SECOND FIVE-YEAR REVIEW REPORT FOR
INDUSTRI-PLEX SUPERFUND SITE
MIDDLESEX COUNTY, MASSACHUSETTS
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Prepared by
U.S. Environmental Protection Agency
Region 1
Boston, Massachusetts
BRYAN
OLSON
Digitally signed by
BRYAN OLSON
Date: 2024.05.23
09:25:42 -04'00'
Bryan Olson, Division Director Date
Superfund and Emergency Management Division
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Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS 2
I. INTRODUCTION 4
Site Background 4
FIVE-YEAR REVIEW SUMMARY FORM 5
II. RESPONSE ACTION SUMMARY 9
Basis for Taking Action 9
Response Actions 10
Status of Implementation 15
Institutional Controls 18
Systems Operations/Operation & Maintenance (O&M) 23
III. PROGRESS SINCE THE PREVIOUS REVIEW 25
IV. FIVE-YEAR REVIEW PROCESS 28
Community Notification. Community Involvement and Site Interviews 28
Data Review 28
Site Inspection 31
V. TECHNICAL ASSESSMENT 32
QUESTION A: Is the remedy functioning as intended by the decision documents'.' 32
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid'.' 34
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy'.' 42
VI. ISSUES/RECOMMENDATIONS 43
Other Findings 44
VII. PROTECTIVENESS STATEMENT 45
VIII. NEXT REVIEW 46
APPENDIX A - REFERENCE LIST A-l
APPENDIX B - SITE CHRONOLOGY B-l
APPENDIX C - PUBLIC NOTICE 1 C-l
APPENDIX D - SUPPORTING FIGURES D-l
APPENDIX E - SUPPORTING TABLES E-l
APPENDIX F - SITE INSPECTION CHECKLIST F-l
APPENDIX G- SITE INSPECTION PHOTOS G-l
APPENDIX H - INTERVIEWS H-l
APPENDIX I - CLEANUP LEVEL/PERFORMANCE STANDARD REVIEW I-1
APPENDIX J - LEAD SCREENING LEVEL CHECKLIST J-1
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LIST OF ABBREVIATIONS & ACRONYMS
ALM Adult Lead Methodology
ARAR Applicable or Relevant and Appropriate Requirement
ATSDR Agency for Toxic Substances and Disease Registry
CASRN Chemical Abstracts Service Registry Number
CBCA Cranberry Bog Conservation Area
CCC Criterion Continuous Concentration
CERCLA Comprehensive Environmental Response. Compensation, and Liability Act
CFR Code of Federal Regulations
COC Contaminant of Concern
CO PC Contaminant of Potential Concern
CSF Cancer Slope Factor
EPA United States Environmental Protection Agency
ESD Explanation of Significant Differences
FS Feasibility Study
FYR Five-Year Review
GERE Grants of Environmental Restrictions and Easements
GSIP Groundwater and Surface Water Investigation Plan
HBHA Halls Brook Holding Area
HFPO-DA Hexafluoropropylene Oxide Dimer Acid (Gen-X)
HI Hazard Index
HQ Hazard Quotient
HQ-115/TFSI Lithium bis|(trifluoromethyl)sulfonyl|azanide (HQ-115)
IC Institutional Control
IEUBK Integrated Exposure Uptake Biokinetic Model for Lead in Children
IRIS Integrated Risk Information System
LOAEL Lowest Observed Adverse Effects Level
MassDEP Massachusetts Department of Environmental Protection
MCL Maximum Contaminant Level
MMCL Massachusetts Maximum Contaminant Level
MRL Minimal Risk Level
MSGWRP Multiple Source Groundwater Response Plan
(.ig/dL Micrograms per Deciliter
(.ig/L Micrograms per Liter
mg/kg Milligrams per kilogram
mg/kg-day Milligrams per kilogram per Day
mg/L Milligrams per Liter
NAAQS National Ambient Air Quality Standard
NAUL Notice of Activity and Use Limitations
NCP National Oil and Hazardous Substances Pollution Contingency Plan
ng/L Nanograms per Liter
NPL National Priorities List
NRWQC National Recommended Water Quality Criteria
O&M Operation and Maintenance
OHHRRAF OLEM's Human Health Regional Risk Assessment Forum
OLEM Office of Land and Emergency Management
ORD Office of Research and Development
PFAS Per- and Polyfluoroalkyl Substances
PFBA Perfluorobutanoic Acid
PFBS Perfluorobutane Sulfonic Acid
PFDA Pe rfl uorodecanoic Acid
PFDoDA Periluorododecanoic acid
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PFHpA
Perfluoroheptanoic Acid
PFHxA
Perfluorohexanoic Acid
PFHxS
Perfluorohexane Sulfonate
PFNA
Perfluorononanoic Acid
PFOA
Perfluorooctanoic Acid
PFOS
Perfluorooctane Sulfonate
PFPrA
Perfluoropropanoic acid
PFTctA
Perfluorotetradecanoic acid
PFUDA
Pc rfl uoroundecanoic acid
PPb
Parts per Billion
PPm
Parts per Million
ppt
Parts per Trillion
PRP
Potentially Responsible Party
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
RfC
Reference Concentration
RfD
Reference Dose
ROD
Record of Decision
RPM
Remedial Project Manager
RSL
Regional Screening Level
TBC
To Be Considered
TCE
Trichloroethene
TFSI
1.1.1 -Trifluoro-N-(trifluorometlianesulfonyl)metlianesulfoiiamide
TOU
Thermal Oxidization Unit
UU/UE
Unlimited Use and Unrestricted Exposure
VCU
Vapor Combuster Unit
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, 42 United States Code
(USC) § 9621, is 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 considers EPA policy.
The Industri-Plex Superfund site (the Site) was listed on the CERCLA National Priority List (NPL) in 19831. This
is the second FYR for the Site. The triggering action for this statutory review is the completion date of the
previous FYR on May 23, 2019. 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 includes two operable units (OlJs). This FYR Report addresses both site OlJs. OU-1 addresses source
area soil and sludges, groundwater (interim action until the OU-2 remedy was issued), and air emissions from an
animal hide pile. OU-2 addresses the final groundwater remedy, soil (excludes OU1 area), sediment (excludes
OU1 area) and surface water contamination. OU-2 also includes downstream surface water and sediment from
OU-3 (the Aberjona River Study Area) of the neighboring Wells G&H Superfund site (see Figure D-l for location
of Wells G&H Superfund site). The Wells G&H Superfund site was listed on the NPL in 19832. The Site's
contaminants impact the Wells G&H OU-3 Aberjona River Study Area within the connected water bodies. In a
2006 Record of Decision (ROD) for OU-2. EPA determined that the Wells G&H OU-3 would be evaluated as
part of the Industri-Plex FYR rather than the Wells G&H FYR.
EPA remedial project manager (RPM) Joseph LeMay, P.E.. led the FYR. Participants from EPA included risk
assessor Paulina Do and attorney David Peterson and Lindsey Short. Jennifer McWeeney from Massachusetts
Department of Environmental Protection (MassDEP) and kirby Webster and Jill Billus from EPA FY R contractor
Skeo also participated in the review, as well as EPA's oversight contractor. AECOM. The Settling Defendants
under separate consent decrees for OU-1 (1989) and OU-23 (2008), were notified of the initiation of the FYR. The
review began on September 12, 2023.
Appendix A includes a list of documents reviewed for this FYR. Appendix B provides a chronology of site
events.
Site Background
The initial approximately 245-acre Site is in the city of Woburn in Middlesex County. Massachusetts, about 10
miles northwest of the city of Boston (Figures 1 and 2). Various chemical and glue manufacturing facilities
operated on-site from 1853 to 1969 (primarily in OU-1). From 1853 to 1931, manufacturers produced chemicals
such as sulfuric acid, arsenic, insecticides and organic chemicals for local textile, leather and paper industries.
From 1934 to 1968, plant operators manufactured glue from animal hides.
Waste products from these operations were randomly disposed of on-site. Prior to 1934, some waste was used to
fill lowlands, wetlands and shallow ponds to provide more usable land. Other waste was used as a construction
material to build dikes and levees to contain liquid wastes. After 1934, waste disposal was generally to areas east
1 https://semspub.epa.gOv/work/01/297159.pdf
2 https://semspub.epa.gOv/work/01/297159.pdf
3 The two Settling Defendants to the OU-2 consent decree. Monsanto and Bayer Crop Science (successor to Stauffcr
Chemical) arc also two of the twenty-six Settling Defendants to the OU-1 consent decree.
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and southeast of the main plant. These wastes were deposited directly on top of the existing deposits and reached
heights in excess of 40 feet above grade.
In 1968, a developer purchased most of the site property from Stauffer Chemical Company with the intent to
develop an industrial park called the Industri-Plex 128. Excavations during development uncovered chemical and
glue manufacturing wastes, including decaying animal hides. Some of these wastes were excavated to
accommodate development and either trucked off-site, buried on the southern utility right of way or stockpiled
into two waste piles at the northern portion of the site (currently known as the West Hide Pile and the East Hide
Pile). Some of these wastes also remained in place or were moved to accommodate development and consolidated
to form two other waste piles (currently known as East-Central Hide Pile and South Hide Pile). The excavation
and disturbance of the animal hide wastes released a very strong and pervasive odor (e.g., hydrogen sulfide) into
surrounding areas.
Subsequent investigations found the OU-1 area was primarily contaminated with metals (e.g., arsenic, lead and
chromium) and buried animal hide wastes. Groundwater was also contaminated with heavy metals (e.g., arsenic)
and organic chemicals (e.g., benzene, toluene, naphthalene, trichloroethene. 1.2-dichloroethane) and ammonia
(primarily from the decay of the animal hide wastes). Contaminated groundwater originating at OU-1 discharged
to OU-2 surface water bodies downstream (the Halls Brook Holding Area [HBHA] Pond, the HBHA Wetlands
and the Aberjona River), impacting sediment, soil, and surface water.
During the 1990s and early 2000s, parts of the Site (primarily OU-1) were redeveloped. Current site uses include
retail, residential, and commercial and light industrial land uses, as well as an intermodal transportation facility,
the Anderson Regional Transportation Center. About 110 acres of OU-1 have protective caps (i.e., engineered and
equivalent caps/covers) constructed as part of the Site's cleanup. Solar panels have been installed on the East Hide
Pile and East Central Hide Pile.
Groundw ater contamination occurs primarily in the overburden aquifer consisting of unconsolidated glacial
deposits. The overburden aquifer is hydraulically connected to the bedrock aquifer but the bedrock does not yield
significant amounts of water. Recharge of this bedrock aquifer by the overburden aquifer is slow due to the low
permeability of the bedrock. Overburden groundwater primarily discharges to downgradient surface waters and
flows to the southeast toward the HBHA Pond. MassDEP classified the aquifer in the northern part of the Site
(e.g., north of Interstate 95) as a Non-Potential Drinking Water Source Area and of low use and value. It is not
used as a source of drinking water. Groundwater in the southern part of the Site, near the inactive municipal wells
G & H (part of the neighboring Wells G&H site), has been classified as a potential source of drinking water.
The Aberjona River, which begins in Reading. Massachusetts, flows through the Site and eventually reaches the
Mystic Lakes in Winchester. OU-2 extends dow nstream along the River from OU-1 to the Cranberry Bog
Conservation Area (CBCA) within Wells G&H OU3. South of OU-1. land use along the river consists of mixed
commercial/industrial and residential properties and open space/conservation areas. Some substantial wetland
areas associated with the Aberjona River floodplain are located on either side of the River.
FIVE-YEAR REVIEW SUMMARY FORM
[
SITE IDEM II IC A I ION
Site Name: Industri-Plex
EPA ID: MAD076580950
Region: 1
State: MA
City/County: Woburn/Middlesex
NPL Status: Final
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Multiple OUs?
Yes
Has the site achieved construction completion?
Yes
RKYIEW SI A I I S
Lead agency: EPA
Author name: Joseph LeMay, P.E.
Author affiliation: EPA
Review period: 9/12/2023 - 5/16/2024
Date of site inspection: 11/17/2023
Type of rev iew: Statutory
Review number: 2
Triggering action date: 5/23/2019
Due date (fiveyears after triggering action date): 5/23/2024
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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. Map image is the
intellectual property of Esh and is used herein under license. Copyright © 2020
Esh and its licensors. All rights reserved Sources: Esri, Town of Reading. Esri,
TomTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS,
EPA, NPS, US Census Bureau, USDA, USFWS, Maxar, the 2006 ROD, the
2014 ESD. the 2018 ESD and MassDEP.
Industri-Plex Superfund Site
City ofWoburn, Middlesex County, Massachusetts
Last Modified: 5/9/2024
Figure 1: Site Vicinity Ma]
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Figure 2: OU-I Site Detail Map
Thermal Oxidation
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II. RESPONSE ACTION SUMMARY
Basis for Taking Action
OU-1
In May 1982, Stauffer Chemical Company, a former site owner and responsible party, signed a Consent Order
with EPA and the Massachusetts Department of Environmental Quality Engineering (DEQE. now MassDEP) to
conduct the Site's remedial investigation (Rl) and feasibility study (FS). Stauffer Chemical Company completed
the RI/FS in 1985. It included an Endangerment Assessment that assessed risks associated with potential exposure
to site contaminants. The primary pathway of concern was direct exposure (ingestion, skin contact and inhalation)
to soils by an industrial worker or recreational visitor. The second potential threat from soils was the off-site
migration of contaminants via surface water resulting from either direct contact of the waste deposits with surface
water or runoff from a storm event. The primary contaminants of concern (COCs) in soils and sludges were
arsenic, lead and chromium. The Endangerment Assessment found that the air emissions from the hide piles
would not adversely impact the public health; however, the emissions contained hydrogen sulfide gas that created
a substantial nuisance odor problem. Tw o groundwater plumes, contaminated with benzene and toluene, were also
cause for concern because of their potential to impact the city of Woburn's water supply wells (Wells G&H),
which were not in use at the time.
Oil-2
The 2005 OU-2 Rl (which included OU-3 at the Wells G&H site) evaluated soil, sediment, groundwater and
surface water contamination and risks along the HBHA and Aberjona River from the Site to the Mystic Lakes in
the town of Arlington. Since the Aberjona River flows through an urban area that includes residential,
commercial, recreational, and industrial properties, the study area was divided into six reaches or areas so that
appropriate human health and ecological risk evaluations could be conducted based on the unique exposure
hazards at each area. Figure D-l in Appendix D shows these reaches.
Baseline risks posed to the public and environment identified in Reach 0 (part of the Northern Study Area that
includes the HBHA Pond and Former Mishawum Lake Bed Area). Reach 1 (includes the Wells G&H Wetland)
and upper Reach 2 (includes the CBCA) are summarized below :
• Arsenic and benzene (as well as ammonia) plumes beneath the OU-1 boundary (groundw ater) may cause
future health risks to people who might come in contact with the water (future industrial/commercial/
construction worker) within Reach 0.
• Arsenic and benzene (as well as ammonia) plumes from OU-1 contribute to significant environmental
risks in the HBHA Pond sediment and deep surface water within Reach 0.
• High concentrations of arsenic in both surface and deep soils in the Former Mishaw um Lake Bed area
may cause future health risk to a daycare child and construction worker who could come in contact with
the soils within Reach 0.
• High concentrations of arsenic in shoreline sediments in three distinct areas along the Wells G&H
Wetland and CBCA present a current and/or future health risk to people recreating along the shoreline
(east side of the 3 8-acre Wells G&H site wetland within Reach 1 near former production well H. west
side of the 3 8-acre Wells G&H site wetland within Reach 1 near the railroad tracks and Olympia Source
Area Property, and west-central area of the CBCA within upper Reach 2).
• High concentrations of arsenic in deeper interior wetland sediments presents a future risk to people who
might come in contact with the sediments (future dredger/construction worker) within Reaches 0 and 1.
No unacceptable CERCLA human health or ecological risks were identified in the further downgradient reaches.
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Response Actions
Early Actions
Since the late 1960s, the Commonwealth of Massachusetts (Commonwealth) has been involved in multiple
enforcement actions against a developer of the site, starting in 1969 when the developer began work without
proper permits. DEQE also issued multiple notices of violation to the developer pertaining to the odors released
during development activities. Despite these actions, the developer continued its work on-site. Federal
involvement began in 1979 when the U.S. Army Corps of Engineers and EPA filed suit against the developer
pertaining to filling of wetlands and a release of hazardous substances.
In November 1980, DEQE installed a temporary latex cover over a large, exposed arsenic and lead deposit on-site
to minimize dust migration.
In 1981, EPA installed a fence around the OU-1 property to prevent unauthorized access. A subsequent action in
1986 repaired the fence. Warning signs were also posted.
EPA listed the Site on the Superfund Interim List of 115 Top Priority Hazardous Waste Sites in 1981. EPA added
the Site to the NPL in 1983.
Remedy Selection
OU-1
EPA selected a remedy for OU-1 in the Site's 1986 ROD. EPA updated the remedy with Explanations of
Significant Differences (ESDs) in 2018 (ESD 1) and 2023 (ESD 2) (collectively referred to as the "OU 1
Remedy"). The 1986 OU-1 ROD identified the follow ing remedial objectives4 , which the ESDs did not change:
• Protect the public health and surface water from direct contact exposure to soils/sludges contaminated
with elevated levels of arsenic, lead, and chromium.
• Protect the public health, welfare and environment from the contaminated soils, odors, and leachate in or
emanating from the East Hide Pile.
• Protect the public health and environment from groundwater contaminated with benzene and toluene.
The major components of the OU-1 remedy, by environment medium, are listed below.
Soils/Sludges
• Site grading.
• Installation of a permeable soil cover cap over certain areas. "
• Implementation of institutional controls.
• Water quality monitoring.
• Post-closure maintenance consistent with Resource Conservation and Recovery Act (RCRA) regulations.
Groundwater
• An interim remedy of pumping "hot spot" areas and groundwater treatment to control odors, air stripping
to remove VOCs (e.g., benzene) and discharge to the upgradient portion of the aquifer. The permanent
groundwater remedy selected in the 2006 ROD for OU-2 later superseded this interim groundwater
remedy (2006 ROD. page 22).
• G rou nd w ate r m on i to ri ng.
4 "Remedial Objectives" arc also referred to a "Remedial Action Objectives" (RAOs) in other CERCL A documents.
5 The 1986 ROD specified the use of 30 inches of clean fill. EPA later approved an alternative cover design that incorporated
the use of a geotextile fabric to reduce the amount of imported fill and minimize impacts on local grades. In addition, the
ROD allowed for the use of alternative covers such as concrete foundations and parking lots in certain areas.
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• Development and implementation of a Multiple Source Groundwater Response Plan (MSGRP) to inform
a final groundwater remedy.
Air
• Stabilization of the side slopes of the East and West Hide Piles.
• Installation of a gas collection layer.
• Installation of a synthetic membrane cap to establish impermeability.
• Treatment of gaseous emissions with either activated carbon or thermal oxidation with the final treatment
selection to be decided after the impermeable cover has been installed.
• Implementation of an air quality monitoring program.
• Routine maintenance.
The selected remedy for OU-1 included institutional controls for any areas containing wastes above the action
levels specified in the ROD. As discussed in the Cleanup Levels section of this FYR Report, the Site's soil
cleanup levels were developed assuming industrial and commercial uses and not considered protective for on-site
residential use.
In 2018, EPA issued ESD 1 to allow residential use on two separate properties within the boundaries of OU-1
(120 Commerce Way and 200 Presidential Way, see Figure 2). In the ESD. EPA updated the OU-1 remedy at
these properties to permit residential development after property-specific baseline human health risk assessments
demonstrated potential soil exposure scenarios, including residential exposures, did not exceed EPA's risk
management criteria. EPA permitted residential development at 200 Presidential Way with no conditions and at
120 Commerce Way with certain conditions (such as preventing exposures to deeper subsurface soil and
groundwater and installing vapor mitigation systems) was documented in IC-206 Notice of Activity and Use
Limitations (NAUL) as an institutional control.
In 2023, EPA issued ESD 2 to allow residential use for a limited 3.42 acres of Class B land7 within the Site
located at Zero New Boston Street after property-specific baseline human health risk assessments demonstrated
potential soil exposure scenarios, including residential use as well as daycare and school use (w ith exposure
scenarios similar to or less than residential use), was reasonable and allowable. Two recorded institutional
controls that covered the development property (IC-328 NAUL and IC-289 Grants of Environmental Restrictions
and Easement (GERE)) will be amended to allow residential development (including residential, daycare and
school uses) on this 3.42 acres of Class B Land.
OU-2
EPA selected a remedy for OU-2 in the Site's 2006 ROD and updated the remedy in a 2014 ESD (collectively
referred to as the "OU 2 Remedy"). The ROD included the follow ing remedial action objectives (RAOs) for the
OU-2 remedial action, which the ESD did not change:
• Within the Northern Study Area from OU-1 to Interstate 95, prevent or mitigate the potential future
exposure of workers via ingestion, dermal contact and/or inhalation to concentrations of arsenic, benzene,
ammonia, trichloroethene (TCE), 1,2-dichloroethane and naphthalene in groundw ater that may present a
human health cancer risk in excess of 10~4 and target organ hazard index (HI) greater than 1. so that the
excess cancer risk attributable to this medium is within the range of 10~4 to 10 ' and the non-cancer HI
does not exceed 1.
• Within the Wells G&H Wetland and CBCA. reduce the current and future potential exposure of
recreational adults and children via ingestion and dermal contact to concentrations of arsenic and
6 Institutional Control Lot IC-20 (Woburn Tax Map 10-1-3)
7 Class B Land: may contain contaminated soils and contaminated groundwater. No cover/cap required.
8 Institutional Control Lot IC-32 ((Woburn Tax Map 09-02-02).
9 Institutional Control Lot IC-28 ((Woburn Tax Map 05-01-01).
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benzo(a)pyrene in near-shore sediment that may present a human health cancer risk in excess of 10~4 and
target organ HI greater than 1, so that the excess cancer risk attributable to this medium is within the
range of 10~4 to 10~6 and the non-cancer HI does not exceed 1.
• Within the HBHA Wetland and the Wells G&H Wetland, prevent or mitigate the potential future
exposure of workers via ingestion and dermal contact to concentrations of arsenic in deeper (interior)
sediment that may present a human health target cancer risk in excess of 10~4 and target organ HI greater
than 1, so that the excess cancer risk attributable to this medium is within the range of 10"4 to 10"6 and the
non-cancer HI does not exceed 1.
• Within the Former Mishawum Lake Bed area, prevent or mitigate the potential future exposure of
workers via ingestion and dermal contact to concentrations of arsenic in subsurface soil that may present a
human health cancer risk in excess of 10"4 and target organ HI greater than 1. so that the excess cancer
risk attributable to this medium is within the range of 10"4 to 10"6 and the non-cancer HI does not exceed
1.
• Within the Former Mishawum Lake bed area, prevent the potential future exposure of children via
ingestion and dermal contact to concentrations of arsenic in surface and subsurface soil that may present a
human health cancer risk in excess of 10"4 and target organ HI greater than 1 such that the cancer risk
attributable to this medium is within the range of 10~4 to 10-6 and the non-cancer HI does not exceed 1.
• Prevent or minimize the exposure of benthic invertebrates and aquatic life to levels of arsenic, benzene
and ammonia in surface water, which are present because of groundw ater discharge, in excess of
applicable or relevant and appropriate requirements ( AR ARs) or benchmarks for the protection of aquatic
life.
• Reduce the exposure of benthic invertebrates to levels of arsenic indicative of impairment in HBHA Pond
sediment.
• Provide an alternate habitat to replace the lost wetland functions and values associated with portions of
the HBHA Pond used as a component of the remedy.
• Minimize, to the extent practicable, the migration of soluble and particulate arsenic during storm events to
downstream dispositional areas.
The major components of the OU-2 remedy documented in the 2006 ROD included:
• Dredging and off-site disposal of contaminated sediments in the southern portion of the HBHA Pond,
dredging and off-site disposal of contaminated near-shore sediments at the Wells G&H Wetland and
CBC A. and restoration of all disturbed areas. This component will address sediments posing unacceptable
human health risks for near-shore sediments and unacceptable ecological risks for the southern portion of
the HBHA Pond.
• Use of the northern portion of the HBHA Pond as a sediment retention area (primary and secondary
treatment cells) that will intercept contaminated groundwater plumes (including arsenic, benzene,
ammonia. 1.2-dichloroethane. TCE and naphthalene) from OU-1, treat/sequester COCs including arsenic,
benzene and ammonia, and minimize dow nstream migration of contaminants including arsenic, benzene
and ammonia.
o The primary treatment cell will intercept the contaminated groundwater plumes discharging in the
HBHA Pond.
o The effluent from the northern portion of the HBHA Pond (secondary treatment cell outlet) will
serve as the surface water compliance boundary and achieve National Recommended Water
Quality Criteria (NRWQC).
o Sediments that accumulate in the northern portion of the HBHA Pond will be periodically
dredged and sent off-site for disposal,
o Portions of storm water from Halls Brook, which may interfere with the natural treatment
processes occurring in the northern portion of the HBHA Pond, will be diverted to the southern
portion of the HBHA Pond.
• If necessary, use of in-situ enhanced bioremediation for contaminated groundwater plumes (e.g., benzene)
at the West Hide Pile.
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• Construction of an impermeable cap to line stream channels (e.g., New Boston Street Drainway) and to
prevent the discharge of contaminated groundw ater plumes, contamination of stream sediments,
downstream migration of COCs and potential impacts on other components of the selected remedy. 10
• Construction of a permeable cap to prevent contaminated soil erosion (e.g., Area A6 | show n in Figure D-
2, Appendix D|). downstream migration of COCs and potential impacts on other components of the
selected remedy.
• Establishing institutional controls to restrict contact with soils, groundwater, or deeper interior wetland
sediments with concentrations above cleanup standards and to protect the remedy.
• Construction of compensatory wetlands for any loss of wetland functions and values associated with the
selected remedy (e.g., the northern portion of the HBHA Pond, the Halls Brook storm water bypass,
capped stream channels) nearby in the watershed.
• Long-term monitoring of groundwater, surface water and sediments, and periodic FYRs of the remedy.
In 2014, EPA issued the 2014 OU-2 ESD that created a new ecological-based cleanup standard for benzene in
sediments of the Lower South Pond adjacent to the West Hide Pile. The ESD required sediments above the new
benzene cleanup standard (1.29 milligrams per kilogram [mg/kg]) to be dredged, dewatered. and disposed of off-
site. and all disturbed areas restored. This action abated the need to implement the in-situ enhanced
bioremediation of contaminated groundw ater in the West Hide Pile. The ESD also updated federal and state
ARARs for the remedial action.
Cleanup Levels
Table 1 lists the cleanup levels for soil and sediment at OU-1. The 300 mg/kg arsenic cleanup level also protects
vegetation, which was needed to reduce contaminated runoff to surface water that was impacting vegetation. ESD
1 clarified that the cleanup levels were developed assuming industrial and commercial use and not considered
protective for on-site residential use.
The 1986 OU-1 ROD established cleanup levels for Site groundwater based on drinking water standards. In 1997,
based on a Groundwater Use and Value Determination performed by MassDEP. the Industri-Plex aquifer was
determined to be a Non-Potential Drinking Water Source Area and of low use and value. Based on this
determination, the 2006 OU-2 ROD changed the groundwater standards to performance standards protective for
non-potable uses. Table 2 lists the groundwater performance standards selected in the 2006 OU-2 ROD. which
superseded the interim groundw ater cleanup levels selected in the 1986 OU-1 ROD.
The OU-2 Remedy set soil and sediment cleanup standards for various areas based on the uses of those areas.
Tables 3 through 5 list these soil and sediment cleanup standards.
The OU-2 Remedy also established ecological-based surface water cleanup levels protective of aquatic life. The
surface water cleanup standards must be met at the point of compliance for the HBHA Pond treatment system,
which is defined as the discharge point of the final/furthest downstream low-head cofferdam (secondary treatment
cell outlet) of the HBHA Pond.
Table 1: Soil Cleanup Levels (OU-1)
cot
Cleanup Level
(m«/k«)
Arsenic
300
Lead
600
Chromium
1,000
Source: The Site's 1986 ROD. page 81.
10 EPA's June 16, 2015 conditional approval letter of the 100% Remedial Design-Part 1 Report documented that the
impermeable cap was not required considering the data gathered during pre-design investigations and presented in the design,
and further described in the September 30, 2015 Final 100% Remedial Design-Part 1.
13
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Table 2: Groundwater Performance Standards" (OlJ-2)
coc
Cleanup Lcvelh
(m«/l)
Basis'
Ammonia
4,000
HQ = 1
Arsenic
150
4 x 10"5 risk
Benzene
4
1 x 10"5 risk
1,2-Dichloroethane
2
1 x 10"5 risk
Naphthalene
5
HQ = 1
TCE
1
3 x 10"5 risk
Notes:
a) Groundwater performance standards arc applicable to the portion of the aquifer from
OU-1 south to Interstate 95 (the Site's 2006 ROD. page 99). Groundwater south of
Interstate 95, within OU-2 of the Wells G&H Site to be addressed by future Wells
G&H CERCLA decision documents.
b) From the Site's 2006 ROD. Table L-l.
c) Groundwater cleanup levels were established based on future incidental ingestion of.
dermal contact with, and inhalation of volatile organic compounds (VOCs) released
during industrial water usage (i.e., a process water or car wash scenario) and worker
excavation activities (the Site's 2006 ROD. page 99).
HQ = hazard quotient
(ig/L = micrograms per liter
Table 3: Soil Cleanup Standards (Former Mishawum Lade Bed Area) for the Protection of Daycare Child
COC
Cleanup Level"-b
(mg/kg)
Basis
Former Mishawum Lake Bed Area
Arsenic
50
HQ = 1
Notes:
a) From the Site's 2006 ROD. Table L-2.
b) Cleanup level for surface and subsurface soil (0 feet to 15 feet below ground surface).
The selected level is also protective for exposure by an excavation worker.
HQ = hazard quotient
Table 4: Sediment Cleanup Standards for the Protection of Recreational and Dredging Worker Direct
Contact Exposures (OU-2
COC
Cleanup Level"
(ms/kg)
Basis
Near-Shore CBCA (e.g., CB-03)
Arsenic
230
HQ = 1
Near-Shore Wells G&H Wetland
(e.g., WH, NT-3,13/TT-27)
Arsenic
300
HQ = 1
Benzo(a)pyrene
4.9
Background
Deeper Interior HBHA Wetland and Wells G&H Wetland
(e.g., SC02, SC05, SC06 and SC08)
Arsenic
300
1 x 10"5 risk
Notes:
a) From 2006 ROD. Table L-4 and page 102.
HQ = hazard quotient
14
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Table 5: Sediment Cleanup Standards for the Protection of Ecological Receptors (OU-2)
cot
Cleanup Level
(mg/kg)
Basis
HBHA Pond
Arsenic
273a
LOAEL
Lower South Pond
Benzene
1.29b
ecological protection0
Notes:
a) From the Site's 2006 ROD. page 102.
b) From the Site's 2014 ESD, page 10.
c) Calculated using a conservative water quality guideline for the protection of sensitive
aquatic organisms and an equilibrium partitioning method (see Attachment 1 of the
2014 ESD).
LOAEL = lowest observed adverse effects level for bcnthic invertebrates
Table 6: Surface Water C
eanup Standards (OU-2)
COC
Cleanup Level"
(Mg/L)
Basis
Arsenic
150
NRWQC-CCC (chronic)
Benzene
46
Tier 11 benchmark
Ammonia
temperature and pH dependent1
NRWQC-CCC (chronic)
Notes:
a) From 2006 ROD. Table G-28 and page 103.
b) The surface water cleanup standard for ammonia is set at the NRWQC-CCC value for
Fish Early Life Stages Present. It is a 30-day average concentration of total ammonia
nitrogen not to be exceeded more than once every three years on average.
CCC = criterion continuous concentration
Status of Implementation
OU-1
In 1989, EPA entered into a Consent Decree with 26 Settling Defendants to perform the OU-1 remedial design
and remedial action.
Soil/ Sludges/Sediments and Air
The OU-1 Settling Defendants completed the design of the permeable and impermeable caps in 1992 and began
construction of the caps in 1993. Permeable caps (or equivalent covers) are in place over approximately 105 acres
of OU-1. including the West Hide Pile, the South Hide Pile, the East Central Hide Pile and surrounding affected
areas. The OU-1 Settling Defendants also installed an impermeable cover over the East Hide Pile, which covers
about 5 acres. A gas collection and treatment system was incorporated in the impermeable cover for the East Hide
Pile. It includes a thermal oxidizer unit (TOU) to treat emissions. The TOU is housed in a building northeast of
the East Hide Pile.
As of September 2008, the OU-1 Settling Defendants documented the completion of the soil, sludge and air
portions of the OU-1 remedy in a Master Cover Certification Report, as well as 34 property-specific Cover
Certification Reports. Institutional controls have been recorded for all of the OU-1 properties to satisfy the
requirements of the 1986 ROD (the Institutional Controls section of this FYR Report provides more information).
In 2011. sediment samples were collected in the drainage swale south of the East Hide Pile. Arsenic was detected
above the cleanup standard (300 mg/kg). The source of the arsenic was determined to be groundwater discharge
into the swale. After sediment removal to address the elevated arsenic concentrations, an impermeable barrier was
installed in 2014 to prevent any continued discharge of arsenic-impacted groundw ater into the sw ale. The overall
design modification and construction for this portion of the drainage swale by the East Hide Pile finished in 2017.
15
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In 2014, an indoor air and sub-slab soil gas monitoring event was performed to evaluate potential hydrogen
sulfide and methane in response to odor complaints from occupants of a building next to the East Central Hide
Pile. A determination was made that workers were not at risk and that potential future acute hazards were very
low, but that potential future nuisance odors could not be excluded due the difficulty in detecting low levels of
hydrogen sulfide. This building will be included as requiring further investigation as part of the vapor intrusion
investigation recommended and carried over from the 2019 FYR.
Groundwater
The OU-1 Settling Defendants began the design for a groundwater treatment system in the early 1990s, called for
in the OU-1 ROD. but it was not constructed. The permanent groundw ater remedy outlined in the 2006 OU-2
ROD superseded the interim groundw ater remedy component of OU-1.
The 1989 OU-1 Consent Decree also required that Settling Defendants implement a Groundwater/Surface Water
Investigation Plan (GSIP). Its objectives were to evaluate the potential for future off-site migration of metals
through surface water pathways and to collect information needed by EPA for the site-related portion of the
MSGWRP, required by the 1986 OU-1 ROD. The groundwater/surface water investigation began in 1990 and
continued until 2004. In 2005, EPA completed the MSGWRP. using data from the Site's GSIP as well as data
from the Wells G&H Superfund site. Aberjona River Study Area (OU-3). The plan was incorporated into the OU-
2 remedy in the 2006 OU-2 ROD.
In the 2018 OU-1 ESD 1 EPA issued a determination, with the concurrence of the Commonwealth, that no
Superfund responses under CERCLA are required and no further cleanup is necessary at the 10.7-acre 200
Presidential Way parcel. EPA and the Commonwealth determined that there are no hazardous substances,
contaminants, pollutants, or associated exposure routes present on the 200 Presidential Way parcel which
constitute a CERCLA risk, and that the parcel was now available for UU/UE and protective of public health and
the environment. Because the 200 Presidential Way parcel contaminant levels meet UU/UE, no operation and
maintenance (O&M) activities or EPA FYRs are required for the parcel. In September 2020, based on the OU-1
ESD 1 conclusion that no responses under CERCLA were required and no CERCLA cleanup on the property was
necessary. EPA deleted the 10.7-acre 200 Presidential Way parcel from the NPL (Figure 2).
OU-2
In November 2008, EPA entered into a Consent Decree with two Settling Defendants11 to perform the Site's
remedial design and remedial action.
OU-2 cleanup was implemented in three phases by the OU-2 Settling Defendants based upon the follow ing
approved remedial designs:
• 2014 OU2 100% Remedial Design for Lower South Pond (adjacent to West Hide Pile) (Haley & Aldrich.
2014).
• 2015 OU2 100% Remedial Design Part 1 (HBHA Pond Remedy Structural Components including
capping Area 6 north of HBHA Pond and Dredging Restoration of Wells G&H and CBCA Wetlands.
Draft ICs Plan) (Haley & Aldrich. 2015b).
• 2016 OU2 100% Remedial Design Part 2 (HBHA Pond Remedy Non-Structural Components such as
secondary treatment cell dredging, aeration zone and settling zone, and mitigation of lost wetland and
flood storage functions and values) (Haley & Aldrich. 2016). Based on the use of the entire HBHA Pond
as part of the remedy, mitigation measures were implemented to compensate for the lost wetland and
floodplain function and values. Mitigation measures included establishing a compensatory wetland at 32
Cabot Road in Woburn and construction of a fish ladder at Center Falls Dam dow nstream on the
Aberjona River in Winchester. Massachusetts (to increase migratory fish habitats within the waterway).
11 The OU-2 Settling Defendants arc Bayer CropScience. Inc. (successor to Stauffer Chemical Company) and Pharmacia
Corporation (formerly known as Monsanto Company) which arc also two of the twenty-six Settling Defendants under the
OU-1 Consent Decree.
16
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From September 2014 until November 2014, the OU-2 Settling Defendants implemented the OU-2 ESD-modified
remedy for the Lower South Pond sediments adjacent to the West Hide Pile. Sediment removal progressed from
the westernmost edge tow ards the eastern edge. A total of about 550 cubic yards of sediment was excavated.
Confirmatory sediment samples were collected on an approximately 20-foot grid. Aquablock was installed along
the western edge of the excavation adjacent to the West Hide Pile to limit future shallow groundwater migration
to the restored wetlands. The excavation was backfilled to pre-remediation elevations. Backfilling activities
consisted of placing a layer of geotextile over the excavation, placement of wetland organic soil and covering that
soil with an erosion control blanket. Restoration activities also included re-planting 15 water lilies that had
become dislodged during excavation activities.
The rest of the remedial action was implemented over two construction seasons during 2015 and 2016.
From August to October 2015, a permeable cap was installed to cover soil impacted with arsenic above the
ecological cleanup standard of 273 mg/kg in the northern end of the HBHA Pond.
From August to December 2015, the Halls Brook diversion structure, bypass structure and pond cofferdam
component of the remedial design was constructed. This involved the construction of several structures within the
HBH A Pond (the Pond) that created a primary cell to intercept most of the contaminated groundw ater discharging
into the Pond (a stable chemocline. sequestering of contaminants). The primary and secondary cells were
separated by a sheet pile cofferdam that extended across the Pond. Flow diversion structures were constructed at
the OU-1 created wetland overflow structure and at the Halls Brook inlet to the Pond. The Halls Brook structure
directs base flow into the primary treatment cell12 and diverts storm flow through a bypass structure to the
southern end of the secondary treatment cell. In addition, energy dissipation structures comprised of riprap and
large boulders were installed at the Atlantic Avenue Drainway and Boston Edison Company inlets to the Pond;
both inlets discharge into the primary cell.
From November to December 2015, a reinforced concrete outlet structure was installed at the HBHA Pond to
provide a more uniformly shaped outlet channel, including wing walls constructed of steel sheet pile on either
side of the outlet structure to direct flow through the channel.
From April to July 2016, the HBHA Pond Secondary Treatment Cell was dredged to remove sediment with
elevated arsenic and ammonia concentrations and to achieve greater depth for adequate separation between the
pond bottom and the Webitats.13 This also created a deeper quiescent zone which allow ed for increased settlement
of solids. Dredging occurred by excavating from top of slope to the toe. A total of three sweeps were necessary to
dredge to the Performance Standard of less than 2 inches of organics within the Secondary Treatment Cell. The
secondary treatment cell incorporated aeration and mixing, along with synthetic engineered media to serve as
substrate for bacteria growth. Aeration, mixing and facilitated biological nitrification via Ammonia Oxidizing
Bacteria biofilm grow th on the Webitats serve as the primary means for treating ammonia. A mechanical building
with electrical and mechanical controls was also constructed.
From June to September 2016, the Wells G&H Wetland and CBCA near-shore sediment removal and disposal
component included the removal, dewatering and off-site disposal of sediment from impacted areas of the Wells
G&H wetland and CBCA that exhibited concentrations above risk thresholds. The wetlands sediment removal
12 The primary treatment cell was designed to intercept the majority of the contaminated groundwater discharging into the
HBHA Pond, maintain the natural processes that arc currently occurring in the northern portion of the HBHA Pond (e.g., a
stable chemocline. sequestering of contaminants, etc.), and preserve and enhance the natural treatment processes that arc
successfully sequestering COCs. The primary treatment cell sequesters high COG concentration in deeper water below the
chemocline. and less concentrations above the chemocline in the shallow surface water pass through a weir in the sheet pile
cofferdam and enter the secondary treatment cell. The Halls Brook bypass structure minimizes storm water disturbance to the
primary treatment cell and the secondary treatment cell's aeration system/zone.
13 Webitat bioreactors and an aeration system were installed in the secondary cell. The system is primarily designed to treat
ammonia by providing growth media (BioWeb) and sufficient aeration to promote biological nitrification. Aeration will
enhance the co-precipitation of arsenic with iron and the natural attenuation of benzene. The final component of the
secondary treatment cell after the aeration system/zone is a quiescent zone for additional settling of iron-arsenic Hoc.
17
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included three separate areas. The areas included the east side of Wells G&H wetland, the west side of Wells
G&H wetland and the CBCA.
From July to October 2016, the wetland mitigation component of the remedy was implemented. The remedy
included compensation for lost functions and values of resource areas (flood flow alternation, fish and wildlife
habitat, groundwater recharge/discharge and sediment/toxicant/pathogen retention) as dictated by the
Massachusetts Wetland Protection Act and federal Clean Water Act Section 404/401, for wetland resource areas
impacted as part of the HBHA remedies. Mitigation measures that compensated for the lost function and values
included excavation, wetland soil installation, wetland plantings, installation of a fish ladder and bank
improvement for wildlife habitat.
A total of 4.71 acres of wetland mitigation and 0.86 acres of floodplain habitat mitigation were required.
In 2017, OU-2 cleanup construction was completed, with closeout reports submitted on September 18, 2015, for
Low er South Pond (Haley & Aldrich. 2015a) and September 22, 2017, for the rest of OU-2 (Haley & Aldrich.
2017a). including wetland mitigation. After the final OU-2 closeout report submission in September 2017, the
OU-2 remedy shakedow n period of approximately 12 months began in October 2017.
Institutional Controls
The 1986 ROD for OU-1 required institutional controls for any areas containing wastes above the action levels.
The objective of the institutional controls is to ensure the long-term effectiveness of the remedial action by
preventing the unauthorized or inadvertent disturbance of the waste deposits and exposure to Site contaminants.
The 2006 ROD for OU-2 required institutional controls to restrict contact with certain soils, groundwater, or
deeper interior wetland sediments with concentrations above cleanup standards and to protect the remedy.
All properties within the Site require institutional controls. For OU-1 properties, the specific land and/or
groundwater use restrictions required are based on four land categories (Class A, B. C and D). These classes are
summarized below :
• Class A Land: May contain soil contamination above levels considered safe for unrestricted activity and
use (i.e., residential, day care and schools), and Contaminated Groundwater.
• Class B Land: May contain Contaminated Soil and Contaminated Groundwater.
• Class C Land: Contains Contaminated Soils and Cover and may contain Contaminated Groundwater.
• Class D Land: Contains Contaminated Soils and Cover and may contain Contaminated Groundw ater.
Class D also comprises the East. West, East-Central, and South Hide Piles.
For OU-2 properties, there are five land categories that drive the requirements for institutional controls:
• Category I Land: Surface soil concentrations exceed soil performance standards.
• Category 11 Land: Subsurface soil concentrations exceed soil performance standards.
• Category III Land: Groundwater concentrations exceed performance standards.
• Category IV Land: Sediment concentrations exceed performance standards.
• Category V Land: Remedy components are maintained and protected to ensure long-term effectiveness.
Institutional controls in the forms of GEREs and NAULs have been recored at all properties in OU-1 in 2024.
Figure 3 shows the OU-1 land classes. Figure 4 shows parcels in OU-1 requiring institutional controls. In
addition, the City of Woburn. working with EPA. promulgated a Road work Ordinance and Regulations (Title 12,
Article XV) that regulates work on roadways within the Site to protect the CERCLA remedy. 14
14 The OU-1 NAULs, GEREs and Roadwork Ordinance/Regulations also include restrictions on groundwater use as part of
the interim OU-1 groundwater remedy that also serve as groundwater institutional controls for the areas of OU-2 within OU-
1.
18
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Figure 5 shows OU-2 properties where institutional controls are required. Institutional controls are not in place in
OU-2, except for groundwater restrictions recorded in the OU-1 NAULs, GEREs and Roadwork Ordinance/
Regulations. Table E-l in Appendix E includes the summary of recorded institutional controls at OU-1 and
planned institutional controls at OU-2.
19
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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. Map image is the
intellectual property of Esri and is used herein under license. Copyright © 2020
Esn and its licensors. All rights reserved. Sources: Esri, Esri Community Maps
Contributors, MassGIS, © OpenStreetMap, Microsoft. Esri, TomTom, Garmin,
SafeGraph, GeoTechnologies. Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau. USDA, USFWS, Maxar. the 2006 ROD, the 2014 ESD. the
2018 ESD. the 2019 FYR Report and MassDEP.
Industri-Plex Superfund Site
City of Woburn, Middlesex County, Massachusetts
Last Modified: 5/14/2024
Figure 3: OU-1 Land Classes
LAND CLASS
May contain contaminated groundwater.
May contain contaminated groundwater and
may contain contaminated soils. No cover/
cap required.
May contain contaminated groundwater and
contains contaminated soil and cover/cap.
May contain contaminated groundwater and
contains contaminated soil and protective
cover/cap. Class D also contains four
animal hide piles.
20
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Figure 4: OU-1 Institutional Control Plan of Restricted Areas
n
iiiisiii'i
83 88!
?,
5/-H/-1'- WISfc. COMPLY hD \AL_5 & GLKLS
CCB
MD=
R
I /IO/21 REVSE PER EPA COMMENT
n~R
mi: j
A
4/ 0/? I UPDATr ir: PARC" ?
DlB
Ml:2
RCV.
DATF DE3CR =>TI0N C/C
DR
CK
/ PLAN OF RESTRICTED AREAS
' (COMPLETION EXHIBIT)
PREPARED FOR:
(NOW OR FORMERLY)
I.S.R.T.
WOBURN, MASSACHUSETTS
SCALE: 1" = 200' SF^TFM^F^ 10,
Surveying a Engineering J Land Planning Permitting 4 Septic C
?A
RELDST©NE
lLAND CONSULTANT
,1 | ~
MASSACHUSETTS BAY
TRANSPORTATION AUTHORITY
HOT C-151
LOCUS:
SCALE: 1"=200'±
Source: Industri-Plex Site Remedial Trust (ISRT) Industri-Plex GUI Coordinator, provided March 31, 2024 to EPA.
21
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Project No. 3204
Plot Date: 511/2024
Arc Operator JR
Reviewed by TM
Projection: Lambert Confermal Conic
Coordinate System: MA State Piane iManlandi
FPS Zone: 2001
Figure 5: OU-2 Properties Requiring Institutional Controls
1U-1-7 Parcel Identification Number
Industri-plex Superfund Site Boundary
I 1 Properties Requiring Institutional Controls
Accessible Near-Shore Wetland Area
6TJ57] Properties Requiring Deeper Interior ¦*
Wetland Institutional Control Area
Category I - V Properties Requiring
Institutional Controls
Industri-Plex
Wobum, Massachusetts
Legend
CaUifjf ly 1
CjUij>£jiy II
CdU*!>tiiy III
Surface Sals (0-3' bgs)
Exceeding Performance Standards
Sub-Surface (3-15' bgs)
Exceeding Performance Standards
Groundwater Concentrations
Exceeding Performance Standards
rsiUJ'10f/U Sediments
J ' Exceeding Performance Standards
r ,. Remedy Components Maintained and
**' *u 1 Protected to Ensure Long-Term Effectiveness
250 500 1,000
¦ Feet
Figure 1
**ddms
Source: Industri-Plex Site Remedial Trust (ISRT) Inc
EPA.
ustri-Plex OU1 Coordinator, provided March 31, 2024 to
22
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Systems Operations/Operation & Maintenance (Q&M)
The O&M phase of the project began in 2008 for OU-1 and in 2017 for OU-2, after construction completion was
documented in September 30, 2008 Master Cover Certification Report, prepared by Roux Associates. Inc.. and
September 22, 2017 Close-Out Report. Industri-Plex Operable Unit 2, prepared by Haley & Aldrich. Inc..
respectively.
For OU-1. this phase entails:
• Inspection (annual) and maintenance of all capped areas (engineered constructed caps as well as
equivalent cover caps).
• In 2024, EPA completed recording either NAULs or GEREs for all OU-1 properties. EPA anticipates
preparing letters to all the property ow ners with covers on their property reminding them of their
obligation to annually inspect the protective covers and other restrictions on their property and submit
annual inspection reports.
• O&M activities for the TOU (upgraded to a vapor combustor unit [VCU] during this FYR period) to
control fugitive emissions from the East Hide Pile.
• Inspections (annual) and maintenance of vegetated and armored surfaces in wetlands and streams.
The OU-1 Hide Pile Properties are inspected annually. The cover inspection indicated no deficiencies after routine
maintenance in 2020, 2021 or 2022. Maintenance activities for the East Hide Pile. South Hide Pile. West Hide
Pile and East Central Hide Pile included the removal of invasive plants (phragmites. autumn olive. Japanese
knotweed. buckthorn, hydrilla. etc.). upland mow ing, upland woody vegetation removal, debris removal, fence
line clearing, treatment of phragmites and hydrilla and removal of trees with a greater than 8-inch circumference
from the area surrounding the Created Wetland. The toe drains at the base of the East Hide Pile and West Hide
Pile are cleared of woody growth, shrubs, saplings, and invasive species. Rodent burrows identified during the
annual inspections are filled. Maintenance for wetlands and drainways included outlet control structure clearing,
treatment of phragmites and removal of vegetation from drainways.
Construction completion and Permission-To-Operate the 4.4-megawatt solar facility at the East-Central Hide Pile
and East Hide Pile of the Site will occur in 2024. Consistent with the EP A approved Photo Solar Electric
Generating Facility Work Plan - Revision 1, Industri-Plex Operable Uni No. 1 Superfund Site, Woburn, M A,
dated March 3, 2022, the solar developer is responsible for post-construction operation and maintenance within
the limits of the solar installation, in accordance with Appendix L Post-Construction Operations and
Maintenance.
The original OU-1 TOU system had been in operation for approximately 26 years, which was beyond its design
service life. During its operation through 2019, Destructive Efficiency Removal (DRE) testing was performed
annually to evaluate and ensure that the TOU system was operating to meet the design specifications. However,
increased maintenance and operational costs and the difficulty in obtaining spare parts due to the aging
equipment, led to the decision to replace the TOU with a more robust and dependable system.
In 2020, the TOU was upgraded to a VCU. Follow ing a series of startup and DRE performance tests, the VCU
was placed into full operation in January 2021. The operating frequency and duration of the VCU is adjusted
based upon the available East Hide Pile waste gas. Throughout 2021 to 2023, the VCU was generally operated
weekly. Routine maintenance included: blower maintenance and lubrication; examining air inlet filters (cleaning
and replacing, as necessary); checking various equipment components for loose hardware; verifying oil levels of
the compressed air lubricator; inspecting and cleaning the spark igniter; cleaning the inner lens of the burner view
port; compressor belt maintenance and replacement; and removing grow th from within the fenced blower area. In
addition, both blowers that extract the landfill gases and supply the VCU system were replaced in 2021.
As with the prior TOU system, the VCU system undergoes annual DRE testing to ensure the system is meting the
design specifications. The most recent DRE test was completed in December 2023.
23
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The focus of the Site Wetlands Operations. Maintenance & Monitoring has included treatment and control of
phragmites and removal of invasive shrubs in and around the wetlands and upland areas. Maintenance mowing
and herbicide treatment of invasive shrubs and phragmites has reduced cover of invasive species to about 5% in
2021 and 2022, which is under the maximum threshold of 10%. Herbicide treatment will continue on an annual
basis, as well as inspecting the entire Site in the spring and fall to identify any additional locations that might need
treating or invasive removal.
Additional items that occur annually are snow and ice removal, as needed, maintenance on VCU building heating,
ventilation, and air conditioning, and electrical systems and routine and non-routine building maintenance.
For OU-2, this phase entails:
• Inspections (annual) and maintenance of vegetated and armored surfaces.
• Inspections (annual) and monitoring of steel sheeting and reinforced concrete structures.
• O&M activities for the Halls Brook bypass flow control systems (annual inspections).
• O&M activities for in-pond treatment system blowers, flow controls and other mechanical systems
(monthly inspections).
• O&M activities for surface water flow monitoring instrumentation and sampling equipment (bi-weekly
inspections).
• Surface water monitoring (assessment of remedy performance and monitoring of dow nstream impacts,
generally monthly).
• Groundwater monitoring (monitoring of hydraulic gradients, and evaluation and verification of the
continued suitability of the required institutional controls, quarterly for the first three years and then
biannual for years four to 10).
• Additional monitoring (sediment sampling [every five years planned for fall 2024], chemocline
monitoring [every six hours] and sediment accumulation monitoring [every five years - occurred in 2019
and scheduled for 2024]).
The Settling Defendants are performing required O&M activities. These activities have generally been performed
as expected in the Site's O&M Plan. OU-2 wetland mitigation monitoring started in 2017 (first report submitted
in 2018) and the Center Falls Dam Fish Ladder is also monitored annually (first report submitted in 2018). Since
the previous FYR Report, the Settling Defendants have been performing the sediment sampling and sediment
accumulation monitoring outlined in a 2016 Operation. Maintenance and Monitoring Plan (OM&M Plan).
During this FYR period, annual structural inspections were performed which included inspection of vegetated and
armored surfaces, steel sheeting and concrete structures, the Halls Brook flow control structure, the groundw ater
monitoring well network and Center Falls Dam fish ladder. In 2021, two additional inspections were conducted:
one inspection on August 24, 2021, follow ing the precipitation event associated with Tropical Storm Henri and
one inspection on September 3, 2021, follow ing the precipitation event associated with Hurricane Ida. Findings
during this review period included:
• Wetland monitoring at three wetland mitigation areas showed that the three wetland mitigation areas
continue to be healthy, diverse, densely vegetated and vigorous growing assemblages of native wetland
species. Inspection of six upland restoration areas showed that they continue to grow in diversity and
density. Monitoring will occur again in 2026 (10 years following construction) with the exception of an
annual assessment for invasive species cover. An inspection of the Aberjona River indicated no presence
of beavers from the southern boundary of the Site (Washington Circle / CBCA to the HBHA Pond).
However, in December 2022, during a routine inspection, beaver activity was observed in the vicinity of
the hydraulic connection between the Aberjona River and the Southeastern Wetland Area 1. In December
2022, seven beavers were removed by Beaver Specialists.
Net Fish Passage at the Center Falls Dam Fish Ladder, Winchester, MA
Year
Net Passage
2019
50,862
2020
56,468
24
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2021
160,944
2022
103,538
2023
166,926
Inspection and Monitoring of Steel Sheeting and Reinforced Concrete Structures
• Inspection of: Halls Brook diversion. Halls Brook bypass and primary and secondary treatment cell
cofferdam and Pond Outlet steel sheeting; precast concrete manhole for the sluice gate and the box
culvert, including the headwall and flanged end section; and reinforced concrete trapezoidal outlet
channel to HBH A Pond, which show ed no areas of corrosion, damage, or other potential problems.
• Halls Brook Bypass Flow Control Systems are inspected annually. This includes the sluice gate
controlling flow to the box culvert and the stop log system that controls the flow to the Halls Brook
bypass. Maintenance activities for the Halls Brook bypass flow control system include: operation of the
sluice gate to ensure smooth operation; checking the sluice gate for any signs of corrosion; cleaning and
lubricating mechanical components of the sluice gate as appropriate; checking for and removing debris
from the sluice gate manhole and stopping the log structure; and inspecting the stop log structure groove
seal.
Q&M of In-Pond Treatment Svstem Blowers. Flow Controls and Other Mechanical Systems include the
following.
As of the 2023 Annual Report, all system components remain functional and operational as designed.
• At a minimum, the components of the in-pond treatment system are inspected once per month and during
regular maintenance and monitoring intervals.
• The follow ing are inspected annually: mechanical building; generator pad; fencing and gates; gangway,
docks, railings, pile brackets and hoops; and Webitats. surface aerator and fine bubble diffuser head tie
lines.
o Maintenance includes removing accumulated debris, vacuuming, and cleaning the components
and lubricating and adjusting valves, as needed.
• The Webitats coupon (including documentation for algae growth), area between the cofferdam and
downstream baffle, and impermeable curtain (used to separate the aeration zone from the settling zone)
are inspected quarterly.
o Maintenance includes removing accumulated debris and tightening the impermeable curtain
anchor line, as needed.
• The follow ing remedy activities occur monthly:
o Clean and balance Webitats.
o Inspect and clean dock system.
o Inspect primary and secondary treatment areas for debris.
o Check air lines and hose connections to Webitats.
o Clean and vacuum mechanical building including interior and exterior of blow er cabinets and
horizontal surfaces to remove accumulated dust and dirt.
o Monitor dissolved oxygen concentrations within, and immediately adjacent to Webitats.
o Maintenance of the above components included removing accumulated debris, vacuuming, and
cleaning the components as necessary and recording all field data collected.
Required maintenance activities completed throughout 2022 included inspection and maintenance of the blowers.
airflow , and airlines associated with the secondary treatment cell aeration system/zone. Also, a natural gas
emergency generator was permanently installed to act as a back-up generator for the secondary treatment cell
aeration system.
III. PROGRESS SINCE THE PREVIOUS REVIEW
Table 7 includes the protectiveness determinations and statements from the 2019 FYR Report. Table 8 includes
25
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the recommendations from the previous FYR Report and the current status of those recommendations.
Table 7: Protectiveness Determinations/Statements from the 2019 FYR Report
OH #
Protectiveness Determination
Protectiveness Statement
1
Short-term Protective
The remedy at OU-1 currently protects human health and the
environment, as exposure pathways that could result in unacceptable
risks arc being controlled. Soils and waste arc covered, there is no
current use of groundwater, and some institutional controls arc in
place. Operation and Maintenance activities arc in place to ensure
that the covers and associated components of the remedy remain in
good condition. Annual inspections must continue to be conducted to
ensure that deficiencies arc noted and corrected. However, in order
for the remedy to be protective in the long-term, additional
institutional controls will be created and recorded to restrict
inappropriate land uses (including use of groundwater) and protect
the components of the rcincdv.
2
Short-term Protective
The rcincdv at OU-2 currently protects human health and the
environment, as exposure pathways that could result in unacceptable
risks arc being controlled. The water treatment remedy is active and
meeting treatment standards. There is no current use of groundwater.
Operations and maintenance activities have been initiated and will
ensure that the components of the remedy remain in good condition.
In addition, monitoring of groundwater and surface water will
continue to assess the continued protectiveness of the water
treatment remedy. However, in order for the remedy to be protective
in the long-term: institutional controls will be created and recorded
to restrict inappropriate land uses (including use of groundwater) and
protect the components of the remedy; an evaluation of whether the
revised 2013 NRWQC for ammonia changes the discharge standards
will be performed; an evaluation of the potential for vapor intrusion
from groundwater contaminants and methane and hydrogen sulfide
gases will be performed; and analyze for PFAS [per- and
polvfluoroalkvl substances] in upcoming monitoring will be
performed to determine if PFAS arc COPCs |contaminants of
potential concern].
Sitewide
Short-term Protective
The remedies at the Site currently protect human health and the
environment, as exposure pathways that could result in unacceptable
risks arc being controlled. However, in order for the remedy to be
protective in the long-term: institutional controls will be created and
recorded to restrict inappropriate land uses (including use of
groundwater) and protect the components of the rcincdv; an
evaluation of whether the revised 2013 NRWQC for ammonia
changes the discharge standards will be performed; an evaluation of
the potential for vapor intrusion from groundwater contaminants and
methane and hydrogen sulfide gases will be performed; and analyze
for PF AS in upcoming monitoring will be performed to determine if
PFAS arc COPCs.
Table 8: St
tatus of Recommendations from the 2019 FYR Report
OIJ #
Issue
Recommendation
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
OU-1
Institutional
controls
restricting
inappropriate land
uses and
protecting the
Discussions between
EPA, MassDEP,
Settling Defendants,
and the property
owners arc ongoing.
Upon completion of
Completed
The final institutional controls
have been recorded during
this review period completing
OU1 institutional controls.
During this period the City of
Woburn also promulgated
2/26/2024
26
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OIJ #
Issue
Recommendation
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
reined}
components need
to be established
on OU1
properties.
discussions between
the Settling
Defendants,
institutional controls
should be established.
Roadwork Ordinance and
Regulations to establish OU-1
IC requirements over the
roadways within OU-1 that it
regulates.
OU-2
Institutional
controls
restricting
inappropriate land
uses and
protecting the
remedy
components need
to be established
on 0U2
properties.
Discussions between
EPA, MassDEP, and
the Settling
Defendants arc
ongoing. Upon
completion of
discussions between
the Settling
Defendants,
institutional controls
should be established.
Ongoing
Institutional controls need to
be established for OU-2
properties and arc in progress
To Be
Determined
OU-2
The NRWQC for
ammonia has been
updated since the
2006 ROD.
Evaluate whether the
revised 2013 NRWQC
calls for a change to
the discharge
standards in the OU2
ROD for ammonia
concentrations at the
point of compliance to
protcctivcness of the
remedy.
Completed
The Settling Defendants
prepared a freshwater mussel
field investigation plan in
May 2021 and the plan was
implemented in June 2021
with EPA field oversight. On
July 9, 2021, the Settling
Defendants submitted the
results of their June 2021
field investigation and
concluded no unionid mussels
or evidence of unionid
mussels were found in the
investigation areas. Because
no evidence of unionid
mussels in the investigation
areas, the original 2006 ROD
ammonia cleanup levels
remain appropriate.
9/9/2021
OU-2
Groundwater
cxcccdances of
VISLs [Vapor
Intrusion
Screening Levels]
(e.g., benzene,
TCE,
naplitlialcne)
show that the
vapor intrusion
pathway may be
of concern.
Migration of
methane and
hydrogen sulfide
to nearby
buildings may
also be of
concern.
Evaluate the potential
for vapor intrusion
from groundwater
an unacceptable risk
and the potential for
migration of methane
and hydrogen sulfide
from animal hide
residue/remnants to
nearby buildings
posing an explosive
hazard or risk.
U nder
Discussion
The Settling Defendants
prepared a Draft Preliminary
Vapor Intrusion Work Plan in
April 2021. EPA has provided
written comments on the
Draft Preliminary Vapor
Intrusion Work Plan and is
awaiting a revised work plan.
Not applicable
27
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OIJ #
Issue
Recommendation
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
OU-2
Groundwater
monitoring has
not included
analysis for
PFAS, so it is
unclear if these
chemicals arc
contaminants of
potential concern
at the site.
Include analysis for
PFAS in an upcoming
groundwater
monitoring event to
determine if these
compounds arc
contaminants of
potential concern at
the site.
Under
Discussion
In 2020, 12 groundwater
wells were sampled for
PFAS. Because the 2006
ROD identified the
groundwater as non-potable,
the 2006 groundwater cleanup
remains protective, and no
additional PFAS groundwater
investigations are currently
planned.
7/10/2020
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Community Involvement and Site Interviews
EPA issued an online news release in February 2024 to announce that the FY R 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/industriplex.
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 H
includes the completed interview forms. While the City of Woburn's Engineering Department provided a
response, the City of Woburn's Board of Health did not respond to requests for an interview.
Jennifer McWeeney, the MassDEP project manager stated that the OU-1 and OU-2 remedies are well-managed
and maintained and Site OU-1 reuse activities are well-managed in accordance with existing OU-1 institutional
controls. She mentioned that if it is possible, the Preliminary Vapor Intrusion Work Plan should be finalized in
time to allow for indoor air sampling in winter or early spring of 2024. The City of Wobum's engineer John
Corey stated that he is aware and well-informed of the former issues at the Site and the Site's activities and
remedial progress. He stated that EPA has done an excellent job keeping involved parties and surrounding
neighbors informed of activities at the Site. The Settling Defendants" representative for OU-1. Todd Majer with
de maximis, inc.. stated that the remedial activities at the Site are effective and protective of human health and the
environment. The monitoring data indicate that the surface water cleanup levels are being met at the point of
compliance. The Settling Defendants would like to conduct an aeration pilot study within the secondary treatment
cell and would like to reduce the frequency of base flow surface water sampling and groundwater sampling. They
are awaiting EPA's response to determine a path forward. The Settling Defendants" representative for OU-2,
Bruce Thompson with de maximis. inc.. stated that the long-term O&M is proceeding and working as expected
and that groundwater and surface water concentration trends are declining or steady. He stated that the surface
water monitoring program has been ongoing since remedy completion and could be reduced as proposed in the
O&M Plan. Representatives from Aberjona Study Coalition stated that they are aware of the former
environmental issues at the Site and that their impression is that it is a professional, we 11-managed project. They
are not aw are of any effects of the Site on the surrounding community and feel that EPA has kept involved parties
and surrounding neighbors informed of activities at the Site.
Data Review
OU-1
The Vapor Combustor Unit (VCU) replaced the original Thermal Oxidation Unit (TOU) during this FYR period.
The VCU destroys hydrogen sulfide gases associated with the East Hide Piles impermeable cover and gas collection
and treatment system. The December 7. 2022 Compliance Test Report of the VCU documented Hydrogen Sulfide
and Total Reduced Sulfur Destruction Removal Efficiency (DRE) at 99.84% and 99.83%, respectively.
28
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The vapor mitigation system installed during the 2019-2020 development at 120 Commerce Way was tested
consistent with EPA and MassDEP guidance, and collected four rounds of sub-slab soil gas. indoor air and outdoor
air samples. All sub-slab soil gas samples were below EPA and MassDEP soil gas screening levels, and all soil gas
samples had laboratory reporting limits below the screening levels. Hence, vapor intrusion into occupied spaces of
the building is not a concern based upon this data. The results of the sub-slab soil gas. indoor air and outdoor air
will be documented in a Completion Report, which is anticipated to be submitted to EPA and MassDEP for review
and approval later in 2024.
Ongoing inspection and maintenance work for OU-1 is included in the O&M section of this FYR Report.
OU-2 - Groundwater
The groundw ater monitoring program includes up to 25 monitoring wells (Appendix D. Figure D-3).
Groundwater flow s from OU-1 to the southeast toward the HBHA Pond. The pond is a groundwater intercept
system for the Site. Groundwater contamination remains at concentrations above the 2006 ROD groundwater
performance standards for ammonia, arsenic and benzene, show n in Table 9. Figures D-8 to D-14 show the
locations of groundwater contamination in November 2022. As shown in these figures, groundwater monitoring
wells with contamination are generally located at or upgradient of the HBHA Pond. The HBHA Pond Remedy's
treatment cells appear to be removing ammonia and sequestering groundwater contaminants as intended. Table E-
2 in Appendix E provides the groundwater sampling data from 2022.
Table 9: Maximum COC Groundwater Concentrations in 2022
COC
Cleanup Level"
(UU/L)
Maximum in 2022b (jijj/L)
Ammonia
4,000
424,000 (May, MW-213)
Arsenic (dissolved)
150
3,430 (November MW-204)
Bcn/cnc
4
42,000 (November. MW-104S)
1.2-Dichloroethanc
2
Not detected from October 2017 to December 2022
Naphthalene
5
0.31 (May, MW-201)
TCE
1
0.23 (Februarv. MW-006D)
Notes:
a) Groundwater performance standards arc applicable to the portion of the aquifer from OU-1 south to Interstate 95
(2006 ROD. page 99). Groundwater south of Interstate 95 is being address by the Wells G&H site remedies.
b) From Section 3.4.3.3, Groundwater Sampling Results, of the 2022 Draft Final OU-2 Annual Report, pdf pages 30-32
and Table 9 (pdf pages 106-113) of the 2022 Draft Final OU-2 Annual Report.
Bold = Exceedance of cleanup level.
Time-series plots of COC concentrations in groundw ater based on monitoring well locations are show n in Figure
D-15 in Appendix D. Mann-Kendall analysis using data from 2017 to 2022 are presented in Table E-3 in
Appendix E. The Mann-Kendall analysis provides a statistical analysis to show whether there is an upw ard or
downward trend of the variable of interest over time. The following observations are noted based on the
groundwater analytical sampling:
• Ammonia: Of the 19 monitoring wells where ammonia has been detected in more than 50% of the
samples collected, no significant trend was observed at 12 monitoring wells, a decreasing trend was
observed at three monitoring wells (MW-001D. MW-002D and MW-213) and an increasing trend was
observed at four monitoring wells (MW-007D. MW-209, MW-2 10, MW-2 11).
• Arsenic: Of the 16 monitoring wells where arsenic has been detected in more than 50% of the samples
collected, no significant trend was observed at 14 monitoring wells for total arsenic and at 12 monitoring
wells for dissolved arsenic. An increasing trend was observed at three monitoring wells, MW-003D
(dissolved only), MW-006D and MW-209.
• Benzene: Of the six monitoring wells where benzene has been detected in more than 50% of the samples
collected, no significant trend was observed at four monitoring wells (MW-003D, MW-104S, MW-106S
and MW-208), a decreasing trend was observed at monitoring well MW-202 and an increasing trend was
observed at monitoring well MW-007D.
29
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• 1,2-Dichloroethane: Not detected from October 2017 to December 2022.
• Naphthalene: Only detected in select samples from four monitoring wells (MW-007D. MW-102, MW-
104S and MW-201). Naphthalene was detected in less than 50% of the total samples collected from each
specific monitoring well and all detections, so no trend analysis is observed. Naphthalene was below
cleanup levels in 2022.
• TCE: Never detected above the cleanup level.
Per- and Polyfluoroalkyl Substances (PFAS)
In 2020, the Settling Defendants sampled 12 groundwater wells for PFAS, and analyzed the samples using EPA
Method 537.1, Version 2, March 2020. Seven of the wells (MW-001D. MW-003D, MW-007D. MW-102. MW-
202, MW-208 and MW-213) have total PFAS for the sum of the six compounds regulated by the state greater
than the current state standard (20 nanograms per liter [ng/L] for the sum of perfluorodecanoic acid (PFDA).
perfluoroheptanoic acid (PFHpA). perfluorohexanesulfonic acid (PFHxS). perfluorononanoic acid (PFNA),
perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). MW-001D had the highest
concentration of PFAS with a sum of the six compounds regulated by the state of 55.982 ng/L.
In April 2024, EPA issued MCLs for six PFAS contaminants including PFOA. PFOS. PFNA, PFHxS. HFPO-DA
(Gen-X) and PFBS (discussed in Section V). Table 10 shows a comparison of the maximum 2020 PFAS
concentrations against the 2024 PFAS MCLs. The PFAS MCLs of 4 ng/L for both PFOA and PFOS. individually,
were exceeded in all twelve wells. Table E-4 in Appendix E provides the complete groundwater sampling results.
The 2006 OU-2 ROD identifies the groundw ater as non-potable and there are no current uses of groundw ater at
the site, north of Interstate 95.
Table 10: Comparison of 2020 PFAS sampling to KPA's PFAS MCLs
PFAS Comi)ouml
EPA PFAS MCL
(n^/L)
Maximum Concentration in
2020b (n«/L)
Pcrfluorohcxancsulfonic Acid (PFHxS)
10
3.12 (MW-213)
Perfluorononanoic Acid (PFNA)
10
2.6 (MW-001D)
Perfluorooctanesulfonic Acid (PFOS)
4
13.2 J (MW-208)
Perfluorooctanoic Acid (PFOA)
4
25.5 (MW-00ID)
Perfluorobutanesulfonic Acid (PFBS)
Hazard Index 1 limitless)"
4.42 (MW-102)
Notes:
a) The PFAS MCL Hazard Index (HI) of 1 for PFBS is defined as a mixture containing two or more of PFHxS,
PFNA, HFPO-DA. and PFBS. The H1 based on the 2020 maximum concentrations equates to 0.6. HFPO-DA
(Gen-X) was not sampled in 2020 sampling event,
b) Table 8 of the Remedial Action Progress & Compliance Report No. 045, June 2020.
J = estimated value
Bold = cxcecdance of MCL
OU-2 - Surface Water
The surface water monitoring program consists of nine surface water monitoring stations and four in-pond
locations (Appendix D. Figures D-3 through D-5). Performance of the remedy relative to the surface water
cleanup standards is evaluated at the point of compliance - surface water monitoring station SW-02-TT. which is
the discharge point from the secondary treatment cell in the HBHA Pond. Other monitoring locations evaluate
concentrations at inputs to the pond and at various stages across the pond as well as dow nstream conditions.
Concentrations of arsenic and benzene did not exceed the cleanup levels at the surface water monitoring point of
compliance, station SW-02-TT. in 2020, 2021 or 2022 (Appendix E, Tables E-5, E-6 and E-7). Concentrations of
ammonia in samples collected at the outlet of HBHA Pond (SW-02-TT) were compared to the NRWQC-CCC for
fish in early life stages present, as defined in the 1999 Update of Ambient Water Quality Criteria for Ammonia.
The NRWQC-CCC is dependent on temperature and pH. To comply with the surface water Cleanup Standard, the
30-day running average ammonia concentration quotient should not exceed a value of 1.0 more than once every
three years, or 2.5 averaged over four days. As an example, the 30-day running average ammonia concentration
quotient for data collected throughout 2022 is included as Figure D-6 in Appendix D. A figure summarizing the
30
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four-day running average ammonia concentration quotient for data collected throughout 2022 is included as
Figure D-7 in Appendix D. The 2019 through 2022 ammonia concentrations have all been below the four-day and
30-day running average ammonia concentration quotient of 2.5 and 1.0, respectively.
The NRWQC for ammonia has been updated since the 2006 ROD. The 2013 update reflects new data on sensitive
freshwater unionid mussels and gill-breathing snails. The 2019 FYR Report recommended that the applicability of
the revised 2013 NRWQC and the potential need to revise the OU-2 remedy discharge standard for ammonia
concentrations at the point of compliance to maintain the protectiveness of the remedy should be re-evaluated
during the next FYR period. In 2021, the Settling Defendants prepared a freshwater mussel field investigation
plan, which EPA approved. A detailed field investigation took place on June 22, 2021, to determine if freshw ater
mussels in the Order of Unionoida (unionid mussels) are present or absent from the area of investigation. No
unionid mussels or evidence of unionid mussels were identified in the investigation areas. Because no unionid
mussels were identified during the investigation, the 2006 ROD ammonia cleanup levels remain appropriate.
OU-2 -Sediment
Due to the construction completion sequence, long term sediment sampling under the 2016 OM&M Plan is
divided into two sampling periods (2019 and 2022) where samples are collected every five years.
The Settling Defendants collected two sediment sample locations (SP-02 and SP-03) from the Low er South Pond
adjacent to the West Hide Pile in 2019, and five sediment sample locations (SE-205, SE-217, SE-218 from Wells
G&H Wetland and SE-225, SE-227 from CBCA). All of these sediment sample results were below their
respective 2006 ROD and 2014 ESD sediment cleanup levels, as noted in Tables 4 and 5 on pages 14-15.
Sediment Sample
Date
Arsenic
fme/ke)
Benzo(a)pyrene
Cma/ka)
Benzene
(iiisi/kii)
SP-02
11/12/2019
NC (Not
Collected)
NC
0.0018
SP-03
11/12/2019
NC
NC
ND
(0.0021)*
SE-205
10/27/2022
13.4
0.3
NC
SE-217
10/28/2022
45.1
0.35
NC
SE-218
10/27/2022
93.5
0.052
NC
SE-225
10/27/2022
26.5
NC
NC
SE-227
10/27/2022
10.5
NC
NC
Notes:
*ND (0.0021) means non-detect with a laboratory detection limit of 0.0021 mg/kg.
In addition, the Settling Defendants also collected five sediment samples from downstream locations (SE-301,
SE-302, SE-303, UML-UF-SED-400, and UML-LF-SED-401) in 2022 consistent with the OM&M Plan.
Site Inspection
The site inspection took place on 11/17/2023. In attendance were Gordon Bui lard (Twin Lights Associates. LLC.
subcontractor to EPA contractor AECOM), Todd Majer of de maximis, inc. (site manager for the OU-1 Settling
Defendants, who also coordinates with site manager for the OU-2 Settling Defendants), and Kirby Webster and
Jill Billus (EPA FYR 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.
Site inspection participants met at the TOU building, which is east of the East Hide Pile. Participants discussed
the history of the Site, remediation activities and current redevelopment activities. Site inspection participants
visited the OU-1 hide piles. Within the past five years, the East Hide Pile has been developed with solar panels.
The East Hide Pile and the West Hide Pile did not have any significant issues observed. The East Hide Pile is
fenced to prevent access to the solar panels. Participants observed the Lower South Pond and discussed the effort
31
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to remove invasive species from the pond. During the past five years, the TOU has been transitioned to a vapor
combustor. The vapor combustor was built off the back of the TOU building and operates as intended.
Participants drove around the OU-1 area to observe the East Central Hide Pile, the South Hide Pile, different
types of cover, redevelopment that has occurred and the new residential developments located at 200 Presidential
Way (now delisted from the site) and 120 Commerce Way.
The representatives from Twin Lights Associates and Skeo also visited 211 New Boston Street where, during a
building modification project consistent with an EPA-approved NAUL work plan, the concrete floor of the
building collapsed from the weight of the concrete floor saw-cutting equipment due to underlying void spaces
associated with the discovery of undocumented buried drums beneath the floor. The limited number of visible
metal drums are in poor condition and the contents of the drums and the presence or absence of contamination are
unknown. Ground Penetrating Radar (GPR) readings indicate up to 300 drums may be buried under the building,
but it has not been safely possible to sample the contents of the drums. Further investigations of the drums and
their removal are in the planning process. Under the OU-1 remedy, the building foundation was designated as part
of the cover over the Site's contaminated soils. Since the FYR inspection, a secure, locked chain-link fence was
installed across the building opening to prevent unauthorized access to the building. It is currently inaccessible.
Site inspection participants viewed the HBHA Pond Remedy and associated drainageways along with the Webitat
Biological Treatment Units and the Operation Building associated with the treatment units. Participants viewed
the HBHA wetland and drove to the Center Falls Dam Fish Ladder. Vegetation is well established across the Site.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents'.'
Question A Summary:
The remedy selected for OU-1 in the 1986 ROD. as modified by the 2018 and 2023 ESDs. included site grading,
the installation of impermeable and permeable caps over certain areas along with a gas collection layer and
treatment, as well as maintenance, monitoring and institutional controls. The 2018 and 2023 ESDs re-evaluated
land uses for certain portions of the Site to allow residential use. The remedy selected for OU-2 in the 2006 ROD.
as modified by the 2014 ESD, included dredging and off-site removal of sediments, interception and treatment of
contaminated groundwater, construction of impermeable and permeable caps and institutional controls. These
actions addressed both human health and ecological risks identified during the remedial investigations. Based on a
review of site documents and recent data, there are currently no unacceptable risks to human or ecological
receptors, and institutional controls and engineering controls are in place to prevent future exposures in OU-1
(described below) but have not been established for OU-2
OU-1
Yes. except in one limited area. The review of documents and monitoring data and the results of the site
inspection indicate that the cover component of the remedy has been designed and constructed as intended in the
Site's 1986 ROD. The gas collection and treatment system has been designed, constructed, and upgraded (in
2020) and is performing as intended in the ROD to control nuisance odors emanating from the East Hide Pile.
During this FYR period, the gas collection and treatment system was upgraded from the TOU to a VCU to
improve efficiency.
In 2023, EPA issued ESD 2 to allow residential use for a limited 3.42 acres of Class B land within the Site located
at Zero New Boston Street. The remedy change in ESD 2 was based on a property-specific baseline human health
risk assessments demonstrated potential soil exposure scenarios, including residential use as well as daycare and
school use (with exposure scenarios similar to or less than residential use), are reasonable and allowable. The IC-
32 NAUL and IC-28 GERE will be amended to allow residential development (including residential, daycare and
school uses) within Class B land at this property.
32
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As of February 2024, institutional controls, as required by the ROD. have been established at all OU-1 properties
and for roadways within OU-1 and are functioning appropriately. Only minor violations of the institutional
controls have occurred during this review period and these violations have been corrected. For example, at one
property utility poles were installed through the protective cover and surplus contaminated soils were left adjacent
the utility poles. Under an EPA approved Work Plan entitled Contaminated Soil Removal and Cap Repair
Industri-Plex Superfund Site, Woburn, MA, prepared for MBTA, dated June 2019, corrective measures were
implemented to address the contaminated soils and repair the remedy. Annual inspections identify maintenance
items, which are generally addressed following notification of individual property owners.Under the City's
Roadw ork Ordinance and Regulations EPA is notified of any proposed work within IC-restricted areas. No
violations of the Ordinance and Regulations has been reported to EPA.
Consistent with the institutional controls and Exhibit I - Work Protocols, various landow ners proposing to disturb
the protective remedy have prepared Work Plans generally describing how the remedy will be disturbed, workers
protected, contaminated soils and groundwater managed, and remedy reinstated for EPA review and approval.
Since the 2019 Five Year Review Report. EPA has approved Work Plans including, but not limited to:
• Environmental Work Plan. Proposed Utility Installation. 20 Atlantic Avenue, Woburn. MA, dated June
17. 2019;
• Soil and Groundwater Management Work Plan for Construction. 120 Commerce Way, Woburn. MA,
dated August 2019;
• MBTA North Side ATC Signal Work. Industri-Plex Superfund Site. Revised Work Plan, dated August
2020;
• Photovoltaic Solar Electric Generating Facility Work Plan-Revision 1. Industri-Plex Operable Unit No. 1
Superfund Site, dated March 2022;
• Work Plan Building Modification Project. 21 1 New Boston Street. Woburn. MA, dated January 17.
202316;
• EPA Work Plan, Bridge Replacement Project. New Boston Street over MBTA Railroad. Woburn. MA,
dated May 2, 2023;
• Work Plan, Removal and Replacement of Distribution Line 375-H5 (ROW 9) Poles 1009/60D,
1009/61D. and P161/36 located within Class B and C Land. Industri-Plex Superfund Site. New Boston
Street. Woburn. MA, dated May 2023.
Under the OU-1 institutional controls, each landow ner with Class C and/or D Land Covers on their property has
an obligation to annually inspect the covers on their property associated with NAULs Sections 5 and 4. Each
landowner with Class A and/or B Land on their property has an obligation to annually inspect their property
associated with NAULs Sections 5.E - 5.F, and 4 (e.g., ensuring no groundwater use. no residential, day care or
school use. no interference with the Remedy, etc .).
The limited area where the remedy is not functioning as intended by the OU-1 remedy is at the 21 1 New Boston
Street property where the foundation floor has failed due to the underlying disposal of buried drums containing
unknown material. The building's concrete floor serves as a component of the OU-1 protective cover, known as
an equivalent cover, preventing contact with underlying contaminated soils. Since the FYR inspection, a secure,
locked chain-link fence was installed across the building opening to prevent unauthorized access to the building
and potential exposure until any potential contamination determined to be in the drums is addressed and the
equivalent cover is restored.
QU-2
15 Under the terms of the OU-1 Consent Decree, the OU-1 Settling Defendants arc responsible for maintaining the
effectiveness of the remedial action as required under the O&M Plan approved or developed by EPA pursuant to the Consent
Decree and the Statement of Work. Landowners are responsible for normal O&M activities for surface features on top of the
remedial components on their properties (e.g., maintaining existing parking lots over remedy caps, mowing).
16 This is the work plan that was in effect when the drums buried under the building's foundation were uncovered.
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Yes. The review of documents and monitoring data and the results of site inspections indicate that the
soil/sediment removal components of the remedy have been designed and implemented as intended in the Site's
2006 OU-2 ROD. The HBHA Pond treatment cells also were designed and constructed as intended in the ROD
and appear to be removing ammonia and sequestering groundw ater contaminants as intended. Impermeable
covers were also designed and constructed as intended in the ROD. Institutional controls, as required in the ROD.
have not been established yet. Monthly and annual reports show that O&M activities are working in a manner that
will continue to maintain the effectiveness of the remedy. Groundwater concentrations of COCs above the
applicable groundw ater performance standards are not migrating into a property where institutional controls are
not contemplated. This is reviewed annually. Increasing trends for ammonia were observed at four monitoring
wells (MW-007D. MW-209, MW-2 10, MW-2 11). Increasing trends for arsenic were observed in groundwater at
three monitoring wells (MW-003D [dissolved only]. MW-006D. MW-209) and increasing trends of benzene were
observed at monitoring well MW-007D. These wells and the other groundwater monitoring wells as well as
surface water monitoring will continue to be monitored consistent with the prior monitoring program to monitor
trends and remedy performance.
Wetland monitoring at three wetland mitigation areas showed that the three wetland mitigation areas continue to
be healthy, diverse, densely vegetated, and vigorous growing assemblages of native wetland species. Inspection of
six upland restoration areas showed that they continue to grow in diversity and density. Monitoring will occur
again in 2026 (10 years following construction), with the exception of an annual assessment for invasive species
cover.
The 2023 Center Falls Dam fish passage counts show that the fish ladder continues to operate appropriately.
About 166,926 herring were observed migrating up the fish ladder successfully in 2023. Per the Site's O&M Plan,
this monitoring will be performed annually for the first five years and then in years 10 and 15. This is the second
FYR and constitutes year 10.
QUESTION B: Are 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 and potential standards since the 1986 OU-1 ROD. and its
subsequent ESDs in 2018 and 2023 and 2006 OU-2 ROD as modified by the 2014, 2018 and 2023 ESDs were
issued as discussed below and shown in Appendix I. The changes described below and in Appendix I are not
expected to alter the current protectiveness of the remedy because engineering controls are in place, the
groundwater is currently not being used for drinking water, and institutional controls in place for OU-1 and
planned for OU-2 that ill prevent future exposures to soil, sediment, air. and groundwater contamination.
Changes in Standards and To Be Considered Criteria (TBCs)
New standards (federal or state statutes and/or regulations), as well as new TBC guidance, should be considered
during the FYR process as part of the protectiveness determination. Under the NCP, if a new federal or state
statute and/or regulation is promulgated or a new TBC guidance is issued after the ROD is signed, and, as part of
the FYR process it is determined that the standard needs to be attained or new guidance procedures follow ed to
ensure that the remedy is protective of human health and the environment, then the FYR should recommend that a
future decision document be issued that adds the new standard as an ARAR or guidance as a TBC to the remedy.
EPA guidance states:
"Subsequent to the initiation of the remedial action new standards based on new scientific information or
aw areness 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
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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, pp. 1-56).
ARARS were established and TBC guidances identified for the OU-1 remedy in the 1986 OU-1 ROD. ARARs
were established and TBC guidances identified for the OU-2 remedy in the 2006 OU-2 ROD and were updated
and modified by the 2014 ESD. No new statu to ry/regu I ato ry standards or changes in existing ARARs or TBC
guidances have been identified during this review period that would alter the protectiveness of either the OU-1 or
OU-2 remedies.
PFAS Activities at the Industri-Plex Superfund Site
The purpose of this section is to present current information related to PFAS activities at the Site and to evaluate
whether there are any potential impacts to remedy protectiveness from PFAS. On April 10, 2024, EPA issued
MCLs for six PFAS contaminants, including PFOA. PFOS. PFNA, HFPO-DA (Gen-X). PFHxS, and PFBS:
Compound
Final MCL
PFOA
4 ppt
PFOS
4 ppt
PFHxS
10 ppt
PFNA
10 ppt
HFPO-DA (Gen-X)
10 ppt
Mixtures containing two or more of PFHxS,
PFNA, HFPO-DA, and PFBS
Hazard Index 1 (unitless)
PFOA was detected at a maximum concentration of 25.5 ng/L (MW-001D). PFOS at 13.2 ng/L (MW-208), PFNA
at 2.6 ng/L (MW-001D). PFHxS at 3.12 ng/L (MW-213) and PFBS at 4.42 ng/L (MW-102). Detected levels of
PFOA and PFOS exceeded the MCL of 4 ppt for both contaminants individually. The PFAS MCL Hazard Index
(HI) of 1 for PFBS is defined as a mixture containing two or more of PFHxS. PFNA, HFPO-DA. and PFBS. The
HI equates to 0.6. The groundwater is identified as non-potable, there are no current uses of groundwater, and
federal and state MCLs are not ARARs for either the OU-1 or OU-2 remedies.
The following subsections discuss the relevant PFAS toxicity values and standards that are currently available,
followed by a discussion of Site activities related to PFAS and protectiveness conclusions.
PFAS Toxicity Values
This section presents the toxicity values that EPA currently has available for PFAS compounds.
2024 Cancer and Non-cancer Toxicity Values for PFOA and PFOS
On April 10, 2024, EPA issued new MCLs for PFOA and PFOS (4 ppt individually) which utilize updated
toxicity values for cancer and non-cancer effects developed by EPA Office of Water. The new oral cancer slope
factors are 29,300 |mg/kg/day|"'for PFOA and 39.5 [mg/kg/day]J for PFOS. For non-cancer, the new oral
reference dose values are 3 x 10~8 (mg/kg/d) for PFOA and 1><10~7 (mg/kg/d) for PFOS. It is noted that toxicity
values for PFHxS. PFNA, HFPO-DA (Gen-X). and PFBS are not changed with the new MCLs.
2023 Non-cancer Toxicity Values for PFODA, PFTetA, PFDoDA, PFUDA, PFHxA, PFPrA, HQ-115
In November 2023, EPA adopted new non-cancer oral reference dose (RfD) values for multiple PFAS compounds
based on toxicity values developed by the State of Wisconsin Department of Health Services which include
35
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perfluorooctadecanoic acid (PFODA) 4E-0217 mg/kg-day, perfluorotetradecanoic acid (PFTetA) 1E-03 mg/kg-
day. perfluorododecanoic acid (PFDoDA) 5E-05 mg/kg-day, and perfluoroundecanoic acid (PFUDA) 3E-
04 mg/kg-day.18
Additionally, new oral RfD values were released for two PFAS compounds based on toxicity values published by
the EPA Office of Research and Development (ORD) which include perfluoropropanoic acid (PFPrA) 5E-04
mg/kg-day and lithium bis|(trifluoromethyl)sulfonyl|azanide (HQ-1 15) 3E-04 mg/kg-day, also known as 1.1.1-
trif]uoro-N-(trifluoromethanesu!fonyI)methunesuIfbnumide (TFSI).19
These values were determined to be based on similar methods and procedures as those used for other Tier 3
toxicity values. It is noted that currently there are no analytical methods available for PFODA and the two EPA
ORD compounds PFPrA and HQ-115/TFSI.
In April 2023, EPA released a new non-cancer oral RfD of 5.0E-04 mg/kg-day for perfluorohexanoic acid
(PFHxA) based on an Integrated Risk Information System (IRIS) value.20
In June 2020, the Settling Defendants collected 12 groundwater samples and analyzed the samples via EPA
Method 537.1, Version 2, March 2020. The table below includes results from the 2020 PFAS sampling event at
the Site. Since groundwater consumption is not an exposure pathway for the Site (because the aquifer is non-
potable and there are no current uses of groundwater), the data does not show any potential impacts to the
protectiveness of the OU-2 remedy.
PFAS compound
Industri-Plex 2020 Groundwater
Sampling Maximum Concentrations
PFODA
Not sampled*
PFTetA
Not detected
PFDoDA
Not detected
PFUDA
0.253 (estimated) ng/L (MW-003D)
PFHxA
15.6 ng/L (MW-001D)
PFPrA
Not sampled*
HQ-1 15/TFSI
Not sampled*
* Analytical methods not available
2022 Non-cancer Toxicity Values for PFNA, PFHxS, HFPO-DA, PFBA
In May 2022, EPA issued new non-cancer oral RfD values for multiple PFAS compounds based on Agency for
Toxic Substances and Disease Registry ( ATSDR) Minimal Risk Levels (MRLs) for ingestion exposure which
include perfluorononanoic acid (PFNA) 3.0E-06 mg/kg-day, and perfluorohexane sulfonic acid (PFHxS) 2.0E-05
mg/kg-day. Additionally, an RfD value for HFPO-DA. also known as "Gen-X," was released based on a chronic
oral RfD published by the EPA Office of Water at 3E-06 mg/kg-day. The remedy remains protective at the Site
because the aquifer is a non-potable aquifer and there are no current uses of groundwater.
In December 2022, EPA released a new non-cancer oral RfD of 1.0E-03 mg/kg-day for perfluorobutanoic acid
(PFBA) based on a new IRIS value.
In 2020, PFAS groundwater samples were collected for PFBA. The maximum concentration reported was at MW-
202 at 45.8 ng/L. Since groundwater consumption is not an exposure pathway for the Site (because the aquifer is a
17 "E" means to raise the number that comes after it to a power of 10. For example, 4E-02 equates to 4><10~2, or 5E-05
equates to 5><10~5.
18 https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
19 https://www.epa.gov/ri sk/regional-screening-levels-rsls-generic-tables
20 https://iris.epa.gov/ChemicalLanding/&substance_nmbi=704
36
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non-potable and there are no current uses of groundwater) the data does not show any potential impacts to the
protectiveness of the OU-2 remedy.
2021 Non-cancer Toxicity Value for PFBS
In May 2021, EPA issued an updated non-cancer RfD for perfluorobutanesulfonic acid (PFBS). PFBS has a
chronic oral RfD of 3E-04 mg/kg-day. The remedy remains protective at the Site because the aquifer is a non-
potable aquifer and there are no current uses of groundw ater.
PFAS State Standards
On October 2, 2020, the Commonwealth promulgated Massachusetts Maximum Contaminant Levels (MMCLs)
for drinking water for the sum of six PFAS compounds into the State's Drinking Water Regulations (310 CMR
22.00). The MMCL is 20 ng/L (parts per trillion, ppt) for the sum of six PFAS compounds:
• PFOS
• PFOA
• PFHxS
• PFNA
• PFHpA
• PFDA
In 2020, the Settling Defendants sampled 12 groundwater wells for PFAS. Seven of the wells have total PFAS for
the sum of the six compounds regulated by the state greater than the current state standard (see Table E-4 in
Appendix E). Although there are exceedances of the sum of the six compounds regulated by the Commonwealth,
the remedy remains protective at the Site because the aquifer is a non-potable aquifer and there are no current uses
of groundw ater.
At this time EPA has made no determination of whether these State standards will need to be added as an ARAR
for this Site. How ever, for informational purposes a comparison of PFAS data against state standards is included
along with the comparison to federal MCLs in Appendix E (Table E-4).
Summary of Site PFAS Activities
PFAS groundwater sampling was conducted in 2020 as described above. The remedy remains protective at the
Site because the aquifer is a non-potable aquifer and there are no current uses of groundwater. Because the 2006
OU-2 ROD identified the groundwater as non-potable, the 2006 groundwater cleanup remains protective, and no
additional PFAS groundwater investigations are planned at the Site.
Floodplain
Federal Floodplain Management: Federal regulations at 40 CFR Part 6. Appendix A identified in the 2006 OU-1
ROD were withdrawn. The 2014 ESD, modifying the OU-2 remedy, replaced the 40 CFR Part 6 requirements
with a revised 500-year flood standard required under regulations at 44 CFR Part 9, to address potential
floodplain impacts. The September 2015, 100% Remedial Design Part 1. and September 30, 2016 Remedial
Design Part 2, accounted for these requirements and potential impacts to the 100-year and 500-year floodplain.
For example, the 500-year event flow s and the p re-remedy conditions are similar to the post-remedy conditions
(i.e., Halls Brook Diversion Structure and Storm Water Bypass System), the HBHA Pond Remedy treatment
building and backup generator are constructed above the 500-elevation; etc.
Changes in Toxicity and Other Contaminant Characteristics
Appendix I provides cleanup level/performance standards review. In 2013, the NRWQC for ammonia was
updated to a more stringent level since the 2006 OU-2 ROD to account for the protection of additional sensitive
species to include unionid mussels and gill breathing snails. In 2021, the OU-2 Settling Defendants prepared a
freshwater mussel field investigation plan, which EPA approved. A detailed field investigation took place on June
22, 2021, to determine if freshw ater mussels in the Order of Unionoida (unionid mussels) are present or absent
from the areas of investigation. No unionid mussels or evidence of unionid mussels were identified in the
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investigation areas. Because no evidence of unionid mussels during the investigation, the original 2006 ROD
ammonia cleanup levels remain appropriate.
The 2006 OU-2 ROD changed the OU-1 interim groundwater cleanup levels to groundwater performance
standards at levels protective for non-potable uses based on a site-specific risk assessment for a process water
worker or a car wash scenario. Similarly, the 2006 ROD for OU-2 set soil and sediment cleanup standards for
various areas of OU-2, based on site-specific uses of those areas. The toxicity value evaluation indicates that the
human health risk-based cleanup goals for arsenic remain valid for soil and sediment as oral exposures are driving
the risk for these exposure pathw ays and the oral toxicity values have not changed (Table 1-1) For
benzo(a)pyrene. site cleanup is based on a background concentration, which is not a risk-based value and not
dependent on changes in toxicity values (Table 1-4). As show n in Table 1-4, TCE was the only COC where the
toxicity value became more stringent. The current inhalation reference concentration (RfC) is 20-fold low er than
the value in the 2006 ROD. The groundwater cleanup level (1 ug/L based on the indoor car wash scenario) is
associated with a noncancer hazard index of 0.02 (cancer was the driver for the selection of the cleanup level; see
2006 ROD Table L-l). Therefore, adjusting for the increased toxicity of TCE would result in the groundw ater
performance standard being associated with a noncancer hazard index of 0.4, below the acceptable noncancer
hazard index of 1. Therefore, the changes in toxicity values do not affect the protectiveness of the remedy.
2021 Updated Recommendations on the Use of Chronic or Subchronic Non-cancer Values
In 2021, a memorandum was released from the Office of Land and Emergency Management (OLEM) regarding
the use of subchronic toxicity values rather than the chronic non-cancer 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 non-cancer 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.
• Subchronic inhalation RfC selected for the following chemicals (Chemical Abstracts Service Registry
Number [CASRNJ):
o Acrylic acid (79-10-7)
o 2-Ethoxyethanol (110-80-5)
o Ethyl-chloride (75-00-3)
o 2-Methoxyethanol (109-86-4)
• Subchronic oral RfD selected for the following chemicals (CASRN):
o Allyl alcohol (107-18-6)
o Atrazine (1912-24-9)
o Bromodichloromethane (75-27-4)
o Cadmium (7440-43-9)
o p-Chloroaniline (106-47-8)
o p-Cresol (106-44-5)
o Ethyl acetate (141-78-6)
o Ethylbenzene (100-41-4)
o Ethylene glycol (107-21-1)
o Heptachlor (76-44-8)
o Hexachlorobenzene (118-74-1)
o Hexachlorocyclohexane, gamma (58-89-9)
o 1,2,4,5-Tetrachlorobenzene (95-94-3)
OHHRRAF recommended the chronic inhalation non-cancer value for the follow ing chemicals: ammonia,
chlordane, 1.1 -dichloroethylene. methyl tert-butyl ether, nitromethane and vinyl acetate.
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OHHRRAF recommended the chronic oral non-cancer value for the follow ing chemicals: acrylamide. acrylic
acid. 1.1-biphenyl. cyclohexanone. endosulfan. ethylene glycol monobutyl ether and pentachlorophenol.
Ammonia is a COC at the Site. The remedy remains protective at the Site because the aquifer is a non-potable
aquifer and there are no current uses of groundw ater.
Lead in Soil Cleanups
On January 17. 2024, EPA OLEM released the "Updated Residential Soil Lead Guidance for CERCLA sites and
RCRA Corrective Action Facilities" ("OLEM Memo") which updates the residential soil lead screening level
(RSL) for the CERCLA and RCRA programs. The OLEM Memo recommends that EPA regions use a residential
soil lead RSL of 200 parts per million (ppm). However, the OLEM Memo also provides that it may be appropriate
to use a screening level of 100 ppm if additional sources of lead (e.g., lead water service lines, lead-based paint,
non-attainment areas where the air lead concentrations exceed National Ambient Air Quality Standards
[NAAQS]) are identified that warrant lowering the RSL. The new OLEM guidance was issued due to mounting
scientific evidence of cognitive function decrements and other adverse health effects at blood lead levels below 10
micrograms per deciliter (jig/dL).21 Additionally, children can be exposed to multiple sources of lead other than
contaminated soil/dust at Superfund sites.
Residential properties are defined as any area with high or unrestricted accessibility to sensitive populations (e.g.,
young children) and includes, but is not limited to. properties containing single- and multi-family dwellings,
apartment complexes, vacant lots in residential areas, schools, day-care centers, community centers, playgrounds,
parks, greenw ays. and other recreational areas. As noted in the OLEM Memo, the RSL is not a default cleanup
level and should not be used as such. The RSL is a tool used to identify properties that may warrant additional
evaluation.
It is noted that the updates in the OLEM Memo pertain to residential sites only. For commercial/industrial sites, a
screening level of 1,000 mg/kg is calculated for soil using the adult lead methodology with a target blood lead
level of 5 (.ig/dL and default parameters. This approach is consistent with a risk goal of limiting exposure to
soil/dust such that there is no more than 5% probability of fetal blood lead exceeding 5 (ig/dL for the exposed
population.
The cleanup level for OU-1 soil (600 mg/kg) was established to protect industrial workers. As the paragraph
above sets a lead soil screening level at 1,000 mg/kg for commercial/industrial exposures, the existing cleanup
level remains protective of industrial workers. This update to the Region 1 lead strategy would not impact the
current p reflectiveness of the remedy for areas where residential use is restricted. If land use or site conditions
were to change in the future, lead may need to be re-evaluated.
The OLEM Memo recommends that a review of soil lead cleanups be conducted as part of the FYR process for
residential sites. Therefore, an updated assessment for lead was performed to determine the appropriate RSL for
certain areas of the site where residential use is now allowed under OU-1 ESD 1 and ESD 2. An RSL of 200 ppm
was used for the residential properties permitted under the two ESDs.
An RSL of 200 ppm for soil is consistent with a risk goal to limit exposure to soil lead levels such that a
typical (or hypothetical) child or group of similarly exposed individuals would have an estimated risk of no
more than 5% probability of exceeding a blood lead level of 5 (ig/dL. An RSL of 200 ppm was determined to
be appropriate for the site because no additional sources of lead are identified at or in the vicinity of the Site
(see Lead Screening Checklist in Appendix J).
Land use changes were evaluated for three properties located within OU-1 where, as documented in ESD 1.
individual baseline risk assessments were performed to assess future residential purposes. The evaluations
included the updated default Integrated Exposure Uptake Biokinetic Model for Lead in Children (IEUBK) and
21 USEPA, 2013. Integrated Science Assessment for Lead EPA/600/R-10/075F.
https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=255721
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Adult Lead Methodology (ALM) parameters outlined in the 2017 OLEM memorandum (OLEM Directive
9285.6-56). The land use change for these two properties was documented in ESD 1. Similarly. ESD 2 also
evaluated an area (Lot IC-32 and a portion of IC-28) assuming a residential exposure. The lead exposure
evaluations in the two ESDs concluded that the estimated blood lead levels were determined to be below
consensus values used by EPA to manage lead risks. Toxicity values have not changed since the 2018 and 2023
ESDs were issued, however. EPA reduced the target blood lead level (more stringent) in January 2024. Prior to
2024, the target blood level of 10 (.ig/dL should not be exceeded by 5% of the exposed population. The 2024 new
target blood level is 5 (ig/dL assuming soil ingestion is the only route of exposure to lead, which equates to a
residential screening level of 200 mg/kg. The lead evaluation for the ESD 2 used a screening level of 400 mg/kg
to evaluate lead at the two properties. Therefore, to determine if the lead exposure conclusions in the two ESDs
remain valid in light of the January 2024 Lead Policy, the lead exposure point concentrations used in the
residential risk evaluations were reviewed and compared to the updated 200 mg/kg screening level. For parcels
where the maximum soil lead concentration exceeded the 200 mg/kg screening level, the average concentrations
were evaluated to determine if there were unacceptable lead risks. Table 11 shows that the average lead
concentration is below the residential screening level of 200 mg/kg. which supports that the risk conclusions
presented in the 2018 and 2023 ESDs remain valid and appropriate for residential use.
Table 11: Review of Residential Lead Exposure Evaluation in the 2018 ESD 1 and the 2023 ESD 2
Pared
Soil Interval Evaluated for
Risk
Maximum
(ms/kK)
Average (nig/kg)
120 Commercial
Way3
Surface soil (0-6 inches)
171
Not a COC (<200 mg/kg)
Subsurface soil (0.5 - 6 feet)
460
33
200 Presidential
Wayb
Undisturbed surface oil
(0-6 inches)
80.9
Not a COC (<200 mg/kg)
Disturbed surface soil
(0-6 inches)
84.2
Disturbed deep soil
(2-6 feet)
8.68
Site-wide disturbed soil
(0-6 feet)
84.2
Lot IC-32 and
portion of IC-280
Topsoil (0-6 inches)
468
55
Surface soil
85
(<200 mg/kg)
Subsurface soil
614
90
Natural soil
32
(<200 mg/kg)
Total soil
614
50
Notes:
a) Maximum obtained from Attachment 3 of the 2018 ESD, Tables 4 and 5, R AGS Part D Table 2.1 and
2.2; averages obtained from Table 8, RAGS D Table 3.
b) Maximum obtained from Attachment 4 of the 2018 ESD, RAGS Part D Table 2.1 SGI. Table
2.1SG2A. Table 2.1SG2B and Table 2.1SG2A+B.
c) Maximum obtained from Attachment 3 of the 2023 ESD, R AGS Part D Table 2.1 to Table 2.5
(Tables 6-10); averages obtained from R AGS D Table 3.1, Table 3.2 and Table 3.4 (Table 12, 13 and
15).
For OU-2, lead was a CO PC in two areas of the Site (near HBHA Pond and in the area of the former Mishawum
Lake, where the OU-2 remedy requires institutional controls restricting residential, daycare and school uses on
these properties), with an average lead concentration for a site-specific worker exposure of 1,223 mg/kg as listed
in the 2005 Rl. In addition, the Rl evaluated residential child exposure based on a site-specific time-weighted
exposure point concentration of 140 mg/kg. Because the worker exposure concentration exceeds the industrial
screening value of 1,000 mg/kg. the updated ALM model was run using the site-specific exposure frequency of
150 days/year and the default model assumptions. The model results show the < 5% of children (fetuses of
exposed women) could exceed a target blood lead level of 5 (ig/dL goal is achieved (see Appendix I. Table 1-5).
In addition, the time-weighted exposure point concentration for children is below the site-specific screening level
of 200 mg/kg.
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Changes in Risk Assessment Methods
There have been multiple changes to EPA's risk assessment methodologies since the 2005 risk assessment.
Engineering controls are in place, the groundwater is currently not being used, and institutional controls will
prevent exposures. During the time that institutional controls are not in place, work plans are typically submitted
to EPA for review to establish means and methods for preventing exposures to residual soil, sediment and
groundw ater among other work protocols. Therefore, changes in methodologies do not affect the current
protectiveness of the remedy for the site. Current methodologies were used during evaluations prepared as part of
the 2018 and 2023 OU-1 ESDs.
Changes in Exposure Pathways
Arsenic and Chromium in the 2018 USD 1 and the 2023 USD 2
The 2018 and 2023 ESDs modified the 1986 OU-1 remedy to re-evaluate risks at site parcels that were originally
evaluated under a commercial worker exposure scenario. The 2018 ESD conducted a residential risk evaluation
for two parcels (120 Commerce Way and 200 Presidential Way) and the 2023 ESD evaluated residential risks
associated with one parcel (Lot IC-32 and a portion of Lot IC-28). Both ESDs concluded that the residential risks
and noncancer hazards were within acceptable levels. Toxicity values have not changed for arsenic and chromium
since the 2018 ESD and 2023 ESDs were issued thus, the risk conclusions in the ESDs remain valid for these two
contaminants.
EPA Regional Screening Levels
EPA Regional Screening Levels (SLs) are risk-based concentrations derived by combining exposure information
assumptions with EPA toxicity data. EPA RSLs are updated twice a year. The most up-to-date tables as available
at: https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
Methods for Evaluating Vapor Intrusion
EPA Guidance on Vapor Intrusion
The most current guidance available to evaluate risk from vapor intrusion is the EPA 2015 Vapor Intrusion
Technical Guide. The guidance emphasizes the use of multiple lines of evidence to evaluate the potential for
vapor intrusion. This guidance was considered when assessing the potential for vapor intrusion during the FYR
process. This resource can be found at: https://www.epa.gov/sites/defaultyfiles/2015-Q9/documents/oswer-vapor-
intrusion-technical-guide-final.pdf
EPA VISL Calculator
The EPA online Vapor Intrusion Screening Level (VISL) calculator is a web-based tool 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 Regional Screening Levels for toxicity values and physiocheinical
parameters and is automatically updated during the semi-annual RSL updates. Please see the User's Guide for
further details on how to use the VISL calculator, https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-
level-calculator.
Vapor Intrusion Investigations for the Industri-Plex Superfund Site
In response to an issue identified during the 2019 FYR. the Settling Defendants prepared a Preliminary Vapor
Intrusion Work Plan in April 2021.
In March 2023, EPA provided comments on the Draft Preliminary Vapor Intrusion Work Plan and requested a
revised work plan. No additional vapor intrusion sampling has been conducted at the time of the writing of this
FYR. EPA is awaiting Settling Defendants submission of the Revised Vapor Intrusion Work Plan.
Expected Progress Towards Meeting OU-1 Remedial Objectives and OU-2 RAOs
OU-1
41
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The Remedial Objectives for OU-1 included protection of direct contact to soils/sludges contaminated with
arsenic, lead, and chromium; protection from the contaminated soils, odors and leachate in or emanating from the
East Hide Pile; and protection of the public health and environment from groundwater contamination. The OU-1
remedy has met these Remedial Objectives through the use of permeable caps over soils and sediments
contaminated with arsenic, lead and chromium, an impermeable cap over the East Hide Pile with a gas collection
and treatment system, and institutional controls to protect the covers and restrict the use of contaminated soil and
groundwater. Institutional controls have been established on all the OU-1 properties via either recorded NAULs
or GEREs. and through the municipal road work ordinance and regulations.
OU-2
The OU-2 RAOs and their current status are described by area.
The RAO for the Northern Study Area is to prevent or mitigate exposure to contaminated groundwater.
Institutional controls have not yet been put in place in OU-2. However interim groundwater restrictions were
included in the OU-1 NAULs and GEREs and the municipal road work ordinance and regulations. Institutional
controls for properties outside of OU-1 are in progress and there are no current exposure pathw ays to
groundwater. This RAO will be met once the institutional controls are put in place.
Within the Wells G&H Wetland and CBCA. the RAO is to reduce the current and future potential exposure of
recreational adults and children to arsenic and benzo(a)pyrene in near-shore sediment. The Wells G&H Wetland
and the CBCA near-shore sediment removal and disposal occurred from June to September 2016. This RAO has
been met.
Within the HBHA Wetland and the Wells G&H Wetland, the RAO is to prevent or mitigate the potential exposure
of workers to concentrations of arsenic in deeper (interior) sediment. Institutional controls will be put in place to
restrict access to deeper sediment in the HBHA Wetland and the Wells G&H Wetland. Sediment sampling is
planned for fall 2024, including sediment locations within the Lower South Pond.
Within the Former Mishaw um Lake Bed area, the RAO is to prevent or mitigate the potential future exposure of
workers to arsenic in subsurface soil and to prevent the potential future exposure of children to arsenic in surface
and subsurface soil will be met with the use of institutional controls. They have not yet been put in place.
However, as described in the 2006 OU-2 ROD. the contaminated surface and subsurface soils are mostly under
buildings and bituminous parking lots and streets.
The RAO to prevent or minimize the exposure of benthic invertebrates and aquatic life to contaminants in surface
water is being met at the compliance point of the HBHA Pond. The RAO to reduce the exposure of benthic
invertebrates to levels of arsenic indicative of impairment in HBHA Pond sediment has been met by the August to
October 2015 permeable cap installation to cover soil impacted with arsenic above the ecological cleanup
standard of 273 mg/kg in the northern end of the HBHA Pond.
Alternate habitat has been provided to replace the lost wetland functions and values associated with portions of
the HBHA Pond used as a component of the remedy.
The migration of soluble and particulate arsenic is minimized during storm events to downstream depositional
areas by the sequestration of COCs in the northern portion of the HBHA. The 2023 Annual Report states that
based on the arsenic results at station SW-02-TT. the remedy has minimized, to the extent practicable, the
migration of soluble and particulate arsenic during storm events to dow nstream depositional areas.
QUESTION C: Has any other information come to light that could call into question the protecti veil ess of
the remedy?
The expected impacts of climate change in New England pose increasing risks to contaminated sites. Increases in
air and water temperature, precipitation, flooding, and periods of drought may result in altered fate and transport
pathw ays, exposure assumptions, impaired aquatic habitats, dispersal of contaminants, damage to remediation
42
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related structures and ultimately ineffective remedies. Increased frequency of extreme weather events may cause
damage or releases at sites, impairing remedial efforts where remedies have not been adequately designed to
protect against these risks.
The risks posed by climate change in New England are not expected to alter the protectiveness of the remedy at
the Industri-Plex site because the OU-2 Remedy accounted for potential impacts to the 100-year and 500-year
floodplain and annual inspections have not observed any storm water erosion concerns with the OU-1 and OU-2
remedies.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues and Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): 1
Issue Category: Changed Site Conditions
Issue: During renovations at 21 1 New Boston Street building consistent with the
NAUL, the concrete floor that serves as the OU-1 Remedy Protective Cover
collapsed, due to underlying void spaces associated with the discovery of
undocumented buried drums below the concrete floor. Access to the drums is
restricted due to locked fence and the instability of the building.
Recommendation: Implement solution to properly address the drums and any
contamination they contain or have released, re-establish the protective cover, and
ensure future protectiveness.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
Settling Defendants
EPA
12/31/2024
OU(s): 2
Issue Category: Institutional Controls
Issue: Institutional controls restricting inappropriate land uses and protecting the
remedy components need to be established on the OU-2 properties.
Recommendation: Discussions among EPA. Mass DEP. the Settling Defendants
and the property owners are ongoing. Upon completion of discussions among the
parties, institutional controls should be established.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
Settling Defendants
EPA/State
12/31/2028
43
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OU(s): 1 and 2
Issue Category: Remedy Performance
Issue: Groundwater contamination has been identified above vapor intrusion
screening levels, and animal hide residue/remnants potentially causing migration
of hydrogen sulfide and methane may be a concern with nearby buildings.
Recommendation: Evaluate the potential for vapor intrusion from groundwater
contaminants and animal hide residue/remnants to nearby buildings using
multiple lines of evidence.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
Settling Defendants
EPA
12/31/2025
Other Findings
In addition, the follow ing are findings that were identified during the FYR but do not affect current or future
protectiveness:
• Increasing trends for ammonia were observed in groundwater at some of the monitoring wells (i.e., MW-
007D. MW-209, MW-2 10 and MW-2 11). Increasing trends for arsenic were also observed in
groundwater at some of the monitoring wells (i.e., MW-003D [dissolved only]. MW-006D, MW-209) and
increasing trend of benzene was observed at one monitoring well (i.e., MW-007D). The groundw ater and
surface water monitoring program will continue to monitor trends and remedy performance consistent
with the prior five years of monitoring.
• Prepare letters to OU-1 property owners with covers reminding them of their obligation to annually
inspect protective covers and other restrictions on their property and submit annual reports consistent with
the institutional controls/ recorded NAULs.
• Residential use for a limited 3.42 acres of Class B land within the Site located at Zero New Boston Street
requires modification of an existing IC. The IC-32 NAUL and IC-28 GERE will be amended to allow
residential development (including residential, daycare and school uses) within Class B land at this
property.
44
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VII. P ROT ECTIVEN ESS STATEMENT
I'roliTliM'iii'ss Sliili'ini'iiKs)
Operable Unit:
Protectiveness Determination:
Planned Completion
1
Short-term Protective
Date:
12/31/2025
Protectiveness Statement:
The remedy at OU1 currently protects human health and the environment, as exposure pathways that
could result in unacceptable risks are being controlled. Soils and waste are covered, all remedy
components are operating, and ICs are in place. Access to 211 New Boston Street building where
drums have been discovered under the building is secured with a locked fence, preventing any
potential exposure. Operation and Maintenance activities are in place to ensure that the covers and
associated components of the remedy remain in good condition. Annual inspections must continue to
be conducted to ensure that deficiencies are noted and corrected. However, in order for the remedy to
be protective in the long-term, discovered drums at 21 1 New Boston Street must be properly removed
and disposed off-site and address any contamination they contain or have released and the protective
cover (i.e., concrete floor) re-established. Also, an evaluation of the potential for vapor intrusion from
groundwater contaminants and the potential release of methane and hydrogen sulfide gases from
animal hide residues/remnants will be performed using multiple lines of evidence to assess the vapor
intrusion pathway.
Proli'CliM'iii'ss Sliili'ini'iiMs)
Operable Unit: Protectiveness Determination: Planned Completion
2 Short-term Protective Date:
12/31/2028
Protectiveness Statement:
The remedy at OU2 currently protects human health and the environment, as exposure pathways that
could result in unacceptable risks are being controlled. The water treatment remedy is active and
meeting treatment standards. There is no current use of groundwater and interim groundwater
restrictions established under the OU-1 remedy are in place. Operations and Maintenance activities are
in place to ensure that the components of the remedy remain in good condition. In addition, monitoring
of groundwater and surface water will continue to assess the continued protectiveness of the water
treatment remedy. However, in order for the remedy to be protective in the long-term: institutional
controls will be created and recorded to restrict inappropriate land uses and protect the components of
the remedy; and an evaluation of the potential for vapor intrusion from groundwater contaminants and
the potential release of methane and hydrogen sulfide gases from animal hide residues/remnants will
be performed using multiple lines of evidence to assess the vapor intrusion pathway.
Protectiveness Determination:
Short-term Protective
Protectiveness Statement:
Si lew idc IVoli'cliM'iii'ss Skilcmcnl
45
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The remedies at the Industri-Plex site currently protect human health and the environment, as
exposure pathways that could result in unacceptable risks are being controlled. However, in
order for the remedy to be protective in the long-term: discovered buried drums at 21 1 New Boston
Street must be properly removed and disposed off-site removed and disposed off-site and address any
contamination they contain or have released and the protective cover and the protective cover (i.e.,
concrete floor) re-established, within OU-2 institutional controls will be created and recorded to
restrict inappropriate land uses (including use of groundwater) and protect the components of the
remedy; and an evaluation of the potential for vapor intrusion from groundwater contaminants and
releases of methane and hydrogen sulfide gases from animal hide residues/remnants will be performed
using multiple lines of evidence to assess the vapor intrusion pathway.
VIII. NEXT REVIEW
The next FYR for the Industri-Plex Superfund site is required five years from the completion date of this review.
46
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APPENDIX A - REFERENCE LIST
ATS DR. 2021. Toxicological Profile for Perfluoroalkyls. https://www.atsdr.cdc.gov/toxprofilesAp200.pdf.
de maximis. inc. 2015. Industri-plex Superfund Site. Operable Unit 2, Woburn. Massachusetts. Submission of
Final 100% Remedial Design. Part 1 Report. September 30, 2015.
de maximis, inc. 2016. Industri-plex Superfund Site. Operable Unit 2, Woburn. Massachusetts. Final 100%
Remedial Design. Part 2 Report. September 30, 2016.
de maximis, inc. 2017. Industri-plex Superfund Site. Operable Unit 2, Woburn. Massachusetts. Close-Out Report.
September 22, 2017.
de maximis, inc. 2020. Industri-plex Operable Unit 2 Superfund Site. Remedial Action Progress & Compliance
Report - June 2020.
de maximis, inc. 2021. Industri-plex OU-1 Superfund Site. Woburn. Massachusetts. 2020 Operations and
Maintenance Annual Report. March 30, 2021.
de maximis. inc. 2021. Industri-plex OU2 Superfund Site. Woburn. Massachusetts. Freshwater Mussel Field
Investigation Plan. May 6. 2021.
de maximis. inc. 2021. Industri-plex OU2 Superfund Site. Woburn. MA. Freshwater Mussel Field Investigation
Results. July 9, 2021.
de maximis. inc. 2021. Operation. Maintenance and Monitoring Report. Industri-plex Operable Unit 2 (including
Wells G&H Operable Unit 3) Superfund Site. Woburn. Massachusetts. April 2, 2021.
de maximis. inc. 2021. Responses to EPA Comments on Freshwater Mussel Field Investigation Plan. Industri-
plex Operable Unit 2 Superfund Site. Woburn. MA. January 6. 2021.
de maximis. inc. 2022. 2021 Operations and Maintenance Annual Report. Industri-plex OU-1 Superfund Site.
Woburn. Massachusetts. July 31. 2022.
de maximis. inc. 2022. Operation. Maintenance and Monitoring Report. Industri-plex Operable Unit 2 (including
Wells G&H Operable Unit 3) Superfund Site. Woburn. Massachusetts. March 31. 2022.
de maximis. inc. 2023. 2022 Operations and Maintenance Annual Report. Industri-plex OU-1 Superfund Site.
Woburn. Massachusetts. July 23, 2023.
de maximis. inc. 2023. Operation. Maintenance and Monitoring Report. Industri-plex Operable Unit 2 (including
Wells G&H Operable Unit 3) Superfund Site. Woburn. Massachusetts. September 15, 2023.
EPA. 1986. Superfund Record of Decision. Industri-plex. MA. September 30, 1986.
EPA 1988. Request for One Year Exemption & Additional Funding. Industriplex Site. Woburn. Massachusetts.
Action Memorandum. May 1 1. 1988.
EPA. 1988. CERCLA Compliance with Other Laws Manual: Interim Final (Part 1). EPA/540/G-89/006. August
1988.
EPA. 2005. Draft Final Technical Memorandum. Evaluation of Ammonia and Supplemental Soil Data. Remedial
Investigation/Feasibility Study. Industri-Plex Site. Woburn. Massachusetts. October 2005.
A-l
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EPA 2006. Record of Decision. Industri-plex Superfund Site Operable Unit-2 (and including Wells G&H
Superfund Site Operable Unit-3, Aberjona River Study). City of Wobum. Middlesex County. Massachusetts.
January 2006.
EPA. 2014. Explanation of Significant Differences (ESD). Industri-Plex Superfund Site. Operable Unit 2,
Wobum. Massachusetts. September 11. 2014.
EPA. 2014. Human Health Evaluation Manual. Supplemental Guidance: Update of Standard Default Exposure
Factors Memorandum. OSWER Directive 9200.1-120.
EPA. 2017. Transmittal of Update to the Adult Lead Methodology's Default Baseline Blood Lead Concentration
and Geometric Standard Deviation Parameters Memorandum, May 17. 2017. OLEM Directive 9285.6-56.
EPA. 2018. Explanation of Significant Differences (ESD). Industri-Plex Superfund Site. Wobum. Massachusetts.
June 2018.
EPA. 2018. Vapor Intrusion Screening Level (VISL) Calculator. Office of Land and Emergency Management,
Office of Superfund Remediation and Technology Innovation (OSRTI). May 2018.
https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator.
EPA. 2019. First Five-Year Review Report for Industri-Plex Superfund Site. Wobum. Middlesex County.
Massachusetts. May 23, 2019.
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. DC. 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. DC. October 2021.
EPA. 2023. Second Explanation of Significant Differences (ESD). Industri-plex Superfund Site Operable Unit 1.
Wobum. Massachusetts. December 2023.
EPA. Integrated Risk Information System (IRIS). Available at https://www.epa.gov/iris.
EPA. Provisional Peer-Reviewed Toxicity Values. Available at https://www.epa.gov/pprtv.
EPA. Regional Screening Level Tables. Available at https://www.epa.gov/risk/regional-screening-levels-rsls-
generic-tables.
Geosyntec Consultants. 2021. Preliminary Vapor Intrusion Work Plan. Industri-Plex Superfund Site. Wobum.
MA. April 2021.
Haley & Aldrich. Inc. 2015. Industri-plex Superfund Site. Operable Unit 2, Wobum. Massachusetts. Revised
Close-Out Report Lower South Pond Sediments Adjacent to West Hide Pile. September 18, 2015.
Normandeau Associates. 2022. 2022 Center Falls Dam Fish Passage Counts - Letter Report. December 5, 2022.
A-2
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Tetra Tech Nus, Inc. 2005. Draft Final MSGRP Remedial Investigation Report. Volume 1 of 12, Text, Tables and
Figures. Remedial Investigation/Feasibility Study. Industri-Plex Site. Woburn. Massachusetts. March 2005.
A-3
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APPENDIX B - SITE CHRONOLOGY
Table B-l: Site Chronology
Event
Date
Manufacturers produced chemicals such as sulfuric acid, arsenic,
insecticides and organic chemicals for the local textile, leather and paper
industries at the Site
1853-1931
Manufacturers produced glue from animal hides
1935-1969
A developer purchased most of the property with the intent to develop an
industrial park; excavations uncovered chemical and glue manufacturing
wastes, including decaving animal hides
1968
EPA completed an initial assessment
Mav 1. 1980
EPA began the OU-1 RI/FS
June 1. 1981
EPA proposed the Site to the NPL
December 1982
EPA filial i/cd the Site on the NPL
September 1983
EPA conducted a removal action
My -September 1986
EPA conducted a removal action
May 11. 1988 - June 18-1988
EPA completed the OU-1 RI/FS
EPA selected the OU-1 reincdv in the ROD
September 30, 1986
Settling Defendants began the OU-2 RI
December 8, 1989
EPA began the OU-2 combined RI/FS
May 1990
Site redevelopment began
1990s
Settling Defendants began the OU-1 remedial action
May 18, 1992
Settling Defendants completed the OU-2 RI
2005
EPA completed the OU-2 RI/FS
EPA selected the OU-2 reincdv in the ROD
January 31, 2006
Settling Defendants completed the OU-1 remedial action
September 30, 2008
OU-1 sediment removal in drainage swale south of the East Hide Pile
2011
Institutional controls put in place
2011-ongoing
Settling Defendants began the OU-2 remedial action
August 15, 2014
EPA modified the OU-2 reincdv in an ESD
September 11. 2014
Settling Defendants completed the OU-2 remedial action
September 27, 2017
EPA modified the OU-1 reincdv in an ESD
June 14. 2018
EPA signed the Site's First FYR
May 23, 2019
EPA deleted a portion of the Site (200 Presidential Way)
September 30, 2020
A solar company completed the installation of solar panels on the East
Central Hide Pile and East Hide Pile
2023
EPA modified the OU-1 reincdv in an ESD
December 20, 2023
B-l
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APPENDIX C - PUBLIC NOTICE
2J&TH, 11:03 AM
El* to Review Ctemyps * 14 Maswehweis Suparfund Mm this Yew | US EPA
An sffidal website of the Urfted States gorerament
a
MENU
News Releases: Region 01
.gov/n«w>ra((*saVfMms/contact-is>
EPA to Review Cleanups at 14
Massachusetts Superfund Sites this
Year
February 1,2024
Contact Information
James Anderson (anderson.James.r@epa.gov)
(617) 918-1401
BOSTON (Feb. 1,2024) - The U.S. Environmental Protection Agency (EPA) will conduct
comprehensive reviews of completed cleanup work at 14 National Priorities List (NPL) Superfund
Sites in Massachusetts this year.
Each individual site 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. Once the Five-
Year Review is complete, its findings will be posted to EPA's website in a final report.
"Every step of the process ata Superfund site is critical and reflects a commitment we make with
local communities to be as thorough as possible. Cleaning up hazardous waste sites takes extensive
time and effort, and these Five-Year Reviews allow EPA to ensure our cleanup efforts continue to
protect public health and the environment, while keeping everyone informed and accountable,
especially in those communities that have been overburdened by industrial pollution." said EW New
England Regional Administrator David ttf. Cash. "EPA continues to evaluate these cleanups, with
the overarching mission to protect public health and the environment and ensuring that
Massachusetts communities will continue to be protected,"
In 2024 EPA will conduct Five-Year Reviews at the below listed sites. The included web links provide
detailed information on site status as well as past assessment and cleanup activity.
FIv«-Year Reviews of Superfund sites in Massachusetts to ba completed in 2024:
Nyaraa Chemical Waste Dump, Ashland
hapsi'/wwss.sjpa.gov/new5i«eascs/cpa-review-
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mm, ii:03am
EPA to Review Gfennups at 14 M«sea«hu$ette Supwftini Sites tils Ywr | US ERft
Sutton Brook Disposal Area, Tewksbury
Ind ustri-Ptex, Wobum
Weils G&H, Wobum
W.R. Grace & Co., Inc. (Acton Plant}, Acton
Baird & McGuire, Hotbrook
Hatheway & Patterson, Mansfield & Fox bono
Rose Disposal Pit, Lanes borough
Hocomonco Pond, Westborough
Silresim Chemical Corp., Lowell
South Weymouth Naval Air Station, Weymouth
Naval Weapons Industrial Reserve Plant, Bedford
Flve-Yfear Reviews of Suparfund silts in Mauachusetts to begin in 2024, to be completed in
Fiscal Year 2023:
Blackburn & Union Privileges, Walpole
Norwood PCBs, Norwood
More Information:
The Superfund program, a federal program established by Congress in 1380, investigates and cleans
up the most complex, uncontrolled, or abandoned hazardous waste sites in the country and EPA
endeavors to facilitate activities to return them to productive use, In total, there are 123 Superfund
sites across New England,
1 Superfund and other cleanup sites in New England (pdf)
«http$://ww*apa.gov/5yrter«/ftes/dcx;ument$/2024-02/urts-ssf}-ehari-5Q8.pdf» (91.4 KB)
ERA'S Superfund program ims/tc«tact^s> to ask a question, provide feedback, or report a
problem,
LAST UPDATED ON FEBRUARY 1» 2024
hltp»y/www.ep«oovftwwi»r»l«»»M^l»p«-fgv>wi» c^nup»-14-m«awfru»att»-«up»
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APPENDIX D - SUPPORTING FIGURES
Figure D-l: RI Reaches Studied
FIGURE A-4
Source: Figure A-4 of the 2019 FYR Report.
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Figure D-2: Figure Showing Area A6
/SO
HIDE/
PILE
STREAM CHANNEL WITH
IMPERMEABLE CAP
(NEW BOSTON STREET
DRAIN WAY)
SECONDARY
TREATMENT
PRIMARY
TREATMENT
CELL
STORM
WATER
BY-PASS
HBHA-4: STORMWATER BYPASS AND
SEDIMENT RETENTION WITH PARTIAL
DREDGING AND PROVIDING AN
ALTERNATE HABITAT
GRAPHIC SCALE
SOIL AREA WITH
PERMEABLE CAP
(AREA A6)
NORTHERN
PORTION OF
HBHA POND
LEGEND
SOUTHERN
PORTION OF
HBHA POND
FIGURE J-6
Source: Figure J-6 of the 2005 OU2 ROD.
D-2
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Figure D-3: Monitoring Locations (North Portion of the Site)
.tScatlon IsrbtfB 5fiow>rtr(f
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Figure D-4: Monitoring Locations (South Portion of the Site)
Legend
© Surface Water Men itomg static t
A Sediment Accuiru."a«on Monitoring Location I Active >
A Sediment Sairiplo Locate*: (Proposadi
|| WfessG&H and CBCA Sedimenl Removal Areas
Parcel Boundary
m
Monitoring Locations
South Portion of Site
IndiistH-Plex OU2
Woburn Massachusetts
Project No 3204
Plot Date. 2/6/2020
Arc Operator LDS
Reviewed by JLT
Figure 2-2
nTddms
Source: Figure 2-2 of the Operation, Maintenance & Monitoring 2022 Annual Report.
[SW^4=TYfi
U-r,: I ' I
gwas-Tjj
D-4
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Figure D-5: Monitoring Locations (Mystic Lakes)
Legend
© Surface water Monitoring Station
A Sediment Sample Locator- < Proposed >
Monitoring Locations
Mystic Lakes
Industrl-Ptex OU2
VVcfccrn Massachuaetts
Project No 3204
Plot Date: 2/6/2020
Arc Operator LDS
Reviewed by JLT
Figure 2-3
Vddms
Source: Figure 2-1 of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-5
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Figure D-6: Ammonia Ambient Water Quality Criteria Quotient at SW-02-TT - 30-Day Running Average
Figure 6 Ammonia Ambient Water Quality Criteria (AWQC) Quotient at SW-02 TT
30 Day Running Average
I ndustri-Plex OU2
1 2
10
-J 08
r 06
§
•&
o
O 04
02
00
2/1/22 3/1/22 4/1/22 5/1/22 6/1/22 7/1/22 8/1/22 9/1/22 10/1/22 11/1/22 12/1/22
—- Quotient Criteria 30-Day Rtinning Average Quotient
Calculating NRWQC CCC
The NRvVQC-CCC is depended! on temperature and pH and is calculated as
CCC = + f2-85- 145 x
CalsiiMaa NRWQC-CCC SO-DiiyJWeraae
The NR
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Figure D-7: Ammonia Ambient Water Quality Criteria Quotient at SW-02-TT - Four-Day Running
Average
Figure 7 - Ammonia Ambient Water Quality Criteria (AWQC) Quotient at SW-02-TT
4-Day Running Average
Industrial ex OU2
Calculating NRWQC-CCC
The NRWQC-CCC is dependent on temperature and pH and is calculated as.
ccc = (,.££-*. - n^ss) * *'* t285'145 *
C5!cMlatin,a.Uie_NRWQC-CCC Aveiaas
The NRWQC-CCC 4-Day is averaged over a 4-day period to calculate the 4-day ammonia quotient Q^
_— i^-> l 1
Qm - -/ Q: ~ ~ (0.922 -I-1.126) = -(2.118) = 1.0S9
n 2 2
«
Additional detail is referenced in Exhibit 2 - Calculation Modules in the June 2016 Operation, Maintenance and Monitoring Plan,
Source: Figure 7 of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-7
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Figure D-8: Overburden Groundwater Benzene Concentrations - November 2022
2
" /
\41 • MxMt
Source: Figure 9-ID of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-8
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Figure D-9: Overburden Groundwater Nitrogen Ammonia Concentrations - November 2022
Source: Figure 9-2D of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-9
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Figure D-10: Overburden Groundwater Naphthalene Concentrations - November 2022
Source: Figure 9-3D of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-10
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Figure D-ll: Overburden Groundwater 1,2-Dichloroethylene Concentrations - November 2022
Source: Figure 9-4D of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-ll
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Figure D-12: Overburden Groundwater Trichloroethylene Concentrations - November 2022
Source: Figure 9-5D of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-12
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Figure D-13: Overburden Groundwater Dissolved Arsenic Concentrations - November 2022
Source: Figure 9-6D of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-13
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Figure D-14: Overburden Groundwater Total Arsenic Concentrations - November 2022
Source: Figure 9-7D of the Operation, Maintenance & Monitoring 2022 Annual Report.
D-14
-------
Figure D-15: Time Series Plots for Groundwater (Appendix J of the 2022 Annual Report)
MW-001D
VOCs
Nitrogen, Ammonia
Jan 2018 Jan 2019 Jan 2020 Jnn 2021 Jem 2022 Jan 2023
Sample Date
Jnn 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondeteets displayed as triangles at the reporting Emit. Empty graphs Indicate parameter not sampled during the time period.
MW-002D
VOCs
1> 0-100
Jnn 2013 Jim 3019 Jan 2020 Jim 2021 Jim 2022 J an 2023
Sample Date
Nitrogen, Ammonia
Jon 2018 Jnn 2019 Jan 2020 Jnn 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2016 Jan 2020 Jan 2021 Jar 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondeteets displayed as triangles at the reporting Imtt Empty graphs Indicate parameter not sampled during the time period.
D-15
-------
MW-003D
VOCs
Nitrogen, Ammonia
J:tn 2018 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2
Sample Date
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting limit. Empty gmptis indicate parameter not sampled during the time period.
MW-004D
VOCs
Nitrogen, Ammonia
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting Imlt. Empty graphs indicate parameter not sampled during the time period.
D-16
-------
MW-005D
VOCs
Nitrogen, Ammonia
n 2918 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2023
Sample Date
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting limit. Empty gmptis indicate parameter not sampled during the time period.
MW-006D
VOCs
0.100
0.010
0.001
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nitrogen, Ammonia
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting Unlit. Empty graphs indicate parameter not sampled during the time period.
D-17
-------
MW-007D
VOCs
Nitrogen, Ammonia
i 2- iP J n ' in KCf Jan 'r2\ Ij ! r\U*~
Sample Date
100.00
Jan 2018 Jcto 2019 Jan 2020 Jan 2021 Jaw 20Z
Sample Date
Total Arsenic
m-w4
<-n TV20 jn 20
Sampfe Ddte
Dissolved Arsenic
0010
I.
}
I
®
Jan 2018 Jai* 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondttetts drsptoy#d at triangle* at th® reporting Imii. Empty grapfi* ind^cat* parameter not sampled durirrg the ttm» (Mrtod
D-18
-------
MW-102
VOCs
Nitrogen, Ammonia
J:tn 2018 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2
Sample Date
10.0
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at (tie reporting firciit. Empty grnpiis indicate parameter not sampled during the time period.
MW-103
VOCs
Nitrogen, Ammonia
10.0
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at (tie reporting Imit. Empty graphs indicate parameter not sampled during the time period.
D-19
-------
MW-104S
VOCs
Nitrogen, Ammonia
10.0
Jan 2018 Jan 2019 Jan 2020 Jar 2021 Jan 2022 Jan 2
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 20)9 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at (tie reporting Imit. Empty graphs indicate parameter not sampled during the time period.
MW-106S
VOCs
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2
Sample Date
10.0
Nitrogen, Ammonia
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at the reporting Imit. Empty graphs indicate parameter not sampled during the time period.
D-20
-------
MW-200
VOCs
"S. 0.100
0 010
0,001
-A A- A-A-A-A -A- A- A-A
A \A -Ar- A- A - A -A -A- A- A-
. A- A-A -A
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nitrogen, Ammonia
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 201 a Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at the reporting emit. Empty graphs indicate parameter not sampled during the time period.
MW-201
VOCs
Nitrogen, Ammonia
1> 1.00
Jan 2018 Jan 3019 Jan 2020 Jan 2021 Jar 2022 Jan 2
Sample Date
Jan 2018 J an 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
*
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at the reporting Imit. Empty graphs indicate parameter not sampled during the time period.
D-21
-------
MW-202
VOCs
Nitrogen, Ammonia
Jan 2918 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2023
Sample Date
Jon 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2016 Jan 2030 Jan 2021 Jar 2022 Jan S023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetect? displayed as triangles at the reporting Imit. Empty graphs indicate parameter not sampled during the time period.
MW-203
VOCs
Nitrogen, Ammonia
"a 0.100
0 010
0,001
1.000
A -A A- A-A 4-4A-A-A
A, -A A- A-A A -A- A- A-A
A -A A- A-A A- -A. A- A
•w
0.100
^ i-IUHa .
-------
MW-204
VOCs
Jan 2918 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2023
Sample Date
Nitrogen, Ammonia
Jon 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 201S Jan 2030 Jan 2021 Jar 2022 Jan S023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetect? displayed as triangles at the reporting Imit. Empty graphs indicate parameter not sampled during the time period.
MW-205
VOCs
0.100-
^0.010-
0.001 ^
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nitrogen, Ammonia
i.ooo-
0.010
0.001 -I
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jon 2023
Sample Date
Total Arsenic Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023 Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date Sample Date
Nondetects displayed as triangles at the reporting Imit. Empty graphs indicate parameter not sampled during the time period.
D-23
-------
MW-206
VOCs
Nitrogen, Ammonia
Jan 2018 Jan 2019 Jan 2020 Jan 2021 J nil 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jon 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at the reporting emit. Empty graphs indicate parameter not sampled during the time period.
MW-207
VOCs
Nitrogen, Ammonia
|oo-
1-0.0
Jan 2018 Jan 2019 Jan 2020 Jnn 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at the reporting Imit. Empty graphs indicate parameter not sampled during the time period.
D-24
-------
MW-208
VOCs
Nitrogen, Ammonia
Jan 2018 Jan 2919 Jan 2020 Jan 2321 Jan 2022 Jan 2
Sample Date
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting limit. Empty graphs indicate parameter not sampled during the time period.
MW-209
VOCs
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2W23
Sample Date
Nitrogen, Ammonia
0.100
0.010
0.001
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting Imit. Empty graphs indicate parameter not sampled during the time period.
D-25
-------
MW-210
VOCs
Nitrogen, Ammonia
Jan 2918 Jan 2019 Jan 2020 Jan 2021 Jar 2022 Jan 2023
Sample Date
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting limit. Empty gmptis indicate parameter not sampled during the time period.
MW-211
VOCs
Nitrogen, Ammonia
|>0 0'
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting Unlit. Empty graphs indicate parameter not sampled during the time period.
D-26
-------
MW-212
VOCs
Jan 2018 Jan 2019 Jan 2020 Jan 202* Jan 2022 Jan 2023
Sample Date
Nitrogen, Ammonia
0.100
0.010
0.001
¦ -~ •-
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting limit. Empty gmptis indicate parameter not sampled during the time period.
MW-213
VOCs
Nitrogen, Ammonia
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Jan 2018 Jnn 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Total Arsenic
Dissolved Arsenic
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
1
E
Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 Jan 2023
Sample Date
Nondetects displayed as triangles at die reporting Unlit. Empty graphs indicate parameter not sampled during the time period.
D-27
-------
APPENDIX E - SUPPORTING TABLES
Table E-l: OU-1 and OU-2 Institutional Controls
Media, Engineered
Controls and Areas
That Do Not Support
UIJ/UE Based on
Current Conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC Lot/Tax Map
IC
Objective
Title of IC
Instrument
Implemented and
Date
OU-1
OU-1 - Class B and C
Land
Yes
Yes
IC-41/10-1-2
Protect remedy,
public health and
environment.
GERE
(5/6/09)
httDs://semsDub.eoa.eo
v/src/document/01 /457
950
OU-1 - Class B. C and
D Land
Yes
Yes
IC-23/10-1-9
Protect remedy,
public health and
environment.
IC-23 - NAUL
(4/26/17)
https://semspiib.epa. go
v/src/document/0115 96
263
First Amendment to
2017 NAUL
(3/22/22)
littps://semspiib.epa.go
v/src/document/01/100
020349
OU-1 - Class B. C and
D Land
Yes
Yes
IC-30/10-1-6
Protect remedy,
public health and
environment.
IC-30 - GERE
(4/8/11)
littps://semspub.epa.go
v/src/document/01 /485
966
OU-1 - Class B Land
Yes
Yes
IC-20/10-1-3
Protect public health
and environment.
NAUL
(7/10/18)
littps://semspub.epa.go
v/src/document/01/100
028308
OU-1 - Class C Land
Yes
Yes
IC-7/9-2-7
Protect remedy,
public health and
environment.
NAUL
(12/28/16)
262
OU-1 - Class A, B. C
and D Land
Yes
Yes
IC-22/10-1-11
Protect remedy,
public health and
environment.
NAUL
(4/26/17)
littps://semspub.epa.go
v/src/document/0115 96
263
First Amendment to
2017 NAUL
(3/22/22)
E-l
-------
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 Lot/Tax Map
IC
Objective
Title of IC
Instrument
Implemented and
Date
httDs://semsDub.eoa.eo
v/src/document/01/100
020349
OU-1 - Class A, B. C
and D Land
Yes
Yes
IC-24/10-1-12
Protect remedy,
public health and
environment.
NAUL
(4/26/17)
httDs://semsDub.eoa.eo
v/src/document/0115 96
263
First Amendment to
2017 NAUL
(3/22/22)
httDs://semsDub.eoa.eo
v/src/document/01/100
020349
OU-1 - Class A, B. C
and D Land
Yes
Yes
IC-26 and IC-
28/5-1-1
Protect remedy,
public health and
environment.
IC-28 - GERE
(5/25/16)
https://semspub.epa. go
v/src/document/01/100
025534
IC-28 - Amendment
to GERE
6/13/23
https://semspub.epa.eo
v/src/document/01/100
025256
OU-1 - Class A, C
and D Land
Yes
Yes
IC-45/Commerce
Way (Roadway
Right of Way)
Protect remedy,
public health and
environment.
NAUL
3/18/19
httDs://semspub.epa. go
v/src/document/01/100
012920
OU-1 - Class A, B. C
and D Land
Yes
Yes
IC-46/Commerce
Way (Roadway
Right of Way)
Protect remedy,
public health and
environment.
NAUL
3/18/19
littps://semspub.epa.£o
v/src/document/01/100
012923
OU-1 - Class B. C and
D Land
Yes
Yes
IC-27/5-1-3
Protect remedy,
public health and
environment.
NAUL
3/18/19
httDs://semspub.epa. go
v/src/document/01/100
012918
First Amendment to
2019 NAUL
3/30/22
https ://semspub. epa. go
v/src/document/01/100
020348
E-2
-------
Media, Engineered
ICs Called
for in the
Decision
Documents
Title of IC
Instrument
Implemented and
Date
Controls and Areas
That Do Not Support
IJIJ/UE Based on
Current Conditions
ICs
Needed
Impacted
Parcel(s)
IC Lot/Tax Map
IC
Objective
OU-1 - Class A, C
Yes
Yes
IC-29/
Protect remedy,
NAUL
and D Land
4-7-11
public health and
environment.
3/18/19
httDs://semsDub.eoa.eo
v/src/document/01/100
012919
OU-1 - Class B. C and
Yes
Yes
IC*-17/
Protect remedy,
NAUL
D Land
10-1-8
public health and
environment.
11/26/19
httDs://semsDub.eoa.eo
v/src/document/01/100
012768
OU-1 - Class B and C
Yes
Yes
IC-19/
Protect remedy,
NAUL
Land
10-1-4
public health and
environment.
1/9/20
httDs://semsDub.eoa.eo
v/src/document/01/100
012917
OU-1 - Class B. C and
Yes
Yes
IC-21/
Protect remedy,
NAUL
D Land
10-1-10
public health and
environment.
1/9/20
https://semspub.epa. go
v/src/document/01/100
012924
OU-1 - Class B and C
Yes
Yes
IC-18/
Protect remedy,
NAUL
Land
10-1-5
public health and
environment.
2/13/20
httDs://semspub.epa.eo
v/src/document/01/100
013072
OU-1 - Class B Land
Yes
Yes
IC-32/
9-2-2
Protect public health
and environment.
NAUL
8/26/20
httDs://semspub.epa.eo
v/src/document/01/100
014421
OU-1 - Class B and C
Yes
Yes
IC-5/
Protect remedy,
NAUL
Land
9-2-6-3 and 9-2-6-
4
(formerly 9-2-5)
public health and
environment.
9/30/20
https://semspub.epa. go
v/src/document/01/100
11
OU-1 - Class B and C
Yes
Yes
IC-6/
Protect remedy,
NAUL
Land
9-2-6-1 and
9-2-6-2
(formerly 9-2-6)
public health and
environment.
9/30/20
https://semspub.epa.eo
v/src/document/01/100
11
OU-1 - Class B and C
Yes
Yes
IC-8/
Protect remedy,
NAUL
Land
9-2-8
public health and
environment.
10/1/20
https://semspub.epa.eo
v/src/document/01/100
OU-1 - Class B and C
Yes
Yes
IC-9/
Protect remedy,
NAUL
Land
9-7-3
public health and
environment.
10/1/20
https://semspub.epa.eo
v/src/document/01/100
OU-1 - Class B and C
Yes
Yes
IC-10/
Protect remedy,
NAUL
Land
9-1-19
(formerlv 9-1-5)
public health and
environment.
10/1/20
E-3
-------
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 Lot/Tax Map
IC
Objective
Title of IC
Instrument
Implemented and
Date
httDs://semsDub.eoa.eo
v/src/document/01/100
OU-1 - Class B and C
Land
Yes
Yes
IC-11/
9-1-6
Protect remedy,
public health and
environment.
NAUL
10/1/20
httDs://semsDub.eoa.eo
v/src/document/01/100
OU-1 - Class B and C
Land
Yes
Yes
IC-16/
15-1-11
Protect remedy,
public health and
environment.
NAUL
10/2/20
httDs://semsDub.eoa.eo
v/src/document/01/100
OU-1 - Class B and C
Land
Yes
Yes
IC-12/
9-1-7
Protect remedy,
public health and
environment.
NAUL
10/16/20
https://semspub.epa. go
v/src/document/01/100
'2
OU-1 - Class B and C
Land
Yes
Yes
IC-13/
9-1-8
Protect remedy,
public health and
environment.
NAUL
10/16/20
https://semspub.epa.eo
v/src/document/01/100
'3
OU-1 - Class B and C
Land
Yes
Yes
IC-1/
9-2-1-3 and
9-2-1-4
(formerly 4-7-9)
Protect remedy,
public health and
environment.
NAUL
11/19/20
https://semspub.epa.eo
v/src/document/01/100
a
OU-1 - Class B and C
Land
Yes
Yes
IC-2/
9-2-1-1 and
9-2-1-2
(formerly 9-2-1)
Protect remedy,
public health and
environment.
NAUL
11/19/20
https://semspub.epa. go
v/src/document/01/100
a
OU-1 - Class B and C
Land
Yes
Yes
IC-14/
9-7-4
Protect remedy,
public health and
environment.
NAUL
11/23/20
https://semspub.epa.eo
v/src/document/01/100
•2
OU-1 - Class A, C
and D Land
Yes
Yes
IC-25/
10-1-17
Protect remedy,
public health and
environment.
NAUL
4/2/21
https://semspub.epa.eo
v/src/document/01/100
16
OU-1 - Class C Land
Yes
Yes
IC-3/
9-2-3
Protect remedy,
public health and
environment.
NAUL
5/26/21
https://semspub.epa.eo
v/src/document/01/100
M
OU-1 - Class C Land
Yes
Yes
IC-4/
9-2-4
Protect remedy,
public health and
environment.
NAUL
5/26/21
https://semspub.epa.eo
v/src/document/01/100
;8
E-4
-------
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 Lot/Tax Map
IC
Objective
Title of IC
Instrument
Implemented and
Date
OU-1 - Class B and C
Land
Yes
Yes
IC-31/
10-1-7
Anderson
Regional
Transportation
Center
Protect remedy,
public health and
environment.
NAUL
12/13/21
httDs://semsDub.eoa.eo
v/src/document/01/100
020176
OU-1 - Class A Land
Yes
Yes
IC-34/
5-1-8
Protect public health
and environment.
NAUL
2/1/22
httDs://semsDub.eoa.eo
v/src/document/01/100
020178
OU-1 - Class A Land
Yes
Yes
IC-33/
5-1-9
Protect public health
and environment.
NAUL
2/2/22
httDs://semsDub.eoa.eo
v/src/document/01/100
o:
OU-1 - Class A Land
Yes
Yes
IC-42/
10-1-19
Protect public health
and environment.
NAUL
6/23/22
https://semspub.epa. go
v/src/document/01/100
021968
OU-1 - Class A Land
Yes
Yes
IC-43/
10-1-20
Protect public health
and environment.
NAUL
6/23/22
https://semspub.epa.eo
v/src/document/01/100
021969
OU-1 - Class A, C
and D Land
Yes
Yes
IC-48/
Interstate 93
Interchange
Ramps
Protect remedy,
public health and
environment.
NAUL
8/29/23
https://semspub.epa. go
v/src/document/01/100
026896
OU-1 - Class A Land
Yes
Yes
IC-35/
5-4-3
Protect public health
and environment.
NAUL
8/8/22
https://semspub.epa.eo
v/src/document/01/100
021967
OU-1 - Class A Land
Yes
Yes
IC-37/
5-4-6
Bridge/Culvert
Area
Protect public health
and environment.
NAUL
8/29/23
https://semspub.epa.eo
v/src/document/01/100
026897
OU-1 - Class A Land
Yes
Yes
IC-39/
5-4-5
Protect public health
and environment.
NAUL
8/29/23
https://semspub.epa.eo
v/src/document/01/100
026898
OU-1 -Class B and C
Land
Yes
Yes
IC-15/
31-2-2
Protect public health
and environment.
NAUL
8/31/21
https://semspub.epa.eo
v/src/document/01/100
023880
E-5
-------
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 Lot/Tax Map
IC
Objective
Title of IC
Instrument
Implemented and
Date
OU-1 - Class A Land
Yes
Yes
IC-38/5-4-4
Protect public health
and environment.
NAUL
12/28/2023
httDs://semsDub.eoa.eo
v/work/01/100028044.
ixtr
OU-1 - Class A Land
Yes
Yes
IC-40/
10-1-16
Protect public health
and environment.
NAUL
2/22/2024
httDs://semsDub.eoa.eo
y/src/dociiment/01/100
028439
OU-1 - Class A Land
Yes
Yes
IC-44/
10-1-18
Protect public health
and environment.
NAUL
11/21/2023
httDs://semsDub.eoa.eo
v/src/document/01/100
028124
OU-1 - Roads
Yes
Yes
IC-47/
Roadways
Protect public health
and environment.
Roadway Ordinance
https ://woburnma. gov/
WP-
content/uoloads/2022/
09/Citv-of-Woburn-
Roadwork-
Reeulations.txir
OlJ-2
OU-2 - Category I, 111
and V Land
Yes
Yes
15-1 -4/Lot A
Protect remedy,
public health and
environment.
NAUL
(planned)
OU-2 - Category 11.
Ill and V Land
Yes
Yes
15-1 -4/Lot B
15-1-4/Lot C
Protect remedy,
public health and
environment.
NAUL
(planned)
OU-2 - Category I,
III, IV and V Land
Yes
Yes
15-1-4/Lot D
Protect remedy,
public health and
environment.
NAUL
(planned)
OU-2 - Category II.
Ill and IV Land
Yes
Yes
15-1-20
Protect public health
and environment.
NAUL
(planned)
OU-2 - Category III
Land
Yes
Yes
15-1-10
Protect public health
and environment.
NAUL
(planned)
OU-2 - Category I
Land
Yes
Yes
15-1-3
20-1-3
Protect public health
and environment.
NAUL
(planned)
OU-2 - Category 11
and III Land
Yes
Yes
15-1-2
20-1-23
Protect public health
and environment.
NAUL
(planned)
OU-2 - Category I, II
and III Land
Yes
Yes
20-1-2
Protect public health
and environment.
NAUL
(planned)
OU-2 - Category IV
Land
Yes
Yes
20-1-21
25-18-2
32-1-13
32-1-14
32-1-15
32-1-16
Protect public health
and environment.
NAUL
(planned)
E-6
-------
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 Lot/Tax Map
IC
Objective
Title of IC
Instrument
Implemented and
Date
32-1-17
38-1-6
38-1-7
45-12-23
E-7
-------
Table E-2: Summary of Groundwater Analytical Results, February - November 2022
Ted h
Sum* iiv ' I Tt tiiriit v |i J&mStidR it'
-I 11 a t .'02 V * tnb'f JW
ll -*u TSt PI )l ' Ai j rt
Lim uti.i'i D D.--0 Labiiir >>c IC
OrviirdwR-M
^W-C01D
Vs" I'll'
1,11",' 'I'
"t t , 1' 1 1
CA5 ^S4i!
Pu t M«3
H\, 1 1 1 ¦
V '".11 , 1., 1
11 i'V 1 ¦ M .
W.1 •' | , I i' '
(.•
1 V 11 ' ' "
f'l'l " '
S*a
» .ifna.'n
o cmo «
mil i
. • 'f
i . <1 l|
0 T#1
oif
C 898
" i»i •
j, :::¦
DC- .
0 .T ">*'> 1 1 1
U 74
hj
i1
(f 91*
" VT
VOt
'in.-
1 -
>' ¦*;
11 ,
&» u
i i
r
ti
* Hi .'l". ll- 1
• ! "
i 1
1 1
:";D M
i
l I
Ti HI ... Ii -Ti
1 '
' ;...i
5
1
1 I 1
SO U
1
I
"
'
p .'N *«i ui.^hh
's^'K1-'. 1 ¦. (! . K, i
i;
k,
0 iXi
X
in'
o
V '1
,, .
. M < h' ||. ' ll(, 1 ¦ !. P.. |l |V'
A
- ' i
. .1
' 1
i
¦V '
rs in1 ji'^,
-»{
-I ,
1
¦i 7'f,
" : 1
H v. k\, •-1
lf.11
4 jC
ic :m
i -
V-:J
ID7.'
iL.t.J.T, ...Lb
n in,"
v..
w -A>
| ll"
Source: Table 9 of the 2022 Annual Report
E-8
-------
'I'K'rk ©
• nv i t &i 1 id tt- Aiu t i\ Results
fVbflM ¥ 2\.>2Z Nil ^lllbrl 2Q22
'"sin inrUv ih i sj.ii i hs
In in im-PI- s m ? U1 jlui n HA
Li .ifi-n. Si---,1ih- D 0*T>> Lai* bji'uVi' «C
»V.(XJ30-
MW4W3D
l.'l'S. '
r<\ < 1
UW-tXBD
' V •• i
M.S >1
i r - ' |
.. Ai> Nm i'x i
*-V t,K>f ,S,V O
f.1.
'l-L-rt CI
M'-'-l J.LC-K i.J.
'.Wji-'Luri. _
7/ -Cu._
r v i >. j
r 'V o L'_-' ii,...:
•i
Sv itMiii
Oa^i'2022 1t'5.:5
I'll!,' ' I
OSf'IS-'ajaS 13 20
11-'iaO22M00
H/W2022 14®
I' I "
' ,' . 1 -.
L,_ i' .
L._J . '
L'i".
L—'
L «' - , H 4
-:j 1
1
fj'ti'i ,nr f>| iiiujil)
l'. . i a . r ¦>, i. -
HI
2^
it 3
:r%<
23U
t 'i
,' t-
0
0.178
0
VOCU.I Hi-S
,„-L J J.-vl u- v
i - -Ll-_
t.!,: u
i: l
1 J J
1.0 U
j.
C- J
c
I/IM.
) >» -
m
m
84
m
-ii!
m
rfs 1
'I"! I
.1 1
i.l[ 'I®' il' '1!
'I ,v
2 0 u
2 c u
L : L
.. i j
v ;j
_
J"
Jl
ir .il- i
1 !,
1 1 !
10 U
1
.1
!
1
K :hl P "J'l.1
ft-
....
f! oc
0 'Vi
n -;r<
: ¦>:
do:
Of.
rs.v.
1 m ',»-S 50
'.J I
., i
1 b irih II -
H
.¦ i:1
r
r^'-lfVjfftr-. 1 -r
t, -
.vi •;
¦- i
¦ ¦¦i >;
¦-¦,4
¦" ->
C> If rl 111 ' !>" 1
U, ;¦¦¦'
u' '">"1
i'
I i A '
!r ,
k t Jt '
kfE
-
O.J?
- "
-c
. i:
h 1-"* i i^t- i
5 ;stanoar
Source: Table 9 of the 2022 Annual Report
E-9
-------
Htm r rv t Ti nunJ v tf' •,t > <1 Raeutte
c frn t v Zu22 \hunnh-' Zr,."1
r rri viIt i l'«
If h siii PI s. "31 r v" 1 KI ri HA
?J,tr i >-[-. J5p-' i" ¦Imivl,!
i li 'h1 il i
If ' V I Pft r.i
Graur*dwatf»f
}-* i ' ll >
i St»icard areboki
In , I • ' . i
@ mei iessman trie Repcrtr.g L.
Source: Table 9 of the 2022 Annual Report
-------
Tr ; 9
Suitir si> • t 131 < 4 t? i t l ! Rasufts
c> tin n > Z-'lj; Jt -irrih r 2<'L?
oi nrrijw its- Ri ¦w h»-
l> i I Iff PI » •)! ? 0 .'ISITI I A
i t I'Sjl'-llH- |n,g.l,i
r » 'l.r
u* U* I !>J
i Reduction Psteniaf f
If if fifth •» l~
2.in i ' H ' 1 1 I I J . . 1 •>.'
3 ! l-i I" "1 .•
' . .ii., ,• I 1 • i -r i hi
= - _,.'i .f-o . >A 'y«, i ?. in ji t r ,n lUI* :
fsiil 'I ' I 1 '< || I i ' 1 ! 1 ,,!„•) ,~ , -N ,„q!, i -v < '
!> „il • i if . . |J <> >l I1, ' M' i ' l 1 • a . ' !• I il I"
Source: Table 9 of the 2022 Annual Report
E-l I
-------
TaWeSi
tiM i f >ii i.nni vn«' An.* % t. il Fr! jib
^tm-R-y I02Z 2i£2
isT' i.irrlu iti i £»i>m |i+
I.- I i irl-£|'x 01 ,< V1" i* i'ri
L h.ari''i.i, &.»iiiCiS>-C^"h Lib Saie.uu ID
Ab Ntsi-1,*<-
C.M,u,
K" r-in
3'•
.a —
• i> ,, , j i
L-. >1 ii
r -1
'r~': I
Wi-im
Mv'-.J'-f 'I.'J.
MW-2GC
1 :vhi. ,!
N IrrnT, n.¦, i|ri!>ijiij
-r-
4
4 31? '
'.i'jji}
KO
Mat? (ms, '!<
-4 - '
owm •>
DOOM J-
t> 2tii
« 245
vor.,, „r,
.-i i -i' it
-i,-I , ii
i.i, -ii '. "H.
100 V
8X»fi
i.>
S'.Mt
ii
1.0 u
M y
I
. 1.". ri', |U > 1 J'Ll
I •> •• h».f 'tl,, r >), I
" '¦
T. ipck K- ,
'1
...
' 1 Jl*
raw
"I I 1 l-V t
It J .I I
M H • r | i- i 'IP
Source: Table 9 of the 2022 Annual Report
E-12
-------
Table &
bun"- j]> i f Si a lini-wm^ An? n't c li Results
"•.bri..i"v 1022. Mi.'^mbTr 2^2.
in itinHi'V >h r h*
In i i 'iti o| ^ "ii.? r i*a
-As- Nun S'-it
tff Kit h, (
S<.> uvM
L.-i-atK-ii ai
ipkt D s-nii t'n D?"ii L?l> Sohm t* IC
"'b ^ 1 : ^.
; — -:
"
..
(.V . Ti
L-„ ' "<-i
U (it. 'i.i. Sii«, m !i!»j'l,i
• > i ."-i ,
- 1'
:;-
xv
1.: -iijir
aU . .IS ¦ > 1
44
OMI I 1 36
. W
' !
(10987
95
3,43
' '"U!
.-r 1 '-"jet IF'C
i:~-i. -j
1 - " I
1 .
1 J .1
! i.i U
.} !.i
¦; :,J
-
"1 K'l 1.
!
_l» " s
'1 u
, • 1
s.ao u
o.c-o u
0.50 O
Ml ll'llll 1
. 1-_" ~
: | _ i
20 U
_ i 1
2.0 u
2.0 U
|1 IMV) 1i -h-
- 1
*
1
1 I I
i '..i ¦,»
v;
'¦ til P,| HI |i '1 f-
s,
|i i ' 1.
' ¦ \
-25&J0
,'.i
-S6.OT
h is •« ti J' ' i
' " '
Uif J J. -¦
v F>r
~
"
s Stnoarcr are bow
IHI tl ] I | v- I
is the rwoiirg ummm w
reeled ai a level
-------
Tanle 0
bumr ai> i f Gi i.miiKtTm' ft i il Rasalts
?eb!Lj..» IU22 Nii.i>&nl«i 2iiZ2
r-r dw i1- ^n-Jt*-
If 1 (Jdi-B| a ni 7 v" Mu fA
1...;!;: cjaTOHf+s ¦¦ t.' ftimnow Ui-. ts ,:>,?n)„ i:jm «*„¦¦
N4m- U
&> U! 1
Pr> (iil'F o M «»
SU ,C W P 'i Kii-^r.
" M S It > VI
O ' 1-1 RU-.liu '~-li IV n
r,?f
....
IC-'.o
oca
1' i 1
7fl 7£l
if- if mm « • i
11 T 1 i t .
. I"
'if
jV. i ^..F
>1 ¦
' J
1
1 > . '
Source: Table 9 of the 2022 Annual Report
E-14
-------
T»-ti|.!r S>
^nmnji> i F Gi iu ufAWf-An? jt •! RasuMs
iVforLa-* Z022 MiNemfcrr£CC2
til> -i 1 i Ms
In J.i iri Ph ill? > i )d
G'-'urt-Jvoii i
Pwfomtri e*
¦>!,'<•«•! rri
Locafiori, Saf
¦yh- D h> 4 •• D f L-ih Sflrrflio ID
Plif7
n , -iti
W!- ¦¦¦'
Vi-.i . I >
;,j . i
Mili'i.inr Spfi nMniyii)
r*
- :«i
'OF
i ae
»;s
t ^
424
?^i"te||r 1? m. ti s
—
ArWIVf: i f ;V.ftC.
s.t - ¦ .
MP
1 • 1
i . ¦ i I
11 i* | 0 253
V 5^?
it w
H i
,4
M: J '
,A\
Ml 1-
"¦> i-n "j 223
-
cssr
0 563
VOfsi ili'A
:-l :i
2
[ Z, L
i; l
-
_
-
J> .!.•! !l
¦14,
4
> . | 1 •<" l
i. .» • L
"U I'tliJl'. "1'.'
\ - <•" !-
:. i
....
-
ir 'll-rr-ti'rll-
i i
Pckj (*/r in..'s.-F •
:iv, i'1 > i it". "4' -1
r.'
i" :c :
x
O.QQ
0- LC
• ;•
3 "C
i 1 v. |, -i.i ;ji, • - I, i,,'
V b
• - -i I * <
t ¦ >
> <
-§©.20
-"SIM-
^ ' i !
| i' ltil l> r
tt
r
- a
r -
fff " " 1 |r*3r.-«i | ' -'|
? ' "
j r> -
uTi
I » ii. i
7,
h If .t 11 1 1.',' .
' ' '
" 'i
>" "
11 l jl. ;»
:ipz
1
_
1 ~ :
1
Mil, W i
" Imitates flats no* cmsrteii
J ,*( - ¦ H » i f -i «.'! -!¦- <¦- > i* -3tar>o*
-------
Table E-3: Mann-Kendall Analysis Results - Groundwater COCs
Table 10
Mann Kendall Analysis Results - Groundwater
October 2017 - December 2022
Groundwater Results
Industri-Plex OU2, Woburn, MA
Mann-Kendall Trend Analysis Results October 2017 to December 2022
Nitrogen,
Ammonia
Arsenic
(Total)
Arsenic
(Dissolved)
1,2-Dichloroethane
Benzene
Naphthalene
Trichloroethene
MW-001D
DEC [211
>50% ND [211
>SO% MD [21]
100%ND[21]
100% ND [211
100% ND [21]
>50% ND [21]
MW-002D
DtC (21]
MS |21]
NS |21]
100% ND [21]
>50% ND [21]
100% ND [21]
100% ND [21]
MW-003D
MS 120]
MS [20]
INC [20]
100% ND [20]
NS 120]
100% ND |20]
>50% ND [20]
MW-004D
>50% ND [21]
MS [21j
NS [21]
100% ND [21]
>50% ND [21]
100% ND [21]
100% ND [21]
MW-005D
MS (21)
>50% ND [21]
>50% MD [21]
100% ND [21]
100% ND [21]
100% ND [21]
100% ND [21]
MW-006D
MS 121]
INC [21]
INC [21]
100% ND [21]
100% ND [21]
100% ND [21]
>50% ND [21]
MW-007D
INC (21]
MS [21]
NS [21]
100% ND [21]
IMC [21]
>50% ND [21]
100% ND [21]
MW-007S
NA [1]
NA [0]
NA [0]
NA [1]
NA [11
NA [1]
NA [1]
MW-102
NA (0]
NA [0]
NA [0)
100% ND [11]
>50% ND [11]
>50% ND [11]
>50% ND [11]
MW-103
NA [0]
NA [0]
NA [0]
100% N Dill]
>50% ND [11]
100% ND [11]
>50% ND [11]
MW-104S
NA [0]
NA [0]
NA [0]
100% ND [10]
NS [10]
>50% ND [10]
100% ND [10]
MW-10GS
NA (0]
NA[0]
NA [0]
100% ND [10]
NS [10]
100% ND [10]
100% ND [10]
MW-200
NS 111]
>50% MD [11]
>50% MD [11]
100% ND [11]
>50% ND [11]
100% ND [11]
100% ND [11]
MW-201
NS [11]
MS 111]
NS [11]
100% ND [11]
>50% ND [11]
>50% ND [11]
100% ND [11]
MW-202
NS [11]
MS [11]
NS [11]
100% ND [11]
DEC [11]
100% ND [11]
>50% ND [11]
MW-203
NS [11]
MS |10]
NS [9]
100% ND [10]
>50% ND [10]
100% ND [10]
100% ND [10]
MW-204
NS [11]
MS 111]
NS [11]
100% ND [11]
100% ND [11]
100% ND [11]
100% ND [11]
MW-205
NS [11]
MS [11]
NS [11]
NA [0]
NA [0]
NA [0]
NA [0]
MW-206
NS [11]
>50% MD [11]
100% MD [11]
NA [0]
NA [0]
NA [0]
NA [0]
MW-207
NA [0]
>50% ND [11]
>50% MD 111]
NA [0]
NA [0]
NA [0]
NA [0]
MW-208
NS [11]
MS [11]
NS [11]
100% ND [9]
NS[9]
100% MD [9]
100% ND [9]
MW-209
INC [11]
INC [11]
INC [11]
NA [0)
NA [0]
NA [0]
NA [0]
MW-210
INC [21]
MS [21]
NS [21]
100% ND [21]
100% ND [21]
100% ND [21]
100% ND [21]
MW-211
INC [9]
MS |7]
>50% ND 17]
NA 10]
NA [0]
NA [0]
NA [0]
MW-212
NS [11]
MS [11]
NS [11]
NA [0]
NA[0]
NA [0]
NA [0]
MW-213
DEC [111
MS [11]
NS [11]
NA [0]
NA [0]
NA [0]
NA [0]
Notes:
NC = Increasing Trend
DFC = Decreasing Trend
NS = Nlo Significant Trend
VIA = Not applicable due xo insufficient data
100% N D = All samples were non-detect. Trend not calculated.
> 50% ND = More than 50% of the samples were non-detect. Trend not calculated.
ftfl = Number of samples evaluated .
Source: Table 10 of the 2022 Annual Report
E-16
-------
Table E-4: Summary of PFAS in Groundwater
T«U»S
3 j mmary or PFAS
June 2020
Groundwater Reculta
Induct rt-Ptox QU2, Woburn. MA
PFAS Standard*
Loostlofi, Sample ID, Sample Dale, Lio
a
I
MMHM10
MMHH2D
MW-007D
MW-102
WA-1IWS
MW-200
MW-201
CAS Number
MoiDLr
HCS.
CP*
HQ.
WW-001D-061520
MA-003D-06 *52
0
MW-0O7D-061620
WA-102-051S20
MAM0iS-061S2E
WA-200-061S20
MW-201-061720
D5.,16.'2Q20 11DS
L20254Q2-09
06'1&'2020 09OC
L2C25±02-D5
06.16.2020 10:00
L2025402-06
06'180020 09:30
12025854-05
0&'1&'2020 10:00
L2025S64-09
06.16-2020 UQS
-2025402-'2
3i •- 222C IE -IC
L2G25402- IS
PFAS (noiTl
2-IN-Mrthylp*rrVj3rccctanesiifD'nrr«3€; acett acd iNMeFOSAA;
2355-31-9
1.78 II
1-75
o
1.96
If
1.75
u
1-75
U
1.32
U
1.95
0
Gtydne, N^diy!-N-IiheptadecBi\jjraocty1>si*fcjrr/l]-1 N-EE=Q£AA)
2891-50-6
1.78
li
1.76
u
1.96
U
1.75
u
1.76
u
162
u
1.95
y
375-73-5
2.95
1 29
J
2.32
4.42
3.65
1.09
J
2.35
FefljorDOi^rc Acid (PFBAJ
375-22-4
11.1
13.4
10-1
16.6
12.B
644
8.71
=erruQTDcleanesu?anc add (PFDS>
335-77-3
1.79
U
1.75
u
1-96
u
1.75
u
1.75
u
162
U
1.95
y
Per*i*r«todecanose AcB i p=Oqa;i
307-55-1
1.78
u
1.76
u
1.96
u
1-75
u
1.75
u
1.52
1.95
y
=er'uerDhsiK3rec .fene Add ;PFH>s;i
375-92-3
1.78
u
1.76
u
1.96
u
1.75
u
1.75
u
1.82
u
1.95
y
=errLcroOeEroc Add iPFHiA:
3C 7-24-4
15.5
3.63
5.16
4.23
3.02
162
3.16
Fertuoranoflanesiifortc add ,'P=NS;i
60255-12-1
1.78
u
1.76
u
1-96
u
1.75
u
1.75
u
152
u
1.95
y
=erruorDorarefJ*or^Tide iPFOSA)
754-91-5
178
u
1.75
u
1-96
u
1.75
u
1.75
u
1 52
u
1.95
y
Per*jjorcottare: j'coc Add ;PFPeSj
2705-51-4
0.492
J
1.76
u
0.66
J
0.691
J
0>i3&
J
0.254
J
1.95
y
=er'Lisca,T! sJfonate .5:2
35108-34-4
1.78
u
1.76
u
1.96
u
1.75
u
1.75
u
1.32
U
1.95
y
Sodtjn 1H1H,2R2H-oaTlijcro^iaiie5Ufefla:e (4:2)
757134-72-4
1.78
u
1.76
u
1.96
u
1.75
u
1.75
y
162
U
1.85
y
Sotikm 1H1H2H.2H-DerfUcrecctane lurfcnax €:2j
27619-57-2
1.78
u
4.53
1-96
u
1Q5
1-75
u
1-82
u
1.95
y
ser*uorodeEanoic Acid (PFDAI
Fer'uorDhepftsroc Acid 'iPFHsA)
335-76-2
375-35-9
0.902
tt.1
J
1.76
2.88
u
1 96
4.37
u
1.75
3,56
u
1-75
1.84
y
1-32
1-43
J
1.95
2.57
y
=er,u3nshe-.eretJ\»-fc Acd iPFHcs
355-46-4
ID
2.7B
2.55
2,53
1.36
J
0.8
j
2.C4
0.685
j
=er'lLj + i.PFSS conc'2CCC ngfl.) + IPFNA oondlD n&Vi + ;P=H*S cone1 in r©*_j.
Source: Table 8 of the June 2020 Remedial Action Progress & Compliance Report
E-17
-------
TlMtS
3 ummao' or PFA3
June 2020
Groundwater Recultc
hdL'Str-P»>: OU2, Wotnxn. MA
PFAS Standardc
Location Sarrpie C, Sample Date, Lab &a?iple ID
M'A-202
MkV-232
MW-204
MkV-2G5
MW-23S
MW-213
CAS Nurrt-sr
Vhua CEP
WTL
MCL
WA-222-0S172D
WW-222D-D61720
MW-2C4-D51620
MW-2E5<»51€2C
M kV- 2DS-061720
MW-213-05162E
06''17.'2020 1 3:15
06'17.'202E 13:20
C6'15'202G 1025
0&,16'2020 11:00
06.-17.2020 10:05
05'15'2020 13:15
uxnsafrt-o'i
L2025564-02
L2D25402-07
L2025^02-03
L20254C2-17
L2025402-1D
FFM fnOiTI
2-JN-M ethylceTVjcfoc-rtanesuftananldo] acetic acd (PMeFQSAA.;
2355-31-9
1.52
U
1.78
U
1.53
U
1.5
U
17.5
u
1.75
U
Glycne, N-etfvHN-D reptadecafLCOoctyitJ^tfy]- N-EtFOSAA.;
2SS1-5&-5
1.32
u
1.7B
u
1.53
u
1.3
U
17.5
u
1.79
U
=er*koraOUEaret J*cr»c Add !FFB5j
375-73-5
J
I 4
J
1.53
u
129 J
1-.5
u
129
J
Fer'uorooir/rc Ada i;P=SA;
17S-22-±
456
452
167
3.87
17.5
u
3.71
=erryorodecarvesufcnc add iFFCS;
33S-77-3
1.32
u
1.75
u
1.53
u
1.3
U
17.5
u
t.75
u
=er*iicrcd>dtcanc-c Acid (PFDoA)
307-55-1
1.32
u
1.7E
u
1.53
y
1.3 U
17.5
u
1.79
u
Fer'Sjeroteptaresufortc Add ;PFffcS)
375-92-5
1.32
u
1.78
u
1.53
u
1.3
U
17.5
u
1.79
u
Fer'iuonAe^Qroe Add iPFHlAi
307-24-i
3.04
323
558
3€€
11.5
J
4.OS
Fer'iciTroranesiffanse acsd ;P=MS.i
68255-12-1
1.32
u
1.78
u
1.53
u
1.3 U
17.5
u
1.79
u
PefUroocteneHCOnorrt «IFFQSA)
754-91-5
1.32
u
1.78
u
1.53
u
1.3
U
17.5
u
1.79
u
PenutrapertaresLffOrfc Add PFPeS)
27D5-5S-4
1.32
u
1.78
u
1.53
u
1.3
U
17.5
u
1.79
u
Peffconapeftanofc .AcW \PFBeA)
2706-90-3
6.64
3.05
8.63
4.03
42.9
4.6
=er*tiOrotetradecanclc Add iFFTreAi
375-05^7
1.32
u
1.7B
u
1.53
u
1.3
U
17.5
u
1.79
u
=err«3xDC Acid '.'PFUrA;
2053-54-6
1.32
u
1.78
u
1.53
u
!.S
U
17.5
u
1.79
u
Socfcin 1H, 1K2H.2H-perfixrcOecaTe surtonate 3:2
35106-34-4
1.32
u
1.78
u
1.53
u
1.3
U
17.5
u
1.79
u
Sodfcjri 1K1H2KZH-Derffjcrone*ane jufcnar.e i4:2)
757124-72-4
1.32
u
1.78
u
1.53
u
1.3
U
17.5
u
1.79
y
Stxttun 1H1H2K>H>em>jGTOcctaw5UTcfia« €:2j
27615-97-2
1.32
u
4.95
1.53
u
1.3
U
17.5
u
1.79
y
Fefucrcdecanoc Add A;i
375-65-9
2.68
2.55
2.59
2.35
741
J
3.58
=er*ucr€ftea2r«J^Dric ACd iPFHkSi
355-46-4
1D
1.52
J
2.53
0.456
J
1.B
u
17.5
u i
3.12
^er*wror»narK4c .Acd iPFTNA'
375-95-1
M
1.03
J
1.46
if
1.53
u
1.39
1
17.5
u
0.532
j
=erriu
-------
Table E-5: Summary of Surface Water Data from 2020 at Compliance Point SW-02-TT
Tail!* I
Ufi '< ill I1-, RT II .1. mi ' in 1 M.Htfli n t.)
>i*ii! . ii\ I i r-j b m N H i i' M tti * U, <,$>$> t! P*. sutl®
Inr'sistn f i»> fir* MrH itt- Op*r>ht* I Irit ^
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FM J
"RMID-OSBiS
OW?/2C^C 13 45
oxzwzox 1210
DSC&2020 12:25
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mmmm %im
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mmrmisj m 4€
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1
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....
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r *
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it r
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7
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l"r-V " J.-..'. I.I -n
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tl-MP
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- ! 1
7.9$
7 M
! -t 4
|
, M .
1 fa >:¦. -¦aiwdt as 1 - 1 ilr» - 1i - -f r 11 > -r I e
Source: Table 1 of the 2020 Annual Report
E-19
-------
I |:
L'|.., th n IV i I (»irn % i! Mi i Ian
Sunrn..r. J ucrsj-Tuni .Vat*. ,n. ni> li„ jl ht suits
mrr =vdf pin. ';07.S
01A37.G02Q tO 'ID
Cd 3/2020 Q'g. 35
SW02TD-011320
•
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...
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0.831
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0.909 U
om
o.ow
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1 i
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J i .ul -r .*> I"y. i'v-1 - V
1 1-' 11 i!-1
....
V0,8
tms
?: *
216.fi
1.::' c
l«5
TIMS
...
•.'1 .11
0.4
_> i
MS
,
t, L-.i
1194
Source: Table 1 of the 2020 Annual Report
E-20
-------
"IVbk; 1;
J|i > um,..uni J »or-j 1 ynri &uij.u vvs^tk.j A jivlkd! h..suits
rn"»«ti i p!»« Sirwr-nn-i Sit* Op«nrl* Jint ,2
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I
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O.. « >"i ' l?,1
Location SaniploiQ. SamatoDal*, LabSamplw!D
_____ „
SW-LS4 T
SVWXNT?'
-vso.n-t _":_v
TT h
LJl J ' I- -
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L_ a. -l
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„ »•' ' | i
i
...
I
Fi. Id \
.«• >• ,-M- [il'> r 1
' 111 V "i I'l 11." N h'"!;- illl 1 'I i-
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f 40
! ,
o°o??
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i
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¦ i".
14t?7 I 17M3
:¦>/, :>¦¦?¦
6.31 13.17
Source: Table 1 of the 2020 Annual Report
E-21
-------
¦41
I j< >!i i !V. ii|
Si«si. i.il< J «ur .i-fuiit isuli. ' s« - r. r it .'•IK.sote
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3 N*/l » Bm Pmmtmm ?wt am to tttiutprnsstf
" i t» « I! 1 1 ' M ' 1 < *
5. J = Estimate: value AraM»detected at alevel itiR!_iar
~ i ii » - .i ¦*> V-tf ^ «i ' L t 't i " J.-»i - «wf
~I , I 1)1 if.' . - «
" m - r-t. r~!, *• I'-bd^-i I 1
¦! , I .1 I '~ . (I M |I I <• I I
§. tU * Artaiyte no! fjefected afewe 8tb reocrti?>g limst SsWrated value
In 1 . . (sd , lh. « ii r , ~« j i i i *- ~ >
Source: Table 1 of the 2020 Annual Report
E-22
-------
!i !¦
Cl<> i ilnns IV ii t mi. -r J Mr iM ri u
Sunn pr, .f „L.ro-T«Tnt Surf t o "-"tin'4 h. Ik ii
n« i tn pi> • c n*r urii CpfrV'U* un * I
h i' un Mr <¦ ;u * f
Source: Table 1 of the 2020 Annual Report
E-23
-------
"IVbk; 1;
J|i > um,..uni J »or-j 1 ynri &uij.u vvs^tk.j A jivlkd! h..suits
rn"»«ti i p!»« Sirwr-nn-i Sit* Op«nrl* Jint ,2
WiNih M c- - ii
Li.r.itii.n SaiivMD !•»t
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I' 1 1 ',f i f In M if t , i •> ' .
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Source: Table 1 of the 2020 Annual Report
E-24
-------
IJt-.iX.fr t.
( >{iii ill if I" i il nu ti > fdi tal ii in
5>uni..i.K. J ,U 3 1 tint kurU-.j >.2l~. mi.jMi Ikj
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Source: Table 1 of the 2020 Annual Report
E-25
-------
Optsr attwis, Mislntanwnca .nwi Monitoring
Surnir.ary of Long-Term Surface Water Analytical Results
tm'H'ti i-piw. S. m Itfli"1 J-om !•» t pi- ll
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U = Arralyte noJ
-------
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ln<-u-fri fi». Sir- 5rt* Ur ! 2
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Pte
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¦! , I t| I '~ . (I M |i I <• I I
§. tU * Artaiyte no! fjefected afewe 8tb reocrti?>g lims SsWrated value
In 1 . . (sd , lh. « ii r , ~« j i i i *- ~ >
Source: Table 1 of the 2020 Annual Report
E-27
-------
:* f
Uji ' <0 n IV 11 (Hi n f 11si£>l ri t j
5urrirr„ c.t ^rv-rwrni 5>u?J..e _?«» A.a!» .twi Results
n. tj-fri pl>«« *ui i- tin 1 Sit yp 'i Jm 2
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i r> ~z< <
12033106-02
N'l' i ."it Sj'». iMt 11n1 <• i' -* J*..* .
r, i.H-.!, ; -
VOC16«, Ligi'iJ
FkJ P tii-i
it i l.'i" 1
.1 ||. c P. i', - r ' I1 > " . r,h t
, • «. ,1 j i 1
.. .k l|.ii I ir'i , „ . ]
"i' m * h J
iv.
1 . Ihlil > , >!" 1 I' ' 1' ! 1
' 1 i j. - t f >< t *\>
1 ,1 I u| t . I <» ~ i 1. ' . HI, . i Hit's
1 i Hl> l>! 1 Vi '1 > ! 1 ' i, j ¦
> . I 1 i II ~ J * ' ' If . < 1 1 1 I i l >'
> i r tin ,i x' u . 1
1+ U 1 < ( 'Ml > II
- 4| . , | | .1 1 Ij , ( |!
i 1 > - -i:!,-'- r f1 "»v-tr-< i t-*|. r i ¦+ . i i ~ - '"1 r »
nwM reliability.
.:s 1."-.
L:
1 i ! 1 >
iMt «»*
24 2 25.99
i "i,
7 ftc,
'.-1 r
¦ ¦
—
."! ji; L;
....
....
i i . II. - fi
Source: Table 1 of the 2020 Annual Report
E-28
-------
Optsr attwis, Mislntanwnca .nwi Monitoring
Surnir.ary of Long-Term Surface Water Analytical Results
tm'H'ti i-piw. S11 T'-i :& ¦
I u. 'I >V< '
N 1r ji-ti 5& >•' m- '(nt il -?< r.'u i
HpHimss)
i r -• i » i i -1. 1 * im >* i i i ¦ ^
< ji u. it'.J.. jj> . t! J. i:_. 1 u l . _ t ic ,v >u j „n
- Esiimatetf vaiufc fir-.sgyt® f»tec« al a man- it® Rms\ir® Lmii^
h "« t! i . Jt •> . !« If . J. f i ( s I'll. I
- h
-I 'N I "" IL. b! ! I
l-~M M <1 I - lt<> S „„ * Ml
U = Arralyte not
-------
Lji ill i'v- EV.1I ( ir j M v
Sif-i! iiN 1 „f?ru-T(.Tm 5»' n„g vV ^ f AnM? -i! F-'n
.n> M-tri pl«» Str^rMrwl Op* Un>? 2
VVoiiUl rL Massti-cJUnswuts
Syrfac«Walw
SW-Q2-TT
'"awff^MSe""
mmmn-M
L203S207-02
SW-02-TI
'^S^£2T-1691~W^
Wt?aQ2C 3.20
L2C?3S01SM32
SW02TT -0S2120
8/21/202010:15
L233S53542
Location. SamplsiD. $»mpi» Date, tab Sampia ID
&M/2G2& 9:^5
12040408-02
' s"mzu-mmm
2®mom 13:45
L204CBB^02
SVV-02-' 1'
""a^02T^-tC0220
1«2ffiD2Qa.t5
L204'3$6-O2
SW-02-""T
'"S^£ff-T®520
t®&282aa25
L204223@-0l
^£^®2TI-10£B2l "
f&l¥202»S.2G
L 204 330 3-02
SW-G2-'n
" SWQ27T - 1C ^220 '
10/12*2020 ^30
12043577-32
NBrageri Specie®
Nitrogen. Amrr.O'-iie
Nitrogen Nitrate as ncxj
7664-41-7
W?8?-6^S_N03 !
2.72
2SS
Metols. (iTifJl)
A-w»e iTcta)
ArS€n»C i.DiWOfcretf)
iron |I-3lal)
¦mma,
74COS-2
T439119.6
9.16
o.»
VOC« (t^T)
felK.fig
Fkfki Pat amatars
OissoBwsl Ctey@®n
OxWatian Rete® PttenM ittV J
pH,'pHuolttj
Soeafic Conductance i umnosto'j
T«mpiMid«aC)
Tur&sMyinlui
DO
ORP
PH
tew
IURB
S 8?
206. t-
€.88
9.0?
t30 3
i i .1. (
1038.5
19.21
8.86
12Q0.S
15.79
15,32
1097
22»1.3-
1367. t
17-5S
\72A
1311.1
2%m
13.59
B.4S
m.i
7.m
1351.3
17.22
11 ?1
1368.1
2: 98
1S06.8
14.8
IJ.K
. Ail date is validated exoef
i, - t i , . . .
N-Vt « Fekt^a^-iWer -x
r kti
th& Surnr.
equips
if acted atw*
H: , In
Source: Table 1 of the 2020 Annual Report
E-30
-------
Table I
! rvtrx ¦, si' < MiiiwIi in
i>unin. Jn-wt'ririii Sn-* Op^nhN* Urn..
•AtnWl'1 Mil1- n 'it
J C AS Niirifcot
S,l f «f VYif.,i
fV>,in. n Pi m > m
ri S.miii IHD S*ki.-I*0.i1v, L.V San^iklC j
-;"t."n't::
r-——11 •'i,ti'¦' ii—
i ¦ j.i j1
1 i
L J '4> i.
SW-02-"-*
__J- -4- „
illilji
Nrii i •<» 5r¦»' in- unn'U ]
•lie V * -( i'i ' i'.J " 1 '1 *
•i.> n-i ;<,.,rt«' i ¦ ' i
IY> I >N nini'l'i j
M.'f il.'h J > >1 M f
'^Lsi>| l| ]
ft,', |
ry- • v i'1'j- ] r
I't-Ii -M« 1 -:,w M ' | < 'i.f-
i- , 1 (|-t=S'*. ? |.J I 1 -II j
» i t.-< il. . i 'i-., 1 1 M-
«
1 U
' 0! 1
——- ——j— —
I ,tAi*
' "
| *
M
¦r:.) ¦"! :i
7 If
1 •
X J 308
!: i
II i
ir ¦ '1
„ Ii
......
;12!
i ,....
I ^
i i
5. J - EsSrriabssc- value. Araiyie detected at a isvef testf» tie Raportir® Unit (> arscf
n ¦' fan . - .<> <» -i I' !i » • < 11 - i ^ t 3, -.i « \ lit i *
' i h In i sh i • • »
ft*
I < S l t if h - i! M || (| it
9 LU ® Arafyte not Reeled f&o/e f«resxrttng torsi Btmsed '.-slue
ii •, . >j rv i, lie.1-- iir-
-------
"IVbk; 1;
J|i > um,..uni J »or-j 1 ynri &uij.u vvs^tk.j A jivlkd! h..suits
rn"»«ti i p!»« Sirwr-nn-i Sit* Op«nrl* Jint ,2
WiNih M c- - ii
Li.r.itn.n Saih^I^ID !•»
¦U iD
«,•«> NtsnJ'i'
a WwfrM
O.. « >"i ' l?,1
SW-OZ-i: T
't- 1
1 \ \ .. . 11 ' .
uv-c-c-:
_ i'' ¦.
sw-02-' r
. iV'-IT"-112CO.'
1 _ -
LJ '•--4 -I'.
_ I'
Fl«1i 'i'.i-o S?ii" iti"
Ii'"**- i ,'n» "• ,-r .ri< •
~M( ! '1
1 i
3»
,,,
IV>.; ih miii'li
„ »•' '
M, lir'h
o.«
~~ ^
....
VOL'* (1-11|
7M«
C 50 Si
Fi. Id P,c,!>"i^i'i',
>'-r tiii>
' I'lM'-J I'l 11.-" N h'"!;- llll '
, l« |. IM1
i»" "l," ,. 1 Ii *H •j ,| IT-, i|
' >I jli . i (|
" . UT'. i ' !
'
CO
1 'I }•
I "!
F&MP
- !"
11
io is
1*56.3
i ,¦¦ >-
-f T
' - .1
-i l1
IV
¦>IM
M
. I',''
H
¦ 1
¦! ^ 1
¦ i.y
p., cite!
1 I i ' ( . .|i.jil i, . i. > , * J
'-in. J . Jl« ¦ _¦ t> I*
- 1 )Mi i i Ii " M s I t si . >[ 1 i i i i u i
5. J = Estimates vsJue-. Ar rtyle detected at o fewel tesslhsn Ih© Reporting Lifnft sRi,.i:
>L,t * I 31 f I J V !! * .1 I - J < . I i«
n I I hi i il < i i «'u
"" Ii ~ ft J - I- -Ml h "
8 U = An#yienoi deferled alxws we rsjjormg larsl
I' 1 1 ',f i f In M if t , i •> ' .
i „n . :k>p Jli-i'-.- li"-> - - r ii- - -1
Source: Table 1 of the 2020 Annual Report
E-32
-------
Lj, A lis n IV SI -I i »ir< , M i Ml I li n 51
'iunn-.Tir. .1 -cry-T«rrn &L.rhi,t. . Jit«t Auh. to. J P..vs
'n. itt.fi i pW i i nMuH '"ft Op-r bit- U»rt2
i'i vtt.it M I-- ii 'u- 't-
S U. -
Oaru-p Sm^rc
N ji fi ! !| Sfj'ti 1st- (,riH|''i
ir nfn '""I1, '118.
r > i r,-r as n<
nc^uHi
¦i i Ml t Pi li rTl i'I
I p I. >t
I I i U ill! jl
IM I i, j".
' t - I. >tl. I tk'.sl ¦ ¦
"I I !h II
I - J| >1, I <)lj I 1 li ..
i,. jiic1,'- i 1 - e 1- «->•
h « , ,>f . HI. i . |i«
icrisrc lirnii: E seated value
Source: Table 1 of the 2020 Annual Report
U i ill' ?* &pinn MO -.im !<• Lsl .mil !f."
E-33
-------
Table E-6: Summary of Surface Water Data from 2021 at Compliance Point SW-02-TT
to i:
Op lii 'lis IV 11 i! *r\tr' 4 ir I Mm«I< n i i
tr> if _i r<«-Tnni S r1 t-n ?Sht iVnMii ""I P su|-s
inn sin p|n, 5mwr"un1 Sit- Op^r-^h Unt *.
•fl ll.UI M 1 V* il
1
j CAS Ni*Tir?9t
I
1
!a -i f »t i
O men St n*av
Localioti S»(nnl«iD- Safno!» Qat», LabS.»n\pt® !D
[¦;! w. ir:
PI,' ru,;;!-;:
SW-B2-TT I SW-02-" I
Nit' i i h t- i rn!'I
'lll—yiPO 'inm
¦i 1
. X
* 1 1 f i
."'.oiiv
3.96
ilf-i i I r „l V.f 1' >
i«sK!2t«as
fiVHs 11>H| i,i
— r :
.....
i?
0.033&
3.0175 J-
i
7440-38-2
0.
3 309 U
. ,
¦J.1XA-
-
.¦ ¦« .
tron i •( rit ai s
.'Li
TOCsiJiai 1)
*- - >
! ;
6415 J
Pi, !,i P.*i i m mn
"r--> 1
!
I15'? i?-®!
...,
f\ j' . i ir i ,
ORP
: a
750.3
¦::: • c
i " j. <<,
PH
¦I
< to
1
= -*.r »r"i j« f-« ¦'•M i.< r-, -,i 1
1126.&
305.21
1466 & 1325.5
¦¦
i3G0.S-
1300.6
¦.n^'cJuk <. -vs -i
TEMP
_¦ 1
J..'
8.®
Vi a| 1
IU4-,
' ^
Source: Table 1 of the 2021 Annual Report
E-34
-------
Tafete t
OfW i'i n- ' .Mr., h rf Mr.trWUiriny
Sumr.tir> cf -tr.^-T^rni iur.a.e VY.it), Miiji/.i.j! Results
'nnrtti pl» • Ssi t sin * «i!" Oji-rinf^ Unt 2
in.ii M i- - h in j t'
N 1! Sj- »<- iim,v I
!)•-.-*< »rr, mi
ft* 11' i •! " . r •
M> I •! >
wyp
educ
S f». "At t..l
Cfcw o funcjr-
I 1,1 - ^ III l! > I. II l" > ! I
¦I. I l|:t> I.
lM I" 1 I I - . . ' I Hi.
Analvi® above tf<(, 4
,*= i -i "i- i. ¦> i
Source: Table 1 of the 2021 Annual Report
E-35
-------
5 I
Ojn x ill tc Rc i i. rur rti I M it&,h ri dj
Sisnnurs jl »i.r.y.-Tcrnt &urr3„e AnoU iu jI P.*5i
i|
I,* ftl rt.Tl,,
iir v i i ; ,1 ,!S no;
IW.-fu imyl)
SSflteS
•ff, ll,-h
VCOny l|
Field Ff iineMN
w «l ? Redu«
Si f?"« i- W.-l» i
Cir-in.ip Stnair-
1 f I si 4 f « • » I I » • Hj, i' i!
-I ii 1> |t .1 1 o II L '! .1 J . lu 1 >i- '
. J = Estimates flfi-aVte git a N«i *ess> tfw
t -.1m <1. i « .
( i1 i . 11
Mm ¦ i! U I i! i
>• ii-vj )~ 1' 1 •
Source: Table 1 of the 2021 Annual Report
E-36
-------
T-i ist
_|JII V ill M1N iV 11 "ll li-f! • i II I Ml !»h n h|
Ssirru.-arv _t -cry-Tom Su?j„<. 'A'zK.• Rwsulls
'nru«tfri-plr. "sj-w-urH Sit° Opmrfknh Unt 2
¦fit .1 mi > Mi- n i»n „
I
Ni1'vi"i^>i S| mtihs iniq'H
lifr i-i- i ¦'< irr
Nif t! I >!>',tsNO
¦l.'.il J f'Ui 1 I" 'I '
¦r^pH unite!
" 'i irn
~|l l~1r£' M 1= IfiiS '
' 'I! if-J t M .-> ic !><
'II h I' V>'» r
^ «r>cvfc itn? Suisse*
' ivari *rf rv vr
:,.vr;>~-nco || :y,i i;tt r iio:
L> i N'sti-, !« S«m t"w'.4?< i ,jt ?IT,
» -I- i Mf!-* "-i -if - '
no* detected sbim.
I, ! iJ|. |!
Source: Table 1 of the 2021 Annual Report
E-37
-------
r I
>V , ill ,ns IV 11 im.m „ i Mi .at. i.»
aifjui.it J „\>iv, Ilihi !>uik 'Vih i k i"i il R
In. u-rn pit • "ni-«r >in1 'it ~y«rr»hk- 'Jnl *.
'ft .1 t I MlS H'il , nn
Li l ill Ii S.M
i, bll' s>m,.k 0,»1« Ui pl.-iC
'-.Vi. Nijii'w
S ifw ICnfc.1
N „
swsrrS^OBSj
i. • 1 i - i _
1 1
;¦ ,._n 'j11
' 1 - H I!' ,1
LJt f J' < .
T=g||nZIl^
, - i - ¦, : ¦
t. k
L20t'7304-CC
N-{fx> >> i Kj»»
iti . "i in j ¦ i
'¦lit i - i - i .li '
~GG 4-41-7
. M
i .
2 33
M»ii Is iish) ii
A-mstk: tOsso^itj
1,1 il •! 1
aw
;ir4 I
1
___ _J___
_ _
.¦
''0Ls{i^ l|
fiiTiire'R
Tlffi
.IF,
....
...
....
....
fVIr! ki-.i p.iIi-I-s
"use-i a- (-s)- rnqi
r.f =»fn iVli,-v
-,w - r - -y j 1 1 1 1 , ,
I'-'-t. 11
DO
r;H
: ;¦ ¦ :vi •¦¦¦'
:
04? 24
r 11::"
::;-i
1020-5
rt
i ;i
.. . .[....
j >-7
¦ IV
**
7ii
¦:
. ' l'I I- j'.. U j I ^
i< il U lf' t- i'fi if I L ¦ l s[ ' ! i1 J 1 J
5. J= EstjtnateiG' value. Arsflyt© detected at a §sv&j imfMAVwltapiitngLwftauvrf
,> .<• • m ^ t.i-n-h II V .'-mi l ! ¦ iuj! > -ritedreJ{Qt"i-fty
I 111 III. j t I I)
11 - rv T" I -" i*4 hp-sad h--—
1 " ll I I il 1 || t l! 1 I |> K tl
9 UJ * Anslyte nsA Usjeclerf stwe t»t reporting isms!: Z.wm>i mim
>1 1 M T ,, H ,11. > in , ,• . ,! f . „ s , -
Source: Table 1 of the 2021 Annual Report
E-38
-------
: I
0|«'i ih hi- 5 11 I f.ir. ti >i n
Sumnur. of -o.r.j-IVfni Strafe A.nai>lu.-il Results
tfii"! «tn-p!» « Svi v 'mil sii .^.p^r-ihh UntZ
'jM i!>>)! M j' > it hi t
S ,-it ti ,t ¦
CVan.p S^3Tia»:
CAc- Ni/ti"
IK- HlU]"1
1,^^, jpn-rr,
W i 11 y ,.1 ,r. E i j
mm'S)
VOCsvug ii
Fteln Pft-. itf-jfc
'1 . N, ( I V\<
I- II. .< Pi !• * f **»nfe!
"•fJb - i I |
____ L
I t r ,«r ! t, ~ m 1. •- ,||> i h I !< .»
ii I. I" I ,ti.< 1 l| If , M I (, ¦ »
I i, ' i I 1 i i h i< \ '
ti I ill f i% * k> I! > » ll I ! i 'l i
~ E - k . _» »'
- ! ('< J -I «i1 ifl» t>s i ^mfih It
E-39
-------
* |!
Hj it ^ ftr,i i r 11 > > n 1 n !».i <> !
•sunu..:!r> .1 -era Tsnti ...Uoi A.uS ti, j! Rtsults
ii ! fn | I s ^ i-m ¦aiiui Sit Cp^r k b Mrs t 2
^ Mi Mi ii hi «'f-
1
!
tutu Vj-Sm
C«e sn.ip Stmcwa
L.> .Hi n 4,Mri,-(,>!£! f,.m >Hn« l II i. ,.|||.. It
* SSI2S'
1.23G2&32--0S
"swflert^BMKj
SW-Q2-TT SW-C2-*T
.. ::i
*'IS222
u.-' _ n ¦
Nitrogen Specie* (mg/1) j" ~~
jjfr-, -•£.-) >!•>,!, | ' t ' "
is i , i 1 * 1. r i' ¦ ) . 1 ?
Mtrial* irrKt-'J) |
'tu '
VOCsJug/l] 1
Fl> i«» j
. , . , , .1 [f j
".1 O1- 1 Pi h V f, ' |l 1 ] "'Fr
.7; „ i M
0.15
i
t :;4
i I
1342.?
— —
r«
i '¦*.».
"1 '*}.
i »r
r
i
1
i
I
I
_____ _L— —_
i
¦' .'V. I :.5':
129.9 »IJ
! '
:'l i 1
St
m- i :ir
Noiet
Source: Table 1 of the 2021 Annual Report
E-40
-------
11
Ulii" ill us iV\)i rui • s-iti'f1 f«1 >«I'm!i¦>» n«i
£ urn ^11, .1 .ei ^-Tuiirt Watei Ku suits
nfusti i pi** in>i Sit- Op*n»M<" Uh-t 2
'Ifl'l Ml ¦> M 'I '|1 H'"tS
f CAS> HumtoF
J
J
S.'.Im .-ftilw
st i. > »,
Location. SsmpltiQ. Sartiol* &at«, Lab Sample ID j
. 'i
sw-02-t r §w-D&r,;
bvV-i.ji.-i i
L •„ Ai' <
L . -
SW2TT^f'i3S ~
-StStG -J.—SSSfclL
SW32TT-071823 SWCETC-07182G
Nitrogan Specia* (rng/l) 1
Ai N MM 1 ) M
n • i l» ,i! i , I '' I "J • ! ' ">
mm l,i 1
, ... , ] « .•
>i , r-A. I 1. .
I —
i
vols (i,nn \
Fl. I.r P,,-,. |
< "lull1 f i'Vjf," " ¦! *•
.•»- V 1 r»'il irri -i - [11,i v
-------
¦ t
i {I i!i it IV u I i 11 >. <. i IMi nl mi
-.or..,* Tuns k.i!.u .k,aSti, j-aTjMu J f.,3
nr i tri pjp* «i p" "nnl £rt» Cp-r? 4- ' In t r
••V .1 hi i V is .. 'k < 'f
N 1 s << j> ii f^n it> in- t,ni>s¦1 s
, jr * - , h> ii .1.,
ll> i , I 11 ,t! ,35 NO
IWi'l its lllli) i,l
Awk (Ida")
i&ssm
-| nl< J I'r.i,, V I I' !
" I I .1-,
4 i&ralvie detects
I< i .iti>.i) S.iiii l->ll §«ij. !«' t.s * !> i.jiIm !L
W02TT-07
,J> |.-.
5MSTD-&3-1220
3 VMD2TT-OS1220 | SW02TT-
j&'12G02!J 1246 I BS^CK
L J 1 ~ _ v '
i- I' Ii- if . ' i 11 |i> !i
^ I » .lid il»» . t- - >
' _ ~ 'i 'Vi - i - h t m 11
i ' i i il 1 l> it »
9. UJ » Ansiyte noi <>3teete«i »»•
I' 1 rtm i v n' -rHri"--- is
Source: Table 1 of the 2021 Annual Report
E-42
-------
C|i« < flit ti"- f¥ni ri i Mnr*|i ri hi
Sumr.ar, vf-.tr^-Tcum &ui1aie Wite: i-cnWifiral Hi suits
iVk Ktn pl-« *>u « Mn1 cf1- >.'p»i «h!»- Ufi'1
Vfaafttiin Maftsaehiswrtia
location, SamptelD. SamptoDat», Lab Sampl»!D
Sut*f2K'4l
Cleanup Standard
SW-C2-T?
SW-Q2-TT
S¥V-»2-Y~
SW-Q2-TT
SVV412-~T
SiV-02-TT
SW-02-TT
SW-02-Tf
CM Wumtotr
SVVC2TT -Of.! ?2€
0S173SS *2 3}
-
svvcsT^-oasflsn
c®2®2020 mm
¦
SWD2TI-0S2eO
QS©V2D£0 10:05
t20M$23-02
SVVCC.-TT-032723
O&G7S02-IH2-1S
L2035272-02
-
skm2T^-mmm
mm-iam&im
1233S4&4-02
SWQ2TT-C90SS3
QMSG020 14:05
L2C37341-C6
SIW2TD-093920
mmw u 10
12037341-0?
WVW2QKH1:15
aomm-os
NHrogan Spaciee (mgfl)
Nfrogen Amnxnie
7664-4.1-7
*- 76
;-;:7
0.0S7
:.03
2.12
2.30
NMQM. ***»•• N03
147SP-55-5N08 :
¦¦
-
....
: w
...
..
MM*lr(ingJI)
7440-3W I
0.
....
....
....
¦¦
¦¦
¦¦
i:. i. :v
-
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Source: Table 1 of the 2021 Annual Report
E-43
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Source: Table 1 of the 2021 Annual Report
E-45
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Source: Table 1 of the 2021 Annual Report
E-47
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Table E-7: Summary of Surface Water Data from 2022 at Compliance Point SW-02-TT
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Source: Table 1 of the 2022 Annual Report
E-48
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Tafcte 1
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Source: Table 1 of the 2022 Annual Report
E-49
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Source: Table 1 of the 2022 Annual Report
E-51
-------
T >hl ¦ i
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Source: Table 1 of the 2022 Annual Report
E-52
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14 I »
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Source: Table 1 of the 2022 Annual Report
E-53
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F.irn-nti ilLjcq ftfTT j Wvr- Ar-aiytical and Water Quality R«utts
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Source: Table 1 of the 2022 Annual Report
E-54
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Source: Table 1 of the 2022 Annual Report
E-55
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T ibte 1
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Source: Table 1 of the 2022 Annual Report
E-56
-------
Table 1
fetirmi , i! 1 nn Iht fc' " ftnaiyticalarwj Watar Quality Result*
j nmr> 2 '22 [>-< io?"
Sj |H r t J10' P.'V |Hs
in ii it Pl»n rv •> o\i ,< hi ft'A
Nitioasri \Pv~ b
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l 600 *«tr qui
*tNss»wptag<
Source: Table 1 of the 2022 Annual Report
Lv ,ti. n,S,tvi l> ID, S--r\:!>*0*r.< Lai. Snr f"o!D
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•m
r V
1452
3°M?
7.45
SM6
13 SS
1S.18
T#
i
7.21
•fft-v1
1M»
13.41
T1S
smi
12/3
J1.99
':0
1132 8
¦¦v.r,n
1190
1192.S
12 50
,190.
7,16
1165.'-
{8.13
,,. ......
11S17
12 47
21 SS
Source: Table 1 of the 2022 Annual Report
E-58
-------
Table 1
fetirmi , i! 1 nn Iht fc' " ftnaiyticalarwj Watar Quality Result*
j nmr> 2 '22 [>-< io?"
Sj |H r t J10' P.'V |Hs
in ii it Pl»n rv •> o\i ,< hi ft'A
41 i. - ^ i .i.
I 1 ».<. I ft,*-' Kiy-
Water
l?rnn Stmd^rf
p«'Qture i;
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II • >1 ,'!< I
I = -if
f it!
SS fWl t!tt Rt
mi} ?hts
-------
Tin*
S\im'w, 11.^ iq Ifi n 5 0> ? A'
-------
T t I
S urn ifj ifL jq Tht c< rK - ,Y«t*r Analytical and W»tar QualKy R9*utt*
J-.iiu.if2"". D».uribj. ITCZ
l tt-r F?*S Jh«.
Iii-uM -PI. » "I J rt> h IS IVA
1
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|
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- - 1 f
^""^Wmff-5T27S
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_____
:4_T "ir
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l: ^ 11
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7064-4 V?
! |
- i -
„
....
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<• -I
irot" iTolati
7440-IS-2
i —
i I
¦Li i j
.
VCC= uyj. ,i
1 < " t>
,, j
rf> mp« p w<,>
"l t'.u . 1 " If ("
_ ii-.w'1' i' F d.v' ji ! -Is.1 ' jl n . i
iff- m .1 ¦) >iir
ORP
I'EfelP
! "¦
!
"l '
12.39
¦ IS
f;5
I 'CI
KkVW
1 A>i date is w^icialea
l (t=«; I I "1 - Il=-_1«r
' i1 l'r| 1 ' ' ' ' > I ' i 1 iii ip S'.afniard s'« boid.
i J = „ JL h._... -
£. J+ - Esls^Rjtiid value tessS'ti higft
J II- 1 1| h I . .* XC --nil
,l I < I' ~ .1 - » - t- ' 1 ,
) (jf i i * r t r-i> r ( 'V! - < - ,
0 R§W pgsramelere o5Slee?-«;t usrsg an snd^efxteit ir> Aaia'f ROt l BOO mHs qu»y
meier [&r an #qusv*l«rt meier) that has t-eefi calibrated cn the nomng c' th# sampling 4ay
ii^ssstUfwrmm i-Died
Source: Table 1 of the 2022 Annual Report
E-61
-------
T iNt '
SutT!~n?s U' in 1»rv ">1 ih . Win Analytical and Water Quality
J ,.nu.u y 2TI2 C^c^ti b«?* 102.7
S.km , Ri t i,h
In u,l -Fli ~ -"V ? W ID
r«s \ir- U 1
Surf«c© mam
"•t St .If lit( «ii» il
2/1W2022 1M3G
!"iiiV lid. ! i
;a:
s»tM-n
^#5111-011722
L220547?-C^
\ ' 1 I
- •/> i r-\ 2:
sw-04.Tr
8VWJ4...T?
2'24'"«5)2210.40
>>\ ' "
sww-ri
1
jrr-j." "i.
1 \ -i
Niti t vn 83 if- i »> r 1
'ii i.i ¦ (ik
i^l h ur ,i' .
• '! '
¦i.K.-
•
h'nhlx
t' > - i 1
p "i f\ '!' .!
> i 1 , J
744&3&S
;•) is
"¦11-
v.'-r.' in .j. i
4S
r,i m Fim !' (t's-i •
J'.lM'.Jl. »|
,-c th... K niii >1 'i
tir | i'M-1
s
ej
7 11
Svi
T c| i ',j,
1 J. jJl,. il,lL i
TEMP
i:.-
ii.i
''
" 1 V:fl
¦«
A'-l -date >s valtdoled
i -I < t r ! II i<
AnaMe detected above the Surface Wat
u !l, - ' M I ¦ li . _ n
* i" I f ^ 1» r . ' si L ' i ..
'¦¦mM using an ndapendert irv&fcj.® AcjubTRQL
meim thai has bten calibrated on m -tmmnQ c
Source: Table 1 of the 2022 Annual Report
E-62
-------
14 I »
Siijrrri * , ^ I m Urn 5>i * Wats? Analytical arvd Wator Quality Rebuffs
J utii in, 2X2 O ^~ih" rO»!u
SlfM fc P»> jit'.
in ii- 1--F! . Ot : jfji i in !VA
i
LotSliwli, Sai
> i..m, s,-iv,r.i n»(rt i
ih s,ar ;> * if?
-,£$ \u-AjC
r yup ?tc" dcT | (
' >-M i
^OiTt^STTS?'"'''
SVV-C4-> T
: 'v** *t~-c "i ;;
>_i j : - .•
": ¦ vr
L..' " ~jl
Nitrorasn Sperms ,mr h
Nh « ¦> - -
>il J' • tJi> j. i :•:
7664-41-?
1 ->.<
] ...
..
„
....
....
Metats
[< vK- 'I
. iT:'at
'
TWS54? 015 00120
7440-38-2 I <11S 1 0 00?
„
VCO .j i
777 ~ I ~~
r i i ¦ p ij ' i'i i •
• M.I. .11 1 « >\ . *
,1" I •> n.l ,
rs"i"> "t 1 -1-- .r«-v,
~ ',-11r, irli
- 1 ¦ ¦
i
! .1
12.33
;./o -I
:'l ..:o
i i'
11 7
V:>¦
:
H
"I
Source: Table 1 of the 2022 Annual Report
E-63
-------
t irl« i
&HIT1-IV, iii .in Urn S>| H- ! L-h ID
CAS Number
ha t i fV i p
" » v u| 5s I s >tj i
SW-04-5 T
'''''^SW4fT-tMT3S"">"
mmmz n is
L2219306-03
i'i,1!;.. i ;
iT~ Jl
J '1 « - » iv
J' ii, • 1,11 .'"I ,< ' >
?6€4-4 1-7
h
«
fr' l11111» !' It 1 [ 11!
i-n r^_-«i mm
7M&3S-2
0 003 J+
¦
-
VCO h ,, ¦
«
r,-M f-)(-i'.«.
..
['¦ «M i
• . 1 i >1 i ii -
Temperature >1
i
•iM'i
Siirfa;
r hi
|| r>l ¦"•1^ ,f I- I- ---r I r
U = Analyfe nfflJ detected atoa llw reporting iinift
U» - -f 1- VvJ- - T > . - L '
I i - 1|, I" 1 < »1 !
iEealertjan or equaittffie tteftcd DetecSon fmt;MOU
unless othcvrtse rot&l
Source: Table 1 of the 2022 Annual Report
E-64
-------
Som i n, i I iq Urr Eurir « ^ n* ftnaiytieat ami Water Quality Results
I ruin C»- wnh fc 122
Sut " fr 1 vU Phs iMs
In I Jl ~ ^ h iri ffi
Source: Table 1 of the 2022 Annual Report
E-65
-------
T tl
•Minim tf L i°iq Urn "hi » VYi'r • ftiniiyttcal and Water Quality Rosuft*
I-mi u 2~Z2 O Mnh^i ?"i2"
Smf« < i • h» s iH-s
i!t sit I Fl •> "
¦II-m,
11 11V ?>)' !'• -tS
iteiateitnpnf
® .«•. L b_-uKL ll
vcr_ „»i i
n» r 1 f11*'
Terrij^etufe .dec C
date is vasJate::!
hi if , 1 1 lit'
aMe •deSec.ited above Ihe Surface. W,
i' r a
II« Anulyte r-sl
J - Estimated value Analyse
EsBmsteavifcH
. »» fie
"I * J ,
Source: Table 1 of the 2022 Annual Report
E-66
I ¦ I_
1 ' 1 r ,1
i . 1 '.M
-------
APPENDIX F - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: Industri-Plex
Date of Inspection: 11/17/2023
Location and Region: Woburn. MA Region 1
EPA ID: MAD076580950
Agency, Office or Company Leading the Five-Year
Weather/Temperature: Cloudy. 65 degrees
Review: EPA
Fahrenheit
Remedy Includes: (check all that apply)
^1 Landfill cover/containment
~ Monitored natural attenuation
~ Access controls
~ Groundwater containment
^1 Institutional controls
^1 Vertical barrier walls (West Hide Pile Flow Barrier)
~ Groundwater pump and treatment
[3 Surface water collection and treatment
[X] Other: Groundwater treatment via discharge to the HBH A Pond where natural processes and
chemocline sequester arsenic and other compounds at depth within the primary treatment cell, and
biological processes treat ammonia and benzene within the aeration zone followed bv Quiescent zone
within the secondary treatment cell (OU-2); landfill gas collection and vapor combustion of off-gas
(OU-1).
Attachments: d Inspection team roster attached
O Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager Todd Maicr and Bruce
OU-1 and OU-2 Settling Party 12/18/2023
Thompson
Representatives 01/04/2024
Name
Title Date
Interviewed [~~| at site flat office [~~| by phone Phone:
Problems, suggestions [~~| Report attached:
2. O&M Staff
Name
Title Date
Interviewed [~~| at site [~~| at office [~~| bv phone 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 MassDEP
Contact Jennifer McWeenev Project 01/10/2024
Name Manager Date Phone
Title
Problems/suggestions PI Report attached:
Agency City of Woburn
Contact John Corey City Engineer 12/26/2023
Name Title Date Phone
Problems/suggestions PI Report attached:
Agency
Contact
Name Title Date Phone
Problems/suggestions PI Report attached:
Agency
F-1
-------
Contact
Name Title
Problems/sueeestions PI Report attached:
Date
Phone
Aeencv
Contact
Name Title
Problems/sueeestions [~~l Report attached:
Date
Phone
4.
Other Interviews (optional) d Report attached:
Representatives from Aberjona Study Coalition
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
13 O&M manual Readily available
^1 Up to date
~ N/A
13 As-built drawings ^ Readily available
^ Up to date
~ N/A
13 Maintenance logs |3 Readily available
13 Up to date
~ N/A
Remarks:
2.
Site-Specific Health and Safety Plan
^ Readily available
13 Up to date
~ n/a
~ Contingency plan/emergency response plan
~ Readily available
~ Up to date
Sn/a
Remarks:
3.
O&M and OSHA Training Records
Remarks:
~ Readily available
~ Up to date
13 N/A
4.
Permits and Service Agreements
~ Air discharge permit
~ Readily available
~ Up to date
13 N/A
~ Effluent discharge
~ Readily available
~ Up to date
13 N/A
~ Waste disposal, POTW
~ Readily available
~ Up to date
13 N/A
n Other permits:
~ Readily available
~ Up to date
13 N/A
Remarks:
5.
Gas Generation Records
Remarks:
^ Readily available
13 Up to date
~ n/a
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
Sn/A
7.
Groundwater Monitoring Records
Remarks:
^ Readily available
13 Up to date
~ n/a
8.
Leachate Extraction Records
~ Readily available
~ Up to date
Sn/A
Remarks:
9.
Discharge Compliance Records
13 Air ^ Readily available
^ Up to date
~ N/A
F-2
-------
13 Water (effluent) Readily available Up to date dl N/A
Remarks:
10. Daily Access/Security Logs
~ Readily available ~ Up to date E3 N/A
Remarks:
IV. O&M COSTS
1. O&M Organization
l~l State in-housc
O Contractor for state
1 1 PRP in-housc
[X] Contractor for PRP
[~l Federal facility in-house
~ Contractor for Federal facility
n
2. O&M Cost Records
[~l Readily available
~ Up to date
E3 Funding nicclianisin/agrccincnt in place E3 Unavailable
Original O&M cost estimate:
O Breakdown attached
Total annual cost by year for review period if available
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS ^ Applicable ~ N/A
A. Fencing
1. Fencing Damaged ~ Location shown on site map ~ Gates secured [3 N/A
Remarks: Fencing is present and in good condition. However, it is not reciuired bv the decision
documents and appears to function inainlv to protect the solar dcvclopincnt.
B. Other Access Restrictions
1. Signs and Other Security Measures
~ Location shown on site map ^ N/A
Remarks:
C. Institutional Controls (ICs)
F-3
-------
1. Implementation and Enforcement
Site conditions imply ICs not properly implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by): __
Frequency: Annual Inspections
Responsible party/agency:
Contact
Title
Name
Reporting is up to date
Reports arc verified by the lead agency
Specific requirements in deed or decision documents have been met
Violations have been reported
Other problems or suggestions: ~ Report attached
~ Yes
~ Yes
El No ~ N/A
[S3 No ~ N/A
Date
Phone
S Yes
~
No
~n/a
M Yes
~
No
~ n/a
l~l Yes
m
No
~ n/a
[~l Yes
No
~ n/a
2. Adequacy ~ ICs arc adequate [3 ICs arc inadequate ~ N/A
Remarks: While main institutional controls have been put in place, there are still some that are in
progress.
D. General
1. Vandalism/Trespassing ~ Location shown on site map
Remarks:
No vandalism evident
2. Land Use Changes On-Site ~ N/A
Remarks: The Site continues to be redeveloped consistent with what is allowed by the remedy.
3. Land Use Changes Off-Site
Remarks:
13 N/A
VI. GENERAL SITE CONDITIONS
A. Roads
[3 Applicable ~ N/A
1. Roads Damaged
Remarks:
~ Location shown on site map ^ Roads adequate
~ N/A
B. Other Site Conditions
Remarks:
VII. LANDFILL COVERS
1^ Applicable ~ N/A
A. Landfill Surface (Hide Piles)
1. Settlenient (low spots)
Area extent:
Remarks:
~ Location shown on site map
Settlement not evident
Depth:
2.
Cracks
Lengths: _
Remarks:
~ Location shown on site map
Widths:
E3 Cracking not evident
Depths:
F-4
-------
3.
Erosion
Area extent:
Remarks:
I~l Location shown on site map
[x] Erosion not evident
Depth:
4.
Holes
Area extent:
Remarks:
~ Location shown on site map
^1 Holes not evident
Depth:
5.
Vegetative Cover
l~l Grass
E3 Cover properly established
l~l No signs of stress
l~l Trees/shrubs (indicate si/c and locations on a diagram)
Remarks: Invasive species contol and cover maintenance is ongoing as needed.
6.
Alternative Cover (e.£
armored rock, concrete)
~ N/A
Remarks: Armored areas in slope drains and drainage swales are intact and functioning as designed.
7.
Bulges
Area extent:
Remarks:
~ Location shown on site map
^ Bulges not evident
Height:
8.
Wet Areas/Water Damage Wet areas/water damage not evident
l~l Wet areas
O Location shown on site map
Area extent:
[~l Ponding
~ Location shown on site map
Area extent:
[~l Seeps
~ Location shown on site map
Area extent:
l~l Soft subgrade
O Location shown on site map
Area extent:
Remarks:
9.
Slope Instability
O Slides
~ Location shown on site map
1^ No evidence of slope instability
Area extent:
Remarks:
B.
Benches ~ Applicable [3 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
Remarks:
[~l Location shown on site map
[~l N/A or okay
2.
Bench Breached
Remarks:
l~l Location shown on site map
l~l N/A or okay
3.
Bench Overtopped
Remarks:
l~l Location shown on site map
l~l N/A or okay
C.
Letdown Channels
~ Applicable [3 N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
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.)
F-5
-------
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
~ No evidence of degradation
Material tvpc:
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:
~ No obstructions
n Location shown on site man Area extent:
Size:
Remarks:
6.
Excessive Vegetative Growth Tvdc:
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
n Location shown on site man Area extent:
Remarks:
D.
Cover Penetrations ~ Applicable ^ N/A
1.
Gas Vents Q Active
l~l Passive
l~l Properly secured/locked Q Functioning O Routinely sampled O Good condition
l~l Evidence of leakage at penetration O Needs maintenance O N/A
Remarks:
2.
Gas Monitoring Probes
[~l Properly secured/locked O Functioning ~ Routinely sampled O Good condition
[~l Evidence of leakage at penetration O Needs maintenance ~ N/A
Remarks:
3.
Monitoring Wells (within surface area of landfill)
l~l Properly secured/locked Q Functioning ~ Routinely sampled O Good condition
l~l Evidence of leakage at penetration O Needs maintenance O N/A
Remarks:
4.
Extraction Wells Leachate
l~l Properly secured/locked [U Functioning ~ Routinely sampled O Good condition
F-6
-------
I~l Evidence of leakage at penetration O Needs maintenance
~ N/A
Remarks:
5.
Settlement Monuments Q Located O Routinely surveyed
~ N/A
Remarks:
E.
Gas Collection and Treatment Applicable ~ N/A
1.
Gas Treatment Facilities
[~l Flaring ^ Thermal destruction
~ Collection for reuse
[~l Good condition ~ Needs maintenance
Remarks:
2.
Gas Collection Wells, Manifolds and Piping
E3 Good condition ~ Needs maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
[~l Good condition ~ Needs maintenance K1 N/A
Remarks:
F.
Cover Drainage Layer ^ Applicable ~ N/A
1.
Outlet Pipes Inspected O Functioning E3 N/A
Remarks:
2.
Outlet Rock Inspected E3 Functioning ~ N/A
Remarks: Hide pile toe drains do not show evidence of damage.
G.
Detention/Sedimentation Ponds ^ Applicable ~ N/A
1.
Siltation Area extent: Depth:
~ N/A
E3 Siltation not evident
Remarks:
2.
Erosion Area extent: Depth:
E3 Erosion not evident
Remarks:
3.
Outlet Works Q Functioning £
3 N/A
Remarks:
4.
Dam Functioning £
3 N/A
Remarks:
EL Retaining Walls ~ Applicable [3 N/A
1.
Deformations O Location shown on site map Q Deformation not evident
Horizontal displacement: Vertical displacement:
Rotational displacement:
Remarks:
F-7
-------
2.
Degradation O Location shown on site map Q Degradation not evident
Remarks:
I. Perimeter Ditehes/Off-Site Discharge Applicable ~ N/A
1.
Siltation O Location shown on site map ^ Siltation not evident
Area extent: Depth:
Remarks:
2.
Vegetative Growth ~ Location shown on site map ~ N/A
Vegetation does not impede flow
Area extent: Tvpe:
Remarks:
3.
Erosion ~ Location shown on site map E3 Erosion not evident
Area extent: Depth:
Remarks:
4.
Discharge Structure Functioning ~ N/A
Remarks:
VIII. VERTICAL BARRIER WALLS ^ Applicable ~ N/A
1.
Settlement ~ Location shown on site map E3 Settlement not evident
Area extent: Depth:
Remarks:
2.
Performance Monitoring Tvoe of monitoring:
[~l Performance not monitored
Freciuencv: 1 1 Evidence of breadline
Head differential:
Remarks: Groundwater flow barrier installed at the toe of the West Hide Pile eastern slope to protect the
Lower South Pond from benzene discharges. Monitoring will begin as Dart of the Long-Term
Monitoring Plan.
IX.
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
O Readily available Q Good condition ~ Requires upgrade Q Needs to be provided
Remarks:
F-8
-------
B. Surface Water Collection Structures, Pumps and Pipelines Applicable O N/A
1.
Collection Structures, Pumps and Electrical
Good condition ~ Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
Good condition ~ Needs maintenance
Remarks:
3.
Spare Parts and Equipment
[x] Readily available Q Good condition ~ Requires upgrade Q Needs to be provided
Remarks:
C.
Treatment System (OU-2) ^ Applicable ~ N/A
1.
Treatment Train (check components that apply)
O Metals removal ~ Oil/water separation ~ Biore mediation
~ Air stripping ~ Carbon adsorbers
n Filters:
n Additive (e.g.. chelation agent, flocculent):
n Others:
E3 Good condition Q Needs maintenance
13 Sampling ports properly marked and functional
13 Sampling/maintenance log displayed and up to date
E3 Equipment properly identified
n Ouantitv of groundwater treated annuallv:
n Ouantitv of surface water treated annuallv:
Remarks: Biore mediation occurs in oond Webitat bio-net and aeration svstem to treat ammonia
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A |3 Good condition ~ Needs maintenance
Remarks:
3.
Tanks, Vaults, Storage Vessels
K1 N/A ~ Good condition ~ Proper secondary containment ~ Needs maintenance
Remarks:
4.
Discharge Structure and Appurtenances
~ N/A |3 Good condition ~ Needs maintenance
Remarks:
5.
Treatment Building)*)
O N/A |3 Good condition (esp. roof and doorw ay s) O Needs repair
Chemicals and equipment properly stored
Remarks:
F-9
-------
6.
Monitoring Wells (pump and treatment remedy)
O Properly secured/locked Q Functioning ~ Routinely sampled O Good condition
~ All required wells located ~ Needs maintenance ^ N/A
Remarks: Pump and treat is not a rcmcdv at the Site.
D. Monitoring Data
1.
Monitoring Data
Is routinely submitted on time ^ Is of acceptable quality
2.
Monitoring Data Suggests:
O Groundwater plume is effectively contained ~ Contaminant concentrations arc declining
E.
Monitored Natural Attenuation
1.
Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
~ All required wells located ~ Needs maintenance ^ N/A
Remarks: Monitored natural attenuation is not a rcmcdv at the Site.
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 facility associated with the remedy. 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 OU-1 rcmcdv was designed to prevent contact with underlying contaminated soils. The majority of
the properties arc occupied bv active commercial businesses and public roads. The cover systems arc
generally in good condition, however ongoing repair and maintenance is necessary. Institutional controls
arc in place at the majority of the OU-1 properties. The hide piles have constructed cover sv stems which
arc all in good condition. The TOU svstcni was upgraded to a vapor conibustcr svstcni during this FYR
period.
The OU-2 remedy was designed to capture site contaminated groundwater as it discharges into the HBHA
Pond and treat the contamination through primary and secondary treatment cells. The primary cell natural
attenuation processes scciucstcr ammonia, arsenic and benzene. The secondary cell includes an aeration
zone promoting biological degradation of ammonia followed bv ciuicsccnt zone to promote further
settling. All components of the rcnicdv have been effective in reducing downstream migration of
groundwater contamination. Contaminated soils around the northern banks of the HBHA Pond have been
capped.
The remedies at OU-1 and OU-2 appear to be functioning effectively as designed.
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.
No O&M issues were identified related to the current protectiveness of the rcmcdv. Ongoing inspection
and maintenance of the OU-1 cauivalcnt covers is necessary for long-term protectiveness.
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 rcmcdv may be compromised
in the future.
No earlv indicators of potential rcmcdv problems were identified.
D.
Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
No opportunities for optimization were identified.
F-10
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APPENDIX G - SITE INSPECTION PHOTOS
West Hide Pile
/ / / /
" /. / /-/,/[/./?.
-—/I / / / r
1M uLjL
.. V "« T.
Solar panels on the East Hide Pile
G-l
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Lower South Pond
New vapor combustor located behind the TOU building
G-2
-------
East Central Hide Pile
TOU building interior
G-3
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Constructed wetlands
Commuter rail and bus station on-site
G-4
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211 New Boston Street, where drums of unidentified contents are present m the floor breach
South Hide Pile
G-5
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HBHA Pond
Operations building for the Webitat biological treatment units
G-6
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WINCHESTER FISH LADDER!
SEE www.winchester.us/fishladder
Winchester Fish Ladder
G-7
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APPENDIX H - INTERVIEWS
INDUSTRI-PLEX SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Industri-Plex
EPA ID: MAD076580950
Subject name: Jennifer McWccncy Subject affiliation: MassDEP
Subject contact information: Jennifer.mcweeney@mass.gov
Interview date: January 10, 2024
Interview time:
Interview location: on-line
Interview format (circle one): In Person Phone Mail i Other
Interview category: State Agency
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)'.' The Iplex OU-1 and OU-2 remedies are well managed/maintained, and site OU-1 reuse
activities are well managed in accordance with existing OU-1 ICs (the work protocols section in
particular). Development of OU-2 ICs is expected to resume soon.
2. What is your assessment of the current performance of the remedy in place at the Site'.' The OU-1 and OU-2
remedies are performing well to prevent exposure to contaminated soils (capping/ICs) and sediments
(sequestering/dredging and off-site disposal and capping) and treat contaminated groundwater/surface
water (HBHA treatment cells).
EPA previously flagged groundwater exceedances above VISLS, which suggest that vapor intrusion
may be a concern at certain buildings. A draft vapor intrusion evaluation workplan was prepared and
EPA comments have been provided. The work plan has not yet been finalized. It is hoped the workplan
can be finalized in time to allow indoor air sampling this winter/early spring.
3. Are you aw are of any complaints or inquiries regarding site-related environmental issues or remedial
activities from residents in the past five years? No.
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. There were no site-related communications/activities
outside of those ov erseen/m an aged by EPA.
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy'.'
MassDEP's 2024 MCP [Massachusetts Contingency Plan] becomes effective 3/1/24. Revisions include
language related to SSDS [sub slab depressurization system| (need to establish acceptable vacuum
range to maintain negative pressure field; and need for continuous monitoring/telemetry). Although
this is not currently applicable to Iplex, it may be in future should SSDS ever be required. In addition,
the 2024 MCP also has some revisions that may impact MassDEP's federal model NAUL (currently
under revision). This would not impact the Iplex OU-1 NAULs, but may impact the OU-2 NAULs.
6. Are you comfortable with the status of the institutional controls at the Site'.' If not. what are the associated
outstanding issues'.' Yes, OU-1 ICs are almost complete, and OU-2 IC development is expected to
resume soon.
H-l
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7. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy'.' If possible, the Preliminary Vapor Intrusion Work Plan should be finalized in time to
allow for indoor air sampling this winter/early spring (2024).
8. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report'.' Yes.
H-2
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INDUSTRI-PLEX SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Industri-Plex
EPA ID: MAD076580950
Subject name: John Corey Subject affiliation: City Engineer
Subject contact information: City Hall. 10 Common St.. Woburn 01801
Interview date: December 26. 2023
Interview time: 3:00 p.m.
Interview location: Engineering Department
Interview format (circle one): In Person Phone Mail f I Other
Interview category: Local Government
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date'.' I am aware.
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 am well informed.
3. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing'.' None that I am aware of.
4. Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy'.' I am not aware of any changes.
5. Are you aware of any changes in projected land use(s) at the Site'.' I am.
6. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site'.' They have done
an excellent job. How can EPA best provide site-related information in the future'.' The current system
works well.
7. Do you have any comments, suggestions or recommendations regarding the project'.' None.
8. Do you consent to have your name included along w ith your responses to this questionnaire in the FYR
report'.' I give my consent.
H-3
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INDUSTRI-PLEX SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Industri-Plex
EPA ID: MAD076580950
Subject name: Todd Major Subject affiliation: de maximis, inc.
Subject contact information: tmajer@demaximis.com
Interview format (circle one): In Person Phone Mail I I Other:
Interview category: Potentially Responsible Party (PRP) / Settling Party (SP) Representative
1. What is your overall impression of the remedial activities at the Site'.' They are operating as designed and
continue, at no small cost, to be effective and protective.
2. What have been the effects of this Site on the surrounding community, if any? Positiv e effects based on all
the redev eloping activities, including the construction of residential dwellings and the construction of a
solar array system that is providing energy to the City of Somerville.
3. What is your assessment of the current performance of the remedy in place at the Site'.' That the remedy is
meeting all design expectations and is protective of human health and the environment.
4. What are the findings from the monitoring data'.' What are the key trends in contaminant levels that are being
documented overtime at the Site'.' The findings from the monitoring data indicate we are meeting our
ammonia and other COC surface water monitoring cleanup levels at our point of compliance.
Groundwater results remained the same over the last five years. Trend results are located in the
Annual Reports.
5. What is the frequency of on-site O&M presence (e.g., continuous, weekly, monthly; estimate hours)'.' Please
describe O&M staff responsibilities and activities and frequency of site inspections. There is an O&M
technician on-site 32-40 hours per week to maintain the IPLEX OU1 Vapor Combustor and hide pile
cover maintenance activities and for OU-2 compliance monitoring, aeration treatment operation,
wetland inspections/piezometer readings and Center Falls Dam fish ladder maintenance and
monitoring.
6. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so. do they affect the effectiveness of the remedy'.' Please
describe changes and impacts, if any. No.
7. Have there been unexpected O&M difficulties at the Site since start-up or in the last five years? If so. please
provide details. No.
8. Have there been opportunities to optimize O&M activities or sampling efforts'.' Please describe changes and
any resulting or desired contaminant reductions, improved cleanup efficiencies, or cost savings. See
response to Question No. 11. There are opportunities to optimize the O&M and sampling efforts but
that would take a collaborated effort on all parties to agree to the process.
9. Are you aw are of any complaints or inquiries regarding environmental issues or the remedial action from
residents since implementation of the cleanup'.' No.
10. 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'.' We feel well informed with respect to redevelopment
activ ities associated with the site but feel the agencies could provide better responses with respect to the
remedial progress (i.e., 2017 100% IC Design Report).
H-4
-------
1 1. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy'.' Yes, we had proposed doing an aeration pilot study within the secondary treatment cell
(HBHA Pond) in 2021 to try and reduce our monthly electrical bill. The Settling Defendants believe
that during the pre-design investigation phase of the project, multiple "knobs" were "turned" while
performing the in-pond aeration treatment and the ex-situ aeration treatment pre-design pilot studies
and although EPA had started to look at our aeration pilot study, we never received any feedback from
them on our proposed process to eliminate some of the knobs (i.e., fine bubble diffusers, surface
aerators) that were implemented into the final remedy. In addition, we have requested in our 2021 and
2022 Annual Reports to reduce the frequency of baseflow surface sampling and groundwater sampling
and are still awaiting a response from EPA.
12. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report'.' Yes.
H-5
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INDUSTRI-PLEX SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Industri-Plex
EPA ID: MAD076580950
Subject name: Bruce Thompson Subject affiliation: de maximis, inc.
Subject contact information: brucet a demaxi in is com
Interview format (circle one): In Person Phone Mail f Email) Other:
Interview category: Potentially Responsible Party (PRP) / Settling Party (SP) Representative
1. What is your overall impression of the remedial activities at the Site'.' The long-term O&M is proceeding
and working as expected.
2. What have been the effects of this Site on the surrounding community, if any? None noted.
3. What is your assessment of the current performance of the remedy in place at the Site'.' The remedy is
working as designed, is effective, and protective.
4. What are the findings from the monitoring data'.' What are the key trends in contaminant levels that are being
documented overtime at the Site'.' Groundwater and surface water concentrations trends are declining or
steady.
5. What is the frequency of on-site O&M presence (e.g., continuous, weekly, monthly; estimate hours)'.' Please
describe O&M staff responsibilities and activities and frequency of site inspections. O&M staff are at the
site several days per week, conducting monitoring and system maintenance pursuant to the O&M Plan.
Refer to the O&M Plan for details.
6. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so. do they affect the effectiveness of the remedy'.' Please
describe changes and impacts, if any. No significant changes to the O&M Plan.
7. Have there been unexpected O&M difficulties at the Site since start-up or in the last five years? If so. please
provide details. No unexpected difficulties with O&M.
8. Have there been opportunities to optimize O&M activities or sampling efforts'.' Please describe changes and
any resulting or desired contaminant reductions, improved cleanup efficiencies, or cost savings. The surface
water monitoring program has been ongoing since remedy completion, and could be reduced as
proposed in the O&M Plan.
9. Are you aw are of any complaints or inquiries regarding environmental issues or the remedial action from
residents since implementation of the cleanup? Not aware of any inquiries.
10. 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 about site activities.
1 1. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy'.' No.
12. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report'.' Yes.
H-6
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INDIJSTRI-PLEX SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: Industri-Plex
EPA ID: MAD076580950
Subject name: Not applicable
Subject affiliation: Representatives from
Aberjona Study Coalition
Interview date: December 5, 2023
Interview time: 1 p.m.
Interview location: 10 N Maple Street Woburn MA 01801
Interview format (circle one): In Person
Phone
Mail
Other:
Interview category: Resident
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date'.' Yes.
2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)'.' Professional well managed project.
3. What have been the effects of this Site on the surrounding community, if any? None that we are aware of.
4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing'.' None that we are aware of.
5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site'.' How can EPA
best provide site-related information in the future'.' The EPA through their website is and has provided up
to date project information.
6. Do you have any comments, suggestions or recommendations regarding any aspects of the project'.' None.
H-7
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APPENDIX I - CLEANUP LEVEL/PERFORMANCE STANDARD REVIEW
OU-1 Cleanup Level and Standards Review
Soil
The 1986 ROD established OU-1 soil cleanup levels. The 2018 and 2023 ESDs clarified that the cleanup levels
were developed assuming industrial and commercial use and not considered protective for on-site residential use.
Table 1-1 compares the soil cleanup goals against EPA's current composite worker RSLs. RSLs incorporate
current toxicity values and standard default exposure factors. The evaluation indicates that the cleanup goals
correspond to noncancer HQs below EPA's threshold of 1 and cancer risks within EPA's cancer risk range of 1 x
10_4to 1 x 10"6. EPA has not developed RSLs for lead and evaluates lead exposure using blood-lead modeling.
The 1986 ROD soil cleanup goal for lead is below the current industrial level of 800 mg/kg. indicating it
continues to remain valid.
Table 1-1: Screening-Level Risk Review for OU-1 Soil Cleanup Levels
coc
Soil Cleanup
Level-1 (mg/kg)
Composite Worker Soil RSLh
(mg/kg)
Cancer Risk1
Noncancer HQ1'
1 x 10"6 Risk
HQ= 1.0
Arsenic
300
3
480
1 x 10"4
0.6
Chromium0
1,000
-
1,800,000
-
0.001
Lead
600
i,ooof
N/A
Notes:
a) Cleanup levels from 1986 ROD.
b) RSLs accessed 12/28/2023 at https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables.
c) Cancer risks were calculated using the following equation, based on the fact that RSLs arc derived based on 1 x 10~6
risk: cancer risk = (cleanup goal ^ cancer-based RSL) x 10~6.
d) Noncancer HQ calculated using the following equation: HQ = cleanup goal ^ noncancer-based RSL.
e) RSLs for trivalcnt chromium were used because the 1986 ROD confirmed that chromium it is not present in the
hcxavalent form.
f) Lead screening value calculated for soil using the adult lead methodology with a target blood lead level of 5 ng/dL
and default parameters. The cleanup goal is directly compared to the screening level.
- = toxicity criteria not established
mg/kg = milligrams per kilogram
N/A = not applicable
OU-2 Cleanup Levels and Standards Review
Surface Water
Surface water cleanup levels for the protection of aquatic life and include the N RWQC-CCC chronic criteria for
arsenic and ammonia and the Great Lakes Water Quality Initiative Tier 11 methodology for benzene. Table 1-2
compares surface water cleanup levels to current standards. Table 1-2 show s that the standard for ammonia has
changed and become more stringent. EPA updated the ammonia criteria in 2013 to account for the latest
freshwater toxicity information, including toxicity studies for sensitive unionid mussels and gill-breathing snails.
The updated criteria are more stringent than the previously recommended 1999 criteria. The duration components
of the 1999 and 2013 criteria remain the same, which is a 30-day average duration for the chronic criteria. The
frequency component for the chronic criteria remains once in three years on average. In addition, the Tier 11
benchmark established by the Great Lakes Water Quality Initiative for benzene has become less stringent. The
benzene cleanup level remains protective because it is more stringent than the most current Tier 11 benchmark.
1-1
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Table 1-2: QtJ-2 Surface Water Cleanup Standards
COC
Cleanup Level
Basis
Current Standard
Standard
Change
Arsenic
150 ng/L
NRWQC-CCC (chronic)
150ap.g/L
No change
Benzene
46 ng/L
Tier 11 benchmark
(chronic)
97.08b ng/L
Less stringent
Ammonia
4.5 (mg/L)°
(Chronic 30-day rolling
average)
NRWQC-CCC (chronic)
1.9dmg/L
More stringent
Notes:
a) Current NRWQC standards accessed on 1/3/2024 at https://www.epa.gov/wqc/national-recommended-water-
qualitv-criteria-aquatic-life-criteria-table.
b) The Great Lakes Initiative Tier 2 chronic benchmarks were revised in 2013. The Tier 2 levels for benzene range
from 97.08 to 210 ng/L depending on different acute to chronic ratios; the most stringent Tier 2 level is listed.
These 2013 values arc located in a downloadable database at the following website:
https://www.epa.gov/svstem/files/other-files/2023-10/gliclear v220.zip.
c) The surface water cleanup standard for ammonia is set at the NRWQC-CCC value for Fish Early Life Stages
Present as established by EPA in 1999 based on the total ammonia nitrogen (in milligrams per total ammonia
nitrogen per liter or mg/TAN/L), not to be exceeded more than once every three years on average and is
temperature and pH dependent. The criterion values presented are based on pH 7 and 20°C for comparison
purposes. The criterion is not to be exceeded more than once in three years on average. In addition, this should not
exceed 2.5 times the criterion continuous concentration as a four-day average within a 30-day period.
d) EPA updated the criterion in 2013 to account for additional sensitive species. The criterion values presented are
based on pH 7 and 20°C for comparison purposes. The criterion is not to be exceeded more than once in three
years on average. In addition, this should not exceed 2.5 times the criterion continuous concentration as a four-day
average within a 30-day period. Value obtained from: https://www.epa.gov/sites/default/files/2015-
08/documents/fact sheet aqiiatic-life-ambient-water-ciuality-criteria-for-ammonia-freshwater-2013.pelf
NRWQC = National Recommended Water Quality Criteria
CCC = criterion continuous concentration
Sediment
EPA established sediment cleanup levels for the HBHA Pond and Lower South Pond for the protection of aquatic
life for arsenic and benzene, respectively. The arsenic cleanup standard for the HBHA Pond is the lowest
observed effects level for benthic invertebrates for survival and/or growth exposed to pond sediments (Table 1-3).
The benzene standard for the Lower South Pond was calculated using a conservative water quality guideline for
the protection of sensitive aquatic organisms and an equilibrium partitioning method. These values remain valid
as the basis for these ecological risk values has not changed and the methodology for calculating these values has
not changed.
Table 1-3: OU-2 Sediment
Cleanup Standards for the Protection of Ecological Receptors
COC
Cleanup Level
(mg/kg)
Basis
HBHA Pond
Arsenic
273a
LOAEL
Lower South Pond
Benzene
1.29b
Ecological protection"
Notes:
a) From the Site's 2006 ROD. page 102.
b) From the Site's 2014 ESD, page 10.
c) Calculated using a conservative water quality guideline for the protection of sensitive aquatic
organisms and an equilibrium partitioning method (see Attachment 1 of the 2014 ESD).
LOAEL = lowest observed adverse effects level for bcnthic invertebrates
1-2
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Soil Sediment and Groundwater
The 2006 ROD updated the groundwater performance standards to levels protective for non-potable uses based on
site-specific risk assessment for a process water worker or a car wash scenario. Similarly, the 2006 ROD for OU-
2 set soil and sediment cleanup standards for arsenic and/or benzo(a)pyrene for various areas of the Site (Former
Mishawum Lake Bed Area. Near-Shore CBCA. Near-Shore Wells G&H Wetland, and Deeper Interior HBHA
Wetland and Wells G&H Wetland), based on site-specific uses of those areas. To determine if the site-specific
cleanup standards remain valid, rather than recreating the cleanup goals using risk assessment methodology, the
toxicity values were evaluated to see if there were any updates to the values since the 2006 ROD. If the toxicity
values have not changed, then the cleanup goals would remain valid for the exposure scenarios evaluated. As
show n in Table 1-4, TCE was the only COC where the toxicity value became more stringent. The current
inhalation RfC is 20-fold lower than the value in the 2006 ROD. The groundw ater cleanup level (1 ug/L based on
the indoor car wash scenario) is associated with a noncancer hazard index of 0.02 (cancer was the driver for the
selection of the cleanup level; see 2006 ROD Table L-l). Therefore, adjusting for the increased toxicity of TCE
would result in the groundw ater cleanup level being associated with a noncancer hazard index of 0.4, below the
acceptable noncancer hazard index of 1. Therefore, the changes in toxicity values do not affect the protectiveness
of the remedy.
Table 1-4: Toxicity Values Used to Develop the OU-2 Performance Standards Versus Current Toxicity
Values
COC
Noncancer Toxicity Values
Carcinogenic Toxicity Values
Oral
(mu/k
RfD
ijAJa.v)
Inhalation RfC
(m«/mJ)
Oral
(mu/ks.
CSF
/(lay)"1
IUR
(iig/m3)"1
2006111
2023b
2006"
2023b
2006"
2023h
2006"
2023b
Ammonia
NTV
NTV
IE-0I
5E-0 i
NTV
NTV
NTV
NTV
Arsenic"
3E-04
3E-04
ND
ND
1.5E+00
1.5E+00
4.3E-03
4.3E-03
Bcn/o(a)pvrcnc
NA
NA
NA
NA
NA
NA
NA
NA
Bcn/cnc
4E-03
4E-03
3E-02
3E-02
5.5E-02
5.5E-02
7.8E-06
7.8E-06
1.2-
Dichlorocthane
NTV
NTV
5E-03
7E-03
9.1E-02
9.1E-02
2.6E-05
2.6E-05
Naphthalene
2E-02
2E-02
3E-03
3E-03
NTV
NTV
NTV
NTV
TCE
3E-04
5E-04
4E-02
2E-03
4.0E-01
4.6E-02
1.1E-04
4.1E-06
Notes:
a) The 2006 ROD adjusted the oral cancer and noncancer toxicity factors based on site specific bioavailability in
sediments, in addition to unadjusted toxicity values. This toxicity review used the unadjusted toxicity values
from the 2006 ROD listed in Table G-8 (Cancer Toxicity Data Summary) and Table G-9 (Noncancer Toxicity
Data Summary).
b) Values obtained from EPA's IRIS or from EPA's Provisional Peer-Reviewed Toxicity Values.
Bold Value = value is more stringent or is a new toxicity value.
NA = toxicity values were not evaluated since the site cleanup is based on a background concentration, which is
not a risk-based value. CERCLA cannot require responsible parties to clean up sites to levels below background.
NTV = no toxicity value
RID = reference dose
RfC = reference concentrations
CSF = cancer slope factor
IUR = inhalation unit risk
ing/kg/day = milligram per kilogram per day
mg/m3 = milligrams per cubic meter
Hg/m3 = micrograms per cubic meter
Source of2006 toxicity values: Carcinogenic oral and inhalation toxicity values from MSGRP baseline risk
assessment.
Source of2023 toxicity values: EPA's IRIS as denoted by the letter I in EPA's November 2023 RSL table.
1-3
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Table 1-5
OU-2 Adult Worker Lead Evaluation for Average Soil Concentration of 1,223 mg/kg
Calculations of Blood Lead Concentrations (PbBs) and Risk in Nonresidential Areas
U.S. EPA Technical Review Workgroup for Lead
Version date 06/14/2017 Edit Red Cells
Variable
Description of Variable
Units
CbVi and PbBo
from Analysis of
NHANES 2009-
2014
PbS
Soil lead concentration
pq/q or ppm
1223
Rfetal/matemal
Fetal/maternal PbB ratio
—
0.9
BKSF
Biokinetic Slope Factor
pg/'dL per
un/dav
0.4
GSD,
Geometric standard deviation PbB
1.8
PbBo
Baseline PbB
pq/dL
0.6
IRs
Soil ingestion rate (including soil-derived indoor dust)
g/day
0.050
IRs+d
Total ingestion rate of outdoor soil and indoor dust
g/day
—
Ws
Weighting factor; fraction of IR5+D ingested as outdoor soil
-
—
Ksd
Mass fraction of soil in dust
—
—
AF5, D
Absorption fraction (same for soil and dust)
—
0.12
EFs,d
Exposure frequency (same for soil and dust)
days/yr
150
at=.d
Averaging time (same for soil and dust)
days/yr
365
PbBadult
PbB of adult worker, geometric mean
pq/dL
1.8
PbBfetai^ 0.95
95tli percentile PbB among fetuses of adult workers
uq/dL
4.3
PbBt
Target PbB level of concern (e.g., 2-8 ug/dL)
pq/dL
5.0
P( PbBfetal > PbBt)
Probability that fetal PbB exceeds target PbB, assuming
lognormal distribution
%
2.8%
1-4
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APPENDIX J - LEAD SCREENING LEVEL CHECKLIST
Residential Lead Screening Level Checklist
Site Information
Site or study area name
INDUSTRI-PLEX
Location (City/County, State, Zip)
WOBURN, MA
SEMS EPA ID
MAD076580950
Current remedial pipeline phase
POST CONSTRUCTION
Does a site boundary exist in SEMS?
Kl Yes ~ No
Briefly describe any removal or
remedial work completed to date,
including previous screening levels
Majority of site is non-residential use. Recently, the land use at some site properties were modified to residential use. Risk
evaluations were conducted to verify acceptability of this new land use, including lead-related risks in soil. Exposure point
concentrations in these residential areas were less than 200 ppm.
Briefly describe the geographic scope
of the study area that was considered
while completing the checklist
Full site boundary
Checklist completed by:
Name
Title and Organization
Date
Matthew Audet
Chief, MASuperfund Section
3/4/24
Table 1: Evaluate Primary Data Sources in "Residential Lead GIS Screening Tool" [**Ctrl+Click here to access GIS tool**1
Yes
No
¦?
Question
Data Evaluation Notes
References
~
m
~
Is the study area in a NAAQS
nonattainment zone for lead?
SCREENSHOT ATTACHED
EPA Green Book provides detailed information
about NAAQS designations
~
(El
~
Does the EJScreen Lead Paint Index
data demonstrate that a majority of
the homes in the study area are at or
above the 80th percentile?
SCREENSHOT ATTACHED
EJ Screen Environmental Indicators
Census Bureau housine data tools
American Community Survey data
~
~
Are you able to you select a screening
level based on these primary data
sources?
Kl Yes: 200 ppm ~ Yes: 100 ppm ~ No: continue with checklist
If yes, skip to the last page to summarize the weight of evidence and to document approval.
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Table 2: Evaluate Secondary Data Sources on Potential Lead Exposures
Yes
No
p
Question
Data Evaluation Notes
References
~
~
~
Are you aware of any potential soil
exposures due to deteriorating exterior
lead-based paint?
EPA Regional Lead-Based Paint Contacts
~
~
~
Are there facilities in the study area with
known lead violations?
Search for facilities to assess their compliance
Check with state and local contacts for facilities
not subject to EPA authorities
~
~
~
Are you aware of lead pipes and/or lead
service lines in the study area?
Check with the state's drinking water program
Check local drinking water quality annual reports
~
~
~
Among the schools in the study area, are
there drinking water reports or testing
that indicate lead exposures?
The local public water department may have
more information
Check local drinking water quality annual reports
EPA contacts for voluntary_testing in schools
~
~
~
Are you aware of any local cultural
practices or community activities that
may involve lead? (e.g., ceremonial uses,
traditional medicines, pottery/jewelry
making)
EPA resources on lead in cultural products
~
~
~
Are there reports or data demonstrating
elevated blood lead levels (BLL) in
children in the study area? (If so, do
reports indicate meaningful trends?)
Local Health Department may have more
information
CDC childhood lead Doisonine prevention data
and statistics
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Table 3: Evaluate Mitigation Efforts
Yes
No
Question
Data Evaluation Notes
References
~
~
~
Does the state, tribe, or territory have
an EPA-authorized lead-based paint
program?
Lead-based paint abatement programs
RRP program information
Identify authorized professionals
EPA Regional Lead-Based Paint Contacts
~
~
~
Is the study area covered by a lead
ordinance or local lead laws? (e.g., real
estate disclosure, dust hazard
mitigation, building codes, permits or
requirements for renovations)
Check with the state and local government
authorities to find out about lead laws and
ordinances specific to the area.
Learn about federal lead laws and regulations
Real estate disclosures about potential lead
hazards
~
~
~
Are you aware of whether older homes
and/or schools have addressed lead-
based paint through mitigation,
encapsulation, or renovation?
Check with your regional Lead-Based Paint
Coordinator, the local health department,
education department, or school district(s) for
this information.
How to check for lead hazards in schools and
childcare facilities
~
~
~
Are you aware of whether lead service
lines have been replaced or are
scheduled to be replaced?
Check with the local public water department for
more information
~
~
~
Have there been other previous
initiatives to directly address lead
exposures in the study area? (If yes,
add notes on the outcome, including
successes, challenges and gaps in
effectiveness.)
Check with your state or local health department
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Additional Notes
Document any additional findings not addressed by the items specified in the checklist, including any input from key points of contact in other lead programs in the
region or other federal, state and local agencies.
From 2024 Five Year Review: The cleanup level for OU-1 soil (600 ppm) was established to protect industrial workers. As the Adult Lead Methodology sets a lead soil
screening level at 1,000 ppm for commercial/industrial exposures, the existing cleanup level of 600 ppm remains protective of industrial workers. This update to the
Region 1 lead strategy does not impact the current protectiveness of the remedy for the industrial portions of the site. Land use changes were evaluated for two
properties (120 Commerce Way and 200 Presidential Way) associated with OU-1 where individual baseline risk assessments were performed to assess future
residential purposes. The land use change for these two properties was documented in the 2018 ESD. Similarly, the 2023 ESD evaluated an area (Lot IC-32 and a
portion of IC-28) assuming a residential exposure. The lead evaluations for these properties were updated using the 200 ppm lead screening value established in the
2024 OLEM memorandum and concluded that the average lead concentrations were below the residential screening value as follows: 33 ppm for subsurface soil for
the 2018 ESD; and 55 ppm for top soil and 90 ppm for subsurface soil for the 2023 ESD. For OU-2, lead was selected as a COPC in two areas of the site (near HBHA Pond
and in the area of the former Mishawum Lake where the OU-2 remedy requires the institutional controls restricting residential, daycare and school uses on these
properties), with an average lead concentration of approximately 1200 ppm. Because the exposure point concentration exceeds the industrial screening level of 1,000
ppm, the Adult Lead Methodology was run using a site-specific exposure frequency and default model assumptions. The model results showed the < 5% of children
(fetuses of exposed women) could exceed a target blood lead level of 5 |ug/dL goal is achieved. In addition, the time-weighted lead exposure point concentration for
children is below the site-specific screening level of 200 ppm.
Recommended Regional Screening Level
Select the appropriate screening level and summarize the weight of evidence assembled above.
200 ppm
~ 100 ppm
MATTHEW 2024.05.22
AUDET 09:21:59-04'00'
Approved By [Type Name, Title] Date
Version 1 - February 2024 4
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]
Meadow
Residential Lead GIS Screening Tool wrth ArcGis Web AppBuitder
Find address or place
5
Superfund Site Boundaries: INDUSTRI-PLEX
ft
<$>
NPL Superfund Site Boundaries (EPA Public)
Nonattainment Areas and Designations -
Lead (2008 standard)
Lead Paint Indicator (EJScreen 2.2
September 2023)
Lead Paint
^ at least 95%ile
2: 90-94%ile
80-89%ile
1
EPA Region
^ EPA Program
EPA ID
Site Name
Feature Class
/ Feature Type
Feature Name
Feature
Description
1
Superfund Remed al
MAD0765B0950
INDUSTRI-P-EX
Site Boundary
Extent of Contamination
Approximate ndustr -P ex Site
Bouncary
The ndustr-P.ex Superfund Sr
former cher~ cal and c -e
manufacturing fac ty located i
Woburn Massachusetts. Indus'
was ^sec forma^-fscturng
chem cals such as ead-arsenic
insecticides, acet c acid, and si
ec d for ocal text e. leathe' er
Woburn
_,i, TcmTom, Garmin, SafeGranh, GeoTechna
Version 1 - February 2024
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