Sixth Five-year Review Report for Wells G&H Superfund Site Middlesex County Massachusetts


SIXTH FIVE-YEAR REVIEW REPORT FOR

WELLS G&H SUPERFUND SITE
MIDDLESEX COUNTY, MASSACHUSETTS



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Prepared by

U.S. Environmental Protection Agency
Region 1
Boston, Massachusetts

Digitally signed by BRYAN

BRYAN OLSON 0LS0N

Date: 2024.05.30 16:44:06
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	6

FIVE-YEAR REVIEW SUMMARY FORM	8

II.	RESPONSE ACTION SUMMARY	8

Response Actions and Basis for Taking Action	8

Status of Implementation of the OU-1 Remedy	13

Institutional Controls	16

Systems Operations/Operation & Maintenance (O&M)	17

III.	PROGRESS SINCE THE PREVIOUS REVIEW	19

IV.	FIVE-YEAR REVIEW PROCESS	22

Community Notification. Community Involvement and Site Interviews	22

Data Review	23

Site Inspection	30

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'.'	35

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	45

APPENDIX A - REFERENCE LIST	A-l

APPENDIX B - SITE CHRONOLOGY	B-l

APPENDIX C - PRESS RELEASE	C-l

APPENDIX D - INTERVIEW FORMS	D-l

APPENDIX E - OU-1 GROUNDWATER RESULTS SUMMARY	E-l

APPENDIX F - GRACE PROPERTY DATA REVIEW FIGURES AND TABLES 	F-l

APPENDIX G - UN I FIRST PROPERTY DATA REVIEW FIGURES AND TABLES	G-l

APPENDIX H - WILDWOOD PROPERTY DATA REVIEW FIGURES AND TABLES	H-l

APPENDIX I - NEP PROPERTY DATA REVIEW FIGURES AND TABLES	1-1

APPENDIX J - OLYMPIA PROPERTY DATA REVIEW FIGURES AND TABLES	J-l

APPENDIX K - SITE INSPECTION CHECKLISTS	K-l

APPENDIX L - SITE INSPECTION PHOTOS	L-l

APPENDIX M - SOIL CLEANUP LEVELS REVIEW	M-l

APPENDIX N - ARARS REVIEW	N-l

APPENDIX O - VISL SCREENING	0-1

APPENDIX P - LEAD SCREENING LEVEL CHECKLIST	P-l

1

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LIST OF ABBREVIATIONS & ACRONYMS

AOC	Administrative Order on Consent

ARAR	Applicable or Relevant and Appropriate Requirement

AS	Air Sparge

ATSDR	Agency for Toxic Substances and Disease Registry

CASRN	Chemical Abstracts Service Registry Number

CERCLA	Comprehensive Environmental Response. Compensation, and Liability Act

CFR	Code of Federal Regulations

cis-1,2-DCE cis-1.2-Dichloroethene

COC	Contaminant of Concern

cPAH	Carcinogenic Polycyclic Aromatic Hydrocarbon

DDT	Dichlorodiphenyltrichloroethane

DEQE	Department of Environmental Quality Engineering

DNAPL	Dense Non-Aqueous Phase Liquid

EPA	United States Environmental Protection Agency

ESD	Explanation of Significant Differences

FDD A	Former Drum Disposal Area

FS	Feasibility Study

FYR	Five-Year Review

GAC	Granular Activated Carbon

GWETS	Groundwater Extraction and Treatment System

HFPO-DA	Hexafluoropropylene Oxide Dimer Acid

HQ-115/TFSI Lithium bis|(trifluoromethyl)sulfonyl|azanide (HQ-115)

ICs	Institutional Controls

IRIS	Integrated Risk Information System

I SCO	In-Situ Chemical Oxidation

J	Estimated value

MassDEP	Massachusetts Department of Environmental Protection

MCL	Maximum Contaminant Level

MCLG	Maximum Contaminant Level Goal

MCP	Massachusetts Contingency Plan

mg/kg	milligrams per kilogram

mg/kg-day	milligrams per kilogram per day

MMCL	Massachusetts Maximum Contaminant Level

MRL	Minimal Risk Level

(.ig/dL	micrograms per deciliter

(.ig/L	micrograms per liter

(ig/m3	micrograms per cubic meter

NAAQS	National Ambient Air Quality Standards

NAPL	Non-Aqueous Phase Liquid

NCP	National Oil and Hazardous Substances Pollution Contingency Plan

ND	Not Detected

NEP	New England Plastics

ng/L	nanograms per liter

NPL	National Priorities List

O&M	Operation and Maintenance

OHHRRAF OLEM's Human Health Regional Risk Assessment Forum

OLEM	Office of Land and Emergency Management

OU	Operable Unit

PCB	Polychlorinated Biphenyl

PCE	Tetrachloroethene

PDI	Pre-Design linestigation

PFAS	Per- and Polyfluoroalkyl Substances

2

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PFBA

Pcrfluorobutajioic Acid

PFBS

Perfluorobutanesulfonic Acid

PFDA

Perfluorodecanoic Acid

PFDoDA

Perfluorododecanoic Acid

PFHpA

Pc rfl u o roll c ptano i c Acid

PFHxA

Perfluorohexanoic Acid

PFHxS

Perfluorohexanesulfonic Acid

PFNA

Pc rfl uorononanoic Acid

PFOA

Pc rfl uorooctanoic Acid

PFODA

Pcrfluorooctadccajioic Acid

PFOS

Pc rfl uorooctancsu 1 fon ic Acid

PFPrA

Perfluoropropanoic Acid

PFTetA

Pcrfluorotctradccajioic Acid

PFUDA

Pc rfl uoroundccanoic Acid

PID

Photoionization Detector

PPA

Prospective Purchaser Agreement

PPb

Parts per Billion

PPm

Parts per Million

PPRTV

Provisional Peer Reviewed Toxicity Value

ppt

Parts per Trillion

PRP

Potentially Responsible Party

RAO

Remedial Action Objective

RfC

Reference Concentration

RfD

Reference Dose

RI

Remedial Investigation

ROD

Record of Decision

RPM

Remedial Project Manager

RSL

Regional Screening Level

SD

Settling Defendant

SVE

Soil Vapor Extraction

SVET

Soil Vapor Extraction and Treatment

TBC

To Be Considered

TCA

Trichloroethane

TCE

Trichloroethene

UU/UE

Unlimited Use and Unrestricted Exposure

VISL

Vapor Intrusion Screening Level

VOC

Volatile Organic Compound

ZVI

Zero-Valent Iron

3

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I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR reports such as this one. In addition. FYR reports
identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response. Compensation, and Liability Act (CERCLA) Section 121. consistent with the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section
300.430(f)(4)(ii)), and considering EPA policy.

This is the sixth FY R for the Wells G&H Superfund site (the Site). The triggering action for this statutory review
is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants
or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of three operable units (OlJs). as presented in Table 1. Figure 1 shows the approximate locations
of the OlJs (OU-1, OU-2 and OU-4). Another OU (OU-3, known as Aberjona River Study) was merged with OU-
2 of the neighboring Industri-Plex Superfund site in 2002, and documented in the January 2006 ROD entitled
Industri-Plex Superfund Site Operable Unit-2 (and including Wells G&H Superfund Site Operable Unit-3,
Aberjona River Study). This 2006 ROD established a surface water and sediment cleanup decision for Wells
G&H OU-3 Aberjona River Study. Further evaluation of the OU-3 Aberjona River Study, including FYRs. is
conducted as part of activities at the Industri-Plex Superfund site.'

Table 1: Site OUs

OU

Description

Area(s) Addressed by OU

OU-1

Source Area Properties

W.R. Grace (Grace) Property

UniFirst Corporation (UniFirst) Property

New England Plastics (NEP) Property

Wildwood Conservation Corporation (Wildwood) Property

Olvmpia Nominee Trust (Olvmpia) Property

OU-2

Central Area

All groundwater and land masses within the site boundary except for
areas covered by OU-1 and OU-4.

OU-4

Southwest Properties

Aberjona Auto Parts ( Aberjona) Property
Whitney Barrel (Whitney) Property
Murphy's Waste Oil (Murphy) Property

This FYR addresses only OU-1 because it is the only OU with an initiated remedial action. OU-2 is not addressed
in this FYR because it does not yet have a Record of Decision (ROD) for remedial action; the remedial
investigation/feasibility study (RI/FS) for OU-2 is ongoing. EPA signed a ROD for OU-4 in September 2017 and
entered an OU-4 Consent Decree with Settling Defendants (SDs) in 2020 to perform the response actions, but the
remedial action has not been initiated; OU-4 is currently in the remedial design stage. The Response Actions
Summary of this FYR Report presents a summary of the remedy planned for OU-4.

EPA remedial project manager (RPM) Joseph F. LeMay, P.E., led the FYR. Participants from EPA included risk
assessor Paulina Do and site attorney Susan Scott. Jennifer McWeeney from the Massachusetts Department of
Environmental Protection (MassDEP) and kirby Webster and Jill Billus from EPA FYR contractor Skeo also
participated in the review, as well as EPA's oversight contractor HydroGeoLogic (HGL). The SDs were notified
of the initiation of the FYR. The review began on September 12, 2023.

1 The cleanup decision for the OU-3 Aberjona River Study is documented in EPA's January 2006 Record of Decision for
Industri-Plex Superfund Site Operable Unit-2 (and including Wells G&H Superfund Site Operable Unit-3, Aberjona River
Study). More information about the Industri-Plex Superfund site is available on EPA's site profile page at

www.epa.gov/siiperfimd/industriplex.

4

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Figure 1: Site Vicinity Map

Disclaimer This map and any boundary lines within the map are approximate and
subject to change The map is not a sun/ey The map is for informational purposes
only regarding EPA's response actions at the Site Map image is the intellectual
property of Esn and is used herein under license. Copyright © 2020 Esri and its
licensors All nghts reserved Sources: Esri. Map data OpenStreetMap contributors.
Microsoft. Facebook. Inc. and its affiliates. Esri Community Maps Contributors Map
layer by Esri. Maxar, TomTom. Garmin, SafeGraph, GeoTechnologies, Inc.. MET!/
NASA. USGS. EPA. NPS. US Census Bureau. USDA. USFWS. the 2019 FYR
Report and the 2023 Monitoring Well Installation Work Plan.

N Wells G&H Superfund Site

A City of Woburn, Middlesex County, Massachusetts

Last Modified: 5/21/2024

Approximate Site Boundary

OU-1

OU-2

OU-4

Surface Water
Rail Line

Former Municipal Well

OU-3 Aberjona River Study is now part
' - of Industri-Plex Superfund Site OU-2.

5

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Site Background

The approximately 330-acre Site is in the City of Woburn in Middlesex County. Massachusetts (Figure 1). It
includes the aquifer and land within the zone of contribution of two former municipal drinking water wells known
as Wells G and H. located next to the Aberjona River. The boundaries of the Site are Interstate 95 to the north.
Interstate 93 to the east, the Massachusetts Bay Transportation Authority rail line to the west, and Salem Street to
the south.

In May 1979, the Massachusetts Department of Environmental Quality Engineering (DEQE. now MassDEP).
discovered chlorinated volatile organic compound (VOC) contamination in Wells G and H; the wells were
immediately shut down. OU-1, the subject of this FYR. consists of the five Source Area Properties found to
contribute to the contamination in the former municipal wells. They include the W.R. Grace (Grace) property, the
Uni First Corporation (UniFirst) property, the New England Plastics (NEP) property, the Wildwood Conservation
Corporation (Wildwood) property and the Olympia Nominee Trust (Olympia) property. Figure 2 shows the
approximate locations of the OU-1 Source Area Properties.

The Site is in a highly developed and populated area, which consists of a mix of light industry, commercial
businesses, office and industrial parks, residences, and recreational properties. Many of the OU-1 Source Area
Properties have been in continued use or have been redeveloped:

• Grace property: Between 2014 and 2019, the property was sold, and the new owners redeveloped
the Grace property into the Woburn Landing commercial space; it includes a hotel, two
restaurants, and one currently unoccupied restaurant building.

• Uni First property: The Uni First property houses a self-storage facility. In 2021, the property
owner added a 0.3-megaw att rooftop solar array on the facility's building.

• NEP property: NEP continues to operate as a plastics fabricator on its property.

• Wildwood property: The Wildwood property is undeveloped and primarily contains wooded and
wetland areas.

• Olympia property: The northeast part of the Olympia property is in use by a trucking terminal, a
shipping facility, a church, and other businesses. The southern and southwestern part of the
property, next to the Aberjona River, is undeveloped.

The Aberjona River runs through the western part of the Site and eventually reaches the Mystic Lakes in
Winchester as part of the Mystic River watershed. A substantial wetland area associated with the river's
floodplain is located on either side of the river on-site.

Groundwater at the Site occurs in two principal formations - the sand and gravel (overburden) formation and a
bedrock formation.2 The two formations are separated in a few areas by a thin deposit of glacial till. The sand and
gravel aquifer yields the largest quantities of water in the area. Wells G and H were located in the sand and gravel
aquifer. The general direction of groundwater flow is from upland areas east, west and north of the Aberjona
River valley southward. The Aberjona River and its wetlands are a seasonal discharge area. Groundwater from the
aquifer flow s upw ard discharging into these surface water bodies.

Groundw ater at the Site is no longer used as a drinking water source. The City of Woburn uses the Horn Pond
water as its major water supply.

Appendix A provides a list of the documents reviewed for this FYR. Appendix B provides a chronology of major
site events.

2 Throughout this FYR Report, the sand and gravel formation is also referred to as overburden or unconsolidated deposits.

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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 sun/ey. 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 Esri and its
licensors. All rights reserved. Sources: Esri, Map data OpenStreetMap
contributors, Microsoft, Facebook, Inc. and its affiliates, Esri Community Maps
Contributors, Map layer by Esri, Maxar, TomTom, Garmin, SafeGraph,
GeoTechnologies, Inc.. METI/NASA, USGS, EPA, NPS, US Census Bureau,
USDA, USFWS and the 2019 FYR Report.

Wells G&H Superfund Site

City of Woburn, Middlesex County, Massachusetts

Last Modified: 1/28/2024

Figure 2: OU-1 Source Area Properties Mai

UniFirst

Olympia

Well G

H|||H

Wildwood

^	„•»1K k

Approximate Site Boundary
I I OU-1

Former Drum Disposal Area
Wetlands
Surface Water
^ Former Municipal Well

7

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FIVE-YEAR REVIEW SUMMARY FORM

SITE IDEM II IC A I ION

Site Name: Wells G&H

EPA ID: MAD980732168

Region: 1

State: MA

City/County: Woburn/Middlesex

SITE S I A 1 I S

| NPL Status: Final |

Multiple OUs?
Yes

Has the site achieved construction completion?

REVIEW S I A 1 I S

Lead agency: EPA

Author name: Joseph F. LeMay, P.E.

Author affiliation: EPA

Review period: 9/12/2023 - 5/23/2024

Date of site inspection: 12/5/2023 and 12/6/2023

Type of rev iew: Statutory

Review number: 6

Triggering action date: 5/30/2019

Due date (fiveyears after triggering action date): 5/30/2024

II. RESPONSE ACTION SUMMARY
Response Actions and Basis for Taking Action

Initial Response

In May 1979, the Wobum Police Department found 184 drums containing polyurethane and toluene di-isocyanite
on a vacant lot in Wobum. As a result. Massachusetts DEQE sampled the nearest dow ngradient water supply
(Wells G and H) and identified chlorinated VOC contamination in the samples. The City of Wobum immediately
shut down Wells G and H and arranged for an alternative water supply with the Metropolitan District
Commission, now the Massachusetts Water Resources Authority.

In 1981, EPA conducted a hydrogeologic investigation and groundwater quality evaluation in Wobum. Based on
the investigation. EPA identified potential sources of contamination to the aquifer that services Wells G and H
(i.e., the five OU-1 Source Area Properties). As a result of the contamination. EPA listed the Site on the
Superfund program's National Priorities List (NPL) in September 1983.

In 1983, EPA issued administrative orders to Grace. UniFirst and Beatrice Foods. Inc. (for the Wildwood
property), requiring them to study contamination on their properties. The companies then initiated groundwater
monitoring programs at their properties.

In 1986 and 1987, EPA issued two separate orders to Olympia Nominee Trust to remove 17 drums and debris
from their property in an area known as the Former Drum Disposal Area (FDDA) (Figure 2). Olympia completed

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the removal actions. Also in 1987, EPA issued an administrative order to Uni First to install additional monitoring
wells on its property.

EPA conducted the Site's remedial investigation (Rl) from 1986 to 1988 and issued the initial Rl Report in 1986
and a Supplemental Rl Report in 1988 supporting the 1989 OU-1 ROD. The Rl identified contaminated soil,
sludge and/or groundwater at the five Source Area Properties (Grace. UniFirst. NEP, Wildwood and Olympia). all
within about 1 mile of Wells G and H. Contamination at the Olympia property was confined to the FDDA
(Figure 2).

Basis for Taking Action

EP A completed an Endangerment Assessment in 1988 that included evaluation of potential impacts on human
health and the environment. The greatest potential risks identified at the OU-1 Source Area Properties were
attributed to ingestion of contaminated groundwater, inhalation of volatiles while showering, and exposure to
surface soils through dermal contact and incidental ingestion. Chlorinated VOCs were detected in groundwater at
concentrations above levels considered to be protective. Concentrations of pesticides, polychlorinated biphenyls
(PCBs). lead and carcinogenic polycyclic aromatic hydrocarbons (cPAHs) in soil/sludge were present at levels
that would endanger public health if ingested or derm ally contacted in a future residential setting. Table 2 lists the
OU-1 contaminants of concern (COCs).

Table 2: OU-1 COCs

coc

Groundwater

Soil
(leaching to

groundwater)

Soil

(direct contact)

Chlordane

—

cPAHs

—

Chloroform

—

4,4'- Dichlorodiphcnvltrichlorocthanc (DDT)

—

1,1 -Dichlorocthanc

—

1,2-Dichloroethane

—

1,1 -Dichloroethene

—

Lead

—

PCBs

—

Tctrachlorocthcnc (PCE)

—

Trichlorocthcnc (TCE)

—

trans-1,2-Dichloroethene

—

1.1.1-Trichlorocthanc (TCA)

—

Vinvl chloride

—

Notes:

X = identified as a COC for the medium.
- = not a COC for the medium.

Source: Tables 5, 6 and 7 of the Site's 1989 ROD; lead is identified as a COC on page 30 of the 1989 ROD.

OU-1 Remedy Selection

EPA selected the remedy for OU-1 in a 1989 ROD and updated it in a 1991 Explanation of Significant
Differences (ESD). The OU-1 ROD identified the follow ing remedial action objectives (RAOs) for OU-1:

Groundwater

• Prevent the further introduction of contaminated groundw ater from the Source Areas (OU-1) to the
Central Area (OU-2).

• Limit the further migration of contaminated groundw ater off-site from the Source Areas.

• Restore the bedrock and overburden aquifers in the vicinity of the Source Areas to drinking water quality.

• Prevent public contact with contaminated groundwater above the cleanup levels.

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Soil

• Prevent public contact with contaminated soil above the cleanup levels.

• Stop the leaching of soil contaminants to the groundw ater.

• Protect the natural resources at the Site from further degradation.

The OU-1 ROD outlined an approach to first address contamination at the OU-1 Source Area Properties to reduce
infiltration from source soil/sludge and prevent migration of contamination toward the Central Area aquifer (OU-
2).

The selected remedy for OU-1 included:

• Treatment of contaminated soil using in-situ volatilization at the Wildwood property.

• Excavation and on-site incineration of contaminated soils at the Wildwood. Olympia. NEP and Uni First
properties.

• Treatment and/or disposal of sludge and debris at the Wildw ood property in a manner to be determined
during remedial design.

• Extraction and treatment of contaminated groundwater separately at the five properties using pre-
treatment for metals and an air stripper to remove contaminants. The extraction systems were to be
designed to address the specific bedrock and/or overburden contamination at each source area property.
Treatment technologies other than air stripping may be considered for implementation of the groundw ater
remedy if they can be demonstrated to be equally or more effective, as approved by EPA.

• Groundwater monitoring to determine compliance with cleanup goals.

At the time of the OU-1 ROD. there was no soil found at the Grace property with COC concentrations above
cleanup levels. Consequently, the ROD did not call for soil removal at the Grace property.

EPA's 1991 ESD described three significant changes and one minor change from the remedy specified in the
OU1 ROD. as follows:

• On-site incineration of soils at the Wildw ood. Olympia and NEP properties was changed to off-site
incineration.

• On-site incineration of soils at the Uni First property was changed to in-situ volatilization.

• Groundw ater extractions systems could be combined for the Uni First and Grace properties.3

• A typographical error was corrected resulting in more stringent target cleanup levels for groundwater.

In March 2003, EPA issued an Action Memorandum to conduct source removal activities at the Olympia
property. The Action Memorandum documented that data collected at the Site since the Rl indicated higher levels
of PCBs and trichloroethene (TCE) than previously believed to exist at the property. The 2003 Action
Memorandum identified the follow ing removal actions for the Olympia property, which updated the source
control components of the remedy selected in the OU-1 ROD:

• Excavate PCB-contaminated surface soils.

• Address TCE-contami nated subsurface soils through a combination of treatment, excavation and/or
capping in place.

• Dispose of waste streams at approved off-site disposal facilities.

• Restore disturbed areas of the Site to vegetative cover.

The Action Memorandum also noted that if subsurface soils are excavated, it was anticipated that sheet piling
would be needed to ensure a safe excavation and a dew atering/carbon treatment system would be needed to
handle VOC-contaminated groundwater infiltrating the excavation.

3 At the time of the 1991 ESD, the SDs had proposed a single extraction well at the UniFirst property to extract groundwater
from both the Grace and UniFirst properties. The final designed systems included extraction wells at both the UniFirst and
Grace properties (and separate treatment systems); however, UniFirst"s deep bedrock extraction system also captures deep
bedrock groundwater contamination from the Grace property.

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OU-1 Cleanup Levels

Tables 3 through 5 present the soil and groundwater cleanup levels for OU-1 from the OU-1 ROD and ESD.

Table 3: OU-1 ROD Cleanup Levels for Soil Based on Leaching to Groundwater

coc

Cleanup Level"-b (m«j/k«j)

Chloroform

0.0625

PCE

0.0367

TCE

0.0127

trans-1,2-Dichlorocthcnc

0.0832

1.1.1-TCA

0.613

Notes:

a) Cleanup levels arc from Table 5 of the 1989 ROD.

b) Cleanup levels arc based on the attainment of a target risk level in soils that
corresponds to attainment of applicable or relevant and appropriate requirements
(ARARs) in groundwater.

mg/kg = milligrams per kilogram

Table 4: OU-1 ROD Cleanup

..evels for Soil Based on Direct Contact

COC

Cleanup Level"- b-c (nig/kg)

Chlordanc

6.14

4,4'-DDT

23.5

cPAHs

0.694

PCBs

1.04

Lead

640

Notes:

a) Cleanup levels, except for lead, arc from Table 6 of the 1989 ROD. Lead cleanup
level is from page 30 of the 1989 ROD.

b) Cleanup levels, except for lead, arc based on the attainment of a target risk level of
10"6. The cleanup level for lead is based on a target blood lead level of 10 micrograms
per deciliter (ng/dL).

c) The Site's 1989 FS Report (Section 1.4.3.2) indicates that the soil cleanup levels were
based on future residential use.

Table 5: OU-1 ROD Cleanup Levels for Groundwater Used as Drinking Water

COC

Cleanup Level" b (fig/L)

Chloroform

100c

1,1 -Dichlorocthanc

1.2-Dichlorocthanc

1,1 -Dichlorocthcnc

PCE

TCE

trans-1.2-Dichlorocthcnc

70f

1,1,1-T richlorocthanc

200

Vinvl chloride

Notes:

a) Cleanup levels arc from Tabic 7 of the 1989 ROD.

b) Cleanup levels arc maximum contaminant levels (MCLs) in effect in 1989, unless

otherwise noted.

c) MCL is for total trihalomcthancs.

d) MCL is for 1.2-dichlorocthanc.

e) MCL is for TCE.

f) Proposed maximum contaminant level goal.

p,g/L = micrograms per liter

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OU-2 Remedy Selection and Current Status

A remedy has not yet been selected for OU-2, the Central Area aquifer. The RI/FS for OU-2 is ongoing.
OU-4 Remedy Selection and Current Status

OU-4, the Southw est Properties, comprises the contiguous properties of land on Salem Street known as the
Aberjona property, the Whitney property and the Murphy property (Figure 1). The Southwest Properties include a
wetland area (referred to as the Murphy Wetland) that extends along the northern border of the Southwest
Properties and into the OU-1 Wildwood property. The Southwest Properties have been used for various light
industrial operations for nearly 60 years. A detailed description of the Southwest Properties history is provided in
the 2016 OU-4 Rl Report and the 2016 OU-4 FS Report.

EPA selected the remedy for OU-4 in a September 2017 ROD. The selected remedy for OU-4 included:

• Excavation and off-site disposal of about 5,400 cubic yards of significantly contaminated soil at the
designated Northern Whitney Soil Area, and blending remaining contaminated soil below the water table
with an amendment (e.g., zero-valent iron |ZVI|) prior to backfilling to provide soil and localized
groundw ater treatment. In addition, excavation and off-site disposal of about 12,400 cubic yards of soil in
the Murphy upland. Whitney and Aberjona property areas to facilitate installation of impermeable caps.
Construction of impermeable caps over areas with low er concentration soils that exceed cleanup levels to
reduce soil exposure risks and/or prevent contaminant movement to groundwater.

• Excavation and off-site disposal of non-aqueous phase liquid (NAPL) in the Murphy and Whitney
property areas, including about 6,000 cubic yards of N A PL-contaminated soil and then blending any
remaining NAPL-contaminated soil below the water table with an amendment (e.g., ZVI) prior to
backfilling to provide soil and localized groundw ater treatment.

• Containment and cleanup of groundw ater contaminants throughout OU-4 by pumping and treating the
groundwater.

• Excavation and off-site disposal of about 7,000 cubic yards of wetland sediment/soil from the Murphy
Wetland exceeding cleanup levels and wetland restoration.

• Long-term monitoring and periodic FYRs.

• Institutional controls to maintain the integrity of the soil caps and other remedial components, to prevent
development of the properties for residential, school and daycare use (except on the Aberjona residential
area), to prohibit use of contaminated groundwater until cleanup levels are met and to require evaluation
of the vapor intrusion pathway if a change in usage of any of the existing buildings is contemplated or as
part of new building construction, including any addition/alteration to existing buildings on any of the
properties.

Tables L-l. L-2 and L-3 of the OU-4 ROD establish cleanup levels for groundwater, soil and wetland
sediment/soil, respectively, for the protection of human health. Table L-4 of the OU-4 ROD establishes wetland
sediment/soil cleanup levels for the protection of ecological receptors in the Murphy Wetland.

EPA entered into a Consent Decree with the OU-4 SDs in September 2020 to implement the OU-4 remedial
design/remedial action. EPA approved the Remedial Design Work Plan for the Southwest Properties in March
2021. Pre-design investigations (PDIs) as part of the OU-4 remedial design are ongoing. The Phase 1 PDI
Evaluation Report for the Southw est Properties Operable Unit 4 report was prepared in May 2023 and the 30%
Design Report was prepared in January 2024. The OU-4 SDs will continue the Phase 1 remedial design process
by preparing 95% and 100% Design Reports. Once the Phase 1 100% Design Report is approved and
implemented, the OU-4 remedy will be evaluated in future FYRs.

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Status of Implementation of the OU-1 Remedy

In 1991, EPA entered into a Consent Decree with four SDs (W.R. Grace Co. - Conn. Property, the Uni First
Corporation. New England Plastics, and Beatrice Company |for the Wildwood property |). in which the parties
agreed to implement the remedies selected in the 1989 OU-1 ROD and 1991 ESD for their own properties.
Olympia did not sign the Consent Decree. As required by the Consent Decree, a group of potentially responsible
parties (PRPs) also agreed to conduct the RI/FS for OU-2, which at the time included the Southwest Properties
(now OU-4).

In March 2003, Olympia entered into an Administrative Order on Consent (AOC) with EPA to address the
cleanup of cPAH and PCB-contaminated surface soils on the property. Olympia entered into a second AOC in
2004 for the removal of TCE-impacted soils within the FDD A.

Except for the lack of groundwater pump-and-treat systems at the Olympia and NEP properties, all components of
the OU-1 remedy response actions have been implemented or are currently being implemented. Improvements
have been made or are in the process of being made, where necessary, to optimize the remedial systems as a result
of ongoing performance monitoring. The 2014 FY R Report contains a thorough discussion of implementation
activities conducted at the Site. The sections below focus on recent activities and summarize historical remedial
activities for the five Source Area Properties.

Grace Property

The 1989 ROD. as modified by the 1991 ESD. called for extraction and treatment of contaminated groundw ater
and long-term monitoring of groundwater to determine compliance with the cleanup levels.

Groundwater Extraction and Treatment

In September 1992, Grace began operation of its long-term groundw ater extraction and treatment system
(GWETS). The system is designed to prevent contaminated groundwater in the unconsolidated deposits and
shallow bedrock from flow ing off-property, and to capture contaminated groundwater from the unconsolidated
deposits and shallow bedrock on the Grace property. Uni First deep bedrock extraction well UC-22 and treatment
system also captures contaminated groundwater in the deep bedrock underneath the Grace property, which is
consistent with the 1991 ESD.

With EPA approval, the GWETS has been modified overtime as contaminant concentrations have decreased. In
2002, Grace replaced the ultraviolet/oxidation treatment unit with two granular activated carbon (GAC) units. In
2010, recovery well RW22 was deepened to extend to 25 feet into bedrock and is now referred to as RW22RE.
The number of operating recovery wells has also been reduced from the initial 22 wells at system startup to three
(R W1 7. RW20 and RW22RE), as of June 2015. The remedial system completed its 31st year of operation in
September 2023. Groundw ater sampling continues to be performed to assess the progress of the remedial actions
in achieving cleanup levels. The Data Review section of this FYR Report discusses recent groundw ater
monitoring results for the Grace property.

In response to a recommendation in the Site's Third FYR Report (2009), Grace collected groundwater, sub-slab
soil gas and indoor air data in areas downgradient of the property to evaluate the vapor intrusion pathway into
commercial and residential properties. EPA evaluated the data and determined that the vapor intrusion pathw ay
was not likely to pose unacceptable current indoor air risk at the dow ngradient commercial buildings and
residential buildings.

Additional Work for Site Redevelopment

In 2006, Grace demolished a large manufacturing building and warehouse, including building slabs and
foundations, in anticipation of the property's potential redevelopment.

During review of the Grace Remedial Action Report, dated May 2009, EPA identified several locations on the
Grace property with soil concentrations above the ROD's soil cleanup levels. With EPA approval, about 900 tons

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of contaminated soils exceeding ROD cleanup levels were excavated from the Grace property in 2012 and
disposed of off-site. Results are documented in the 2013 Soil Response Action Completion Report. Revision 1.

In 2014, the property was sold to a new owner who planned to redevelop the property. EPA provided the new
owner with a comfort letter, which provided information about liability and outlined recommendations for the
proposed redevelopment. Between 2014 and 2019, the new property owner redeveloped the Grace property into
the Woburn Landing commercial space. The new owners" development incorporated vapor mitigation measures
into all new buildings, managed contaminated soils according to an EPA-approved 2015 Final Soil and
Groundwater Management Plan, and protected the Site's GWETS and monitoring well network.4 The
redevelopment resulted in the excavation and off-site disposal of 2,100 cubic yards of contaminated soil.

UniFirst Property

The 1989 ROD. as modified by the 1991 ESD. called for treatment of contaminated soil using in-situ
volatilization, extraction and treatment of contaminated groundwater and long-term monitoring of groundwater.

Groundwater Extraction and Treatment

The GWETS at the UniFirst property began operating in September 1992. It initially included one recovery well
(UC-22), which was designed to capture contaminants in the unconsolidated deposits, shallow bedrock and deep
bedrock at the UniFirst property, as well as contaminants in the deep bedrock at the Grace property. The
ultraviolet/oxidation treatment unit at UniFirst was replaced with GAC units in October 2003.

To address EPA concerns regarding groundwater capture. UniFirst installed a new overburden extraction well
(EX-1) in 2014, which began operation in May 2016. The GWETS completed its 3 1 st year of operation in
September 2023. Groundwater sampling continues to be performed at the UniFirst property to assess progress of
the remedial actions in achieving cleanup levels. The Data Review section of this FYR Report discusses recent
groundwater monitoring results.

Soil Vapor Extraction (SVE)

In response to a recommendation in the Site's Third FYR Report (2009), UniFirst collected groundwater, sub-slab
soil gas and indoor air data at the existing commercial building on its property and in areas downgradient of the
property to evaluate the vapor intrusion pathway. EPA evaluated the data and determined that the vapor intrusion
pathway was not likely to pose unacceptable current indoor air risk at and downgradient of the UniFirst property,
including all residential buildings. However, potential future indoor air risks were above EPA's risk management
guidelines at two commercial buildings (including the UniFirst building) if they were used for residential
purposes in the future. As a result. UniFirst began annual monitoring of the vapor intrusion pathway in 2012 at the
downgradient commercial buildings and began designing a soil vapor extraction and treatment (SVET) system at
the UniFirst building (i.e., the other commercial building). The Data Review section of this FY R Report discusses
recent sub-slab vapor and air monitoring for the vapor intrusion pathway collected at the downgradient
commercial building.

In 2014, UniFirst installed and began operating the SVET system on its property, which serves as the in-situ
volatilization treatment technology. The current system on the property is being operated to mitigate potential
vapor intrusion into the on-property building and reduce VOC mass in unsaturated unconsolidated deposits. The
SVET system completed its ninth year of operation in 2023.

In 2022, EPA requested that UniFirst remove a sewer line that may be acting as a continuing source of
contamination to the subsurface. EPA recommended that the sewer line be removed, inspected, soils screened.

4 Every building constructed at the Grace property with occupied tenants has a vapor mitigation system that has been tested
consistent with EPA and MassDEP guidelines and demonstrated to be functioning properly as passive systems. Passive
systems have a vapor mitigation barrier under the building that prevents vapor migration into the occupied building and
passively collects and vents subsurface vapors out through the roof (versus active system which would generally be the same
design except it would include active fans operating at the roof vents).

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and soil borings and samples be collected to evaluate existing soil conditions. In August 2023, Uni First submitted
a Work Plan for Supplemental Soil Investigation at the property. EPA provided comments on the work plan in
October 2023. Uni First is currently reviewing EPA's recommendations for additional work. It is expected that
Uni First will implement the sewer line investigation once the work plan is finalized.

Also in 2022, EPA requested that Uni First optimize their SVET system to address persistent VOC contamination.
In response. Uni First implemented preliminary water level monitoring in the vicinity of their SVET system. EPA
and Uni First are assessing the data and evaluating options for optimizing the SVET system.

Wildwood Property

The 1989 ROD. as modified by the 1991 ESD, called for sludge and debris removal, excavation and off-site
incineration of contaminated soil, in-situ volatilization of contaminated soil (primarily in a wetland area),
extraction and treatment of contaminated groundw ater and long-term groundw ater monitoring. Beatrice is
responsible for response actions at the Wildwood property.

In 1994, Beatrice completed the excavation and off-site disposal of 252 cubic yards of sludge. 220 cubic yards of
debris, and 1.1 12 cubic yards of mixed-contaminated soil (total of 1,584 cubic yards). In 1998, Beatrice began
operation of an integrated subsurface treatment system. The system includes a bedrock GWETS and an air sparge
(AS)/SVE system.

Extracted groundwater is treated using an air stripper for primary treatment followed by GAC secondary
treatment. Over time. VOC concentrations in the influent to the vapor-phase GAC have decreased significantly, to
levels that do not require treatment. With EPA approval, the vapor treatment system was reconfigured in August
2018 to bypass the carbon treatment. Monthly vapor sampling of the final vapor effluent is ongoing, and the vapor
treatment system components have been left on-site, as outlined in EPA's August 2018 approval letter, in the
event treatment is required in the future.

In 2014-2015, the AS system was expanded with two additional AS points near monitoring well BSW-1 to target
persistent elevated VOCs within the finer sand layers of the groundwater overburden, and operated for 15 months
resulting in significant VOCs contamination reductions of greater than 95%. Also, more groundwater monitoring
wells were installed on the eastern and southern parts of the property to further assess groundwater capture
concerns. Between 2015 and 2017, Beatrice conducted additional field investigations to better delineate the lower
conductivity fine sands and to identify areas that require further treatment to achieve ROD cleanup levels.

Residual contamination was found in the lower conductivity fine sands. Since that time. EPA has been working
with Beatrice to optimize both the AS/SVE system and GWETS.

Beatrice submitted a Work Plan to Optimize Air Sparge System at Wildwood Property in May 2021, which was
revised in September 2023 after additional site investigations in 2021 and 2022. The work plan proposed to
expand the existing AS to incorporate AS points screened within the lower conductivity fine sands and to address
additional impacts found in the area south of the existing treatment area (referred to as the South Area). EPA
provided comments on the September 2023 work plan on October 25, 2023. In response to EPA's comments.
Beatrice submitted a revised work plan {Work Plan to Optimize Air Sparge System at Wildwood Property, Rev. 3,
Final) in December 2023. EP A anticipates that implementation of this Work Plan to Optimize Air Sparge System
at Wildwood Property will begin in 2024.

Beatrice also prepared the Work Plan to Optimize Bedrock Pump & Treat System at Wildwood Property in June
2023 and submitted a revised version (Rev. 2) in October 2023. The work plan presents proposed field work for a
PDI needed to assess potential locations and depths to install more groundwater recovery wells. EPA approved
the work plan on October 26. 2023. Work to optimize the AS/SVE and GWETS systems is ongoing.

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NEP Property

The 1989 ROD. as modified by the 1991 ESD, originally called for excavation and off-site incineration of
contaminated soil, extraction and treatment of contaminated groundw ater and long-term monitoring.

Ultimately, the source control remedy for the NEP property included AS/SVE. This system ran from 1998 to
2000. The system was discontinued after reaching soil cleanup levels in unsaturated soils. Significant reductions
in VOCs in groundwater were also seen. Since the shutdown of the AS/SVE, groundwater sampling continues to
be performed at the NEP property to assess the progress of the remedial actions in achieving cleanup levels. NEP
also completed an investigation of deep bedrock groundw ater in 2017; PCE and TCE were detected above
cleanup levels in discrete fractures in deeper bedrock. The Data Review section of this FY R Report discusses
recent groundwater monitoring results for the NEP property.

A GWETS has not been developed for the NEP property. EPA will continue to evaluate site data to determine the
need for groundw ater treatment.

Otympia Property

The 1989 ROD. as modified by the 1991 ESD. originally called for excavation and off-site incineration of
contaminated soil, groundwater extraction and treatment, and long-term groundwater monitoring. The 2003
Action Memorandum updated the source control component of the remedy to include excavating PCB-
contaminated surface soils and addressing TCE-contaminated subsurface soils through a combination of
treatment, excavation and/or capping in place.

Cleanup at the Olympia property has been implemented under the 2003 and 2004 AOCs. Under the 2003 AOC.
Olympia excavated and disposed of 56 cubic yards of PCB-contaminated surface soils and about 5 cubic yards of
cPAH-contaminated soil, evaluated options for addressing the TCE-contaminated soils and prepared a work plan
for addressing TCE with in-situ chemical oxidation (ISCO). Under the 2004 AOC. which required that Olympia
address the TCE-impacted soils. Olympia installed a sheet pile wall to isolate a treatment cell area at the FDDA.
The fiberglass sheet pile wall extends 20 to 25 feet below ground surface and contains an area of about 60 feet
wide by 150 feet in length. Areas inside and outside the treatment cell were treated by ISCO using sodium
permanganate from 2005 to 2020. During that time, a total of 176,520 gallons of sodium permanganate solution
were applied to the subsurface.

In 2022, a Final Report documented the completion of PCB and PAH soil removal at the Olympia property
consistent with the 2003 AOC. In late 2022, EPA entered into a Prospective Purchaser Agreement (PPA) and past
cost agreement with a prospective purchaser of the Olympia property. Under the PPA. the prospective purchaser
agreed to perform a removal action in an effort to enhance and accelerate the treatment of TCE-contaminated soils
to achieve cleanup levels. The PPA supersedes the work required by the 2004 AOC. The work required by the
PPA will include site characterization, removal options assessment and proposal, removal implementation and site
restoration. The new owner of the Olympia property submitted a Characterization Work Plan in April 2023,
which was revised in September and October 2023 and implemented in Fall 2023. In March 2024, the new owner
submitted a Site Characterization and Removal Options (SC/RO) Report, which is under review. Follow ing EPA
approval of the SC/RO Report, the owners will submit a Removal Work Plan for review, approval and
implementation.

A GWETS has not been developed for the Olympia property as work to further assess cleanup options is currently
underway as part of the PPA. EPA will continue to evaluate site data to determine the need for a GWETS.

Institutional Controls

The 1989 ROD. as modified by the 1991 ESD. states (ROD. p. 34-35), "Once cleanup goals have been satisfied
|Ground Water Extraction and Treatment], the extraction wells will be shut down and a monitoring program will
be implemented. This program will consist of a minimum of three years of quarterly monitoring of ground water

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quality. If the monitoring data during this period shows an increase in contaminant levels overtime, such that
cleanup goals are not maintained, active groundwater remediation will be resumed. The results of this monitoring
program will be reviewed by EPA in order to evaluate the success of the remedy, the maintenance of cleanup
goals, the need for any additional site work including the resumption of the remedy or the implementation of
institutional controls, and to provide information for site delisting. EPA recommends that the State and the City of
Woburn implement controls, such as regulations, ordinances, deed and land restrictions, or other effective forms
of land use control to prevent the use of the aquifer in the vicinity of the Site. Groundwater use should be
restricted until it is determined conclusively that the cleanup goals have been met." Groundwater contaminants
remain above ROD cleanup levels at the five OU-1 Source Area Properties (see the Data Review section of this
FYR Report for more information). In addition, soil contamination above levels protective of UU/UE likely
remains at the UniFirst. Wildwood and Olympia properties, where response actions are ongoing.

Currently, all occupied buildings within OU-1 use the municipal public water supply as drinking water, and
private wells are not present in the area.

In addition, redevelopment projects have been proposed at various properties within affected areas of the Site,
where the projects may alter existing building conditions, change land uses, potentially cause exposure to
contaminated groundwater and/or soils, etc. Since 2014, the proponents for redevelopment at the Grace property
coordinated with EPA and MassDEP regarding the safe redevelopment of the property, requesting a comfort letter
summarizing the status of the cleanup and recommendations for redevelopment. In response to the comfort letter,
the proponents prepared Groundwater and Soil Management Work Plans and Health and Safety Plans describing
how groundwater and soil would be safely managed with workers protected and how the remedy would be
maintained. The proponents also prepared vapor mitigation system designs for occupied buildings, and
constructed and tested the vapor mitigation systems. EPA approved the work plans and designs, and conducted
periodic field oversight of intrusive development activities to ensure that the Site's remedy remained protective of
human health and the environment.

EPA will continue to apply the above redevelopment process at the Site. EPA will also assess the need for
institutional controls to: (1) control use of groundwater until cleanup levels have been met; (2) assure
development of plans for controlling soil and/or groundwater exposures/management during intrusive work, as
appropriate; (3) require assessment of the vapor intrusion pathway, as necessary, until groundwater cleanup levels
have been met; and (4) maintain operation of vapor mitigation systems until groundw ater cleanup levels have
been met.

Systems Operations/Operation & Maintenance (Q&M)

O&M activities at each of the five OlJ-1 Source Area Properties vary by property. They are described below.

Grace Property

Contractors for Grace conduct O&M activities associated with the GWETS consistent with the requirements of
the 1991 Consent Decree. Extracted groundw ater is treated using in-line particulate filters and two 1,000-pound
GAC units. Treated water is discharged to Snyder Creek at the eastern property boundary. Contractors monitor
influent and effluent concentrations monthly to assess mass removal rates, treatment system efficiency, the need
for G AC changeout and to verify compliance with discharge criteria. Treated effluent concentrations have met the
treatment system goals since operation began. Maintenance activities are summarized in monthly and annual
reports submitted to EPA.

During the past five years, the system has operated with minimal downtime. Downtime was generally a result of
power outages, carbon change-outs, system alarms, compressor repairs or maintenance activities. In the period
between the end of May and beginning of August 2023, one of Grace's three groundwater extraction wells
(RW20), operated at a reduced flow rate due to pump performance issues that required pump replacement and
redevelopment of the well.

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Grace also implements a long-term groundwater monitoring program with sampling conducted annually. In
response to Grace's April 5, 2021 request for modifying the long-term groundwater monitoring plan, EPA
submitted a response and comments letter on April 26. 2022 with acceptable long-term groundwater monitoring
plan modifications. In 2023, Grace verbally accepted EPA's response and began applying EPA's acceptable
modifications. EPA is awaiting for Grace's submission of the updated long-term monitoring plan, consistent with
EPA's response.

There is no current O&M plan in place for the passive vapor mitigation systems installed beneath the occupied
buildings at the Grace property.

Uni First Property

Contractors for Uni First conduct O&M activities associated with the SVET system and the GWETS consistent
with the property's O&M Plan, dated February 1993 and revised March 1994, August 2004 and July 2007 and the
1991 Consent Decree. Maintenance activities are summarized in monthly and annual reports submitted to EPA.

The SVET system includes six SVE points installed in the eastern portion of the property (three points inside the
building and three points outside the building), a regenerative blower and two parallel treatment trains of two
vapor phase GAC drums each. Treated vapors are discharged through a stack that terminates above the roof line at
the eastern end of the building. Figure G-8 in Appendix G shows the SVE point locations.

O&M activities for the SVET system include routine monitoring of vacuum at the SVE wells and monitoring
points, pressure, temperature and soil vapor flow rate measurements, and monthly VOC screening readings using
a photoionization detector (PID). Sampling of treatment system influent and discharge following the third and the
fourth G AC drums prior to emission takes place bimonthly with samples analyzed for target VOCs. Water levels
are monitored quarterly in select SVE wells and soil vapor monitoring locations; some locations are monitored
every two to three weeks. Routine maintenance conducted during the past five years included carbon changeouts.
maintenance on the blower and knockout tank, and replacement of the blower and motor starter. Based on data
presented in the Uni First RD/R A Combined Years 29/30 Annual Report dated January 2023 and Year 3 1 Annual
Report dated November 2023, the SVET system operated 54% of the time in its seventh year of operation
(October 2020 - September 2021), 95% of the time in its eighth year of operation (October 2021 - September
2022), and 75% of the time in its ninth year of operation (October 2022 - September 2023). The extended
shutdow ns in the seventh year were caused by a power outage, a multi-week shutdow n for blower replacement
and a multi-month shutdown to evaluate anomalous PID readings in the treatment system samples. The system
was shut dow n once during Year 9 of operation in response to anomalous laboratory analytical results for
treatment system samples. The anomalous readings were determined to be alcohol and hydrocarbon constituents
unrelated to Uni First activities at the property. Additional downtime occurred intermittently in March and April
2023 as a result of high spring water levels causing water to be draw n into and shutting dow n the vapor extraction
system. In 2022 and 2023, Uni First measured water levels on a weekly basis to better understand the role of the
water table on SVET performance. Elevated water levels regularly impact the efficiency of the SVET system to
remove VOCs. and the system is being evaluated for potential enhancements and optimization.

For the GWETS. extracted groundwater from extraction wells UC22 and EX 1 is treated using a particulate filter
and three 1.000-pound G AC units. Treated water is discharged to the storm sewer. Contractors collect bimonthly
samples of the system influent and monthly samples of the effluent. Routine O&M activities also include weekly
system inspections, quarterly sensor checks and annual inspection of the entire system, including tanks, valves,
piping and filters. Uni First submits monthly O&M summary reports to EPA. Effluent from the treatment system
met discharge limits in Year 29, Year 30 and Year 3 1 and was online approximately 99%, 96% and 97% of the
time, respectively. Minimal system dow ntime was caused by power outages and system alarms.

Uni First also continues to implement a long-term groundw ater monitoring program.

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Wildwood Property

Beatrice contractors conduct O&M activities in accordance with an EPA-approved 1998 Operations. Maintenance
and Monitoring Plan. Activities include monitoring of the GWETS performance, the AS/SVE system
performance and groundwater quality, as well as O&M activities associated with upkeep of the treatment systems
and general site maintenance. Beatrice summarizes results in monthly and annual reports submitted to EPA.

Monthly activities include pressure readings and influent and effluent sampling for the GWETS. flow and
pressure readings for the AS system, as well as vacuum and flow readings, influent and effluent air sampling, and
ambient air PID readings for the SVE system.

The Wildwood property GWETS and AS/SVE system continued to operate during this FYR period with minimal
dow ntime. Causes of system dow ntime included, but are not limited to. occasional pow er failures, pump repairs,
carbon changeouts, groundwater sampling and routine maintenance. Remedy optimization measures are currently
underway for the GWETS and AS/SVE.

Before 2018, long-term groundwater monitoring was conducted quarterly. With EPA approval, sampling
frequency was reduced to semiannual beginning with the April 2018 groundwater sampling event.

NEP Property

There are no ongoing O&M activities at the NEP property. Biennial groundwater sampling continues to assess the
progress of the remedial actions in achieving cleanup levels.

Olympia Property

From 2005 to 2020, the responsible party for the Olympia property was treating TCE-contaminated soil in the
FDD A using I SCO via subsurface permanganate delivery (through gravity-fed and direct push injection). During
the current FYR period, focused in jections of permanganate were performed in December 2019 and November
2020. Comprehensive groundwater sampling events took place in 2019 and 2021, with additional focused
sampling events in 2020 and 2021.

Soil and groundwater characterization work at the property is now being conducted by the new property owner
under the 2022 PPA.

III. PROGRESS SINCE THE PREVIOUS REVIEW

Table 6 includes the protectiveness determinations and statements from the 2019 FYR Report. Table 7 includes
the recommendations from the 2019 FYR Report and the current status of those recommendations.

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Table 6: Protectiveness Determinations/Statements from the 2019 FYR Report

OIJ

Protectiveness

Determination

Protectiveness Statement

Short-term Protective

The remedy at the Source Area (OU-1) properties currently protects human health and
the environment because exposure pathways that could result in unacceptable risks arc
being controlled. Active remedial actions have been or continue to be implemented in
conjunction with routine O&M and monitoring. The current evaluation of the vapor
intrusion pathway at both oil-property and downgradicnt of/ncar property locations
also supports the conclusion that the OU-1 remedy is currently protective. However, in
order for the remedy to be protective in the long term, the following actions arc
recommended: 1) groundwater capture and treatment system assessment/enhancements
at the Wildwood property actions arc required; 2) deep groundwater assessment, and
as required, treatment at the NEP property is needed; 3) assessment of soil and
groundwater cleanup levels from additional planned ISCO treatment at the Olyinpia
property to determine if additional groundwater treatment is necessary; and 4)
assessment of groundwater conditions relative to arsenic, manganese. 1.4-dioxane and
PFAS |per- and polvfluoroalkvl substancesl at all Source Area Properties is needed.

Table 7: Status of Recommendations from the 2019 FYR Report

OIJ

Issue

Recommendation

Cu rrent
Status

Current Implementation Status
Description

Completion

Date (if
applicable)

Extraction systems
performance
(insufficient capture

of groundwater
contamination) at
Wildwood property.

As described in
EPA's position on
the path forward
(EPA. 2018a): 1)
perform surface
geophysics to assist
in locating
additional bedrock
recovery wells and
install/test
additional recovery
wells at the
northern and
southern ends of the
property to prevent

migration to the
central area; 2)
expand/optimize
the AS/SVE system
to address areas
with elevated
concentrations of
VOCs in
overburden
groundwater; and 3)
implement pilot of
ISCO in the
bedrock area of
BW-6R as an
enhancement to the
pump-and-treat
remedy for bedrock
groundwater.

Ongoing

Beatrice submitted a Work Plan
to Optinii/c Air Sparge System at
Wildwood Property in May 2021,
which was revised in September
2023 after more site
investigations in 2021 and 2022.
The work plan proposed to
expand the existing AS to
incorporate shallow AS points
screened within the lower
conductivity fine sands and to
address additional impacts found
in the South Area. In December
2023, Beatrice submitted a Final
Work Plan for AS/SVE
optimization in response to
EPA's October 2023 comments.

Beatrice also prepared the Work
Plan to Optinii/c Bedrock Pump
& Trcat System at Wildwood
Property in June 2023, which
was revised in October 2023.
EPA approved the work plan on
October 26, 2023, where deeper
bedrock borings arc being
installed. This predesign field
effort is ongoing. Future detailed
work plans will be submitted to
Optinii/c Bedrock Pump & Trcat
System for EPA approval.

Because the optimization tasks
have not been fully implemented,
this issue is carried forward as an
issue for this FYR.

Not
applicable

20

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OIJ

Issue

Recommendation

Current
Status

Current Implementation Status
Description

Completion

Date (if
applicable)

1

No groundwater
pump and treatment
system implemented
at the NEP property
following AS/SVE
shutdown.

Additional

sampling of wells
on the property
(e.g., NEP 1 and 2
deep bedrock
production wells) to
further assess
contamination
above the cleanup
levels, bedrock
conditions and
groundwater
treatment during the
upcoming OU-2
investigation.

Ongoing

NEP is expected to conduct a
deep bedrock investigation that
includes NEP 1 and 2 (both
former production wells) during
the OU-2 Phase IB Rl.

However, because VOCs remain
above cleanup levels at the NEP
property in overburden and deep
bedrock, this issue is carried
forward as an issue in this FYR.

Not
applicable

1

No groundwater
pump and treatment
remedy implemented
at the Olvmpia

property.

Continue to
evaluate the

progress of ISCO in
achieving ROD
groundwater and
soil cleanup levels
based on post-
injection

monitoring data and

the need for
groundwater
cleanup at the
conclusion of the
removal action.
Upon 1 SCO
completion, the
effectiveness of
ISCO will be
assessed and EPA
will determine the
need for

implementing the
groundwater pump
and treatment
system identified
under OU1 for the
Olvmpia property.

Ongoing

Under the 2022 PPA, the new
owner of the Olympia property

agreed to perform a removal
action in an effort to enhance and
accelerate the treatment of TCE-
contaminated soils to achieve
cleanup levels. The work
required by the PPA will include
site characterization and removal
options assessment, removal
work plan and implementation,
restoration, construction
completion report, post-removal
monitoring, and post-removal
site controls. This work is
ongoing and will be used to
determine the next steps for the
remedy at the Olympia property.

However, because the removal
work is ongoing, this issue is
carried forward as an issue in this

FYR.

Not
applicable

1

Limited current and
historic data for
arsenic, manganese,
1,4-dioxane and
PFAS. Detection
limits for 1,4-dioxane
samples elevated
above risk screening
levels. These
contaminants were
not identified as
COCs in the ROD
but may need to be
identified as of

Perform
comprehensive
sampling for
arsenic, manganese,
1.4-dioxane and
PFAS at the Source
Area Properties to
assess whether
concentrations are
of concern (arsenic,
manganese and 1,4-
dioxane during the
OU-2

investigation).

Ongoing

PFAS sampling has been
performed at each of the five
OU-1 Source Area Properties
between October 2021 and
December 2021. Results arc
presented in the Data Review
section of this FYR Report. The
results exceed EPA 2024 MCLs
for PFAS as well as state MCLs
for PFAS.

Sampling for arsenic, manganese,
1,4-dioxane, and PF AS will be
performed during the OU-2

Not
applicable

21

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OIJ

Issue

Recommendation

Current
Status

Current Implementation Status
Description

Completion

Date (if
applicable)

possible concern.
Where appropriate.

revise cleanup goals
through a remedy
decision document.

investigation and will include
sampling at OU-1 Source Area
Properties.

However, because only partial
PFAS sampling occurred, this
issue is carried forward as an
issue in this FYR.

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 at EPA's site profile page at www.epa.gov/superfund/wellsgh.

During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy that has been implemented to date. Interviews were performed via email with the MassDEP
representative. City of Woburn officials. SDs or responsible parties (or their site coordinators), and community
stakeholders. The City of Woburn's Board of Health did not respond to requests for an interview. Table 8 lists the
people interview ed. Appendix D includes the completed interview forms. The results of these interviews are
summarized below .

Table 8: Summary of Interviews

Interviewee

Affiliation

Interview Date

Jennifer McWccncv

MassDEP

1/10/2024

Citv Engineer Jay Corey

Citv of Woburn

1/2/2024

Anthony Penfold

W.R. Grace

12/19/2023

Catherine Malagrida

UniFirst

12/22/2023

Jeff Haniel

Woodard & Curran for NEP

1/9/2024

Peter Cox

AECOM for Wildwood

12/6/2023

Frank Clicrena

Roux. Inc. for IV5 60 Olvnipia Ave, LLC and
IV5 60 Olvnipia Ave Land. LLC (new owners
of the Olvnipia property)

12/22/2023

Peter Nangcroni

Woodard & Curran for OU-4 SDs

12/15/2023

Michael and Linda A. Ravniond

Aberjona Studv Coalition

12/5/2023

MassDEP Representative

The MassDEP representative noted that the Site is extremely complicated and difficult, but it is well-managed by
EPA and the OU-1 source area remedies are performing as designed. EPA is working with the responsible parties
to address needs for further investigation or optimization at several source area properties. Revisions to the 2024
Massachusetts Contingency Plan (MCP) become effective March 1. 2024; as such, there are some revisions that
may affect MassDEP's federal model Notice of Activity and Use Limitation (NAUL). which is one potential form
of institutional controls that may be implemented at the Site. She noted that the development of institutional
controls as NAULs has not yet begun.

City of Woburn Representatives

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The City of Woburn representative noted that he feels well-informed about the Site's activities and remedial
progress. The system in place for disseminating information works well. He was not aware of any problems with
vandalism at the Site. He was not aw are of any changes in state law s or local regulations that might affect the
protectiveness of the remedy. He was not aware of any changes in projected land use at the Site.

SDs/Responsible Parties

The SDs. responsible parties, or their representatives reported that the remedial systems, where active, are
operating as designed and progress is being made toward achieving ROD cleanup levels. O&M activities are
taking place as required in the property-specific O&M plans. All representatives noted decreases in contamination
concentrations since the remedies were first implemented.

The representatives for the Wildwood property also noted that optimization efforts are underw ay for both
overburden soils and bedrock in accordance with overburden and bedrock work plans recently approved by EPA.
The representative for the new owners of the Olympia property noted that additional work will be necessary to
achieve the ROD standards for the FDDA.

The representatives for the Grace. Uni First and Wildwood properties reported recent EPA-approved reductions in
required sampling frequencies, which may reduce costs. The Grace representative noted, however, that he feels
the continued operation of the pump and treat system is not cost-cffective at this property, which has three
relatively small areas with chemical concentrations above MCLs. The representative suggested that it may be time
to consider a transition from active groundwater extraction to monitored natural attenuation. Grace recently
submitted the Groundwater Sampling and Analysis Plan in Support of Remedy Enhancement Evaluations to EPA
in September 2023.

The representative for Uni First noted that Uni First intends to continue technical meetings with EPA to discuss
SVE system influence and ongoing removal of target VOCs from soil.

The representative for NEP noted that the source control remedy at the property (AS/SVE that operated from
1998 to 2000) has resulted in signification reductions and continual decreasing and/or stabilizing of PCE and TCE
concentrations in both source area and dow ngradient overburden as well as shallow bedrock groundwater.
Assessment of deep bedrock groundw ater is ongoing as part of OU-2 work.

Community Stakeholders

Representatives for the Aberjona Study Coalition, a local community group, noted that the project has been a
professional, w ell-managed project. They are not aw are of any problems w ith vandalism or trespassing at the Site.
They are kept informed of site activities through EPA's website.

Data Review

This FYR included review of recent monitoring reports, work plans and other documents for the five OU-1
Source Area Properties. Data reviewed primarily included groundwater analytical data, treatment system
performance data and, at the Uni First property, vapor intrusion sampling data. Property-specific data evaluations
are included in the subsections below . Appendices F through J contain property-specific figures and data
summary tables.

Groundwater data are collected at all five Source Area Properties to monitor the progress of the remedial actions
in achieving ROD cleanup levels. Table E-l in Appendix E summarizes maximum detected concentrations for
primary contaminants at each property during this FYR period compared to the maximum concentrations reported
in the 2019 FYR Report. One or more COCs exceed the ROD groundwater cleanup goals at all five Source Area
Properties, although the magnitudes of the exceedances vary by property. The Wildwood and Olympia properties
reported some of the highest contaminant concentrations in groundwater during this FY R period; work is
currently underway at both properties to optimize the remedies and expedite cleanup.

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In response to a recommendation in the 2019 FYR Report, contractors collected groundwater samples from select
monitoring wells at each of the Source Area Properties and submitted the samples for PFAS analysis. Table E-2 in
Appendix E presents the results. PFAS results were compared to EPA 2024 MCLs for individual PFAS
compounds and the Massachusetts Maximum Contaminant Level (MMCL) of 20 nanograms per liter (ng/L) for
the sum of six PFAS compounds (perfluorooctanesu 1 fon ic acid [PFOS], perfluorooctanoic acid [PFOA],
perfluorohexanesu 1 fon ic acid [PFHxS], perfluorononanoic acid [PFNA], perfluoroheptanoic acid [PFHpA] and
pe rfl uorodecanoi c acid |PFDA|). For the PFAS constituents sampled, PFAS constituents were detected at all five
Source Area Properties above the MMCL and EPA MCL for PFOA. PFOS and/or Hazard Index of 1 for PFBS.
PFHxS. PFNA and HFPO-DA (Gen-X) . Discussion of the PFAS results by property is below. In addition.
Question B of this FY R Report presents additional assessment of PFAS compounds.

Grace Property

Long-Term Groundwater Monitoring

This FYR included review of the 2023 Annual Monitoring Report - W.R. Grace OU-1 Source Area (Grace
Annual Report). Grace contractors collect groundwater level measurements and sample groundwater annually
from on- and off-property monitoring wells and three extraction wells. The samples are analyzed for Site COCs.
in addition to cis-1.2-dichloroethene (cis-1.2-DCE). which is a TCE degradation product. In May 2023,
groundwater samples were collected from 38 wells on the Grace property and four wells on nearby Cuminings
properties to the south (G39S, G39D, UG 15 and UG 16). In addition, water quality samples were collected from
one location in Snyder Creek along the eastern Grace property boundary. Table 4-2 in the Grace Annual Report
includes a comprehensive summary of groundwater analytical results from 1983 to 2023. Appendix F of this FY R
Report includes figures and data summary tables for the Grace property.

Figure F-1 and Figure F-2 in Appendix F present the water table map and shallow bedrock potentiometric surface
map. respectively, from the May 2023 monitoring event. The maps show that RW17 and RW20 have established
a localized hydraulic capture zone along a portion of the southern property boundary and from a portion of the
Cumin ings property to the south. Extraction well RW22RE also continues to capture groundwater in the
unconsolidated deposits and shallow bedrock. Groundwater in areas unaffected by the pumping flows in a
southwesterly direction.

Based on review of the 2023 analytical results, most of the wells on the Grace property meet the ROD cleanup
levels. TCE is the primary COC remaining above ROD cleanup levels in groundwater on the Grace property. TCE
concentrations were above the ROD cleanup level in seven wells (GOD, G16S, G16D, G19M, G24S, G24D and
RW22RE) in 2023, with a maximum detected concentration of 100 micrograms per liter ((.ig/L) in well G16S
compared to the TCE cleanup level of 5 (ig/L. PCE concentrations were detected above its cleanup level in two
off-property wells G39S and G39D in 2023, with a maximum detected concentration of 14 (ig/L in well G39S.5
All other COCs were below cleanup levels. cis-l,2-DCE exceeded the MCL of 70 jig/L in RW22RE in 2022 at a
concentration of 210 (ig/L.

Figures F-3 and F-4 in Appendix F show the estimated areal distribution of PCE and TCE, respectively, in the
unconsolidated deposits and shallow bedrock from the 2023sampling event. Concentrations of TCE in
groundwater at the sampled monitoring and recovery wells have declined significantly since the start of the
extraction system as a result of the extraction system operation and. in some portions of the property, natural
biodegradation.

Statistical tests of COC concentration trends were included in the Grace Annual Report to determine TCE
concentration trends in samples from the three operating extraction wells and seven wells in areas where
concentrations exceeded ROD cleanup goals. Of the 10 wells for which a TCE concentration trend test was done.

5 The Grace Annual Report notes that EPA acknowledges that it is likely that a source of VOC-contaminated groundwater
south of the Grace property is causing PCE concentrations in samples from certain monitoring wells to exceed the ROD
cleanup goal for PCE.

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six wells had a statistically significant decreasing TCE concentration trend (G13D, G19M, G24D, G37S, RW17.
and RW20), three wells did not have a statistically significant TCE concentration trend (G16S, G24S and
RW22RE) and one well had a statistically significant increasing trend (G16D). Over the past five years, the
highest TCE concentrations on the Grace property have been detected in the G16 well cluster. The Grace Annual
Report suggests that the elevated TCE concentrations in G16D and G16S may be related to the former building's
demolition or property redevelopment activities that occurred between 2006 and 2019. These activities may have
resulted in a delayed release of TCE contamination from historical Grace operations, causing the observed
increasing TCE concentrations at the G16 well cluster. However, the exact mechanism and location of the TCE
re lease* s) causing the increasing TCE concentrations at the G16 well cluster remain unknown. Despite the
persistent elevated concentrations in the G16 well cluster. VOC concentration data from downgradient well
samples along the Washington Street property boundary demonstrate that groundwater with VOC concentrations
greater than the ROD cleanup goals is not flow ing off-site in the unconsolidated deposits or shallow bedrock.
Groundwater monitoring will continue to track contaminant trends and evaluate potential off-property migration.

EPA continues to encourage Grace to consider optimization and/or enhancements of the GWETS for reducing the
time of attaining groundw ater cleanup criteria specified in the Consent Decree. Grace submitted the Groundw ater
Sampling and Analysis Plan in Support of Remedy Enhancement in September 2023. EPA is currently review ing
the plan.

GWETS

Tli rough the end of the 31 st year of operation (October 1. 2022, through September 30, 2023), the GWETS has
treated almost 106 million gallons of groundwater (Table F-l, Appendix F). The mass of VOCs contained in the
groundwater and removed by the system has generally been declining overtime. About 18 pounds of VOCs were
removed during the first year of operation, while on average less than a pound of VOCs were removed each year
over the past five years through September 30, 2023

/'/¦AS

In response to a recommendation in the 2019 FYR Report. Grace contractors collected groundwater samples from
eight monitoring wells (GOD, G16S, G16D, G19M, G24S, G24D, G37S and G40D) in October 2021 and
submitted the samples for PFAS analysis. PFOA and PFOS concentrations in samples from seven and three of the
eight monitoring wells, respectively, exceeded their 4 ng/L MCL (Table E-2, Appendix E). The maximum PFOA
concentration (22.2 ng/L) was detected in monitoring well G19M. The maximum PFOS concentration (32.3 ng/L)
was also in G19M.

UniFirst Property

Long-Term Groundwater Monitoring

This FYR included review of the RD/RA Year 3 1 Annual Report for the UniFirst Site, dated November 2023
(UniFirst Annual Report). UniFirst and its contractors collect groundwater level measurements, monitor for dense
non-aqueous phase liquid (DNAPL) and sample groundwater annually from on- and off-property monitoring
wells, including overburden extraction well EX-1. The samples are analyzed for VOCs. which include all site
COCs plus cis-l,2-DCE. The current long-term monitoring program includes groundwater sample collection at 41
wells, water-level measurements at 111 monitoring points and monitoring for DNAPL at eight monitoring points.
Wells are added or removed from the monitoring program with EPA approval. Appendix I of the UniFirst Annual
Report includes a comprehensive summary of groundwater analytical results from 1983 to 2023. Appendix G of
this FYR Report includes figures and data summary tables for the UniFirst property.

Figures G-l, G-2 and G-3 present potentiometric surface maps for the unconsolidated deposits, upper bedrock and
lower bedrock, respectively, at the UniFirst property and surrounding area. Evaluation of the potentiometric maps
and cross sections presented in the UniFirst Annual Report shows an extensive vertical and horizontal zone of
groundwater capture in the bedrock. Except for brief periods of pumping system down time, the UniFirst Annual
Report indicates that this capture has been maintained beyond the UniFirst property boundary.

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Tabic G-l in Appendix G presents results from the 2023 annual sampling event. Based on review of the 2023
results, several wells monitored on and off the Uni First property meet ROD cleanup levels: unconsolidated
deposits wells UC26S, UC26D, UC30 and UC33; shallow bedrock wells UC18, and off-property wells UG10.
GOIDB and S81S. The remaining wells sampled in 2023 reported PCE and/or TCE above the ROD cleanup
levels. Elevated concentrations of cis-l,2-DCE (up to 480 J (ig/L in UC11 -2 in 2023) were also detected in site
monitoring wells.6 The MCL for cis-l,2-DCE is 70 (ig/L. Highest concentrations of PCE at Uni First were
detected in shallow bedrock wells UC7-2 and UC7-3 with concentrations of 2,500 (ig/L and 1,700 (ig/L,
respectively, in 2023. The same wells also had the highest concentrations of TCE in 2023 (420 (ig/L at UC7-2 and
250 (ig/L at UC7-3). As show n in Figures G-4 and G-5 (time-concentration graphs) in Appendix G, PCE
concentrations at these sampling locations are about an order of magnitude low er than concentrations prior to
startup of the GWETS; how ever, concentrations have been similar over the past two decades with some
fluctuations. The wells are within the capture zone of the GWETS (Figure G-2).

The Uni First Annual Report includes Mann-Kendall trend analyses to determine PCE concentration trends for
wells exhibiting VOC concentrations exceeding ROD cleanup levels. The data used were from 2010 to 2023.
Table G-3 in Appendix G presents the results of the Mann-Kendall trend analyses. Most wells indicated
decreasing or no trends at the 90% and 95% confidence intervals. For the period from 2010 to 2023, on-property
well UC10-3 (bedrock) reported increasing concentration trends at the 90% and 95% confidence intervals. UC7-2
also reported an increasing concentration trend at the 90% confidence interval but no trend at the 95% confidence
interval. Figures G-6 and G-7 are time-concentration graphs for well UC10-3. Well UC10-3, located along the
southern property boundary, is within the capture zone of the groundwater extraction system (Figure G-l).
Monitoring at these well points is ongoing.

For the period from 2010 to 2023, off-property well S81M (unconsolidated deposits) reported increasing
concentration trends at the 90% and 95% confidence intervals. Off-property well S81M is located to the
southwest and adjacent to wetlands; it may be outside the capture zone of the groundwater extraction system.
During this FYR period. PCE concentrations in S81M ranged from 120 (ig/L (2019, 2022, 2023) to 140 (ig/L
(2020 and 2021). Figures G-6 and G-7 are time-concentration graphs for w ell S81M. Monitoring at these well
points is ongoing.

During the 2023 sampling event, six on-property monitoring wells and two sumps in on-property vapor
monitoring points were gauged for DNAPL presence. DNAPL was not present in any of the gauged wells and
monitoring points. Historically. DNAPL has only been observed in one monitoring well (UC8).

GWETS

The GWETS has been operating since 1992. The GWETS treated approximately 22.4 million gallons of
groundwater during operational year 31 (2023), and a cumulative total of about 652 million gallons during 31
years of operation. About 19 pounds of PCE and 0.9 pounds of TCE were removed during operational year 31.
and about 2,454 pounds of PCE and 119 pounds of TCE have been removed during the 31 years since operations
began.

SVET System

The SVET system, shown in Figure G-8, has been operating since 2014. The estimated cumulative mass removal
of target VOCs during the ninth year of operation (2023) is approximately 1.3 pounds and over the full SVET
system operational period is about 54 pounds (Figure G-9). The levels of VOCs as measured with a PID have
decreased since the system began operation (Figure G-10). VOCs measured using the PID continue to be detected
at all of the SVE wells. However, recent PID readings show no particular trend over time, except for a recent
increase in the PID readings at SVE-6 and seasonal increases during periods with a low water table.

As previously noted in the System Operations/O&M section of this FY R Report, the SVET system was shut dow n
for several months in 2021 and 2023 and for several days in 2022 to assess anomalous PID screening readings for
treatment system influent and discharge samples. The anomalous readings were determined to be alcohol and

6 The "J" data qualifier indicates the detected concentration is an estimated value.

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hydrocarbon constituents unrelated to Uni First activities at the property. UniFirst is continuing to assess the
source of non-target VOCs unrelated to Uni First activities at the property being introduced to the SVET system.

Vapor Intrusion Sampling

Due to elevated soil gas concentrations of PCE beneath the commercial building immediately west/downgradient
of the Uni First property, annual monitoring of the sub-slab soil gas and indoor air at this commercial building
(260206) has been occurring since 2013. Annual sub-slab soil gas and indoor air monitoring of the commercial
building at the Uni First property will begin after completion of the SVET remedy. The active extraction and
treatment of vapors from beneath the building at the Uni First property currently protects this building from vapor
intrusion.

Uni First contractors collect indoor air. ambient air and sub-slab soil gas samples annually from existing locations
at commercial property 260206. During each event, three indoor air samples, one ambient air sample and three
sub-slab soil gas samples are collected and submitted for VOC analysis. The data are evaluated for consistency
with VOC concentrations present during an initial sampling event in 2011. at which time risks associated with the
detected concentrations were within the acceptable human health risk ranges. Sub-slab soil gas PCE
concentrations have decreased from a maximum of 5,730 micrograms per cubic meter (|ig/m3) in 201 1 to a
maximum of 1,790 (ig/m3 in 2019 and 1,080 (ig/m3 in 2023, while PCE indoor air concentrations have decreased
from a maximum of 1.23 |ig/m3 in 201 1 to a maximum of 0.617 (ig/m3 in 2019 and 0.163 (.ig/m3 in 2023. The
2023 PCE indoor air concentrations are below the residential EPA RSL of 1 1 (ig/m3. Tables G-4 and G-5 in
Appendix G present the historical indoor air and sub-slab soil gas results for commercial property 260206.

As shown in Table G-4. several other constituents were detected in indoor air at concentrations above their
respective RSLs during the most recent sampling event in 2023: benzene, carbon tetrachloride, chloroform and
ethylbenzene. However, benzene, carbon tetrachloride and ethylbenzene were not detected in sub-slab soil gas
above laboratory detection limits and benzene and carbon tetrachloride were also detected in ambient air samples
at concentrations similar to the indoor air samples. These observations indicate that sub-slab soil gas is not the
source of these compounds in indoor air.

Chloroform was present in both indoor air and sub-slab soil gas samples above EPA RSLs during this FYR
period. EPA previously evaluated cancer risks and noncancer hazards using a maximum exposure point
concentration of 5.6 (.ig/m3 for chloroform in the 2012 risk assessment. The associated risks were within EPA's
acceptable risk range. In the 2023 sampling event, chloroform was detected at a maximum concentration of 0.396
(ig/m3 in indoor air. which is an order of magnitude lower than the concentration used in the 2012 risk assessment.
The chloroform concentration reduction demonstrates that the potential cancer risk and noncancer hazard are
below those previously calculated.

The indoor air and sub-slab soil gas results continue to confirm that the vapor intrusion pathway does not exceed
thresholds established for current and future exposure risk at commercial property 260206.

/'/¦AS

Uni First collected groundw ater samples from six monitoring wells (UC8, UC25, S71S. UC6, S71D and S70D) in
December 2021, and submitted the samples for PFAS analysis. Figure G-l 1 in Appendix G shows the sampling
locations. Table E-2 in Appendix E presents the results. PFOA concentrations in all six sampled wells exceeded
the MCL of 4 ng/L. with a maximum reported concentration of 19 ng/L in S70D. PFOS concentrations in all wells
except for UC6 exceeded the MCL of 4 ng/L. The maximum PFOS concentration was 25 ng/L in the duplicate
sample from UC25. In S70D. the MCL for PFHxS (10 ng/L) and for the combined concentrations of PFHxS and
PFNA (Hl=l) was also exceeded.

Wildwood Property

Long-term Groundwater Monitoring

Beatrice contractors collect groundwater samples semiannually for groundw ater COCs plus cis-l,2-DCE. Figure
H-l in Appendix H show s monitoring locations. In addition. Beatrice contractors have conducted several

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additional field investigations at the Wildwood property during this FYR period to further define the extent of
COCs above ROD cleanup levels, to further characterize the extent of the lower conductivity fine sands unit, and
to inform the design for the AS/SVE system and GWETS optimization. The 2023 Work Plan to Optimize Air
Sparge System at Wildwood Property report and the 2023 Work Plan to Optimize Bedrock Pump & Treat System
at Wildwood Property report are the primary sources of information for this data review. Appendix H of this FY R
Report includes figures and data summary tables for the Wildwood property.

Elevated concentrations of COCs remain above ROD cleanup goals in overburden and bedrock groundw ater
monitoring wells. TCE is the primary COC with concentrations above ROD cleanup levels, although PCE. 1.1.1-

trichloroethane (TCA) and vinyl chloride also exceed cleanup goals. Cis-1,2-DCE is also consistently detected at
elevated concentrations in groundwater at the Wildwood property.

Figures H-2 and H-3 in Appendix H present total VOC concentration contours in the upper overburden and deep
overburden, respectively. Figure H-4 in Appendix H presents the estimated extent of TCE contamination in the
bedrock aquifer. Figure H-4 also shows the proposed bedrock boring locations for the pre-design investigation to
inform where additional groundwater recovery wells may be installed.

While operation of the AS system has substantially reduced VOC concentrations in portions of the overburden,
recent investigations indicated the presence of elevated VOCs in shallow overburden groundwater in the northern
and southern portions of the treatment area in the lower conductivity fine sands unit, as well as extending further
south of the treatment area. In addition, recent investigations further defined contamination in the deep
overburden in the southern part of the treatment area. Contamination in the deep overburden extends from well
WW-208D (total VOCs of 13,487 (.ig/L in April 2022) to the southeast (Figure H-3. Appendix H). As indicated in
Section 11 above. Beatrice submitted a Final Work Plan in December 2023.

During the previous FYR period. EPA identified several wells outside the groundwater extraction system's
recovery zone exhibiting concentrations of VOCs above ROD cleanup levels. Beatrice is currently implementing
the October 2023 Work Plan to Optimize Bedrock Pump & Treat System at Wildwood Property. After new
bedrock wells are installed and data evaluated. Beatrice will work with EPA to determine optimum locations for
more groundwater recovery wells. Work at the Wildwood property to optimize the AS/SVE system and GWETS
system is ongoing.

PFAS

Beatrice contractors collected groundwater samples from 10 monitoring wells (WW-200D. WW-203, WW-205S,
WW-206. WW-208D, WW-21 1D. BW-6RD-LO. BW-10. BW-14RD and BW-17R) in October 2021, and
submitted the samples for PFAS analysis. Figures H-5 through H-7 show the wells sampled for PFAS in the upper
overburden, lower overburden, and bedrock, respectively. Table E-2 in Appendix E presents the results. Samples
from nine wells (BW-6RD-LO. BW-10. BW-17R. WW-200D. WW-203. WW-205S, WW-206. WW-208D, and
WW-21 1D) reported PFAS concentrations above one or more MCLs. In these wells, PFOA. PFOS and PFNA
were reported at concentrations above MCLs (Table E-2). The maximum concentration of PFOA was reported in
WW-203 at 15.5 ng/L (MCL of 4 ng/L). The maximum concentration of PFOS was also reported in WW-203 at
11.8 ng/L (MCL of 4 ng/L). The maximum concentration of PFNA was reported in BW-6RD-LO at 13.5 ng/L
(MCL of 10 ng/L).

NEP Property

Long-term Groundwater Monitoring

This FY R included review of the 2021 and 2023 Groundwater Monitoring Reports for the NEP Property, as they
are the most recent reports available. Appendix I of this FYR Report includes figures and data summary tables for
the NEP property.

NEP implements a groundwater monitoring program to evaluate residual VOC concentrations and trends in both
the overburden and shallow bedrock aquifer since the shutdown of the AS/SVE system in 2000. NEP contractors
collect groundwater samples biennially from five overburden wells (EPA-1. EW-1. 'NEP-101. NEP-104 and NEP-

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108) and four shallow bedrock wells (NEP-101B, NEP-104B, NEP-106B and NEP-108B) for VOCs analysis,
which includes all site COCs. The sampling scope has changed over time due to changing site conditions and the
installation and/or decommissioning of monitoring wells. Groundw ater flow direction in both the overburden and
bedrock aquifers at the NEP property is primarily south/southwest, toward the Aberjona River. Figures 1-1 and 1-2
in Appendix I present the 2023 potentiometric surface contours from the July 2023 monitoring event for the
overburden and shallow bedrock aquifers, respectively. The figures also show the 2023 PCE/TCE results.

During the most recent sampling events in 2021 and 2023, PCE was the only COC detected above ROD cleanup
levels in the wells sampled. PCE exceeded the ROD cleanup level (5 (ig/L) at one overburden well (NEP-101) at
a concentration of 6.5 (ig/L in 2021 and 8.5 (ig/L in 2023. Historical PCE concentrations in well NEP-101 were as
high as 3,407 (ig/L prior to 1998. Mann-Kendall trend analysis provided in the 2023 Groundw ater Monitoring
Report indicated a decreasing trend at NEP-101. COC concentrations in all other sampled wells were below ROD
cleanup levels.

As noted in the 2019 FYR Report. NEP sampled three deeper bedrock wells (NEP-A, NEP-B and NEP-3) in 2016
and identified PCE and TCE above ROD cleanup levels in the wells. In EPA's 2021 review of the 2017
Groundwater Investigation Report - Deeper Bedrock. EPA requested that NEP also sample two other deep
bedrock wells (NEP-1 and NEP-2) and discreet sample zones in NEP-A, NEP-B and NEP-3. NEP has not
sampled bedrock wells NEP-1 and NEP-2 because they consider them to be inaccessible (one is directly adjacent
to an electrical substation; the other is next to a silo). EPA has requested that NEP conduct a deep bedrock
investigation at the property during the OU-2 Phase IB Rl including deep bedrock wells NEP-1 and NEP-2.

PFAS

NEP contractors collected groundwater samples from four bedrock wells (NEP-101B, NEP-104B, NEP-106B and
NEP-108B) and two overburden monitoring wells (EW-1 and NEP-101) in November 2021, and submitted the
samples for PFAS analysis. Figure 1-3 in Appendix I show s the wells sampled. Table E-2 in Appendix E presents
the results.

Samples from all six wells reported PFAS concentrations above one or more MCLs. PFOA concentrations in all
six wells exceeded the MCL (4 ng/L) at concentrations ranging from 48.5 ng/L in NEP-106B to 76.4 ng/L in
NEP-108B. PFOS concentrations in all six wells also exceeded the MCL (4 ng/L) at concentrations ranging from
14.6 ng/L in NEP-106B to 3 1.4 ng/L in NEP-101.

Otympia Property

Long-Term Groundwater Monitoring

This FYR Report included review of the February 2022 Project Memorandum: Summary of Activities: November
2020 to December 2021, 60 Olympia Avenue and the October 2023 Characterization Work Plan for the Wells
G&H NPL Site. Former Drum Disposal Area. Appendix J of this FYR Report includes figures and data summary
tables for the Olympia property. Figure J-l shows site features, including monitoring well locations.

Olympia contractors implemented I SCO treatment at the FDD A treatment cell from 2005 to 2020. Periodic
groundwater monitoring occurred to determine the effectiveness of the permanganate injections. While the
treatments reduced TCE concentrations in parts of the FDDA. substantial mass remains based on recent
monitoring data.

The most recent comprehensive groundwater sampling event took place in April 2021. During the April 2021
sampling event, contractors collected groundwater samples from 50 monitoring wells and submitted the samples
for VOCs analysis. In September 2021, a smaller, focused sampling event was performed and included the
collection of samples from 16 monitoring wells for analysis of VOCs. The primary VOCs detected in
groundwater above ROD cleanup levels are PCE, TCE and vinyl chloride. cis-l,2-DCE was detected above its
MCL of 70 (ig/L. The follow ing maximum concentrations were detected during the 2021 groundwater sampling
events:

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• PCE - 88 (.ig/L at MW-212S (September 2021), compared to the ROD cleanup level of 5 (ig/L.

• TCE - 7,400 (ig/L at MW-205DX (April 2021), compared to the ROD cleanup level of 5 (ig/L.

• cis-l,2-DCE - 15,000 (ig/L at MW-210D (April 2021), compared to the MCL of 70 (ig/L.

• Vinyl chloride - 4,700 (ig/L at MW-210D (April 2021), compared to the ROD cleanup level of 2 (ig/L.

Under the 2022 PPA, the new property ow ner's contractor recently reviewed historical data for the FDDA and
presented preliminary findings along with proposed activities for additional site characterization in the 2023
Characterization Work Plan. Figure J-2 in Appendix J show s the most recent TCE concentrations in groundwater
throughout the FDDA. As seen in the map. elevated TCE concentrations above the ROD cleanup level have been
observed inside the treatment cell and outside the treatment cell to the east, west and south.

Site characterization activities began in October 2023. These activities include soil and groundwater sampling
inside and outside the treatment area at the FDDA and investigating for the presence of residual DNAPL. A site
characterization report is expected to be completed in 2024. The data will be used to inform the selection of an
expedited cleanup approach, as required under the 2022 PPA.

PFAS

Olympia contractors collected groundwater samples from seven monitoring wells screened in the unconsolidated
deposits and submitted the samples for PFAS analysis. Monitoring wells MW-202S, MW-202D, MW-205D and
MW-206D are located inside the treatment cell and monitoring wells MW-215M, MW-216S and MW-217M are
outside the treatment cell. Figure J-l in Appendix J shows the wells sampled. Table E-2 presents the results.

Two wells (MW-202S and MW-202D) had PFOS concentrations above the MCL of 4 ng/L and six wells (MW-
202S, MW-202D, MW-205D, MW-206D, MW-216S and MW-217M) had PFOA concentrations above the MCL
of 4 ng/L with a maximum PFOA concentration of 1 1 ng/L (MW-202S) and maximum PFOS concentration of 6.7
ng/L (MW-202S). There were no other exceedances of MCLs.

Site Inspection

The site inspection for the OU-1 Source Area Properties was conducted on December 5 and 6. 2023. Site
inspection participants also visited the OU-4 Southw est Properties on November 16. 2023. The purpose of the
inspection was to assess the protectiveness of the remedy. Appendix K includes the completed site inspection
checklists for each of the five Source Area Properties. Appendix L includes photographs from the site inspection.
A summary of the observations made for each of the OU-1 Source Area Properties is below.

Grace Property

The site inspection for the Grace property took place on December 5, 2023. In attendance were Jennifer
McWeeney and Janet Waldron from MassDEP, Jim Ricker from HGL (EPA oversight contractor). Tony Penfold
from W.R. Grace. Marvel len Johns from de maximis. inc. (Grace contractor). Van Sawyer from GES (Grace
contractor), and Kirby Webster from Skeo (EPA FYR contractor). The property has been redeveloped with a
hotel, three restaurants, and parking areas (one of the restaurant spaces is currently unoccupied). Site inspection
participants observed site monitoring wells, the extraction wells, and the treatment building. The treatment
building is located on the east side of the hotel and is kept locked when contractors are not on-site. Grace
contractors noted that they conduct a yearly inspection of the pavement around the property's monitoring wells,
and that Madison Holdings (the current property ow ner) is responsible for repairs to the pavement. O&M plans
and other site documents were available for review. The Chick-fil-A restaurant on-site recently expanded its
drive-thru, which included earth-moving activities. Soil management plans were follow ed for the work. Grace
contractors also noted that they have repaired one of the extraction wells near the Chick-fil-A. They also noted the
inherent issues with maintaining an aging system in which infrastructure is located beneath redeveloped areas,
including new paving. No issues of concern related to protectiveness of the remedy were observed during the site
inspection.

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UniFirst Property

The site inspection for the UniFirst property took place on December 5, 2023. In attendance were Jennifer
McWeeney and Janet Waldron from MassDEP, Jim Ricker from HGL (EPA oversight contractor), Kirby Webster
from Skeo (EPA FYR contractor). Cat Malagrida from UniFirst. and Bettina Longino from A read is (UniFirst
contractor). Site inspection participants observed site monitoring wells, the two extraction wells, and the treatment
room that houses the SVE and groundw ater treatment systems. UniFirst indicated that the effluent from the
groundwater treatment system is discharged to the sewer. UniFirst also maintains O&M documents on the
property. Indoor air and sub-slab soil gas sampling continues at the commercial property 260206 adjacent to
UniFirst. Remedial components appeared to be in good condition. Trespassing is not an issue at the property. No
issues of concern related to protectiveness of the remedy were observed during the site inspection.

Wildwood Property

The site inspection for the Wildw ood property took place on December 6. 2023. In attendance were Jennifer
McWeeney from MassDEP, Pete Cox, Jen Atkins and Brendan Maye from AECOM (Wildwood contractor), and
Kirby Webster from Skeo (EPA FYR contractor). Site inspection participants observed the treatment building,
which houses components for both the groundwater system and AS/SVE system. The building is kept locked
when contractors are not on-site. No issues of concern were noted with the system components. O&M manuals
and some site documents were available on-site; the AECOM representatives noted that others can be accessed
electronically. The Wildwood property is wooded and undeveloped. The representatives from AECOM noted that
additional SVE probes had recently been installed on the property in anticipation of the upgrade to the AS/SVE
system. Clear-cutting of trees in the southern part of the property is also planned for the system upgrades. The
AECOM representatives noted that this area will be used for a separate AS/SVE system to address contamination
in the southern part of the property. No issues of concern related to the protectiveness of the remedy were
observed during the site inspection.

NEP Property

The site inspection for the NEP property took place on December 5, 2023. In attendance were Jennifer
McWeeney and Janet Waldron from MassDEP, Jim Ricker from HGL (EPA oversight contractor). Kirby Webster
from Skeo (EPA FYR contractor), and Jeff Hamel from Woodard and Curran (NEP contractor). Site inspection
participants walked the exterior of the property and observed site monitoring wells and the location of former
production wells. Former deep bedrock production wells NEP-1 and NEP-2 have not been sampled. They were
reportedly capped in place at least 4 feet below ground surface. NEP-1 is immediately next to an electrical
substation that provides power for the operating facility. NEP-2 is in the rear of the property and adjacent to a silo
that is no longer in use. The trailer housing the former AS/SVE remains in place, behind the NEP building. The
NEP contractor noted that there are no issues with trespassing. No issues of concern related to protectiveness of
the remedy were observed during the site inspection.

Olympia Property

The site inspection for the Olympia property took place on December 6. 2023. In attendance were Jennifer
McWeeney from MassDEP, Brian Klaus and Ed Weagle from Roux (contractor for the new property ow ner), and
Kirby Webster from Skeo (EPA FYR contractor). Site inspection participants met at 60 Olympia Avenue and
observed the developed parts of the Site. Several businesses, including a trucking operation and shipping business
as well as a church, were operating in the northern part of the Olympia property. The state representative noted
that a petroleum spill in this part of the property is being managed under the state's remediation program. Site
inspection participants then traveled to the FDDA. where work is ongoing to further characterize soil and
groundw ater contamination under the PPA. The FDDA is adjacent to wetlands and is accessed from the
Wildwood property to the south. It is surrounded by chain-link fence. Characterization work, including
boring/well installation, was ongoing during the site inspection. Several existing monitoring wells and injection
wells from the I SCO remedy, as well as new sampling locations, were observed within and around the FDDA.

-------
The Roux contractors indicated that there are no issues with trespassing. No issues of concern related to the
protectiveness of the remedy were observed during the site inspection.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary

Yes. the OU-1 remedy is functioning as intended by the Site's decision documents (1989 ROD. 1991 ESD and
2003 Action Memorandum) at the Grace. UniFirst. and NEP properties. Progress has also been made at the
Wildwood and Olympia properties; remedy optimization efforts are currently underway at both properties to
improve and expedite cleanup.

The remedy was designed to address unacceptable human health risks from ingestion of contaminated
groundwater, inhalation of volatiles while showering and contact with contaminated surface soil. Although COCs
in groundwater and soil remain above cleanup levels selected in the Site's decision documents at some of the OU-
1 properties, the Site's cleanup is progressing as expected and there are no current exposures to soil and
groundwater contamination.

VOC contamination remains in the underlying aquifer at concentrations above the ROD cleanup levels at all five
Source Area Properties. In addition. PFAS constituents were detected in groundwater above the EPA MCLs and
MMCL. How ever, the groundw ater is not used as a source of drinking water.

Contaminated soil has met cleanup levels at the Grace and NEP properties, and soil treatment is ongoing at the
UniFirst and Wildwood properties. Groundwater treatment systems continue to operate at the Grace. UniFirst and
Wildwood properties. Additional site characterization is being performed at the Olympia property to determine
options to optimize the soil and groundwater cleanup at this property. Further assessment of the remedy at each
OU-1 Source Area Property is below .

Remedial Action Performance

Grace Property

The remedy implemented at the Grace property includes operation of the GWETS and long-term groundwater
monitoring.

Significant progress has been made at the Grace property since operation of the GWETS began in 1992.
Groundwater quality samples collected from property wells demonstrate a reduction in total VOC concentrations
on and downgradient of the property. Most wells on the Grace property meet the ROD cleanup levels as of May
2023. Of the wells where TCE concentrations remain above the ROD cleanup level, most had decreasing TCE
concentration trends. Over the past 5 years, the highest TCE concentrations in groundw ater at the Grace property
have been detected at Wells G16D and G16S, located in the approximate center of the property. The TCE
concentration at G 16D shows a statistically significant increasing trend, and neither an increasing nor decreasing
trend at G16S. Despite the elevated TCE concentrations in the G16 well cluster. VOC concentration data from
dow ngradient well samples along the Washington Street property boundary show that groundwater with VOC
concentrations greater than the ROD cleanup levels is not flow ing off-property in the unconsolidated deposits or
shallow bedrock. Grace recently submitted the Groundwater Sampling and Analysis Plan in Support of Remedy
Enhancement in September 2023. EPA is currently reviewing the plan and will work with Grace to determine
options for addressing remaining groundwater contamination.

UniFirst Property

The remedy implemented at the UniFirst property includes operation of a GWETS and SVET system and long-
term monitoring. Annual monitoring of the sub-slab soil gas and indoor air at the commercial building

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downgradient of the Uni First property has also been occurring since 2013. Results continue to confirm that the
vapor intrusion pathw ay docs not exceed residential use thresholds established for current and future exposure
risk at the downgradient property. Operation of the SVET system also protects the existing on-property
commercial building from vapor migrating into indoor air.

The GWETS is working as designed to capture contaminated groundw ater in the unconsolidated deposits, shallow
and deep bedrock at the Uni First property. Several wells monitored on and off the Uni First property meet ROD
cleanup levels. Most wells with PCE ROD cleanup level exceedances indicate decreasing or no trends; however,
two wells (S71S and off-property S81M, both in the unconsolidated deposits) reported increasing PCE
concentration trends. Well S71S is within the capture zone of the groundwater extraction system. In addition, an
investigation of a sewer line upgradient of well S71S is planned to determine if potential PCE contamination in
the sewer line is serving as an ongoing source of contamination. Well S81M is an off-property well, located to the
southwest of the property; contamination in this well may be outside the capture zone of the extraction system.
S81 off-property well cluster and additional monitoring wells are being investigated through the ongoing OU-2
Central Area aquifer Rl by the appropriate settling defendants under the 1991 Consent Decree.

The SVET system continues to operate as designed, although the system was shut down for several months during
this FYR period to assess anomalous PID screening readings. The anomalous readings were determined to be
alcohol and hydrocarbon constituents unrelated to Uni First activities at the property. Uni First should continue to
assess SVET system optimizations to address persistent VOC contamination.

NEP Property

The 1989 ROD. as modified by the 1991 ESD. originally called for excavation and off-site incineration of
contaminated soil and development of a GWETS at the NEP property. Ultimately, the source control remedy
included AS/SVE, which operated from 1998 to 2000. A GWETS has not been developed for the NEP property.

Significant reductions of groundwater contaminant concentrations have been achieved at the NEP property.

During the most recent sampling events, only one overburden well reported PCE concentrations above the ROD
cleanup level. Sampling of deeper bedrock groundwater in 2016 detected concentrations of PCE and TCE at
concentrations above ROD cleanup levels. EPA requested that NEP also sample two other deep bedrocks wells
(NEP-1 and NEP-2). NEP is expected to sample NEP-1 and NEP-2 (both former production wells) during the
OU-2 Phase IB Rl.

Wildwood Property

The remedy implemented at the Wildw ood property included removal and off-site disposal of sludge, debris, and
mixed-contaminated soil (completed in 1994) and operation of a bedrock GWETS and an AS/SVE system.

VOC concentrations have been reduced in many overburden and bedrock wells since system startup in 1998;
however. VOCs in shallower overburden remain above cleanup levels. Work is underway to optimize the
AS/SVE system, including the addition of over 100 new air sparge wells within and south of the existing
treatment area. Optimization work is anticipated to be completed in 2024.

During the previous FYR period. EPA also identified several wells outside the groundwater extraction system's
recovery zone and exhibiting concentrations of VOCs above ROD cleanup levels. Work is currently underw ay to
optimize the GWETS. After new bedrock wells are installed and data evaluated. Beatrice will work with EPA to
determine optimum locations for additional groundwater recovery wells. Optimization work is anticipated to be
completed in 2024 or 2025.

Olympia Property

The 1989 ROD. as modified by the 1991 ESD. originally called for excavation and off-site incineration of
contaminated soil, development of a GWETS and long-term groundwater monitoring. The 2003 Action
Memorandum called for excavating PCB-contaminated surface soils and addressing TCE-contaminated
subsurface soils through a combination of treatment, excavation and/or capping in place. The remedy
implemented to date at the Olympia property has included excavation and off-site disposal of contaminated soil

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(completed in 2003) and I SCO treatment to address TCE-contaminated subsurface soils (2005-2020). A GWETS
has not been developed for the Olympia property.

The ISCO injections have significantly reduced concentrations of VOCs at many monitoring locations within the
treatment area at the FDDA. However, substantial mass remains in the subsurface based on recent monitoring
data. In 2022, EPA entered into a PPA with a prospective purchaser of the Olympia property. The prospective
purchaser agreed to perform a removal action to enhance and accelerate cleanup at the FDDA. The work includes
site characterization and removal options assessment, removal work plan and implementation, restoration,
construction completion report, post-removal monitoring, and post-removal site controls. Site characterization
activities began in October 2023. EPA will determine the need for implementing a GWETS after post-removal
monitoring.

System Operations/O&M

The SDs are performing O&M activities at those properties with active treatment systems (Grace. UniFirst and
Wildwood) in general accordance with EPA-approved O&M plans. The current operating procedures maintain the
effectiveness of remedial systems operations.

Some SDs have noted the increasing costs associated with maintaining aging treatment systems. EP A continues to
encourage the SDs to consider optimization and/or enhancements of their systems to reduce the time of attaining
groundw ater cleanup criteria.

Implementation of Institutional Controls and Other Measures

The 1989 ROD. as modified by the 1991 ESD. states (ROD. p. 34-35), "Once cleanup goals have been satisfied
|Ground Water Extraction and Treatment|. the extraction wells will be shut dow n and a monitoring program will
be implemented. This program will consist of a minimum of three years of quarterly monitoring of ground water
quality. If the monitoring data during this period shows an increase in contaminant levels over time, such that
cleanup goals are not maintained, active groundwater remediation will be resumed. The results of this monitoring
program will be reviewed by EPA in order to evaluate the success of the remedy, the maintenance of cleanup
goals, the need for any additional site work including the resumption of the remedy or the implementation of
institutional controls, and to provide information for site delisting... EPA recommends that the State and the City
of Woburn implement controls, such as regulations, ordinances, deed and land restrictions, or other effective
forms of land use control to prevent the use of the aquifer in the vicinity of the Site. Groundwater use should be
restricted until it is determined conclusively that the cleanup goals have been met."

Redevelopment projects have been proposed at various properties within affected areas of the Site, where the
projects may alter existing building conditions, change land uses, potentially cause exposure to contaminated
groundwater and/or soils, etc. Since 2014, the proponents for redevelopment at the Grace property coordinated
with EPA and MassDEP regarding the safe redevelopment of the property, requesting a comfort letter
summarizing the status of the cleanup and recommendations for redevelopment. In response to the comfort letter,
the proponents prepared Groundw ater and Soil Management Work Plans and Health and Safety Plans describing
how groundwater and soil would be safely managed with workers protected and how the remedy would be
maintained. The proponents also prepared vapor mitigation system designs for occupied buildings, and
constructed and tested the vapor mitigation systems. EPA approved the work plans and designs, and conducted
periodic field oversight of intrusive development activities to ensure that the Site's remedy remained protective of
human health and the environment.

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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 to the toxicity values, exposure assumptions, exposure pathways and methods of
evaluating risk since the 1989 ROD and 1991 ESD. How ever, the RAOs selected for the Site are still valid. The
changes as described below are not expected to alter the protectiveness of the remedy because the drinking water
pathway is currently incomplete. Municipal drinking water is available and private wells are not present in the
area.

The protectiveness of the soil cleanup levels was fully evaluated in the 2014 FYR Report, which concluded that
the ROD soil cleanup levels were protective for a residential exposure scenario. Table M-1 in Appendix M re-
evaluates the ROD soil cleanup levels using updated toxicity data and confirms revised toxicity data do not alter
the protectiveness of the remedy.

Although the remedy was not designed to be protective of vapor intrusion, this pathw ay is incomplete under
current land use conditions at the Wildw ood and Olympia properties and has been evaluated and determined to
not pose an unacceptable risk under current land use conditions at the UniFirst and NEP properties and
downgradient areas. Buildings constructed at the Grace property as part of redevelopment activities have been
fitted with engineering controls to mitigate the potential vapor intrusion pathway.

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 followed 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 A RA R 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
awareness may be developed and these standards may differ from the cleanup standards on which the remedy
was based. These new... | standards] should be considered as part of the review conducted at least every five
years under CERCLA § 121(c) for sites where hazardous substances remain on-site. The review requires EPA
to assure that human health and the environment are being protected by the remedial action. Therefore, the
remedy should be examined in light of any new standards that would be applicable or relevant and appropriate
to the circumstances at the site or pertinent new [standards], in order to ensure that the remedy is still
protective. In certain situations, new standards or the information on which they are based may indicate that
the site presents a significant threat to health or environment. If such information comes to light at times other
than at the five-year reviews, the necessity of acting to modify the remedy should be considered at such
times." (See CERCLA Compliance with Other Laws Manual: Interim Final (Part 1) EPA/540/G-89/006
August 1988, pp. 1-56.)

The Site's groundw ater cleanup goals are based on the Safe Drinking Water Act MCLs, which are chemical-
specific ARARs for the Site. The MCLs for site COCs have not changed since the 1989 ROD. except for
chloroform (see Appendix N. Table N-l). The ROD cleanup goal for chloroform of 100 (.ig/L was based on the
MCL for total trihalomethanes. The current MCL for total trihalomethanes is 80 (ig/L. This change does not affect
the protectiveness of the remedy because groundwater is not in use as a drinking water source at OU-1.

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The Site's 1988 Endangerment Assessment originally identified arsenic as a chemical of potential concern in
groundwater, but it was eliminated from further consideration for remedial action because detected concentrations
were below the MCL of 50 pg/L in effect at that time. The arsenic MCL has since changed from 50 pg/L to 10
pg/L in 2001. Historical arsenic concentrations were either above 10 (ig/L or detection limits exceeded 10 (ig/L.
This issue was identified in previous FYRs for OU-1. Further assessment of arsenic in groundw ater is ongoing for
OU-1 and OU-2.

PFAS Activities at the Wells G&H 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

VICLs for six PFAS contaminants, including PFOA. PFOS. PFNA, HFPO-DA (Gen-X). PFHxS. and PFBS:7

Compound

Final MCL

PFOA

4 ppt

PFOS

4 PPt

PFHxS

10 ppt

PFNA

10 ppt

HGPO-DA (Gen-X)

10 ppt

Mixtures containing two or more of PFHxS. PFN A,
HFPO-DA. and PFBS

Hazard Index 1 (unitless)

The table below includes the maximum detected concentration and well location at each OU-1 property during the

PFAS sampling events in 2021

for PFAS MCLs.

PFAS
compound

MCL

Grace

Property3

UniFirst

Property15

NEP

Property0

Wildwood
Propertyd

Olympia
Property"

PFOA

4 ng/L

22.2 ng/L
(G19M)

19 ng/L
(S70D)

76.4 ng/L

(NEP-108B)

15.5 ng/L
(WW-203)

11 ng/L

(MW-202S)

PFOS

4 ng/L

32.3 ng/L

(G19M)

25 ng/L
(UC25, DUP-
1)

31.4 ng/L
(NEP-101)

11.8 ng/L
(WW-203)

6.7 ng/L

(MW-202S)

PFNA

10 ng/L/HI=l

0.99 J ng/L

(G19M)

1.2 J ng/L
(UC8)

3.04 ng/L
(NEP-101)

13 .5 ng/L

(BW-6RD-
LO)

0.82 J

(MW-202S)

PFHxS

10 ng/L/HI=l

2.19 ng/L

(G19M)

16 ng/L
(S70D)

6.09 ng/L
(NEP-101)

2.84 ng/L
(WW-200D)

2.6 J

(MW-202S)

HFPO-DA
(Gen-X)

10 ng/L/HI=l

Not sampled

Not detected

Not detected*

Not sampled

Not detected

PFBS

Hl= 1

88.5 ng/L
(G24S)

8.4 ng/L
(UC25 DUP-

1)

18.2 ng/L
(NEP-108B)

10.9 ng/L

(WW-208D)

1.8 J ng/L

(MW-202S)

* Detection limits ranged from 46.1 ng/L to 48.9 ng/L, which exceed the MCL for HFPO-DA
J = estimated concentration1 H 1=0.3 for mixtures containing two or more of PFHxS. PFNA, HFPO-DA. and PFBS.
a H 1=0.3 for mixtures containing two or more of PFHxS. PFNA, HFPO-D A. and PFBS.
b H 1=2 for mixtures containing two or more of PFHxS. PFNA, HFPO-D A. and PFBS.

0 H 1=0.9 for mixtures containing two or more of PFHxS. PFNA, HFPO-D A. and PFBS.
d H 1=2 for mixtures containing two or more of PFHxS. PFNA, HFPO-D A. and PFBS.
e H 1=0.3 for mixtures containing two or more of PFHxS. PFNA, HFPO-D A. and PFBS.

Both PFOA and PFOS concentrations exceed MCLs at each OU-1 property; PFNA was detected above the MCL
at the Wildwood property. PFHxS and PFNA were detected above the 10 ng/L and/or HI = 1 MCL at the UniFirst
property, respectively. The calculated HI for PFHxS. PFNA and PFBS for Grace. NEP, and Olympia properties

' https://www.epa.gov/sdwa/and-polvfluoroalkYl-substances-pfas

36

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were below the MCL of HI=1; both Uni First (well S70D) and Wildwood (well BW-6RD-LO) properties
individually exceeded the MCL with HI=2 (see Table E-2 in Appendix E). HFPO-DA (Gen-X) was either not
detected above the EPA MCLs or not sampled.

The data does not affect protectiveness of the remedy because the drinking water pathway is currently incomplete.
Municipal drinking water is available and private wells are not present in the area.

The following subsections discuss the relevant PFAS toxicity values and state 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 andPFOS

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 EP A Office of Water. The new oral cancer slope
factors are 29,300 |mg/kg/day|"' for PFOA and 39.5 |mg/kg/day|"' for PFOS. For non-cancer, the new oral
reference dose values are 3><10~8 (mg/kg/d) for PFOA and 1 x 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 released 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 perfluorooctadecano ic acid (PFODA) 4E-02 milligrams per kilogram per day (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.

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-115) 3E-04 mg/kg-day. also known as 1.1.1-

trifluoro-N-(trifluoromethanesulfonyl)methanesulfonamide (TFSI).

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 the two ORD compounds
PFPrA and HQ-115/TFSI.

In April 2023, EPA released a new non-cancer RfD of 5.0E-04 mg/kg-day for perfluorohexanoic acid (PFHxA)
based on an Integrated Risk Information System (IRIS) value.

The table includes the maximum detected concentration and well location at each OU-1 property for these PFAS
during the PFAS sampling events in 2021.

PFAS
compound

Grace

Property

UniFirst
Property

NEP Property

Wildwood
Property

Olynipia
Property

PFODA

Not sampled

Not sampled

Not sampled

Not sampled

Not sampled

PFTetA

Not detected

Not detected

Not detected

Not detected

Not detected

PFDoDA

Not detected

Not detected

Not detected

Not detected

Not detected

PFUDA

Not detected

Not detected

Not detected

3.5 ng/L
(BW-6RD-LO)

Not detected

PFHxA

7.41 ng/L
(G24D)

7.2 ng/L
(UC8)

14.9 ng/L
(NEP-101)

5.89 ng/L
(BW-6RD-LO)

2.7 ng/L
(MW-202D)

37

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PFAS
compound

Grace

Property

UmiFirst
Property

NEP Property

Wildwood
Property

Olympia
Property

PFPrA

Not sampled

Not sampled

Not sampled

Not sampled

Not sampled

HQ-

115/TFSI

Not sampled

Not sampled

Not sampled

Not sampled

Not sampled

PFUDA and PFHxA were detected in OU-1 groundwater samples. Sampling has not yet occurred for the PFAS
compounds PFODA. PFPrA and HQ-115/TFSI. It is noted that currently there are no analytical methods available
for PFODA and the two ORD compounds PFPrA and HQ-115/TFSI. At the time the PFAS investigation was
conducted. EPA had not yet finalized the toxicity value for PFODA and therefore was not sampled. PFODA
sampling will be included in future investigations, if the analyte is included in the list of compounds analyzed for
by the selected EPA-approved laboratory analytical method. However, this does not affect protectiveness of the
remedy because the drinking water pathway is currently incomplete. Municipal drinking water is available and
private wells are not present in the area.

2022 Non-Cancer Toxicity Values for PFBA

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.

The table includes the PFBA maximum detected concentration and well location at each OU-1 property during
the PFAS sampling events in 2021.

PFAS compound

Grace
Property

UmiFirst
Property

NEP

Property

Wildwood
Property

Olympia
Property

PFBA

13.7 ng/L
(G24S)

Not sampled

Not sampled

Not sampled

14 ng/L
(MW-202S)

PFBA was detected at the Grace and Olympia properties. This does not affect protectiveness of the remedy
because the drinking water pathway is currently incomplete because municipal drinking water is available and
private wells are not present in the area. The local municipal code requires connection to the public water system.

PFAS State Standards

At this time EPA has made no determination of whether these State standards will need to be added as an ARAR
for this Site. However, for informational purposes a comparison of PFAS data against state standards is included.

On October 2, 2020, the State 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 (ppt) for the sum of six PFAS compounds:

•	PFOS

•	PFOA

•	PFHxS

•	PFNA

•	PFHpA

•	PFDA

Summary of Site PFAS Activities

Based on a recommendation in the 2019 FYR Report, groundwater samples were analyzed for PFAS at all five
OU-1 Source Area properties in 2021. PFAS compounds were detected in groundwater at all five properties.
Concentrations exceeded the state's MMCL at all five properties. PFOA and PFOS concentrations also exceeded

38

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EPA MCLs at all five properties. PFNA exceeded the EPA MCL at one well on the Wildwood property. PFHxS
was detected above the MCL at the Uni first property.

Table E-2 in Appendix E presents compiled PFAS data for the five properties. Although there are exceedances of
the MMCL and EPA MCLs for PFOA. PFAS. PFNA, PFHxS and PFBS. the remedy remains protective because
the drinking water pathway is currently incomplete because municipal drinking water is available and private

wells are not present in the area. The local municipal code requires connection to the public water system.

1,4-Dioxane at the Wells G&H Superfund Site

There is no current federal MCL for 1.4-dioxane. Using 2013 updated IRIS toxicity information and the standard
Superfund risk assessment approach. EPA's carcinogenic risk range of 10~6 to 10~4 for 1.4-dioxane equates to a
concentration range of 0.46 (.ig/L to 46 (.ig/L (ppb). The MassDEP Drinking Water Guidelines/MCP Method 1
(GW-1) standard of 0.3 jj.g/1 does not apply at this Site pursuant to Section 40.011 of the MCP which limits the
applicability of the MCP to response actions at disposal Sites that are deemed adequately regulated.

This compound was commonly used as a chlorinated solvent stabilizer to prevent product degradation. It was
identified as a COC in OU-4 groundw ater in the 2017 ROD. Limited sampling in 201 1 at the Uni First (four wells)
and Grace (five wells) properties did not detect this compound at a reporting limit of 2 (ig/L. In 2016, three deeper
bedrock wells at the NEP property were sampled and had 1.4-dioxane detections above the 0.46 jig/L EPA RSL
(cancer risk of 10"6). The upcoming OU-2 sampling event will include OU-1 wells and will include 1,4-dioxane as
part of the analytical suite with detection limits that meet tap water RSLs. If it is detected at the Source Area
Properties, additional investigation and/or evaluation may be performed to determine if any changes are needed to
the remedy. However, if it is detected in OU-1 groundwater, it does not pose any additional threat to human
health due to the current use of municipal water as the source of drinking water at and in the vicinity of the Site.

Floodplain

Federal Floodplain Management: Federal regulations at 40 CFR Part 6. Appendix A identified in the ROD were
withdrawn. Furthermore, these regulations, and therefore the current CERCLA remedy, only addressed potential
floodplain impacts up to the 100-year flood elevation. Current federal floodplain regulations at 40 CFR Part 9
require a greater assessment of potential floodplain impacts, including preventing the release of contamination
from waste management units and other remedial infrastructure up to the 500-year floodplain elevation. EPA has
assessed potential floodplain impacts from a 500-year flood event on the Site's remedial infrastructure
(monitoring wells and groundwater treatment plant at the Wildw ood property). There are no new concerns since
the remedial components were originally designed and constructed in consideration of potential impacts from the
Aberjona River floodplain.

Because EPA has not identified any protectiveness issues at this time, we do not include a recommendation to add
this requirement as an ARAR in a future determination.

Changes in Toxicity and Other Contaminant Characteristics

2022 cis-l,2-DCE Non-Cancer Toxicity Value

In October 2022, EPA released a noncancer reference concentration (RfC) of 4.00E-02 milligrams per cubic
meter (mg/m3) for cis-1.2-DCE. based on a provisional peer reviewed toxicity value (PPRTV) screening value.
Previously, no RfC was available for cis-1.2-DCE.

Cis-1.2-DCE was detected in site groundwater at levels up to 15,000 (ig/L (Olympia property. Table E-l in
Appendix E) during this FYR period. However, the change in the toxicity value for cis-1.2-DCE does not call into
question the protectiveness of the remedy because groundwater is not currently used for drinking water at the Site.

2020 trans-1,2-DCE Non-cancer Toxicity Value

In November 2020, EPA finalized a new RfC for trans-1.2-DCE based on a new PPRTV. There previously was
no RfC for trans-1.2-DCE.

-------
Trans-1.2-DCE has been detected in groundwater at the Site. In 2022, trans-1.2-DCE was detected at the Uni First
property at a concentration of 42 (ig/L (UC1 1-2). However, the change in the trans-1.2-DCE toxicity value does
not affect protectiveness of the remedy because groundwater is not used for drinking water at the Site.

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 ((.ig/dL). 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 inulti-family dwellings,
apartment complexes, vacant lots in residential areas, schools, day-care centers, community centers, playgrounds,
parks, greenways 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 ppm 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.

As noted in the 2019 FYR Report, lead was only identified as a soil COC at the Wildwood property due to the
presence of sludge. Although the lead cleanup level identified in the ROD (640 mg/kg) exceeds the current lead
soil screening level for residential land use of 200 mg/kg (and 100 mg/kg with additional sources of lead present),
the Wildwood property is currently undeveloped and undergoing remedial actions. In addition, based on sampling
conducted in 1987 for soil and 1994 post-excavation sampling following sludge removal activities, the average
lead concentrations in surface soil (76.9 mg/kg). subsurface soil (13.1 mg/kg) and sludge (53.5 mg/kg) at the
Wildwood property are less than the residential soil screening levels (Table M-2, Appendix M).

In 1987, surface and subsurface soil lead data were collected from the Grace. NEP and Olympia properties. In
addition. 16 surface and subsurface soil samples were collected and analyzed for lead at the Grace property in
2005. These soil lead data were presented in the 2019 FYR Report (Table 5) and are included in Table M-2 in
Appendix M of this FYR Report. Because the average lead surface soil and subsurface soil concentrations at each
of the properties are less than 200 mg/kg. the change in the SL for lead docs not affect the protectiveness of the
remedy. There were no available lead data for the Uni First property. The Lead Screening Level Checklist is
included and attached as Appendix P.

Changes in Risk Assessment Methods

There have been no notable changes in risk assessment methodologies since the previous FYR.

Changes in Exposure Pathways

Exposure pathw ays considered in the 1988 Endangerment Assessment included: 1) ingestion of groundw ater and
inhalation of VOCs while showering by future residents; 2) soil ingestion, dermal contact and inhalation
exposures by adolescent trespassers and commercial workers; and 3) soil ingestion and dermal contact by future
residents. The properties continue to be used commercially (Grace. Uni First and NEP) or are undeveloped

-------
(Wildwood and Olympia). A hotel and restaurants were developed on the Grace property. Because the property
was remediated to residential cleanup levels and vapor mitigation measures were taken during construction, the
change in land use does not affect remedy protectiveness. Municipal water is available for use at the Site and
surrounding area, which prevents exposure to affected groundw ater until cleanup levels are achieved.
Additionally, the local municipal code requires connection to the public water supply.

Ecological Risk Considerations

The Site's 1988 Endangerment Assessment included an ecological risk assessment, which found potential risks to
ecological receptors at the Wildw ood and Olympia properties, which are adjacent to the Aberjona River. The
evaluation indicated potential risk to aquatic life due to metals and phthalates in surface water. Potential risk to
invertebrates and mammals were identified due to metals, pesticides. PAHs and PCBs in sediments. The area
subsequently became part of Wells G&H OU-3, the Aberjona River Study, and was merged with OU-2 of the
neighboring Industri-Plex Superfund site in 2002. A remedy for the surface water and sediments of Wells G&H
OU-3, Aberjona River Study, was documented in the Industri-Plex Superfund Site OU-2 (and including Wells
G&H Superfund Site Operable Unit-3, Aberjona River Study) in 2006 ROD. and completed in 2017.

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 Evaluation 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/2015-09/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 physiochemical
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 Wells G&H Superfund Site

EPA's Third FYR Report (2009) included a recommendation to evaluate the vapor intrusion pathway. The SDs
collected additional data to assess the potential for vapor intrusion. In April 2012, EPA prepared a human health
risk assessment report for the vapor intrusion pathway. EPA concluded that the vapor intrusion pathway was not
likely to pose unacceptable current indoor air risk at the UniFirst property and downgradient of/near the UniFirst.
Grace and NEP properties, including all dow ngradient residential buildings. The vapor intrusion pathway was
also unlikely to pose unacceptable future risk at buildings dow ngradient of/near the UniFirst. Grace and NEP
properties, including all downgradient residential buildings. However, there was a potential unacceptable future
indoor air risk associated with the vapor intrusion pathway at the commercial building 260206 west
/downgradient of the UniFirst property should this building be used for residential purposes in the future.

As noted in the Data Review section of this FY R Report, annual vapor intrusion sampling, which includes
collection of indoor air. ambient air and sub-slab soil gas samples, continues at the commercial building
immediately west/downgradient of the UniFirst property. The indoor air and sub-slab soil gas results collected

-------
during this FYR period continue to confirm that the vapor intrusion pathway does not exceed thresholds
established for current and future exposure risk at the commercial property.

Consistent with the 2014 FYR Report, groundwater VISLs have been used to evaluate current shallow
groundwater concentrations at the NEP, Uni First and Grace properties, and downgradient of the Grace and
Uni First properties, to confirm that the conclusions of EPA"s 2012 vapor intrusion risk assessment remain valid.
In general, shallow groundwater concentrations have remained consistent or have decreased since 2012 (see Table
0-1 in Appendix O). indicating that the remedy remains protective of the vapor intrusion pathway. For the Grace
property, vapor mitigation measures were implemented at new buildings. The operation of the SVET system at
Uni First is protecting the existing commercial building from vapor impacts. In addition, the commercial building
west/dow ngradient of the Uni First property is monitored annually for vapor intrusion concerns. The Wildwood
and Olympia properties have not been evaluated since these properties are currently undeveloped. The vapor
intrusion pathway should be evaluated in the future if these properties are planned for development.

Expected Progress Towards Meeting RAOs

Soil excavation/off-site disposal and treatment activities, and the operation of soil and groundwater treatment
systems have significantly reduced the concentrations of contaminants in soil and groundw ater. Concentrations of
VOCs in groundwater have diminished since the systems have been operating; the systems continue to limit the
migration of contaminated groundw ater from the OU-1 Source Area Properties.

Contaminated soil has met cleanup levels at the Grace and NEP properties, and soil treatment is ongoing at the
Uni First and Wildwood properties. Groundwater treatment systems continue to operate at the Grace. Uni First and
Wildwood properties. The AS/SVE system and the GWETS at the Wildwood property are being expanded and
optimized. More site characterization is being performed at the Olympia property to determine options to
optimize the soil and groundwater cleanup at this property. A soil investigation near a potential source (sewer
line) is also planned for the Uni First property. These efforts are expected to improve remedial performance and
progress towards meeting RAOs. Although groundwater COCs and lingering VOCs concentrations above cleanup
levels remain in groundwater, remedy protectiveness is not affected because groundwater is not a current source
of drinking water, while response actions are ongoing.

QUESTION C: Has any other information come to light that could call into question the protectiveness 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 and exposure assumptions, impaired aquatic habitats, dispersal of contaminants, damage to remediation-
related structures and. ultimately, ineffective remedies. At coastal sites, saltwater impacts made more likely by
sea-level rise may cause corrosion of remediation equipment and impair restoration efforts. 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 Wells G&H site because the OU-1 remedy accounted for the wetlands and floodplains. and
inspections have not observed any concerns.

-------
VI. ISSUES/RECOMMENDATIONS

Oll(s) without Issues and Recommendations Identified in the FYR:
None

Issues and Recommendations Identified in the FYR:

OU(s): 1

Issue Category: Remedy Performance

Issue: The extraction systems at the Wildwood property are not capturing
contamination effectively.

Recommendation: Implement the activities described in the 2023 work plans to
optimize the AS/SVE system and the bedrock pump and treat system at the
Wildwood property. After these systems have been optimized to effectively
capture and reduce groundwater contamination, implement an in-situ pilot (e.g.,
ISCO) in the bedrock area of monitoring well BW-6R as an enhancement to the
GWETS remedy for bedrock groundwater contamination.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

PRP

EPA

5/30/2029

OU(s): 1

Issue Category: Other
Remedy Implementation



Issue: No groundw ater pump and treatment system implemented at the NEP
property follow ing AS/SVE shutdown.



Recommendation: Additional sampling of wells on the NEP property (e.g., NEP
1 and 2 deep bedrock production wells) to further assess contamination above the
cleanup levels, bedrock conditions and groundwater treatment during the
upcoming OU-2 investigation. Determine the need for implementing the GWETS
identified under OU1 for the NEP property.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

PRP

EPA

5/30/2029

OU(s): 1

Issue Category: Other
Remedy Implementation



Issue: No groundwater pump and treatment remedy implemented at Olympia
Property.



Recommendation: Upon removal action completion, assess the effectiveness of
the removal action, and determine the need for implementing the GWETS
identified under OlJ 1 for the Olympia property.

43

-------
Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight
Party

Milestone Date

Yes

PRP

EPA

5/30/2029

OU(s): 1

Issue Category: Other
Additional Contaminants of Concern

Issue: Limited current and historic data is available for As. Mn, 1,4-dioxane, and
PFAS. Sampling for 1,4-dioxane requires lower detection limits to achieve risk
screening levels. These contaminants were not identified as COCs in the ROD but
may need to be identified as of possible concern. Where appropriate, revise
cleanup goals through a remedy decision document. Limited PFAS sampling and
analyses have been performed and PFAS were detected in groundwater at the five
OU-1 Source Area Properties at concentrations above the MCLs (PFOA. PFOS.
PFNA and/or PFHxS and PFBS) and state MMCL.

Reconi in en dation: Perform comprehensive sampling for As. Mn, 1.4-dioxane.
and PFAS at the Source Area Properties to assess whether concentrations are of
concern (As, Mn & 1.4-dioxane during OU2 investigation), and determine if
further investigation of PFAS in groundw ater or other media is warranted.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

Yes

PRP

EPA

5/30/2029

Other Findings

In addition, the follow ing recommendations that do not affect current or future protectiveness were identified
during the FYR:

• At the UniFirst property, continue to investigate the cause of non-target VOCs being introduced to the
SVET system. Also, implement the soil investigation near the sewer line to determine if residual PCE in
the sewer line may be serving as an ongoing source of contamination. Elevated water levels regularly
impact the efficiency of the SVET system to remove VOCs. and the system is being evaluated for
potential enhancements and optimization. Assess if off-property well S81M is outside the capture zone of
the groundwater extraction system.

• There is no O&M plan in place for the passive vapor mitigation systems at the Grace property. EPA and
MassDEP will determine the need for an O&M plan for the systems. In addition. EPA is awaiting receipt
of the most recent revision of the LTMP for the Grace property.

-------
VII. P ROT ECTIVEN ESS STATEMENT

I'rotectiMMiess Sl;ilcmcnl(s)

Operable Unit:l	Protectiveness Determination:

Short-term Protective

Protectiveness Statement:

The remedy at the OU-1 Source Area Properties currently protects human health and the environment
because exposure pathways that could result in unacceptable risks are being controlled. Active remedial
actions have been or continue to be implemented in conjunction with routine O&M and monitoring. The
current evaluation of the vapor intrusion pathway at both on-property and downgradient of/near property
locations also supports the conclusion that the OU-1 remedy is currently protective. For the remedy to
be protective over the long term, the following actions are recommended: 1) implement the activities
described in the 2023 work plans to optimize the AS/SVE system and the bedrock pump and treat system
at the Wildw ood property; 2) perform additional sampling of wells on the NEP property (e.g., NEP 1
and 2 deep bedrock production wells) to further assess contamination, and the need for GWETS
identified under OU-1 for the NEP property; 3) determine the need for GWETS identified under OU-1
for the Olympia property after removal action completion; and 4) perform comprehensive sampling for
As, Mn, 1,4-dioxane, and PFAS at the Source Area Properties to assess whether concentrations are of
concern (As, Mn & 1.4-dioxane during OU2 investigation), and determine if further investigation of
PFAS in groundwater or other media is warranted.

VIII. NEXT REVIEW

The next FYR for the Wells G&H Superfund site is required five years from the completion date of this review.

45

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APPENDIX A - REFERENCE LIST

General Site References

ATS DR. 2021. Toxicological Profile for Perfluoroalkyls. www.atsdr.cdc.gov/toxprofiles/tp20Q.pdf.

Clement Associates. Inc.. 1988. Endangerment Assessment for the Wells G&H Site. Woburn. Massachusetts.
December 1988.

EPA. 1988. CERCLA Compliance with Other Laws Manual: Interim Final (Part 1). EPA/540/G-89/006. August
1988.

EPA. 1989. EPA Superfund Record of Decision: Wells G&H OU1, Woburn. MA. EPA R01-R89-036 1989,
September 1989.

EPA. 1991. Explanation of Significant Differences. Wells G&H. EPA ID: MAD980732168, OUOl, Woburn.
Massachusetts. April 25, 1991.

EPA. 2009. Third Five-Year Review Report for Wells G&H Superfund Site. Woburn. Middlesex County.
Massachusetts. September 2009.

EPA. 2014. Five-Year Review Report for Wells G&H Superfund Site. Middlesex County. Massachusetts.
September 29, 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. 2017. Record of Decision Southwest Properties. Wells G&H Superfund Site Operable Unit 4. September
2017.

EPA. 2018. Vapor Intrusion Screening Level (VISL) Calculator. Office of Land and Emergency Management.
Office of Superfund Remediation and Technology Innovation (OSRTI). May 2018.
www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator.

EPA. 2019. Fifth Five-Year Review Report for Wells G&H Superfund Site. Woburn. Middlesex County.
Massachusetts. May 30, 2019.

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. 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 Non-cancer Values for Superfund Human
Health Risk Assessments Memorandum. May 26. 2021. Office of Land and Emergency Management.
Washington. DC. 2021.

EPA. Integrated Risk Information System (IRIS). Available at www.epa.gov/iris.

A-l

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EPA. Provisional Peer-Reviewed Toxicity Values. Available at www.epa.gov/pprtv.

EPA. Regional Screening Level Tables. Available atwww.epa.gov/risk/regional-screening-levels-rsls-generic-
tables.

M. Grippo. J. Hay sc. I. Hlohowskyj. and K. Picel. 2021. Derivation of PFAS Ecological Screening Values.

Environmental Science Division. Argonne National Laboratory, September 2021.

United States District Court. District of Massachusetts. 1990. Consent Decree. Civil Action No. 91-11807MA.
September 1990.

Property-Specific References

Grace Property

GES and JG Environmental Inc.. 2022. Groundwater Sampling Results for Per- and Polyfluoroalkyl Substances
(PFAS). 369 Washington Street (W.R. Grace property). Wells G&H Superfund Site. Woburn. Massachusetts.

January 28, 2022.

EPA. 2023. EPA April 6. 2023 Comments on Grace 2022 Annual Report (Year 30). April 6. 2023.

de maximis, inc.. 2023. 2023 Annual Monitoring Report - W.R. Grace OU-1 Source Area (Revision 1). December
6. 2023.

NEP Property

EPA. 2021. EPA Comments on the New England Plastic Corporation (NEP) April 2017 report titled.
Groundwater Investigation Report - Deeper Bedrock. July 26. 2021.

Woodard & Curran, 2023. 2023 Groundwater Monitoring Report. September 28, 2023.

Woodard & Curran, 2022. November 2021 PFAS Groundwater Monitoring. January 31. 2002.

Woodard & Curran, 2021. 2021 Groundwater Monitoring Report. November 9, 2021.

UniFirst Property

EPA. 2023. EPA comments on Work Plan for Supplemental Soil Investigation. UniFirst Corporation. Wells G&H
Superfund Site. Woburn. Massachusetts. October 31. 2023.

UniFirst Corporation. 2022. PFAS Sampling. January 31. 2022.

UniFirst Corporation. 2023. RD/RA Combined Years 29/30 Annual report for the UniFirst Site. Remedial Action
at the Northeast Quadrant of the Wells G & H Site. Woburn. Massachusetts. Operations Report: Groundwater and
Soil Vapor Extraction Systems. January 31. 2023.

UniFirst Corporation. 2023. Vapor Intrusion Monitoring Results. 2023, Commercial Property. Woburn. MA,
260206, Wells G&H Superfund Site. Woburn. Massachusetts. May 22, 2023.

UniFirst Corporation. 2023. RD/RA Year 3 1 Annual report for the UniFirst Site. Remedial Action at the
Northeast Quadrant of the Wells G&H Site. Woburn. Massachusetts. Operations Report: Groundwater and Soil
Vapor Extraction Systems. November 15, 2023.

A-2

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Wildwood Property

AECOM, 2021. Annual Report - Year 19 and Year 20, Wells G&H Superfund Site. RD/RA for Wildwood
Property. March 24, 2021.

AECOM, 2022. Per- and Polyfluoroalkyl Substances (PFAS) Sampling Results. Wildwood Property Portion of
the Wells G&H Superfund Site. Woburn. Massachusetts. January 31, 2022.

AECOM, 2023. Work Plan to Optimize Air Sparge System at Wildwood Property. Rev. 3, Wells G&H Superfund
Site. Woburn Massachusetts. December 11. 2023.

AECOM, 2023. Work Plan to Optimize Bedrock Pump & Treat System at Wildwood Property. Rev. 2, Final.
Wells G&H Superfund Site Woburn. Massachusetts. October 26. 2023.

EPA. 2021. EPA comments on A ECO Ms proposed Phase I Work Plan (Work Plan) to Expand Air Sparging
System in Northern Portion of Wildw ood Property, dated October 4, 2018. January 26. 2021.

EPA. 2021. EPA response to AECOM's Work Plan to Optimize Air Sparge System at Wildwood Property. Wells
G&H Superfund Site, dated May 3, 2021. June 17. 2021.

EPA. 2023. OU1-Wildw ood at Wells G&H Site: EPA Review of AECOM 's September 18, 2023 Response to
EPA July 26. 2023 Comments, and AECOM's September 25, 2023 Work Plan to Optimize Air Sparge System at
Wildwood Property. Rev. 2. October 25, 2023.

Olympia Property

EPA. 2003. Administrative Order on Consent for Removal Action (Olympia Nominee Trust). March 12, 2003.

EPA. 2003. Action Memorandum: Request for Removal Action at the Wells G&H Site (Olympia Property).
Woburn. Middlesex County. Massachusetts. February 14, 2003.

EPA. 2022. Administrative Settlement Agreement for Removal Action by Prospective Purchaser. November 8,
2022.

Geolnsight. 2022. Project Memorandum - Summary of PFAS Sampling Activities, 60 Olympia Avenue. Woburn.
Massachusetts. January 25, 2022.

Geolnsight. 2022. Project Memorandum - Summary of Activities: November er 2020 to December 2021, 60
Olympia Avenue, Woburn. Massachusetts. February 21, 2022.

Roux Associates. Inc.. 2023. Characterization Work Plan. Wells G&H NPL Site. Former Drum Disposal Area. 60
Olympia Avenue, Woburn. MA, Revision 4. October 13, 2023.

A-3

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APPENDIX B - SITE CHRONOLOGY

Table 6-1: Site Chronology

Event

Date

Municipal water wells G and H first developed

1964 to 1967

Woburn police found abandoned drums on a vacant lot. which prompted DEQE to sample
downgradient supply wells

May 1979

DEQE discovered contamination in Wells G and H; the wells were shut down

1979

EPA investigated groundwater near Wells G and H

1981

EPA proposed the Site for listing on the NPL

December 1982

EPA listed the Site on the NPL

September 1983

EPA ordered three PRPs to studv soil and groundwater contamination on their properties

1983

EPA began the investigation of the entire 330-acre Site

1985

Under an EPA order. Olvmpia removed 17 drums in the FDDA

1986 and 1987

EPA issued an Administrative Order to UniFirst to install monitoring wells and remove
contaminants

1987

EPA completed the Site's Supplemental RI

September 1988

EPA completed the Site's FS and issued the OU-1 ROD

September 1989

EPA and four SDs signed a Consent Decree to implement the OU-1 rcmcdv

September 1990

EPA issued an ESD for OU-1

April 1991

SDs began the OU-1 remedial design

1991

Two of five SDs for OU-1 began the long-term groundwater cleanup and two other SDs began
soil excavation

September 1992

Grace and UniFirst began operating GWETSs

September 1992

Beatrice issued a Draft RI Report for the Southwest Properties (OU-4)

February 1994

Beatrice completed sludge, debris and soil removal at the Wildwood property

1994

NEP initiated its source control remedy (AS/SVE)

February 1998

Beatrice began operation of the GWETS and AS/SVE system at the Wildwood property

1998

EPA issued the Site's first FYR Report

August 1999

NEP ended operation of its AS/SVE system

March 2000

EPA combined the study of Wells G&H OU-3 (the Abeijona River Study) with Industri-Plex
OU-2

Spring 2002

EPA issued an Action Memorandum for a removal action at the Olympia property; Olympia
entered into the first AOC with EPA to implement the removal action

March 2003

Olympia removed contaminated surface soil and PCB-contaminated material and disposed of
it off-site

June - August
2003

Beatrice began the Supplemental RI of the Southwest Properties (OU-4) and issued a Draft
Supplemental RI Report

August 2003

EPA issued the Baseline Human Health and Ecological Risk Assessment for the Southwest
Properties (OU-4)

March 2004

Olympia entered into a second AOC with EPA to address TCE-impacted soils associated with
the FDDA at the Olympia property

June 2004

EPA issued the Site's second FYR Report

September 2004

Olympia began ISCO treatment system to address TCE contamination in soil and groundwater
at the FDDA

September 2005

Grace demolished site buildings in anticipation of potential redevelopment

2006

The owner of the Aberjona Auto Parts property (OU-4) constructed a public ice rink facility

September 2008

EPA issued the Site's third FYR Report

September 2009

EPA issued an Addendum to the third FYR Report to include a human health risk assessment
for the vapor intrusion pathway for additional data collection at the UniFirst property and
downgradient of the UniFirst, Grace and NEP properties; UniFirst began collecting annual
vapor intrusion data from the adjacent commercial building

April 2012

Grace implemented soil removal activities

2012

UniFirst began operating a SVET at its property

2014

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Event

Date

2014-2019

The Grace pro perls is rede\ eloped iiilo die Wo bum Landing commercial space, more soil
removal activities were conducted and vapor mitigation measures were implemented for new
buildings

EPA issued the Site's fourth FYR Report

September 2014

Grace reduced the number of operating extraction wells to three (RVV17, RVV20 and RVV22RE)

June 2015

UniFirst began operating new overburden extraction well EX-1

2016

NEP completed an investigation of deep bedrock

2017

EPA issued the Site's fifth FYR Report

September 2019

ISCO injections at the Olympia property ceased

2020

EPA entered into a PPA with a prospective purchaser of the Olympia property; under the PPA,
the prospective purchaser agreed to perform a removal action in an effort to enhance and
accelerate the treatment of TCE-contaminated soils to achieve cleanup levels - the PPA
supersedes the work required by the 2004 AOC

2022

UniFirst submitted a work plan for a supplemental soil investigation at its property to address
a sewer line

August 2023

The new owner of the Olympia property submitted a Characterization Work Plan and began
investigations at the property

October 2023

Beatrice submitted work plans to optimize the bedrock pump and treat systems at the
Wildwood property

October 2023

Beatrice submitted work plans to optimize the AS systems at the Wildwood property

December 2023

B-2

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APPENDIX C - PRESS RELEASE

2^24,8JDSAM

EPA to Rs^m Cleanups at 14 Mass a tfiusetts Superfine! Sites tils ¥m? | US EPA

S3B An official website of the United States government

Q

MENU

News Releases: Region 01



CONTACT US

EPA to Review Cleanups at 14
Massachusetts Superfund Sites this
Year

February 1,2024

Contact Information

J ames An aer so n (a riders on,j am es,r@epa, gov)

(61?) 918-1401

BOSTON (Feb. 1,2024) -The U.S. Environ mental Protection Agency (EPA) wilt conduct
comprehensive reviews of completed cleanup work a>. 14 National Priorities List (1VPL) 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 'inoings will be posted to EPA's website in a final report.

1 Every step of the process at d Supermini! site is critical anti rejects a commitment we make with
local com mun ities to be as thorough as possible. Cleaning up hazardous waste sites takes extensive
time ano effort, ana these Five-Year Reviews allow EPA to ensure our cleanup eforts continue to
protect public health ant; the environment, while keeping everyone informed and accountable,
especially in those communities that have been overburdened by industrial pollution.' said EPA New
England Regional Administrator David W. Cash. "EPA continues to evaluate these cleanups, with
the overarching mission to protect public health and theenvironmentaridensuririg that
f.'assachusetts 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 anu cleanup activity.

Five-fear Reviewsof Superfund sites in Massachusetts to be completed In 2024:

Nyartza Chemical Waste Dump, Ashland

htlps:,lkWiw.spaa£w,'iie*Msl«ases.'s|ja-fS¥iBW-claani|)S-14-niasiachasette-ftupBrtim-sttes-yBar

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2®24,Bfl3AM

fcPAto (Mm Glaanyps at 14 Massachusetts Suparltnii Sites tiisYear I US ERft

Sutton Brook Disposal Area, Tewksbury
Industri-Plex, 'A'oburr
Wells G&K Wo burr-

WJt Grace & Co., Inc.. (Acton Plant), Acton:

Bairti & fv'cGuire, Holbrook
Hathewdy & Patterson, Mansfield & Foxboro
RcseDispe Sdl Pit, Lanesborough

hoturnorvco Pond, Westborough
Silresim Chemical Corp., Lowell
South Weymouth N'dVdl Air Station. Weymouth
Kavdl WfcopcPb Industrial Reserve Plant. Bedford

Fiv^Year Reviews of Superfund site-sin Massachusetts to begin in 2024, to be completed in
Fiscal fear 2025:

Blackburn & Lniur Privileges. Walpele
Norwouu PCBs. Norwood

More information:

The Superfurtdprogram, afeaeral program estdblisheo by Congrt&bir 1980, investigates arc clear*
up the most complex, uncontrolled, ur dbardcreu haarcciiiwabte sices in the tuoPtry«rc EPA

endeavors to facilitate activities tc return therri to productive use. If totdL there are 123 Superfunc

sites across Mew England.

f§ Superfund and other cleanup sites in New England (pdf)

**itt3'<'/w»».ep!i.go»/ss'st«m;fii!s/da€uments«w24-a2,/urls-.ssp-{:li»rl;-S98.p-Elf> (91.4 KB)

EPA's Superfund pR>gram-*htt|«/.i«r<3S.,iuBcriJi>

Con ttict Ls «nttasc '/tp; ,r,o*'n »wreiease.s/fcrms/contact-us» to ask a uuesticn. provide feedback, or report a
problem.

LAST Ut-'DA LU OK I LIllfUARY 1,2024

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APPENDIX D - INTERVIEW FORMS

MassDEP Representative

WELLS G&H SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Wells G&H

EPA ID: MAD98073216£

Interviewer name: Kirby Webster

Interviewer affiliation: Skeo

Subject name: Jennifer McWeeney

Subject affiliation: MassDEP

Subject contact information: Jennifer.mcweeney@mass.gov

Interview date: 1/10/2024

Interview time: not applicable

Interview format (circle one): In Person

Phone

Mail

Other:

Interview category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)'.'

The Wells G&H site is an extremely complicated, difficult site with numerous sources of contamination
impacting both overburden and bedrock aquifers, and with a variety of responsible parties. Despite this, the
Site is well-managed by EPA.

2. What is your assessment of the current performance of the remedy in place at the Site'.'

OU-1 source area remedies have been established and are performing as designed. Certain OU-1 remedies
(Wildwood. Uni first. Grace and Olympia) have also been flagged for further investigation/optimization. EPA
is working with the responsible parties to address these needs for further investigation/optimization.

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 overseen/managed 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 becomes effective 3/1/24. Revisions include language related to |sub-slab
depressurization systems] (need to establish acceptable vacuum range to maintain appropriate negative
pressure field; and need for continuous monitoring/telemetry). In addition, the 2024 MCP also has some
revisions that may impact MassDEP's federal model NAUL (currently under revision).

6. Are you comfortable with the status of the institutional controls at the Site'.' If not. what are the associated
outstanding issues'.'

Development of institutional controls (NAULS) has not yet begun.

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7.	Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy'.'

The MassDEP PFAS MMCL is a promulgated standard and the PFAS MMCL should also be considered as
an ARAR. No additional comments beyond those already shared directly with the EPA project manager.

8.	Do you consent to have your name included along with your responses to this questionnaire in the FYR
report'.'

Yes.

D-2

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City of Woburn Representative

WELLS G&H SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Wells G&H

EPA ID: MAD980732168

Interviewer name: Kirby Webster

Interviewer affiliation: Skeo

Subject name: John Corey

Subject affiliation: City Engineer

Subject contact information: City Hall. 10 Common St.. Woburn. MA 01801

Interview date: December 26. 2023

Interview time: 3:15 p.m.

Interview location: Engineering Department

Interview format (select one): In Person Phone Mail Email XX Other:

Interview category: Local Government

1. Are you aw are 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 do feel well informed. The system in place for disseminating information works well.

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 aw are of any changes.

5. Are you aw are of any changes in projected land use(s) at the Site'.'

There are none proposed at present.

6. 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'.'

They have. 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 with your responses to this questionnaire in the FYR
report'.' I give my consent.

D-3

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Representatives for the SDs or Responsible Parties

WELL'S G,vH SUPERTTNI} SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Wells G&H

EPA ID; MAD9S073216S

Interviewer name:

Interviewer affiliation;

Subject name; Anthony Penfold

Subject affiliation: W.R. Grace

Subject contact information:

",50D Grace Drive, Columbia. MB, USA 21144
M -1 {901) 361-S1~8 Tcny.perfoMftgfaee.cofn

Interview date: nor applicable

Interview rime: not applicable

Interview location: not applicable

Interview format (circle onei: la Person

Pfccae

Mail

Email

Other:

Interview category: Potentially Responsible Party (PRP) Settling Paity (SP) Representative

1.	What is your overall impression of the remedial activities .at; flie Site1

Tit groundwater pump ami treat/management of migration system has operated consistently for wnr 30 years
and tie site currently lias three relatively snail areas with chemical concentrations ikft the federal
Maximal Contaminant Levels, Incremental ndKtiwt through mUnadprap and treat system operation
¦re not cast-effective and a transition to a monitored natural attenuation 0MKA) remedy continues to fee

appropriate, After 31 years of operation of the groundwater extraction/treatment system and conducting water
level and water quality monitoring Kwdmd with tie M9 Wiikftw Street property, tie data indicates dut
the performance	set forth in the Record of Decision (ROB) for the site are being met,

2.	What hare® been the effects of this Site oti the surmmfiiig community, if any?

Redevelopment of the property lias i^rmd At use including m-nal restaurants and a hotel.

3.	What is your assessment of the current perfhimance of the remedy in place it the Site?

At the time of remedy iapitMitidm VOC concentrations otettM I mg/L rr« narl of tlie site. There lias
been a significant reflmcticm in VOC concentrations in site poudwiKr dace ftt remedy began operating. The
current groundwater data demonstrates that VOC' concentrations at Best monitoring locations are below tlie
ROD cleanup levels while it only a few locations VOC concentrations exceed clean-up levels,

4.	What are the findings from the monitariiig data? What are the key trends in contaminant levels that are
being documented over time at die Site?

Excerpts from the 2023 Annual Monitoring report are provided below:

The Grace groundwater recovery and treatment system continues to prevent groundwater with volatile
¦organic ceoptaad (VOC) concentrations greater than K.ec#rd of Decision (ROB) cleanup goals/Maximum
Contaminant Levels (MCLs) fro* flowing off-property im the ncanUitcd deposits and shadow bedrock
The VOC-contaminated groundwater bcanfli tie former Grace property located at 369 Washington Street
(the "Property") that is not captured by the operating Grace recovery wells either attenuates to concentrations
less than MCLs or flows downward into deeper ktdrotk beneath the Property ami then toward and is captortd
by a deep bedrock extraction wel (UC22) on tlie nearby UniFirst property located at IS Olympia Arrant,
Woburn, Massachusetts. Tie combined Grace and UniFirst groundwater remedies bare significantly reduced
the contaminant concentrations in. groundwater at tie Property and in the off-Property area. These
cwdidws are based on the results of extensive water level measurements and analysis of groundwater quality

D-4

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fro* monitoring wells, recovery wells, and Grace tmMmt system taflaeat and effluent water qualify since
tie remedy begin operating in September Iff 2, as well as gronadwater level, pwurimttr quality and
hydraulic testing latt collected at ami near At Property since 1983.

Tlie total buss of VOC mowed by the extraction system, estimated to be approximately 18,2 pounds ioring
the firit yen* of operation, 
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In 2023, one of the active extraction welts, RW-2f (which contained an upper ami lower pump) reqoirei
redevelopment and a smaller diameter pump for the "bottom" paiup ioe to an issue with the well casing.
Water bwk measured after rabfdepmit nd me of the smaller diameter pump confirmed the two current
pni.im.ps are achieving dw required water level atRW-20 (2' below bedrock surface),

S, Have there been, opportunities to optimize OirM activities or sampling efforts? Please describe changes and
any resulting or desired contaminant reducticMis, improved cleanup efficiencies, or cost savings.

Grace pr#p«sei changes t» the water quality sampling program in April 2021 wilcli were approved by EPA
wif.li mdUnthnt in April 2022. C«t savings were «a the ord» of $4,t>§i/year,

EFA is cnrrently mfairiBg Groundwater Sampling and Analysis Plan iti Support of Jtemedy Enhancement
Evaluation* which was submitted on September 22, 2023. This plan is a result of several previous proposals
ami Jiscowi«ms with EPA related to transitioning to mattered natural attenuation and #fher possible remedy
optimizations dating back to 2019.

9 Are you aware 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-mformed regarding ite Site's activities ami remedial progress? If not tow might EPA
convey site-related iiifonnalion in the future?

Information related to remedial work performed at the Olympia Property Site lias not been shared with other
€117-1 PRPs. EPA cooU provide a snunj of activities and reports to which we don't not have access or
Inks to specific reports which contain tills information.

11,	Do you have any comments, suggestions or reornnien Jattans regarding fc management or operation of the

Site's remedy?

Yes,, it re time to consider transition from active groundwater extraction and allow groundwater cleanup goals
to be achieved through MNA processes,

12,	Do you consent to have your name inctndbd along with your responses to ins questionnaire in lie FYR.
report0

Ye-.

D-6

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WELLS G&H SI PEREl ND SITE
FIVE-YEAR RE MEW INTERVIEW FORM

Sit# Name: W#ls GSH

EPA ID: MAD9S073216S

Iutei viename:

Iutei viewer affiliation:

Subject name: Catherine- Malagiida

Subject affiliation: VuiFii st Environmental

Compliance Manager

Subject contact information: cathrrinf ma

lagi ida a uni first, cow

Interview date: 12 20 2023

Interview time:

Interview location: N A

Interview format (circle one): In Person

Phone Mail Email Other:

Interview category: Potentially Responsible

Partj" (PR?) Settling Party (SP) Representative

1. What is your overall impression of the remedial activities at the Site"1

2.	What have been the effects of this Site on the surrounding community, if any*1

U111Ftrsf s groundwater and soil vapor extraction and treatment systems continue to reduce
VOC mass in the subsurface at and beyond the boundaries of the UniFirst properry. i iie-se

cleanup activities continue to lave a positive impact on downgradient properties and ensure
that the remedy remains protective of public health and the environment.

3.	What is your assessment of the current performance of the remedy in place at the Site?

See responses 1 and. 2 above.

D-7

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4. What are the findings from the monitoring data? What axe the key trends in contaminant
levels that are being documented over time at the Site?

See Section 6 of UmFirst's Year 31 Annual Report, see also response 1 above.

5, What is the frequency of on-site Q&M presence (e.g., continuous, weekly, monthly; estimate
hours)? Please describe O&M staff responsibilities and activities and frequency of site
inspections.

6, Have there beat any significant changes in sile 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.

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'1 Please
describe changes and any resulting or desired contaminant reductions, unproved cleanup
efficiencies, or cost savings.

D-8

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9. Are you aware of any complaints or inquiries regarding environment a 1 issues or the remedial
action from residents since implementation of the cleanup'1

10. Do you feel well-informed regarding the Site's activities and remedial progress'1, If not. how
might EPA convey site-related information in the future^

11. Do you have any comments, suggestions or recommendations regarding the management or

operation of the Site's remedy?

12. Do you consent to have your name included along with your responses to this questionnaire
in the FYR report'7

D-9

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WELLS G&H SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Wells G&H

EPA ID: MAD980732168

Interviewer name: Kirby Webster

Interviewer affiliation: Skeo

Subject name: Peter Cox

Subject affiliation: Wildwood Property Project Manager

Subject contact information: AECOM, 250 Apollo Drive. Chelmsford. MA 01824 | 978-764-4257

Interview date: December 6. 2023

Interview time: 9:00 a.m.

Interview location: 278 Rear Salem Street. Woburn. MA (on-site)

Interview format (select one): In Person Phone Mail Email Other:
Interview category: Potentially Responsible Party (PRP) /1Settling Party (SP) Representative]

1.	What is your overall impression of the remedial activities at the Site'.'

VOC concentrations are reduced in the majority of the site wells in overburden and bedrock since system
startup. VOCs in deep overburden are at or very close to cleanup levels. VOCs in shallower overburden
remain above cleanup standards in two general areas of the site:
o Northern Area.

o Southern Area, including an area adjacent to but south of the existing treatment cell.

Optimization work is underway for both overburden soils and bedrock in accordance with overburden and
bedrock work plans recently approved by EPA. Over 100 new air sparge wells are planned for installation
within and south of the treatment cell to address residual VOCs in overburden. Bedrock borings are being
installed and tested to determine optimal locations for additional recovery wells to improve capture of
bedrock groundw ater. Optimization work is anticipated to be completed in CY 2024.

Despite optimization efforts, residual VOCs are anticipated to remain in bedrock above cleanup levels after
remedy completion (as acknow ledged in ROD).

2.	What have been the effects of the Site on the surrounding community, if any?

Minimal. Work is performed on a private property not directly visible or adjacent to public areas.

3.	What is your assessment of the current performance of the remedy in place at the Site'.'

The remedy is progressing and the need for optimization of the aging treatment system is not unexpected. The
remedy for the overburden (air sparging and soil vapor extraction) has a good chance of meeting cleanup
goals follow ing optimization efforts. The remedy for bedrock (pump and treat) will take many more decades
and still may not meet cleanup criteria given the complex bedrock fracture networks and the contaminant type
present at the Site. The potential to not meet cleanup goals in bedrock was noted in the ROD and remains
unchanged.

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'.'

VOC concentrations in all waste streams (groundwater influent and soil vapor) have steadily decreased over
time, as expected. Follow ing system optimization completion in CY 2024, it is anticipated that additional
mass will be removed from the system in both soil vapor and groundwater influent.

D-10

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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.

A weekly presence is maintained to complete O&M activities. On average, the operator is on-site 3 days/week
to properly maintain the aging treatment system and complete requisite monitoring and sampling activities.
Following optimization of overburden impacts, it is envisioned that a less frequent presence will be required
to maintain the bedrock groundw ater pumping system.

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.

Tw o changes have been made to the O&M plan over the past 5 years, including (1) temporary removal of
vapor phase carbon treatment on the soil vapor collection system in 2018, and (2) starting in 2018,
groundwater monitoring was reduced from quarterly to a semi-annual basis at a key set of wells that provide
the best information to track remedial progress.

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 1 above. Optimization has the potential to significantly improve mass removal at the site from
both overburden and bedrock groundwater.

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'.'

Yes.

1 1. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy'.'

The optimization work currently underway will improve the Site's remedy performance, however, it is
expected that remediating bedrock groundw ater to the ROD cleanup standards will be technically impractical,
requiring a |technical impracticability! waiver in the future.

12. Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report'.'

Yes.

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WELLS G&H -SUPERFUND SITE
FIVE-YEAR REVIEW rMT^^ IE W FORM

Site Name: Wells G&B



EPA ID: MAD980732168

Iutei-viewer name:

Interviewer affiliation:

Subject name: Jeffrey Hansel

Subject affiliation: Wooriard & Curran, Inc.
Consultant to New England Plastics
Corporation

Subject contact information: jhamel« ivoortaricurrau.com

Interview date: December 18. 2023

Interview time:

Interview location:

Interview format (circle one): In Person Phone Mail Email Other:

Interview category; Potentially Responsible Party iPRP) 1 Settling Party (SP) Representative

1. What is your overall impression of the remedial activities at the Site?"

Substantial progress in satisfying the remedial objectives lias been made through the
implementation of the Source Control Remedy. Mann-Kendall -statistical trend tests using the
2023 poaadwattr results further indicate the effectiveness of the Source Control remedy by
confirming decreasing or stable concentration trends in sit# groundwater. Groundwater
concentrations from the litest data in site wells are below or only slightly over ROD levels.
Assessment of deep bedrock groundwater on-going as part of OU-2 work.

2, What have been the effects of this Site on the surrounding community, if any?

The implemented remedial actions have reduced VOC concentrations in soils anil
groundwater in this portion of EPA's Wells G&H site.

3. What is your assessment of the current performance of the remedy 111 place at the Site?

PCE (and TCE) concentrations have been significantly reduced from. pre-Source Control

Remedy concentrations. The Source Control Remedy (AS/SYE) operated at the Site from
February 2,1998 to March 7, 2000. The remedial objectives were to reduce contaminants in
unsaturated soil to cleanup levels identified in the ROB (EPA, 1989), and to reduce the
concentration of contaminants in the source area saturated and unsaturated soils and
overburden groundwater to the greatest extent possible. The final compliance soil sampling
data demonstrated that the Source Control Remedy was successful in achieving the objective
relating to remediation of unsaturated soils within the source area.

With respect to groundwater, operation of the Source Control Remedy has resulted in:

•	Significant reductions and continual decreasing and/or stabilizing PCE and TCE
concentrations in both source area and downgradient overburden and shallow
bedrock groundwater

*	An overall decrease in the area! extent of the plume.

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Substantial progress in, satisfying the groundwater remedial objectives lias been made
through At implementation of tie Source Control Remedy. All veils sampled during tie
litest monitoring rant {July 2023) exhibit decreasing or stabilized WCE and TOE trends in
groundwater cmtntriflHis (determined «k| Mann-Kendall trend: analyses) based on. a
comparison of results from lifS to present,

4.	Wftaf are tie findings from the monitoring data? What are tie key trends in contaminant levels
that are being documented over time at tlie Site?

The latest groundwater monitoring results (July 2023) indicate tint only one volatile organic
compound (VOC), FCE, was detected in tit- nine wells sampled during the ntit, Comparison
of ties# data to ROD cleanup levels indicates that die PCI {wcatrKkn in poundwater at
one monitoring wd (^Ef-191) was detected at a level slightly akrt the ROD cleanup level
(8.5 ngffl, compared to tie ROD level of 5 ugfl). TCE Is one of tlie other primary contaminants
of concern identified in tlie SOB. TCE was not detected in groundwater daring the July 2025
sa.fBpl.inf event Since 2007 and ilaring tlie past nine groundwater sampling events,
concentrations of TCE hare ronixNl below SOD deanop levels,

AH wells sampled, during the latest monitoring event (July 2023) exhibit decreasing or
stabilized PCE and TCE trends in groundwater concentrations (determined using Mann-
Kenial tread analyses') based mi a n^nben of results from 1®SS to present

5.	What is the frequency of on-site O&M presence(e.g.7 continuous, weekly, monthly: estimate
hows)? Please describe OAM staff responsibilities and activities and frequency of site
inspections.

There is no on-site O&M presence as the system, 'was terminated in. 2000 and groundwater

monitoring is conducted in one field day every two years,

§, Have there been any significant changes .in site O&M rec|iiirements. maintenance schedules or
sampling routines since start-up or in. tlie last five years'? If so, do they affect the effectiveness
of fie remedy? Please describe changes and impacts, if any.

The system was shutdown in March 2000. Annual groundwater monitoring was conducted
until 2011 at which time the frequency was switched to biennial and sampling events
performed every 2 years since that time. Groundwater levels continue to be stable or
decreasing over time.

7. Have there been unexpected O&M. difficulties at tlie Site since start-up or in tie last five years?
If so, please provide details,

Suae, the active system was shut-down in 2000 after meeting cleanup levels.

D-13

-------
S Have there oeeii opportunities fo optimize 0"EP

10. Do you feel ivell-iiifb.mied. regarding rlie Site's activities and remedial progress1" If not. liovr
miglit EPA convey die-re J a led information in the future1

Yes, no additional infoimation or methods needed

11	Do vou have any comment;. suggestion; or recommendations regarding the management or

operation of the Site's remedy?

None at this time

12	Do you consent to hare your name included along will your responses to fliis questionnaire in
the PYR report'?

Yes

D-14

-------
WELLS G&H SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Wells G&H

EPA ID: MAD980732168

Interviewer name: Kirby Webster

Interviewer affiliation: Skeo

Subject name: Frank Cherena

Subject affiliation: Roux Associates. Inc.

Subject contact information: fcherena@rouxinc.com

Interview date: 12/22/2023

Interview time: 12 p.m.

Interview location: virtual

Interview format (circle one): In Person

Phone

Mail

Other:

Interview category: Potentially Responsible Party (PRP) / Settling Party (SP) Representative

Note: Responses provided below are limited to the 60 Olympia/Former Drum Disposal Area (FDDA) and are not
intended to discuss/describe the overall Wells G&H Superfund Site.

1.	What is your overall impression of the remedial activities at the Site'.'

Remedial activities at the FDDA have been on-going for an extended period of time and have been effective
in targeting the source of contamination at the FDDA. However, the standards set forth in the ROD have not
yet been achieved for the FDDA; additional work will be necessary to achieve the ROD standards.

2.	What have been the effects of this Site on the surrounding community, if any?

We are not aw are of any effects of this Site on the surrounding community since the last FYR.

3.	What is your assessment of the current performance of the remedy in place at the Site'.'

Based on data previously collected by others, as well as data collected to date by Roux. the remedial actions
that have been implemented at the FDDA have progressed the Site towards closure. However, additional work
will be necessary to achieve the ROD standards.

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'.'

Monitoring data has been collected from the FDDA for several decades. Contaminant concentrations in
groundw ater have generally been reducing.

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 are no active systems requiring O&M at the FDDA.

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.

There are no active systems requiring O&M at the FDDA.

D-15

-------
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.

There are no active systems requiring O&M at the FDDA.

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.

There are no active systems requiring O&M at the FDDA. However, in October 2023 Roux began a
characterization investigation with the goal of evaluating current site conditions in order to design and
implement a remedy to expedite the remediation of the FDDA.

9.	Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from
residents since implementation of the cleanup'.'

I am not aware of any complaints or inquiries from residents at this time.

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'.'

Yes. the EPA has been helpful in providing information regarding the Site.

1 1. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy'.'

Not at this time.

12. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report'.'

Yes.

D-16

-------
WELLS G&H SVPERFUND SITE
FIVE YEAR KL\ ILW IM LRVIEW FORM

Site Name: "Wells G&H

Interviewer name:

Interviewer affiliation:

Subject name: Peter Nangerani

Subject affiliation: Project Coordinator for
Ol"4 Performing Settling Defendants	

Subject contact information: pnangeraniYiwooclardcui ran.coin

Interview date: December 15,2023

Interview time:

Interview location: via email

Interview format (circle one): In Person

Phone

Email

Other:

Interview category: Potentially Responsible Party (PRP'jSettling Party (SP) Representative

1,	What is your overall impression of tlie remedial activities at the Site'? My i espouses are
limited to Operable Unit 4 {GU 4}- My impression is that OU4 remedial activities are
proceeding in accordance with the ROD and SOW

2,	What have been the effects of this Site on the surrounding community, if any? I do not
believe tlieie have been any effects from OU4 on the surrounding community,

3,	What is your assessment of the current performance of the remedy in place at the Site? Not
applicable, the OU4 remedy is not in place yet,

4,	What are the findings from the monitoring data? What are the key trends in contaminant
levels that are being documented over time at the Site'? We do not have sufficient rounds of
around water monitoring data to assess trends yet. but 1115" impression of the initial
groundwater data we have collected is that groundwater concentrations are generally lower
than expected based on the RI and historic data

5,	What is the frequency of on-site OJtM presence{e,g,, continuous, weekly, monthly: estimate
hours)'? Please describe O&M staff responsibilities and activities and frequency of site
inspections. O&rM is not applicable to GU4 at tins time as we are in the Remedial Design
1RD1 stage,

6,	Have there been any significant changes in site O&M requirements, maintenance schedules
or sampling routines since start-up or 111 the last five years'? If so. do they affect the
effectiveness of the remedy? Please describe changes and impacts, if any. Not applicable.

7,	Have there been unexpected OtSrM difficulties at the Site since start-up or 111 the last five
years'? If so. please provide details, Xot applicable.

D-l 7

-------
S, 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. Not applicable

9.	Are you aware of any complaints or inquiries reaarcling environmental issues or tlie remedial
action from residents since implementation of the cleanup? Xo

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? Yes

11.	Do you have any comments, suggestions or recommendations regarding the .management or
operation of die Site's reined}'? Xo

12,	Do you consent to have your name included along with your responses to this questionnaire
in the FYR report? Yes

D-18

-------
Community Stakeholders

WELLS G&H SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Wells G&H

EPA ID: MAD980732168

Interviewer name: Kirby Webster

Interviewer affiliation: Skeo

Subject name: Michael L. And Linda A. Raymond

Subject affiliation: ASC

Interview date: December 5, 2023

Interview time: 1 p.m.

Interview location: 10 N Maple Street. Woburn MA 01801

Interview format (select one): In Person

Phone

Mail

Email

Other:

Interview category: Resident

1.	Are you aw are 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 the 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'.'

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 pro ject'.'

None.

D-19

-------
APPENDIX E - OU-1 GROUNDWATER RESULTS SUMMARY

Table E-l: Current Maximum Groundwater Contaminant Concentrations Above ROD Cleanup Levels by

Property for Select COCs					





ROD
Cleanup

Level"
(MS/L)

Maximum

Detected

Cu rrent

Well Location / Date of

Current Maximum
Detected Concentration
During the FYR Period

OU-1 Source Area
Property



Concentration

Maximum

Contaminant

Reported in
2019 FYR
Report
(UU/L)

Detected
Concentration
(M«/L)

Grace

PCE

5

19

7.4

RW17 / Mav 2020



TCE

5

91

110

G16S/May 2021



cis-1.2-DCE

70

180

210

RW22RE / Mav 2023



Vinvl chloride

2

2.1



not applicable

UniFirst

PCE

5

2,500

6,000

UC-5/Mav 2019



TCE

5

440

480

UC7-2 / Mav 2020



cis-1.2-DCE

70

230 J

480

UC11-2/May 2023



Vinvl chloride

2





not applicable

NEP

PCE

5

12

8.5

NEP-101 / Julv 2023



TCE

5

38



not applicable



cis-1.2-DCE

70





not applicable



Vinvl chloride

2





not applicable

Wildwood

PCE

5

113







TCE

5

21,000

Total VOCs
87,230b

MHPT-4 (43-47)



cis-1.2-DCE

70

1,500

(groundwater grab sample



Vinvl chloride

2

364

through July 2022)



TCA

200

510





Olympia

PCE

5

22

110

MW-213SX/March 2020



TCE

5

5,700

7,400

MW-205DX /April 2021



cis-1.2-DCE

70

9,200

15,000

MW-2 10D / April 202 1



Vinvl chloride

2

530

4,700

MW-2 10D / April 2021

Notes:

a)	cis-1.2-DCE is a TCE degradation product. It is a monitored compound in OU-1 and has been included in previous
FYR Reports. The MCL for cis-l,2-DCE is 70 ng/L.

b)	Individual VOC results were not available for review for the Wildwood property. Total VOCs were presented on
Figures 3 A and 3B of the September 2023 Work Plan to Optimize Air Sparge System at Wildwood Property. Rev. 2.

J = estimated concentration

~ = either not detected or detected below ROD cleanup level / MCL
Sources:

2023 Annual Monitoring Report - W.R. Grace OU-1 Source Area, dated December 2023.

RD/R A Combined Years 29/30 Annual Report for the UniFirst Site, dated January 2023.

2023 Groundwater Monitoring Report (NEP), dated September 2023.

Work Plan to Optimize Air Sparge System at Wildwood Property. Rev. 2, dated September 2023.

Project Memorandum: Summary of Activities: November 2020 to December 2021, 60 Olympia Avenue, dated

February 2022.

E-l

-------
Table E-2: PFAS Sampling Results Summary, by Property (prepared by HGL)

Summary of PFAS Groundwater Anafyticaf Res
OUl- Source Area Properties

SKAwilU-	ULfnl,.,-,, *J8 fti

yKcits ooLft aupenuna ojiCf wouwrn^ iwi











H6«afiuo-oofoov'ene









Mixtures Containi ng







Perfiucrooctanesutfonic

Perfluorooctano?c

PerflucrobutanesuFon-c

Oxide-Dimer Acid

Ferffeiofofcesanesalfomk

Perfluoronoanoic

FsrffiKifateptaftDic

l^sfiuorodec^Dk

TWO Of Mots of PFHxS,

Sum* of

Sample ID

L^tholofic Unit

Acid iPFOS)

Acid jPFOAl

Acid |PFBSj

(HFPO-DA) "Gen-X"

Acid fWWs5|

Acid (PFNA)

Acid {PFHpAj

Acid (PFDA)

PFNA, HFPO-OA, and PFBS

MassDEP PFASS

Massachusetts MCL

Sum of 6 (combined)'

NA

NA

Smm of 6 (combined)



20 ppt

LSEPAMG.'

4 ppt

4ppt



1C ppt / H!=lu

10ppt/Ht=i!'

10 ppt / Hl=lfa

MA

NA

Hi—1

-NA

#.R» Grace







613D

Jppsr Bed ock

ISA

14.6

1.4 J

MR

1.56 J

. l -: .

3J2

1.77 U

Ht=0.2

35.7

616S

Unccnjolidate-d

0.38 J

4,23

0 ? J

m

0.41 J

l^~ u

0.6 J

1.77 U

1-1=1 C4

5.7

G16D

t'oper Bedrod

0.93 J

5.S8

0 62 J

m

0.52 J

12 U

0.89 J

1.8 U



7.9

S24S

UnccTiio!id2te3

3.63

15.3

.15

m

1.07 J

0 € J

4.01

1.75 U

h'=o :

24.6

G24D

Jpper Bedrock

3.20

21.9

.0 4

m

1.32 J

C 31 1

6.06

1.78 U

H =0 2

32.8

G40D

Jopsr Bedrock

0.26 J

0.47 J

i 1£ J

m

LIS U

ln5 L

0.63 J

1.79 U

-* =0 0006

1.4

S319-M

Unccnioiidsted

32.3

7?,?

13"

m

2.19

C 99 J

4.75

1.82 U

H'=Ol

62.4

G37S

Unconsolidated

17,6

UA

158 J

m

1.29 j



5.93

1.83 U

Hi=0.2

40.1

UniFirst











UC25

I nccnjolidated

22

10

7.6

m

2.4

1.0 i

2.5

0.46 U

H =C» 5

37.9

UC25!DUPi

Unconsolidated

25

10

8.4

NR

2.7

1.1 J

2.6

0.45 U

H =3 4

4L4

S71S

Unconsolidated

16

12

4.4

NR

4.1

1 0 J

3.1

0.47 U

H =3 5

36.2

UC6

Unconsolidated

1.8 U

SJs

1.8 I#

NR

7 0

C 45 t

2.4

0.45 U

H'=3 7

14.0

JC.

i- r:y-i:ri 'l c;er S s 3"CCf

12

14

2."

NP

2.1

12.1

5.2

1 1 1

H =0 3

35.6

"¦-C

Jpper Bedrocl

22

15

3

NR

6.7

C S3 J

3.4

0 45

H=08

4S

^DD

UDoer Bedrock

11 Ml

19

I>_ U

NR

16

0.9 j

45

0 45 J

H!=2

5L4

Qfympia



Unconsoiidsted

6.7

11

IS !

1.9 U

2.6

0.82 J

2.5

1.9 u

Hi=0.3

23.6

IV"W-202j

Unconaoiiosted

4.5

6.5

0 91J

1.8 U

1.5 J

0.67 J

1.4 j

1.8 U

o

ii
X

14.6

!V'W-205D

Inccnioiidstsd

2-6

4.6

3 3£ J

2.1 U

1.1 i

" : V

0.71 j

2.1 U

Hi=0 1

9

f/Vtf-206D

Lnccn:oii03ted

3.7

5,9

0 4c J

2.0 U

1 J

: t

1.1 j

2.0 y

H =0 1

11.7

JVPA -215 f/

Unccnsaiidated

1.7' U

1.7 U

17 U

1.7 U

0.49 J

17 u

0.096 J

1.7 U

H 1=0 C 5

0.6

MW-ilSM'DJP)

Ineonsohdaced

2.0 U

2.0 U

20 U

2.0 U

2.0 U

2.0 I*

2.0 U

2.0 U

H =0

NO

M-llSS

Lnconjohd-ated

3-D

4.2

C 31 J

1.8 U

0.92 i

1st

0.65 j

1.8 U

Hi=D K?

8.8

MW-217M

Unconsolidated

2.9

4.3

0 63 J

1.8 U

1.6 J

1.8 L

0.97 J

1.8 U

X
ii

o

9.8

NEP

EV-:

Lnccn:ohdsted

25.2

55

10.1

4S? U

4.98

2.45

C5"

1.96 J

Hi=0 7

96.2

mef-:o~

Unconsolidated

31A

56.7

s.ss

-"J .

6.09

3 04

3 "4

1.51 J

H =0 9

107

NEP-10-B

Upper Bedrock

273

49.2

8 86

4" 2 U

4.44

23_

922

LBS J

H =3 7

92,5

NEP-104B

Upper Bedrock

22.6

58.4

-¦-g

4.

c:

4.43

187 L

i 34

I.S4 J

Hl=0 4

MA

NEP-106B

Upper Bedrock

14.6

48,5

bbS

4S.b U

3.64

1MI

6.99

1.86 U

HI=-0 4

73.7

NEP-10SB

Upper Bedrock;

21.3

76.4

*3

46.9 U

4.61

ISt" u

9.49

1.87 U

H =0 5

111.8

Wif'd%#ooeli







BW-6R>-3>

Lower Bedrock

8.78



1.58 J

MR

1.06 J

las

4,34

L12 J

HI=1.5

37.4

S^V-13

Upper Bedrock

10.3

12.1

5.92

NR

2.54

1.24 J

2.88

1.77 U

H=0-f

29.1

3W-14BD

UpprBrfrock

2.88

1.51 J

1.46 J

NR

1.92

0.36 J

1.85 U

1.85 U

H =0 2

6.70

SW-17F

Upper Bedrock

3.07

4.14

1.00 J

m

0.464 j

C J

2,57

0.311 J

o
X

11.2

BW-I7P IDJP,

Upper Bedrock

3.37

4.08

1.09 J

m

0.536 J

n^5 I

2.56

0 365 i

H =0 a.

11.6

WW-20CT1

Unconsolidated

11.2

12.4

4.23

m

2.84

U 7S2 j

3.31

1.83 U

H'sG*

34,8

WW-2C2

Unconsolidated

11&

15.5

4.94

m

2.S3



4.26

1.82. U

H =0 5

42.7

WW-205",

Unconsolidated

5.16

8.01



NR

1.44 J

C b5 J

1.92

1.S2 U

H«3 2

21,5

WW-2C6

Lnconso idsted

5.3

7.5



NR

1.66 J

u l

2.43

1.82 U



26.8

WW-23£j

Lncc ijo is a fee

4.7a

6.44

1C

NR

1.69 J

0 62"*

1.81

1.76 U

- =.:

26.2

WW-211D

Unconsolidated

WA

UA



NR

2.71

C b2 J

2.97

1.87 U

H=3 3

32.9

E-2

-------
APPENDIX F - GRACE PROPERTY DATA REVIEW FIGURES AND TABLES

Figure F-l: Water Table Map, 2023

XZ33I

LEGEND

RW17* ACTIVE RECOVERY WELL LOCATION
RWI9® FORMER RECOVERY WELL LOCATION
G36S* MONITORING WELL SCREENED IN THE UNCONSOLIDATED
DEPOSITS

UG19,MONITORING WELL SCREEN IN THE UNCONSOLIDATED

DEPOSITS AND BEDROCK
G39D» MONITORING WELL SCREENED IN THE BEDROCK
UC22* UNIFIRST DEEP BEDROCK RECOVERY WELL

	WATER LEVEL CONTOUR (5 FEET INTERVAL)

* NOT USED IN CONTOURING
- - - ESTIMATED UNCONSOLIDATED DEPOSITS CAPTURE ZONE
^ APPROXIMATE FLOW DIRECTION

	 STREAM

WETLANDS

	APPROX. FORMER W.R. GRACE PROPERTY BOUNDARY



Source: 2023 Annual Monitoring Report, W.R. Grace OU-1 Source Area. Prepared by GES and J.G. Environmental, Inc. December 2023.

F-l

-------
Figure F-2: Shallow Bedrock Potentiometric Surface Map, 2023

LEGEND

RW1T ACTIVE RECOVERY V\£LL LOCATION
RW19* FORMER RECOVERY WELL LOCATION
G39D* MONITORING \AELL SCREENED IN THE BEDROCK
UC22# UNIFIRST DEEP BEDROCK RECOVERY WELL

	WATER LEVEL CONTOUR (5 FEET INTERVAL)

* NOT USED IN CONTOURING
- - - ESTIMATED SHALLOW BEDROCK CAPTURE ZONE
^ APPROXIMATE FLOW DIRECTION

	 STREAM

S&. WETLANDS

	APPROX. FORMER W.R. GRACE PROPERTY BOUNDARY

NOTES:

NM - Not Monitored

Water level from shallow bedrock well in the well cluster is used for
contouring. See Table 2-1 for water levels from other wells in the duster. ~x

Only monitoring wells gauged and/or sampled under the current
W.R. Grace annual monitoring program are depicted on the East and
West Cummings Park properties.

Shallow Bedrock Potentiometric SurfaceMap
August 14,2023

W.R Grace
Woburn.MA

11/28/23

Source: 2023 Annual Monitoring Report, W.R. Grace OU-1 Source Area. Prepared by GES and J.G. Environmental, Inc. December 2023.

F-2

-------
Figure F-3: PCE Distribution in Unconsolidated Deposits and Shallow Bedrock Groundwater, 2023

ND {°'501 o-36

ND (0.50|

LEGEND

RW17* ACTIVE RECOVERY WELL LOCATION
RW19* FORMER RECOVERY WELL LOCATION
r.,c MONITORING WELL SCREENED IN THE UNCONSOLIDATED
G36S DEPOSITS

iinq. MONITORING WELL SCREEN IN THE UNCONSOLIDATED

DEPOSITS AND BEDROCK
G39D* MONITORING WELL SCREENED IN THE BEDROCK

W.R. Grace
Woburn, MA

Drawn	I Date

GKS	I: 11/29/23

Designed	Figure

DMC	4-1

Approved	3"'

scs

Scale In Feel (Approximate)

r~i zra m
LZiajffS

WATER QUALITY DATA

3.2 D TETRACHLOROETHENE (PCE)

L DUPLICATE SAMPLE
CONCENTRATIONS IN ug/L
ND(1) = NONDETECT AT REPORTING LIMIT
SAMPLES COLLECTED IN MAY 2023

CONCENTRATION GREATER THAN MCL/ROD CLEANUP
LEVEL FOR PCE (5 ug/L)

ESTIMATED REGION GREATER THAN 5 ug/L BASED ON
MAY - JUNE 2023 CONCENTRATIONS
ESTIMATED UNCONSOLIDATED DEPOSITS CAPTURE ZONE
ESTIMATED SHALLOW BEDROCK CAPTURE ZONE
STREAM
WETLANDS

• APPROX. FORMER W.R. GRACE PROPERTY BOUNDARY



Source: 2023Annual Monitoring Report, W.R. Grace OU-1 Source Area. Prepared by GES and J.G. Environmental, Inc. December 2023.

F-3

-------
Figure F-4: TCE Distribution in Unconsolidated Deposits and Shallow Bedrock Groundwater, 2023



G36S* "

UG19*

LEGEND

RW17* ACTIVE RECOVERY WELL LOCATION
RW1 FORMER RECOVERY WELL LOCATION

§ MONITORING WELL SCREENED IN THE UNCONSOLIDATED
DEPOSITS

, MONITORING WELL SCREEN IN THE UNCONSOLIDATED
DEPOSITS AND BEDROCK
G39D* MONITORING WELL SCREENED IN THE BEDROCK
WATER QUALITY DATA

3.2 D TRICHLOROETHENE (TCE)

L DUPLICATE SAMPLE
CONCENTRATIONS IN ug/L
ND(1) = NONDETECT AT REPORTING LIMIT
SAMPLES COLLECTED IN MAY 2023

CONCENTRATION GREATER THAN MCL/ROD CLEANUP
LEVEL FOR TCE (5 ug/L)

¦ - - ESTIMATED UNCONSOLIDATED DEPOSITS CAPTURE ZONE
- - - ESTIMATED SHALLOW BEDROCK CAPTURE ZONE
STREAM
WETLANDS

	APPROX. FORMER W.R. GRACE PROPERTY BOUNDARY

MAY 2023 TCE CONCENTRATIONS > 5 ug/L

W.R. Grace
Woburn, MA

11/28/23

<*-DP11
*K.7

V

Source: 2023 Annual Monitoring Report, W.R. Grace OU-1 Source Area. Prepared by GES and J.G. Environmental, Inc. December 2023.

F-4

-------
Table F-l: Estimated Annual Volume of Water and Mass and Volume of VOC Removal from October 1992 through September 2023

Table 3-6: Estimated Annual Volume of Water and Mass and Volume of VOC Removal
from October 1992 through September 2023****

Year of

Calendar Year

Volume of Water Removed

Estimated VOC Mass Removed

Operation

(Mgallons*)

Pounds**

Gallons***

1

October '92 through September '93

4.4

18.2

1.60

2

October '93 through September '94

2.8

10.4

0.90

3

October '94 through September '95

2.6

8.2

0.70

4

October '95 through September'96

3.7

5.0

0.40

5

October '96 through September '97

4.58

3.3

0.30

6

October '97 through September '98

4.3

8,2

0.70

7

October '98 through September'99

2.62

3.8

0.34

8

October '99 through September '00

3.21

3.6

0.32

9

October '00 through September '01

3.27

5.0

0.44

10

October '01 through September '02

2.38

2.4

0.21

11

October '02 through September '03

3.92

4.4

0.39

12

October '03 through September'04

3.72

3.0

0.26

13

October '04 through September '05

4.11

2.2

0.19

14

October '05 through September '06

4.14

1.6

0.11

15

October '06 through September'07

4.45

1.5

0.13

16

October '07 through September '08

3.69

1.4

0.13

17

October '08 through September '09

4.43

1.2

0.10

18

October'09 through September'10

4.29

1.0

0.09

19

October'10 through September'11

3.89

1.61

0.14

20

October'11 through September'12

4.66

1.48

0.13

21

October'12 through September'13

4.05

1.38

0.12

22

October'13 through September'14

2.96

1.40

0.12

23

October'14 through September'15

2.87

0.79

0.07

24

October'15 through September'16

2.14

0.92

0.08

25

October'16 through September'17

2.50

0.86

0.08

26

October'17 through September'18

2.73

0.99

0.09

27

October'18 through September'19

2.70

0.40

0.04

28

October'19 through September'20

2.70

0.59

0.05

29

October '20 through September '21

3.03

0.62

0.05

30

October '21 through September '22

3.04

0.77

0.07

31"

October '22 through September '23

2.44

1.06

0.09

Total

106.31

97.27

8.44

Notes:

* Mgallons = Million Gallons
** Volume of water removed and estimated
pounds removed during Year 31
derived from Table 3-5. Data rounded to two
significant figures.

*** See example calculation
**** Data shown for calendar years October '92

through September '23 obtained from previous
annual reports.

Example Calculation - Volume (Gallons) of VOC removed during Year 31
Volume= mass/density of VOC

Density of VOC=density of water x average specific gravity of VOC
Density of water = 62.4 lb/ft3 at 15.56°C

Volume = ((1.06 lb/(62.4 lb/ft3 x 1.36)) x 7.48 gal/ft3) = 0.09 gallons

Conversion: 1ft3 = 7.48 gal
Average specific gravity of VOC = 1.36

Source: 2023 Annual Monitoring Report, W.R. Grace OU-1 Source Area. Prepared by GES and J.G. Environmental, Inc. December 2023.

F-5

-------
APPENDIX G - UNIFIRST PROPERTY DATA REVIEW FIGURES AND TABLES
Figure G-l: Unconsolidated Deposits Water Level Elevations, May 2023

Legend

Monitoring Location

Monitoring Location (Not Measured)	1 Source Area P roperties

-	Equipotential (51)		Roads

-	Equipotential (5', Inferred)	NWI Wetlands

| Buildings

Basemap information compiled by The Johnson Company
and provided to Arcadis U.S. by UniFirst Corporation.

NOTES:

1.W&ter	levels were measured on May 23-24,2023.

2.Elevationsare	in feet NG\<0 1929.

3.	VWiere water level values are underlined for multilevel
monitoring locations, only the underlined value wa s used for
contouring equipotentials.

4."*"	indicates water level was not used for contouring equipotentials.

5.During	the water level measurement event on May 23-24,2023, the
daily average UC22 extraction rate was43.5 gallons per minute (gpm)
and the daily average EX1 extraction rate was 3.5 gpmGrace recovery
wells RWI7, RW20, and RV\22RE were active during collection

of the water level measurements shown. Refer to the Grace Annual
Monitoring Report for a more-detailed evaluation of the water levels in the
vicinity of the Grace recovery wells.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

WELLS G&H
WOBURN, MASSACHUSETTS

UNCONSOLIDATED DEPOSITS
WATER LEVEL ELEVATIONS (MAY 2023)

I FIGURE

^AROUDIS A-2A

-------
Figure G-2: Upper Bedrock Water Level Elevations, May 2023

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15,2023.

Legend

Basemap information compiled by The Johnson Company
and provided to Acadis U.S. by UniFirst Corporation.

NOTES:

1 ,V\feter levels were measured on May 23-24,2023.

2.Elevations	are in feet NGVD 1929.

3.	Where water lev el values are underlined for multilevel
monitoring locations, onlythe underlined value was used for
contouring equipotentials.

4."*"	indicates water level was not used for contouring equipotentials.

5.During	the water level measurement event on May 23-24,2023, the
daily average UC22 extraction rate was 43.5 gallons per minute (gpm)
and the daily average EX1 extraction rate was 3.5 gpmGrace recovery
wells RWI7, RW20, and RW22RE were active during collection of the water
level measurements shown. Refertothe Grace Annual Monitoring Report
for a more-detailed evaluation of the water levels in the vicinity of the
Grace recovery wells.

WELLS G&H
WOBURN, MASSACHUSETTS

UPPER BEDROCK
WATER LEVEL ELEVATIONS (MAY 2023)

I FIGURE

ARCADIS A-2B

G-2

-------
Figure G-3: Lower Bedrock Water Level Elevations, May 2023

Legend

© MeniKfing Location

	 Eauectcitm <;s>

—I—i—| EautwtenM <:r.

Basenvap information c&rplied by The Johnson Company
and provided 10 ArcadlE U.S. oy UniFast Corporation.

MOTES:

i Water levels were measured on Way 19,2022.

£.Eieval5ons are in feet NGVD 1529.

3.Where water level values aire underlined for multilevel
mofliwmg locations, only eie underlined value was used for
contouung equlpotefiBals.

4-"™ macates water level was nsl used for contouring esuipcsentials.
E.Dwing trie water level measurement event on
May 15.2B22. the daily average UC22 extraction rate was 43.0 ganons
per minute (gpm} and eie daily average EX 1 extraction rate was 3.9 gpm.
Grace recovery wells RW17, RW2D. and RW22RE were active
during coftecBon of the W3ier level measurements sticwn. Refer to
the Grace Annual Monitoring Report for a more-detailed evaluation
of the water levels in the tfcinity of the Grace recovery wells.

WELLS G&H
WOBURN, MASSACHUSETTS

LOWER BEDROCK
WATER LEVEL ELEVATIONS (MAY 2022)

FIGURE

B-2C

P»ARCADIS

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15,2023.

G-3

-------
Figure G-4: Time-Concentration Graph for Shallow Bedrock Well UC7-2, UniFirst Property

Shallow Bedrock Well UC7-2
(All Data)

25000

£ 20000

15000

10000

5000

"T—l^t

9/30/92 System Startup

7



1—I 1*1 I I i r

i *i *i i, I, ti«,; i, j

0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.

-PCE

TCE

•cis-l,2-DCE

Shallow Bedrock Well UC7-2
(2010-2023 Timeframe)



	PCE 	TCE 	cis-l,2-DCE

L ND entries without detection limitsnot plotted; ND entries with detection limits plotted asopen symbols.
2. t flagged data (Exceeds Calibration Range) not plotted when non E flagged data exist for the same sample date.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-4

-------
Figure G-5: Time-Concentration Graph for Shallow Bedrock Well UC7-3, UniFirst Property

Shallow Bedrock Well UC7-3
(All Data)

'^¦Lnt£)r>NOOCTiO*Hr\im'^-LnvDr>«oocnOtHrNiro,=tin^DrvoocriOtHr\iro'^LntDr^coa)0*H(Nro
oooooooooooocn(j)cricr)aia>cnai(^cnooooooooooHHHHHHHHHHNN(NfM

6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.6.

(D(D(D(D(D(L>
-------
Figure G-6: Time-Concentration Graph for Unconsolidated Deposits Well S71S, UniFirst Property

Unconsolidated Deposits Well S71S
(All Data)

2000

_ 1800

J 1600
¦—

I 1400

1 1000
.1 800

to

I 600

a>

c 400

o

u

200







		 9/30/92 Syste m Sta rtu p











	\





\



1

\







v





V

iN'1! i i r*T~



Q.aaaaaaaaaaaaa.aa.aaa.Q.aaaaaaaaaiiaaaQ.aQ.aaaa

(DQJ(D(D(UCD(D(D(D

-PCE •

-TCE

Unconsolidated Deposits Well S71S
(2010 - 2023 Timeframe)

100

80

60

,o 40

20

—r-

o

-PCE

-TCE

1.	ND entries without detection limits not plotted; ND entries with detection limits plotted as open symbols.

2.	E-flaggeddata (ExceedsCalibration Range) not plotted when non E-flagged data exist for the same sample date.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-6

-------
Figure G-7: Time-Concentration Graph for Unconsolidated Deposits Well S81M, UniFirst Property

Unconsolidated Deposits Well S81M
(All Data)

250

£ 200

£

S

o1 150

h.

u

1

o 100

o

u

50

















-—— 9/30/92 System Startup ^





	

0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.0.

Q)d>

5 50

O

*—1



O

*—1

fN





H

*—t

T—1

*—1

H

H

H

«-H

tH

rsi

rM

OJ



C

C

C

c

c

C

C

C

c

c

c

c

c

c

-------
Figure G-8: SVET System Plan, UniFirst Property

LEGEND

Property lino
Building footprint

Approximate location of block wall
Fencellne

Concrete retaining wall
Wood retaining wall
Water line
Sewer line

UC7A©

SV-01 #

SVE-1 0

SVM-101 ®
SV-01 O

Approximate storage area footprint
Groundwater monitoring well location
Previous sub—slab soil vapor sampling location
2012 soil vapor extraction (SVE) point location
2012 soil vapor monitoring (5VM) point location
2014 soil vapor extraction (SVE) point location
2014 pa wive air Injection point location
2014 soli vapor monitoring (SVM) point location
2014 sub—slab soli vapor monitoring location

Notes:

1. Base map prepared by Col—East, Inc. of North Adams, MA. at a
scale af 1 Inch = 100 feet from April 1990 aerial photographs
modified after Martinage Engineering Associates, Inc. Nov.2, 1992.
All property line# are approximate. Well locations from a survey
by BSC Group of Boston, MA.

Interior building information from an undated La>out Drawing of
the Extra Space Storage Operation provided to UnlFTrst Corp.

S\E, SVM, SV, and PI point locations based an field survey by
The Johnson Company.

All locations are approximate.

PLAN REFERENCE:

BASE PLAN PREPARED BY ENSR CONSULTING * ENGINEERING;
BASEMAP INFORMATION COMPILED BY THE JOHNSON COMPANY AND
PROVIDED TO ARCADI5 U.S. BY UNIFIRST CORPORATION

GRAPHIC SCALE

UNIFIRST CORPORATION
15 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS

SVET SYSTEM
EXTRACTION AND MONITORING POINT
LOCATIONS

PIARCADIS B.

QNtaKCmMnnqr

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-8

-------
Figure G-9: SVET System - Total VOC Concentrations at SVE Points, UniFirst Property

Figure 9: SVET System - Total VOC Concentrations at SVE Points

UniFirst Property
Woburn, Massachusetts

Oct-15

Oct-16

Oct-17

Oct-18 Oct-19
Date

Oct-20

Oct-21

Oct-22

Oct-23

—SVE-1 —»-SVE-2A	SVE-3A	SVE-4A -B-SVE-5	SVE-6

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-9

-------
Figure G-10: SVET System - Estimated Cumulative Mass Removal by SVE Points, UniFirst Property

Figure 10: SVET System - Estimated Cumulative Mass Removal by SVE Points

UniFirst Property
Woburn, Massachusetts

60.0

6.0

50.0

40.0

¦S 30.0

20.0

10.0

Oct-15

Oct-16

Oct-17

-SVE-2 A

SVE-3A

Oct-lS	Oct-19

Date

SVE-4A —SVE-1

Oct-20

Oct-21

Oct-22

0.0
Oct-23

¦SVE-5

SVE-6

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-10

-------
Figure G-ll: December 2021 PFAS Sampling Locations

Legend	\

EX ICD	Extraction Well

PZ3S A	Shallow Unconsolidated Deposits Piezometer Location

PZ3DB	Deeper Unconsolidated Deposits Piezometer Location

UC6S#	Unconsolidated Deposits Mentoring Wei Location

UC15D #	Bedrock Monitoring Wei Location

^	PFAS Sampling Location

		Roads

	J	BuSdings

"i	Property Boundary

UNI FIRST CORPORATION
15 OLYMP1A AVENUE
WOBURN. MASSACHUSETTS

BASEMAP INFORMATION COMPILED BY THE
JOHNSON COMPANY AND PROVIDED TO
ARCADIS U.S. BY UNIFIRST CORPORATION.

DECEMBER 2021 PFAS SAMPLING
LOCATIONS



^ARC^DIS

Olympia Avenue

UC7-1
UC7-2
UC7-3
UC7-4
UC7-5

S7104S71S

UC10-2
UC10-3 ^
UC10-4 / UC10D
UC10-5 4

ucio-6 I m

' UC10-M

I

\ UC6S

13-

UC15D
UC15S

	UC6- -

UCS-1

	 UC9-2

		UC9-3- —

• UC3-4
UC22BH UC9-5

_ _ ura-fi

.PZ1SA	PZ2SA

PZ1D® EX1IS	PZ2D*

~H~v—r~—-

Source: PFAS Sampling letter report. Prepared by UniFirst. January 31, 2022.

G-ll

-------
Table G-l: 2023 Groundwater Quality Data, UniFirst Property

Spring 2023 Groundwater Quality Data

Chemical

1, 1,1 -T richl oroet'h an e
-14/2^2-Tetrschloroe thane
. 1,1,2-T ri ch 1 or oe th an e

1.1-Dichloroethane
%1-Dichloroethene
1/2-Dichloroethane

1.2-Dichioroethene
1,2-Dichloropropane
2-Hexanone
4-Methyl-2-pentanone
Acetone
Benzene

Bromodichloromethane
Bromoform
Bromom ethane
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chioroethane
Chloroform
Chloromethane
cis-l,2-Dichloroethene
cis-l,3-Dichloropropene
Dibromochloromefhane
Ethylbenzene
m-&p-Xylenes
Methyl Ethyl Ketone
Methylene Chloride
o-Xyiene
Styrene

Tetrachloroethene
Toluene
trans-l,2-Dichloroethene
tran s-1,3-Dlchi orop ropene
Trichloroethene
Vinyl Chloride
Xylenes, Total

Qualifiers:

* - Total 1,2-dichloroethene was not reported by the laboratory; result shown is sum of laboratory-reported concentrations of cis-l/2-dichloroethene and trans-l,2-dichloroethene
J - Estimated value

U - Analyte not detected above the indicated limit

Abbreviation:

ug/L - Micrograms per liter

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-l 2

-------
Table G-l: 2023 Groundwater Quality Data, UniFirst Property

Spring 2023 Groundwater Quality Data

Chemical

1,1,1 -Tri ch [ oroe th an e
1,1,, 2,2 -T e trach [ or oe th an e
1,1,2-Trich t or oe th an e
1,1-Dichioroethane

1.1-Dichioroethene

1.2-Dichloroethane
1,2-Dichloroethene
l/2-Dicbloropropan>
2-Hexanone
4-Methyl-2-pentanoi
Acetone
Benzene
Bromodichlot
Bromoform
Bromom ethane
Carbon Disulfide
Carbon Te trachl orid
Chlorobenzene
Chloroethane
Chloroform
Chlorome thane
cis-l,2-Dichloroethene
cis-l,3-Dichloropropene
Dibromochloromethane
Ethyibenzene
m-&p-Xylenes
1VIethyl Ethyl Keton-
Methylene Chloride
o-Xylene
Styreni

Tetrachloroethene
Toluene
tran s-1,2-Dichl oroeth ene
trans-l^S-Dichloropropene
Trichloroethene
Vinyl Chloride
Xylenes, Total

Sample Location
Field Sample ID'
Sample Date
Unit;
ug/l
Ug/l
ug/l
ug/l

Qualifiers:

*	;hloroethene was not reported by the labor

J	slue

U ¦ Anaiyic not detected above the indicated limit

Abbreviation:

ug/L - Micrograms per liter

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. November 15, 2023.

G-l 3

-------
Table G-l: 2023 Groundwater Quality Data, Uni First Property

Spring 2023 Groundwater Quality Data

Sample Location	LOO	UC33	LC5	UC6	IJC7-2	UC7-3	L1C7-4	UG10	US17

Field Sample ID	UC30A	IJC33A	XUC3A	XU06A	IJC72A	UC73A	UC74A	US10A	US17A

Sample Date 5/25/2023	5/25/2023	5/26/2023	5/25/2023	5/25/2023	5/25/2023	5/25/2023	5/31/2023	5/31/2023

Chemical	Units	Result	Result	Result	Result	Result	Result *	Result	Result	Result

1.1.1-Trichloroethane	ug/l	0.50	U	0.50	4.2	0.50	U	21	IS . 9.3	0.50	IJ	0.50	U
1,1,2,2-Tetrachloroethane	ug/i	0.50	U	0.50	' U	0.50	U	0.50	U	10	U	10	U	5.0	IJ	0.50	U	0.50	U

1.1.2-Trichioroethane	ug/i	0.75	U	0.75	U	0.75	U	0.75	U	15	U	15	IJ	7.5	U	0.75	U	0.75	U

1.1-Dichloroethane	ug/l	0.75	U	0.75	U	0.75	U	0.75	U	15	U	15	IJ	7.5	IJ	0.75	U	0.75	U
¦1,1-Hchloroethene	. ug/l	0.50	IJ	0.50	U	0.50	U	0.50	U	10	U	10	U	5.0	U	0.50	U	0.50	U

1.2-Dichioroethane	ug/l	0.50 . U	0.50	' U	0..50	U	0.50	U	10	II	10	U	5.0	U	0.50	U	0.50	U
1,2-Dichloroethene	ug/l	0.50	U	0.50	U	0,50	U ' 1.8	70	47	17	0.50	U	0.50	U
1,2-Dichioropropane	ug/l	1,3 ' U	1,8	U	l.S	U	l.S	U	35	U	35	U	18	U	l.S	U	l.S	U
¦ 2-Hexanone	' ug/l	5.0	U	5.0	IJ	5.0	U	5.0 ' U	100	LI	100	U	50	L	5.0	LI	5.0	U
4-Methyl-2-pentanone	ug/l	5.0	L	5.0	IJ	5.0	U	5.0	U	100	U	100	U	50	U	5.0	U	5.0	U
Acetone	ug/l	5.0	L	25	5.0	LI	5.0	U ' 100	J	100	Li	50	U	5.0	U	5.0	U
Benzene	ug/l	0.50	L	0.50	U	0.50	U	0,50	U	10	U ' 10	' U	5.0	U	0.50	U	0.50	U
Bromodichioromethane	ug/l	0.50	U	0.50	U	0,50	U	0.50	U	10	U ' 10	U . 5.0	U	0.50	U	0.50	U
Bromoform	ug/l	2.0	IJ	2.0	U	2.0	U	2,0	U	40	' U	40	IJ	20	IJ	2.0	U	2.0	U
Bromomethane	. ug/l	1.0	U	1.0	U	1.0	U	1.0	U	20	U	20	U	10	U	1.0	U	1.0	U
Carbon Disulfide	ug/l	5.0	L)	5.0	U	5.0	U	5.0	U	100	U	100	LI	SO	U	5.0	U	.5.0	U
Carbon Tetrachloride	ug/l	0.50	U	0.50	U	0.50	U	0,50	U	10	' IJ	10	U . 5.0	U	0.50	U . 0.50	L
Chlorobenzene	ug/l	0.50	LI	0,50	U	0,50 ' IJ	0.50	U	10	U	10	U	5,0	U	0.50	U	0.50	LJ
Chloroethane	ug/l	1.0	U	1.0	. U	1.0	U	1.0 ' U	20	' IJ	20	IJ . 10	IJ	1.0	U	1.0	U
Chloroform	' ug/l	0.75	U	0.75	' U . 0.75	U	0.75	U	15	U	15	IJ	7.5	U	0.75	U	0.75	U
Chloromethane	ug/i	2.5	111	2.5	LJ	2.5	Hi	2.5	UJ	50	UJ	50	LI)	25	UJ	2,5	UJ	2.5	UJ
cis-l,2-Dichloroethene	ug/l	0.50	IJ	0,50	U	0.50	U	l.S	70	47	17	0.50	U	0.50	U
cis~l>Dichloropropene	ug/l . 0.50	U	0.50	U * 0,50	U	0.50	U	10	' U " 10	LI	5.0	U	0.50	U	0.50	U
Dibromochloromethane	ug/l	0.50	L	0.50	U	0.50	IJ	0.50	U	10	IJ . 10	U	5.0	U	0.50	IJ	0.50	U
Ethylbenzene	ug/l	0.50	IJ	0,50	U	0,50	U	0.50	U	10	U	10	' U	5.0	U	0.50	U	0.50	Li
m-&p-Xy!enes	ug/l	1.0	U	1.0	U	1.0	U	1.0	U	20	U	20	IJ ' 10	U	1.0	LJ	1.0	U
Methyl Ethyl Ketone	' ug/l	5.0	U	5.0	* U	S.4 ' .1+	5.0	U	100	' U	100	U	50	U	5.0	U ' 5.0	U
Methylene Chloride	ug/l	3.0	U	3.0	U	3.0	IJ	3.0	U	60	U	60	U	30	IJ	3.0	U	3.0	U
o-Xylene	ug/l	1.0 . U ' 1.0	U	1.0	U	1.0	U . 20	U	20	' U	10	U	1.0	U ' 1.0	U
¦Styrene	ug/l	1.0	IJ	1.0	U	1.0	U	1,0	U	20	U	10	U	10	U , 1,0	IJ	1.0	U
Tetrachloroethene	ug/l	1.1 ' 2.7	35	61	2500	1700	1300	2.6	2S
Toluene	ug/i	0,75	U	0.75	U	0.75	U	0.75	U	28	15	IJ	7.5	IJ	0.75	U . 0.75	U
trans-lj2~Dichloroethene	' ug/l	0.75	U	0.75	LI ' 0.75	U	0.75	U	15	U ' 15	U	7.5	U	0.75	U	0.75	U
trans-l,3-Dichloropropene	ug/l	0.50	U	0.50	U	0.50	U	0.50	U	10	U	10	U	5.0	U	0.50	U	0.50	U
Trichloroethene	ug/l	0.50	U	0.50	U	0.50	U	9,8	420	250	93	0.S0	U	0.50	U
Vinyl Chloride	ug/l	1.0	UJ	1.0	UJ	1,0	UJ	1.0	UJ	20	UJ	20	' UJ	10 ' UJ	1.0	UJ	1.0	UJ
.Xylenes, Total	ug/l	1.0	U	1.0	U	1.0	U	1.0	U	20	U	20	LJ	10	LI	1.0	U	1.0	U

Qualifiers:

* - Total 1,2-dichloroethene was not reported by the labor
J - Estimated value

U - Analyte not detected above the indicated limit

Abbreviation:

ug/L - Micrograms per liter

Source: RD/RA Year 31 Annual Report for the Uni First Site. Prepared by Uni First. Corporation. November 15, 2023.

G-14

-------
Table G-3: Mann-Kendall Trend Analysis Results for 2010-2023 PCE Concentration Data, UniFirst
Property

TABLE J-l
Mann-Kendall Trend Analysis Results
2010-2023 PCE Concentration Data
UniFirst. Property
Woburn, Massachusetts

Well ID

Time Span of Trend
Analysis133

Constituent

Mann~Kent!all Analysis

CV Stability Test4

Trend at 90% C.L,

Trend at 95% C.L.

S71S

7/2010 - 5 2023

PCE

No Trend

No Trend



S71D

7/2010- < 2023

PCE

No Trend

No Trend

Stable

SS1M

7/2010 - 5 2023

PCE

Increasing

Increasing

—

S81D

7/2010- 5 2023

PCE

Decreasing

Decreasing



UC5

7/2010- S 2023

PCE

No Trend

No Trend

Unstable

UC6

7/2010 - 5 2023

PCE

No Trend

No Trend

Stable

UC7-1

7/2010 - 5/2017

PCE

No Trend

No Trend

Stable

UC-2

~ 2010 - 5 2023

PCE

Increasing

No Trend



UC7-3

- 2010 - 5 2023

PCE

No Trend

No Trend

Stable

UC7-4

7/2010 - 5 2023

PCE

No Trend

No Trend

Stable

UC7-56

7/201(i - 5 2021

PCE

No Trend

No Trend

Stable

UC10-1

7/2010 - 5/2023

PCE

No Trend

No Trend

__

UC10-2

7/2010 - 5/2023

PCE

No Trend

No Trend

Stable

UC10-3

7/2010 - 5/2023

PCE

Increasing

Increasing

—

UC10-4

7/2010 - 5 2023

PCE

No Trend

No Trend

Stable

UC10-5

7/2010 - 5 2023

PCE

Decreasing

No Trend

—

UC10-6

7/2010- 5,2023

PCE

No Trend

No Trend

__

UC25

7/20l0 - 5 2023

PCE

No Trend

No Trend



UC29D

7/2010 - 5'2023

PCE

No Trent

No Treni



UC29S

7/2010 - 5'2023

PCE

Decreasing

Decreasing



UG17

7/2010 - 5'2023

PCE

No Trend

No Trend

Stable

Abbreviations:

C.L. ¦= Confidence Level	PCE = Tetrachloroethene

CY = Coefficient of Variation	-- = not applicable

Notes:

1	The M asm-Kendall test requires a minimum of four consecutive lesults to establish statistical significance of a ti end

2	Where non-detect results were included in a trend anahsis, half of the reporting limit was used as the constituent concentration,

3	Wheie duplicate sampksweic collected and analyzed, the higher \alue of the duplicates was used as the constituent concentration.

4	Hie CY Stability Test indicates stability of the results around the mean and is applied if no ti end is identified at the 8<<°o confidence level. If
the coefficient of \ at mtion is gi eatei than one, the lesnlts are considered unstable.

5	UC-1 had insufficient water for sampling m the 201S through 2023 sampling events.

6	UC-5 had insufficient water for sampling m the 2012 through 2014, 2016, and 2022 through 2023 sampling events.

Source: RD/'RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

G-15

-------
Table G-4: Indoor and Ambient Air Sampling Results - Commercial Property 260206

Table B1

Indoor and Ambient Air Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, Massachusetts

-------
Table B1

Indoor and Ambient Air Sampling Results • Commercial Property 260206
UniFirst Corporation
Woburn, Massachusetts

ftARCADIS

Sample Location:

Units

USEPA Residential

Endpoint

AA-1

AA-1

AA-1

AA-2

AA-2

OA-2

IA-1

IA-1

IA-1

IA-1

Date Collected:

Air RSL (1)

(2)

2/20/2021

2/19/2022

2/18/2023

03/12/11

6/18/2011

3/2/2013

03/12/11

6/18/2011

3/2/2013

2/9/2014

1,1,1-Trichloroethane

|jg/m3

5200

n

0.109 U

0.109 U

0.109 U

0.109 U

0.109 U

<0.109

0.109 U [0.109 U]

0.109

<0.109 [<0.109]

<0.109 [<0.109]

1,1,2-Trichloroethane

Hg/m3

0.18

c**

0.109 U

0.109 U

0.109 U

0.109 U

0.109 U

<0.109

0.109 U [0.109 U]

0.109 U

<0.109 [<0.109]

<0.109 [<0.109]

1,1-Dichloroethane

Hg/m3

1.8

c

0.081 U

0.081 U

0.081 U

0.0810 U

0.081 U

<0.0809

0.0810 U [0.0810 U]

0.081 U

<0.0809 [<0.0809]

<0.081 [<0.081]

1,1-Dichloroethene

Hg/m3

210

n

0.079 U

0.079 U

0.079 U

0.0790 U

0.079 U

<0.0793

0.0790 U [0.0790 U]

0.079 U

<0.0793 [<0.0793]

<0.079 [<0.079]

1,2,4-Trimethylbenzene

Hg/m3

63

n

0.098 U

0.098 U

0.098 U

0.0980 U

0.142

<0.0983

0.339 [0.295]

2.13

0.841 [0.821]

0.329 [0.349]

1,2-Dibromoethane

Hg/m3

0.0047

<

0.154 U

0.154 U

0.154 U

0.154 U

0.154 U

<0.154

0.154 U [0.154 U]

0.154 U

<0.154 [<0.154]

<0.154 [<0.154]

1.2-Dichloroethane

Hg/m3

0.11

c*

0.243 JN

0.219

0.081 U

0.0810 U

0.081 U

<0.0809

0.125 [0.125]

0.308

0.134 [0.138]

0.081 [<0.081]

1,2-Dichloropropane

Hg/m3

0.76

c**

0.092 U

0.092 U

0.092 U

0.0920 U

0.092 U

<0.0924

0.0920 U [0.0920 U]

0.092 U

<0.0924 [<0.0924]

<0.092 [<0.092]

1,3-Butadiene

Hg/m3

0.094

c*

0.049 JN

0.044 U

0.044 U

0.0440 U

0.044 UJ

<0.0442

0.0580 [0.0600]

0.077 J

<0.0442 [<0.0442]

0.060 [0.064]

1,3-Dichlorobenzene

Hg/m3

NA

NA

0.12 U

0.120 U

0.120 U

0.120 U

0.12 U

<0.12

0.120 U [0.120 U]

0.12 U

<0.12 [<0.12]

<0.120 [<0.120]

1,4-Dichlorobenzene

Hg/m3

0.26

c

0.12 U

0.120 U

0.120 U

0.120 U

0.12 U

<0.12

0.120 U [0.120 U]

0.18

<0.12 [<0.12]

<0.120 [<0.120]

Benzene

Hg/m3

0.36

c*

0.54

0.390

0.319

0.373

0.224 U

0.45

0.721 [0.661]

3.18

0.534 [0.53]

0.716 [0.709]

Bromodichloromethane

Hg/m3

0.076

c

0.134 U

0.134 U

0.134 U

0.134 U

0.134 U

<0.134

0.134 U [0.134 U]

0.315

<0.134 [<0.134]

<0.134 [<0.134]

Bromoform

Hg/m3

2.6

c

0.207 U

0.207 U

0.207 U

0.206 U

0.207 U

<0.207

0.206 U [0.206 U]

0.207 U

<0.207 [<0.207]

<0.207 [<0.207]

Carbon Tetrachloride

Hg/m3

0.47

c

0.434

0.478

0.440

0.553

0.459

0.39

1.36 [1.29]

0.704

0.403 [0.39]

0.434 [0.434]

Chlorobenzene

Hg/m3

52

n

0.461 U

0.461 U

0.461 U

0.0920 U

0.092 U

<0.0921

0.0920 U [0.0920 U]

0.092 U

<0.0921 [<0.0921]

<0.092 [<0.092]

Chloroform

Hg/m3

0.12

c

0.103

0.103

0.098

0.0980 U

0.098 U

<0.0977

3.22 [3.20]

5.27

0.474 [0.459]

0.288 [0.288]

cis-1,2-Dichloroethene

Hg/m3

NA

NA

0.079 U

0.079 U

0.079 U

0.0790 U

0.079 U

<0.0793

0.0790 U [0.0790 U]

0.079 U

<0.0793 [<0.0793]

<0.079 [<0.079]

Ethylbenzene

Hg/m3

1.1

c

0.096

0.087 U

0.087 U

0.0870 U

0.087 UJ

<0.0869

0.521 [0.464]

3.47 J

0.934 [0.895]

0.365 [0.365]

Isopropylbenzene

Hg/m3

420

n

2.46 U

2.46 U

2.46 U

2.46 U

2.46 U

<2.46

2.46 U [2.46 U]

2.46 U

<2.46 [<2.46]

<2.46 [<2.46]

Methyl tert butyl ether	

Hg/m3

11

c

0.072 U

0.072 U

0.072 U

0.0720 U

0.072 UJ

<0.0721

0.0720 U [0.0720 U]

0.072 UJ

<0.0721 [<0.0721]

<0.072 [<0.072]

Methylene Chloride

Hg/m3

100

c**

1.74 U

1.74 U

1.74 U

1.99

3.96

<1.74

1.74 U [1.74 U]

6.81

<1.74 [<1.74]

<1.74 [<1.74]

Naphthalene 	i

Hg/m3

0.083

c*

0.262 U

0.262 UJ

0.262 U

0.262 UJ

g.i57J

<0.262

0.262 UJ [0.262 UJ]

0.603 J

<0.262 [0.262]

<0.262 [<0.262]

Tetrachloroethene

Hg/m3

11

c**

0.136 U

0.136 U

0.136 U

0.136 U

0.136 U

<0.136

1.02 [0.942]

1.09

0.719 [0.705]

1.38 [1.36]

Toluene

Hg/m3

5200

n

0.659

0.479

0.377 U

0.339 U

0.724 J

0.558

3.82 [3.43]

27.9 J

4.45 [4.11]

2.46 [2.52]

trans-1,2-Dichloroethene

Hg/m3

42

n

0.079 U

0.079 U

0.079 U

0.0790 U

0.079 U

<0.0793

0.0790 U [0.0790 U]

0.079 U

<0.0793 [<0.0793]

<0.079 [<0.079]

trans-1,3-Dichloropropene

Hg/m3

0.7

c*

0.091 U

0.091 U

0.091 U

0.0910 U

0.091 U

<0.0908

0.0910 U [0.0910 U]

0.091 U

<0.0908 [<0.0908]

<0.091 [<0.091]

Trichloroethene

Hg/m3

0.48

c**

0.107 U

0.107 U

0.107U

0.107 U

0.107 U

<0.107

0.107 U [0.107 U]

0.107 U

<0.107 [<0.107]

<0.107 [<0.107]

Vinyl Chloride

Hg/m3

0.17

c

0.051 U

0.051 U

0.051JJ	

0.0510 U

0.051 U

<0.0511

0.0510 U [0.0510 U]

0.051 U

<0.0511 [<0.0511]

<0.051 [<0.051]

Xylenes, Total

Hg/m3

100

n

0.356

0.261 U

0.261 U

0.260 U

0.304

<0.261

2.68 [2.37]

18.8

3.69 [3.54]

1.50 [1.54]

Notes:

U or < = Constituent not detected
J = Indicates an estimated value
NA = not available
N = presumptively present
Hg/m3 = micrograms per cubic meter
[0.109 U] = duplicates results

Screening value for 1,3-dichloropropene was used as a
surrogate for trans-1,3-dichloropropene.

(1)	USEPA Regional Screening Levels (May 2023)

(2)	basis for screening level: n = noncancer; c = cancer

c* = the noncancer SL is less than 100 times the cancer SL
c** = the noncancer SL is less than 10 times the cancer SL
Bold = exceedance of residential screening level

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. Feb man 15, 2023.

G-17

-------
Table B1

Indoor and Ambient Air Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, Massachusetts

ftARCADIS

Sample Location:
Date Collected:

Units

USEPA Residential
Air RSL (1)

Endpoint
(2)

IA-1

3/15/2015

IA-1

2/27/2016

IA-1

3/11/2017

IA-1

02/18/18

IA-1

03/02/19

IA-1

02/22/20

IA-1

2/20/2021

IA-1

2/19/2022

IA-1

2/18/2023

1,1,1-Trichloroethane

pg/m3

5200

n

0.109 U

0.109 U

0.109 U

0.109 U [0.109 U]

0.109 U

0.109 U

0.109 U

0.109 U

0.109 U

1,1,2-Trichloroethane

pg/m3

0.18

c**

0.109 U

0.109 U

0.109 U

0.109 U [0.109 U]

0.109 U

0.109 U

0.109 U

0.109 U

0.109 U

1,1-Dichloroethane

pg/m3

1.8

c

0.081 U

0.081 U

0.081 U

0.081 U [0.081 U]

0.081 U

0.081 U

0.081 U

0.081 U

0.081 U

1.1-Dichloroethene

pg/m3

210

n

0.079 U

0.079 U

0.079 U

0.079 U [0.079 U]

0.079 U

0.079 U

0.079 U

0.079 U

0.079 U

1,2,4-Trimethylbenzene

pg/m3

63

n

0.354

0.905

0.477

0.501 [0.752]

0.27

0.516

0.221

0.408

1.02

1,2-Dibromoethane

pg/m3

0.0047

c

0.154 U

0.154 U

0.154 U

0.154 U [0.154 U]

0.154 U

0.154 U

0.154 U

0.154 U

0.154 U

1,2-Dichloroethane

pg/m3

0.11

c*

0.15

0.109

0.13

0.134 J [0.097 J]

0.101 J,N

0.125

0.219 JN

0.340

0.081 U

1,2-Dichloropropane

pg/m3

0.76

C»*

0.092 U

0.092 U

0.092 U

0.092 UJ [0.092 U]

0.092 U

0.092 U

0.092 U

0.092 U

0.143 U

1,3-Butadiene

pg/m3

0.094

c*

0.055

0.049

0.077

0.173 [0.195]

0.044 U

0.044 U

0.073

0.044 U

0.049

1,3-Dichlorobenzene

pg/m3

NA

NA

0.12 U

0.12 U

0.12 U

0.12 U [0.12 U]

0.12 U

0.12 U

0.12 U

0.120 U

0.120 U

1,4-Dichlorobenzene

pg/m3

0.26

c

0.12 U

0.12 U

0.12 U

0.12 U [0.12 U]

0.12 U

0.18

0.12 U

0.120 U

0.120 U

Benzene

pg/m3

0.36

c*

0.68

0.431

0.537

0.732 [0.933]

0.76

0.511

0.652

0.367

0.553

Bromodichloromethane

pg/m3

0.076

c

0.134 U

0.134 U

0.134 U

0.134 U [0.134 U]

0.134 U

0.134 U

0.134 U

0.134 U

0.134 U

Bromoform

pg/m3

2.6

c

0.207 U

0.207 U

0.207 U

0.207 U [0.207 U]

0.207 U

0.207 U

0.207 U

0.207 U

0.207 U

Carbon Tetrachloride

pg/m3

0.47

c

0.472

0.409

0.478

0.528 [0.434]

0.126 U

0.289

0.44

0.447

0.579

Chlorobenzene

pg/m3

52

n

0.092 U

0.092 U

0.461 U

0.461 U [0.461 U]

0.461 U

0.461 U

0.461 U

0.461 U

0.461 U

Chloroform

pg/m3

0.12

c

0.493

0.479

0.713

0.435 [0.327]

0.693

0.44

0.889

0.244

0.396

cis-1,2-Dichloroethene

pg/m3

NA

NA

0.079 U

0.079 U

0.079 U

0.079 U [0.079 U]

0.079 U

0.079 U

0.079 U

0.079 U

0.079 U

Ethylbenzene

pg/m3

1.1

c

0.261

0.478

0.265

0.582 [0.847]

0.278

2.95

0.387

0.200

1.65

Isopropylbenzene

pg/m3

420

n

2.46 U

2.46 U

2.46 U

2.46 U [2.46 U]

2.46 U

2.46 U

2.46 U

2.46 U

2.46 U

Methyl tert butyl ether	

pg/m3

I 11 |

c

0.072 U

0.072 U

0.072 U

0.072 U [0.072 U]

0.364

0.072 U

0.072 U

1.18

0.072 U

Methylene Chloride

pg/m3

100

c**

2

1.74 U

1.74 U

1.74 U [1.74 U]

1.74 U

1.74 U

1.74 U

1.74 U

1.74 U

Naphthalene

pg/m3

0.083

c*

0.262 U

0.199J

0.262 U

0.189 J [0.262 U]

0.262 U

0.262 U

0.262 U

0.262 UJ

0.262 U

Tetrachloroethene

pg/m3

11

c**

0.692

0.692

0.665

0.542 [0.515]

0.4

0.258

0.258

0.163

0.136 U

Toluene

pg/m3

5200

n

3.12

3.03

2.25

5.77 [7.24]

3.46

1.56

2.05

1.55

2.74

trans-1,2-Dichloroethene

pg/m3

42

n

0.079 U

0.079 U

0.079 U

0.079 U [0.079 U]

0.079 U

0.079 U

0.079 U

0.079 U

0.079 U

trans-1,3-Dichloropropene

pg/m3

0.7

c*

0.091 U

0.091 U

0.091 U

0.091 UJ [0.091 U]

0.091 U

0.091 U

0.091 U

0.091 U

0.091 U

Trichloroethene

pg/m3

0.48

c**

0.107 U

0.107 U

2.59

0.107 U [0.107 U]

0.107 U

0.107 U

0.215 0.107 U

0.107 U

Vinyl Chloride

pg/m3

0.17

c

0.051 U

0.051 U

0.051 U

0.051 U [0.051 U]

0.051 U

0.051 U

0.051 U

0.051 U

0.051 U

Xylenes, Total

pg/m3

100

n

0.99

2.18

1.08

2.59 J [3.74 J]

1.09

15.4

1.42

0.843

9.95

Notes:

U or < = Constituent not detected
J = Indicates an estimated value
NA = not available
N = presumptively present
pg/m3 = micrograms per cubic meter
[0.109 U] = duplicates results

Screening value for 1,3-dichloropropene was used as a
surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

(1)	USEPA Regional Screening Levels (May 2023)

(2)	basis for screening level: n = noncancer; c = cancer

c* = the noncancer SL is less than 100 times the cancer SL
c** = the noncancer SL is less than 10 times the cancer SL
Bold = exceedance of residential screening level

G-18

-------
Table B1

Indoor and Ambient Air Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, Massachusetts

P»ARCADIS

Ot »Kflt & l L'.rUlijfl':-/

for nature) and
built aswls

Sample Location:

Units

USEPA Residential

Endpoint

IA-2

IA-2

IA-2

IA-2

IA-2

IA-2

IA-2

IA-2

IA-2

Date Collected:

AirRSL (1)

(2)

03/12/11

6/18/2011

3/2/2013

2/9/2014

3/15/2015

2/27/2016

3/11/2017

02/18/18

03/02/19

1,1,1-Trichloroethane

pg/m3

5200

n

0.109 U

0.109 [0.109 U]

<0.109

<0.109

0.109 U

0.109 U [0.109 U]

0.109 U [0.109 U]

0.109 U

0.109 U [0.109 U]

1,1,2-Trichloroethane

pg/m3

0.18

c**

0.109 U

0.109 U [0.109 U]

<0.109

<0.109

0.109 U

0.109 U [0.109 U]

0.109 U [0.109 U]

0.109 U

0.109 U [0.109 U]

1,1-Dichloroethane

pg/m3

1.8

c

0.0810 U

0.081 U [0.081 U]

<0.0809

<0.081

0.081 U

0.081 U [0.081 U]

0.081 U [0.081 U]

0.081 U

0.081 U [0.081 U]

1.1-Dichloroethene

pg/m3

210

n

0.0790 U

0.079 U [0.079 U]

<0.0793

<0.079

0.079 U

0.079 U [0.079 U]

0.079 U [0.079 U]

0.079 U

0.079 U [0.079 U]

1,2,4-Trimethylbenzene

pg/m3

63

n

0.314

2.3 [2.67]

0.895

0.354

0.447

0.85 [0.934]

0.315 [0.27]

0.634

0.315 [0.27]

1.2-Dibromoethane

pg/m3

0.0047

c

0.154 U

0.154 U [0.154 U]

<0.154

<0.154

0.154 U

0.154 U [0.154 U]

0.154 U [0.154 U]

0.154 U

0.154 U [0.154 U]

1,2-Dichloroethane

pg/m3

0.11

c*

0.125

0.081 U [0.081 U]

0.134

<0.081

0.146

0.113 [0.117]

0.105 J,N [0.105 J,N]

0.130 J

0.105 J,N [0.105 J,N]

1,2-Dichloropropane

pg/m3

0.76

c**

0.0920 U

0.092 U [0.092 U]

<0.0924

<0.092

0.092 U

0.092 U [0.092 U]

0.092 U [0.092 U]

0.092 UJ

0.092 U [0.092 U]

1,3-Butadiene

pg/m3

0.094

c*

0.0580

0.1 J [0.1 J]

<0.0442

0.062

0.062

0.044 [0.047]

0.044 U [0.044 U]

0.181

0.044 U [0.044 U]

1,3-Dichlorobenzene

pg/m3

NA

NA

0.120 U

0.12 U [0.12 U]

<0.12

<0.120

0.12 U

0.12 U [0.12 U]

0.12 U [0.12 U]

0.12 U

0.12 U [0.12 U]

1,4-Dichlorobenzene

pg/m3

0.26

c

0.120 U

0.168 [0.186]

<0.12

<0.120

0.12 U

0.12 U [0.12 U]

0.12 U [0.12 U]

0.12 U

0.12 U [0.12 U]

Benzene

pg/m3

0.36

c*

0.753

3.19 [3.14]

0.527

0.719

0.668

0.428 [0.441]

0.748 [0.757]

0.719

0.748 [0.757]

Bromodichloromethane

pg/m3

0.076

C

0.134 U

0.328 [0.315]

<0.134

<0.134

0.134 U

0.134 U [0.134 U]

0.134 U [0.134 U]

0.134 U

0.134 U [0.134 U]

Bromoform

pg/m3

2.6

c

0.206 U

0.207 U [0.207 U]

<0.207

<0.207

0.207 U

0.207 U [0.207 U]

0.207 U [0.207 U]

0.207 U

0.207 U [0.207 U]

Carbon Tetrachloride

pg/m3

0.47

c

1.22

0.679 [0.66]

0.409

0.44

0.459

0.409 [0.428]

0.126 U [0.126 U]

0.541

0.126 U [0.126 U]

Chlorobenzene

pg/m3

52

n

0.0920 U

0.092 U [0.092 U]

<0.0921

<0.092

0.092 U

0.092 U [0.092 U]

0.461 U [0.461 U]

0.461 U

0.461 U [0.461 U]

Chloroform

pg/m3

0.12

c

3.36

5.13 [4.79]

0.513

0.288

0.586

0.508 [0.527]

0.698 [0.693]

0.425

0.698 [0.693]

cis-1,2-Dichloroethene

pg/m3

NA

NA

0.0790 U

0.079 U [0.079 U]

<0.0793

<0.079

0.079 U

0.079 U [0.079 U]

0.079 U [0.079 U]

0.079 U

0.079 U [0.079 U]

Ethyl benzene 	

pg/m3

1.1

c

0.538

3.56 J [3.68 J]

1.01

0.517

0.265

0.473 [0.513]

0.295 [0.269]

0.647

0.295 [0.269]

Isopropylbenzene

pg/m3

420

n

2.46 U

2.46 U [2.46 U]

<2.46

<2.46

2.46 U

2.46 U [2.46 U]

2.46 U [2.46 U]

2.46 U

2.46 U [2.46 U]

Methyl tert butyl ether

pg/m3

11

c

0.0720 U

0.072 UJ [0.072 UJ]

<0.0721

<0.072

0.072 U

0.072 U [0.072 U]

0.368 [0.407]

0.072 U

0.368 [0.407]

Methylene Chloride

pg/m3

100

c**

1.74 U

3.26 [3]

<1.74

<1.74

1.74 U

1.74 U [1.74 U]

1.74 U [1.74 U]

1.74 U

1.74 U [1.74 U]

Naphthalene

pg/m3

0.083

c*

0.262 UJ

0.587 J [0.514 J]

<0.262

<0.262

0.173J

0.215J [0.257J]

0.262 U [0.262 U]

0.262 U

0.262 U [0.262 U]

Tetrachloroethene

pg/m3

11

c**

1.19

1.13 [1.23]

1.02

1.57

0.841

0.875 [0.888]

0.617 J [0.441 J]

0.665

0.617 J [0.441 J]

Toluene

pg/m3

5200

n

5.64

29 J [27.2 J\

4.82

2.58

3.25

2.74 [2.98]

3.81 [3.58]

6.07

3.81 [3.58]

trans-1,2-Dichloroethene

pg/m3

42

n

0.0790 U

0.079 U [0.079 U]

<0.0793

<0.079

0.079 U

0.079 U [0.079 U]

0.079 U [0.079 U]

0.079 U

0.079 U [0.079 U]

trans-1,3-Dichloropropene

pg/m3

0.7

c*

0.0910 U

0.091 U [0.091 U]

<0.0908

<0.091

0.091 U

0.091 U [0.091 U]

0.091 U [0.091 U]

0.091 UJ

0.091 U [0.091 U]

Trichloroethene

pg/m3

0.48

c**

0.107 U

0.107 U [0.107 U]

<0.107

<0.107

0.107 U

0.107 U [0.107 U]

0.107 U [0.107 U]

0.107 U

0.107 U [0.107 U]

Vinyl Chloride

pg/m3

0.17

c

0.0510 U

0.051 U [0.051 U]

<0.0511

<0.051

0.051 U

0.051 U [0.051 U]

0.051 U [0.051 U]

0.051 U

0.051 U [0.051 U]

Xylenes, Total

pg/m3

100

n

2.67

19 [19.9]

3.89

2.09

1.02

2.18 [2.31]

1.21 [1.07]

2.9

1.21 [1.07]

Notes:

U or < = Constituent not detected
J = Indicates an estimated value
NA = not available
N = presumptively present
pg/m3 = micrograms per cubic meter
[0.109 U] = duplicates results
Screening value for 1,3-dichloropropene was used as a
surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. Feb man 15, 2023.

(1)	USEPA Regional Screening Levels (May 2023)

(2)	basis for screening level: n = noncancer; c = cancer

c* = the noncancer SL is less than 100 times the cancer SL
c** = the noncancer SL is less than 10 times the cancer SL
Bold = exceedance of residential screening level

G-19

-------
Table B1

Indoor and Ambient Air Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, Massachusetts

^ARCADIS

Desiyn ft Consultancy
for natural and
built assets

Sample Location:
Date Collected:

Units

USEPA Residential
Air RSL (1)

Endpoint
(2)

IA-2
02/22/20

IA-2

2/20/2021

IA-2

2/19/2022

IA-2

2/18/2023

IA-3

03/12/11

IA-3
6/18/2011

IA-3

3/2/2013

IA-3
2/9/2014

IA-3

3/15/2015

1,1,1-Trichloroethane

pg/m3

5200

n

0.109 U

0.109 U [0.109 U]

0.109 U

0.109 U [0.109 U]

0.109 U

0.109 U

<0.109

<0.109

0.109 U

1.1,2-Trichloroethane

pg/m3

0.18

c**

0.109 U

0.109 U [0.109 U]

0.109 U

0.109 U [0.109 U]

0.109 U

0.109 U

<0.109

<0.109

0.109 U

1,1-Dichloroethane

pg/m3

1.8

c

0.081 U

0.081 U [0.081 U]

0.081 U

0.081 U [0.081 U]

0.0810 U

0.081 U <0.0809

<0.081

0.081 U

1,1-Dichloroethene

pg/m3

210

n

0.079 U

0.079 U [0.079 U]

0.079 U

0.079 U [0.079 U]

0.0790 U

0.079 U <0.0793

<0.079

0.079 U

1,2,4-Trimethylbenzene

pg/m3

63

n

0.526

0.202 [0.226]

0.423

0.954 [0.954]

0.236

2.69 0.973

0.388

0.516

1,2-Dibromoethane

pg/m3

0.0047

c

0.154 U

0.154 U [0.154 U]

0.154 U

0.154 U [0.154 U]

0.154 U

0.154 U <0.154

<0.154

0.154 U

1,2-Dichloroethane

pg/m3

0.11

c*

0.081

0.206 JN [0.247 ]

0.344

0.109 U [0.113 U]

0.162

0.368 0.146

0.085

0.146

1.2-Dichloropropane

pg/m3

0.76

c**

0.092 U

0.092 U [0.092 U]

0.092 U

0.139 U [0.120 U]

0.0920 U

0.092 U <0.0924

<0.092

0.092 U

1,3-Butadiene

pg/m3

0.094

c*

0.044

0.069 [0.082]

0.044 U

0.053 [0.060]

0.0730

0.077 J <0.0442

0.066

0.06

1,3-Dichlorobenzene

pg/m3

NA

NA

0.12 U

0.12 U [0.12 U]

0.120 U

0.120 U [0.120 U]

0.120 U

0.12 U <0.12

<0.120

0.12 U

1.4-Dichlorobenzene

pg/m3

0.26

c

0.12 U

0.12 U [0.12 U]

0.120 U

0.120 U [0.120 U]

0.120 U

0.168 <0.12

<0.120

0.12 U

Benzene

pg/m3

0.36

c*

0.527

0.604 [0.645]

0.380

0.543 [0.540]

0.747

3.07

0.54

0.728

0.76

Bromodichloromethane

pg/m3

0.076

c

0.134 U

0.074 J [0.087 JN]

0.134 U

0.134 U [0.134 U]

0.0740 J

0.315

<0.134

<0.134

0.134 U

Bromoform

pg/m3

2.6

c

0.207 U

0.207 U [0.207 U]

0.207 U

0.207 U [0.207 U]

0.206 U

0.207 U

<0.207

<0.207

0.207 U

Carbon Tetrachloride

pg/m3

0.47

c

0.327

0.447 [0.415]

0.484

0.554 [0.428]

1.54

0.679

0.415

0.447

0.503

Chlorobenzene

pg/m3

52

n

0.461 U

0.461 U [0.461 U]

0.461 U

0.461 U [0.461 U]

0.0920 U

0.092 U

<0.0921

<0.092

0.092 U

Chloroform

pg/m3

0.12

c

0.41

0.742 [0.874]

0.254

0.356 [0.356]

4.07

5.57

0.542

0.322

0.537

cis-1,2-Dichloroethene

pg/m3

NA

NA

0.079 U

0.079 U [0.079 U]

0.079 U

0.079 U [0.079 U]

0.0790 U

0.079 U

<0.0793

<0.079

0.079 U

Ethylbenzene

pg/m3

1.1

c

2.99

0.326 [0.374]

0.213

1.56 [1.52]

0.486

3.57 J

1.08

0.413

0.287

Isopropylbenzene

pg/m3

420

n

2.46 U

2.46 U [2.46 U]

2.46 U

2.46 U [2.46 U]

2.46 U

2.46 U

<2.46

<2.46

2.46 U

Methyl tert butyl ether

pg/m3

11

c

0.072 U

0.072 U [0.072 U]

1.19

0.072 U [0.072 U]

0.0720 U

0.072 UJ <0.0721

<0.072

0.072 U

Methylene Chloride

pg/m3

100

c**

1.74 U

3.38 [1.74U]

1.74 U

1.74 U [1.74 U]

2.01

2.89

<1.74

<1.74

1.74 U

Naphthalene

pg/m3

0.083

c*

0.262 U

0.262 U [0.262 U]

0.262 UJ

0.262 U [0.262 U]

0.262 UJ

0.603 J

0.357

<0.262

0.173J

Tetrachloroethene

pg/m3

11

c**

0.393

0.285 [0.359]

0.217

0.163 [0.156]

1.17

1.19 0.759

1.51

0.746

Toluene

pg/m3

5200

n

1.65

2.1 [2.06]

1.63

2.62 [2.54]

4.03

27 J 4.71

2.59

3.34

trans-1,2-Dichloroethene

pg/m3

42

n

0.079 U

0.079 U [0.079 U]

0.079 U

0.079 U [0.079 U]

0.0790 U

0.079 U <0.0793

<0.079

0.079 U

trans-1,3-Dichloropropene

pg/m3

0.7

c*

0.091 U

0.091 U [0.091 U]

0.091 U

0.091 U [0.091 U]

0.0910 U

0.091 U <0.0908

<0.091

0.091 U

Trichloroethene

pg/m3

0.48

c**

0 .107 U

0.156 [0.188]

0.107 U

0.107 U [0.107 U]

0.107 U

0.107 U 1 <0.107

<0.107

0.107 U

Vinyl Chloride

pg/m3

0.17

c

0.051 U

0.051 U [0.051 U]

0.051JJ	

0.051 U [0.051 U]

0.0510 U

0.051 U <0.0511

<0.051

0.051JJ	

Xylenes, Total

pg/m3

100

n

15.7

1.24 [1.43]

0.912

9.73 [9.51 ]

2.46

19.3 4.24 1.72

1.13

Notes:

U or < = Constituent not detected
J = Indicates an estimated value
NA = not available
N = presumptively present
pg/m3 = micrograms per cubic meter
[0.109 U] = duplicates results

Screening value for 1,3-dichloropropene was used as a
surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

(1)	USEPA Regional Screening Levels (May 2023)

(2)	basis for screening level: n = noncancer; c = cancer

c* = the noncancer SL is less than 100 times the cancer SL
c** = the noncancer SL is less than 10 times the cancer SL
Bold = exceedance of residential screening level

G-20

-------
Table B1

Indoor and Ambient Air Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, Massachusetts

-------
Table G-5: Sub-Slab Vapor Sampling Results - Commercial Property 260206

Table B2

Sub-slab Soil Vapor Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, MA

<3»ARCADIS

Design & Consultancy
for natural and
built assets

Sample Location:
Date Collected:

Units

USEPA
Residential Sub-
slab RSL (11

Endpoint (2)

SS-1

03/12/11

SS-1
6/18/2011

SS-1

3/2/2013

SS-1

2/9/2014

SS-1

3/15/2015

SS-1

2/27/2016

SS-1
3/11/2017

1,1,1-Trichloroethane

Mg/m3

52000

n

10.8 [10.5]

8.4 [7.69]

4.67 [4.47]

2.48 [2.36]

3.6 [3.46]

3.24

3.39

1,1,2-Trichloroethane

Mg/m3

1.8

c**

0.109 U [0.109 U]

0.218 U [0.6 U]

<0.364 [<0.364]

<0.218 [<0.218]

0.273 U [0.273 U]

0.364 U

0.273U	

1,1-Dichloroethane

Mg/m3

18

c

0.497 [0.481]

0.518 [0.445 U]

0.324 [0.337]

0.178 [0.162]

0.263 [0.253]

0.27 U

0.202 U

1,1-Dichloroethene

pg/m3

2100

n

0.0790 U [0.0790 U]

0.158 U [0.436 U]

<0.264 [<0.264]

<0.159 [<0.159]

0.198 U [0.198 U]

0.264 U

0.198 U

1,2,4-Trimethylbenzene

fjg/m3

630

n

0.0980 U [0.0980 U]

0.197 U [0.624]

0.393 [0.328]

0.256 [0.501]

0.246 U [0.246 U]

0.328 U

0.246 U

1,2-Dibromoethane

Mg/m3

0.047

c

0.154 U [0.154 U]

0.307 U [0.845 U]

<0.513 [<0.513]

<0.307 [<0.307]

0.384 U [0.384 U]

0.513 U

0.384 U

1,2-Dichloroethane

Mg/m3

1.1

c*

0.0810 U [0.0810 U]

0.162 U [0.445 U]

<0.27 [<0.27]

<0.162 [<0.162]

0.202 U [0.202 U]

0.27 U

0.202 U

1,2-Dichloropropane

Mg/m3

7.6

c**

0.0920 U [0.0920 U]

0.185 U [0.508 U]

<0.308 [<0.308]

<0.185 [<0.185]

0.231 U [0.231 U]

0.308 U

0.231 U

1,3-Butadiene

Mg/m3

0.94

c*

0.0440 U [0.0440 U]

0.089 UJ [0.243 UJ]

<0.148 [<0.148]

<0.089 [<0.089]

0.111 U [0.111 U]

0.148 U

0.111 U

1,3-Dichlorobenzene

(jg/m3

NA

NA

0.120 U [0.120 U]

0.24 U [0.661 U]

<0.401 [<0.401]

<0.240 [<0.240]

0.301 U [0.301 U]

0.401 U

0.301 U

1,4-Dichlorobenzene

Hg/m3

2.6

c

0.120 U [0.120 U]

0.24 U [0.661 U]

<0.401 [<0.401]

<0.240 [<0.240]

0.301 U [0.301 U]

0.401 U

0.301 U

Benzene

ng/m3

3.6

c*

0.223 U [0.223 U]

0.447 U [1.23 U]

<0.744 [<0.744]

<0.447 [0.447]

0.559 U [0.559 U]

0.744 U

0.559 U

Bromodichloromethane

Mg/m3

0.76

c

3.61 [3.46]

2.57 [2.32]

1.05 [1.03]

0.482 [0.469]

0.569 [0.502]

0.380 J

0.268 J

Bromoform

|jg/m3

26

c

0.206 U [0.206 U]

0.414 U [1.14 U]

<0.69 [<0.69]

<0.414 [<0.414]

0.517 U [0.517 U]

0.69 U

0.517 U

Carbon Tetrachloride

Mg/m3

4.7

c

0.126 U [0.126 U]

0.252 U [0.692 U]

<0.42 [<0.42]

<0.252 [<0.252]

0.315 U [0.315 U]

0.42 U

0.315 U

Chlorobenzene

Mg/m3

520

n

0.0920 U [0.0920 U]

0.184 U [0.506 U]

1.99 [1.6]

<0.184 [<0.184]

0.23 U [0.23 U]

0.691

1.48

Chloroform

Mg/m3

1.2

c

57.9 [55.3]

58.6 [58.6]

28.9 [28]

13.2 [12.4]

16.9 [16.1]

16.6

10.7

cis-1,2-Dichloroethene

Mg/m3

NA

NA

0.242 [0.258]

0.285 [0.436 U]

<0.264 [<0.264]

<0.159 [<0.159]

0.198 U [0.198 U]

0.264 U

0.198 U

Ethylbenzene

Mg/m3

fl

c

0.0870 U [0.0870 U]

0.174 UJ [0.478 UJ]

0.405 [0.333]

0.226 [0.278]

0.217 U [0.217 U]

0.29 U

0.217 U

Isopropylbenzene _	]

Mg/m3

4200

n

2.46 U [2.46 U]

4.92 U [13.6 U]

<8.21 [<8.21]

<4.92 [<4.92]

6.15 U [6.15 U]

8.21 U

6.15 U

Methyl tert butyl ether	

Mg/m3

110

c

0.0720 U [0.0720 U]

0.144 UJ [0.815 J]

<0.24 [<0.24]

<0.144 [<0.144]

0.18 U [0.18 U]

0.24 U

0.18 U

Methylene Chloride

Mg/m3

1000

c**

1.74 U [1.74 U]

3.47 U [11.3]

<5.8 [<5.8]

<3.47 [<3.47]

4.34 U [19.1]

5.8 U

4.34 U

Naphthalene

Mg/m3

0.83

c*

0.262 UJ [0.262 UJ]

0.524 UJ [1.45 UJ]

4.89 [4.16]

<0.524 [0.566]

0.655 U [0.655 U]

0.876 U

0.655 U

Tetrachloroethene

Mg/m3

110

c**

1,340 [1,270]

1100 [1190]

956 [963]

479 [452]

657 [587]

949

739

Toluene

Mg/m3

52000

n

0.188 U [0.188 U]

0.377 UJ [1.22 J]

1.67 [1.52]

1.20 [1.48]

0.528 [0.546]

1.04

0.471 U

trans-1,2-Dichloroethene

Mg/m3

420

n

0.273 [0.261]

0.285 [0.436 U]

<0.264 [<0.264]

<0.159 [<0.159]

0.198 U [0.198 U]

0.264 U

0.198 U

trans-1,3-Dichloropropene

Mg/m3

7

c*

0.0910 U [0.0910 U]

0.182 U [0.499 U]

<0.303 [<0.303]

<0.182 [<0.182]

0.227 U [0.227 U]

0.303 U

0.227 U

Trichloroethene

Mg/m3

4.8

c**

27.6 [26.0]

25.7 [23.8]

17.6 [17.2]

9.73 [9.19]

13.9 [12.8]

13

7.58

Vinyl Chloride

Mg/m3

1.7

c

0.0510 U [0.0510 U]

0.102 U [0.281 U]

<0.171 [<0.171]

<0.102 [<0.102]

0.128 U [0.128 U]

0.171 U

0.128 U

Xylenes, Total

Mg/m3

1000

n

0.260 U [0.260 U]

0.521 U [1.44 U]

1.53 [1.3]

1.06 [1.38]

0.652 U [0.652 U]

0.869 U

1.04

Notes:

U = Constituent not detected	(1) Calculated from USEPA Residential Air RSL (May 2023) as follows:

J = Indicates an estimated value	Sub-slab RSL = Indoor air RSL + 0.1; where 0.1 is the attenuation factor

NA = not available	(2) basis for screening level: n = noncancer; c = cancer

Mg/m3 = micrograms per cubic meter	c* = the noncancer SL is less than 100 times the cancer SL

[0.109 U] = duplicates results	c** =the noncancer SL is less than 10 times the cancer SL

Screening value for 1,3-dichloropropene was used as a	Bold = exceedance of residential screening level

surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

G-22

-------
Table B2

Sub-slab Soil Vapor Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, MA

Sample Location:
Date Collected:

Units

USEPA
Residential Sub-
slab RSL (1)

Endpoint (2)

SS-1

2/18/2018





SS-1
2/20/2021

SS-1
2/19/2022

SS-1

2/18/2023

SS-2
03/12/11

SS-2
6/18/2011

1,1,1-Trichloroethane

Hg/m3

52000

n

3.96

3.63

2.33

3.89

2.98

2.93

50.0

38.2

1,1,2-Trichloroethane H9/m3

1.8

c**

0.136 U

0.273 U

0.364 U

0.176 U

0.287 U

0.364 U

0.218 U

1.09 U

1,1-Dichloroethane

Hg/m3

18

c

0.172 J

0.202 U

0.27 U

0.189

0.213 U

0.270 U

0.178

0.809 U

1,1-Dichloroethene

Hg/m3

2100

n

0.099 U

0.198 U

0.264 U

0.128 U

0.209 U

0.264 U

0.158 U

0.793 U

1,2,4-Trimethyl benzene

Hg/m3

630

n

0.123 U

0.246 U

0.328 U

0.159 U

0.427

0.328 U

0.196 U

0.983 U

1,2-Dibromoethane

Hg/m3

0.047

c

0.192 U

0.384 U

0.513 U

0.248 U

0.404 U

0.513 U

0.307 U

1.54 U

1,2-Dichloroethane

Hg/m3

1.1

c*

0.101 U

0.202 U

0.27 U

0.131 U

0.213 U

0.270 U

0.162 U

0.809 U 1

1,2-Dichloropropane

Hg/m3

7.6

c**

0.116 UJ

0.231 U

0.308 U

0.149 U

0.243 U

0.308 U

0.185 U

0.924 U

1,3-Butadiene

Hg/m3

0.94

c*

0.055 U

0.111 U

0.148 U

0.072 U

0.116 U

0.148 U

0.0880 U

0.442 UJ

1,3-Dichlorobenzene

Hg/m3

NA

NA

0.15 U

0.301 U

0.401 U

0.194 U

0.316 U

0.401 U

0.240 U

1.2 U

1.4-Dichlorobenzene

Hg/m3

2.6

C

0.15 U

0.301 U

0.401 U

0.194 U

0.316 U

0.401 U

0.240 U

1.2 U

Benzene

Hg/m3

3.6

c*

0.28 U

0.559 U

0.744 U

0.361 U

0.588 U

0.744 U

0.447 U

2.24 U

Bromodichloromethane

HQ/m3

0.76

c

0.243

0.335 U

0.447 U

0.194 J

0.352 U

0.447 U

0.589

1.34 U

Bromoform

Hg/m3

26

c

0.258 U

0.517 U

0.69 U

0.334 U

0.544 U

0.690 U

0.413 U

2.07 U

Carbon Tetrachloride

Hg/m3

4.7

C

0.157 U

0.315 U

0.42 U

0.203 U

0.331 U

0.420 U

0.251 U

1.26 U

Chlorobenzene

Hg/m3

520

n

0.576 U

1.15 U

1.53 U

0.741 U

1.21 U

1.53 U

0.184 U

0.921 U

Chloroform

Hg/m3

1.2

c

14

10.5

10.7

10.4

9.28

8.84

29.5

28.9

cis-1,2-Dichloroethene

Hg/m3

NA

NA

0.099 U

0.198 U

0.264

0.128 U

0.209 U

0.264 U

0.158 U

0.793 U

Ethylbenzene

Hg/m3

11

c

0.109 U

0.217 U

0.29 U

0.14 U

0.228 U

0.290 U

0.174 U

0.869 UJ

Isopropylberrzene

Hg/m3

4200

n

3.07 U

6.15 U

8.21 U

3.96 U

6.49 U

8.21 U

4.91 U

24.6 U

Methyl tert butyl ether

Hg/m3

110

c

0.09 U

0.18 U

0.24 U

0.116 U

	0/I90U

0.240 U

0.144 U

0.721 UJ

Methylene Chloride

Hg/m3

1000

c»*

2.17 U

4.34 U

5.8 U

2.8 U

4.59 U

5.80 U

3.47 U

17.4 U

Naphthalene

Hg/m3

0.83

c*

0.328 U

0.655 U

0.876 U

0.423 U

0.692 UJ

0.876 U

0.524 UJ

2.62 UJ

Tetrachloroethene

Hg/m3

110

c**

882

834

666

773

633

547

3,080

5730

Toluene

Hg/m3

52000

n

0.236 U

0.471 U

0.629 U

0.384

0.991 U

1.25 U

0.376 U

1.88 UJ

trans-1,2-Dichloroethene

Hg/m3

420

n

0.124 J

0.198 U

0.264 U

0.128 U

0.209 U

0.264 U

0.158 U

0.793 U

trans-1,3-Dichloropropene

Hg/m3

7

c*

0.113 UJ

0.227 U

0.303 U

0.147 U

0.239 U

0.303 U

0.181 U

0.908 U

Tri chl oroethene	

Hg/m3

4.8

c**

7.42

6.72

5.91

7.04

5.86

5.64

4.28

4.46

Vinyl Chloride

Hg/m3

1.7

c

0.064 U

0.128 U

0.171 U

0.083 U

0.134 U

0.171 U

0.102 U

0.511 U

Xylenes, Total

Hg/m3

1000

n

0.326 U

0.652 U

0.869 UJ

0.42 U

0.686 U

0.869 U

0.521 U

2.61 U

Notes:

U = Constituent not detected	(1) Calculated from USEPA Residential Air RSL (May 2023) as follows:
J = Indicates an estimated value Sub-slab RSL = Indoor air RSL + 0.1; where 0.1 is the attenuation factor

NA = not available	(2) basis for screening level: n = noncancer; c = cancer

|jg/m3 = micrograms per cubic meter	c* = the noncancer SL is less than 100 times the cancer SL

[0.109 U] = duplicates results	c** = the noncancer SL is less than 10 times the cancer SL

Screening value for 1,3-dichloropropene was used as a	Bold = exceedance of residential screening level
surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

^ARCADIS &

G-23

-------
Table B2

Sub-slab Soil Vapor Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, MA

ftARCADIS

Sample Location:
Date Collected:

Units

USEPA
Residential Sub-
slab RSL (1)

Endpoint (2)

SS-2

3/2/2013





SS-2
2/27/2016

SS-2
3/11/2017

SS-2
2/18/2018

SS-2
3/2/2019

SS-2
2/22/2020

SS-2
2/20/2021

SS-2
2/19/2022

1,1.1-Trichloroethane

pg/m3

52000

n

27.1

27.7

21.1

20.7 [20]

19.9 [21.5]

19.8

15.1

9

15.7

4.03

1,1,2-Trichloroethane

pg/m3

1.8

c**

<1.09

<1.09

1.09 U

1.09 U [1.09 U]

0.546 U [0.546 U]

0.364 U

1.09 U

0.911 U

0.39 U

0.341 U

1,1-Dichloroethane

pg/m3

18

c

<0.809

<0.809

0.809 U

0.809 U [0.809 U]

0.405 U [0.405 U]

0.27 U

0.809 U

0.676 U

0.289 U

0.253 U

1,1-Dichloroethene

pg/m3

2100

n

<0.793

<0.793

0.793 U

0.793 U [0.793 U]

0.396 U [0.396 U]

0.264 U

0.793 U

0.662 U

0.283 U

0.248 U

1.2,4-Trim ethyl benzene

pg/m3

630

n

<0.983

<0.983

0.983 U

0.983 U [0.983 U]

0.492 U [0.492 U]

0.328 U

0.983 U

0.821 U

0.351 U

0.307 U

1,2-Dibromoethane

pg/m3

0.047

c

<1.54

<1.54

1.54 U

1.54 U [1.54 U]

0.769 U [0.769 U]

0.513 U

1.54 U

1.28 U

0.549 U

0.480 U

1,2-Dichloroethane

pg/m3

1.1

c*

<0.809

<0.809

0.809 U

0.809 U [0.809 U]

0.405 U [0.405 U]

0.27 U

0.809 U

0.676 U

0.289 U

0.253 U

1,2-Dichloropropane

pg/m3

7.6

c**

<0.924

<0.924

0.924 U

0.924 U [0.924 U]

0.462 U [0.462 U]

0.308 UJ

0.924 U

0.772 U

0.33 U

0.289 U

1,3-Butadiene

pg/m3

0.94

c*

<0.442

<0.442

0.442 U

0.442 U [0.442 U]

0.221 U [0.221 U]

0.148 U

0.442 U

0.369 U

0.158 U

0.138 U

1,3-Dichlorobenzene

pg/m3

NA

NA

<1.2

<1.20

1.2 U

1.2 U [1.2 U]

0.601 U [0.601 U]

0.401 U

1.2 U

1 U

0.429 U

0.376 U

1,4-Dichlorobenzene

pg/m3

2.6

c

<1.2

<1.20

1.2 U

1.2 U [1.2 U]

0.601 U [0.601 U]

0.401 U

1.2 U

1 U

0.429 U

0.376 U

Benzene

pg/m3

3.6

c*

<2.24

<2.24

2.24 U

2.24 U [2.24 U]

1.12 U [1.12 U]

0.744 U

2.24 U

1.86 U

0.799 U

0.700 U

Bromodichloromethane

pg/m3

0.76

c

<1.34

<1.34

1.34 U

1.34 U [1.34 U]

0.67 U [0.67 U]

0.246 J

1.34 U

1.12 U

0.646

0.502

Bromoform

pg/m3

26

c

<2.07

<2.07

2.07 U

2.07 U [2.07 U]

1.03 U [1.03 U]

0.69 U

2.07 U

1.73 U

0.738 U

0.646 U

Carbon Tetrachloride	

pg/m3

4.7

c

<1.26

<1.26

1.26 U

1.26 U [1.26 U]

0.629 U [0.629 U]

0.42 U

1.26 U

1.05 U

0.449 U

0.452

Chlorobenzene

pg/m3

520

n

<0.921

<0.921

0.921 U |

0.921 U [0.921 U]

2.3 U [2.3 U]

1.53 U

4.61 U

3.84 U

1.64 U

1.44 U

Chloroform

pg/m3

1.2

c

16.4

13.3

11.3

11 [10.7]

8.3 [8.35]

11

7.37

7.67

9.47

3.86

cis-1,2-Dichloroethene

pg/m3

NA

NA

<0.793

<0.793

0.793 U

0.793 U [0.793 U]

0.396 U [0.396 U]

0.264 U |

0.793 U

0.662 U

0.283 U

0.248 U

Ethylbenzene

pg/m3

11

c

<0.869

<0.869

0.869 U

0.869 U [0.869 U]

0.434 U [0.434 U]

0.29 U

0.869 U

0.725 U

0.31 U

0.271 U

I sopropyl benzene

pg/m3

4200

n

<24.6

<24.6

24.6 U

24.6 U [24.6 U]

12.3 U [12.3 U]

8.21 U

24.6 U

20.5 U

8.75 U

7.67 U

Methyl tert butyl ether

pg/m3

110

C

<0.721

<0.721

0.721 U

0.721 U [0.721 U]

0.361 U [0.361 U]

0.24 U

0.721 U

0.602 U

0.257 U

0.225 U

Methylene Chloride

pg/m3

1000

c**

<17.4

<17.4

17.4 U

17.4 U [17.4 U]

8.69 U [8.69 U]

5.8 U

17.4 U

14.5 U

6.18 U

5.42 U

Naphthalene

pg/m3

0.83

c*

<2.62

<2.62

2.62 U

2.62 U [1.89 J]

1.31 U [1.31 U]

0.876 U

2.62 U

2.19 U

0.933 U

0.818 UJ

Tetrachloroethene

pg/m3

110

c**

3390 D

2830

2090

2870 [2800]

1800 [1840]

2370

1790

1380

1760

428

Toluene

pg/m3

52000

n

<1.88

<1.88

1.88 U

1.88 U [1.88 U]

0.942 U [0.942 U]

0.629 U

1.88 U

1.57 U

0.671 U

1.18 U

trans-1,2-Dichloroethene

pg/m3

420

n

<0.793

<0.793

0.793 U

0.793 U [0.793 U]

0.396 U [0.396 U]

0.264 U

0.793 U

0.662 U

0.283 U

0.248 U

trans-1,3-Dichloropropene

pg/m3

7

c*

<0.908

<0.908

0.908 U

0.908 U [0.908 U]

0.454 U [0.454 U]

0.303 UJ |

0.908 U

0.758 U

0.324 U

0.284 U

Trichloroethene

pg/m3

4.8

c**

3.39

2.96

2.36

2.42 [2.36]

2.07 [2.34]

1.95

1.72

1.75

1.9

0.554

Vinyl Chloride

pg/m3

1.7

c

<0.511

<0.511

0.511 U

0.511 U [0.511 U]

0.256 U [0.256 U]

0.171 U I

0.511 U

0.427 U

0.183 U

0.160 U

Xylenes, Total

pg/m3

1000

n

<2.61

<2.61

2.61 U

2.61 U [2.61 U]

1.3 U [1.3 U]

0.869 U

2.61 U

2.17 UJ

0.93 U

0.817 U

Notes:

U = Constituent not detected	(1) Calculated from USEPA Residential Air RSL (May 2023) as follows:

J = Indicates an estimated value	Sub-slab RSL = Indoor air RSL + 0.1; where 0.1 is the attenuation factor

NA = not available	(2) basis for screening level: n = noncancer; c = cancer

pg/m3 = micrograms per cubic meter	c* = the noncancer SL is less than 100 times the cancer SL

[0.109 U] = duplicates results	c** = the noncancer SL is less than 10 times the cancer SL

Screening value for 1,3-dichloropropene was used as a	Bold = exceedance of residential screening level

surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

G-24

-------
Table B2

Sub-slab Soil Vapor Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, MA

^ARCADIS

Design & Consul fancy

Sample Location:
Date Collected:

Units

USEPA
Residential Sub-
slab RSL (1)

Endpoint (2)

SS-2
2/18/2023

SS-3
03/12/11

SS-3
6/18/2011

SS-3
3/2/2013





SS-3
2/27/2016

SS-3
3/11/2017

SS-3
2/18/2018

SS-3
3/2/2019

1,1,1-Trichloroethane

pg/m3

52000

	_n	

11.8

15.9

12.1

5.43

3.84

2.6

5.14

5.73

6.49 J [6.33 J]

6.44 [6.44]

1,1,2-Trichloroethane

pg/m3

1.8

c**

0.682 U

0.109 U 0.218 U

<0.364

<0.218

0.109 U

0.273 U

0.218 U

0.109 U [0.109 U]

0.218 U [0.218 U]

1,1-Dichloroethane

pg/m3 18

c

0.506 U

0.0810 U 0.162 U

<0.27

<0.162

0.081 U

0.202 U

0.162 U

0.081 U [0.081 U]

0.162 U [0.162 U]

1,1-Dichloroethene

pg/m3

2100

n

0.496 U

0.0790 U 0.158 U

<0.264

<0.159

0.079 U

0.198 U

0.159 U

0.079 U [0.079 U]

0.159 U [0.159 U]

1,2,4-Tri methyl benzene

pg/m3

630

n

0.615

0.138 l 0.197 U

<0.328

<0.197

0.241

0.246 U

0.197 U

0.098 U [0.098 U]

0.197 U [0.197 U]

1,2-Dibromoethane

pg/m3 0.047

c

0.961 U

0.154 U | 0.307 U

<0.513

<0.307

0.154 U

0.384 U

0.307 U

0.154 U [0.154 U]

0.307 U [0.307 U]

1,2-Dichloroethane

pg/m3 1-1

c*

0.506 U

0.0810 U 0.162 U

<0.27

<0.162

0.081 U

0.202 U

0.162 U

0.081 U [0.081 U]

0.162 U [0.162 U]

1,2-Dichloropropane

pg/m3 7.6

c"

0.578 U

0.0920 U 0.185 U

<0.308

<0.185

0.092 U

0.231 U

0.185 U

0.092 UJ [0.092 UJ]

0.185 U [0.185 U]

1,3-Butadiene

pg/m3 0.94

c*

0.277 U

0.0440 U 0.089 UJ

<0.148

<0.089

0.044 U

0.111 U

0.089 U

0.044 U [0.044 U]

0.089 U [0.089 U]

1,3-Dichlorobenzene

pg/m3

NA

NA

0.752 U

0.120 U 0.24 U

<0.401

<0.240

0.12 U

0.301 U

0.24 U

0.12 U [0.12 U]

0.24 U [0.24 U]

1,4-Dichlorobenzene

pg/m3

2.6

c

0.752 U

0.120 U 0.24 U

<0.401

<0.240

0.12 U

0.301 U

0.24 U

0.12 U [0.12 U]

0.24 U [0.24 U]

Benzene

pg/m3 3.6

c*

1.40 U

0.223 U 0.447 U

<0.744

<0.447

0.345

0.559 U

0.447 U

0.224 U [0.224 U]

0.447 U [0.447 U]

Bromodichloromethane

pg/m3 0.76

c

3.31

0.623 0.482

<0.447

<0.268

0.100J

0.335 U

0.322

0.214 [0.221 ]

0.268 U [0.268 U]

Bromoform

pg/m3 26

c

1.29 U

0.206 U 0.414 U

<0.69

<0.414

0.207 U

0.517 U

0.414 U

0.207 U [0.207 U]

0.414 U [0.414 U]

Carbon Tetrachloride

pg/m3 4.7

c

0.786 U

0.283 j 0.302

<0.42

<0.252

0.289

0.315 U

0.252 U

0.157 [0.151 ]

0.252 U [0.252 U]

Chlorobenzene

pg/m3 520

n

2.88 U

0.0920 U 0.184 U

<0.307

<0.184

0.092 U

0.23 U

0.921 U

0.461 U [0.461 U]

0.921 U [0.921 U]

Chloroform

pg/m3 12

c

16.4

31.3 32.7

9.67

5.52

4.61

10.8

17.5

37.4 [36.9]

36.3 [36.7]

cis-1,2-Dichloroethene

| pgAn3 I NA

NA

0.496 U

0.0790 U 0.158 U

<0.264

<0.159

0.079 U

0.198 U

0.159 U

0.079 U [0.079 U]

0.159 U [0.159 U]

Ethylbenzene

pg/m3 11

c

0.543 U

0.269 0.174 UJ

0.347

0.287

0.304

0.217 U

0.174 U

0.087 U [0.087 U]

0.174 U [0.174 U]

Isopropylbenzene

pg/m3 4200

n

15.3 U

2.46 U I 4.92 U

<8.21

<4.92

2.46 U

6.15 U

4.92 U

2.46 U [2.46 U]

4.92 U [4.92 U]

Methyl tert butyl ether

pg/m3 110

c

0.451 U

0.0720 U 0.144 UJ

<0.24

<0.144

0.072 U

0.18 U

0.144 U

0.072 U [0.072 U]

0.144 U [0.144 U]

Methylene Chloride

pg/m3 1000

c"

10.8 U

1.74 U I 3.47 U

<5.8

<3.47

2.11

4.34 U

3.47 U

1.74 U [1.74 U]

3.47 U [3.47 U]

Naphthalene

pg/m3 0.83

c*

1.64 U

0.262 UJ 0.524 UJ

<0.876

<0.524

0.262 U

0.655 U

0.524 U

0.262 U [0.152 J]

0.524 U [0.524 U]

Tetrachloroethene

pg/m3 110

c**

1080

1,380 1120

787

447

330

705

538

726 [712]

609 [623]

Toluene

pg/m3 52000

n

2.36 U

0.192 U 0.377 UJ

0.818

0.867

1.37

0.471 U

0.377 U

0.188 U [0.188 U]

0.377 U [0.377 U]

trans-1,2-Dichloroethene

pg/m3 420

n

0.496 U

0.0790 U 0.158 U

<0.264

<0.159

0.079 U

0.198 U

0.159 U

0.079 U [0.079 U]

0.159 U [0.159 U]

trans-1,3-Dichloropropene

pg/m3 7

c*

0.567 U

0.0910 U 0.182 U

<0.303

<0.182

0.091 U

0.227 U

0.182 U

0.091 UJ [0.091 UJ]

0.182 U [0.182 U]

Trichloroethene

pg/m3 4.8

c"

1.61

0.644 0.709

0.519

0.333

0.274

0.43

0.473

0.419 [0.403]

0.462 [0.43]

Vinyl Chloride

pg/m3 1.7

c

0.320 U

0.0510 U 0.102 U

<0.171

<0.102

0.051 U

0.128 U

0.102 U

0.051 U [0.051 U]

0.102 U [0.102 U]

Xylenes, Total

pg/m3 1000

n

1.63 U

11.6 0.521 U

8.17

3.62

4.43

0.652 U

0.521 U

0.261 U [0.261 U]

0.521 U [0.521 U]

Notes:

U = Constituent not detected	(1) Calculated from USEPA Residential Air RSL (May 2023) as follows:

J = Indicates an estimated value	Sub-slab RSL = Indoor air RSL + 0.1; where 0.1 is the attenuation factor

NA = not available	(2) basis for screening level: n = noncancer; c = cancer

pg/m3 = micrograms per cubic meter	c* = the noncancer SL is less than 100 times the cancer SL

[0.109 U] = duplicates results	c** = the noncancer SL is less than 10 times the cancer SL

Screening value for 1,3-dichloropropene was used as a	Bold = exceedance of residential screening level
surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. February 15, 2023.

G-25

-------
Table B2

Sub-slab Soil Vapor Sampling Results - Commercial Property 260206
UniFirst Corporation
Woburn, MA

^ARCADIS

Design & Consultancy
for natural and
bui» iissots

Sample Location:
Date Collected:

Units

USEPA
Residential Sub-
slab RSL (1)

Endpoint (2)

SS-3

2/22/2020

SS-3
2/20/2021

SS-3
2/19/2022

SS-3
2/18/2023

1,1,1-Trichloroethane

pg/m3

52000

n

5.02 [4.47]

7.75 [8.35]

5.89 [6.93]

6.44 [6.60]

1,1,2-Trichloroethane

|jg/m3

1.8

C"

0.303 U [0.273 U]

0.14 U [0.13 U]

0.202 U [0.228 U]

0.237 U [0.248 U]

1.1-Dichloroethane

pg/m3

18

c

0.225 U [0.202 U]

0.104 U [0.096 U]

0.150 U [0.169 U]

0.176 U [0.184 U]

1,1-Dichloroethene

pg/m3

2100

n

0.22 U [0.198 U]

0.101 U [0.094 U]

0.147 U [0.165 U]

0.172 U [0.180 U]

1,2,4-Trimethyl benzene

pg/m3

630

n

0.273 U [0.246 U]

0.126 U [0.117 U]

0.182 U [0.205 U]

0.214 U [0.224 U]

1,2-Dibromoethane

pg/m3

0.047

c

0.427 U [0.384 U]

0.197 U [0.183 U]

0.284 U [0.320 U]

0.334 U [0.350 U]

1,2-Dichloroethane

pg/m3

1.1

c*

0.225 U [0.202 U]

0.104 U [0.096 U]

0.150 U [0.169 U]

0.176 U [0.184 U]

1,2-Dichloropropane

pg/m3

7.6

c**

0.257 U [0.231 U]

0.118 U [0.11 U]

0.171 U [0.193 U]

0.201 U [0.210 U]

1,3-Butadiene

pg/m3

0.94

C

0.123 U [0.111 U]

0.057 U [0.053 U]

0.082 U [0.092 U]

0.096 U [0.101 U]

1.3-Dichlorobenzene

pg/m3

NA

NA

0.334 U [0.301 U]

0.154 U [0.143 U]

0.222 U [0.251 U]

0.262 U [0.274 U]

1,4-Dichlorobenzene

pg/m3

2.6

c

0.334 U [0.301 U]

0.154 U [0.143 U]

0.222 U [0.251 U]

0.262 U [0.274 U]

Benzene

pg/m3

3.6

c*

0.62 U [0.559 U]

0.287 U [0.266 U]

0.415 U [0.466 U]

0.486 U [0.508 U]

Bromodichloromethane
Bromoform

pg/m3

0.76

C

0.372 U [0.335 U]

0.335 [0.359]

0.360 [0.349]

0.291 UJ [0.426 J]

pg/m3

26

c

0.575 U [0.517 U]

0.265 U [0.246 U]

0.383 U [0.431 U]

0.450 U [0.470 U]

Carbon Tetrachloride

pg/m3

4.7

c

0.35 U [0.315 U]

0.161 U [0.157]

0.233 U [0.262 U]

0.274 U [0.286 U]

Chlorobenzene

pg/m3

520

n

1.28 U [1.15 U]

0.589 U [0.548 U]

0.852 U [0.958 U]

0.999 U [1.05 U]

Chloroform

pg/m3

1.2

c

54.7 [46.1 ]

56.6 [61.5]

50.8 [58.1 ]

57.1 [57.6]

cis-1,2-Dichloroethene

pg/m3

NA

NA

0.22 U [0.198 U]

0.101 U [0.094 U]

0.147 U [0.165 U]

0.172 U [0.180 U]

Ethylbenzene

pg/m3

11

c

0.242 U [0.53]

0.111 U [0.103 U]

0.161 U [0.181 U]

0.189 U [0.198 U]

Isopropylbenzene

pg/m3

4200

n

6.83 U [6.15 U]

3.15 U [2.93 U]

4.55 U [5.11 U]

5.36 U [5.60 U]

Methyl tert butyl ether

pg/m3

110

c

0.2 U [0.18 U]

0.092 U [0.086 U]

0.133 U [0.150 U]

0.157 U [0.164 U]

Methylene Chloride

pg/m3

1000

c**

4.83 U [4.34 U]

2.23 U [2.07 U]

3.22 U [3.61 U]

3.79 U [3.96 U]

Naphthalene

pg/m3

0.83

c*

0.729 U [0.655 U]

0.336 U [0.312 U]

0.486 UJ [0.545 UJ]

0.572 U [0.598 U]

Tetrachloroethene

pg/m3

110

C"

566 [478]

586 [644]

462 [529]

430 [438]

Toluene

pg/m3

52000

n

0.524 U [0.471 U]

0.275 [0.238]

0.697 U [0.784 U]

0.818 U [0.855 U]

trans-1,2-Dichloroethene

pg/m3

420

n

0.22 U [0.198 U]

0.101 U [0.094 U]

0.147 U [0.165 U]

0.172 U [0.180 U]

trans-1,3-Dichloropropene

pg/m3

7

c*

0.252 U [0.227 U]

0.116 U [0.108 U]

0.168 U [0.189 U]

0.197 U [0.207 U]

Trichloroethene

pg/m3

4.8

c**

0.507 [0.457]

0.503 [0.505]

0.478 [0.559]

0.432 [0.428]

Vinyl Chloride

pg/m3

1.7

c

0.142 U [0.128 U]

0.065 U [0.061 U]

0.095 U [0.107 U]

0.111 U [0.116 U]

Xylenes, Total

pg/m3

1000

n

0.725 UJ [2.54 J]

0.334 U [0.31 U]

0.482 U [0.543 U]

0.565 U [0.591 U]

Notes:

U = Constituent not detected	(1) Calculated from USEPA Residential Air RSL (May 2023) as follows:

J = Indicates an estimated value	Sub-slab RSL = Indoor air RSL 0.1; where 0.1 is the attenuation factor

NA = not available	(2) basis for screening level: n = noncancer; c = cancer

pg/m3 = micrograms per cubic meter	c* = the noncancer SL is less than 100 times the cancer SL

[0.109 U] = duplicates results	c** = the noncancer SL is less than 10 times the cancer SL

Screening value for 1,3-dichloropropene was used as a	Bold = exceedance of residential screening level

surrogate for trans-1,3-dichloropropene.

Source: RD/RA Year 31 Annual Report for the UniFirst Site. Prepared by UniFirst Corporation. Febraary 15, 2023.

G-26

-------
WILD WOOD PROPERTY

BW-12

>WWJJo-

WW3Q0&

mmuhkd

wwfl-fi
'WWWWV211C

VWW-21DD
WW-310S

BW-14RS2-'
- BCW-14
aw-14

'HW-Xi-

-	BSSW-15

-	BMMSRP _

-	PZ-1A *

-	PZ-'B
BCW-fS
EW-1«D|UP|
BW-HHOfl-O)
-3CWL1S
=^B3rt--G

-	BCMM0

-	BSW-10

BttklfiR

wwpoeo —

VM.2Q&B ->*
bwMoloi

BW-6RD;UEv
qyb^R —4-
i>OWJ6—iy-

SW-1D

WW304

FW3
V.W-- Q2I0

wmuiisa
¦mxe
assw-17
¦ 9WW-17
BW-17R
- PW-3

V7\

asw-e ' y > .
B5£\v-e A;rtw.2»^

WW-212

WUWOOD PROFSSTV
WEU.GAH 3WFERFUND 3ITE

APPENDIX H - WILDWOOD PROPERTY DATA REVIEW FIGURES AND TABLES

figure H-l: Site Layout - Wildwood Property

Legend

& Ai Soj'ae vVa«
• Montcrtnn Well
© Pvong Wei

VOOi in SosI Abort.
CtMltafl Cm Bid

Emwtor sVe l

BMHMMMOa

— . nuttf I *«¦

wow	mewaft:

hi t.si'yt r4tf*uf>.



x ^77fcf#S77£^ >
<* S7tSS®ig77c. ^





¦ PZ-S

ABERJONAAUTO PARTS
PROPERTY

awt ifjet-ia |oftwn a	|		

Source: Integrated Subsurface Treatment System Annual Report Year 19 and 20
by AECOM. March 24, 2021.

- May 2016 through April 2018. Prepared

AECOM

H-l

-------
BBW-7
<4fi1 /2011)

MM FT-16
TOO SMO)
WW-201
43O0M82O17)

1 BSW-12

\ MHPT-4
11.315 (16-20)«
£7230(43-47)

~WW-211S
79 2 (4O6C022)
I WA1211D
'i6io yaaajzt) j
WHPT- 10.' 5

47820 {JS-37)

WiV-2CCO

WW3103
44 2 >}4.*2£.*2022>

^		MHOT-26

.-		MOD (21-25)

	 AW-213

¦-r—=-*^7 1230(4tf&l2Q22>

BW20K* .
S. 47 2* {7/7/8015)^ 	

-1 mmptS >*s 2

23150(17-21)/

B0'A'-14
I8(1«18.'201«)

MHP7r273
-:33 (6-10)

7-f N O 	«

1«0 NO
MH»7-104
NO <7-11) —
25(16-20)
'AW-20SS
1 5 (408/2022)
88-12

24 ND 	

1MB ND

><15.(1CEl_4)i

16 (4.'2Si'2D18)
) '

^vassw-a

(4,'11»!1S)

WW-20S#
21282 (4.27.2022)

	 MHPT-20

27® 2 (14-18)
S&SW-17
~ 222 8(4.'27.r2022)

434 <13-17;.
M3 420-24),

2713 (16-20)
'AUV-214S
«4 5(4«7tf027>
	 MS-PT-19

1» 9(14-18)-

/MHPT-120GW
ND (14-18) ^

«MHPT-1Z2
M 3 8 (20-24)
) BOWS
NO {1MQB017)

BSW9

22(7«?J017)
BOWS
ND (427.2011) '
«H>T-118
NO (12-16)

112*8(14-18)
24(22-26) |

Jf?(1f19£Q16)

« MW>T-1 16 f
\\ 9420(20-24) g
. " l*B OS-JCil

NO (10-14)

233 2,(3M4)

7S740 (22-26) ^

22(31-36)

I A&55 /
ND(4/2«20il)

-RSLEYWEU.2

Figure H-2: Total VOCs Isoconcentration Contours, Upper Overburden

Legend

Tola VOCs Isoconcentration Contour

VOC Results Not Exceeding the
Consent Decree Cleanup Criteria

Total VOCs In Groundwater (|jg/L)
O Nor>-Detect (ND)
® >0 and <=10
O >10 and <=100

•	> 100

Total VOCs In MHPT Locations (pg/L)

~	Non-Deteet (ND)

~	>0 and <=10

~	>10 and <=100
¦ > 100

Total VOCs In Soil Borings Ipg/kg)
A Non- Detect
~ >0 and <=10
A >10

•	Air Sparge Wells
Air Sparge Network

= = Treatment Cell

	St rea m/Waterbody

	Road

Railroad
Sewer Line
Fence

W LDWOOD PROPERTY

— VOCsinSoilAbove
! Cleanup Criteria

Notes

1.	The upper overburden isocencentration
contours were drawn to both figures.

2.	The undefined wells were not used in
contouring,

3.	This figure presents the most recent data
point for each well as of April 2022, with the
corresponding sample date in parentheses.

4.	This figure presents the groundwater grab
sample dala collected through July 2022.

S775S^
j*)(4«3tf018)

ABERJONAAUTO PARTS
PROPERTY

WILDWOOD PROPERTY
WELLS G&H SUPERFUNDSITE

6071120421

FIGURE 3A

TOTAL VOCs ISOCONCENTRATION CONTOURS
UPPER OVERBURDEN

A=COM

Scale m Feet

Source: Work Plan to Optimize Air Sparge System at Wilchvood Property, Rev. 2. Prepared by AECOM. September 25,
2023.

H-2

-------
I BW-7
1 NO <4010011)

9 8W-12
N0<4fiH«011)

ND <4/25/2018L

W) <4/250018)

t/HPT-17
462(32-36)

WW210D
ND (4/23/2002)

SCW-14
NO <2/17/2017)

;42r46j

A 8SW14
X" 62 6 <4/18/20171

MHPT-27
ND232 7 (4O7/2022)

MHf=T-23
170 <27-31)
WW209

" 906(32-36)

[iwt V3640I
V.184 <42-461

UHPTr105,
NO <22-2® <

"MHSrr-224
42<2e-3ofl

6 <404 4)

1359 <3&42)

' M.f»T-121
30 <32-36)
v$C8 >36-40)

ND {31-35)1

WWT-114
95ND (4/26/3011)

Figure H-3: Total VOCs Isoconcentration Contours, Deep Overburden

Legend

Total VOCs Isoconcentration Contour

OV0C Results Not Exceeding the
Consent Decree Cleanup Criteria

Total VOCs in Groundwater (pg/L)

O Non-Detect (ND)
® >0 and <=10
O >10 and <=100
& >100
Total VOCs in M HPT Locations (ug/L)

WILD WOOD PROPERTY

~	Non-Detect (ND)

~	>0and<*10

~	>10 and <=100

~	> 100

® Air Sparge Wells
Air Spaige Network
= = Treatment Cell

	Stream/Waterbody

	Road

Railroad
Sewer Line
Fence

VOCs in Soil Above
Cleanup Criteria

Notes

1.	The deep overburden isocenoentration
contours were drawn to both figures.

2.	The underlined wells were not used in
contouring.

3.	This figure presents the most recent data
point for each well as of April 2022, with the
corresponding sample date in parentheses.

4.	This f igu re presents the grou ndwater grab
sample data collected through July 2022.

S7 70 ^

<10/22/2018)

S77M sf
ND <4/23/2018)JM
/ S77S {CJ
3 9 ¦4/23/2016)

MWSAStWS?/,^.,^

\V MHPTJ8	un'

W 576(40^44).

\\	8CW-6

^^O»5<10/f7/20J^l

OTYOFWO0URN 	\ %V

SEWEREJfifcMENT \\ NO*MO>	\ V N

\\	Q >vQ46<37

MMM-116^ X\ *
\\ NO <17-41)	« »

u	r£. \

ABERJONAAUTO PARTS
PROPERTY

WILDWOOD PROPERTY
WELLS G&H SUPERFUND SITE

60711204 21

FIGURE 3B

TOTAL VOCs ISOCONCENTRATION CONTOURS
DEEP OVERBURDEN

AECOM

Source: Work Plan to Optimize Air Sparge System at Wildwood Property, Rev. 2. Prepared by AECOM. September 25,
2003.

H-3

-------
Figure H-4: Proposed Bedrock Boring Locations

Source: Work Plan to Optimize Bedrock Pump & Treat System at Wildwood Property, Rev. 2, Final. Prepared by AECOM.
October 26, 2023 (with mark-ups to reflect additional investigative locations discussed by EPA and AECOM in late 2023).

H-4

-------
figure H-5: PFAS

Overburden, 2021

FIGURE 1

OCTOBER2021 PFAS SAMPLE LOCATIONS
UPPER OVERBURDEN

I

1

A=COAi	" "" a"

in FppI

WILDWOOD PROPERTY

WILDWOOD PROPERTY
WELLS G&H SUPERFUND SrTE

6QS039CM.2018 /JO

dm t:: ovjisa an | iiiavn : jb	[

Legend

WW-211D Lofton Sampbd for PFAS
in October 2021

® Monitoring Well

© Air Sparge Wells

—Air Spaigc Network

= == Treatment Cell

	Stream/Waterbody

	Road

Railroad

Sewer Une

Fence

	VOCs in Soil Above

J Cleanup Criteria



1

BSSW-16€K	~

/ ~

, ' *

' S	/

, / *

' / ~

/ / /

/ /' /' ABERJONAAUTO PARTS

/ / ,/	PROPERTY

1 ' /'

©BOW^B
©BSW-8 \

\

\

\

Source: Per- and Polyfluoroalkyl Substances (PFAS) Sampling Results Wildwood Property Portion of the Wells G&H
Superfund Site. Prepared by AECOM. January 31. 2022.

H-5

-------
„ 	H-6: PFAS Sample Locations in Lower Overburden, 2021

WILD WOOD PROPERTY
WELLS G&HSUPERFUND SITE

FIGURE 2

OCTOBER 2021 PFAS SAMPLE LOCATIONS
LOWER OVERBURDEN

A=COM	0 " 80

Scale in Feel

Legend

WW-206 Locatbn Sampled for PFAS
in October 2021

£ Monitoring Well

• Air Sparge Wells

Air Spaige Network

= = Treatment Cell

	StreanYWaterbody

	Road

Railroad

Sewer Une

Fence

j	1 VOCs in Soil Above

J Cleanup Criteria

WILDWOOD PROPERTY

ABERJONAAUTO PARTS
PROPERTY

Source: Per- and Polyfluoroalkyl Substances (PFAS) Sampling Results Wildwood Property Portion of the Wells G&H
Superfund Site. Prepared by AECOM. January 31, 2022.

H-6

-------
Figure H-7: PFAS Sample Locations in Bedrock, 2021

A=COM

ABERJONAAUTO PARTS
PROPERTY

Legend

RW-10 Location Sam pled (or PFAS

in October 2021
WW-191.BR Location Inaccessible for

PFAS Sampling in October 2021

o Monitoring Well
© Ait Sparge Wells

	Air Sparge Network

= = Treatment Cell

	Stre a m.'Wa terbo dy

	Road

- Railroad
Sewer Line
hence

~ VOCs in Soil Above
Cleanup Criteria

Source: Per- and Polyfluoroalkyl Substances (PFAS) Sampling Results Wildwood Property Portion of the Wells G&H
Superfund Site. Prepared by AECOM. January 31. 2022.

H-7

-------
APPENDIX I - NEP PROPERTY DATA REVIEW FIGURES AND TABLES





Figure 1-1: Overburden Potentiometric Surface and July 2023 PCE/TCE Concentrations

New England Plastics
Corporation

noees:

1.	NEP-1Q2 W3£ paved over n 1595. NEP-10S6 MS destroyed
in 19S3 ana decommissioned lr 200?

2.	Sur^ data Tor h&ixfcal wells (exciudlngNEP-111 andNEP-
112) fcased en trie 1950 elevation and location survey o> GeoTrans.

3.	Property Boinsane'te noi deleted ai specified referring limit

g.5	Concentrations in excess of ROD altera (5 ug.".

1 inch = 70 feet



Project#; 230322

Map Created: September 2023 ... , ,

Woodard

TNraParty GS Dacamer ThB map itr . f" . »
re!w*rceana jj'SD'-ical ditkcm Guyana " WUIIOM
stw-fci re. Ce *c f J jecn by third caret: I5r
any :ejaf Oeds4or.s fnt wiance uocr tf«
a hewn tut fce X tfre

-------
<9MG&i^§

Figure 1-2: Bedrock Potentiometric Surface and July 2023 PCE/TCE Concentrations

Figure 4

Bedrock Potentiometric Surface and
July 2023 PCE/TCE Concentrations

New England Plastics Corporation
Wofoum, Massachusetts



Legend

-(J)- Monfiortng Weils

Destroyed Monitwng Wess
-ftjr Forme? Searodc Production Wells

Off-Property Overburden wets

New England Plastics]
Corporation F

inferred Bearcefc PoiencomKPc Contours (ft AMSl;.

51.54 Measured SedrocK Pot&itiometrte Surface
Elevation, July 21,2023

TCE Trtcaloroetoene, u&'l

<1.0 Aiayle no: detected at speared reporting limit

Project ft 230322

Kite© Created September 2023 Wo Od d rd

TOrdSaro St3 D:sciai~.er:TMs mac a Iter H, f nrrnn
and graphs pupMes onyarfl * V-UITail
i-oj-d not Be relied jpy fj inra nates 'cr

1.	NEP-1D2 #as paved ovef n 19S6. nep-1059 was oespoyea
In 1993 and seconmissionea in 2001.

2.	Survey cata *or nsarlca «e-s lext tiding NEP-111 and NEP-
112) aased on mei9SC elevarJon ana oca tor survey By GeoTrans.

3.	Propeny bconsartes ostalned from M3SSGIS.

Source: 2023 Groundwater Monitoring Report, New England Plastics Corporation. Prepared by Woodard & Curran. September 2023.

1-2

-------
England Plastics
Corporation

"igure 1-3: PFAS Sampling Locations, 2021





M:r



¦,-r

103B

New

NERTl09!f

,r p

Figure 1

November 2021
PFAS Sampling Locations

New England Plastics Corporation
Woburn, Massachusetts

Legend

-0- Mcnltoflng Well

Nc.«moer 2021 PFAS Sampung Location
Destroyed Monitoring well
-qr Foimer Secroc* Production Well
-0- Deep BedroeK well

OP-Prope.ty Overouraen Wei

1.	NEP-1Q2 was paved over in 1S96. NEP-109B was
dsstroysd in 1993 3nd deccnnusslcned in 2001.

2.	Property boundaries ossasnea fforn MassGis.

1 inch = 70 feet

Project#: 230322
Map Created Januaiy 2022

TJiM s=art( OlS Disclaimer This rap is fa- ^

reference ara spapWca puroases only ana

sfto-Jfl net te re ea upcr Oj BUM partes "or WOO DA RD

Source: November 2021 PFAS Groundwater Monitoring, New England Plastics Corporation. Prepared by Woodard& Curran. January 31, 2022.

1-3

-------
APPENDIX J - OLYMPIA PROPERTY DATA REVIEW FIGURES AND TABLES

Figure J-l: Olympia Property Site Features

J-l

-------
Source: Characterization Work Plan, Wells G&H NPL Site, Former Dram Disposal Area. Prepared by Roux Associates, Inc. October 2023.

J-2

-------
APPENDIX K- SITE INSPECTION CHECKLISTS

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST



I. SITE INFORMATION

Site Name: Wells G&H - Grace Property (OU-1)

Date of Inspection: December 5, 2023

Location and Region: Woburn. MA; Region 1

EPA ID: MAD980732168

Agency, Office or Company Leading the Five-Year

Weather/Tcmpcrature: partly cloudy, approx. 35

Review: EPA Region 1

degrees F

Remedy Includes: (check all that apply)



~ Landfill cover/containment ~ Monitored natural attenuation

~ Access controls ~ Groundwater containment

~ Institutional controls ~ Vertical barrier walls

^ Groundwater pump and treatment



~ Surface water collection and treatment



~ Other:



Attachments: S Inspection team roster attached

~ Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Marvellen Johns, de

Project manager

maximis. inc.

Title Date

Name



Interviewed ~ at site ~ at office ~ by phone by email

Problems, suggestions [~~| Report attached: See Appendix D.

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.

Agencv MassDEP



Contact Jennifer McWecnev Project

Name manager Date Phone

Title



Problems/suggestions PI Report attached: See Appendix D.

Agencv



Contact Name



Title

Date Phone

Problems/suggestions PI Report attached:



Agencv



Contact



Name Title

Date Phone

Problems/suggestions PI Report attached:



Agencv



Contact



Name Title

Date Phone

Problems/suggestions P| Report attached:



K-l

-------


Aeencv
Contact

Name Title Date

Problems/suggestions [~~| Report attached:

Phone





4.

Other Interviews (optional) PI Report attached:











III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents









13 O&M manual Readily available Up to date

~ n/a





[3 As-built drawings ^ Readily available ^ Up to date

~ n/a





13 Maintenance logs ^ Readily available ^ Up to date

~ n/a





Remarks: O&M documents are also maintained electronicallv.







2.

Site-Specific Health and Safety Plan |3 Readily available

~ Up to date

~ n/a



~ Contingency plan/emergency response plan ~ Readily available

~ Up to date

E

|n/a



Remarks:







3.

O&M and OSHA Training Records ^ Readily available

~ Up to date

~ n/a



Remarks: Maintained off-site bv respective contractors.







4.

Permits and Service Agreements









~ Air discharge permit ~ Readily available

~ Up to date

E

|n/a



~ Effluent discharge ~ Readily available

~ Up to date

IE

|n/a



~ Waste disposal. POTW ~ Readily available

~ Up to date

IE

|n/a



n Other permits: fl Readilv available

~ Up to date

E

|n/a



Remarks: Discharge to Snvder Creek is per agreement with the citv of Woburn.





5.

Gas Generation Records ~ Readily available
Remarks:

~ Up to date

E

|n/a

6.

Settlenient Monument Records ~ Readily available

Remarks:

~ Up to date

E

|n/a

7.

Groundwater Monitoring Records ^ Readily available

13 Up to date

~ n/a



Remarks: Maintained off-site. Annual reports arc submitted to EPA.







8.

Leachate Extraction Records ~ Readily available

~ Up to date

E

|n/a



Remarks:







9.

Discharge Compliance Records









~ Air ~ Readily available ~ Up to date

13 n/a





13 Water (effluent) |3 Readily available 13 Up to date

~ N/A





Remarks: Effluent is tested monthlv; results arc submitted in annual reports to EPA.





K-2

-------
10. Daily Access/Security Logs

^1 Readily available Up to date [H N/A

Remarks: The treatment building is locked. Access logs are kept in the treatment building.

IV. O&M COSTS

1. O&M Organization



[~l State in-housc

O Contractor for state

1 1 PRP in-housc

1X1 Contractor for PRP (de niaxiniis. GES)

l~l Federal facility in-house

O Contractor for Federal facility

n



2. O&M Cost Records



[~l Readily available

~ Up to date

1^1 Funding nicclianisni/agrcciiicnt in place O 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 ^ N/A

Remarks:



B. Other Access Restrictions

1. Signs and Other Security Measures

~ Location shown on site map ~ N/A

Remarks: The treatment building is kept locked.

C. Institutional Controls (ICs)

K-3

-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented

[H Yes



No

~ N/A

Site conditions imply ICs not being fully enforced

~ Yes

El

No

~ N/A

Type of monitoring (e.g.. self-reporting, drive by):









Frequency:









Responsible partv/agencv:









Contact









Name Title

Date



Phone

Reporting is up to date

[~l Yes

~

No

IKlN/A

Reports arc verified by the lead agency

l~l Yes

~

No

0N/A

Specific requirements in deed or decision documents have been met

l~l Yes

~

No

0N/A

Violations have been reported

[~l Yes

~

No

§N/A

Other problems or suggestions: ~ Report attached

2. Adequacy	^ ICs arc adequate	~ ICs arc inadequate	~ N/A

Remarks: Decision documents did not require institutional controls for OU-1. However, a local ordinance
prohibits installation of private wells and property-specific soil management plans are used to manage
potential exposures to soil and groundwater. EPA should determine whether a decision document is
needed to identity institutional controls as a remedy component.

D. General

1.	Vandalism/Trespassing ~ Location shown on site map	No vandalism evident
Remarks:	

2.	Land Use Changes On Site	~ N/A

Remarks: The property has been redeveloped with a hotel and three restaurants. The Chick-fil-A
restaurant recently expanded its drive-thru lanes. One of the three restaurant spaces is not currently in use
(the building is vacant).

3.	Land Use Changes Off Site	~ N/A

Remarks: None

VI. GENERAL SITE CONDITIONS

A.	Roads ^ Applicable ~ N/A

1. Roads Damaged	~ Location shown on site map [3 Roads adequate ~ N/A

Remarks: Parking areas and access roads on the developed property were in good condition.

B.	Other Site Conditions

Remarks:	

VII. LANDFILL COVERS	~ Applicable ^ N/A

VIII. VERTICAL BARRIER WALLS	~ Applicable ^ N/A

IX. GROUNDWATER/SURFACE WATER REMEDIES ^ Applicable ~ N/A

A. Groundwater Extraction Wells, Pumps and Pipelines	[3 Applicable ~ N/A

1. Pumps, Wellhead Plumbing and Electrical

K-4

-------


^1 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

Readily available £3 Good condition O Requires upgrade ~ Needs to be provided
Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A

1.

Collection Structures, Pumps and Electrical

O Good condition Q 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

~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:

C.

Treatment System ~ Applicable ~ N/A

1.

Treatment Train (check components that apply)

O Metals removal ~ Oil/water separation O Bioremediation
~ Air stripping ^ Carbon adsorbers
E3 Filters: bag

n Additive (e.g.. chelation agent flocculent):
n Others:

E3 Good condition ~ Needs maintenance
E3 Sampling ports properly marked and functional

E3 Sampling/maintenance log displayed and up to date
E3 Equipment properly identified

K Ouantitv of groundwater treated annually: See annual report,
n Ouantitv of surface water treated annually:

Remarks:

2.

Electrical Enclosures and Panels (properly rated and functional)
~ N/A E3 Good condition ~ Needs maintenance

Remarks:

3.

Tanks, Vaults, Storage Vessels

I"! N/A ^ Good condition Ex] Proper secondary containment PI Needs maintenance

K-5

-------
Remarks:

4.

Discharge Structure and Appurtenances

O N/A O Good condition ~ Needs maintenance
Remarks: Not observed

5.

Treatment Building)*)

O N/A 1^ Good condition (esp. roof and doorways) O Needs repair

O Chemicals and equipment properly stored

Remarks:

6.

Monitoring Wells (pump and treatment remedy)

[x] Properly secured/locked ^ Functioning ^ Routinely sampled ^ Good condition

O All required wells located ~ Needs maintenance ~ N/A
Remarks:

D. Monitoring Data

1.

Monitoring Data

Is routinely submitted on time ^ Is of acceptable quality

2.

Monitoring Data Suggests:

E3 Groundwater plume is effectively contained [3 Contaminant concentrations are declining*

*Most wells show decreasing trends, although two
wells in the center of the property show increasing
trends (see Data Review section of the FYR
Report).

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:

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 any facility associated with the rcmcdv. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

A.

Implementation of the Remedy



Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).



The rcmcdv for the Grace property includes groundwater extraction and treatment and long-term
groundwater monitoring. Although not reciuired bv the ROD. vapor intrusion barriers were also installed
at several of the ncwiv-constructcd buildings during redevelopment activities.



The GWETS is designed to prevent contaminated groundwater in the unconsolidated deposits and shallow
bedrock from flowing off-propertv. The svstem is operating as designed. Concentrations of TCE in
groundwater at the sampled monitoring and recovery wells have declined significantlv since the start of
the extraction svstem as a result of the extraction svstem operation. Manv monitoring w ells on-site have
met the ROD cleanup levels. However, at least one ell on-site is showing increasing concentration trends.
Opportunities for optimizing the rcmcdv should be evaluated.

B.

Adequacy of O&M

K-6

-------
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.
	O&M procedures are adequate.	

C.	Early Indicators of Potential Remedy Problems	

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future.

None noted; however, the Grace contractors noted the challenges inherent with maintaining an aging
	system on a redeveloped property.	

D.	Opportunities for Optimization	

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Opportunities for optimization will be evaluated as part of the FYR process.

Site Inspection Participants:

Jennifer McWeeney, MassDEP

Janet Waldron. MassDEP

Jim Ricker. HGL (EPA oversight contractor)

Kirbv Webster. Skeo (EPA FYR contractor)

Tony Penfold. W.R. Grace

Maryellen Johns, de maximis, inc. (Grace contractor)
Van Sawyer, GES (Grace contractor)

K-7

-------
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST



I. SITE INFORMATION

Site Name: Wells G&H - UniFirst Property (OU-1)

Date of Inspection: December 5, 2023

Location and Region: Woburn. MA; Region 1

EPA ID: MAD980732168

Agency, Office or Company Leading the Five-Year

Weather/Tcmpcrature: Partly cloudy; approx. 35

Review: EPA Region 1

degrees F

Remedy Includes: (check all that apply)



~ Landfill cover/containment ~ Monitored natural attenuation

~ Access controls ~ Groundwater containment

~ Institutional controls ~ Vertical barrier walls

Groundwater pump and treatment



~ Surface water collection and treatment



Kl Other: SVE system; long-term groundwater monitoring

Attachments: S Inspection team roster attached

~ Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Cat Malagrida

UniFirst Environmental

Name

Comoliance Manager Date



Title

Interviewed ~ at site at office ~ by phone [3 by email

Problems, suggestions [~~| Report attached: See Aooendix D.

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.

Agencv MassDEP



Contact Jennifer McWecnev Project

Name manager Date Phone

Title



Problems/suggestions PI Reoort attached: See Aooendix D.

Agency



Contact Name



Title

Date Phone

Problems/suggestions PI Reoort attached:



Agency



Contact



Name Title

Date Phone

Problems/suggestions PI Reoort attached:



Agency



Contact



Name Title

Date Phone

Problems/suggestions PI Reoort attached:



Agency



Contact



K-8

-------


Name Title
Problems/sueeestions [~~| Report attached:

Date

Phone



4.

Other Interviews (optional) ~ Report attached:











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

^1 Up to date

~ N/A



[3 Maintenance logs ^ Readily available

Up to date

~ N/A



Remarks: O&M manuals were on-site for the site inspection. Electronic versions arc also maintained



bv UniFirst and its contractors.







2.

Site-Specific Health and Safety Plan

^ Readily available

~ Up to date

~ n/a



~ Contingency plan/emergency response plan

13 Readily available

~ Up to date

~ n/a



Remarks: Maintained off-site.







3.

O&M and OSHA Training Records
Remarks: Maintained off-site.

^ Readily available

13 Up to date

~ 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 ocrmits:

~ Readily available

~ Up to date

13 N/A



Remarks:







5.

Gas Generation Records

^ Readily available

13 Up to date

~ n/a



Remarks: SVE flow rates arc kept oil-site and rcDortcd to EPA annuallv.





6.

Settlement Monument Records
Remarks:

~ Readily available

~ Up to date

13 N/A

7.

Groundwater Monitoring Records
Remarks: Maintained off-site.

^ Readily available

13 Up to date

~ n/a

8.

Leachate Extraction Records

Remarks:

~ Readily available

~ Up to date

13 N/A

9.

Discharge Compliance Records









13 Air ^ Readily available

^ Up to date

~ N/A



13 Water (effluent) ^ Readily available

^ Up to date

~ N/A



Remarks: Discharge records arc maintained off-site and reported to EPA monthly and/or annuallv.

10.

Daily Access/Security Logs

13 Readily available

13 Up to date

~ n/a

K-9

-------
Remarks:

IV. O&M COSTS

1. O&M Organization





l~l State in-housc

~ Contractor for state

1X1 PRP in-housc

1X1 Contractor for PRP ( Arcadis)

l~l Federal facility in-house

O Contractor for Federal facility

~





2. O&M Cost Records





l~l Readily available

O Up to date



1X1 Funding mechanism/agreement in place Q Unavailable



Original O&M cost estimate:

~ Breakdown attached



Total annual cost by year for review period if available

From: To:



~ Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: None





V. ACCESS AND INSTITUTIONAL CONTROLS ^ Applicable ~ N/A

A. Fencing

1. Fencing Damaged ~ Location shown on site map ~ Gates secured ~ N/A

Remarks:





B. Other Access Restrictions

1. Signs and Other Security Measures

~ Location shown on site map [3 N/A

Remarks:





C. Institutional Controls (ICs)

K-10

-------
1.

Implementation and Enforcement







Site conditions imply ICs not properly implemented

[H Yes

M No

~ N/A

Site conditions imply ICs not being fully enforced

~ Yes

S No

~ N/A

Type of monitoring (e.g.. self-reporting, drive bv):







Frequency:







Responsible partv/agencv:







Contact







Name Title

Date

Phone

Reporting is up to date

[~l Yes

~ No

IKlN/A

Reports arc verified by the lead agency

l~l Yes

~ No

0N/A

Specific requirements in deed or decision documents have been met

l~l Yes

~ No

0N/A

Violations have been reported

[~l Yes

~ No

IKIn/a

Other problems or suggestions: ~ Report attached







2. Adequacy	^ ICs arc adequate	~ ICs arc inadequate	~ N/A

Remarks: Decision documents did not require institutional controls for OU-1. However, a local ordinance
prohibits installation of private wells and property-specific soil management plans are used to manage
potential exposures to soil and groundwater. EPA should determine whether a decision document is
needed to identify institutional controls as a remedy component.

D. General

1.	Vandalism/Trespassing ~ Location shown on site map	No vandalism evident
Remarks:	

2.	Land Use Changes On Site	~ N/A
Remarks: None.

3.	Land Use Changes Off Site	~ N/A

Remarks: None.

VI. GENERAL SITE CONDITIONS

A.	Roads [3 Applicable ~ N/A

1. Roads Damaged	~ Location shown on site map ^ Roads adequate ~ N/A

Remarks:	

B.	Other Site Conditions

Remarks:	

VII. LANDFILL COVERS	~ Applicable ^ N/A

VIII. VERTICAL BARRIER WALLS	~ Applicable ^ N/A

IX. GROUNDWATER/SURFACE WATER REMEDIES [3 Applicable ~ N/A

A. Groundwater Extraction Wells, Pumps and Pipelines	[3 Applicable ~ N/A

1. Pumps, Wellhead Plumbing and Electrical

^ Good condition	All required wells properly operating ~ Needs maintenance ~ N/A

K-ll

-------
Remarks: UC-22 and EX-1 were both operating.

2.

Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
^1 Good condition Q Needs maintenance

Remarks:

3.

Spare Parts and Equipment

Readily available O Good condition O Requires upgrade O Needs to be provided
Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A

1.

Collection Structures, Pumps and Electrical

O Good condition Q 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

~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:

C.

Treatment System ^ Applicable ~ N/A

1.

Treatnient Train (check components that apply)

~	Metals removal ~ Oil/water separation ~ Biorcinediation

~	Air stripping E3 Carbon adsorbers
Ex] Filters: (sand and bag filters)

n Additive (e.g.. chelation agent, flocculent):
n Others:

E3 Good condition ~ Needs maintenance
E3 Sampling ports properly marked and functional
E3 Sampling/maintenance log displayed and up to date

Equipment properly identified
K Ouantitv of groundwater treated annuallv: varies; see annual O&M reports
n Ouantitv of surface water treated annuallv:

Remarks:

2.

Electrical Enclosures and Panels (properly rated and functional)
~ N/A ^ Good condition ~ Needs maintenance

Remarks:

3.

Tanks, Vaults, Storage Vessels

K-12

-------


O N/A ^ Good condition ~ Proper secondary containment

1 1 Needs maintenance



Remarks:



4.

Discharge Structure and Appurtenances

O N/A ~ Good condition ~ Needs maintenance
Remarks: Not observed; treated effluent is discharged to the storm sewer.



5.

Treatment Building)*)





O N/A ^ Good condition (esp. roof and doorways)

~ Needs repair



O Chemicals and equipment properly stored





Remarks:



6.

Monitoring Wells (pump and treatment remedy)





Properly secured/locked E3 Functioning ^ Routinely sampled

Good condition



~ All required wells located ~ Needs maintenance

~ N/A



Remarks: Not all site wells were observed. The observed flush mount wells were secured and in good
condition.

D. Monitoring Data

1.

Monitoring Data





Is routinely submitted on time ^ Is of acceptable quality

2.

Monitoring Data Suggests:





E3 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



O All required wells located ~ Needs maintenance

En/a



Remarks:



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 any facility associated with the remedy. An example would be soil vapor extraction.



SVE



The SVE svstcm appears to be in good condition and operating as designed. SVE performance is reported

monthly and annually to EPA.

XI. OVERALL OBSERVATIONS

A.

Implementation of the Remedy



K-13

-------


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 reincdv for UniFirst includes a GWETS to prevent off-propertv migration of contaminated
groundwater and an SVE svstein to reduce VOCs in soil to cleanup levels and to reduce the potential for
vapor intrusion into the on-site building. The GWETS appears to be preventing off-site migration of
contaminated groundwater with two extraction wells (UC-22 and EX-1). The SVE svstein has been
effective in removing VOC mass from soil and continues to do so. A negative vacuum is maintained in
soil beneath the building indicating that the potential for vapor intrusion is being controlled. The GWETS
continues to extract contaminated groundwater and over time should reduce concentrations of VOCs to
cleanup levels. However, elevated levels of VOCs remain in the eastern part of the property. An
investigation of a potential source area near the former sewer line is planned.

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.
None.

C.

Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future.

None.

D.

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Opportunities for optimization will be evaluated as part of the FYR process.

Site inspection participants:

Jennifer McWeeney, MassDEP

Janet Waldron. MassDEP

Jim Ricker. HGL (EPA oversight contractor)

Kirby Webster. Skeo (EPA FYR contractor)

Cat Malagrida, UniFirst

Bettina Longino, Arcadis (UniFirst contractor)

K-14

-------
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST



I. SITE INFORMATION

Site Name: Wells G&H - New England Plastics Property
(OU-1)

Date of Inspection: December 5, 2023

Location and Region: Woburn. MA; Region 1

EPA ID: MAD980732168

Agency, Office or Company Leading the Five-Year

Weather/Tcmpcrature: Partly cloudy; approx. 35

Review: EPA Region 1

degrees F

Remedy Includes: (check all that apply)



~ Landfill cover/containment ~ Monitored natural attenuation

~ Access controls ~ Groundwater containment

~ Institutional controls ~ Vertical barrier walls

^1 Groundwater pump and treatment (not implemented)

~ Surface water collection and treatment



[3 Other: SVE/AS system operated from 1998-2000; long-term groundwater monitoring

Attachments: S Inspection team roster attached

~ Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Jeff Hamel. Woodard &



Curran. LSP

Title Date

Name



Interviewed ~ at site ~ at office ~ by phone by email

Problems, suggestions [~~| Report attached: See Appendix D.

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.

Agencv MassDEP



Contact Jennifer McWecnev Project

Name manager Date Phone

Title



Problems/suggestions PI Report attached: See Appendix D.

Agencv



Contact Name



Title

Date Phone

Problems/suggestions PI Report attached:



Agencv



Contact



Name Title

Date Phone

Problems/suggestions PI Report attached:



Agencv



Contact



Name Title

Date Phone

Problems/suggestions PI Report attached:



Agencv



Contact



K-15

-------


Name Title
Problems/suggestions [~~| Report attached:

Date

Phone

4.

Other Interviews (optional) d Report attached:









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



~ As-built drawings ~ Readily available

~ Up to date

M N/A



~ Maintenance logs ~ Readily available

O Up to date

I3n/a



Remarks: O&M is no longer reauired for SVE/AS system; a long-term monitoring plan is in place.

2.

Site-Specific Health and Safety Plan

^1 Readily available

13 Up to date ~ N/A



~ Contingency plan/emergency response plan

~ Readily available

~ Up to date [X] N/A



Remarks: A health and safetv plan is maintained off-site and taken in the field when field work is



performed (i.e.. sampling).





3.

O&M and OSHA Training Records
Remarks: Maintained off-site.

^ Readily available

13 Up to date LJ N/A

4.

Permits and Service Agreements







~ Air discharge permit

~ Readily available

~ Up to date [X] N/A



~ Effluent discharge

~ Readily available

~ Up to date [X] N/A



~ Waste disposal. POTW

~ Readily available

~ Up to date [X] N/A



n Other permits:

~ Readily available

~ Up to date [X] N/A



Remarks:





5.

Gas Generation Records
Remarks:

~ Readily available

~ Up to date 13 N/A

6.

Settlement Monument Records
Remarks:

~ Readily available

~ Up to date 13 N/A

7.

Groundwater Monitoring Records
Remarks: Maintained off-site.

^ Readily available

13 Up to date ~ N/A

8.

Leachate Extraction Records

~ Readily available

~ Up to date 13 N/A



Remarks:





9.

Discharge Compliance Records







~ Air ~ Readily available

~ Up to date

13 n/a



~ Water (effluent) ~ Readily available

~ Up to date

13 N/A



Remarks:





10.

Daily Access/Security Logs

~ Readily available

~ Up to date 13 N/A



Remarks: NEP is an operating facilitv; Woodard & Curran coordinates with the property owner for

K-16

-------
sampling events.

IV. O&M COSTS

1. O&M Organization





l~l State in-housc

O Contractor for state

1 1 PRP in-house

1X1 Contractor for PRP (Woodard & Curran)

l~l Federal facility in-house

~ Contractor for Federal facility

n





2. O&M Cost Records





[~l Readily available

~ Up to date



1^1 Funding mechanism/agreement in place O Unavailable



Original O&M cost estimate:

~ Breakdown attached



Total annual cost by year for review period if available

From: To:



~ Breakdown attached

Date Date

Total cost



From: To:



~ Breakdown attached

Date Date

Total cost



From: To:



~ Breakdown attached

Date Date

Total cost



From: To:



~ Breakdown attached

Date Date

Total cost



From: To:



~ Breakdown attached

Date Date

Total cost



3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: None.





V. ACCESS AND INSTITUTIONAL CONTROLS £

] Applicable ~ N/A

A. Fencing

1. Fencing Damaged ~ Location shown on site map ~ Gates secured N/A

Remarks: Although not reciuircd for the remedy. the property is fenced and gates arc generally secured

when no one is present on the property.

B. Other Access Restrictions

1. Signs and Other Security Measures

~ Location shown on site map ~ N/A

Remarks: The property is fenced. The trailer housing the former AS/SVE system is also locked.

C. Institutional Controls (ICs)

K-17

-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented

[H Yes



No

~ N/A

Site conditions imply ICs not being fully enforced

~ Yes

El

No

~ N/A

Tvdc of monitoring (e.g.. self-reporting, drive bv):









Frequency:









Responsible partv/aucncv:









Contact









Name Title

Date



Phone

Reporting is up to date

[~l Yes

~

No

IKlN/A

Reports arc verified by the lead agency

l~l Yes

~

No

0N/A

Specific requirements in deed or decision documents have been met

l~l Yes

~

No

0N/A

Violations have been reported

[~l Yes

~

No

IKIn/a

Other problems or suggestions: ~ Report attached

2.

Adequacy ^ ICs arc adequate ~ ICs arc inadequate ~ N/A

Remarks: Decision documents did not rcciuire institutional controls for OU-1. However, a local ordinance
prohibits installation of private wells and propcrtv-spccific soil management plans arc used to manage
potential exposures to soil and groundwater. EPA should determine whether a decision document is
needed to identify institutional controls as a rcincdv component.

D.

General

1.

Vandalism/Trespassing ~ Location shown on site map ^ No vandalism evident

Remarks:

2.

Land Use Changes On Site ~ N/A
Remarks: None.

3.

Land Use Changes Off Site ~ N/A
Remarks: None.

VI. GENERAL SITE CONDITIONS

A. Roads [3 Applicable ~ N/A

1.

Roads Damaged ~ Location shown on site map ^ Roads adequate ~ N/A
Remarks:

B.

Other Site Conditions

Remarks:

VII. LANDFILL COVERS ~ Applicable ^ N/A

VIII. VERTICAL BARRIER WALLS ~ Applicable ^ N/A

IX. GROUNDW ATER/SURFACE WATER REMEDIES ~ Applicable ^ N/A

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 any facility associated with the remedy. An example would be soil vapor extraction.

LONG-TERM GROUNDWATER MONITORING

K-18

-------


Observed monitoring wells were secured. The wells arc routinely monitored in accordance with EPA-
approved plans. Monitoring data arc routinelv submitted on time and arc of acceptable aualitv.



EPA recently rcciucstcd monitoring of two additional deep bedrock wells (NEP-1 and NEP-2). Both well
locations were observed during the site inspection. Thev arc both inaccessible for sampling. One is near
an electrical substation; the other is under a silo.

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 1989 ROD originally called for groundwater pumping and treatment. However, this part of the
rcincdv has not been implemented.



The implemented rcincdv for NEP included AS and SVE. which was intended to reduce concentrations in
soil and overburden groundwater to ROD cleanup goals. The AS/SVE svstcm was effective in addressing
ROD cleanup levels in unsaturated soils and significantly reducing concentrations of TCE and PCE in
groundwater. The svstcm has been shut down since 2000. Overburden and shallow bedrock groundwater
is presently monitored even other year (bicnniallv) and shows downward trends. During the most recent
sampling events in 2021 and 2023. PCE was the onlv COG detected above ROD cleanup levels in the
wells sampled. Sampling in 2016 also identified contamination above cleanup levels in deep bedrock
wells on-site. EPA has rcciucstcd sampling of additional deep bedrock wells, but the rcciucstcd wells
(NEP-1 and NEP-2) were found to be inaccessible during the site inspection (one well was located next to
an electrical substation that serves the operating facility; the second well was under a silo).

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.
None.

C.

Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future.

None.

D.

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Opportunities for optimization will be evaluated as part of the FYR process.

Site Inspection Participants:

Jennifer McWeeney, MassDEP

Janet Waldron. MassDEP

Jim Rickcr. HGL (EPA oversight contractor)

Kirby Webster. Skeo (EPA FYR contractor)

Jeff Hanicl. Woodard and Curran (NEP contractor)

K-19

-------
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST



I. SITE INFORMATION

Site Name: Wells G&H - Wildwood Property (OU-1)

Date of Inspection: December 6, 2023

Location and Region: Woburn. MA; Region 1

EPA ID: MAD980732168

Agency, Office or Company Leading the FYR: EPA
Region 1

Weather/Temperature: cloudy. 32 degrees F

Remedy Includes: (check all that apply)



~ Landfill covcr/containmcnt ~ Monitored natural attenuation

~ Access controls ~ Groundwater containment

~ Institutional controls ~ Vertical barrier walls

^ Groundwater pump and treatment



~ Surface water collection and treatment



^ Other: soil, sludge and debris removal. AS/SVE, long-term groundwater monitoring

Attachments: Inspection team roster attached

O Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Pete Cox. AECOM



Name

Title Date

Interviewed ~ at site ~ at office ~ by phone



Problems, sueeestions [~~| Report attached: See Aooendix D.

2. O&M Staff



Name

Title Date

Interviewed [~~| at site [~~| at office [~~| bv phone Phone:

Problems/sueeestions [~~| 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.

Agencv MassDEP



Contact Jennifer McWecnev Project

Name manager Date Phone

Title



Problems/sueeestions PI Reoort attached: See Aooendix D.

Aeencv



Contact Name



Title

Date Phone

Problems/sueeestions PI Reoort attached:



Aeencv



Contact



Name Title

Date Phone

Problems/sueeestions PI Reoort attached:



Aeencv



Contact



Name Title

Date Phone

Problems/sueeestions PI Reoort attached:



Aeencv



Contact



K-20

-------


Name Title
Problems/sueeestions [~~| Report attached:

Date

Phone



4.

Other Interviews (optional) d Report attached:











III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents

13 O&M manual Readily available
13 As-built drawings Readily available
[3 Maintenance logs ^ Readily available
Remarks:

^1 Up to date
^1 Up to date
^ Up to date

~	N/A

~	N/A

~	N/A

2.

Site-Specific Health and Safety Plan

~ Contingency plan/emergency response plan

Remarks:

^1 Readily available
~ Readily available

~	Up to date

~	Up to date

~ n/a
Sn/a

3.

O&M and OSHA Training Records
Remarks:

^ Readily available

~ Up to date

~ n/a

4.

Permits and Service Agreements

~	Air discharge permit

~	Effluent discharge

~	Waste disposal, POTW
n Other permits:

Remarks:

~	Readily available

~	Readily available

~	Readily available

~	Readily available

~	Up to date

~	Up to date

~	Up to date

~	Up to date

13 N/A
13 N/a
13 N/A
13 N/A

5.

Gas Generation Records
Remarks:

~ Readily available

~ Up to date

13 N/A

6.

Settlement Monument Records
Remarks:

~ Readily available

~ Up to date

13 N/A

7.

Groundwater Monitoring Records
Remarks:

^ Readily available

13 Up to date

~ n/a

8.

Leachate Extraction Records
Remarks:

~ Readily available

~ Up to date

13 N/A

9.

Discharge Compliance Records

13 Air ^ Readily available ^ Up to date
13 Water (effluent) ^ Readily available ^ Up to date
Remarks: Maintained off-site and reported to EPA ciuarterlv.

~	N/A

~	N/A

K-21

-------
10. Daily Access/Security Logs

^1 Readily available Up to date [H N/A

Remarks:



IV. O&M COSTS

1. O&M Organization



[~l State in-housc

O Contractor for state

1 1 PRP in-housc

M Contractor for PRP (AECOM)

l~l Federal facility in-house

O Contractor for Federal facility

n



2. O&M Cost Records



[~l Readily available

O Up to date

1^1 Funding mechanism/agreement in place O 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: Costs associated with optimization of the AS/SVE svstein and GWETS.

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable ~ N/A

A. Fencing

1. Fencing Damaged ~ Location shown on site map ~ Gates secured ~ N/A

Remarks: The proocrtv is fenced except along the Abcriona River.

B. Other Access Restrictions

1. Signs and Other Security Measures

~ Location shown on site map ~ N/A

Remarks: Signs on both Droocrtv gates. The treatment building is locked when contractors arc not on-

site.

C. Institutional Controls (ICs)

K-22

-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented

[H Yes



No

~ N/A

Site conditions imply ICs not being fully enforced

~ Yes

El

No

~ N/A

Tvdc of monitoring (e.g.. self-reporting, drive bv):









Frequency:









Responsible partv/agencv:









Contact









Name Title

Date



Phone

Reporting is up to date

[~l Yes

~

No

IKlN/A

Reports arc verified by the lead agency

l~l Yes

~

No

0N/A

Specific requirements in deed or decision documents have been met

l~l Yes

~

No

0N/A

Violations have been reported

[~l Yes

~

No

IKIn/a

Other problems or suggestions: ~ Report attached

2.

Adequacy ^ ICs arc adequate ~ ICs arc inadequate ~ N/A

Remarks: Decision documents did not rcciuire institutional controls for OU-1. However, a local ordinance
prohibits installation of private wells and property-specific soil management plans arc used to manage
potential exposures to soil and groundwater. EPA should determine whether a decision document is
needed to identify institutional controls as a rcincdv component.

D.

General

1.

Vandalism/Trespassing ~ Location shown on site map ^ No vandalism evident

Remarks:

2.

Land Use Changes On Site ~ N/A

Remarks: None observed, but tree cutting is planned for the southern part of the propertv. It is being
cleared for optimization of the AS/SVE svstcm.

3.

Land Use Changes Off Site ~ N/A
Remarks: None

VI. GENERAL SITE CONDITIONS

A.

Roads ^ Applicable ~ N/A

1.

Roads Damaged ~ Location shown on site map ^ Roads adequate ~ N/A
Remarks:

B.

Other Site Conditions

Remarks:

VII. LANDFILL COVERS ~ Applicable ^ N/A

VIII. VERTICAL BARRIER WALLS ~ Applicable ^ N/A

IX. GROUNDWATER/SURFACE WATER REMEDIES ^ Applicable ~ N/A

A. Groundwater Extraction Wells, Pumps and Pipelines [3 Applicable ~ N/A

1

Pumps, Wellhead Plumbing and Electrical

^ Good condition All required wells properly operating O Needs maintenance ~ N/A

K-23

-------
Remarks:

2.

Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

^1 Good condition Q Needs maintenance

Remarks:

3.

Spare Parts and Equipment

Readily available £3 Good condition O Requires upgrade ~ Needs to be provided
Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A

1.

Collection Structures, Pumps and Electrical

O Good condition Q 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

~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:

C.

Treatment System ^ Applicable ~ N/A

1.

Treatnient Train (check components that apply)

~ Metals removal ~ Oil/water separation ~ Bioremediation
^ Air stripping E3 Carbon adsorbers
Ex] Filters: bag and sand
n Additive (e.g.. chelation agent, flocculent):
n Others:

E3 Good condition ~ Needs maintenance
E3 Sampling ports properly marked and functional

E3 Sampling/maintenance log displayed and up to date
E3 Equipment properly identified

K Ouantitv of groundwater treated annuallv: See ciuarterlv reports
n Ouantitv of surface water treated annuallv:

Remarks:

2.

Electrical Enclosures and Panels (properly rated and functional)
~ N/A ^ Good condition ~ Needs maintenance
Remarks:

3.

Tanks, Vaults, Storage Vessels

~ N/A ^ Good condition ~ Proper secondary containment ~ Needs maintenance
Remarks:

K-24

-------
4.

Discharge Structure and Appurtenances

O N/A ^ Good condition ~ Needs maintenance

Remarks: Treated effluent is discharged to a storm sewer and then the Aberiona River (manhole/catch
basin in Salem Street).

5.

Treatment Building)*)

O N/A ^ Good condition (esp. roof and doorw ay s) ~ Needs repair

[x] Chemicals and equipment properly stored

Remarks:

6.

Monitoring Wells (pump and treatment remedy)

O Properly secured/locked ^ Functioning ^ Routinely sampled O Good condition
~ All required wells located ~ Needs maintenance Q N/A
Remarks: Not all wells were secured.

D. Monitoring Data

1.

Monitoring Data

E3 Is routinely submitted on time [3 Is of acceptable quality

2.

Monitoring Data Suggests:

O Groundwater plume is effectively contained ~ Contaminant concentrations arc declining

The AS/SVE and bedrock extraction svstem arc

being upgraded to optimize the rcmcdv.

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:

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 any facility associated with the remedy. An example would be soil vapor extraction.



AS/SVE

Beatrice submitted a Work Plan to Optimize Air Sparge Svstem at Wildwood Property in Mav 2021. which was

revised in September 2023 after additional site investigations in 2021 and 2022. The work plan proposed to

expand the existing AS to incorporate shallow AS points screened within the lower conductivity fine sands and to

address additional impacts found in the area south of the existing treatment area (referred to as the South Area).

This work is ongoing.

Off-gas treatment of the existing svstem has been disconnected temporarily with EPA approval. Off-gas treatment

will resume if warranted for the svstem upgrade.

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 remedy at Wildwood includes in-situ volatilization of contaminated soil (primarily in a wetland area),
extraction and treatment of contaminated groundwater and long-term groundwater monitoring. It also

K-25

-------
included soil, sludge and debris removal. The existing systems arc functioning as designed; however, the
AS/SVE is being expanded to address contamination found in the lower conductivity fine sands as well as
the southern part of the property. The bedrock groundwater extraction system is also being optimized.

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 protcctivcncss of the remedy.

O&M for the existing systems are adequate at this time. Once the upgraded systems are installed, the

	^	

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 protcctivcncss of the remedy may be compromised
in the future.

	None.	

D.	Opportunities for Optimization	

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Upgrades and expansion of the AS/SVE system and GWETS are ongoing.

Site Inspection Participants:

Jennifer McWeeney, MassDEP

Janet Waldron. MassDEP

Kirbv Webster. Skco (EPA FYR contractor)

Pete Cox, AECOM (Wildwood contractor)

Jen Atkins. AECOM (Wildwood contractor)

Brandan Maye, AECOM (Wildwood contractor)

K-26

-------
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Wells G&H - Olympia Property (OU-1)

Date of Inspection: December 6, 2023

Location and Region: Woburn. MA; Region 1

EPA ID: MAD980732168

Agency, Office or Company Leading the FYR: EPA
Region 1	

Weather/Temperature: cloudy, approx. 32 degrees
F

Remedy Includes: (check all that apply)

~	Landfill cover/containment	~ Monitored natural attenuation

~	Access controls	~ Groundwater containment

~	Institutional controls	Vertical barrier walls
[3 Groundwater pump and treatment (not implemented)

~	Surface water collection and treatment

	Other: soil removal. I SCO, long-term groundwater monitoring	

Attachments: S Inspection team roster attached

~ Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager

Brian Klaus. Roux
Name

Interviewed ~ at site ~ at office ~ by phone

Title

| by email

Problems, suggestions Q Report attached: See Appendix D.

Date

2. O&M Staff

Name

Interviewed ~ at site ~ at office ~ by phone
Problems/suggestions Q Report attached:

Title

Phone:	

Date

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

Name	manager

Title

Problems/suggestions ~ Report attached: See Appendix D.

Date

Phone

Agency.
Contact

Name

Title

Date

Phone

Problems/suggestions ~ Report attached:.

Agency	

Contact 			

Name Title
Problems/suggestions ~ Report attached:	

Date

Phone

Agency	

Contact 			

Name Title
Problems/suggestions ~ Report attached:	

Date

Phone

Agency .
Contact

K-27

-------


Name Title
Problems/suggestions [~~| Report attached:

Date

Phone



4.

Other Interviews (optional) ~ Report attached:











III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents









~ O&M manual ~ Readily available

~ Up to date

EIn/a



~ As-built drawings ~ Readily available

~ Up to date

EIn/a



~ Maintenance logs ~ Readily available

~ Up to date



N/A



Remarks: There arc no ongoing O&M activities. Under the PPA. site characterization activites arc



taking place.







2.

Site-Specific Health and Safety Plan

^ Readily available

~ Up to date

~ n/a



~ Contingency plan/emergency response plan

~ Readily available

~ Up to date

Sn/A



Remarks: Site contractors maintain a health and safetv plan while work is ongoing.



3.

O&M and OSHA Training Records
Remarks: Maintained off-site bv contractors.

^ Readily available

~ Up to date

~ n/a

4.

Permits and Service Agreements









~ Air discharge permit

~ Readily available

~ Up to date

Sn/A



~ Effluent discharge

~ Readily available

~ Up to date

Sn/A



~ Waste disposal. POTW

~ Readily available

~ Up to date

0N/A



n Other ocrmits:

~ Readily available

~ Up to date

Sn/a



Remarks:







5.

Gas Generation Records
Remarks:

~ Readily available

~ Up to date

IEI n/a

6.

Settlement Monument Records
Remarks:

~ Readily available

~ Up to date

Sn/a

7.

Groundwater Monitoring Records

~ Readily available

~ Up to date

~ n/a



Remarks: Soil and groundwater characterization is currentlv ongoing under the PPA.



8.

Leachate Extraction Records

Remarks:

~ Readily available

~ Up to date

Sn/A

9.

Discharge Compliance Records









~ Air ~ Readily available

~ Up to date

§N/A



~ Water (effluent) ~ Readily available

~ Up to date

Sn/a



Remarks:







10.

Daily Access/Security Logs

~ Readily available

~ Up to date

Sn/A

K-28

-------
Remarks:

IV. O&M COSTS

1. O&M Organization





l~l State in-housc

~ Contractor for state

1 1 PRP in-housc

O Contractor for PRP

l~l Federal facility in-house

O Contractor for Federal facility

153 Contractor for oroDcrtv owner





2. O&M Cost Records





l~l Readily available

O Up to date



l~l Funding mechanism/agreement in place

l~l Unavailable



Original O&M cost estimate: [~~l Breakdown attached



Total annual cost by year for review period if available

From: To:



~ Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



From: To:



O Breakdown attached

Date Date

Total cost



From: To:



O 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 ~ N/A

Remarks: The FDD A is surrounded bv a fence.





B. Other Access Restrictions

1. Signs and Other Security Measures

~ Location shown on site map [3 N/A

Remarks:





C. Institutional Controls (ICs)

K-29

-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented

[H Yes



No

~ N/A

Site conditions imply ICs not being fully enforced

~ Yes

El

No

~ N/A

Type of monitoring (e.g.. self-reporting, drive by):









Frequency:









Responsible partv/agencv:









Contact









Name Title

Date



Phone

Reporting is up to date

[~l Yes

~

No

IKlN/A

Reports arc verified by the lead agency

l~l Yes

~

No

0N/A

Specific requirements in deed or decision documents have been met

l~l Yes

~

No

0N/A

Violations have been reported

[~l Yes

~

No

IKIn/a

Other problems or suggestions: ~ Report attached

2. Adequacy	^ ICs arc adequate	~ ICs arc inadequate	~ N/A

Remarks: Decision documents did not require institutional controls for OU-1. However, a local ordinance
prohibits installation of private wells and property-specific soil management plans are used to manage
potential exposures to soil and groundwater. EPA should determine whether a decision document is
needed to identity institutional controls as a remedy component.

D. General

1.	Vandalism/Trespassing ~ Location shown on site map	No vandalism evident
Remarks:	

2.	Land Use Changes On Site	~ N/A

Remarks: Site characterization work is ongoing within and near the FDD A: the developed portions of the
property are in use as a trucking facility, church and other commercial/industrial businesses.

3.	Land Use Changes Off Site	~ N/A

Remarks: None

VI. GENERAL SITE CONDITIONS

A.	Roads [3 Applicable ~ N/A

1. Roads Damaged	~ Location shown on site map ^ Roads adequate ~ N/A

Remarks:	

B.	Other Site Conditions

Remarks:	

VII. LANDFILL COVERS	~ Applicable ^ N/A

VIII. VERTICAL BARRIER WALLS	^ Applicable ~ N/A

1.	Settlement	~ Location shown on site map E3 Settlement not evident

Area extent:		Depth:	

Remarks: Subsurface sheetpiling surrounds the FDDA

2.	Performance Monitoring Type of monitoring: None; site characterization is ongoing.

K-30

-------
HH Performance not monitored

Frequency:		~ Evidence of breaching

Head differential:	

Remarks:	

IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable [x] N/A

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 any facility associated with the remedy. An example would be soil vapor extraction.

Site characterization activities at the FDDA are ongoing under the PPA. I SCO was previously used at the property
beginning in 2005 through 2020.

Additional remedial efforts for a petroleum release are underway for the developed portion of the Site under a
state remediation program, and are separate from the CERCL A response.

	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 2003 Action Memorandum called for excavating PCB-contaminated surface soils and addressing
TCE-contaminated subsurface soils through a combination of treatment and/or excavation and/or capping
in place. Contaminated surface soils were removed in 2003. A sheet pile wall was installed around the
FDD A in 2004. I SCO injections took place from 2005 to 2020. In late 2022. EPA entered into a PP A with
a prospective purchaser. Under the PPA. the prospective purchaser agreed to perform a removal action in
an effort to enhance and accelerate the treatment of TCE contaminated soils to achieve cleanup levels. The
work will include site characterization, removal options assessment and proposal, removal implementation
and site restoration. Site characterization efforts are underway.

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.

There are no ongoing O&M activities.

C.	Early Indicators of Potential Remedy Problems	

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future.

	N^n^itjhi^im^	

P. Opportunities for Optimization	

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

Site characterization efforts under the PP A are ongoing. The results will be used to determine remedy
optimization opportunities at the property.	

Site Inspection Participants:

Jennifer McWeeney, MassDEP
Kirby Webster. Skco (EPA FYR contractor)
Brian Klaus. Roux (Property owner contractor)
Ed Weagle, Roux (Property owner contractor)

K-31

-------
APPENDIX L - SITE INSPECTION PHOTOS

Grace Property, December 5, 2023

New hotel on the Grace property

Restaurant on Grace property; a manhole cover for extraction well RW-22RE
is on the right side of the landscaped area

L-l

-------
Groundwater treatment building on the rear of the Grace property

L-2

-------
Groundwater treatment building interior

Extraction well vault cover for RW-20

L-3

-------
L-4

-------
UniFirst Property, December 5, 2023

Self-storage facility on the UniFirst property; vapor intrusion sampling
takes place in the commercial building in the background

-<¦ ¦¦¦

» f s:~

Extraction well near the (synthetic) boulder

L-5

-------
Oxygen Depleted
Atm^phere

Treatment system building interior (GAC units)

SVE treatment system components

L-6

-------
Extraction well vault cover

L-7

-------
NEP Property, December 5, 2023

The NEP building

•.Bf-

Locked trailer that houses the former AS/SVE system components at the NEP property

L-8

-------
Paved area adjacent to the NEP building; deep bedrock well NEP-2 is adjacent to the silo on the right

Area near deep bedrock well NEP-2

L-9

-------
Deep bedrock well NEP-1

L-10

-------
Wildwood Property, December 6, 2023

Gated entrance to the Wildwood property

Wildwood treatment building

L-ll

-------
Treatment building interior

Treatment building interior with SVE piping

1-12

-------
Extraction well

Wetlands at the Wildwood property with the Abeijona River in the background

1-13

-------
Mats needed to support rigs for boring installation at the Wildwood property

Unsecured stick-up well at the Wildwood property, located within the fence

L-14

-------
AS/SVE area at the Wildwood property

L-15

-------
Olympic! Property, December 6, 2023

FDDA work area

L-16

-------
Church on the developed part of the Olympia property, along Olympia Road

Trucking facility fueling area at the Olympia property

1-17

-------
APPENDIX M - SOIL CLEANUP LEVELS REVIEW

Tabic M-1 compares the Site's soil cleanup levels to EPA's current RSLs for residential land use.

EPA's RSLs are calculated using the latest toxicity values, default exposure assumptions and physical and
chemical properties. As shown in Table M-l, the soil cleanup levels correspond to a risk level within EPA's
acceptable risk range (10~6 to 10~4) and an HQ below 1. Although the cleanup level for lead (640 mg/kg) is above
the 200 mg/kg screening level for residential soils, it is below the 1,000 mg/kg screening level for
commercial/industrial land use. None of the Source Area Properties are in residential use.

In addition, lead was only identified as a soil COC at the Wildwood property due to the presence of sludge.
Although the lead cleanup level identified in the ROD (640 mg/kg) exceeds the current lead soil screening level
for residential land use of 200 mg/kg. the Wildwood property is currently undeveloped and undergoing remedial
actions. In addition, based on sampling conducted in 1987 for soil and 1994 post-excavation sampling following
sludge removal activities, the average lead concentrations of surface and subsurface soils at this property are less
than the residential soil screening level. Table M-2 presents average lead concentrations at each of the properties,
where available.

Table M-l: Review of Oi

J-l ROD Cleanup Levels for Soil

COC

Cleanup Level"
(mg/k«)

EPA Residential RSLb

(mg/kg)

Cancer Risk1'

Noncanccr
HQ'1



Risk = 1 x 10*

HQ= 1



Chloroform

0.062

0.32

200

2 x 10""

0.0003

PCE

0.0367

24

81

2 x 10"9

0.0005

TCE

0.0127

0.94

4.1

1 x 10"8

0.003

trans-1,2-Dichloroethene

0.0832

-

70

-

0.001

1,1,1-TCA

0.613

-

8,100

-

0.00008

Chlordanc

6.14

1.7e

35e

4 x 10"6

0.2

4,4'- DDT

23.5

1.9

37

1 x 10"5

0.6

cPAHs

0.694

0.11

18

6 x 10"6

0.04

PCBs

1.04

0.23f

-

5 x 10"6

-

Lead

640

2008

Not applicable

Notes:











a) Cleanup levels arc from Tabic 5 and Tabic 6 of the 1989 ROD. Lead cleanup level is from page 30 of the 1989 ROD.

b) November 2023 residential soil RSLs from www.eoa.eov/risk/regional-screening-levels-rels-generic-tables (accessed

December 18, 2023).











c) The 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 level cancer-based RSL) x 10~6.





d)	The noncanccr HQ was calculated using the following equation: HQ = cleanup goal ^ noncanccr-bascd RSL.

e)	RSL values arc for chlordanc (technical mixture).

f)	RSL values are for PCBs (high risk).

g) Using updated default IEUBK and ALM parameters at a target blood lead level of 5 ng/dL. EPA Region 1 uses a
site-specific screening level of 200 mg/kg for residential exposures and 100 mg/kg when additional sources of lead

are present.

- = cancer or noncanccr-bascd RSL not established; risk or HQ not calculated.





Bold result indicates an cxcccdancc of EPA's 10~4 risk threshold or HQ >1.





M-l

-------
Table M-2: 1987,1994 and 2005 Source Area Property Soil/Sludge Lead Data

1987,1994 and 2005 Source Area Property Soil/Sludge* Lead Data

ID

Depth (ft)

Lead (mg/kg)

ID

Depth (ft)

Lead (mg/kg)

ID

Depth (ft)

Lead (mg/kg)

W.R Grace Property

Qjympia Property

Wildwood Property

S8-9

0-2

37.11

OL-SSOl

Surface

39

OL-SS06

Surface

27

ECS-8

1-3

5.66

OL-SS02

Surface

41

OL-SS07

Surface

8.6

ECS-10

1-3

28.9

OL-SS03

Surface

19

SB1

0-2

683

ECS-10A

1-3

12.3

OL-SS04

Surface

36

SB3

0-2

24.3

SSI

0.5-1

56.5

OL-SS05

Surface

21

SB4

0-2

100

SS-2

0.5-1

460

SB1

0-2

16.97

SB5

0-2

51



Average

100.1

SB2

0-2

42

SB6

0-2

9.59

SB 7

2-4

5.2

SB3

0-2

2.5

SB7

0-2

25.4

ECS-1

10-12

1.48 U

S04

0-2

14.39

SB8

0-2

13.5

ECS-2

5-7

1.63 U

SB5

0-2

18

SB9

0-2

94.58

ECS-3

5-7

1.44 U

SB 6

0-2

21

SB10

0-2

80.4

ECS-4

20-22

1.45 U

SB7

0-2

424

SB11

0-2

4.2

ECS-S

10-12

1.6 U

SBB

0-2

3.4

SB 12

0-2

27.9

ECS-6

8-10

6.95

SB9

0-2

35

SB13

0-2

20

ECS-7

5-7

1.5 U

SB10

0-2

40

SB 14

0-2

13.2

ECS9

10-12

1.55 U



Average

51.6

SB 15

0-2

47.5

ECS-11

5-7

1.56 U

SB1

2-4

0.25 U



Average

76.9

ECS-12

5-7

1.58

SB2

2-4

2.9

SB1

2-4

5.5

ECS-13

5-7

27.9

SB2

4-6

4.6

SB2

2-4

1.2



Average

39.7

SB3

2-4

1.5

SB3

2-4

2.2

NEP Property



SB4

2-4

21

SB4

2-4

23.7

NE-SS-01

Surface

44

SB4

4-6

2.5

SB5

2-4

11.5

NE-SS-02

Surface

192

S85

2-4

3.1

SB6

2-4

0.25

NE-SS-03

Surface

48

SB6

2-6

44

SB7

2-4

1.9

NE-SS-04

Surface

289

SB6

6-8

4.3

SB8

2-4

3.1

NE-SS-05

Surface

236

SB7

2-6

3.9

SB9

2-4

126

NE-SB2-01

Surface

4.6

SB9

2-4

5.7

SB10

2-4

2.6

NE-SB3-01

Surface

8.7

OLl-Ol

Subsurface

122

SB12

2-4

1.7



Average

117.5

OL2-01

Subsurface

44

SB13

2-4

2.7

ME1-01

Subsurface

4.6

OL2-02

Subsurface

9.8

SB14

2-4

1.5

NE1-02

Subsurface

5.2

OL2-03

Subsurface

8.5

SB 15

2-4

2.9

NE2-01

Subsurface

15

OL3-01

Subsurface

40



Average

13.3

NE2-02

Subsurface

17

OL3-02

Subsurface

13

SL-1

Sludge

19

NE2-03

Subsurface

17

OL3-03

Subsurface

14

SL-2

Sludge

9.1

NE3-01

Subsurface

14

OL4-01

Subsurface

18

SL-3

Sludge

124.8

NE3-02

Subsurface

17

OL5-Q1

Subsurface

26

SL-4

Sludge

72.7

NE-SB1-01

Subsurface

3.2



Average

19.5

SL-5

Sludge

14.2

NE-SB3-02

Subsurface

4.7

UniFirst





SL-6/7

Sludge

8.7

NE-SB4-01

Subsurface

2.3

No Data Collected



SL-8

Sludge

51

NE-SB4-02

Subsurface

4.9







SL-10/11

Sludge

10.2

NE-SB5-01

Subsurface

9.8







SL-12

Sludge

228.5



Average

9.6







SL-13

Sludge

66.6













SL-14

Sludge

58.1













SL-15

Sludge

24.2













SL-17/18

Sludge

41.9

Notes:











SL-19

Sludge

29.5

mg/kg = milligrams per kilogram.







SL-20

Sludge

41

ft = feet













Average

53.3

L) - Not detected above listed reporting limit
Full reporting limit used Irs average calculation

Above 200 mg/kg residential screening level
Italicized sample were analyzed in 2005; none italicized samples were collected in 1987. Sludge samples were collected In 1994.
" Sludge data nrwentec are confirmation sample re^iilR collected after ^Icjfto^ removal activities vjcio comnlftrd.	

Source: 2019 FYR Report.

M-2

-------
APPENDIX N - ARARS REVIEW

Table N-l: ARAR Review of ROD Cleanup Levels

Groundwater COC

1989 ROD
Cleanup Level"-b
(uu/L)

Current MCLC
(fig/L)

Chloroform

100d

80d

1,1 -Dichloroethane

5e

5e

1.2-Dichlorocthanc

5

5

1,1 -Dichlorocthcnc

7

7

PCE

5f

5

TCE

5

5

trans- 1.2-Dichloroethene

70s

100

1.1.1 -Trichlorocthanc

200

200

Vinvl chloride

2

2

Notes:





a) Cleanup levels arc from Table 7 of the 1989 ROD.



b) Cleanup levels arc MCLs unless otherwise noted.



c) Current Safe Drinking Water Act MCLs/maximum contaminant level goals (MCLGs)

from www.eoa.eov/groiind-water-and-drinking-water/national-Drimarv-drinking-water-

regulations (accessed September 18. 2023).
d) MCL is for total trihalomethanes; chloroform also has an MCLG of 70 ng/L.

e) MCL is for 1.2-dichlorocthanc. This value is used based on the chemical similarities

between the two compounds and their toxicological endpoints.

f) MCL is for TCE. This value is used based on the chemical similarities between the two

compounds and their toxicological endpoints. This value is also the detection limit,
g) Proposed MCLG.

Hg/L = micrograms per liter

N-l

-------
APPENDIX O - VISL SCREENING

Table 0-1: Comparison of Maximum Detected Groundwater VOC Concentrations in Shallow Wells to VISLs



Maximum Groundwater

Maximum Groundwater

Maximum Groundwater

Vapor Intrusion Screening

Detected Analvte

Concentration (Jig/L)

Concentration (fig/L)

Concentration in Shallow Wells

Level1'



20! 2/2(113='

2017/2018='

(fig/L) 2022/2023"

(fig/L)

UniFirst Data Compared to

Commercial Screening Levels*1







1,1,1-TCA

1.3

6.8

1.3 (UC33)

31,100

cis-l,2-DCE

16

ND (0.5)

1.9 (UC6)

1,050

PCE

2,900

110

88 (IJC25)'

65

TCE

18

ND (0.5)

14 (UC6)

7.4



NEP Data Compared to Commercial Screening Levels

PCE

15

6.8

8.5 (NEP-101)f

65



Downgradient of/near UniFirst and Grace Properties Data Compared to Residential Screening Levels

PCE

22

22

28 (UG17 near UniFirst)8

15

TCE

0.82

0.84

0.84 (G38S near Grace)

1.2











Grace Data Compared to Commercial Screening Levels'1

Chloroform

ND (3.0)

1.9

ND (0.75)

3.6

cis-l,2-DCE

150

180

1.7 (G38S)

1,050

trans-1,2-DCE

0.83

2.2

3.3 (G16S)

457

PCE

15

19

ND (0.5)

65

TCE

68

91

100 (G16S)

7.4

Notes:









a) The 2012/2013 and 2017/2018 data are from the 2019 FYR Report.





b) The higher of the 2022 or 2023 values are presented. Data are from the 2023 Annual Monitoring Report - W.R. Grace OU-1 Source Area, dated December 2023, RD/RA Year 31
Annual Report for the UniFirst Site, dated November 2023 (Appendix C) and 2023 Groundwater Monitoring Report (NEP), dated September 2023 (Table 3). Data from shallow
wells screened in the unconsolidated deposits (as represented on site potentiometric contour maps) were included in the evaluation. If both wells in a well pair are screened in the
unconsolidated deposits (e.g., UniFirst wells UC26D and UC26S), the shallower well is selected for the evaluation.

c) Groundwater vapor intrusion screening levels are from the VISL calculator, based on a target cancer risk of 1 x 10"6 or target HO of 1 from epa-visl.ornl. gov/cei-bin/visl search

(accessed 12/18/2023).

d)	The operation of the SVET system at UniFirst is protecting the existing commercial building from vapor impacts.

e)	The 2023 concentration at off-property well S81M was 120 (ig/L; however, this well is next to a wetland and more than 100 feet from a building and not expected to be a vapor

intrusion concern.









f) The NEP concentration is from 2023 since this is the most recent data available. The prior concentration (in 2021) was 6.5 (ig/L.



g) The maximum PCE concentration in 2023 at 28 (ig/L is lower than the concentration observed in 2011 (46 (ig/L at UG17) during the initial vapor intrusion assessment.

h) Vapor mitigation measures are in place at the buildings on the Grace property and prevent vapor intrusion to indoor air.
ND = not detected at limit indicated in parentheses.

Bold result = screening level exceedance



0-1

-------
APPENDIX P - LEAD SCREENING LEVEL CHECKLIST

Residential Lead Screening Level Checklist

Site Information

Site or study area name

WELLS G&H

Location (City/County, State, Zip)

WOBURN, MA

SEMS EPA ID

MAD980732168

Current remedial pipeline phase

PRP RA; POST CONSTRUCTION

Does a site boundary exist in SEMS?

M Yes ~ No

Briefly describe any removal or
remedial work completed to date,
including previous screening levels

Lead only identified as COC at Wildwood Property, which is not residential. Lead concentrations at other properties are below
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, MA Superfund Section

3/4/2024

Table 1: Evaluate Primary Data Sources in "Residential Lead GIS Screening Tool" [**Ctrl+Click here to access GIS tool**l

Yes

No

7

Question

Data Evaluation Notes

References

~

El

~

Is the study area in a NAAQS
nonattainment zone for lead?

SCREENSHOT ATTACHED

EPA Green Book provides detailed information
about NAAQS designations

~

HI

~

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 housing data tools
American Community Survey data

Ki

~

~

Are you able to you select a screening
level based on these primary data
sources?

23 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.

Version 1 - February 2024	1

P-l

-------
Table 2: Evaluate Secondary Data Sources on Potential Lead Exposures

Yes

No

¦?

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 aualitv 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 poisoning prevention data

and statistics

Version 1 - February 2024	2

P-2

-------
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 2019 Five Year Review: Lead was only identified as a soil contaminant of concern (COC) at the Wildwood Property due to the presence of sludge. Although the
lead cleanup level identified in the ROD (640 mg/kg) exceeds the current lead soil SLfor residential land use of 200 mg/kg, the Wildwood Property is currently
undeveloped and undergoing remedial actions. In addition, based on sampling conducted in 1987 for soil and 1994 post-excavation sampling following sludge removal
activities (Table 5 in Appendix B), the average lead concentrations of surface and subsurface soils at this property are less than the residential soil SL. In 1987, surface
and subsurface soil lead data were collected from the Grace, NEP, and Olympia Properties. In addition, 16 surface and subsurface soil samples were collected and
analyzed for lead at the Grace Property in 2005. These soil lead data are presented in Appendix B, Table 5. Because the average lead surface soil and subsurface soil
concentrations at each of the properties are less than 200 mg/kg, no further remedial work is necessary for lead.

Recommended Regional Screening Level

Select the appropriate screening level and summarize the weight of evidence assembled above.

200 ppm

~ 100 ppm

qancIARULO Digita"ysignedbyR0BERTCIANCIARUL0

Date: 2024.03.04 11:03:26-05'00'

Approved By [Type Name, Title]	Date

Version 1 - February 2024

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Residential

PeoplePJus

https://ppv.epa.gOv/psp/ots92prd/EMPL0YEE/HRMS/h/sjgnin.htnri7

— Legend

A



NPL Superfund Site Boundaries (EPA Public)

Nonattainment Areas and Designations -
Lead (2003 standard)

Lead Paint Indicator (EJScreen 2.2
September 2023)

Lead Paint
^ at least 95%ile
| 90-94%ile
S0-89%ile

Version 1 - February 2024

Superfund Site Boundaries: WELLS G&H

EPA Region 1

EPA Program Superfund Remedial

Fnd address or place

Feature Class
Feature Type

Site 3our>dary
Comprehensive Site Area

Feature Nane Approximate WeUs G&H Site
Boundary

EPA ID	MAD980732168

Site Name WELLS G&H

Feature	The 330-acre Weiis G&H site s

Description located in Woourr .

Massachusetts. The site consisi
of two municipal weISs, known
wells G & Hf which were
deveioped n 1964 ano 1967 t
supplement Wcburn's water

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