location shown on site map ~ N/A or okay
Remarks:
C.
Letdown Channels ~ Applicable £<] N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
F-5
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slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots) ~ Location shown on site map
~ No evidence of settlement
Area extent:
Depth:
Remarks:
2.
Material Degradation ~ Location shown on site map
O No evidence of degradation
Material tvoc:
Area extent:
Remarks:
3.
Erosion ~ Location shown on site map
~ No evidence of erosion
Area extent:
Depth:
Remarks:
4.
Undercutting ~ Location shown on site map
~ No evidence of undercutting
Area extent:
Depth:
Remarks:
5.
Obstructions Tvdc:
n Location shown on site man Area extent:
Si/c:
Remarks:
~ No obstructions
6.
Excessive Vegetative Growth Tvdc:
~ No evidence of excessive growth
~ Vegetation in channels docs not obstruct flow
n Location shown on site man Area extent:
Remarks:
D.
Cover Penetrations Applicable ~ N/A
1.
Gas Vents ~ Active
l~l Passive
l~l Properly secured/locked Q Functioning O Routinely sampled Q Good condition
l~l Evidence of leakage at penetration O Needs ma
mtenance Kl N/A
Remarks:
2.
Gas Monitoring Probes
l~l Properly secured/locked Q Functioning O Routinely sampled O Good condition
l~l Evidence of leakage at penetration O Needs ina
mtenance ^ N/A
Remarks:
3.
Monitoring Wells (within surface area of landfill)
153 Properly secured/locked E3 Functioning Routinely sampled Q Good condition
l~l Evidence of leakage at penetration O Needs ina
mtenance ~ N/A
Remarks:
4.
Extraction Wells Leach ate
F-6
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l~l Properly secured/locked Q Functioning O Routinely sampled
C] Good condition
l~l Evidence of leakage at penetration O Needs maintenance
0N/A
Remarks:
5
Settlement Monuments Q Located Q Routinely surveyed
Remarks:
13 N/A
E.
Gas Collection and Treatment ~ Applicable N/A
1
Gas Treatment Facilities
l~l Flaring O Thermal destruction
Q Collection for reuse
l~l Good condition ~ Needs maintenance
Remarks:
2
Gas Collection Wells, Manifolds and Piping
l~l Good condition ~ Needs maintenance
Remarks:
3
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
l~l Good condition O Needs maintenance O N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable N/A
1
Outlet Pipes Inspected Q Functioning ~ N/A
Remarks:
2
Outlet Rock Inspected Q Functioning O N/A
Remarks:
G. Detention/Sedimentation Ponds Applicable (Stormwater retention basin adjacent to Keyes Drive
parking area) ~ N/A
1.
Siltation Area extent: Depth:
53 Siltation not evident
Remarks:
~ n/a
2.
Erosion Area extent: Depth:
IXI Erosion not evident
Remarks:
3.
Outlet Works O Functioning £
Remarks:
3 N/A
4.
Dam ~ Functioning £
Remarks:
3 N/A
H. Retaining Walls ~ Applicable N/A
1
Deformations d| Location shown on site map Deformation not evident
Horizontal displacement: Vertical displacement:
Rotational displacement:
F-7
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Remarks:
2.
Degradation O Location shown on site map £3 Degradation not evident
Remarks:
I. Perimeter Ditches/Off-Site Discharge ~ Applicable ^ N/A
1.
Siltation O Location shown on site map Q Siltation not evident
Area extent: Depth:
Remarks:
2.
Vegetative Growth O Location shown on site map Q N/A
l~l Vegetation does not impede flow
Area extent: Tvpe:
Remarks:
3.
Erosion ~ Location shown on site map O Erosion not evident
Area extent: Depth:
Remarks:
4.
Discharge Structure Q Functioning ~ N/A
Remarks:
VIII. VERTICAL BARRIER WALLS ~ Applicable M N/A
1.
Settlement O Location shown on site map Q Settlement not evident
Area extent: Depth:
Remarks:
2.
Performance Monitoring Tvpe of monitoring:
l~l Performance not monitored
Frcciuencv: [~~l Evidence of breaching
Head differential:
Remarks:
rx.
GROUNDWATER/SURFACE WATER REMEDIES ^ Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps and Pipelines ~ Applicable N/A
1.
Pumps, Wellhead Plumbing and Electrical
~ Good condition ~ All required wells properly operating ~ Needs maintenance Q N/A
Remarks:
2.
Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition ~ Needs maintenance
Remarks:
3.
Spare Parts and Equipment
l~l Readily available O Good condition O Requires upgrade O Needs to be provided
Remarks:
F-8
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B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable [3 N/A
1.
Collection Structures, Pumps and Electrical
l~l Good condition Q Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
l~l Good condition Q Needs maintenance
Remarks:
3.
Spare Parts and Equipment
l~l Readily available Q Good condition O Requires upgrade Q Needs to be provided
Remarks:
C.
Treatment System ~ Applicable £3 N/A
1.
Treatment Train (check components that apply)
l~l Metals removal Q Oil/water separation Q Bioremediation
O Air stripping ~ Carbon adsorbers
n Filters:
["I Additive (e.g.. chelation agent, flocculent):
n Others:
l~l Good condition Q Needs maintenance
l~l Sampling ports properly marked and functional
l~l Sampling/maintenance log displayed and up to date
l~l Equipment properly identified
n Ouantitv of groundwater treated annuallv:
n Ouantitv of surface water treated annuallv:
Remarks:
2.
Electrical Enclosures and Panels (properly rated and functional)
l~l N/A ~ Good condition ~ Needs maintenance
Remarks:
3.
Tanks, Vaults, Storage Vessels
l~l N/A O Good condition O Proper secondary containment O Needs maintenance
Remarks:
4.
Discharge Structure and Appurtenances
l~l N/A O Good condition O Needs maintenance
Remarks:
5.
Treatment Building(s)
l~l N/A Q Good condition (esp. roof and doorways) O Needs repair
l~l Chemicals and equipment properly stored
Remarks:
F-9
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6
Monitoring Wells (pump and treatment remedy)
l~l Properly secured/locked Q Functioning ~ Routinely sampled Q Good condition
l~l All required wells located Q Needs maintenance O N/A
Remarks:
D. Monitoring Data
1
Monitoring Data
IXI Is routinely submitted on time Is of acceptable quality
2
Monitoring Data Suggests:
l~l Groundwater plume is effectively contained Contaminant concentrations arc declining*
*The Data Review section of the FYR Report has
more information on current COC concentrations in
groundwater.
E.
Monitored Natural Attenuation
1
Monitoring Wells (natural attenuation remedy)
E3 Properly secured/locked [3 Functioning [53 Routinely sampled Q Good condition
l~l All required wells located Q Needs maintenance O N/A
Remarks: Not all wells at the Elm Street Area could be located (in particular. MW-31C). Standing water
was observed in the roadbox of well 09 at the Mill Street Area.
X. OTHER REMEDIES
If there arc remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of anv facilitv associated with the rcmcdv. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS
A.
Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
The OU1 rcmcdv is functioning as designed. Contaminated soils from the Elm Street Area and Mill Street
Area were excavated and taken off site for disposal. The cleanup levels specified in decision documents
were met. The Mill Street Area was cleaned up to allow for residential uses. The Elm Street Area was
cleaned up to allow for recreational uses. It has a final engineered cover that rcauires long-term O&M
activities. O&M activities and long-term groundwater and surface water monitoring arc ongoing to track
progress of MNA. The presence of DN APL in Mill Street Area bedrock groundwater inav rcciuire further
assessment. The OU2 sediment rcmcdv is functioning as designed. Fish advisorv signs are in place along
the rivcrbank.
B.
Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protcctivcness of the remedy.
The Town is responsible for site O&M activities but has not been submitting annual reports to EPA
documenting inspections and O&M activities. The Town has been in communication with EPA regarding
proposed redevelopment of the Site.
C.
Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future. None at this time.
D.
Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None at this time.
F-10
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APPENDIX G - SITE PHOTOGRAPHS
Elm Street Area engineered soil cap area, with newly installed amphitheater in background
Sparse vegetation in some areas of the engineered soil cover at die Elm Street Area
G-l
-------
View from the Keyes Drive parking area, along the reconstructed riverbank; amphitheater in background
Slumped area near top of riprap
G-2
-------
Minor area of erosion at top of riverbank
Parking area along Keyes Drive
G-3
-------
View of riverbank below the Keyes Drive parking lot; note sheet piling, gabion basket and drainage pipes
G-4
-------
Fish advisory sign near the walking bridge from Keyes Memorial Park to the Boys and Girls Club property
Close up of fish advisory sign
G-5
-------
Boat launch area near the Keyes Drive parking lot
Keyes Field (OU2 area)
G-6
-------
MW-18 monitoring well in pavement, with mixed-use building in background
Monitoring wells at the Elm Street Area
-------
Monitoring wells north of the railroad tracks at the Mill Street Area
G-8
-------
Monitoring well MW-21CR at the Mill Street Area, where DNAPL was observed in 2019
Well MW09 with standing water adjacent to the Mill Street Area
G-9
-------
Gravel area at the former Draper Fuel property
Drainage culvert at the Mill Street Area
G-10
-------
APPENDIX H - ARARS REVIEW
Table H-1: Comparison of Oil 1 Groundwater Cleanup Levels to Current Standards
coc
Groundwater Cleanup
Level (fi
-------
APPENDIX I - VISL CALCULATOR OUTPUT
Evaluated using October 2021 data from well MW-18B.
Resident Vapor Intrusion Risk
Chemical
CAS
Number
Dichloroethylene, cis-1,2- 156-59-2
Trichlorabenzene, 1,2,3- 87-61-6
Trichloroethylene 79-01-6
*Sum
Site
Groundwater
Concentration
V
(t-ig/L)
0.66
2.6
30
Site
Indoor Air
Concentration
1.10E-01
1.21E+01
VI
Carcinogenic V!
Risk Carcinogenic
CD! Risk
(ng/m3)
3.92E-02
6.16E+00
CR
2.53E-05
2.53E-05
VI
Hazard
CDI
(mg/m3)
1.06E-04
1.16E-02
VI
Hazard
HQ
2.64E-03
5.79E+00
5.79E+00
Chronic
IUR IUR RfC RfC
(ug/m3)1 Ref (mg/m3) Ref
4.00E-02 SCREEN
4.10E-06 I 2.00E-03 IRIS
Temperature
<°cn
for
Groundwater
Vapor
Concentration
25
25
25
Mutagen?
No
No
Mut
Output generated 03JAN2023:11:34:48
1-1
-------
Commercial Vapor Intrusion Risk
Chemical
Dichloroethylene, cis-1,2-
Trtchlorobenzene, 1,2,3-
Trichloroethylene
SB# Site VI
Groundwater Indoor Air Carcinogenic
Concentration Concentration Risk
CAS C„\ C,\ CDI
dumber (pgrt-) (no/m1) (h0""!!
15(5-59-2 0.66 1.10E-01 8.98'
87-61-8 2.8
79-01-6 30 1.21E+G1 9.85
VI
Caidnogenic
R;sk
CR
VI
Hazard VI
CDI Hazard
(mglm1) HQ
2 51E-05 6.2BE-04
2.76E-03 1.:
Chronic
1UR 1UR RfC RfC
(ug/mV Ref Img'm-) Ref
41tOE-02 SCREEN
Temperature
PC)\
for
Groundwater
V*por
Concentration Mutagen?
25
25
1-2
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