FIFTH FIVE-YEAR REVIEW REPORT FOR
WELLS G&H SUPERFUND SITE
WOBURN, MIDDLESEX COUNTY, MASSACHUSETTS
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TABLE OF CONTENTS
LIST 01 ABBREVIATIONS & ACRONYMS ii
I. INTRODUCTION 1
Site Background 1
FIVE-YEAR REVIEW SUMMARY FORM 2
II. RESPONSE ACTION SUMMARY 2
Basis for Taking Action 2
Response Actions 3
Status of Implementation 4
Systems Operations/Operation & Maintenance 6
III. PROGRESS SINCE THE LAST REVIEW 8
IV. FIVE-YEAR REVIEW PROCESS 14
Community Notification, Involvement & Site Interviews 14
Data Review 17
Site Inspections 23
V. TECHNICAL ASSESSMENT 24
QUESTION A: Is the remedy functioning as intended by the decision documents? 24
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial
action objectives (RAOs) used at the time of the remedy selection still valid? 27
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 32
VI. ISSUES/RECOMMENDATIONS 32
Other Findings 33
VII. PROTECTIVNESS STATEMENT 34
VIII. NEXT REVIEW 34
TABLES
Table 1: Protectiveness Determinations/Statements from the 2014 FYR 9
Table 2: Status of Recommendations from the 2014 FYR 10
Table 3: Summary of Interviewees, Affiliations and Interview Dates 15
APPENDICES
Appendix A - Reference List
Appendix B - Figures and Additional Data Tables
Appendix C - ARARs Tables
Appendix D - Site Inspection Information
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LIST OF ABBREVIATIONS & ACRONYMS
AOC Administrative Order on Consent
ARAR Applicable or Relevant and Appropriate Requirement
AS Air-Sparging
As Arsenic
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
cPAH Carcinogenic Polycyclic Aromatic Hydrocarbon
EPA United States Environmental Protection Agency
FDDA Former Drum Disposal Area
ESD Explanation of Significant Differences
FS Feasibility Study
FYR Five -Year Review
GAC Granular Activated Carbon
GWETS Groundwater Extraction and Treatment System
HA Health Advisory
ICs Institutional Controls
ISCO In-Situ Chemical Oxidation
MassDEP Massachusetts Department of Environmental Protection
MCL Maximum Contaminant Level
mg/kg milligram per kilogram
Mn Manganese
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEP New England Plastics
NPL National Priorities List
O&M Operation and Maintenance
OU Operable Unit
PFAS Per- and Polyfluoroalkyl Substance
PFBS Perfluorobutane Sulfonate
PFOA Perfluorooctanoic Acid
PFOS Perfluorooctane Sulfonate
PCB Polychlorinated Biphenyl
PCE Tetrachloroethene
PRP Potentially Responsible Party
RAO Remedial Action Objective
RI Remedial Investigation
ROD Record of Decision
RPM Remedial Project Manager
SD Settling Defendant
SVE Soil Vapor Extraction
SVET Soil Vapor Extraction and Treatment
TBC To be considered
TCE Trichloroethene
UU/UE Unlimited Use/Unrestricted Exposure
(ig/L microgram per Liter
VI Vapor Intrusion
VISL Vapor Intrusion Screening Level
VOC Volatile Organic Compound
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy in order 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 CFR Section
300.430(f)(4)(ii)), and considering EPA policy.
This is the fifth FYR for the Wells G&H Superfund Site. The triggering action for this statutory review is
the completion date of the previous FYR in September 2014 (EPA, 2014a). 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 (OUs); one OU (OU1) will be addressed in this FYR report.
OU1 addresses the five Source Area Properties. The two OUs that are not addressed in this FYR are OU2
(the Central Area), which does not yet have a Record of Decision (ROD) for remedial action, and OU4
(the Southwest Properties; SWP)1. A ROD was signed in September 2017 for OU4 (EPA, 2017);
negotiations are on-going with the Responsible Parties. Because remedy implementation has not yet
begun for OU4, it is not addressed in this FYR. OU3 (the Abeijona River Study) was merged with OU2
of the Industri-Plex Superfund Site in 2002. Further evaluation of OU3, including FYRs, are conducted as
part of the Industri-Plex Superfund Site reviews.
The Wells G&H Superfund Site FYR was led by Joseph P. LeMay, P.E., Remedial Project Manager
(RPM) for EPA Region 1. Other participants from EPA Region 1 included EPA staff in the roles of
hydrologist, risk assessor, attorney, etc. Jennifer McWeeney (Environmental Analyst III) with the
Massachusetts Department of Environmental Protection (MassDEP) also participated in this review. The
Settling Defendants (SDs) were notified of the initiation of the FYR. The review began on 12/26/2018.
Site Background
The Wells G&H Superfund Site (the "Site") is approximately 330-acres in size and includes the aquifer
and land located within the zone of contribution of two former municipal drinking water wells known as
Wells G and H, located adjacent to the Abeijona River (see Figure 1). OU 1 consists of the W.R. Grace
Property (Grace Property), UniFirst Property, New England Plastics Property (NEP Property), Wildwood
Property, and Olympia Nominee Trust Property (Olympia Property) (see Figure 2). 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. The Abeijona River with its associated
wetlands runs through the central portion of the Site.
On May 4, 1979, 184 5 5-gallon drums containing polyurethane and toluene di-isocyanate were found on a
vacant lot located on Mishawum Road, Woburn. This incident prompted the Massachusetts Department
of Quality Engineering (DEQE), now known as MassDEP, to sample the nearest downgradient water
supply (i.e., Wells G and H). Several chlorinated volatile organic compounds (VOCs) were detected,
including tetrachloroethene (PCE) and trichloroethene (TCE), prompting the City of Woburn to shut
1 The SWP were initially part of OU2, but were separated from OU2 and designated OU4 in 2017.
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down the wells on May 21,1979. Subsequent hydrogeologic investigations and groundwater quality
evaluations identified the general source areas for the chlorinated VOCs to be within a one square-mile
area surrounding the wells. A more thorough discussion of the Site and its history can be found in the
2014 FYR Report (EPA, 2014a).
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Wells G&H Superfund Site
EPA ID: MAD980732168
Region: 1
State: MA
City/County: Woburn/Middlesex County
NPL Status: Final
Multiple OUs?
Yes
Has the site achieved construction completion?
No
Lead agency: EPA
Author name (Federal or State Project Manager): Joseph F. LeMay, P.E.
Author affiliation: EPA Region 1
Review period: 12/26/2018 - 6/30/2019
Date of site inspection: 2/18&19/2019
Type of review: Statutory
Review number: 5
Triggering action date: 9/30/2014
Due date (fiveyears after triggering action date): 9/30/2019
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
The Supplemental Remedial Investigation (RI), completed by EPA in 1988, identified contaminated soil,
sludge, and/or groundwater at five properties within approximately one mile of former municipal Wells G
and H (Grace, UniFirst, NEP, Wildwood, and Olympia Properties) as the sources of contamination at the
Site. Contamination at the Olympia Property is confined to the Former Drum Disposal Area (FDDA)
(Figure 2). Primary contaminants included VOCs, lead, pesticides, polychlorinated biphenyls (PCBs), and
carcinogenic poly cyclic aromatic hydrocarbons (cPAHs).
Based on the results of sampling conducted as part of the RI, ingestion of groundwater and direct contact
with soil/sludge represented the most-significant risks to human health. Chlorinated VOCs were detected
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in groundwater at concentrations above levels considered to be protective. Concentrations of pesticides,
PCBs, lead, and cPAHs in soil/sludge were present at levels that would endanger public health, if ingested
or dermally contacted in a future residential setting.
Response Actions
Analytical data collected by DEQE from former municipal Wells G and H in May 1979 indicated total
concentrations of chlorinated VOCs ranging up to 400 micrograms per liter ((.ig/L). The municipal wells
were shut down later that same month. The Site was listed on the National Priority List (NPL) in
December 1982.
In May 1983, three administrative orders pursuant to Section 3013 of the Resource Conservation and
Recovery Act (RCRA) were issued to W.R. Grace and Co., Inc. Cryovac Division, UniFirst Corporation,
and Beatrice Foods, Inc. (Beatrice). These orders required sampling, analysis, monitoring, and reporting
that would address the problem of possible groundwater contamination on or emanating from their
properties.
The Feasibility Study (FS) was completed in January 1989 (Ebasco, 1989), and in September 1989, EPA
issued a ROD for OU1 of the Site. The Remedial Action Objectives (RAOs) identified in the OU1 ROD
were:
Groundwater
• Prevent the further introduction of contaminated groundwater from the Source Areas to the
Central Area;
• Limit the further migration of contaminated groundwater off-site from the Source Areas;
• Restore the bedrock and overburden aquifers in the vicinity of the Source Areas to drinking water
quality; and
• Prevent public contact with contaminated groundwater above the cleanup levels.
Soil
• Prevent public contact with contaminated soil above cleanup levels;
• Stop the leaching of soil contaminants to groundwater; and
• Protect natural resources at the Site from further degradation.
The approach was to first address contamination at the Source Areas (OU1) to reduce infiltration from
source soil/sludge and prevent migration of contamination toward the Central Area aquifer (OU2).
The selected remedy for OU1 included the following:
• Treatment of contaminated soil using in-situ volatilization at Wildwood Property; excavation and
on-site incineration of contaminated soils at Wildwood, Olympia, NEP, and UniFirst Properties;
• Treatment and/or disposal of sludge and debris found at the Wildwood Property in a manner to be
determined during the design phase of the cleanup; and
• Extraction and treatment of contaminated groundwater (bedrock and/or overburden) separately at
the five Source Area Properties using pre-treatment for metals and an air stripper to remove
VOCs, or an equally or more effective technology approved by EPA.
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EPA's April 1991 Explanation of Significant Differences (ESD) described three significant changes and
one non-significant change from the remedial action to be undertaken at OU1 as set forth in the ROD.
Those changes were as follows:
• On-site incineration of soils at Wildwood, NEP, and Olympia Properties was changed to off-site
incineration;
• In-situ volatilization would be used on the UniFirst Property, rather than incineration;
• Groundwater extraction systems could be combined for UniFirst and Grace Properties; and
• A typographical error was corrected resulting in more stringent target cleanup levels for
groundwater.
Tables la through lc included in Appendix B present the ROD cleanup levels for leaching of soil
contaminants to groundwater, for direct contact with soil, and for groundwater used as drinking water,
respectively.
A Consent Decree (CD) was signed by EPA and four of the five SDs in 1991 (Olympia did not sign the
CD). The four SDs then began work on their respective areas of the Site. As required by the CD, a group
of Potentially Responsible Parties (PRPs) agreed to conduct the RI/FS for OU2, which at the time
included the SWP (now OU4). In March 2003, the Olympia SDs entered into an Administrative Order on
Consent (AOC) with EPA to conduct removal of contaminated surface soil and PCB material from the
FDDA. The Olympia SDs entered into a second AOC in 2004 for the removal of TCE-impacted soils
within the FDDA.
Status of Implementation
With the exception of the lack of groundwater pump and treat systems at the Olympia and NEP
Properties, all components of the OU1 remedy response actions have been implemented. Minor
modifications have been made, where necessary, to optimize the remedial systems as a result of ongoing
performance monitoring. The 2014 FYR contains a thorough discussion of implementation activities
conducted at the Site. This section briefly describes historic remedy implementation activities for each of
the Source Area Properties, but focuses primarily on recent activities occurring at the Site.
Grace Property
In September 1992, Grace began operation of its long-term groundwater cleanup system. In 2002, Grace
replaced their existing system with granular activated carbon (GAC) filtration units to address decreased
contaminant concentrations. Groundwater sampling continues to be performed at the Grace Property to
assess the progress of the remedial actions in achieving cleanup levels.
In 2006, demolition work was performed at the Grace Property in anticipation of potential redevelopment.
In 2010, additional work was performed at the Grace Property to enhance groundwater treatment system
performance and capture. Additional soil investigation work was performed in 2011, resulting in the
excavation of approximately 900 tons of soil exceeding cleanup levels in 2012. To address concerns
related to capture and off-property migration, Grace completed additional monitoring well installation and
sampling in 2013 and 2014. Between 2014 and the present, the Grace Property has undergone
redevelopment into the Woburn Landing commercial space that consists of several restaurants, a hotel,
and associated infrastructure, parking and landscaping. Construction has occurred in consultation with
EPA, including a 2014 "Comfort Letter" providing recommendations for redevelopment consistent with
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the ongoing remedy, 2015 "Final Soil and Groundwater Management Plan", and has included
environmental oversight and monitoring throughout various phases of construction. To date, the
redevelopment has resulted in the excavation and off-site disposal of approximately 2,100 cubic yards of
soil while maintaining an active recovery well system, groundwater treatment system, and monitoring
well network. In addition, vapor mitigation systems have been installed in association with the various
occupied structures. Performance of the vapor mitigation systems has been/will be tested and the systems
will be subject to ongoing monitoring and optimization.
During the first nine months of this FYR period. Grace operated 16 recovery wells (RW-7 through RW-
22RE) in Areas 2, 3, and 4. Recovery well locations are shown on Figure 3. On January 5, 2015, Grace
submitted a plan to shut down the six recovery wells in Area 2 (i.e., RW-7 through RW-12 along the
western property boundary) and seven of the nine recovery wells (i.e., RW-13 through RW-16, RW-18,
RW-19, and RW-21) located in Area 3 along the southern property boundary (TetraTech, 2015a). On
May 6, 2015, EPA conditionally approved the 3-year Shutdown Plan which included water level and
water quality monitoring to assess potential rebound in contaminant concentrations above cleanup levels,
to confirm that operation of the three remaining recovery wells (i.e., RW17, RW20 and RW22RE)
provided adequate capture, and confirm that VOC concentrations above cleanup levels did not migrate
off-property. The Shutdown Plan, which was completed in May 2018, demonstrated that significant
rebound did not occur and that RW17, RW20 and RW22RE were effective in preventing off-property
migration of VOCs associated with the historical release(s) on the Grace Property.
UniFirst Property
UniFirst began operation of its long-term groundwater cleanup system in September 1992. In 2003,
UniFirst replaced their existing system with GAC filtration units to address decreased contaminant
concentrations. Groundwater sampling continues to be performed at the UniFirst Property to assess the
progress of the remedial actions in achieving cleanup levels.
Based on the conclusions of EPA's vapor intrusion (VI) risk assessment report (EPA, 2012a) conducted
for OU1, monitoring of the VI pathway at the commercial building west/downgradient of the UniFirst
Property continues to be performed on an annual basis. In addition, to achieve ROD soil cleanup levels
and to address VI concerns at the UniFirst Property identified in the 2012 VI risk assessment, UniFirst
installed a Soil Vapor Extraction and Treatment (SVET) System which began operating on November 11,
2014. In addition, to address EPA concerns regarding groundwater capture, UniFirst installed a new
overburden extraction well (EX-1), three piezometer clusters, and performed hydraulic testing in 2014.
The overburden extraction well was connected to the UniFirst treatment system and began extracting
groundwater in May 2016 (UniFirst, 2017).
Wildwood Property
By September 1992, source control activities began at the Wildwood Property. The remediation of sludge,
debris, and mixed-contaminated soil was complete in 1994, and the soil and groundwater remediation
system startup occurred in 1998. In 2000, Wildwood replaced their existing system with GAC filtration
units to address decreased contaminant concentrations. Groundwater sampling continues to be performed
at the Wildwood Property to assess the progress of the remedial actions in achieving cleanup levels.
The Wildwood air sparging (AS) system was expanded in 2014 and additional monitoring wells on its
eastern and southern boundaries were installed to further assess groundwater capture concerns. Between
December 2015 and February 2017, a subsurface investigation was undertaken at the property which
included the advancement of direct push points with vertical profiling of VOCs, analysis of chlorinated
VOCs in groundwater grab samples from 30 locations, and the installation and sampling of 19 overburden
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monitoring wells for VOCs (AECOM, 2016a, 2016b, and 2017a). The purpose of this investigation was
to generate data to assess the effectiveness of the AS/SVE remedy and identify areas that require further
treatment to achieve ROD cleanup levels in overburden. EPA is working with Wildwood to optimize the
performance of the AS/SVE system and groundwater pump and treat system as well as to pilot test
remedial enhancements to the existing groundwater remedy.
NEP Property
In 1998, the NEP source control remedy (AS/SVE) was initiated. The NEP soil remediation system was
discontinued in 2000 after reaching soil cleanup levels in unsaturated soils. Groundwater sampling
continues to be performed at the NEP Property to assess the progress of the remedial actions in achieving
cleanup levels.
Olympia Property
Following the removal of contaminated soil from the FDDA at the Olympia Property in 2003, treatment
of TCE in soil and groundwater by In-Situ Chemical Oxidation (ISCO) via injection of sodium
permanganate was initiated in 2005. Groundwater monitoring at the FDDA commenced following the
initiation of TCE treatment. Routine injection of permanganate solution is performed via trenches,
injection wells and/or direct-push equipment guided by monitoring data collected to assess the progress of
ISCO in reducing TCE and other chlorinated VOCs.
Systems Operations/Operation & Maintenance
Descriptions of Operation & Maintenance (O&M) activities conducted since the last FYR are provided
below for UniFirst, Grace, Wildwood and Olympia Properties. NEP has provided the results of on-going
groundwater monitoring activities and a deep bedrock investigation; however, no O&M activities have
occurred at the NEP Property since the shutdown of their AS/SVE system in 2000.
Grace Property
Extracted groundwater is treated using a particulate filter and two 1000-pound GAC units. Treated water
is discharged to Snyder Creek located along the eastern boundary of the property (Figure 3). Influent and
effluent concentrations are monitored to assess the need for GAC change-out and to verify compliance
with discharge criteria. System O&M activities involving the groundwater extraction and treatment
system (GWETS) are performed by Groundwater & Environmental Services (GES) of Westford,
Massachusetts. In 2018, Grace transferred groundwater sampling responsibilities from TetraTech to GES.
During the past five years, the system has operated with limited downtime. Downtime was generally a
result of power outages, carbon change-outs, system alarms conditions, compressor repairs or
maintenance activities. On August 4, 2016, the outer containment pipe for recovery well RW-22RE was
damaged during site redevelopment. As a result, RW-22RE was shut down for 4 days while being
repaired. Maintenance activities are summarized in Monthly Progress Reports prepared by W.R. Grace's
contractor, de maximis, inc., during the period of October 2014 to January 2019 and Annual Reports
submitted since the last FYR (Tetra Tech and JG Environmental, Inc., 2015, 2016, and 2017; GES and JG
Environmental, Inc., 2018).
UniFirst Property
Soil vapor is extracted by the SVET system using an 8.5 horsepower blower from six SVE wells (SVE-
2A, -3 A, and -4A within the building footprint and SVE-1, -5, and -6 outside the building footprint)
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installed in areas where VOCs in soil were elevated above cleanup levels (Figure 4). Four 55-gallon GAC
drums provide treatment of extracted VOCs prior to emission. The SVET system is equipped with an
air/water knockout tank, particulate filter, and programmable logic control (PLC).
O&M activities for the SVET system involves routine system monitoring of vacuum at SVE wells and
monitoring points (refer to Figure 4), pressure, temperature and soil vapor flow rate measurements, and
monthly VOC screening readings using a PID (The Johnson Company, 2015). Sampling of treatment
system influent and discharge following the third and the fourth GAC drums prior to emission takes place
bimonthly with samples analyzed for target VOCs. Water levels are monitored on a monthly basis in
select SVE wells and soil vapor monitoring locations. Routine maintenance conducted during the past
five years included change outs of spent GAC units, replacing the particulate filter, and replacing a
particulate filter element and site tube on the air/water knock-out tank. No modifications have been made
to the SVET system during this FYR period.
During the past five years, the SVET system has reportedly operated greater than 98-percent of the time
(UniFirst, 2015, 2016, 2017 and 2018). The treatment system has removed 94-percent or more of VOCs
present in the influent during this FYR period.
Groundwater is extracted by UC22 and EX1, shown on Figure 5, and is treated by the GWETS using a
filter to remove particulates and three 1,000-pound GAC units to remove VOCs. Treated groundwater is
discharged to an on-site sewer. Bimonthly samples are taken from the treatment system influent and
monthly samples are taken from the treatment system effluent. Routine O&M includes weekly system
inspections, quarterly sensor checks, annual inspection of the entire treatment system including tanks,
valves, piping, filters, and maintenance (UniFirst, 2018).
During this FYR period, the GWETS has operated with limited downtime as the system was reportedly
online between 98 and 99-percent of the time (UniFirst, 2015, 2016, 2017 and 2018). System downtime
was a result of power outages, flow meter replacement and maintenance port installation in EX-1,
transducer malfunction in UC-22, or reseating a hose on a GAC unit. These activities are described in the
Annual Reports (UniFirst, 2015, 2016, 2017 and 2018). Monthly O&M activities are described in
monthly operations/progress reports (UniFirst, 2014a, 2015a, 2016a, 2017a,2018a, and 2019a).
The following system modifications were reported during the FYR period: (1) replacement of the original
Campbell Data Logger with a new PLC-based system that utilizes new transducers for water level
sensing; (2) addition of recovery well EX1 to the existing PLC-based system in May 2016, and; (3)
programming upgrades made in 2017 and 2018.
Wildwood Property
The Wildwood Property AS/SVE and bedrock GWETS continued to operate during this FYR period with
minimal downtime. Causes of system downtime include, but are not necessarily limited to the following
conditions: power outages, non-routine maintenance activities, activation of shutoff switches for the
treatment, and weather-related issues (e.g., frozen discharge lines). Routine and non-routine maintenance
activities were performed throughout the FYR period and are documented in monthly progress reports
submitted to EPA during this FYR period (AECOM, 2016c, 2017b, 2018a and 2019).
Monthly process monitoring activities include pressure readings and influent/effluent sampling of the
GWETS, flow and pressure readings of the AS system, and vacuum and flow readings, influent and
effluent air sampling, and ambient air PID readings for the SVE system.
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In August 17, 2018, EPA granted approval to suspend vapor-phase GAC treatment for the SVE system
and the exhaust from the air stripping unit for the groundwater treatment system. EPA's approval was
based upon modeling which indicated that concentrations currently present in the SVE system and
exhaust from the air stripper (without vapor phase treatment) would not result in exceedances of
MassDEP Health Benchmarks for air. Any future modifications to the AS/SVE system and/or the
GWETS that could increase VOC concentrations above concentrations used in the model would require
GAC treatment to be reinstated.
In November 2017, the SD proposed modifications to the groundwater sampling program including
reducing the sampling frequency from quarterly to annually, with a subset of 13 wells to be sampled
semi-annually, and changing the set of monitoring wells (total of 41 wells)2 to be sampled (AECOM,
2017c). In an April 23, 2018 email, EPA requested 26 additional wells be sampled semi-annually and/or
annually. Included in the sampling program to provide data to assist with remedial optimization decisions.
This modified sampling program was initiated in April 2018. Pending review of these data, EPA will
work with the SD to refine the long-term monitoring program for the Wildwood Property. In addition to
these 63 wells, samples have been collected from 17 other well locations during various monitoring
events over the last five years. Exhibit 1, included in Appendix B. summarizes wells sampled during this
FYR period.
Olympia Property
The PRP for Olympia Property is treating TCE-contaminated soil using ISCO via subsurface
permanganate delivery3 inside an approximately 180 feet long by 100 feet wide sheet pile enclosure in the
FDDA. Since Fall 2008, the monitoring and delivery approach for the FDDA includes approximately 3-
month cycles where permanganate delivery generally occurs from October-December and April-June,
while monitoring/evaluation occurs from January-March and July-September. Occasionally, injections are
performed at other times based on a review of monitoring data. Groundwater monitoring data is used to
guide where remedial injections occur. This approach is consistent with the revised work plan dated
October 2004. During the current FYR period, focused injections of sodium permanganate were
performed in November 2014, July 2015, November 2015, July 2016, December 2016, April 2017,
August 2017, November 2017, and November 2018 to address rebound and lingering concentrations of
VOCs exceeding ROD cleanup levels.
The effectiveness of the cleanup within the FDDA is evaluated by monitoring groundwater for the
distribution of oxidant and reduction of VOC concentrations after injection. Groundwater samples are
collected from monitoring wells and by direct, depth-discrete groundwater sampling using a Geoprobe®.
The sampling program includes groundwater samples collected from various locations and depths
(depending upon where sodium permanganate is injected) that are representative of the different
stratigraphic units within the FDDA. Vertical contaminant profiling using a Membrane Interface Probe
(MIP) was also performed in June 2018 at five locations located within and adjacent to the treatment cell
as shown on Figure 8. According to Geolnsight, the data were used to focus permanganate injections
during November 2018 (Geolnsight, 2019).
III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
2 Four new wells were proposed but have not yet been installed.
3 Depending upon the event and target delivery depth, permanganate delivery to the subsurface occur via injection
wells, direct-push injection and/or gravity infiltration through trenches on the land surface (subsurface delivery).
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Table 1: Protectiveness Determinations/Statements from the 2014 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
1
Short-term Protective
The remedy at the Source Area (OU1) Properties currently
protects human health and the environment because active
remedial actions, including groundwater pump and treatment
(Grace, UniFirst and Wildwood Properties), ISCO (Olympia
Property), AS/SVE source control (NEP property - shutdown
in 2000, and Wildwood Property) and SVE source control
(UniFirst Property) have been or continue to be implemented
in conjunction with routine O&M and monitoring. The current
assessment of the vapor intrusion pathway at both on-property
and downgradient of/near property locations also supports our
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 are recommended: continued
implementation of soil remedy (SVE) at UniFirst Property;
continued monitoring by both Grace and UniFirst Properties;
worker contact with groundwater and soil should be
performed under property-specific Health & Safety
Plan/controls until remedy is complete; groundwater capture
and treatment system assessment/enhancements at the
Wildwood Property; additional groundwater data collection
and assessment including deep bedrock conditions and, as
determined necessary, groundwater treatment at NEP
Property; assessment of soil and groundwater cleanup levels
from ISCO treatment at Olympia Property; assessment of
groundwater conditions relative to arsenic and manganese at
Grace, UniFirst, Wildwood and Olympia Properties;
evaluation of vapor intrusion pathway if Grace, Wildwood
and/or Olympia Properties are developed/redeveloped with
occupied buildings, and, where appropriate, implementation
of vapor intrusion mitigation measures during development.
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Table 2: Status of Recommendations from the 2014 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
1
Extraction systems
performance
(possible
insufficient capture
of groundwater
contamination) at
Wildwood
Property.
Additional data
collection and/or
analysis to determine
whether or not
sufficient capture has
been achieved at the
Wildwood Property,
and, where appropriate,
take corrective actions
to ensure sufficient
capture in the future.
Ongoing
Between 2015 and 2017, the SD
implemented investigations to identify
areas of impact not being effectively
targeted by the existing AS/SVE
System (AECOM, 2016b). In addition,
EPA assessed the distribution of VOCs
above cleanup levels not captured by
the existing groundwater recovery
system and clarified its position on the
path forward for the Wildwood
Property (EPA, 2018a). Work plans
were submitted by the SD in October
2018 to perform additional pre-design
investigations to expand the AS system
in the northern portion of the property
(AECOM, 2018b), to refine the extent
of soil impact in the southern portion of
the property (AECOM, 2018c), and to
perform surface geophysics to assist in
locating additional bedrock recovery
wells (AECOM, 2018d). Work Plans
are pending EPA approval.4
NA
1
No groundwater
pump and
treatment system
implemented at
NEP Property
following AS/SVE
shutdown.
Assess groundwater
conditions on NEP
Property since AS/SVE
shutdown and evaluate
the need for further
groundwater treatment.
Ongoing
Based upon the most recent monitoring
data (Woodard & Curran, 2017a &
2017b), PCE was detected above
cleanup levels in one overburden well
and four bedrock monitoring wells
(including 3 deep bedrock wells).
Additional sampling of other deep
bedrock wells on the property (e.g.,
NEP 1 and 2) will need to be conducted
to further assess contamination above
the cleanup levels, bedrock conditions,
and groundwater treatment in
accordance with the previously
approved 2016 NEP Work Plan.
Additional sampling will occur during
the upcoming OU-2 investigation.5
NA
4 This on-going recommendation has been incorporated in Section VI Issues/Recommendation (page 32) under issue
"Extraction systems performance (insufficient capture of groundwater contamination) at Wildwood Property.".
5 This on-going recommendation has been incorporated in Section VI Issues/Recommendation (page 32) under
issue, "No groundwater pump and treatment system implemented at NEP Property following AS/SVE shutdown.".
10
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Table 2: Status of Recommendations from the 2014 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
1
No recent data
regarding
groundwater
contaminant
concentrations in
deep bedrock at
NEP Property.
Additional data
collection to evaluate
deep bedrock
groundwater conditions
on the NEP Property,
and, where appropriate,
evaluate groundwater
treatment.
Completed
NEP implemented geophysical logging,
transmissivity testing, and sampling at
three deep bedrock wells (NEP A, NEP
B and NEP-3). Based upon results of
the testing (Woodward & Curran,
2017b), PCE and TCE were detected
above cleanup levels in discrete
fractures in deeper bedrock at all three
wells. Additional deeper bedrock data
collection will be conducted, as
described above (see second Issue in
Table 2).
4/20/2017
1
Area south of
treatment system at
Wildwood Property
may have
groundwater
contamination in
excess of ROD
cleanup goals not
receiving
treatment.
Assess groundwater
conditions south of
treatment system at
Wildwood, evaluate the
need for further
groundwater treatment,
and consider other
treatment
enhancements/optimizat
ions as appropriate.
Completed
EPA identified several monitoring
wells south of the treatment system
with concentrations of TCE above
cleanup levels based upon data
collected during the past five years
(EPA, 2018a). Because this issue is
related to insufficient capture, follow-
up work proposed in the SD's 2018
Work Plan under EPA review will help
address this issue, as described above
(see first Issue in Table 2).
7/14/2018
1
No groundwater
pump and
treatment remedy
implemented at
Olympia Property.
Evaluate progress of
Olympia's ISCO soil
clean up to achieve
ROD groundwater and
soil cleanup standards.
Assess need for
groundwater cleanup at
the conclusion of the
removal action.
Ongoing
Additional injections of sodium
permanganate are performed
periodically (most recently in
November 2018) to address lingering
elevated concentrations of chlorinated
VOCs and will continue until cleanup
goals for groundwater are attained.
EPA will continue to evaluate the
progress of ISCO in achieving ROD
groundwater and soil cleanup levels
based upon post-injection monitoring
data and will continue to work with the
SD to identify optimization approaches
to improve delivery and distribution of
oxidant and to more efficiently
achieved cleanup goals.6
NA
6 This on-going recommendation has been incorporated in Section VI Issues/Recommendation (page 33) under
issue, "No groundwater pump and treatment remedy implemented at Olympia Property."
11
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Table 2: Status of Recommendations from the 2014 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
1
The 1988
Endangerment
Assessment did not
comprehensively
evaluate non-
ingestion uses of
groundwater such
as dermal contact
during industrial
groundwater usage
or direct contact
during trench
excavation under
certain current
(commercial
worker) and future
(commercial
worker, residential)
scenarios at Source
Area Properties.
Because of persistent
groundwater
contamination at each
Source Area Property,
worker contact with
groundwater should be
performed under
property-specific
Health & Safety
Plan/controls until the
remedy is complete.
Completed
Intrusive work at the Grace, UniFirst
and Olympia Properties has been
performed under property-specific
Health & Safety Plans. There are no
plans for further intrusive work at this
time. This practice of using Health &
Safety Plans will continue for intrusive
projects, should one be planned at any
of the five Source Area Properties in
the future.
8/11/2018
12
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Table 2: Status of Recommendations from the 2014 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
1
Arsenic MCL
changed from 50
|ig/L to 10 |ig/L.
Arsenic was not
previously targeted
for cleanup based
on prior MCL.
Historical arsenic
concentrations
were either above
10 ng/L, or
detection limits
exceeded 10 |ig/L.
In addition,
manganese was not
identified as a COC
inOU-1
groundwater under
the 1988
Endangerment
Assessment.
Manganese toxicity
values have been
reduced by a factor
of 10 since the
1988 assessment.
Future exposures to
manganese in
groundwater may
exceed EPA's
Lifetime Health
Advisory.
Assess current
groundwater conditions
relative to arsenic and
manganese at UniFirst,
Grace, Wildwood and
Olympia Properties,
and, where appropriate,
revise cleanup goals
through a remedy
decision document.
Ongoing
Limited sampling was completed for
arsenic (As) and manganese (Mn) by
NEP in 2005, Olympia between 2005
and 2008, Grace in 2015, and
Wildwood in 2017. No metals data has
been collected at UniFirst. Some of
these limited data exceeded the As
MCL or Mn Lifetime Health Advisory
(HA). As part of the OU2 investigation,
comprehensive sampling for metals,
including As and Mn, will be
performed in wells from all Source
Area Properties.7
NA
7 This on-going recommendation has been incorporated in Section VI Issues/Recommendation (page 33) under
issue, "Limited current and historic data for As, Mn, 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 possible concern. Where appropriate, revise cleanup goals through a remedy decision
document."
13
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Table 2: Status of Recommendations from the 2014 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
1
An evaluation of
the groundwater to
indoor air pathway
indicates that
potential future
risks at the Grace
Property
(residential,
commercial),
Olympia Property
(commercial,
residential) and
Wildwood Property
(residential) might
exceed EPA risk
management
guidelines should
redevelopment
occur.
Evaluate risk from
exposure to indoor air
at the Grace, Wildwood
and/or Olympia
Properties based on up-
to-date data if any of
the Properties are
developed/ redeveloped
with occupied
buildings. Grace
Property exceeds EPA
groundwater VISL and
development/redevelop
ment should incorporate
engineered vapor
intrusion mitigation
measures into
development plans,
unless otherwise
demonstrated
satisfactorily to EPA
that vapor intrusion will
not pose a potential
threat to future
occupants. If
Wildwood and Olympia
Properties were
proposed for
development, then
evaluate risk from
exposure to indoor air
in accordance with
issue.
Completed
As part of the Grace Property
redevelopment, engineered vapor
intrusion mitigation measures have
been designed and installed at newly
constructed buildings. The Wildwood
and Olympia Properties are not
proposed for development at this time,
and considering the restrictions
associated with wetlands and access, it
is unlikely that these properties will be
developed.
3/1/2019
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Involvement & Site Interviews
EPA Region 1 issued a press release on 2/21/2019, indicating that it would be reviewing cleanups and
remedies at 14 Superfund Sites in Massachusetts, including the Wells G&H Superfund Site
(https://www.epa.gov/newsreleases/epa-begins-14-reviews-massachusetts-superfund-site-cleanups-vear).
In addition to this announcement, an article announcing the commencement of this FYR appeared in the
Daily Times Chronicle on 2/25/2019. The purpose of the public notices were to inform the community
that EPA would be conducting a FYR to ensure that the remedy implemented at the Site remains
protective of public health and the environment and is functioning as designed. The results of the review
and the report will be made available at the Site information repository (Woburn Public Library located at
45 Pleasant Street, Woburn, MA, and EPA Region 1 - New England's Records Center, 5 Post Office Sq.,
First Floor, Boston, MA) and on EPA's website at www.epa.gov/superfund/wellsgh.
14
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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 between March 19 and
April 8 with officials from Woburn, Massachusetts, community stakeholders, MassDEP, and the PRP site
coordinators. The individuals interviewed, their affiliation, date of interviews, and interview types (i.e.,
in person, telephone, by email) are summarized in Table 3. Results of these interviews are summarized
below.
Table 3: Summary of Interviewees, Affiliations and Interview Dates
Interviewee
Affiliation
Interview Date
Interview Type
Clayton Smith
Project Coordinator - de maximis, inc. - Grace
Contractor
March 21, 2019
Email
Timothy Cosgrave
Director Environmental Health and Safety -
UniFirst Corporation
March 27, 2019
Email
Jeff Hamel, LSP, LEP
Woodard & Curran - New England Plastics
Contractor
March 27, 2019
Email
Peter Cox, PG
AECOM - Contractor for Beatrice Foods
(Wildwood)
March 27, 2019
Email
Christene A. Binger
Geo Insight - Olvmpia Contractor
April 1, 2019
Email
Michael L. Raymond
Co-chairman, Aberjona Studv Coalition, Inc.
March 19, 2019
Email
Linda A. Raymond
Co-Chairman, Aberjona Studv Coalition, Inc.
March 19, 2019
Email
Jennifer McWeency
Massachusetts Department of Environmental
Protection
March 21, 2019
Email
Paul Medeiros
Woburn Resident
March 27, 2019
Email
City Official
Citv of Woburn
March 26, 2019
Phone
Health Agent
Citv of Woburn
April X, 2019
Phone
PRP Representatives / Consultants
The PRPs or their representatives reported that remedial systems (where active) are functioning as
required by the ROD and ESD, and that positive progress is being made toward achieving cleanup levels.
Peter Cox (Wildwood) acknowledged that optimization efforts are required at Wildwood to improve the
removal of VOCs from groundwater, but anticipates that residual VOCs will persist in bedrock above
cleanup levels following remedial completion with optimizations.
Representatives of Grace and NEP noted concentrations of VOCs in groundwater have significantly
decreased at these properties since the remedy was implemented and that concentrations have been
reduced below cleanup levels at many of the monitoring wells. Clayton Smith (Grace) stated that it was
Grace's opinion that, based upon existing data, a transition to Monitored Natural Attenuation should be
considered. Christene Binger (Olympia) also indicated that significant reductions in VOCs had occurred
at the Olympia property, but that some wells completed in silt required a change in the method of oxidant
delivery (i.e., direct push) and will take longer to treat. Representatives of UniFirst and Wildwood
indicated that while concentrations have decreased (in some cases below cleanup levels) in some wells,
VOCs persist above cleanup levels in overburden and bedrock wells in certain portions of these sites.
Other than challenges of operating aging systems and finding spare parts, no significant O&M difficulties
within the last five years were identified by the PRPs or their representatives. Representatives of Grace,
UniFirst and Wildwood noted several changes to optimize the remedial systems on these properties
15
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including changes in O&M and sampling schedules. Clayton Smith (Grace) mentioned that although
optimization of O&M and sampling efforts have occurred, these adjustments have not resulted in a
meaningful cost savings.
Except for the addition of EX-1 to Uni First groundwater extraction system. PRPs or their representatives
indicated that no significant changes in overall pumping rates had occurred in the last five years. As per
design, the Uni First pumping well (UC22) helps contain contaminants in the deep aquifer for Grace and
captures some contamination from beyond the Uni first property boundary. One PRP (Grace) reported the
potential impact from an off-site contaminant source. Clayton Smith (Grace) stated that PCE continues to
be drawn onto the southern portion of the Grace property from an off-site source and was supportive of
work completed as part of the Central Area (OU2) investigation to identify the source of the PCE. Jeff
Ham el (NEP) noted that toluene and methyl tcrt-butyl ether (MTBE) are periodically detected in
upgradient and cross gradient wells, which Mr. Ham el maintains are not related the release at NEP. Mr.
Ham el expressed uncertainty concerning possible upgradient sources of impact to deeper bedrock
groundwater in the NEP property or suggested steps that could be taken to address such impacts. The
PRPs or their representatives indicated that the mix of contaminants detected in groundwater or soil
vapor, where applicable, have remained consistent.
With the exception of Grace. PRPs or their representatives reported there were no changes in ow nership
or land use for the Source Area Properties within the last five years and no institutional controls have
been implemented at the OU1 properties. Clayton Smith indicated that the Grace Property was sold to a
local developer in 2014 and that redevelopment of the property with restaurants and a hotel is expected to
be complete by the summer of 2019. Vapor barriers have been incorporated beneath all new buildings to
prevent potential vapor intrusion.
No land use changes arc anticipated by the PRPs or their representatives to occur in the foreseeable
future. With the exception of NEP, industrial processes arc not being conducted at the OU 1 properties and
the PRPs representatives are unaware of any changes in chemical use at the properties.
The PRPs or their representatives identified one or more of the following measures were used to prevent
unauthorized access to contaminated areas:
• Buildings that house treatment systems are locked and equipped with security systems (Grace.
UniFirst. and Wildwood); and
• Fencing and/or gates (UniFirst. Wildwood. NEP and Olympia).
No health and safety issues were identified on-site by the PRPs or their representatives and no incidence
of trespassing or vandalism was identified. No unexpected events that could damage remedial
components (i.e., fires, floods, etc.) have occurred. In addition, no reports of complaints were reported by
the PRPs or their representatives.
With the exception of the representative for Olympia, persons interviewed were aware of the OU4 ROD
signed in 2017 and indicated that the PRPs are participating in the on-going OU2 Remedial
Investigation/Feasibility Study (RI/FS) process.
Concerns raised by two of the parties related to oversight costs and responsiveness of EPA regarding
work plan review and approval. Tim Cosgrave stated that each of the parties has encouraged EPA to
undertake its own evaluation of measures it may implement to reduce unnecessary oversight costs. Peter
Cox indicated that improved agency turnaround time of various work plans would also reduce project
costs.
16
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State and Local Government Officials and Community
The overall opinion expressed by the state/local officials and community representatives/members
interviewed is that the Site is being properly managed by EPA and that positive progress is being made,
although one community member (Mr. Paul Medeiros) felt that there may not be enough oversight
provided by EPA and MassDEP. The MassDEP official and the Woburn Health Agent expressed concern
about the pace of the cleanup activities at the Site, noting that OU1 groundwater pumping has been
ongoing for a long time.
Those interviewed voiced that the community feels that groundwater from the Site should not be used as a
source of potable water, although a representative from the Aberjona Study Coalition indicated that this
stigma appears to be lessening with time. The MassDEP representative noted that they are not aware of
any plans to use the groundwater and the Woburn Health Agent expressed that the cleanup needed to be
completed before there were any discussions concerning groundwater use.
Concerns were expressed relative to redevelopment both at the Site (e.g., the Grace Property) and
upstream of the Site (e.g., Industri-Plex and Olin Chemical sites), and the impact of redevelopment on
traffic, runoff, contaminant redistribution, and on the watershed overall. The MassDEP official felt
cleanup activities to decrease indoor air impacts downgradient of the UniFirst and Grace Properties and
the Grace redevelopment project were having a positive impact on the community. The Woburn Health
Agent expressed that because EPA had investigated and cleaned up portions of the Wells G&H wetland
area, this area could be safely used as walking trails. The City official interviewed also voiced that the
newly-completed walking trails have a positive impact on the community.
The Woburn Health Agent indicated that he has not received any complaints or concerns from the
community related to the Site over the past five years. He does receive a few calls each year from
individuals outside the Woburn area asking questions about the Site.
The state and local government officials felt that they were well informed and had good access to
information on the project. The Woburn Health Agent commented that he accesses the EPA webpage for
the Site to get current information. However, community representatives felt that more information
should be made available to the public and that updates should occur more frequently. Mr. Medeiros
noted that questions concerning whether adequate oversight is occurring by EPA and MassDEP are
related to the lack of information being transmitted to the community. Mr. Medeiros specifically
mentioned that he would like information publicized concerning the result of periodic testing in the
neighborhood downgradient of the Grace and UniFirst Properties and EPA oversight activities that
occurred as part of the Grace redevelopment project.
All state and local government and community representatives interviewed were aware of the continuing
investigation of OU2 and the progress on OU4 of the Site, with a ROD signed for this OU in September
2017. Community member provided additional thoughts related to these two OUs. These community
comments have not been summarized at part of this OU 1 FYR. However, the comments will be reviewed
and considered by EPA as progress continues at the Site.
Data Review
Groundwater monitoring has been performed for a number of years at each of the Source Area Properties
on a property-specific schedule. Table 2 in Appendix B provides a summary of current maximum
detections of contaminants in excess of ROD cleanup levels by Source Area Property, compared to
maximum detected concentrations presented in the 2014 FYR. The discussion below provides further
17
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detail and summarizes the results of groundwater monitoring, as well as monitoring of the SVET at
UniFirst, by Source Area Property during this FYR period.
Grace Property
Grace Property well locations are shown in Figure 3. As previously discussed, Grace shut down 13 of the
16 existing recovery wells in 2015 and implemented an EPA-approved post-shutdown monitoring
program (EPA, 2015). The shutdown monitoring program involved measuring water levels at between
109 and 115 on- and off-property wells and sampling up to 51 on-property monitoring and recovery wells
(depending upon the monitoring event) for chlorinated VOCs. In addition, seven monitoring wells (i.e.,
G8S, G9S, G17S, G21S, G21D, G28S, and G28D) were sampled prior to abandonment in 2015 to
accommodate the ongoing redevelopment of the property with approval from EPA (EPA, 2014b).
On-property monitoring and recovery wells in which contaminant concentrations in excess of ROD
cleanup levels have been detected over this FYR period include monitoring wells G1DB3, GOD, G16S,
G16D, G19M, G19D, G24S, G24D, G26S, G28D, G36DBR, G37S, G37D, G38S, G38D, and G40D and
recovery wells RW-10, RW-17, RW-19, RW-20, RW-21, and RW-22RE. During the most recent
monitoring event completed (May 2018), contaminant concentrations had decreased below ROD cleanup
levels in ten of these wells (i.e., G16D, G19D, G26S, G36DBR, G37S, G38S, G38D, RW-10, RW-20 and
RW-21). Six monitoring wells (G1DB, G20S, G20M, G20D, G23D, and G36DB2) and three recovery
wells (RW-14, RW-15, and RW-18) that were at or above cleanup levels during the 2014 FYR period did
not exceed ROD cleanup levels during this FYR period.
During this FYR period, TCE was detected in 17 on-property monitoring and recovery wells (i.e., G13D,
G16S, G16D, G19M, G19D, G24S, G24D, G26S, G28D, G36DBR, G37S, G37D, G40D, RW-17, RW-
19, RW-21, and RW-22RE) at concentrations above its cleanup level. Maximum concentrations of TCE
were consistently detected at monitoring well G16S and ranged from 63 |ig/L (June 2017) to 140 |ig/L
(December 2016), with the most recent concentration detected at 91 |ig/L (May 2018). The most recent
concentrations of TCE at G16D, G19D, G26S, G37S, G36DBR, RW-17 and RW-21 (May 2018) are
below the ROD cleanup level (see Exhibit 2 in Appendix B.8) TCE concentrations in G19M, G24D, and
G37D appear to be decreasing while TCE in wells G24S, G40D, and RW-22RE do not appear to indicate
a trend. TCE at RW-19 appears to be increasing (refer to Exhibit 3 in Appendix B). TCE in this well, as
well as in wells G19M, G19D, G24S, G24D, G37D, and G40D, appears to be captured by one of the three
recovery wells that remain active. Concentrations at G13D and G16S are not increasing and are currently
confined on the property.
PCE was detected above its cleanup level in two on-property monitoring wells during this FYR period at
maximum concentrations of 9.3 |ig/L (G38D) and 11 |ig/L (G38S). The PCE in these wells appear to be
from an off-property source. Concentrations have decreased below the ROD cleanup level following the
partial shutdown of recovery wells and have remained below the cleanup level since 2015. Concentrations
of PCE have also been detected above the cleanup level in two active (RW-17 and RW-20) and two
inactive (RW-10 and RW-19) recovery wells along the southern boundary of the property (RW-17, RW-
19, and RW-20) which appear to be related to the off-property source. The maximum concentration of
PCE (19 |ig/L) during this FYR period was detected in wells RW-19 and RW-20. Based upon the most
recent monitoring event (May 2018), PCE in RW-10 and RW-20 have decreased below the cleanup level
(see Exhibit 4 in Appendix B).
8 The figure shows TCE concentrations in overburden and shallow bedrock monitoring wells. Consequently, results
for deeper bedrock monitoring well G36DBR are not shown. The TCE concentration at this well during May 2018
was 1.3 |ig/L.
18
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cis-l,2-Dichloroethene (cis-l,2-DCE) was detected above the ROD cleanup level in one well (recovery
well RW-22RE) during this FYR period. Concentrations ranged from 180 (ig/L during the most recent
monitoring event (May 2018) to 270 (ig/L in June 2015 and concentrations appear to be decreasing (see
Exhibit 5 in Appendix B).
Vinyl chloride was detected in excess of its ROD cleanup level in one well (G1DB3) at a maximum
concentration of 2.3 (ig/L during this FYR period. The most recent concentration of vinyl chloride in the
well was 2.1 (.ig/L (May 2018). Contaminated groundwater from this well, as well as G36DBR, is
reported to be captured by the deeper groundwater recovery system operated at the Uni First Property.
Limited sampling for total As and Mn was performed by Grace at six monitoring wells (G16S, G16D,
G22S, G22D, G23D, and G4S) and two recovery wells (RW-17 and RW-22RE) in 2015. These locations
were selected because they currently or historically had detections of VOCs in groundwater and would
provide an indication of whether As and/or Mn is present at elevated concentrations in groundwater at the
property. Concentrations of As and Mn did not exceed the 10 (ig/L MCL for As or the 300 j^ig/L Lifetime
Health Advisory (HA) for Mn.
To date, the system has treated over 92 million gallons of water (GES & JG Environmental, Inc., 2018).
Since the partial shutdown of recovery wells, the annual volume of extracted groundwater increased from
2.14 million gallons to 2.7 million gallons. The increase in extracted groundwater was largely attributable
to installation of a second pump to maintain drawdown below the bedrock surface in recovery well RW-
20, and increased pumping rates in RW-17 during the FYR period which maximizes capture along the
southern border of the Grace Property. The contaminant mass removed over this FYR period has been
relatively consistent at approximately 1 pound per year with the vast majority of this mass coming from
RW-17, RW-20, and RW-22RE. Grace continues to operate these three wells to maintain capture of
groundwater exceeding cleanup levels.
UniFirst Property
Soil Vapor Extraction System
Since the SVET system became operational in November 2014, the system is estimated to have removed
over 49 pounds of VOCs from the subsurface (see Exhibit 6 in Appendix B). Approximately 39 pounds of
this mass was attributable primarily to PCE and to a lesser degree, TCE and 1,1,1-trichloroethane (TCA).
Most of the VOC mass was extracted by wells SVE-2A. -3 A, and -4 A. The levels of VOCs as measured
with a PID have decreased since the system began operation (refer to Exhibit 7 in Appendix B). VOCs
measured using the PID continue to be detected at all of the SVE wells; however, recent PID readings at
the wells show no particular trend over time. Mass removed appears to be declining with time, as
expected, with the mass of PCE. TCE, trans-1,2- DCE, TCA and chloroform decreasing from 17.7 pounds
per year (lb/yr) during the first year of operation to 13.3 lb/yr and 5.5 lb/yr during the second and third
years of operation. The treatment system typically achieves 95 percent or greater reduction in VOCs in
accordance with the Code of Massachusetts Regulations (CMR) Section 40.0049 - Remedial Air
Emissions.
Groundwater
During this FYR period. UniFirst monitored water levels at between 100 and 107 on- and off-property
monitoring wells and the two on-property recovery wells (UC-22 and EX-1), monitored 15 wells for the
presence of dense non-aqueous phase liquid (DNAPL). and collected groundwater samples from 33 wells
located on the property (i.e., EX-1. S70D, S71S/D. UC4, UC5, UC6, UC6S, UC33, UC7-1 through UC7-
5. UC10-1 through UC10-6. UC10S/M/D, UC18, UC19, UC19M, UC25, UC26S/D. UC29S/D, UC30,
19
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UC33) as depicted on Figure 5.9 Over the FYR period. DNAPL was not present at the monitored
locations.
A review of analytical data reveals that contaminant concentrations have not changed significantly in
many routinely monitored wells since the previous FYR. For example, concentrations of PCE, TCE and
cis-l,2-DCE in UC10-3 ranged from 29 to 140 (ig/L, 10 to 46 ug/L, and 86 to 180 ug/L, respectively,
during the previous FYR period. During this FYR period. PCE, TCE and cis-l,2-DCE concentrations in
this well similarly ranged from 19 to 150 ug/L, 17 to 36 ug/L, and 89 to 270 ug/L, respectively. Similarly.
PCE and/or TCE concentrations during this FYR fluctuated over similar ranges observed during the 2014
FYR (above cleanup levels) in S71D. UC6. UC7-1. UC7-2, UC7-3, UC7-4. UC7-5, UC10-1. UC10-2.
UC 10-4. UC10-5, and UC 10-6. At monitoring well UC 18. PCE concentrations decreased and remained
below the cleanup level for the past three years (see Exhibit 9 in Appendix B). At UC26D, TCE decreased
and remained below the cleanup level during this FYR period, and at UC-5, concentrations of PCE were
substantially lower (i.e., between 6.4 and 3 1 (ig/L) than concentrations during the previous FYR (which
generally ranged between 130 to 2,900 (ig/L) and TCE decreased and remained below the cleanup level
(see Exhibits 8 and 10 in Appendix B).
Of the 33 on-property wells sampled during the most recent monitoring event. VOCs were not detected or
exhibited concentrations below cleanup levels at 13 monitoring wells including: S70D. UC4, UC6S,
UC10S/M/D, UC18, UC19, UC19M, UC26S/D. UC30, and UC33. The remaining wells exhibited
concentrations of cis-l,2-DCE, PCE and/or TCE in excess of cleanup levels during one or more sampling
events during this FYR period. Maximum concentrations of PCE. TCE, and cis-l,2-DCE detected in the
wells sampled during the most recent monitoring event are summarized in Table 2. Vinyl chloride. 1.1-
dichloroethene. TCA, and/or chloroform were detected below cleanup levels in limited locations (i.e.,
UC5, UC-7-1. UC7-2. UC-7-3, UC-7-4. UC-7-5, UC 10-1. UC10-3, UC29D, and UC33) and samples
during this FYR period at levels below the cleanup levels. 1.2-Dichloroethane was not detected at any on-
property well during this FYR period. Historically. DNAPL was observed at monitoring well UC8 at the
Uni First Property. In 2012, Uni First proposed enhancing the remedy with I SCO to reduce persistent PCE
in groundw ater bedrock in the vicinity of UC8. Uni First and EPA are monitoring SVET progress, while
considering the I SCO work plan schedule for enhancing the remedy.
As of October 2018, the GWETS has treated over 538 million gallons of water and removed
approximately 2,460 pounds of PCE and TCE with the mass removed ranging from approximately 23 to
34 pounds per year over this FYR period (UniFirst, 2018).
Vapor Intrusion Pathway
Due to elevated soil gas concentrations of PCE beneath the commercial building immediately
west/downgradient of the Unifirst Property, annual monitoring of the subslab and indoor air at the
commercial building immediately west/downgradient of the UniFirst Property has been occurring since
2013 and is expected to continue. Annual subslab soil gas and indoor air monitoring of the commercial
building at the UniFirst Property will commence following completion of the SVET remedy. The active
extraction and treatment of vapors from beneath the building at the UniFirst Property currently protects
this building from vapor intrusion.
Seven annual subslab soil gas and indoor air sampling events have been conducted at the commercial
building immediately west/downgradient of the UniFirst Property. During each sampling event, three
indoor air samples, one to two ambient air samples, and three subslab soil gas samples have been
9 The long-term monitoring program includes sampling at UC34, UC35, and UC36. However, these wells were dry
during each annual monitoring event.
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collected for VOC analysis. The data have been evaluated for consistency with VOC concentrations
present in 2011, which were determined to be associated with risks within the acceptable human health
risk ranges. Subslab soil gas PCE concentrations have decreased from 5,730 (ig/m3 in 2011 to 1,790
(ig/m3 in 2019, while indoor air PCE concentrations have decreased from 1.23 (ig/m3 in 2011 to 0.617
(ig/m3 in 201910 (see Table 3 in Appendix B).
UniFirst/Grace has continued monitoring off-property groundwater in downgradient
residential/commercial areas to confirm that concentrations are remaining constant or decreasing,
indicating that the conclusions of the 2012 VI risk assessment remain valid. Table 4 in Appendix B
presents a comparison of the maximum detected VOC concentrations in 2013 to 2018 concentrations in
the downgradient areas. The comparison indicates that detected VOC concentrations are remaining stable.
These data are discussed relative to Vapor Intrusion Screening Levels (VISLs) in Section V (Technical
Assessment - Question B).
Wttdwood Property
A site and well location map for the Wildwood Property is included as Figure 6. Exhibit 1, included in
Appendix B, summarizes wells sampled at the property during this FYR period. Based upon analytical
data collected during this FYR period. VOCs were either not detected or exhibited concentrations below
cleanup goals at 25 monitoring wells. The 55 remaining monitoring wells sampled during this FYR
period exhibited concentrations of TCE (53 wells), PCE (10 wells), cis-l,2-DCE (1 1 wells), and/or vinyl
chloride (3 wells) above cleanup goals during at least one monitoring event."
Since the groundwater extraction system began operating, concentrations of VOCs have decreased in
several wells, many of which are located within or along the edge of the capture zone of shallow bedrock
recovery well BW-19R shown on Exhibit 1 1 in Appendix B. These wells include bedrock monitoring
wells BW-6R. BW-6RD(LO), BW-8, BW-15RP. BW-18RD(LO), bedrock extraction well BW-19R. and
monitoring well BCW-13 screened in glacial till. Plots showing TCE (the predominant VOC)
concentrations over time at these well locations are shown on Exhibits 12 through 18 in Appendix B.
While concentrations decreased significantly during the first several years of operation. TCE
concentrations have not changed significantly at these well locations during this FYR period and most of
the wells continue to exhibit concentrations above the cleanup levels. In 2018, EPA recommended that
the SD pilot test I SCO in deeper bedrock in the area of deep bedrock well BW-6RD(LO) as potential
remedy enhancement to help reduce elevated and persistent concentrations of VOCs exceeding cleanup
levels in conjunction with the bedrock groundwater pump and treat remedy (EPA. 2018a).
During this FYR period, several wells were identified by EPA as located outside the recovery well
capture zone and exhibiting concentrations of VOCs above cleanup levels (EPA. 2018a). These wells are
shown on Exhibit 11 and include: WW-100SR. WW-101 SR. S77D. S77SR. S92SR, S92DR. S95SR,
BCW-8. BW-8, and BW-9. In a letter dated July 13, 2018, EPA affirmed its position that additional
recovery wells need to be installed between BW-18RD(LO) and S92DR and the area between BW-17R
and S77SR to capture and treat impacted groundwater. EPA will continue to work with the SD to locate
and install additional recovery wells to achieve capture consistent with the ROD.
10 These declining PCE indoor air concentrations are below the EPA Regional Screening Levels (RSLs) for
industrial air of 18 |ig/m3 and residential air of 4.2 |ig/m3 (EPA 2018b).
11 Some samples were analyzed at elevated detection limits greater than the cleanup level. Although certain
compounds were not detected in the affected samples, one or more of these compounds could potentially have been
present above the cleanup level, in the affected samples.
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VOCs contained in soil and overburden groundwater are treated using the AS/SVE system. In June 2014,
the SD began operating two new AS wells screened near the base of a fine sand unit containing elevated
concentrations of VOCs. Operation of these AS wells has significantly reduced (>95% reduction)
concentrations of VOCs in nearby monitoring wells BSW-1 and BW-206. Exhibit 19 in Appendix B
shows the reduction in PCE and TCE since the new AS wells began operating. The SD subsequently
undertook a subsurface investigation during 2015 and 2016 to further assess the presence of residual
VOCs in the area of the existing AS system that may require treatment (AECOM, 2016b). Two general
areas of residual VOC impacts were identified: one at the northern end of the AS/SVE treatment area and
one at the southern end of the treatment area. Exhibit 20 in Appendix B shows the distribution of TCE in
overburden within these areas. In its July 13, 2018 letterto representatives for the SD, EPA outlined the
path forward for optimizing the AS/SVE system to address residual contamination in these areas
including installation and operation of additional AS wells and, as appropriate, additional SVE wells.
Work to optimize the AS/SVE system is ongoing.
During this FYR period, the SD conducted As and Mn sampling at five newly installed overburden
monitoring wells (i.e., WW-200D. WW-203, WW-206. WW-208S, and WW-211S). Arsenic was
detected above the MCL in one well (WW-203) and Mn exceeded the Lifetime HA in all wells except
well WW-206.
The GWETS and AS/SVE continue to treat groundwater in bedrock and overburden respectively. The
GWETS has recovered and treated over 239,500,000 gallons of contaminated groundw ater and the
systems arc estimated to have removed over 2.763 pounds of VOCs from groundw ater. Approximately 20
to 25-percent of the mass of VOCs treated comes from extracted groundwater with the remainder from
the AS/SVE system (AECOM, 2016c; 2017d).
NEP Property
Since the shutdown of the remedial system in 2000, ongoing groundwater monitoring is being performed
at five overburden wells (EPA-1. EW-1. NEP-101. NEP-104, and NEP-108) and four shallow bedrock
wells (NEP-101B. NEP-104B. NEP-106B. and NEP-108B) to evaluate contaminant trends (Figure 7).
With the exception of PCE. chlorinated VOCs were not detected above ROD cleanup levels at overburden
or shallow bedrock monitoring wells during this FYR period. PCE exceeded the ROD cleanup level at
two overburden monitoring wells (EW-1 and NEP-101) and one shallow bedrock well (NEP-104B). The
maximum concentration of PCE in these wells was detected in NEP-101 (1 1 (ig/L). Concentrations of
PCE in these wells decreased over the FYR period with the most recent concentration at EW-1 (July
2017) below the ROD cleanup level as shown on Mann-Kendall trend plots (Exhibit 21 in Appendix B).
In addition, three deeper bedrock wells (NEP-3, NEP-B, and NEP-A as depicted on Figure 7) were
sampled in 2016 in response to EPA's request to assess current concentrations of chlorinated VOCs in
deeper bedrock groundwater (EPA. 2009a). Both PCE and TCE were detected above ROD cleanup levels
in the three deeper bedrock wells. Concentrations of these two compounds were low er than in samples
previously collected from NEP-3 and NEP-B in 1990; however, concentrations were above detection
limits in NEP-A. The maximum concentrations of PCE and TCE were detected at NEP-A at
concentrations of 12 jig/L and 38 (ig/L, respectively.
In addition to chlorinated VOCs. the 2016 samples collected from deeper bedrock wells NEP-3, NEP-A,
and NEP-B were analyzed for 1.4-dioxane. Although not detected in NEP-B above the laboratory
reporting limit, which varied between 0.144 and 0.153 (ig/L, 1.4-dioxane detections exceeded the 0.46
(ig/L EPA Regional Screening Level (RSL) in discrete samples collected from fractures in NEP-3 and
NEP-A. Concentrations in these wells ranged from 0.482 (ig/L in NEP-A to 1.15 (ig/L at NEP-3.
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Groundwater samples were not analyzed for As or Mn during this FYR. However, groundwater samples
were previously collected and analyzed for these metals at the NEP Property in 2008. These data did not
reveal an exceedance of the As MCL or the Mn HA at the NEP Property.
Olympia Property
Well locations at the Olympia Property are depicted on Figure 8. Of the 68 wells sampled as part of the
April 2005 baseline monitoring performed by the PRP prior to initiation of I SCO treatment. 38 had
concentrations of PCE and/or TCE, and in some cases associated daughter products, in excess of
cleanup levels for groundw ater. The I SCO injections have significantly reduced concentrations of
VOCs at most monitoring locations on the property by one or more orders of magnitude as shown in
Exhibit 22. At a few locations. VOCs appear to have decreased below cleanup levels with no apparent
rebound over two or more rounds of sampling (e.g., monitoring wells MW208S, MW211S, MW217S,
MW218S, and MW219M).
Fifty-four of the 68 wells sampled during the baseline monitoring event were monitored for VOCs
during this FYR period as shown on Exhibit 22. Of these 54 wells, 27 wells are located within and 27
wells are located outside of the treatment cell. Concentrations in 23 wells, three located within the
treatment cell (i.e., OL-3M, MW-203S, and MW-211S) and 20 located outside the treatment cell (i.e.,
MW214S/M/D, MW215D, MW216M/D, MW212M/D, MW213D, MW220M/D, MW211S/M,
MW217S/D, MW218S/D, and MW219S/M/D), were below cleanup goals during the most recent
sampling events completed at these wells during this FYR period. In addition. COCs were not detected
in nine wells located within the treatment cell (i.e., MW200S/D, MW202D, MW203D, MW204S/D,
MW205D, MW206S, and MW207D) and in two wells outside the treatment cell (i.e., MW215S and
MW216S) but at detection limits above cleanup goals. At the vast majority of the remaining wells,
concentrations of VOCs continued to decrease or have fluctuated above and below cleanup levels.
Three wells (i.e., MW207S, MW211D, and MW217M) have exhibited increases in TCE and/or cis-1.2-
DCE concentrations in the last five years. Continued I SCO application, which may include additional
optimizations (e.g., improved delivery methods), is anticipated by EPA during the next five years to
address areas of persistent contamination and progress toward attainment of cleanup goals.
Site Inspections
The inspection of the five OU1 Source Area Properties was conducted on 2/18/2019 and 2/19/2019. In
attendance were David Sullivan, LSP, and Jeffrey Hansen, PH, of TRC, on behalf of the EPA RPM. The
purpose of the inspections was to assess the protectiveness of the remedy. A detailed summary of
observations made during the inspection of the Source Area Properties is included in Appendix D.
The following individuals attended inspections for the respective SDs:
• Grace Property: Clayton Smith, Project Coordinator - de maximis, Inc.; Van Sawyer, Technical
Services Manager - GES, and operator of the groundwater extraction and treatment system; and
Paul Bucens of W.R. Grace.
• UniFirst Property: Tim Cosgrave, Director of EHS for UniFirst and O&M Manager for
GWETS.
• Wildwood Property: Peter Cox, PG, Project Manager - AECOM and Edward Zygarowski,
O&M Manager for GWETS and AS/SVE System, also of AECOM.
• NEP Property: Jeff Hamel, LSP and Project Manager - Woodard and Curran, Inc.; and
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• Olympia Property: Christene Binger, Associate Professional Hydrogeologist - Geolnsight.
The inspections included visual inspection of each Source Area Property for site access, record keeping,
and remedy implementation and monitoring activities. Overall, the site inspections indicated that
remedies at the Source Area Properties are being effectively implemented. Pertinent findings noted during
the inspections are summarized below:
• At the Grace Property, the surfaces around some wells have been temporarily affected by
redevelopment. Not all wells could be located or observed due to snow cover or access
constraints associated with redevelopment. It is recommended that all monitoring wells be located
and assessed when snow cover disappears and the redevelopment has been completed to verify
that surfaces surrounding the affected wells has been restored to the satisfaction of EPA and to
assess maintenance needs for the monitoring network, if any.
• At the UniFirst Property, not all wells could be located or observed due to snow cover. However,
covers for some of the observed flush-mounted wells outside the building were missing bolts and
at least one location with a stick up (i.e., PZ1S/D) did not have a lock. The Johnson Company is
currently working on a plan to restore wells DP37D, UC31M and UC3 ID, which were reported
to be sand locked in the 25 Year Annual Report (UniFirst, 2017). It is recommended that all
wells monitored for water levels/water quality be inspected after snow cover has melted to
identify wells that need to be secured and/or require maintenance.
• At the Wildwood Property, not all wells could be located or observed because of snow cover or
safety concerns (e.g., icy conditions on wooden boards to wells in the Abeijona wetlands).
However, protective covers at several well locations were not locked/secured, reportedly because
the property is fenced, with access limited via a locked gate, and O&M personnel are routinely
present. It was also noted that at least one well located in an area subject to periodic flooding
(BSW-14) did not have an expansion plug to prevent surface water from entering the well. A
comprehensive assessment of all wells is recommended once snow cover disappears to identify
wells requiring maintenance, if any. In addition, it is recommended that all wells should be locked
and secured to limit the potential for tampering by trespassers.
• At the Olympia Property, monitoring wells located inside the fenced area were observed to be
unlocked and most did not have covers. Several monitoring wells had sampling tubing protruding
from the well and PVC casing was observed to extend above the steel protective casing at several
location. Although the property is surrounded by fencing, the fencing is unlikely to deter a
determined trespasser. For this reason, it is recommended that all wells should be properly
secured between monitoring and injection events.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes - for the Grace, UniFirst, NEP and Olympia Properties. The review of available documents,
evaluation of compiled data, and the results of the site inspections indicate that the remedy is functioning
as intended in the ROD and ESD. Treatment systems at the Source Area Properties continue to operate
with limited downtime and their operation is resulting in decreasing contaminant concentrations in the
subsurface. Although lingering VOC contamination is present within the aquifer and further investigation
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is required to assess As, Mn and 1,4-dioxane in groundwater at the Source Area Properties12, the
groundwater is not used as a source of drinking water at this time. Vapor mitigation systems have been
installed to prevent the VI pathway at buildings constructed as part of Grace redevelopment activities.
Monitoring of the subslab and indoor air at the commercial building immediately we st/downgradient of
the UniFirst Property since 2013 has not indicated a risk to the occupants and annual monitoring of these
media is expected to continue. The active extraction and treatment of vapors from beneath the building at
the UniFirst Property currently protects this building from vapor intrusion.
For the Wildwood Property, although some contaminated groundwater in bedrock is captured,
contaminated groundwater is present outside the capture zone of recovery wells and continues to enter the
Central Area. EPA is working with the SD to address this issue.
Remedial Action Performance
While some lingering groundwater contamination remains beneath all Source Area Properties,
groundwater contaminant levels have been reduced or controlled and active groundwater remediation
continues to occur at the Grace, UniFirst, and Wildwood Properties.
Due to substantial progress at the Grace Property, EPA granted permission for partial shutdown of 13 of
the 16 extraction wells at the property. Additional soil excavation and off-site disposal occurred as part of
the Grace redevelopment project, along with the installation of vapor mitigation systems in newly-
constructed buildings to mitigate a potential VI pathway.
UniFirst installed an additional extraction well to enhance groundwater capture at the southwest corner of
the property and began operating the SVET system to address VOC contamination in soil and shallow
groundwater. Operation of the SVET system also protects the existing on-property commercial building
from vapor migrating into indoor air. UniFirst is monitoring SVET progress, while considering the
appropriate time to implement enhancement measures (e.g., I SCO) to address residual DN APL present in
the vicinity of UC8.
Significant reductions of groundwater contaminant concentrations have been achieved at the NEP
Property. Exceedances of cleanup levels for PCE remain in overburden and shallow bedrock groundwater
at the property, but these exceedances appear to be contained and near cleanup levels. Recent sampling of
deeper bedrock groundwater detected concentrations of PCE and TCE at concentrations above cleanup
levels and 1,4-dioxane at levels exceeding EPA's tapwater risk-based screening levels. Further evaluation
of NEP Property groundwater in the deeper bedrock is necessary to fully characterize the source area and
ensure remedy effectiveness.
Results of groundwater sampling at the Wildwood Property initially showed reductions in many
contaminant concentrations during the first several years of remedy implementation. Over this FYR
period, however, concentrations have not changed significantly and data continue to confirm exceedances
of cleanup levels for some contaminants, primarily TCE in overburden groundwater. Groundwater
contamination remains outside the capture zone above ROD cleanup levels including in the eastern and
southern portion of the property at bedrock well locations S77SR, S92DR, WW100SR and WW101SR
where concentrations of TCE ranged from 60 to 130 (ig/L during this FYR period. Siting and installation
of additional recovery wells is planned in these areas. Additionally, areas of residual VOCs were
identified during this FYR period in soil that is not being effectively addressed by the AS/SVE system as
currently configured and is contributing to persistent elevated concentrations of VOCs in overburden
12 To be completed as part of sampling during the OU2 investigation.
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groundwater. EPA has recommended enhancement measures including the installation of additional AS
wells and, if warranted, SVE wells as to optimize treatment and/or other measures (e.g., ISCO).
At the Olympia Property, a groundwater pump and treat system has not yet been implemented. However,
cleanup work continues under an AOC with EPA to address soil and groundwater contamination (i.e.,
oxidant injection to destroy subsurface VOCs). Although VOCs continue to exceed cleanup levels. I SCO
injections have significantly reduced concentrations of VOCs at most monitoring locations on the
property by one or more orders of magnitude. Targeted injections continue to be performed, typically
twice a year, to address the remaining contamination. Upon ISCO completion, the effectiveness of ISCO
will be assessed and EPA will determine the need for implementing the groundwater pump & treatment
system identified under OU1 for the Olympia Property.
Concerns resulting from the decreased MCL for As, publication of a lifetime HA for Mn, and assessment
for the emerging contaminant 1,4-dioxane are still being addressed at the Source Area Properties.
Groundwater samples were collected and analyzed for As and Mn at the Grace and Wildwood Properties
during this FYR period, while 1,4-dioxane data were collected at the NEP Property. The groundwater is
not used as a source of drinking water at this time.
The Source Area Property groundwater treatment systems, and associated monitoring programs, are the
only components of the remedy that currently offer the possibility for optimization/enhancements at the
Grace, UniFirst, NEP, and Olympia Properties. Progress continues towards the remedy cleanup goals
since the fourth FYR. Optimizations/enhancement opportunities remain at the Wildwood Property for
capture and groundwater contaminant reductions, as well as the UniFirst Property for groundwater
contaminant reductions, as noted previously. EPA continues to encourage the Source Area Properties to
explore optimization/enhancement techniques to accelerate progress toward the achievement of cleanup
goals at the Site.
System Operations/O&M
Descriptions of the O&M activities conducted during the previous five years are provided in Section 11 for
the UniFirst. Grace, Wildwood and Olympia Properties. No O&M activities have occurred at the NEP
Property since the third FYR, except for groundwater monitoring.
Based on the review of the Source Area Properties' O&M documentation and the results of this FYR site
inspection activities, the current operating procedures maintain the effectiveness of remedial systems
operation at the Source Area Properties.
Implementation of Institutional Controls and Other Measures
As stated in the ROD (p. 18 of 52), "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 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 ofWoburn 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 cleanup goals have been met."
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Redevelopment projects have been proposed at various properties within impacted areas of the Site,
where the projects may alter existing building conditions, change land uses, potentially cause exposure to
contaminated groundwater/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 & Safety Plans describing how groundwater and soil would be safely managed and workers
protected, how the remedy would be maintained, etc. 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 the remedy and public health and environment remained protected.
EPA will continue to apply the above redevelopment process at the Site. EPA will also assess the need for
ICs 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 VI pathway, as necessary, until groundwater cleanup levels have been met; and
(4) maintain operation of vapor mitigation systems until groundwater cleanup levels have been met.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAQs) used at the time of the remedy selection still valid?
Question B 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. However, the RAOs selected for the Site
are still valid. The drinking water pathway is currently incomplete because 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 which concluded that
the ROD soil cleanup levels were protective for a residential exposure scenario. Since 2014, the toxicity
of cPAHs (i.e., benzo(a)pyrene) and lead have been re-evaluated. However, the revised toxicity estimates
do not alter the protectiveness of the remedy.
Although the remedy was not designed to be protective of vapor intrusion, this pathway is incomplete
under current land-use conditions at the Wildwood and Olympia Properties, 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, while newly-constructed buildings at the Grace Property have been
fitted with engineering controls to mitigate the potential vapor intrusion pathway. Therefore, the changes
as described below are not expected to alter the protectiveness of the remedy.
Changes in Standards and TBCs
A review of Applicable or Relevant and Appropriate Requirements (ARARs) was performed to check the
impact on the remedy protectiveness due to any changes in standards that were identified in the ROD,
new promulgated standards, and/or changes in TBCs (to be considered). Tables documenting the review
of each ARAR, using the regulations and requirements synopses listed in the ROD as a basis, are included
as Appendix C. The evaluation included a determination of whether the requirement is currently ARAR
or TBC and whether the requirements have been met. In general, changes in standards since the 1989
ROD and 1991 ESD do not change the protectiveness of the remedy.
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Changes in Toxicity and Other Contaminant Characteristics
Since the time of the original 1988 Endangerment Assessment, EPA has re-examined and updated
toxicity factors for each of the contaminants evaluated. Changes in these toxicity factors do not affect the
groundwater remedy because of its reliance on the use of municipal water as drinking water until cleanup
levels are achieved. ROD groundwater cleanup levels are based on MCLs which have not changed since
1989. With the exception of lead (discussed below), the ROD soil cleanup levels for future residential use
continue to be protective, even considering the updated toxicity factors. Even though the ROD cleanup
level for lead would no longer be considered protective for residential land use, average lead
concentrations on the Source Area Properties do not exceed the current lead screening level (SL). In
addition to updated toxicity values, new information has become available on emerging contaminant 1,4-
dioxane.
• 2016 Lead in Soil Cleanups
EPA's 2016 OLEM memorandum "Updated Scientific Considerations for Lead in Soil Cleanups"
(OLEM Directive 9200.2-167) indicates that adverse health effects are associated with blood lead
levels (BLLs) at less than 10 micrograms per deciliter (|ig/dL). The memo mentioned that several
studies have observed "clear evidence of cognitive function decrements in young children with mean
or group BLLs between 2 and 8 |ig/dL." Any soil screening, action or cleanup level developed based
on the previous target BLL of 10 (ig/dL may not be protective.
EPA's approach to evaluate potential lead risks is to limit exposure to residential and commercial soil
lead levels such that a typical (or hypothetical) child or group of similarly exposed children would
have an estimated risk of no more than 5% of the population exceeding a 5 (ig/dL BLL. This is based
on evidence indicating cognitive impacts at BLLs below 10 (ig/dL. Additionally, this approach aligns
with the Lead Technical Review Workgroup's current support for using a BLL of 5 (ig/dL as the level
of concern in the Integrated Exposure Uptake Biokinetic Model (IEUBK) and Adult Lead
Methodology (ALM). A target BLL of 5 (ig/dL reflects current scientific literature on lead
toxicology and epidemiology that provides evidence that the adverse health effects of lead exposure
do not have a threshold.
EPA's 2017 OLEM memorandum "Transmittal of Update to the Adult Lead Methodology's Default
Baseline Blood Lead Concentration and Geometric Standard Deviation Parameters" (OLEM
Directive 9285.6-56) provides updates on the default baseline blood lead concentration and default
geometric standard deviation input parameters for the Adult Lead Methodology. These updates are
based on the analysis of the NHANES 2009-2014 data, with recommended updated values for
baseline blood lead concentration being 0.6 (ig/dL and geometric standard deviation being 1.8.
Using updated default IEUBK and ALM parameters at a target BLL of 5 (ig/dL, site-specific lead soil
SLs of 200 mg/kg and 1,000 mg/kg are developed for residential and commercial/industrial
exposures, respectively.
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 SL 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 (Table 5 in Appendix B),
the average lead concentrations of surface and subsurface soils at this property are less than the
residential soil SL.
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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.13
• 2017Polycyclic Aromatic Hydrocarbons (PAHs) cancer and non-cancer toxicity values
On January 19, 2017, EPA issued revised (less carcinogenic) cancer toxicity values and new non-
cancer toxicity values for benzo(a)pyrene. Benzo(a)pyrene did not have non-cancer toxicity values
prior to January 19, 2017. Benzo(a)pyrene is now considered to be carcinogenic by a mutagenic mode
of action; therefore, cancer risks must be evaluated for different human developmental stages using
age dependent potency adjustment factors (ADAFs) for different age groups. The cancer potency of
other carcinogenic PAHs is adjusted using relative potency factors (RPFs), which are expressed
relative to the potency of benzo(a)pyrene. The non-cancer effects of benzo(a)pyrene were not
evaluated in the past due to the absence of non-cancer values.
The ROD soil cleanup level for cPAHs (the sum of the benzo(a)pyrene-equivalent concentrations for
the cPAHs adjusted for relative toxicity) is 0.694 mg/kg. EPA's residential soil RSL for
benzo(a)pyrene based on a cancer risk of lxlO"6 is 0.11 mg/kg (EPA, 2018). Therefore, the ROD
cPAH cleanup level would be associated with approximately a 6xl0"6 cancer risk. Because this is less
than the cancer risk estimated in 2014 when the ROD soil cleanup levels were last evaluated for
protectiveness, the cumulative risk of the soil cleanup levels would not exceed EPA's risk
management range (10~6 to 10"4).
• 2013 1,4-Dioxane cancer and non-cancer toxicity values
In 2013, EPA revised the toxicity values for 1,4-dioxane. The oral slope factor increased, while the
value for inhalation unit risk decreased, which indicates that 1,4-dioxane is more toxic from cancer
health effects via the oral pathway, but less toxic from inhalation. Additionally, the non-cancer values
for oral reference dose and inhalation reference concentration both decreased, which indicates that
1,4-dioxane is more toxic from non-cancer hazards.
This compound was commonly used as a chlorinated solvent stabilizer to prevent product
degradation. It was identified as a COC in OU4 groundwater in the 2017 ROD. Limited sampling in
2011 at the UniFirst (four wells) and Grace (five wells) Properties did not detect this compound at a
reporting limit of 2 ug/L. In 2016, three deeper bedrock wells at the NEP Property were sampled and
displayed 1,4-dioxane detections above the 0.46 (ig/L EPA RSL. The upcoming OU2 sampling event
that will include OU1 wells and will include 1,4-dioxane as part of the analytical suite with detection
limits which 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 OU1 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.
• 2016PFOA/PFOS14 non-cancer toxicity values
13 The SS-2 location on the Grace Property was excavated in 2012 as part of the Southern Drainage Ditch soil
removal action, conducted due to exceedances of the ROD cleanup level for cPAHs. Because no lead post-
excavation confirmation sampling was conducted, this data point was retained for the lead evaluation to be health
protective.
14 PFOA and PFOS are Per-and Polyfluoroalkyl Substances (PFAS).
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In May 2016, EPA issued final lifetime drinking water health advisories for PFOA and PFOS, which
identified a chronic oral reference dose (RfD) of 2E-05 mg/kg-day for PFOA and PFOS (EPA, 2016a
and EPA, 2016b). These RfD values should be used when evaluating potential risks from ingestion
of contaminated groundwater at Superfund sites where PFOA and PFOS might be present based on
site history. Considering the variety of disposal activities at the Site, PFOA and PFOS should be
evaluated further at the various Source Area Properties. Potential estimated health risks from PFOA
and PFOS, if identified, would likely increase total site risks due to groundwater exposure. Further
evaluation of potential risks from exposure to PFOA and PFOS in other media at the Site might be
needed based on site conditions and can also affect total site risks.
• 2014PFBS15 non-cancer toxicity value
PFBS has a chronic oral RfD of 2E-02 mg/kg-day based on an EPA Provisional Peer Reviewed
Toxicity Value (PPRTV) (EPA, 2014e). This RfD value should be used when evaluating potential
risks from ingestion of contaminated groundwater at Superfund sites where PFBS might be present
based on site history. Considering the variety of disposal activities at the Site, PFBS should be
evaluated further at the various Source Area Properties. Potential estimated health risks from PFBS, if
identified, would likely increase total site risks due to groundwater exposure. Further evaluation of
potential risks from exposure to PFBS in other media at the Site might be needed based on site
conditions and can also affect total site risks.
Changes in Risk Assessment Methods
The following guidance documents were released bv EPA since the last FYR. Although these
guidance documents represent a change in risk assessment methodology, the change does not affect
remedy protectiveness.
• 2014 OSWER Directive Determining Groundwater Exposure Point Concentrations,
Supplemental Guidance
In 2014, EPA finalized a Directive to determine groundwater exposure point concentrations (EPCs)
Hi ttps://cfpub.cpa.gov/ncca/risk/rccordisplav.cfm'Mcid=236917). This Directive provides
recommendations to develop groundwater EPCs. The recommendations to calculate the 95% UCL of
the arithmetic mean concentration for each contaminant from wells within the core/center of the
plume, using the statistical software ProUCL, could result in lower groundwater EPCs than the
maximum concentrations routinely used for EPCs as past practice in risk assessment, leading to
changes in groundwater risk screening and evaluation. In general, this approach could result in
slightly lower risk or higher screening levels.
• 2014 OSWER Directive on the Update of Standard Default Exposure Factors
In 2014, EPA finalized a Directive to update standard default exposure factors and frequently asked
questions associated with these updates, https://www.epa.gov/risk/superfund-risk-assessment-human-
health-topics (items # 22 and #23 of this web link under exposure assessment; EPA, 2014d). Many of
these exposure factors differ from those used in the risk assessment supporting the 1989 ROD. These
changes in general would result in a slight decrease in the risk estimates for most chemicals.
15 PFBS is aPFAS.
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Changes in Exposure Pathways
Exposure pathways considered in the 1988 Endangerment Assessment included: (1) ingestion of
groundwater and inhalation of VOCs while showering for 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, UniFirst
and NEP) or are undeveloped (Wildwood and Olympia). The Grace Property is undergoing
redevelopment as a hotel and restaurants. However, because the property was remediated to residential
cleanup levels and subslab vapor mitigation systems were installed during construction, the change in
land use does not affect remedy protectiveness. Municipal water is available for use at the Site and
vicinity which prevents exposure to impacted groundwater until cleanup levels are achieved.
The following guidance was released by EPA since the last FYR. Although this guidance represents a
change in the method of evaluating a specific exposure pathway, the changes do not affect remedy
protectiveness.
• 2018 EPA VISL Calculator
In February 2018, EPA launched an online VISL calculator which can be used to obtain risk-based
screening level concentrations for groundwater, sub-slab soil gas, and indoor air. The VISL calculator
uses the same database as the RSLs for toxicity values and physiochemical parameters and is
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)
Consistent with the 2014 FYR, groundwater VISLs have been used to evaluate current shallow
groundwater concentrations at the NEP, UniFirst and Grace Properties, and downgradient of the
Grace and UniFirst Properties, to confirm that the conclusions of EPA's 2012 VI risk assessment
remain valid. In general, shallow groundwater concentrations have remained consistent or have
decreased since 2012 (see Table 4 in Appendix B), indicating that the remedy remains protective of
the VI pathway. For the Grace Property, subslab vapor mitigation systems were installed in the newly
constructed buildings. The operation of the SVET system at UniFirst is protecting the existing
commercial building from vapor impacts. In addition, the commercial building west/downgradient of
the UniFirst Property is monitored annually for VI concerns. The Wildwood and Olympia Properties
have not been evaluated since these properties are currently undeveloped. The VI pathway should be
evaluated in the future if these properties are planned for development.
EPA updates RSL tables twice a year and the most current ones are available at the EPA Regional
Screening Levels web page (https://www.epa.gov/risk/regional-screening-levels-rsls').
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 groundwater.
Concentrations of VOCs in groundwater have diminished since the systems have been operating and
continue to capture and reduce the overall mass of VOCs in groundwater at the Source Area Properties.
Soil cleanup levels have been achieved at the NEP and Grace Properties. Remedial activities to address
subsurface soil and shallow groundwater contamination continue at the UniFirst Property (e.g., SVET
system and EX-1) and within the FDD A at the Olympia Property (i.e., I SCO injection). With the
exception of the Wildwood Property, groundwater capture has been demonstrated at the Source Area
Properties. Although As, Mn and 1,4-dioxane have not been fully investigated as potential groundwater
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COCs and lingering YOCs concentrations above cleanup levels remain in groundwater, remedy
protectiveness is not affected because groundwater is not a current source of drinking water.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy?
No other information has come to light that could call into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
()l (s) wilhoul Issiies/Kocommenthilions Identified in (lie l"i\e-Year Re\ie\\:
None
Issues and Kccommcndalinns Identified in I lie l-"i\e-Year Ue\ie\\:
OU(s): 1
Issue Category: Remedy Performance
Issue: Extraction systems performance (insufficient capture of groundwater
contamination) at Wildwood Property.
Recommendation: 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 contaminant 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 B W-6R as an
enhancement to the pump and treat remedy for bedrock groundwater.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
7/1/2021
OU(s): 1
Issue Category: Other
Remedy Implementation
Issue: No groundwater pump and treatment system implemented at NEP Property
following AS/SVE shutdown.
Recommendation: 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.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2020
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OU(s): 1
Issue Category: Other
Remedy Implementation
Issue: No groundwater pump and treatment remedy implemented at Olympia Property.
Recommendation: Continue to evaluate the progress of ISCO in achieving ROD
groundwater and soil cleanup levels based upon post-injection monitoring data and the
need for groundwater cleanup at the conclusion of the removal action. Upon ISCO
completion, the effectiveness of ISCO will be assessed and EPA will determine the need
for implementing the groundwater pump & treatment system identified under OU1 for the
Olympia Property.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2022
OU(s): 1
Issue Category: Other
Additional Contaminants of Concern
Issue: Limited current and historic data for As, Mn, 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 possible
concern. Where appropriate, revise cleanup goals through a remedy decision document.
Recommendation: 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).
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2020
Other Findings
In addition, the following are recommendations that were identified during the FYR and may improve
performance of the remedy and improve management of O&M, but do not affect current and/or future
protectiveness:
• Some groundwater samples on Olympia and Wildwood were analyzed and reported elevated
detection limits greater than cleanup levels. Olympia and Wildwood SDs will provide EPA copies
of the laboratory data packages and further assess data quality relative to the groundwater cleanup
levels; and
• Not all monitoring wells could be located and inspected due to weather conditions (e.g., snow,
ice, water level, etc.). The Source Area Properties SDs will re-inspect their monitoring well
networks, locate all wells, and assure the wells are operable and secured (e.g., locked), etc. The
re-inspection results will be documented in their next annual reports or progress reports.
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VII. PROTECTIVNESS STATEMENT
Protectiveness Statement(s)
Operable Unit:l Protectiveness Determination:
Short-term Protective
Protectiveness Statement: The remedy at the Source Area (OU1) 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. However, in order for the remedy to be
protective in the long-term, the following actions are recommended: 1) Groundwater capture and treatment system
assessment/enhancements at the Wildwood Property actions are required; 2) Deep groundwater assessment, and as
required treatment at NEP Property is needed; 3) Assessment of soil and groundwater cleanup levels from
additional planned IS CO treatment at Olympia Property to determine if additional groundwater treatment is
necessary; and 4) Assessment of groundwater conditions relative to arsenic, manganese, 1,4-dioxane, and PFAS at
all Source Area Properties is needed.
VIII. NEXT REVIEW
The next five-year review report for the Wells G&H Superfund Site is required five years from the
completion date of this review.
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Appendix A
Reference List
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APPENDIX A - REFERENCE LIST
AECOM, 2016a. Work Plan for Remedial System Optimization Wildwood Property, Wells G&H Superfund Site,
Woburn, MA. August 18, 2016.
AECOM, 2016b. Wildwood Property Revised Conceptual Site Model for Overburden Geology,
Hydrogeology, and Extent of Remaining Impacts and Addendum to Wildwood
Remedial System Optimization Work Plan (dated August 18, 2016). December 14, 2016.
AECOM, 2016c. Wells G&H Superfund Site, RD/RA for Wildwood Property.
May 2016 Progress Report, dated June 10, 2016.
June 2016 Progress Report, dated July 11, 2016.
July 2016 Progress Report, dated August 10, 2016.
August 2016 Progress Report, dated September 12, 2016.
September 2016 Progress Report, dated October 10, 2016.
October 2016 Progress Report, dated November 10, 2016.
November 2016 Progress Report, dated December 10, 2016.
December 2016 Progress Report, dated January 10, 2017 (erroneously dated 2016).
AECOM, 2016d. Integrated Subsurface Treatment System Annual Report, Year 17 - May 2014 through April
2015. July 2016.
AECOM, 2017a. Baseline Groundwater Analytical Results. Email from Pete Cox to Joe Lemay and Others dated
March 3, 2017.
AECOM, 2017b. Wells G&H Superfund Site, RD/RA for Wildwood Property.
January 2017 Progress Report, dated February 10, 2017.
February 2017 Progress Report, dated March 10, 2017.
March 2017 Progress Report, dated April 10, 2017.
April 2017 Progress Report, dated May 10, 2017.
May 2017 Progress Report, dated June 10, 2017.
June 2017 Progress Report, dated July 10, 2017.
July 2017 Progress Report, dated August 10, 2017.
August 2017 Progress Report, dated September 10, 2017.
September 2017 Progress Report, dated October 10, 2017.
October 2017 Progress Report, dated November 10, 2017.
November 2017 Progress Report, dated December 10, 2017.
December 2017 Progress Report, dated January 10, 2018.
AECOM, 2017c. Proposed Groundwater Monitoring Program Modifications-Wildwood Property, Woburn, MA.
Technical Memorandum to EPA. November 13, 2017.
AECOM, 2017d. Integrated Subsurface Treatment System Annual Report, Year 18 - May 2015 through April
2016. October 2017.
AECOM, 2018a. Wells G&H Superfund Site, RD/RA for Wildwood Property.
January 2018 Progress Report, dated February 10, 2018.
February 2018 Progress Report, dated March 10, 2018.
March 2018 Progress Report, dated April 10, 2018.
April 2018 Progress Report, dated May 10, 2018.
May 2018 Progress Report, dated June 10, 2018.
June 2018 Progress Report, dated July 10, 2018.
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July 2018 Progress Report, dated August 10, 2018.
August 2018 Progress Report, dated September 10, 2018.
September 2018 Progress Report, dated October 10, 2018.
October 2018 Progress Report, dated November 10, 2018.
November 2018 Progress Report, dated December 10, 2018.
December 2018 Progress Report, dated January 10, 2019.
AECOM, 2018b: Phase I Work Plan to Expand Air Sparge System in Northern Portion of the Wildwood Property
and Perform Radius of Influence Testing, Wells G&H Superfund Site, Woburn, MA. October 4, 2018.
AECOM, 2018c. E-mail from Peter Cox of AECOM describing proposed soil borings around the B6 well cluster.
October 4, 2018.
AECOM, 2018d. Work Plan for Bedrock Structural Features Review and Surface Geophysics Program Wildwood
Property, Wells G&H Superfund Site, Woburn, MA. October 4,2018.
AECOM, 2019. Wells G&H Superfund Site, RD/RA Monthly Progress Report for Wildwood Property. February
10, 2019.
Arcadis, 2015. Vapor Intrusion Monitoring Results, Commercial Property 260206, Woburn,
Massachusetts. May 20, 2015.
Arcadis, 2016. Vapor Intrusion Monitoring Results, Commercial Property 260206, Woburn,
Massachusetts. April 5, 2016.
Arcadis, 2017. Vapor Intrusion Monitoring Results, Commercial Property 260206, Woburn,
Massachusetts. April 3, 2017.
Arcadis, 2018. Vapor Intrusion Monitoring Results, Commercial Property 260206, Woburn,
Massachusetts. April 6, 2018.
Arcadis, 2019. Vapor Intrusion Monitoring Results, Commercial Property 260206, Woburn,
Massachusetts. April 25, 2019.
de maximis, inc., 2010. W.R. Grace Source Area Property (Site) Proposed Actions to Address Soil Exceeding
ROD Action Levels. November 17, 2010.
de maximis, inc., 2014. Monthly Progress Reports for W.R. Grace Source Area Property (Site).
Monthly Progress Report for September 2014. October 10, 2014.
Monthly Progress Report for October 2014. November 6, 2014.
Monthly Progress Report for November 2014. December 9, 2014.
de maximis, inc., 2015. Monthly Progress Reports for W.R. Grace Source Area Property (Site).
Monthly Progress Report for December 2014. January 9, 2015.
Monthly Progress Report for January 2015. February 6, 2015.
Monthly Progress Report for February 2015. March 6, 2015.
Monthly Progress Report for March 2015. April 9, 2015.
Monthly Progress Report for April 2015. May 7, 2015.
Monthly Progress Report for May 2015. June 10, 2015.
Monthly Progress Report for June 2015. July 10, 2015.
Monthly Progress Report for July 2015. August 6, 2015.
Monthly Progress Report for August 2015. September 8, 2015.
Monthly Progress Report for September 2015. October 9, 2015.
Monthly Progress Report for October 2015. November 10, 2015.
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Monthly Progress Report for November 2015. December 10, 2015.
de maximis, inc., 2016. Monthly Progress Reports for W.R. Grace Source Area Property (Site).
Monthly Progress Report for December 2015. January 8, 2016.
Monthly Progress Report for January 2016. February 9, 2016.
Monthly Progress Report for February 2016. March 9, 2015.
Monthly Progress Report for March 2016. April 8, 2016.
Monthly Progress Report for April 2016. May 9, 2016.
Monthly Progress Report for May 2016. June 10, 2016.
Monthly Progress Report for June 2016. July 8, 2016.
Monthly Progress Report for July 2016. August 8, 2016.
Monthly Progress Report for August 2016. September 14, 2016.
Monthly Progress Report for September 2016. October 10, 2016.
Monthly Progress Report for October 2016. November 10, 2016.
Monthly Progress Report for November 2016. December 9, 2016.
de maximis, inc., 2017. Monthly Progress Reports for W.R. Grace Source Area Property (Site).
Monthly Progress Report for December 2016. January 9, 2017.
Monthly Progress Report for January 2017. February 10, 2017.
Monthly Progress Report for February 2017. March 10, 2017.
Monthly Progress Report for March 2017. April 7, 2017.
Monthly Progress Report for April 2017. May 8, 2017.
Monthly Progress Report for May 2017. June 8, 2017.
Monthly Progress Report for June 2017. July 10, 2017.
Monthly Progress Report for July 2017. August 8, 2017.
Monthly Progress Report for August 2017. September 8, 2017.
Monthly Progress Report for September 2017. October 10, 2017.
Monthly Progress Report for October 2017. November 10, 2017.
Monthly Progress Report for November 2017. December 8, 2017.
de maximis, inc., 2018. Monthly Progress Reports for W.R. Grace Source Area Property (Site).
Monthly Progress Report for December 2017, January 8, 2018.
Monthly Progress Report for January 2018. February 9, 2018.
Monthly Progress Report for February 2018. March 9, 2018.
Monthly Progress Report for March 2018. April 10, 2018.
Monthly Progress Report for April 2018. May 10, 2018.
Monthly Progress Report for May 2018. June 7, 2018.
Monthly Progress Report for June 2018. July 9, 2018.
Monthly Progress Report for July 2018. August 10, 2018.
Monthly Progress Report for August 2018. September 10, 2018.
Monthly Progress Report for September 2018. October 9, 2018.
Monthly Progress Report for October 2018. November 9, 2018.
Monthly Progress Report for November 2018. December 10, 2018.
de maximis, inc., 2019. Monthly Progress Reports for W.R. Grace Source Area Property (Site).
Monthly Progress Report for December 2018. January 7, 2019.
Monthly Progress Report for January 2019. February 7, 2019.
Ebasco, 1988. Endangerment Assessment for the Wells G&H Site. Woburn, Massachusetts. Prepared for Ebasco
Services, Incorporated. Prepared by Clement Associates, Inc. December 1988.
Ebasco, 1989. Draft Final Feasibility Study Report, Wells G&H Site, Ebasco Services Incorporated, January,
1989.
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EPA, 1989. EPA Superfund Record of Decision: Wells G&H OU1, Woburn, MA, EPA R01-R89-036 1989,
September 14, 1989.
EPA, 1991a. Consent Decree, Civil Action No. 91-11807MA, United States District Court, District of
Massachusetts.
EPA, 1991b. Explanation of Significant Differences, Wells G&H, EPA ID: MAD980732168, OUOl, Woburn,
Massachusetts. April 25, 1991.
EPA, 2001. Comprehensive Five-Year Review Guidance. EPA 540-R-01-007, OSWERNo. 9355.-7-03B-P.
June 2001.
EPA, 2006. Record of Decision, Industri-Plex Superfund Site, Operable Unit-2 (and including Wells G&H
Superfund Site Operable Unit-3, Aberjona River Study), City of Woburn, Middlesex County, Massachusetts.
January 31, 2006.
EPA, 2009a. EPA Comments on OU-1 NEP Remedial Action Reports. May 4, 2009.
EPA, 2009b. Five-Year Review Frequently Asked Questions (FAQs) and Answers. OSWER 93557-21.
September 2009.
EPA, 2011. Recommended Evaluation of Institutional Controls: Supplement to the Comprehensive Five-Year
Review Guidance. September 2011.
EPA, 2012a. Human Health Risk Assessment for the Vapor Intrusion Pathway. Wells G&H Superfund Site,
Operable Unit 1, Woburn, Massachusetts. April 2012.
EPA, 2012b. Clarifying the Use of Protectiveness Determinations for Comprehensive Environmental Response,
Compensation and Liability Act Five-Year Reviews. OSWER 9200.2-111. September 13, 2012.
EPA, 2012c. Assessing Protectiveness at Site for Vapor Intrusion, Supplement to the Comprehensive Five-Year
Review Guidance. OSWER Directive 9200.2-84. November 2012.
EPA, 2014a. Five-Year Review Report, Fourth Five-Year Review Report for Wells G&H Superfund Site,
Woburn, Middlesex County, Massachusetts. September 30, 2014.
EPA, 2014b. EPA Comments on W.R. Grace - Request to Decommission Certain Wells at 369 Washington
Street, Woburn, MA - October 13, 2014, Wells G&H Superfund Site, Woburn, Massachusetts. Letter from Joe
Lemay to Clayton Smith dated November 10, 2014.
EPA. 2014c. Determining Groundwater Exposure Point Concentrations. OSWER Directive 9283.1-42. February
2014.
EPA. 2014d. Human Health Evaluation Manual, Supplemental Guidance: Update of Standard Default Exposure
Factors. OSWER Directive 9200.1-120. February 6, 2014.
EPA, 2014e. Provisional Peer-Reviewed Toxicity Values for Perfluorobutane Sulfonate. Superfund Health Risk
Technical Support Center. National Center for Environmental Assessment. Office of Research and Development.
EPA/690/R-14/012F. July 17, 2014.
EPA, 2015. EPA Review of Proposed Plan for Partial Shutdown of Areas 2 & 3 Recovery Wells and
Associated Post-Shutdown Monitoring W.R. Grace Groundwater Recovery System Wells G& H Superfund Site,
Woburn, Massachusetts. May 6, 2015.
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EPA, 2016a. Drinking Water Health Advisory for Perfluorooctanioc Acid (PFOA). Office of Water. EPA-822-R-
16-005. May 2016.
EPA, 2016b. Drinking Water Health Advisory for Perfluorooctane Sulfonate (PFOS). Office of Water. EPA-822-
R-16-004. May 2016.
EPA, 2017. Record of Decision, Southwest Properties, Wells G&H Superfund Site, Operable Unit-4, City of
Woburn, Middlesex County, Massachusetts. September 2017.
EPA, 2018a. EPA Responses to recent AECOM documents and Position on Path Forward for Wildwood Source
Area Property OU-1 of Wells G&H Superfund Site, Woburn, Massachusetts. Letter to Peter S. Cox dated July 13,
2018.
EPA, 2018b. Regional Screening Levels, https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables.
November 2018.
EPA, 2018c. Integrated Risk Information System (IRIS). U.S. Environmental Protection Agency, Environmental
Criterion and Assessment Office. Washington, D.C. February 2018.
EPA, 2018d. Comments on Year 25 Annual Report, UniFirst Corporation, Wells G&H
Superfund Site, OU1 Woburn, Massachusetts. November 5, 2018. Letter from Joe Lemay to Tim Cosgrave.
EPA, 2018e. Wells G&H OU1 - Wildwood: EPA Approval to temporarily disconnect GAC vapor treatment:
Letter to Pete Cox (AECOM) from Joe Lemay (EPA) dated August 17, 2018.
Geolnsight, 2004. Revised TCE Work Plan, Removal Action 60 Olympia Avenue, Woburn, Massachusetts,
Geolnsight, Inc., January 28, 2004.
Geolnsight, 2019. Project Memorandum to Alex Sherrin USEPA; Summary of Activities, 60 Olympia Avenue,
Woburn, Massachusetts. May 8, 2019.
GES & JG Environmental, Inc., 2018. W.R. Grace Remedial Action, Wells G&H Superfund Site, Woburn,
Massachusetts - Annual Report, October 1, 2017 - September 30, 2018.
MassDEP, 2004. Letter: Groundwater Use and Value Determination. Richard Chalpin, Assistant Commissioner,
Bureau of Waste Site Clean-up, MassDEP to Robert Cianciarulo, Chief, Massachusetts Superfund Section, EPA,
June 21, 2004.
Tetra Tech, 2015a. Proposed Plan for Partial Shutdown of Areas 2 & 3 Recovery Wells and Associated Post-
Shutdown Monitoring, W. R. Grace Groundwater Recovery System, 369 Washington Street, Wells G&H
Superfund Site. January 5, 2015.
Tetra Tech & JG, 2015. W.R. Grace Remedial Action, Wells G&H Superfund Site, Woburn, Massachusetts,
Annual Report October 1, 2014 - September 30, 2015. November 15, 2015.
Tetra Tech & JG, 2016. W.R. Grace Remedial Action, Wells G&H Superfund Site, Woburn, Massachusetts,
Annual Report October 1, 2015 - September 30, 2016. November 15, 2016.
Tetra Tech & JG, 2017. W.R. Grace Remedial Action, Wells G&H Superfund Site, Woburn, Massachusetts,
Annual Report October 1, 2016 - September 30, 2017. November 15, 2017 - Revised December 12, 2018.
The Johnson, Co., 2015. Operation, Maintenance and Monitoring Plan (OMMP), Soil Vapor Extraction and
Treatment System, UniFirst Property, Wells G&H Superfund Site, Woburn, Massachusetts. May 2015.
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UniFirst, 2014a. Monthly Operation and Maintenance (O&M) Monthly Reports for UniFirst Source Area
Property (Site).
Monthly O&M Report for September 2014. October 7, 2014.
Monthly O&M Report for October 2014. November 6, 2014.
Monthly O&M Report for November 2014. December 5, 2014.
UniFirst, 2015a. Monthly Operation and Maintenance (O&M) Monthly Reports for UniFirst Source Area
Property (Site).
Monthly O&M Report for December 2014. January 9, 2015.
Monthly O&M Report for January 2015. February 6, 2015.
Monthly O&M Report for February 2015. March 6, 2015.
Monthly O&M Report for March 2015. April 7, 2015.
Monthly O&M Report for April 2015. May 8, 2015.
Monthly O&M Report for May 2015. June 5, 2015.
Monthly O&M Report for June 2015. July 6, 2015.
Monthly O&M Report for July 2015. August 7, 2015.
Monthly O&M Report for August 2015. September 4, 2015.
Monthly O&M Report for September 2015. October 9, 2015.
Monthly O&M Report for October 2015. November 6, 2015.
Monthly O&M Report for November 2015. December 4, 2015.
UniFirst, 2015. RD/RA Year 23 Annual Report for the UniFirst Site, Remedial Action at the Northeast Quadrant
of the Wells G&H Site, Woburn, Massachusetts. November 13, 2015.
UniFirst, 2016a. Monthly Operation and Maintenance (O&M) Monthly Reports for UniFirst Source Area
Property (Site).
Monthly O&M Report for December 2015. January 6, 2016.
Monthly O&M Report for January 2016. February 8, 2016.
Monthly O&M Report for February 2016. March 11, 2015.
Monthly O&M Report for March 2016. April 8, 2016.
Monthly O&M Report for April 2016. May 9, 2016.
Monthly O&M Report for May 2016. June 6, 2016.
Monthly O&M Report for June 2016. July 7, 2016.
Monthly O&M Report for July 2016. August 8, 2016.
Monthly Progress Report for August 2016. September 2, 2016.
Monthly O&M Report for September 2016. October 7, 2016.
Monthly O&M Report for October 2016. November 4, 2016.
Monthly O&M Report for November 2016. December 8, 2016.
UniFirst, 2016. RD/RA Year 24 Annual Report for the UniFirst Site, Remedial Action at the Northeast Quadrant
of the Wells G&H Site, Woburn, Massachusetts. November 15, 2016.
UniFirst, 2017a. Monthly Operation and Maintenance (O&M) Monthly Reports for UniFirst Source Area
Property (Site).
Monthly O&M Report for December 2016. January 6, 2017.
Monthly O&M Report for January 2017. February 7, 2017.
Monthly O&M Report for February 2017. March 8, 2017.
Monthly O&M Report for March 2017. April 4, 2017.
Monthly O&M Report for April 2017. May 4, 2017.
Monthly O&M Report for May 2017. June 2, 2017.
Monthly O&M Report for June 2017. July 6, 2017.
Monthly O&M Report for July 2017. August 4, 2017.
Monthly O&M Report for August 2017. September 7, 2017.
6
-------
Monthly O&M Report for September 2017. October 2, 2017.
Monthly O&M Report for October 2017. November 3, 2017.
Monthly O&M Report for November 2017. December 7, 2017.
UniFirst, 2017. RD/RA Year 25 Annual Report forthe UniFirst Site, Remedial Action at the Northeast Quadrant
of the Wells G&H Site, Woburn, Massachusetts. November 15, 2017.
UniFirst, 2018a. Monthly Operation and Maintenance (O&M) Monthly Reports for UniFirst Source Area
Property (Site).
Monthly O&M Report for December 2017, January 3, 2018.
Monthly O&M Report for January 2018. February 2, 2018.
Monthly O&M Report for February 2018. March 2, 2018.
Monthly O&M Report for March 2018. April 6, 2018.
Monthly O&M Report for April 2018. May 4, 2018.
Monthly O&M Report for May 2018. June 6, 2018.
Monthly O&M Report for June 2018. July 2, 2018.
Monthly O&M Report for July 2018. August 3, 2018.
Monthly O&M Report for August 2018. September 5, 2018.
Monthly O&M Report for September 2018. October 3, 2018.
Monthly O&M Report for October 2018. November 8, 2018.
Monthly O&M Report for November 2018. December 4, 2018.
UniFirst, 2018. RD/RA Year 26 Annual Report for the UniFirst Site, Remedial Action at the Northeast Quadrant
of the Wells G&H Site, Woburn, Massachusetts. December 17, 2018.
UniFirst, 2019. Monthly Operation and Maintenance (O&M) Monthly Reports for UniFirst Source Area Property
(Site).
Monthly O&M Report for December 2018. January 4, 2019.
Monthly O&M Report for January 2019. February 8, 2019.
Monthly O&M Report for February 2019. February 7, 2019.
Woodard & Curran, 2016. Revised Deeper Bedrock Investigation Work Plan. New England Plastics Corporation.
January 2016.
Woodard & Curran, 2017a. Groundwater Monitoring Report. New England Plastics Corporation. September
2017.
Woodard & Curran, 2017b. Groundwater Investigation Report - Deeper Bedrock. New England Plastics
Corporation, April 2017.
7
-------
Appendix B
Additional Data Tables, Figures and Exhibits
-------
Tables
-------
Table la : ROD Cleanup Levels for Soil Based on Leaching to
Groundwater (jig/kg)
Chloroform
62.5
Tetrachloroethene
36.7
Trichloroethene
12.7
trans-1,2-Dichloroethene
83.2
1,1,1 -Trichloroethane
613
Table lb : ROD Cleanup Levels for Soil Based on Direct
Contact (mg/kg)
Chlordane
6.14
4,4'-DDT
235
Carcinogenic PAHs
0.694
PCBs
1.04
Lead
640
Table lc : ROD Cleanup Levels for Groundwater used as
Drinking Water (jug/L)
Chloroform
100
1,1 -Dichloroethane
5
1,2-Dichloroethane
5
1,1 -Dichloroethene
7
Tetrachloroethene
5
Trichloroethene
5
Vinyl chloride
2
trans-1,2-Dichloroethene
70
1,1,1 -Trichloroethane
200
-------
Table 2 : Current Maximum Groundwater Contaminant Concentrations Above ROD Cleanup Levels by Property
Since Last 5 Year Review
Source Area
Property
Contaminant
ROD
Cleanup
Level
Well Location
(Maximum
Detection)'1'
Date of
Current
Maximum
Detected
Concentration
Maximum
Detected
Concentration
During 2014
FYROig/L)
Current
Maximum
Detected
Concentration
0ig/L)(2)
Grace
cis-l,2-DCE
70
RW-22RE
5/23/2018
150
180
TCE
5
G16S
5/22/2018
68
91
PCE
5
RW-19
5/22/2018
15
19(4)
Vinyl Chloride
2
G1DB3
5/22/2018
ND(<4.0)(3)
2.1
UniFirst
cis-l,2-DCE
70
UC10-1
5/30/2018
370
230 J
TCE
5
UC7-2
5/30/2018
380
440
PCE
5
UC7-2
5/30/2018
2,900
2,500
NEP
TCE
5
NEP-A
12/19/2016
—
38
PCE
5
NEP-A
12/19/2016
15(5)
12
Wildwood
cis-l,2-DCE
70
WW203
10/18/2018
—
1,500
TCE
5
WW207
10/18/2018
11,200
21,000
PCE
5
WW200D
4/10/2018
—
113
Vinyl Chloride
2
WW202
4/10/2018
—
364
TCA
200
WW207
10/18/2018
—
510
Olympia
cis-l,2-DCE
70
MW-211D
3/23/2018
1,100
9,200
TCE
5
MW-217M
6/22/2018
8,200
5,700
PCE
5
MW-207S
3/23/2018
210
22
Vinyl Chloride
2
MW-211D
3/23/2018
74
530
Chloroform
100
MW-213
10/5/2015
...
120
Notes:
cis-l,2-DCE = cis-l,2-dichloroethene
PCE = Tetrachloroethene
TCE = Trichloroethene
TCA = 1,1,1-Trichloroethane
— = Not detected above ROD cleanup level during 2014 FYR. Data was not available for deep bedrock groundwater on NEP property.
(1) On-Property well with maximum concentration during most recent monitoring event during this FYR Period.
(2) Based upon the most recent monitoring event. Higher (or lower) concentrations may have been reported earlier during this FYR period.
(3) The highest detection limit is listed as vinyl chloride could potentially have been present at these locations above the ROD cleanup level.
(4) The PCE detected in RW-19 appears to be attributable to the off-site source.
(5) Three deeper bedrock wells exhibited higher concentrations of PCE/TCE than the most recent data from overburden or shallow bedrock wells.
-------
Table 3: Maximum Detected Concentrations of Tetrachloroethene (jig/m ) at Building Immediately
West/Downgradient of the UniFirst Property
Medium
2011
2013
2014
2015
2016
2017
2018
2019
Subslab Soil
Gas
5730
3390
2830
2090
2870
1840
2370
1790
Indoor Air
1.23
1.02
1.57
0.841
0.888
0.698
0.665
0.617
-------
Table 4 : Comparison of Maximum Detected Shallow Groundwater VOC Concentrations to Screening Levels
Detected Analyte
Maximum Groundwater
Concentration (fig/L)
2012/2013
Maximum Groundwater
Concentration (fig/L)
2017/2018
Vapor Intrusion Screening Level
(Jig/L)
UniFirst Data Compared to Commercial Screening Levels
1,1,1-T richloroethane
1.3
6.8
31,100
cis-1,2-Dichloroethene
16
ND (0.5)
NA
T etrachloroethene
2,900
110
65
Trichloroethene
18
ND (0.5)
7.4
NEP Data Compared to Commercial Screening Levels
Tetrachloroethene | 15 | 6.8 | 65
Downgradient of/Near UniFirst and Grace Properties Data Compared to Residential Screening Levels
T etrachloroethene
22
22
15
Trichloroethene
0.82
0.84
1.2
Grace Data Compared to Commercial Screening Levels
Chloroform
ND (3.0)
1.9
4
cis-1,2-Dichloroethene
150
180
NA
trans-1,2-Dichloroethene
0.83
2.2
NA
T etrachloroethene
15
19
65
Trichloroethene
68
91
7.4
Notes:
(a) Values from EPA's Vapor Intrusion Level Screening Level Calculator (https://epa-visl.ornl.gov/cgi-bin/visl_search).
The screening concentrations corresponding to a cancer risk of 1x10 6 and noncancer hazard of 1.
NA - Not available.
-------
Table 5
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
Olympia Property
Wildwood Property
SB-9
0-2
37.11
OL-SS01
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
SS-1
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
SB4
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
SB6
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-5
10-12
1.6 U
SB8
0-2
3.4
SB12
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
SB14
0-2
13.2
ECS-9
10-12
1.55 U
Average
51.6
SB15
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
SB5
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
OL1-01
Subsurface
122
SB12
2-4
1.7
Average
117.5
OL2-01
Subsurface
44
SB13
2-4
2.7
NE1-01
Subsurface
4.6
OL2-02
Subsurface
9.8
SB14
2-4
1.5
NE1-02
Subsurface
5.2
OL2-03
Subsurface
8.5
SB15
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
OL5-01
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
U - Not detected above listed reporting limit
Full reporting limit used in 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 presented are confirmation sample results, collected after sludge removal activities were completed.
-------
Figures
-------
AECOM
C TRC
Wannalancit Mills
650 Suffolk Street
Lowell, MA 01852
978-970-5600
QUADRANGLE
LOCATION
TRCPROJ.NO.: 104161
EPA CONTRACT NO.: EP-S1-06-01
SUBCONTRACT NO.: 3493
0 1000 2000 3000
FIGURE 1
LOCATION MAP
WELLS G&H
SUPERFUND SITE
WOBURN, MASSACHUSETTS
BASE MAP IS A PORTION OF THE
FOLLOWING 7.5' USGS
TOPOGRAPHIC QUADRANGLE:
BOSTON NORTH, 1985
-------
N
A
Figure 2
0U1 Five Source Area
Properties
Wells G&H Superfund Site
Legend
© Wells G&H
L"3 Site Boundary
Source Area Property
\/A Drum Disposal Area
Building Footprint
Woburn Parcel
Aberjona River
2,000
Feet
i Wetland
Source Data: MassGIS
-------
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ALL SIX AREA 2 EXTRACTION WELLS (RW7 THROUGH RW12)
AND SEVEN AREA 3 EXTRACTION WELLS (RW13 THROUGH RW16,
RW18, RW19 AND RW21) WERE SHUT DOWN ON JUNE 2, 2015.
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.
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M.P.
Approved
s.s.
Seal* In Feet (Approjimete)
K57DC? K57M
Groundwater & Environmental Services. Inc.
-------
SDE-6
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LEGEND
Property line
Building footprint
Approximate location of block wall
Fenceline
Concrete retaining wall
Wood retaining wall
Water line
Sewer line
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 (SVM) point location
2014 soil vapor extraction (SVE) point location
2014 passive air injection point location
2014 soil vapor monitoring (SVM) point location
2014 sub—slab soil vapor monitoring location
3.75 7,5
15
SCALE IN FEET
Notes:
1. Base map prepared by Col-East, Inc. of North Adams,
MA. at a scale of 1 inch = 100 feet from April 1990
aerial photographs modified after Martinage Engineering
Associates, Inc. Nov.2, 1992. All property lines are
approximate. Well locations from a survey by BSC Group
of Boston, MA.
2. Interior building information from an undated Layout
Drawing of the Extra Space Storage Operation provided
to UniFirst Corp.
3. SVE, SVM, SV, and PI point locations based on field
survey by The Johnson Company.
4. All locations are approximate.
K:\1-2114-2\CAD\Annual Report 2015\Figure 6.dwg
TDD
mnnmn
can ~~~~
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SB02D229-4600
DrnnnnmnMLn
ccna nmnLL
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smool" ~ 15n Prnmmi -2114-2
FIGURE 4: SVET SYSTEM
EXTRACTION AND MONITORING POINT LOCATIONS
UNIFIRST PROPERTY
WOBURN, MASSACHUSETTS
-------
K:\1-2114-2\CAD\Well Installation Work Plan\Figure 4 - New V\fell Locations, mxd
Legend
Proposed Extraction Well Installation Location
Proposed Piezometer Installation Location
Unconsolidated Deposits Monitoring Well Location
Bedrock Monitoring Well Location
- Roads
| Buildings
Property Boundary
DP36
UC10-1
UC10-2
UC10-3
UC10-4
UC10-5
UC10-6
UC10D
|UC10S
UC10M
UC19M
UC19S
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UC9-2
' ~^r"UC9-3
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nrg-c
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UC17
UC19
K42M
'K42S
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• •
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UC33
UC31S
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UC32
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Ł UC16
#UC25
UC29D
UC26S
UC26D
UC15
UC15S
UC15D
UC6S
S71D
UC30
UG18
UG17
UG10
UG20
FIGURE 4: PROPOSED EXTRACTION WELL
AND PIEZOMETER IN^MIaTION LOCATIONS
Uni @Rd)MHIitocations
WOBURN, MASSACHUSETTS
100 State Street, Suite 600
Montpelier, VT 05602
The
Johnson
Company
Drawn by: DPB
Revised by: TJK
Date: 02/26/13
Date: 04/28/14
Scale: 1 " = 80 feet Project: 1 -2114-2
-------
Path: J:\Jobs\Rem Enq\Proiect Fiies\Beatrice\Southwest Properties\7.0 Project Documents\7.2 CADD-GIS\GIS\Proiects\Q&M Report\Year 15 16 Annual Report\Ficiure 1 2 wildwood property well GH superfund site.mxd
DRAWING NAME: J:\Projects\104161\cad\fig6_sitelayout.dwg - PLOT DATE: February 28, 2019 - 10:54AM - LAYOUT: 11X17P
-------
Legend
-0- Monitoring Wells
Off-Property Shallow Overburden Well Location
Former Bedrock Production Wells
-0- Deep Bedrock Wells
1,260
— 1988 concentration, ug/L
316
— 1989 concentration, ug/L
1,020
— 1990 concentration, ug/L
104
— 1992 concentration, ug/L
544
—1996 concentration, ug/L
209
—1998 concentration, ug/L
43
—1999 concentration, ug/L
10
-j| 2000 concentration, uq/L
11
2001 concentration, ug/L
6
2002 concentration, ug/L
6
— 2003 concentration, ug/L
6
— 2004 concentration, ug/L
nd
— 2005 concentration, ug/L
6
— 2006 concentration, ug/L
nd
— 2007 concentration, ug/L
nd
— 2008 concentration, ug/L
1.8 U
— 2010 concentration, ug/L
6.5
— 2011 concentration, ug/L
2.8
— 2013 concentration, ug/L
2.6
— 2015 concentration, ug/L
2.8
— 2017 concentration, ug/L
Operation of AS/SVE Remedy
Tem inatal on March 7,2000
Notes:
- Indicates not sampled
nd Indicates not detected
U Non-Detect at reported concentration
based on data quality assessment (2010 only)
1. Bedrock wells were not sampled prior to 1988. NEP-109B was destroyed in
1993 and decommissioned in 2001. NEP-102B was paved over in 1996.
2. In October 2011, concentrations of methyl tert-butyl ether (MTBE; a non-chlorinated
VOC) were also detected in overburden well NEP-107B at 18 ug/l.
3. Basemap inferred from MassGIS Orthophotography, 2008.
37 5
75
150
I Feet
-------
-------
Exhibits
-------
Exhibit 1
Wells Sampled During FYR Period
Wildwood Property
Shallow Overburden
BSSW-5
BSSW-6
BOW-8
BW-208
BOW-10
BOW-14
BSSW-15
BSSW-17
S77SS
S92S
S95S
WW-204
WW-205S
WW-207
WW-208S
Intermediate Overburden
BSW-1
BW-206
BSW-6
BSW-8
BSW-9
BSW-10
BSW-12
BSW-13
BSW-14
BOW-16
S77S
S92I
S92M
S95M
WW-102IO
WW-200S
WW-200D
WW-201
WW-203
WW-205D
WW-206
WW-208D
WW-209
WW-210S
WW-211S
WW-212
WW-213
Deeper Overburden
BW-5
BCW-8
BCW-10
BW-11
BCW-14
S77M
S92D
WW-202
WW-210D
WW-211D
Till
BOW-6
BCW-13
BCW-15
BCW-18
S77D
S95D
Shallow Bedrock
BW-5R
BW-6R
BW-8
BW-9
BW-10
BW-13
BW-14
BW-15RP
BW-17R
BW-19R (recovery
well)
S77SR
S92SR
S95SR
WW100SR
WW101SR
PW-1 (recovery
well)
PW-2 (recovery
well)
PW-3 (recovery
well)
Deeper Bedrock
BW-6RD(LO)
BW-14RD
BW-18RD(LO)
(recovery well)
S92DR
Note:
Bold indicates well was included in expanded monitoring event completed during 2018.
-------
G1D6
G20S
ND(O.SO)
(G1DfaG1S
G1DB3
G20M
2.6
RW22RE
34
/G19S
' G19M
13 0
i l\ #G20D
| |ND(0.50)
UG13
ND(O.SO)
G19D
® G17D
G37D
5,3
G16S-.G16D
88 '0.92
91 D
G12D
ND(0.50)
RW12 \
ND(0.50J
I ® G22D
ND{0.60)
G13S ©#G13D
ND(O.SO) 39
(UG19
ND(0.50)
G36DB2«|
G36DBR1
y G40S ^vG40D
ND(0.50) 9 6
RW20
'P05S
RW21
ND(0.50)
lP02S J
>P02D '
P03D
UG14
ND{0.50)
UG16
0 84
• DP40
G39S _ G39D.
ND(0.50) 5.0
UG15
ND(0.5Q)
IDP24S
K62M L \
ND<°-5°)K60S
K55M
K60MI
O
&
o
a.
RW7 • RECOVERY WELL LOCATION
ruCi MONITORING WELL SCREENED IN THE UNCONSOLIDATED
G36S DEPOSITS
UG19. monitoring well screen in the unconsolidated
DEPOSITS AND BEDROCK
G39D* MONITORING WELL SCREENED IN THE BEDROCK
WATER QUALITY DATA
2.3 D TRICHLOROETHENE (TCE)
I
L DUPLICATE SAMPLE
CONCENTRATIONS IN ug/L
ND(1) = NONDETECT AT REPORTING LIMIT
SAMPLES COLLECTED BETWEEN MAY 22 AND MAY 23, 2018
< APPROXIMATE FLOW DIRECTION
12 CONCENTRATION GREATER THAN MCL/ROD CLEANUP
LEVEL FOR TCE (5 ug/L)
ESTIMATED REGION GREATER THAN 5 ug/L BASED ON
MAY 2018 CONCENTRATIONS
- - - ESTIMATED UNCONSOLIDATED DEPOSITS CAPTURE ZONE
ESTIMATED SHALLOW BEDROCK CAPTURE ZONE
STREAM
WETLANDS
FORMER BUILDING
APPROX FORMER W R GRACE PROPERTY BOUNDARY
STREAM GAUGE
ND(0.S0)
TRE TMEN X
Vn ^ //
xhibit
PLAN VIEW OF TRICHLOROETHENE DISTRIBUTION
IN UNCONSOLIDATED DEPOSITS AND SHALLOW
BEDROCK GROUNDWATER MAY 2018
W.R. GRACE
WOBURN MA
12/13/1S
Approved
Groundwater & Snvironrnental Services. Inc.
-------
Exhibit 3
MCL =
o
O
O
O
u
o
o
o
O
O
a
fD
fD
fD
n>
fD
ro
fD
fD
fD
fD
fD
n
O
n
n
n
r>
n
o
n
n
n
O
O
O
O
O
h-4
M
h*
M
Ln
01
00
ID
o
NJ
UJ
4*
Ln
Date
Notes: Compounds reported as ND are plotted at the reporting limit
(RL) as red symbols. Breaks in lines indicate ND with unknown RL.
Where there are multiple detected results on the same day, the minimum and maximum detections are plotted.
Where there is a nondetect at a lower RL than the minimum detection, the nandetect is also plotted.
RW19 Time vs Concentration Plot
-------
LEGEND
WATER QUALITY DATA
3.2 D TETRACHLOROETHENE (PCE)
L DUPLICATE SAMPLE
CONCENTRATIONS IN ug/L
ND(1) = NONDETECT AT REPORTING LIMIT
SAMPLES COLLECTED BETWEEN MAY 22 AND MAY 23, 2018
¦4 APPROXIMATE FLOW DIRECTION
1f) CONCENTRATION GREATER THAN MCL/ROD CLEANUP
LEVEL FOR PCE (5 ug/L)
ESTIMATED REGION GREATER THAN 5 ug/L BASED ON
MAY 2018 CONCENTRATIONS
- - - ESTIMATED UNCONSOLIDATED DEPOSITS CAPTURE ZONE
- - - ESTIMATED SHALLOW BEDROCK CAPTURE ZONE
STREAM
WETLANDS
FORMER BUILDING
APPROX FORMER WR GRACE PROPERTY BOUNDARY
STREAM GAUGE
ND(O.SO)
PLAN VIEW OF TETRACHLOROETHENE
DISTRIBUTION IN UNCONSOLIDATED DEPOSITS AND
SHAlIOWBEDROCK GROUNDWATER MAY 2m
W.R. GRACE
WOBURN, MA
12/13/18
• DP12
Approved
Groundwater & Environmental Setv?ces. Irvc
-------
Exhibit 5
Cis-1,2-Dichloroethene Trend
in Recovery Well RW-22RE
GSI MANN-KENDALL TOOLKIT
for Constituent Trend Analysis
Evaluation Date:
Facility Name:
Conducted By:
Job ID:
Constituent:
Concentration Units:
Sampling Point ID: I RW22RE Ave I RW22RE Max |~
13
CDCE CONCENTRATION (ug/L)
1
Jun-15
245
270
2
3-Jun-16
205
220
3
2-Jun-17
200
200
4
23-May-18
180
180
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Notes:
1. At least four independent sampling events per well are required for calculating the trend. Methodology is valid for 4 to 40 samples.
2. Confidence in Trend = Confidence (in percent) that constituent concentration is increasing (S>0) or decreasing (S<0): >95% = Increasing or Decreasing;
> 90% = Probably Increasing or Probably Decreasing; < 90% and S>0 = No Trend; < 90%, S<0, and COV > 1 = No Trend; < 90% and COV < 1 = Stable.
Methodology based on "MAROS: A Decision Support System for Optimizing Monitoring Plans", J.J. Aziz, M. Ling, H.S. Rifai, C.J. Newell, and J.R. Gonzales,
Ground Water, 41(3):355-367, 2003.
DISCLAIMER: The GSI Mann-Kendall Toolkit is available "as is". Considerable care has been exercised in preparing this software product; however, no party, including without
limitation GSI Environmental Inc., makes any representation or warranty regarding the accuracy, correctness, or completeness of the information contained herein, and no such
party shall be liable for any direct, indirect, consequential, incidental or other damages resulting from the use of this product or the information contained herein. Information in
this publication is subject to change without notice. GSI Environmental Inc., disclaims any responsibility or obligation to update the information contained herein.
GSI Environmental Inc., mm.gsi-net.com
-------
Exhibit 6
Figure 9: SVET System - Estimated Cumulative Mass Removal by SVE Points
UniFirst Property
Woburn, Massachusetts
Oct-14 Feb-15 Jun-15 Oct-15 Feb-16 Juri-16 Oct 16 Feb-17 Jun-17 Oct-17 Feb-18 Jun-18 Oct-18
Date
-4- SVE-2A SVE-3A -B-SVE-4A —H—SVE-1 -S-SVE-5 -©-SVE-6
-------
Exhibit 7
Figure E: SVET System - Total VOC Concentrations at SVE Points
UniFirst Property
Woburn, Massachusetts
Oct-14 Jan-15 Apr-15 Jul-15 Oct-15 Jan-16 Apr-16 Jul-16 Qct-16 Jan-17 Apr-17 Jul-17 Oct-17 Jan-18 Apr-18 Jul-18 Oct-18
Date
-•-SVE-l —SVE-2A —A— SVE-3A -B-SVE 4A —B SVE 5 SVE-6
-------
Exhibit 8
PCE and TCE in UniFirst Well UC5
Date
PCE —~—TCE
-------
Exhibit 9
PCE in UniFirst Well UC18
Date
-------
Exhibit 10
TCE in UniFirst Well UC26D
100
ClO
3
c
o
'¦4->
TO
¦M
c
O)
u
c
o
u
10
0.1
Cleanup Level = 5 pig/L
&
,CV
$y
&
&
a
-------
Note: Groundwater elevations at
BW-6RD-UP and the pumping
wells BW-18RD-LO, PW-1, PW-2
and PW-3 were not used to develop
contours based on professional
judgement.
J ^ \a/fi i "n"
Note: Groundwater elevations at
BW-11, BSW-12, BCW-13, PZ-1A/B
BSW-9, and BCW-8 were not used
to develop contours based on
professional judgement.
WILDWOOD PROPERTY
WILDWOOD PROPERTY
WILDWOOD PROPERTY
WELL "G"
WELL "G"
S92M
43.10
S92DR
43.09
v\
S78(R)
43.01 ^
BOW-14^
43.80
BW-14 r^\
42 84 WW-100SR
/ l~ 43.33 J
BSSW-15
43.35
,STAFI^
GAUGE
42.28
¦S95D,
42-80
^ BOW-10
\\'43.06
S95M
''42.73
BOW-6
42.98
BSSW-6
43.03
BSSW-17
42.90
t BMW-17
\T~ 37.96
-S77D
42.56:
S77M
42.62
\ r
BOW-9
44*12
BOW-8
42.80
;#0W-8
41.92
BSSW-16
42.45
BOW-16
42.59
BSSW-5
42.75
ABERJONAAUTO PARTS
PROPERTY
ABERJONAAUTO PARI
PROPERTY
ABERJONAAUTO PARTS
PROPERTY
TREATMENT BUILDING
TREATMENT BUILDING
TREATMENT BUILDING
RILEY WELL 2
RILEY WELL 2
RILEY WELL 2
1978 ADDITION
1978 ADDITION
1978 ADDITION
FLOOR DRAIN
FLOOR DRAIN
FLOOR DRAIN
OIL/WATER
SEPERATOR
OIL/WATER
SEPERATOR
OIL/WATER
SEPERATOR
FORMER
\ BEDROCK ^Xkibit/l
X X ON GRADE X y /
SHALLCT/'OVERBURDEN
INTERMEDIATE AND DEEP OVERBURDEN
CONCRETE SLAB,
Q
X
o6
O
Q_
W
(D
W
(D
6
o
<
o
AECOM
Monitoring Well with
Groundwater Elevation
Low Groundwater
Contour
= = Treatment Cell
Stream/Waterbody
Interpreted Capture Zone
based on October 2015 data
— - Southwest Properties
Road
NM Not Measured
Railroad
Sewer Line w-
Fence s
WELLS G & H
WILDWOOD PROPERTY
WOBURN, MA
FIGURE 1
LOW GROUNDWATER CONTOURS
OCTOBER 26, 2015
DATE: 7/5/2017 |3RWN: JB
PROJECT 60160533
-------
Exhibit 12
100000
TCE Concentration in Bedrock Well BW-6R
Wildwood
00
cn
o
*—i
rsi
cn
LD
00
cr>
cn
o
o
O
o
o
o
o
o
o
o
*—i
*—i
*—i
r—i
r—i
*—i
*—i
*—i
*—i
cn
cn
o
o
O
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
*—i
*—i
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
*—i
*—i
*—1
*—1
*—i
*—i
*—1
*—1
*—1
*—i
*—1
*—i
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
CO
CO
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
cn
Date
-------
Exhibit 13
TCE Concentration in Deep Bedrock Well
BW-6RD(LO) - Wildwood
W>
C
O
+-•
fD
Q)
U
c
o
u
100000
10000
1000
100
10
00
CD
O
O
*—1
CN
CO
LD
UD
00
CD
o
*—1
*—1
CN
CO
LD
UD
CD
CD
O
o
O
O
o
O
O
o
o
O
O
*—1
*—1
*—1
*—1
*—1
*—1
*—1
r—1
*—i
CD
CD
O
o
o
O
o
O
O
o
o
O
O
o
O
O
O
o
o
O
O
o
*—1
*—1
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
CO
CN
*—1
CN
*—1
O
CD
00
UD
LD
CO
CN
*—1
CN
*—1
o
CD
00
UD
*—1
*—1
*—1
*—1
*—1
*—1
Date
-------
Exhibit 14
TCE Concentration in Bedrock Well BW-8
Wildwood
00
cr>
cr>
o
T—1
CM
no
LO
<Ł)
1^
00
cr>
cr>
o
T—1
CM
no
LO
<Ł)
cr>
cr>
cr>
o
o
O
O
O
o
o
o
o
o
O
o
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
cr>
cr>
cr>
o
o
O
O
O
o
o
o
o
o
O
o
o
o
o
o
o
o
o
o
T—1
T—1
T—1
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
no
T—1
T—1
cr>
1^
LO
no
T—1
T—1
cr>
1^
LO
no
T—1
T—1
cr>
1^
LO
no
T—1
T—1
cr>
1^
T—1
T—1
T—1
T—1
Date
-------
80
70
60
50
40
30
20
10
0
Exhibit 15
TCE Concentration in Till Well BCW-13 -
Wildwood
00
CD
CD
O
*—1
CN
CO
LO
UD
00
CD
CD
O
*—1
CN
CO
LD
UD
CD
CD
CD
o
O
o
o
o
o
o
O
o
O
O
O
*—1
*—1
*—i
*—1
*—1
*—1
*—1
*—1
CD
CD
CD
o
o
o
o
o
o
o
O
o
o
O
O
o
O
o
O
o
o
O
O
*—1
*—1
*—1
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
CN
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—i
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
*—1
CO
*—1
*—1
CD
LD
CO
*—1
*—1
CD
LO
CO
*—1
*—1
CD
LD
CO
*—1
*—1
CD
*—1
*—1
*—1
*—1
Date
-------
Exhibit 16
TCE Concentration in Bedrock Well BW-15RP
Wildwood
W>
10000
1000
o
+-•
fU
¦S 100
0)
u
c
o
u
10
oo
CT>
CT>
CT>
CT>
CT>
O
O
O
CM
O
O
CM
CM
O
O
CM
m
o
o
CM
O
O
CM
LO
O
O
CM
UD
O
o
CM
1^
O
O
CM
00
O
O
CM
CT>
O
O
CM
O
CM
O
CM
cm m
o
CM
o
CM
O
CM
LO UD
O
CM
O
CM
O
CM
T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I T—I
mmmmmmmmmmmmmmmmmmmm
Date
-------
Exhibit 17
TCE Concentration in Deep Bedrock Well
BW018RD(LO) - Wildwood
1000000
_ 100000
W)
c
O
+-•
CO
&_
+J
C
0)
u
c
o
u
10000
1000
100
10
oo
O)
O
o
T—1
fN
m
lD
UD
oo
O)
o
T—1
T—1
fN
m
LD
UD
(J)
o
o
o
o
o
o
o
o
o
o
o
t—i
T—1
T—1
T—1
v—1
T—1
v—1
t—1
t—i
(J)
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
O
o
v—1
v—1
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
fN
t—1
T—1
T—1
T—1
T—1
T—1
t—i
T—1
T—1
T—1
t—i
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
T—1
no
fN
T—1
fN
T—1
o
O)
oo
UD
LD
m
fN
T—1
fN
T—1
o
O)
oo
UD
T—1
T—1
T—1
T—1
T—1
T—1
Date
-------
Exhibit 18
TCE Concentration in Bedrock Well BW-19R
Wildwood
10000
CuO 1000
o
* 100
0)
u
c
o
u
10
00
cr>
cr>
o
no
cr> o
cr> o
cr> o
T—I C\|
o
no
O
no
O
O
CM
O
no
CM
O
O
CM
O
no
no
O
O
CM
O
no
O
O
CM
O
no
LO
o
o
CM
O
no
<Ł)
o
o
CM
O
no
O
O
CM
O
no
00
o
o
CM
O
no
cr>
O
O
CM
o
no
O
CM
O
no
O
CM
O
no
CM
T—I
o
CM
O
no
no
T—I
o
CM
O
no
O
CM
O
no
LO
T—I
o
CM
O
no
(Ł)
T—I
O
CM
O
no
O
CM
O
no
mmmmmmmmmmmmmmmmmmmm
oo
T—I
o
CM
O
no
no
Date
-------
Exhibit 19
PCE & TCE Concentrations in Overburden Well BW-
206
100000
10000
C
o
+j
CO
&_
+J
C
0)
u
c
o
u
A fSo tSo \\
^
AV av aV Av /\V aV AV a^
o\N ^fe\N
•y
Date
•v
,\v
'PCE
¦TCE
-------
Dath: P:\Jobs\Rem Enq\Proiect Files\Beatrice\Southwest Properties\7.0 Project Documents\7.2 CADD-GIS\GIS\Proiects\Wildwood ProperhAMIP HPT Investigation Summarv\MXD\Fiq 2 Overburden MIP HPT Investigation Summary TCE Concen.mxd
-------
Exhibit 21
GSI MANN-KENDALL TOOLKIT
for Constituent Trend Analysis
Evaluation Date:
Facility Name:
Conducted By:
20-Jul-17
New England Plasties
SHS
Job ID:
230322
Constituent: jPCE (Overburden Wells)
Concentration Units:
ug/L
Sampling Point ID: j
EPA-1
tW!
NEP-101
NEP-104 I NEP-108 T
Sampling
Event
Sampling
Date
ICE (OVERBURDEN WELLS) CONCENTRATION (ug/L
)
1
Aua-98
26.0
3.0
26.0
10.0
25
2
Aua-99
15,0
7.0
18.0
330
2 5
3
Aua-00
9.0
2.0
16.0
2 5
2,5
4
Jul-01
7.0
3.0
24.0
2 5
2 5
5
Jul-02
7.0
4.0
36.0
2.5
25
6
Jul-03
25
17.0
14.0
2.5
2.5
7
Jul-04
6.0
10.0
40,0
2.5
2 5
8
Jul-05
2.5
25
11.0
2.5
2.5
g
Jul-06
25
16.0
5.0
2.5
2 5
10
Jul-07
25
2.5
12.0
2 5
25
11
Jul-08
25
2.5
10.0
2.5
2.5
—1
12
Oct-10
3.3
i S
68,0
~ n 5
b
13
Apr-11
25.0
iDecreasec
1
14
Oct-11
2.7
6.6
15,0
0 5
0 5
15
Jul-13
3.2
6,3
15,0
05
0.5
Concentrations
over past 5 years
16
Jul-15
2,7
5.9
11,0
0.5
05
17
18
Jul-17
2.2
4.3
6.8
0.5
19
f
20
/
Coefficient of Variation:
0.57
0.83
0.80
1.88
0.51
Mann-Kendall Statistic (S):
-35
2
-25
-72
-55
Confidence Factor:
96.9%
52.2%
88.0%
100.0%
99.3%
— -"-oasnm.
HBBMUB
Concentration Trend:
Decreasing
No Trend
Stable
Decreasing
Decreasing
i
10/95 07m 04/01 01/04 10/06 07/09 04/12
Sampling Date
12/14 03/17
0S/20
Notes:
1. At least four independent sampling events per well are required for calculating the trend Methodology is valid for 4 to 40 samples
2. Confidence in Trend = Confidence (in percent) that constituent concentration is increasing (S>0) or decreasing (S<0) >95% = Increasing or Decreasing;
z 90% = Probably Increasing or Probably Decreasing, < 90% and S>0 = No Trend, < 90%, SsO, and COV * 1 = No Trend, < 90% and COV < 1 = Stable.
3. Methodology based on "MAROS A Decision Support System for Optimizing Monitonng Plans", J.J. Aziz, M. Ling, H.S. Rifai, C.J. Newell, and J R. Gonzales,
Ground Water, 41 (3):355-367, 2003
4. For Non-Detect results, half of the detection limit was used for trend calculation.
DISCLAIMER: The GSI Mann-Kendall Toolkit is available "as is". Considerable care has been exercised in preparing this software product; however, no party, including without
limitation GSI Environmental Inc., makes any representation or warranty regarding the accuracy, correctness, or completeness of the information contained herein, and no such
party shall be liable for any direct, indirect, consequential, incidental or other damages resulting from the use of this product or the informatbn contained herein. Information in
this publication is subject to change without notice. GSI Environmental Inc., disclaims any responsibility or obligation to update the information contained herein.
GSI Environmental Inc., www gsi-nef com
-------
Exhibit 21 (continued)
ug/L
Sampling Point ID:
NEP-101B
NEP-104B
NEP-106B
NEP-108B
Sampling
Event
Sampling
Date
PCE (BEDROCK WELLS) CONCENTRATION (ug/L)
1
Auq-98
110.0
69.0
51.0
10.0
2
Aua-99
12.0
31.0
38.0
2 5
3
Aua-00
3.0
20.0
42.0
4.0
4
Jul-01
4.0
11.0
38.0
8.0
5
Jul-02
3.0
20.0
33.0
5.0
6
Jui-03
2.5
17.0
23.0
2.5
7
Ju!-04
6.0
20.0
23.0
6.0
8
Jul-05
11.0
2.5
6.0
9
Jul-06
6.0
9.0
2 5
6.0
10
Jul-07
7.0
18.0
11
Jul-08
25
2.5
14.0
5.0
12
Oct-10
09
1.3
11.0
2.1
13
Oct-11
6.5
7.9
14.0
2.8
14
Jul-13
2.8
8.0
3.8
2.1
15
Jul-15
2.6
5.7
4.0
0 5
16
Jul-17
2.8
5.5
3.4
0 5
17
18
19
20
Coefficient of Variation:
9.48 | 0.62
0.82 i 0.60
Mann-Kendall Statistic (S):
-10 j -57
-56 I -42 i
Confidence Factor:
68.6% " j'T^99.9%
99.9% ! I S9.5J4" f. 1"" " Kl
Concentration Trend:
1000
10
0.1
-NEP-101B
NEP-104B
NEP-106B
NEP-108B
ms 07/9$
04/01 01/04 ms 07/09 04/12
Sampling Date
12/14 OS/17
mo
Notes:
1. At least four independent sampling events per well are required for calculating the trend Methodology is valid for 4 to 40 samples
2. Confidence in Trend = Confidence (in percent) that constituent concentration is increasing (S>0) or decreasing (S<0): >95% = Increasing or Decreasing;
2 90% = Probably Increasing or Probably Decreasing; < 90% and S>0 = No Trend < 90%, SsO, and COV 11 = No Trend; < 90% and COV < 1 = Stable.
3. Methodology based on "MAROS. A Decision Support System for Optimizing Monitoring Plans", J.J. Aziz, M Ling, H.S. Rifai, C.J. Newell, and J.R. Gonzales.
Groundwater, 41 (3):355-367, 2003.
4. For Non-Detect results, half of the detection limit was used for trend calculation.
DISCLAIMER: The GSI Mann-Kendall Toolkit is available 'as is". Considerable care has been exercised in preparing this software product; however, no party, including without
limitation GSI Environmental Inc., makes any representation or warranty regarding the accuracy, correctness, or completeness of the information contained herein, and no such
party shall be liable for any direct, indirect, consequential, incidental or other damages resulting from the use of this product or the information contained herein. Information in
this publication is subject to change without notice. GSI Environmental Inc., disclaims any responsibility or obligation to update the information contained herein.
GSI Environmental Inc., www.gsi-net com
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
INSIDE CONTAINMENT CELL
OL-002
12/15/87
4-9'
41
3,100
(DUP)
12/15/87
09/16/97
33
8
3,400
3,700
3
<1
03/20/02
<120
7,900
<120
<120
OL-002 (Field Dup D02290)
03/20/02
<120
8,000
<120
<120
04/22/03
3
91
4
<1
06/02/03
<5
330
17
<5
04/14/05
<50
3,200
76
<100
04/22/08
0
<10
79
<10
<10
04/07/09
1
<3
41
<3
<3
OL-2
10/18/11
0
<20
37
22
<20
04/17/12
0
<10
52
14
<10
03/07/13
0
<2
22
15
<2
03/21/14
1
<5
2.5
5.4
<5
OL-2M
07/09/02
21.5-31.5'
<0.1
5
<2
<0.1
06/02/03
<0.5
<0.5
<0.5
<0.5
04/14/05
<1
<1
<1
<2
01/11/06
<25
1,600
<25
<25
02/09/06
<250
22,000
<250
<250
03/10/06
<25
1,800
<25
<25
04/24/06
<5
400
<5
<5
OL-2M (DUP-3)
04/24/06
07/19/06
<5
1
430
80
<5
<0.5
<5
<0.5
08/31/06
...
<1
34
<1
<1
09/28/06
...
0.7
25
<0.5
<0.5
12/14/06
0
0.8
37
<0.5
<0.5
03/28/07
0
6
260
<5
<5
04/24/07
0
<10
690
<10
<10
04/22/08
0
<0.5
3
<0.5
<0.5
04/07/09
1
1
2
<0.5
<0.5
03/07/13
0
<1
3.8
<1
<1
03/21/14
0
<1
7.1
<1
<1
10/05/15
0
<1
5.3
<1
<1
03/23/18
0
<1
19
1.9
<1
GEO-4
06/24/03
6-16'
...
<5
340
<5
<5
04/14/05
...
<50
2,500
<50
<100
07/19/06
0
<0.5
<0.5
<0.5
<0.5
04/07/09
2
<25
<25
<25
<25
03/07/13
2
<20
<20
<20
<20
03/21/14
3
<10
36
<10
<10
TEST-1
07/09/02
1.8-16.8'
...
14
12,000
15
2
TEST-1 (Field Dup DO2947)
07/09/02
...
15
12,000
15
2
06/02/03
3
1,300
130
3
06/24/03
<5
400
53
<5
04/14/05
<50
3,500
390
<100
TEST-1 (DUP-5)
04/14/05
<50
3,600
400
<100
04/08/09
1
<0.5
<0.5
<0.5
<0.5
Test 1
04/17/12
2
<1
<1
<1
<1
03/07/13
2
<1
<1
<1
<1
03/21/14
2
<1
<1
<1
<1
OL-003
12/15/87
4-9'
45
180
23
ND
09/16/97
5
94
280
95
03/18/02
0.508 (J)
13
57
16
06/02/03
...
0.8
2
11
7
04/13/05
...
<25
930
480
77
04/24/08
0
13
370
450
82
04/07/09
3
<25
<25
<25
<25
OL-3
03/07/13
1
<1
2.4
10
<1
OL-003
03/21/14
0
<1
<1
1.3
2.2
OL-3M
07/10/02
21.5-31.5'
...
<0.1
0.191
<2
<0.1
06/02/03
...
<0.5
<0.5
<0.5
<0.5
04/13/05
...
<1
<1
<1
<2
04/07/09
4
<3
<3
<3
<3
03/07/13
1
3.6
7.1
<2
<2
03/21/14
3
<10
<10
<10
<10
10/12/18
3
<2
2.7
<2
<2
GEO-3
06/24/03
6-16'
<0.5
4
49
35
MW-200S
04/14/05
6.5-9.5'
...
<200
14,000
<200
<400
04/07/09
4
<25
<25
<25
<25
03/23/11
3
<50
<50
<50
<50
03/07/13
3
<100
<100
<100
<100
04/13/16
2
<20
<20
<20
<20
02/21/17
2
<100
<100
<100
<100
MW-200D
04/14/05
14-17'
...
<25,000
870,000
<25,000
<25,000
MW-200D (Dup)
04/14/05
...
<25,000
770,000
<25,000
<25,000
04/07/09
4
<50
<50
<50
<50
02/15/10
4
<250
<250
<250
<250
03/23/11
4
<500
<500
<500
<500
03/07/13
3
<10
<10
<10
<10
03/21/14
3
<50
<50
<50
<50
02/21/17
4
<50
<50
<50
<50
MW-201S
04/14/05
6.5-9.5'
<5
330
<5
<10
11/05/07
<2.5
4
<2.5
<2.5
04/24/08
2
<10
5
<10
<10
03/23/11
0
<0.5
4
<0.5
<0.5
03/07/13
2
<5
<5
<5
<5
03/21/14
2
<10
14
<10
<10
09/29/14
1
<1
6.8
<1
<1
02/21/17
0
<10
400
<10
<10
05/10/17
1
2.0
95
<2
<2
10/26/17
1
<1
9.5
2.3
<1
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 1 of9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-201D
04/14/05
14-17'
<1
11
<1
<2
11/05/07
<5
<5
<5
<5
03/23/11
<100
9,300
<100
<100
10/18/11
1
110
18,000
120
<100
08/24/12
6.8
11
<5
<5
03/07/13
1
<10
350
<10
<10
07/31/13
1
<50
4,300
50
<50
03/21/14
2
<10
120
<10
<10
09/29/14
1
<20
2,200
48
<20
05/12/15
2
<10
35
<10
<10
10/05/15
2
<5
710
16
<5
10/18/16
0
<1
7.7
1.3
<1
02/21/17
0
<20
2,000
23
<20
05/10/17
0
<5
370
8.7
<5
10/26/17
1
<25
3,900
57
<25
03/23/18
1
<1
26
<1
<1
MW-202S
04/14/05
6.5-9.5'
<100
6,200
<100
<200
04/22/08
3
<25
<25
<25
<25
03/07/13
0
<20
770
<20
<20
07/31/13
0
<50
1,600
<50
<50
03/21/14
0
<10
1,300
<10
<10
07/15/14
0
<20
2,300
<20
<20
05/12/15
0
<10
820
<10
<10
10/05/15
<10
690
<10
<10
04/13/16
<10
290
<10
<10
10/18/16
0
<10
220
<10
<10
02/21/17
0
<50
160
<50
<50
10/26/17
<1
49
<1
<1
MW-202D
04/14/05
14-17'
<2,000
89,000
<2,000
<4,000
04/07/09
4
<100
<100
<100
<100
11/03/09
4
<100
<100
<100
<100
03/23/11
4
<250
<250
<250
<250
03/07/13
3
<10
<10
<10
<10
03/21/14
4
<100
<100
<100
<100
02/21/17
4
<200
<200
<200
<200
MW-203S
04/14/05
3-6'
<10
500
<10
<20
04/25/07
0
<0.5
3
0.7
<0.5
11/05/07
<0.5
1
0.7
<0.5
04/23/08
0
<0.5
39
<0.5
<0.5
04/07/09
0
<0.5
4
0.5
<0.5
03/23/11
0
<0.5
3
0.7
<0.5
03/07/13
2
<40
83
<40
<40
07/31/13
0
<1
3.8
<1
<1
03/21/14
0
<1
2.5
<1
<1
10/05/15
0
<10
130
<10
<10
04/13/16
<1
2.2
2.1
<1
02/21/17
0
<1
1.8
<1
<1
MW-203D
04/14/05
14-17'
<500
42,000
<500
<1,000
08/31/06
1
<250
24,000
<250
<250
12/14/06
2
120
<5
<5
<5
11/05/07
<500
33,000
<500
<500
04/24/08
0
<250
26,000
<250
<250
08/06/08
0
<250
37,000
<250
<250
11/13/08
4
<250
47,000
<250
<250
12/11/08
3
<25
<25
<25
<25
03/09/09
2
200
14,000
<100
<100
11/03/09
0
350
45,000
<250
<250
02/15/10
3
30
<25
<25
<25
09/01/10
2
<130
<25
<25
<25
03/23/11
2
120
12,000
<100
<100
10/18/11
1
<100
3,200
<100
<100
04/17/12
2
69
6,800
<25
<25
08/24/12
4
18
64
<5
<5
03/07/13
0
<1
<1
<1
<1
07/31/13
3
<50
3,000
<50
<50
03/21/14
2
<10
54
<10
<10
09/29/14
1
26
2.000
<20
<20
05/12/15
3
<20
<20
<20
<20
10/05/15
0
<5
<26
5.7
<5
02/21/17
3
<25
<26
<25
<25
MW-204S
04/14/05
7-10'
<50
2,400
280
<100
MW-204S (DUP-8)
04/14/05
<50
2,200
250
<100
04/23/08
2
<250
<250
<250
<250
04/07/09
3
<10
<10
<10
<10
03/23/11
3
<0.5
<0.5
<0.5
<0.5
03/07/13
2
<50
<50
<50
<50
03/21/14
2
<10
<10
<10
<10
02/21/17
1
<20
<20
<20
<20
MW-204D
04/14/05
14-17'
<1,000
60,000
<1,000
<2,000
04/25/06
0
<2,500
190,000
<2,500
<2,500
07/19/06
0
<2,500
160,000
<2,500
<2,500
08/31/06
0
<2,500
220,000
<2,500
<2,500
09/28/06
0
<2,500
210,000
<2,500
<2,500
04/25/07
0
<5,000
260,000
<5,000
<5,000
04/24/08
1
<2,500
460,000
<2,500
<2,500
08/06/08
2
<2,500
190,000
<2,500
<2,500
11/13/08
2
<500
70,000
<500
<500
03/09/09
4
<50
<50
<50
<50
04/08/09
3
<100
<100
<100
<100
11/03/09
4
<250
<250
<250
<250
09/01/10
4
<250
<50
<50
<50
03/23/11
3
110
6,900
<100
<100
10/18/11
2
<1000
4,600
<1,000
<1,000
04/17/12
4
<50
<50
<50
<50
03/07/13
1
<20
<20
<20
<20
03/21/14
3
<10
12
<10
<10
02/21/17
2
<250
<250
<250
<250
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 2 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-205S
04/13/05
4-7'
<1
12
4
<2
10/30/06
1
<0.5
2
8
<0.5
04/23/08
0
<0.5
5
5
1
MW-205S (DUP-3)
04/23/08
0
<0.5
4
4
0.9
04/07/09
1
<0.5
<0.5
<0.5
<0.5
03/23/11
0
<0.5
3
5
1
MW-205SX
03/23/11
0
<0.5
3
5
1
03/07/13
0
<1
<1
13
8.6
MW-205SX
03/07/13
0
<1
<1
13
8.6
03/21/14
0
<1
1.9
7.2
2.6
MW-205SX
03/21/14
0
<1
1.8
7
2.4
10/05/15
0
<1
1.6
7
<1
02/21/17
0
<1
4.9
4.4
3
MW-205D
04/13/05
14-17'
<500
16,000
<500
<1,000
04/26/06
0
<1,000
61,000
<1,000
<1,000
07/19/06
0
<2,500
98,000
<2,500
<2,500
08/31/06
0
<2,500
110,000
<2,500
<2,500
09/28/06
0
<2,500
120,000
<2,500
<2,500
10/30/06
0
<1,000
120,000
<1,000
<1,000
04/25/07
0
<2,500
120,000
<2,500
<2,500
04/23/08
1
340
25,000
<250
<250
08/06/08
4
<25
<25
<25
<25
11/13/08
4
<50
<50
<50
<50
03/09/09
4
<100
<100
<100
<100
11/03/09
4
<100
<100
<100
<100
09/01/10
4
<250
<50
<50
<50
03/23/11
4
<100
<100
<100
<100
MW-205DX
03/23/11
4
<100
<100
<100
<100
10/18/11
4
<100
<100
<100
<100
MW-205DX
10/18/11
4
<250
<250
<250
<250
03/07/13
3
<20
<20
<20
<20
MW-205DX
03/07/13
3
<20
<20
<20
<20
03/21/14
4
<10
<10
<10
<10
MW-205DX
03/21/14
4
<20
<20
<20
<20
02/21/17
2
<100
<100
<100
<100
MW-206S
04/14/05
4-7'
<100
8,200
130
<200
04/23/08
1
<5
<5
<5
<5
03/23/11
3
<0.5
<0.5
<0.5
<0.5
03/11/13
2
<1
<1
<1
<1
03/21/14
3
<1
<1
<1
<1
02/21/17
0
<5
<5
<5
<5
MW-206D
04/14/05
14-17'
<25
<25
70
<50
04/26/06
0
<1,000
81,000
<1,000
<1,000
07/19/06
0
<1,000
73,000
<1,000
<1,000
08/31/06
0
<1,000
78,000
<1,000
<1,000
09/28/06
0
<1,000
87,000
<1,000
<1,000
04/25/07
0
<1,000
83,000
<1,000
<1,000
04/23/08
0
500
100,000
400
<50
MW-206D (DUP-2)
04/23/08
0
<1,000
77,000
<1,000
<1,000
08/06/08
2
320
870
<3
<3
11/13/08
3
<500
78,000
640
<500
12/11/08
3
<25
<25
<25
<25
03/09/09
2
200
<50
<50
<50
11/03/09
2
330
14,000
300
<100
02/15/10
2
260
9,200
280
<50
09/01/10
1
210
34,000
2,900
<3
03/23/11
1
150
17,000
2,400
<100
10/18/11
0
<500
13,000
1,900
<500
04/17/12
0
72
8,400
1,400
<25
08/24/12
0
<200
10,000
1,200
<200
03/07/13
1
<100
4,400
630
<100
07/31/13
1
<100
5,800
630
<100
03/21/14
0
42
3,700
520
<40
MW-206D-DUP
03/21/14
0
45
3,600
550
<10
07/15/14
0
46
4,000
520
<25
05/12/15
0
<20
1,700
310
<20
10/05/15
0
29
2,400
300
<25
04/13/16
2
<10
400
73
<10
10/18/16
1
<20
1,200
150
<20
02/21/17
1
<25
680
88
<25
05/10/17
1
<10
200
60
<10
10/26/17
0
<10
1,000
180
<10
03/23/18
0
<10
530
350
<10
MW-207S
04/13/05
6-9'
110
3,700
1,700
320
12/14/06
1
<10
550
150
<10
11/05/07
<25
890
580
54
04/22/08
0
83
1,700
51
<10
08/06/08
2
62
39
<5
<5
04/07/09
2
<10
<10
<10
<10
03/23/11
1
25
930
61
<10
10/18/11
0
<20
970
390
<20
08/24/12
0
<40
2,000
810
42
03/07/13
1
11
130
10
<4
07/31/13
1
<10
160
27
<10
03/21/14
0
<20
1,700
1,100
74
07/15/14
0
<10
550
300
16
05/12/15
0
<20
1,700
100
<20
10/05/15
0
<20
3,200
1,300
100
04/13/16
0
<25
2,100
440
<25
10/18/16
0
<50
2,800
3,200
330
02/21/17
2
10
100
<10
<10
10/26/17
0
<20
2,400
820
62
03/23/18
0
22
2,500
560
31
MW-207D
04/14/05
14-17'
<100
7,900
<100
<200
MW-207D (DUP-7)
04/14/05
<100
8,100
<100
<200
04/07/09
4
<50
<50
<50
<50
03/23/11
4
<100
<100
<100
<100
03/07/13
4
<10
<10
<10
<10
03/21/14
0
<10
<10
<10
<10
02/21/17
2
<50
<50
<50
<50
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 3 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-208S
04/14/05
4-7'
<25
1,100
1,300
95
04/22/08
2
<25
<25
<25
<25
04/07/09
3
<10
<10
<10
<10
03/23/11
2
<0.5
<0.5
1
<0.5
03/07/13
1
<1
<1
2.8
1.7
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
6.9
18
9.6
MW-208D
04/14/05
14-17'
<500
38,000
<500
<500
12/14/06
<2,500
170,000
<2,500
<2,500
12/11/08
3
<25
<25
<25
<25
03/09/09
4
<100
<100
<100
<100
11/03/09
2
40
<25
<25
<25
09/01/10
3
250
73
<50
<50
MW-208DX
09/01/10
3
<2,500
91,000
<500
<500
03/23/11
3
500
64,000
<500
<500
10/18/11
2
380
36,000
410
<100
MW-208 (DUP-1)
10/18/11
2
<500
38,000
<500
<500
04/17/12
3
300
23,000
280
<50
08/24/12
1
290
22,000
270
<250
03/07/13
1
<250
12,000
320
<250
DUP-2
03/07/13
1
<200
11,000
290
<200
07/31/13
0
<400
11,000
<400
<400
03/21/14
1
210
8,000
590
<50
MW-208D-DUP
03/21/14
1
160
8,200
670
<50
07/15/14
0
230
7,400
520
<100
05/12/15
0
84
2,200
690
<25
10/05/15
0
120
2,700
510
<25
04/13/16
0
50
570
350
<10
10/18/16
0
<100
880
500
<100
02/21/17
0
<100
500
380
<100
05/10/17
0
23
210
210
<10
10/26/17
0
24
310
240
<5
03/23/18
0
20
100
94
<10
MW-209S
04/13/05
7-10'
<10
520
1,200
270
04/22/08
0
<5
22
<5
<5
04/07/09
2
<5
<5
<5
<5
03/23/11
0
<10
44
<10
<10
10/18/11
0
1.4
34
1.00
<1
03/07/13
0
<10
<10
<10
<10
07/31/13
0
<10
<10
<10
<10
03/21/14
0
<10
11
<10
<10
10/05/15
0
10
130
<10
<10
04/13/16
<20
49
<20
<20
02/21/17
0
<10
140
<10
<10
MW-209D
04/13/05
14-17'
<25
1,600
<25
<50
04/08/09
3
<10
<5
<10
<10
03/23/11
3
<10
<5
<10
<10
03/21/14
3
<10
24
14
<10
02/21/17
0
<5
49
53
<5
MW-210S
04/13/05
7-10'
<50
730
3,500
1,100
11/05/07
<25
430
1,000
61
04/22/08
0
<25
2,400
2,900
290
08/06/08
3
<25
<25
<25
<25
04/07/09
0
3
30
<0.5
<0.5
09/01/10
2
<25
<5
<5
<5
03/23/11
2
<3
18
4
<3
10/18/11
3
<5
<5
<5
<5
03/07/13
1
<1
14
13
1.6
07/31/13
0
<5
130
210
11
03/21/14
<1
<1
<1
<1
02/21/17
0
<10
930
1,000
200
05/10/17
3
<4
<4
6
<4
MW-210D
04/14/05
14-17'
...
<25
650
1,900
<50
04/07/09
4
<5
<5
<5
<5
09/01/10
4
<130
<25
<25
<25
03/23/11
3
<5
<5
<5
<5
03/07/13
3
<20
<20
<20
<20
03/21/14
3
<10
<10
<10
<10
02/21/17
0
<10
<10
710
270
MW-211S
04/14/05
6.5-9.5'
<2
39
140
27
12/14/06
0
<0.5
1
2
0.6
04/25/07
0
<0.5
1
0.7
<0.5
04/22/08
0
<0.5
2
2
0.8
09/01/10
0
<3
0.5
<0.5
<0.5
03/23/11
0
<0.5
<0.5
0.6
<0.5
03/07/13
0
<1
<1
1.2
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
MW-211D
04/14/05
14-17'
<5
83
150
<10
11/05/07
<50
3,300
830
<50
04/22/08
1
8
69
<1
<1
04/08/09
2
<0.5
<0.5
<0.5
<0.5
03/23/11
2
<25
380
1,600
<25
10/18/11
0
<10
440
830
<10
04/17/12
2
<1
10
81
<1
03/07/13
1
<50
210
1,700
<50
07/31/13
0
<100
690
3,900
<100
03/21/14
2
<1
18
110
<1
09/29/14
0
<40
110
4,800
<40
02/21/17
0
<100
430
11,000
610
10/26/17
0
<100
580
16,000
1,000
03/23/18
0
<50
540
9,200
530
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 4 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-212S
04/14/05
10-13'
450
360
12
<20
04/26/06
0
1,200
2,300
<25
<25
08/31/06
0
1,300
2,200
39
<25
09/28/06
0
240
1,000
310
<25
10/30/06
0
1,300
1,900
42
<25
04/26/07
0
1,200
1,800
68
<25
04/24/08
0
1,100
2,100
200
<25
04/08/09
3
<25
<25
<25
<25
03/23/11
0
1,200
1,600
21
<10
10/18/11
0
1,300
2,500
<50
<50
03/07/13
2
2.4
3.0
<1
<1
03/21/14
1
<10
11
<10
<10
09/29/14
0
<1
<1
<1
<1
02/21/17
1
12
410
<10
<10
10/26/17
0
15
1,600
<10
<10
DEEP OVERBURDEN WELLS
GEO-1
09/21/99
90-100'
<1.5
2.5
<1
<2
03/18/02
0.104
0.244
<2
<0.1
09/13/05
<0.5
<0.5
<0.5
<0.5
01/11/06
<0.5
<0.5
<0.5
<0.5
04/24/06
<0.5
<0.5
<0.5
<0.5
04/24/07
<0.5
<0.5
<0.5
<0.5
GEO-2
09/21/99
95-105'
<1.5
1.6
<1
<2
03/15/02
<0.1
0.175
<2
<0.1
OUTSIDE CONTAINMENT CELL UP GRADIENT
OL-005
12/15/87
3.5-8.5'
ND
ND
03/19/02
<0.1
<1,000
<2
<0.1
06/02/03
<0.5
<0.5
<0.5
<0.5
04/14/05
<1
<1
<1
<2
04/25/06
0
<0.5
<0.5
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
MW-12
07/10/02
3.5-13.5'
<0.1
<0.1
<2
<0.1
04/14/05
<1
<1
<1
<2
04/25/06
<0.5
<0.5
<0.5
<0.5
04/24/07
0
<0.5
32
7
<0.5
04/24/08
0
<0.5
13
0.5
<0.5
04/08/09
0
<0.5
22
4
<0.5
03/07/13
0
<1
<1
4.7
<1
03/21/14
0
<1
<1
<1
<1
MW-214S
04/14/05
10-13'
<1
3
<1
<2
04/25/06
0
<0.5
1
<0.5
<0.5
04/25/07
0
<0.5
<0.5
<0.5
<0.5
04/24/08
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
MW-214M
04/14/05
20-23'
<1
3
<1
<2
04/25/06
0
<0.5
<0.5
<0.5
<0.5
04/25/07
0
<0.5
<0.5
<0.5
<0.5
04/24/08
0
<0.5
<0.5
<0.5
<0.5
MW-214D
04/14/05
30-33'
<1
<1
<1
<2
04/25/06
0
<0.5
<0.5
<0.5
<0.5
04/25/07
0
<0.5
1
<0.5
<0.5
04/24/08
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
SIDE GRADIENT EAST (V
cinity of Ah
erjona River)
MW-010S
04/22/02
4-14'
<0.1
<0.1
<2
<0.1
04/14/05
<1
<1
<1
<2
04/25/06
0
<0.5
<0.5
1
<0.5
04/23/08
0
<0.5
<0.5
0.7
<0.5
11/16/11
<0.5
0.25 (J)
0.45 (J)
<1
MW-010M
04/25/02
04/14/05
40-50'
<0.1
2
0.0779 (J)
1
<2
<1
<0.1
<2
04/25/06
0
<0.5
<0.5
<0.5
<0.5
04/23/08
0
<0.5
<0.5
<0.5
<0.5
11/16/11
<0.5
<0.5
<0.5
<1
MW-010D
04/25/02
88.5-98.5'
0.174
1.4
<2
<0.1
04/25/06
0
<0.5
<0.5
<0.5
<0.5
11/16/11
<0.5
0.75
0.19 (J)
<1
MW-215S
04/13/05
10-13'
2,300
6,200
430
<200
04/24/06
0
2,400
5,400
250
<100
MW-215S (DUP-1)
04/24/06
0
2,400
5,200
260
<100
09/28/06
0
2,900
5,400
290
<50
04/25/07
0
1,900
3,500
<250
<250
04/22/08
0
1,400
1,900
120
<10
11/13/08
3
<50
<50
<50
<50
12/11/08
2
360
<3
<3
<3
03/09/09
2
310
<50
<50
<50
04/08/09
2
190
<50
<50
<50
11/03/09
3
<50
<50
<50
<50
02/15/10
2
<50
<50
<50
<50
03/23/11
3
<5
<50
<5
<5
MW-215SX
03/23/11
3
<25
<25
<25
<25
10/18/11
3
<10
<10
<10
<10
MW-215SX
10/18/11
3
62
710
120
<20
11/21/11
<10
<10
<10
<10
MW-215SX
11/21/11
<10
<10
<10
<10
MW-215S ASCORBIC ACID
04/17/12
3
<1
<1
<1
<1
04/17/12
3
<10
<10
<10
<10
03/07/13
2
<10
<10
<10
<10
MW-215SX
03/07/13
2
<10
<10
<10
<10
03/21/14
3
<1
<1
<1
<1
MW-215SX
03/21/14
3
<20
<20
<20
<20
02/21/17
2
<10
<10
<10
<10
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 5 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-215M
04/13/05
20-23'
<1
<1
<1
<2
MW-215M (DUP-2)
04/13/05
<1
<1
<1
<2
04/26/06
0
<0.5
<0.5
<0.5
<0.5
10/30/06
0
<0.5
2
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
04/22/08
0
<0.5
<0.5
<0.5
<0.5
03/23/11
0
<1
100
<1
<1
10/18/11
0
<1
33
1.5
<1
08/24/12
0
<1
53
<1
<1
03/07/13
0
<2
180
2.7
<2
07/31/13
0
<1
<1
<1
<1
03/21/14
0
<1
190
51
<1
10/05/15
4
<10
<10
<10
<10
02/21/17
0
<1
280
82
<1
10/26/17
0
<2
200
110
<2
MW-215D
04/13/05
30-33'
<1
<1
<1
<2
09/13/05
0
<0.5
<0.5
<0.5
<0.5
01/11/06
0
<0.5
1
<0.5
<0.5
04/26/06
0
<0.5
<0.5
<0.5
<0.5
07/19/06
0
<0.5
<0.5
<0.5
<0.5
03/28/07
0
<0.5
<0.5
<0.5
<0.5
04/22/08
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
<1
<1
MW-216S
04/13/05
10-13'
<500
20,000
<500
<1,000
09/13/05
740
32,000
<500
<500
04/26/06
0
<1,000
35,000
<1,000
<1,000
09/28/06
0
<1,000
48,000
<1,000
<1,000
04/24/07
0
<1,000
48,000
<1,000
<1,000
04/22/08
0
<1,000
95,000
<1,000
<1,000
12/11/08
0
<500
98,000
<500
<500
03/09/09
0
<500
40,000
<500
<500
05/07/09
2
<250
26,000
<250
<250
11/03/09
0
<500
120,000
<500
<500
02/15/10
0
180
32,000
<100
<100
MW-216SX
02/15/10
0
<500
78,000
<500
<500
09/01/10
4
<130
<25
<25
<25
MW-216SX
09/01/10
4
<1,300
56,000
<250
<250
03/23/11
0
<1,000
94,000
<1,000
<1,000
10/18/11
0
<1,000
26,000
<1,000
<1,000
04/17/12
0
<50
17,000
<50
<50
08/24/12
0
<250
20,000
<250
<250
03/07/13
2
<10
600
<10
<10
07/31/13
2
<50
170
<50
<50
03/21/14
2
<10
270
<10
<10
05/12/15
1
<10
82
<10
<10
10/05/15
4
<20
<20
<20
<20
02/21/17
1
<20
<20
<20
<20
MW-216M
04/13/05
20-23'
<1
<1
<1
<2
04/26/06
0
<0.5
4
<0.5
<0.5
04/24/07
0
<0.5
10
<0.5
<0.5
04/23/08
0
<0.5
<0.5
<0.5
<0.5
03/23/11
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
<1
07/31/13
0
<1
<1
<1
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
MW-216D
04/13/05
30-33'
<1
<1
<1
<2
09/13/05
<0.5
<0.5
<0.5
<0.5
01/11/06
<0.5
<0.5
<0.5
<0.5
04/26/06
0
<0.5
<0.5
<0.5
<0.5
07/19/06
0
<0.5
0.5
<0.5
<0.5
12/14/06
0
<0.5
1
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
04/22/08
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
4.2
<1
<1
OUTSIDE CONTAINMENT CELL SIDE GRADIENT WEST
(Adjacent to Sewer
Line Easement)
GEO-5
06/24/03
2-12'
280
3,300
<50
<50
GEO-6
06/24/03
11-16'
<0.5
<0.5
<0.5
<0.5
04/13/05
<1
<1
<1
<2
04/24/06
0
<0.5
<0.5
<0.5
<0.5
10/30/06
0
<0.5
2
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
06/18/07
<0.5
<0.5
<0.5
<0.5
GEO-7
06/24/03
6-16'
2
8
<0.5
<0.5
04/13/05
<1
4
<1
<2
04/24/06
0
<0.5
1
<0.5
<0.5
09/28/06
0
<0.5
2
<0.5
<0.5
04/26/07
0
<0.5
<0.5
<0.5
<0.5
06/18/07
<0.5
<0.5
<0.5
<0.5
MW-13
07/09/02
7-17'
410
780
1,500
<2
04/22/03
650
280
780
<10
06/02/03
430
250
1,300
<25
04/14/05
470
160
340
<20
04/26/06
1,500
1,400
350
<50
09/28/06
1,100
2,200
480
<25
04/26/07
1,400
4,100
380
<50
06/18/07
1,100
7,100
710
34
11/05/07
560
6,400
260
<100
04/22/08
0
730
6,000
420
<50
04/07/09
0
530
6,300
440
<50
02/15/10
3
<10
<10
<10
<10
MW-13X
02/15/10
3
<3
<3
<3
<3
03/23/11
3
<0.5
<0.5
<0.5
<0.5
MW-13 X
03/23/11
3
<25
<25
<25
<25
10/18/11
3
<12
<12
<12
<12
MW-13 X
10/18/11
3
<25
<25
<25
<25
MW-13 ASCORBIC ACID
04/17/12
3
<20
<20
<20
<20
04/17/12
3
<20
<20
<20
<20
03/07/13
3
<10
<10
<10
<10
MW-13X
03/07/13
3
<10
<10
<10
<10
03/21/14
3
<10
<10
<10
<10
MW-13X
03/21/14
3
<10
<10
<10
<10
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 6 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-212M
04/14/05
20-23'
<1
<1
<1
<2
04/26/06
0
<0.5
3
<0.5
<0.5
04/25/07
0
<0.5
7
2
<0.5
03/07/13
0
<1
<1
<1
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
MW-212D
04/14/05
30-33'
<1
<1
<1
<2
MW-212D (DUP-6)
04/14/05
<1
<1
<1
<2
04/26/06
0
<0.5
<0.5
<0.5
<0.5
04/26/07
0
<0.5
<0.5
<0.5
<0.5
04/08/09
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
1
<1
MW-213S
04/13/05
10-13'
240
70
140
<10
MW-213S (DUP-1)
04/13/05
230
70
140
<10
04/24/06
0
120
120
47
<25
03/28/07
0
330
900
150
<10
06/18/07
400
2,000
200
<10
04/22/08
0
280
2,100
110
<25
04/08/09
0
400
6,000
81
<50
09/01/10
2
210
<25
<25
<25
MW-213SX
09/01/10
2
640
13,000
120
<25
03/23/11
0
140
2,000
51
<25
MW-213S (DUP-1)
03/23/11
0
140
2,000 (D)
50
<10
MW-213SX
03/23/11
0
150
2,200
53
<25
10/18/11
0
72
620
140
<40
MW-213SX
10/18/11
0
<10
<10
<10
<10
MW-213 ASCORBIC ACID
04/17/12
0
88
470
36
<10
04/17/12
0
82
500
34
<5
08/24/12
3
120
1,400
36
<20
MW-213SX
08/24/12
3
<5
<5
<5
<5
03/07/13
1
15
59
<10
<10
MW-213SX
03/07/13
1
<10
<10
<10
<10
07/31/13
2
<20
<20
<20
<20
03/21/14
0
<10
18
<10
<10
MW-213SX
03/21/14
0
<10
17
<10
<10
10/05/15
0
16
47
190
<10
02/21/17
0
<25
270
98
<25
10/26/17
0
<10
170
240
<10
03/23/18
0
9.8
260
<5
<5
MW-213M
04/13/05
20-23'
<1
<1
<1
<2
04/24/06
<0.5
<0.5
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
06/18/07
0
<0.5
<0.5
<0.5
<0.5
03/23/11
0
<0.5
6
3
<0.5
10/18/11
0
<1
1.9
1.2
<1
03/07/13
0
<1
3.6
2.4
<1
07/31/13
0
<1
4.2
3.8
<1
03/21/14
0
<1
2.6
1.5
<1
02/21/17
0
<1
6.2
11
<1
MW-213D
04/13/05
30-33'
<1
<1
<1
<2
04/24/06
0
<0.5
<0.5
<0.5
<0.5
03/28/07
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
<1
<1
MW-220M
04/14/05
20-23'
<1
<1
<1
<2
04/26/06
0
<1
<1
<1
<1
04/27/07
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
6.9
<1
MW-220D
04/13/05
30-33'
<1
<1
<1
<2
04/26/06
0
<0.5
<0.5
<0.5
<0.5
09/28/06
0
<0.5
<0.5
<0.5
<0.5
04/26/07
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
<1
<1
SIDE GRADIENT WEST (Adjacent to Sewer Line Easement)
GEO-8 (MW-301)
06/18/07
15-20'
<0.5
<0.5
<0.5
<0.5
04/23/08
0
<0.5
<0.5
<0.5
<0.5
GEO-9 (MW-302)
06/18/07
15-20'
<0.5
<0.5
<0.5
<0.5
04/24/08
0
<0.5
<0.5
<0.5
<0.5
DOWNGRADIENT
MW-011S
04/26/02
4-14'
<0.1
0.13
<2
0.264
04/14/05
2
5
13
<2
04/25/06
0
3
8
26
2
04/23/08
0
0.5
2
12
1
11/16/11
<0.5
2.1
4.7
1.2
M W 11S
03/23/18
0
<1
1.4
4.4
<1
MW-011M
04/26/02
40-50'
7
120
17
<2
04/14/05
<1
19
2
<2
04/25/06
0
<0.5
4
0.8
<0.5
04/23/08
0
<0.5
2
0.6
<0.5
11/16/11
<0.5
0.80
0.30 (J)
<1
03/23/18
<1
<1
<1
<1
MW-011D
04/26/02
81-91'
<0.1
<0.1
<2
<0.1
04/25/06
0
<0.5
<0.5
<0.5
<0.5
04/23/08
0
<0.5
<0.5
<0.5
<0.5
11/16/11
<0.5
<0.5
<0.5
<1
MW-014S
07/10/02
5-15'
25
180
670
190
04/22/03
1
6
61
19
06/02/03
2
15
62
16
04/13/05
3
6
98
16
09/28/06
1
120
810
110
<10
04/24/07
0
39
25
29
6
06/18/07
51
29
33
7
04/23/08
0
68
180
210
31
04/07/09
0
11
27
280
30
10/18/11
0
7.5
45
92
3.2
03/07/13
1
4.2
13
80
5.6
07/31/13
0
<50
610
2,300
79
03/21/14
0
3.3
7.7
110
9.4
09/29/14
2
1.6
33
160
<1
10/05/15
0
<2
10
200
15
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 7 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-014M
07/10/02
04/13/05
20-30'
<0.1
<1
<0.1
<2
<1
<0.1
<2
04/24/06
0
<0.5
<0.5
<0.5
<0.5
10/30/06
0
<0.5
<0.5
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
03/21/14
0
<1
<1
<1
MW-014D
04/13/05
37-40'
<1
<1
<2
MW-014D (DUP4)
04/13/05
<1
<1
<2
04/25/06
0
<0.5
0.6
<0.5
<0.5
12/14/06
0
<0.5
0.5
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
04/24/08
0
<0.5
<0.5
<0.5
<0.5
04/07/09
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
03/21/14
0
<1
<1
<1
MW-217S
04/13/05
10-13'
<5
190
400
<10
04/24/06
0
7
69
80
<5
04/24/07
0
<0.5
3
2
<0.5
04/22/08
0
12
83
520
<5
MW-217S (DUP-1)
04/22/08
0
12
88
530
<5
04/08/09
0
190
550
<5
MW-217S (DUP-1)
04/08/09
0
170
510
<5
09/01/10
0
840
2,200
<25
03/23/11
0
31
25
2
10/18/11
0
<1
<1
5.4
<1
03/07/13
0
<1
1
2.4
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
MW-217M
04/13/05
25-28'
<1
<1
<1
<2
04/24/06
0
<0.5
<0.5
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
04/23/08
2
<25
<25
<25
<25
04/08/09
2
<0.5
<0.5
<0.5
<0.5
03/23/11
0
<0.5
25
19
<0.5
MW-217MX
03/23/11
0
<0.5
26
20
<0.5
10/18/11
0
<1
110
100
1.7
MW-217MX
10/18/11
0
<1
110
100
1.9
MW-217M ASCORBIC ACIE
04/17/12
<5
420
320
10
MW-217M HCL
04/17/12
<5
400
320
10
08/24/12
0
610
500
16
MW-217MX
08/24/12
0
590
470
16
03/07/13
0
780
670
25
MW-217MX
03/07/13
0
540
440
17
DUP-1
03/07/13
0
<20
580
460
<20
07/31/13
0
<20
1,200
690
32
03/21/14
0
1,600
530
34
MW-217MX
03/21/14
0
1,500
490
28
MW-217M-DUP
03/21/14
0
1,400
490
30
09/29/14
2
260
23
<2
05/12/15
0
4,000
430
<50
10/05/15
3
220
7.3
<2
04/13/16
4,500
380
<100
08/10/16
3
8.4
680
14
<2.5
08/25/16
3
<25
1,300
31
<25
10/18/16
0
<20
1,500
98
<20
02/21/17
1
<50
7,800
610
<50
05/10/17
2
<25
1,900
140
<25
06/29/17
1
<2,600
320,000
27,000
<2,600
07/27/17
0
27
4,800
380
28
10/26/17
0
<20
2,700
240
<20
02/27/18
0
<1
<1
<1
<1
03/23/18
0
5,000
380
<50
06/22/18
0
57
7,700
960
<50
06/22/18
0
6,200
590
<50
06/22/18
0
5,700
580
<50
MW-217D
04/13/05
37-40'
<1
<1
<1
<2
09/13/05
0
<0.5
<0.5
<0.5
<0.5
01/11/06
0
<0.5
<0.5
<0.5
<0.5
04/24/06
0
<0.5
<0.5
<0.5
<0.5
07/19/06
0
<0.5
<0.5
<0.5
<0.5
03/28/07
0
<0.5
<0.5
<0.5
<0.5
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
<1
<1
<1
MW-218S
04/13/05
10-13'
<1
27
93
5
04/25/06
0
<1
1
44
6
MW-218S (DUP-2)
04/25/06
0
<1
1
45
6
04/25/07
0
<0.5
3
10
3
04/23/08
0
<0.5
4
9
3
04/08/09
0
<0.5
0.5
1
<0.5
03/21/14
0
<1
<1
1.6
<1
02/21/17
0
<1
<1
1.2
<1
MW-218M
04/13/05
25-28'
<1
<1
<1
<2
04/26/06
0
<0.5
4
<0.5
<0.5
04/25/07
0
<0.5
1
<0.5
<0.5
04/23/08
0
<0.5
0.8
<0.5
<0.5
04/08/09
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
<1
03/21/14
0
<1
<1
<1
<1
02/21/17
0
<1
1
<1
<1
10/12/18
0
<1
5.4
1.4
<1
MW-218D
04/13/05
37-40'
<1
<1
<1
<2
MW-218D (DUP-3)
04/13/05
<1
<1
<1
<2
04/26/06
0
<0.5
1
<0.5
<0.5
12/14/06
0
<0.5
<1
<0.5
<0.5
04/26/07
1
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
<1
<1
Exhibit 22
May 8, 2019
Geolnsight Project 2491-002
Page 8 of 9
-------
TABLE 1
SUMMARY OF GROUNDWATER ANALYTICAL DATA - PRIMARY VOCs
60 OLYMPIA AVENUE
WOBURN, MASSACHUSETTS
Location
Identification
Sampling
Date
Screen
Interval
Color
Tetrachloroethene
Trichloroethene
cis-1,2-
Dichloroethene
Vinyl
Chloride
(feet)
Groundwater Standards
5
5
70
2
MW-219S
04/13/05
10-13'
<1
2
33
5
04/25/06
0
<0.5
<0.5
<0.5
<0.5
04/25/07
0
<0.5
<0.5
<0.5
<0.5
04/23/08
0
<0.5
<0.5
<0.5
<0.5
04/07/09
0
<0.5
<0.5
<0.5
<0.5
03/07/13
0
<1
<1
<1
03/21/14
0
<1
<1
<1
02/21/17
0
1.6
2.8
<1
MW219M
04/13/05
25-28'
6
63
12
04/25/06
0
11
210
12
04/24/07
0
6
56
6
04/23/08
0
4
39
8
04/08/09
0
0.7
2
16
3
03/07/13
0
<1
7.9
1.8
03/21/14
0
<1
9.5
2.3
02/21/17
0
<1
<1
<1
10/12/18
0
1.6
3.4
<1
MW-219D
04/13/05
37-40'
<1
<1
<2
09/13/05
<0.5
<0.5
<0.5
<0.5
01/11/06
0
<0.5
<0.5
<0.5
<0.5
04/25/06
0
<0.5
<0.5
<0.5
<0.5
07/19/06
0
<0.5
<0.5
<0.5
<0.5
03/28/07
0
<0.5
<.5
<0.5
<0.5
04/24/07
0
<0.5
<0.5
<0.5
<0.5
02/21/17
0
<1
<1
<1
<1
NOTES:
1. Values in micrograms per liter (|ig/L).
2. Bold exceeds laboratory detection limits.
3. Shaded concentrations exceed applicable Groundwater Standard.
4. Groundwater Standards are ROD ICLs or MCP Method 1/GW-l Risk Standards.
5. (J) = estimated concentration.
6. (UJ) = estimated non-detect.
7. ND =Not Detected: detection limit unknown.
8. — = Not analyzed
9. Sodium permanganate injected between September 1, 2005 and November 16, 2018.
10. D = listed value obtained from second (diluted) analytical run.
11. e = Concentration exceeded calibration range for the analyte.
12. On March 28, 2007 OL-2M was mislabled as MW-OL-2M on the chain of custody submitted to the lab.
May 8, 2019
Geolnsight Project 2491-002
Exhibit
22
Page 9 of 9
-------
Appendix C
ARARs Tables
-------
TABLE CI - LOCATION-SPECIFIC ARARS
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
RCRA - Location Standards (40 CFR
264.18). Alternatives SC-10 andMOM-2
Relevant and
Appropriate
This regulation outlines the requirements
for constructing a RCRA facility on a
100-year floodplain. A facility located on
a 100-year floodplain must be designed,
constructed, operated, and maintained to
prevent washout of any hazardous waste
by a 100-year flood, unless waste may be
removed safely before floodwater can
reach the facility, or no adverse effects on
human health and the environment would
result if washout occurred.
These requirements remain
applicable. The ROD assumed
that remediation facilities would
be located outside the floodplain
or designed to allow quick
mobilization out of the area and
to prevent damage by initial
floodwaters. The management
of RCRA regulated wastes takes
place outside the floodplain.
Federal Regulatory
Requirements
CWA - Section 404 Dredge and Fill
Requirements (Guidelines at 40 CFR 230).
Alternatives SC-10 and MOM-2
Applicable
For activities under Section 404
jurisdiction, the governing regulations
favor practicable alternatives that have less
impact on wetlands. If no mitigated
practicable alternative exists, impacts must
be mitigated.
Activities at the Source Areas
governed by this requirement are
complete. No PRP facility is
currently proposing to conduct
dredge and fill operations,
therefore the requirements are
no longer applicable.
Federal Regulatory
Requirements
Wetlands Executive Order (EO 11990) *
Alternatives SC-10 and MOM-2
* Now under Floodplain Management and
Protection of Wetlands - 44 CFR. 9
Applicable
Under this Executive Order, federal
agencies are required to select alternatives
that minimize the destruction, loss or
degradation of wetlands, and preserve and
enhance natural and beneficial values of
wetlands. If no practicable alternative
exists impacts must be mitigated
Activities at the Source Areas
governed by this requirement are
complete. No PRP facility is
currently proposing work in a
wetland, therefore the
requirements are no longer
applicable.
Federal Regulatory
Requirements
Floodplains Executive Order (EO 11988) *
Alternatives SC-10 and MOM-2
* Now under Floodplain Management and
Protection of Wetlands - 44 CFR. 9
Applicable
Federal agencies are required to reduce the
risk of flood loss, to minimize impact of
floods, and to restore and preserve the
natural and beneficial value of floodplains.
In addition, practicable alternatives must
be selected that have less impact on
wetlands.
Activities at the Source Areas
governed by this requirement are
completed. No PRP facility is
proposing further work in the
floodplain.
1
-------
TABLE CI - LOCATION-SPECIFIC ARARS
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
RCRA Floodplain Restrictions for Solid
Waste Disposal Facilities and Practices - 40
C.F.R. § 257.3-1
NEW ADDITION
Applicable
Solid waste practices must not restrict the
flow of a 100-year flood, reduce the
temporary water storage capacity of the
floodplain or result in washout of solid
waste, so as to pose a hazard to human
life, wildlife, or land or water resources.
Any solid waste generated from the
installation and maintenance of
monitoring/extraction wells, access ways,
and treatment systems will be managed so
that it will not impact floodplain resources.
Activities at the Source Areas
governed by this requirement are
completed. No PRP facility is
proposing further work in the
floodplain.
Federal Regulatory
Requirements
Protection of Archaeological Resources (32
CFR 229). Alternative SC-10
Status not
provided in
ROD
These regulations develop procedures for
the protection of archaeological resources.
Archeological resources were
not discovered during response
actions and are not expected to
be in the future.
Federal Regulatory
Requirements
National Historical Preservation Act -16
U.S.C. 469 et seq.; 36 C.F.R. Part 65
NEW ADDITION
Relevant and
Appropriate
When a federal agency finds, or is
notified, that its activities in connection
with a federal construction project may
cause irreparable loss or destruction of
significant scientific, pre-historical,
historical, or archeological data, the
substantive standards under the Act will be
met.
Any undisturbed areas where
monitoring/extraction wells,
access ways, and treatment
systems will be constructed will
be assessed to ensure no
protected resource areas are
present. If present there will be
consultation with federal and
state preservation officials to
address measures to avoid,
minimize and/or mitigate any
impacts to protected resource
areas.
Federal Regulatory
Requirements
Fish and Wildlife Coordination Act -16
U.S.C. §§ 662, 663
NEW ADDITION
Relevant and
Appropriate
Requires consultation with appropriate
agencies to protect fish and wildlife when
federal actions may alter waterways. Must
develop measures to prevent and mitigate
potential loss to the maximum extent
possible.
Consultation with appropriate
federal agencies will be
maintained during planning and
implementation of enhancements
to the remedy, if any, that may
alter protected resource areas
2
-------
TABLE CI - LOCATION-SPECIFIC ARARS
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Massachusetts Wetlands Protection
Requirements (310 CMR 10.00).
Alternatives SC-10 and MOM-2
Applicable
These requirements control regulated
activities in freshwater wetlands, 100 year
floodplains, and 100 foot buffer zones
beyond these areas. Regulated activities
include virtually any construction or
excavation activity. Performance standards
are provided for evaluation of the
acceptability of various activities. The
Wetland Protection Act was most recently
amended in October 2017.
Activities at the Source Areas
governed by this requirement are
complete. No PRP facility is
proposing work in a wetland.
State Regulatory
Requirements
Massachusetts Waterways Licenses (310
CMR 9.00). Alternative MOM-2
Applicable
Controls dredging, filling, and other work
in water of the Commonwealth. These
regulations were most recently amended in
March 2017.
The centralized treatment
facility for the Wells G&H
Source Areas is not currently a
component of the remedy;
therefore, these requirements are
not applicable to OU-1.
State Regulatory
Requirements
Massachusetts Certification for Dredging
and Filling (314 CMR 9.00). Alternative
MOM-2
Relevant and
Appropriate
Establishes water quality-based standards
for filling activities (CWA Section 401).
These regulations were most recently
amended in October 2014.
Source area pumping and central
area treatment require placement
of pipes under and across the
Abeijona River. Proper
measures were taken to avoid
contravention of water quality
standards (i.e., turbidity) during
installation of pipes, thereby
complying with the ARAR.
State Regulatory
Requirements
Inland Wetland Orders (302 CMR 6.00),
currently regulated under the Adopting
Inland Wetland Orders (310 CMR 13.00).
Alternative MOM-2
Relevant and
Appropriate
Defines wetland areas, establishes
encroachment lines along waterways or
floodplain areas, and regulates activities in
these areas.
The centralized treatment
facility is no longer a component
of the remedy; therefore, these
requirements are not relevant
and appropriate.
3
-------
TABLE CI - LOCATION-SPECIFIC ARARS
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Operation and Maintenance and
Pretreatment Standards for Waste Water
Treatment Works and Indirect Discharges
(314 CMR 12.00). Alternative MOM-2
Relevant and
Appropriate
Insures the proper operation and
maintenance of waste water treatment
facilities including operation and
maintenance, sampling, and discharges.
These requirements remain
relevant and appropriate. Proper
operation, maintenance,
sampling and discharge
procedures are being complied
with at the UniFirst, Grace and
Wildwood facilities. These
regulations were amended in
April 2014.
State Regulatory
Requirements
Massachusetts Hazardous Waste
Regulations, Location Standards for Land
Subject to Flooding - 310 C.M.R. 30.701
NEW ADDITION
Relevant and
Appropriate
Any new or expanding hazardous waste
storage or treatment facility (which only
receives hazardous waste from on-site
sources), the active portion of which is
located within the boundary of land
subject to flooding from the statistical 100-
year frequency storm, shall be flood-
proofed. Flood-proofing shall be designed,
constructed, operated and maintained to
prevent floodwaters from coming into
contact with hazardous waste. Any
hazardous waste generated from
installation and maintenance of
monitoring/extraction wells, access ways,
and treatment systems will be managed so
that it will not impact floodplain resources.
These regulations are relevant
and appropriate.
State Regulatory
Requirements
Public Waterfront Act; Waterways
regulations - M.G.L. ch. 91; 310 C.M.R.
9.00
NEW ADDITION
Relevant and
Appropriate
Sets forth criteria for work within
waterways, below the high water mark,
designated by the State (including the
Abeijona River).
If there are no practical
alternatives to installation and
maintenance of
monitoring/extraction wells,
access ways, and treatment
systems on or adjacent to the
river bank, then measures will
be taken to meet environmental
standards and limit impacts.
4
-------
TABLE CI - LOCATION-SPECIFIC ARARS
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
EPA Groundwater Protection Strategy.
Alternative MOM-2
TBC
EPA classifies groundwater into three
categories depending on current, past or
potential use to serve as a guide for
protection of the resource.
The Wells G&H aquifer is a
Class IIB aquifer (potentially
usable aquifer). The requirement
for Class IIB standards to be
attained following remediation.
5
-------
TABLE C2 - CHEMICAL-SPECIFIC ARARs AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
SDWA - Maximum Contaminant Levels
(MCLs) (40 CFR 141.11-141.16)
Relevant and
Appropriate
MCLs have been promulgated for a
number of common organic and inorganic
contaminants. These levels regulate the
concentration of contaminants in public
drinking water supplies, but may also be
considered relevant and appropriate for
groundwater aquifers potentially used for
drinking water.
The MCL for arsenic in drinking
water has decreased since the
1988 Endangerment
Assessment. Arsenic
concentrations in OU-1 should
be further evaluated to
determine if currently associated
with a risk above regulatory
guidelines. Groundwater is not
being used at OU-1;
nonetheless, these requirements
remain relevant and appropriate.
Federal Regulatory
Requirements
Safe Drinking Water Act; National primary
drinking water regulations, Maximum
Contaminant Level Goals (MCLGs)
NEW ADDITION
Relevant and
Appropriate for
Non-zero
MCLGs only;
MCLGs set as
zero are To Be
Considered.
Establishes MCLGs for public water
supplies. MCLGs are health goals for
drinking water sources. These
unenforceable health goals are available
for a number of organic and inorganic
compounds.
Considered as part of this FYR.
Federal Regulatory
Requirements
RCRA - Maximum Concentration Limits
(MCLs) (40 CFR 264.94)
Relevant and
Appropriate
RCRA MCLs provide groundwater
protection standards for 14 common
contaminants. All are equal to the SDWA
MCLs for those contaminants.
The MCL for arsenic in drinking
water has decreased since the
1988 Endangerment
Assessment. Arsenic
concentrations in OU-1 should
be further evaluated to
determine if currently associated
with a risk above regulatory
guidelines. Groundwater is not
being used at OU-1;
nonetheless, these requirements
remain relevant and appropriate.
1
-------
TABLE C2 - CHEMICAL-SPECIFIC ARARs AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
CWA - Ambient Water Quality Criteria
(AWQC) - Protection of Freshwater
Aquatic Life, Human Health - Fish
Consumption
Relevant and
Appropriate
AWQC are developed under the Clean
Water Act (CWA) as guidelines from
which states develop water quality
standards. A more stringent AWQC for
aquatic life may be found relevant and
appropriate rather than an MCL, when
protection of aquatic organisms is being
considered at a site.
AWQCs have been updated
since the 1989 ROD (EPA-822-
R-02-047, November 2002,
EPA-822-F-03-012, December
2003 and revised National
Recommended Water Quality
Criteria (NRWQC) were issued
in 2009). These criteria remain
relevant and appropriate.
Incremental updates for
parameters, such as PCE and
TCE in 2015, are documented at
www. epa. gov/wqc.
State Regulatory
Requirements
Massachusetts Drinking Water Regulations
Maximum Contaminant Levels (MCLs) and
Maximum Contaminant Level Goals
(MCLGs) (310 CMR 22.00)
Relevant and
Appropriate
Massachusetts MCLs establish levels of
contaminants allowable in public drinking
water supplies. The Massachusetts MCLs,
listed in 310 CMR 22.00, consist of
promulgated EPA MCLs which have
become effective, as well as
Massachusetts-specific MCLs. The
regulations were last promulgated on
March 11, 2016. Massachusetts Maximum
Contaminant Levels (MCLs) and
Maximum Contaminant Level Goals
(MCLGs) are specified for numerous
contaminants, including inorganic and
organic chemicals. For the most part, the
numerical criteria are identical to Federal
SDWA MCLs and MCLGs, although there
are several additional chemicals that have
criteria.
The MCL for arsenic in drinking
water has decreased since the
1988 Endangerment
Assessment. Arsenic
concentrations in OU-1 should
be further evaluated to
determine if currently associated
with a risk above regulatory
guidelines. Groundwater is not
being used at OU-1;
nonetheless, these requirements
remain relevant and appropriate.
2
-------
TABLE C2 - CHEMICAL-SPECIFIC ARARs AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Massachusetts Groundwater Quality
Standards (314CMR6.00)
Relevant and
Appropriate
These standards consist of groundwater
classifications which designate and assign
the uses of Commonwealth groundwaters,
and water quality criteria necessary to
sustain these uses. There is a presumption
that all groundwaters are Class I.
This regulation has been
rescinded as revisions to 314
CMR 5.00, promulgated in
December 2016, eliminated the
need for this regulation. These
requirements are no longer
applicable.
Federal Criteria, Guidance,
Advisories to be
Considered
EPA Risk Reference Doses (RfDs)
TBC
Guidance used to compute human health
hazard resulting from exposure to non-
carcinogens in site media. RfDs are dose
levels developed by the EPA for
noncarcinogenic effects and are considered
to be the levels unlikely to cause
significant adverse health effects
associated with a threshold mechanism of
action in human exposure for a lifetime..
Changes in toxicity values, including
benzo(a)pyrene, have occurred since the
fourth FYR. Other toxicity values have
also changed as described in the text.
The toxicity values for
manganese in drinking water
have decreased since the 1988
Endangerment Assessment.
Manganese concentrations in
OU-1 should be further
evaluated to determine if
associated with a risk above
regulatory guidelines. While
groundwater is not being used at
OU-1, these requirements
remain TBCs.
Federal Criteria, Guidance,
Advisories to be
Considered
EPA Carcinogen Assessment Group
Potency Factors
TBC
These factors are used to evaluate an
acceptable risk from a carcinogen. Potency
Factors are developed by the EPA from
Health Assessments or evaluation by the
Carcinogen Efforts Assessment Group.
Note that potency factors have changed
since the Endangerment Assessment. See
text for additional information.
These requirements remain
TBCs.
Federal Criteria, Guidance,
Advisories to be
Considered
EPA Health Advisories
NEW ADDITION
TBC
EPA publishes contaminant-specific health
advisories that indicate the non-
carcinogenic risks associated with
consuming contaminated drinking water.
Used to develop risk-based cleanup
standards.
Serves as the risk basis for
manganese in OU1 groundwater.
3
-------
TABLE C2 - CHEMICAL-SPECIFIC ARARs AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Criteria, Guidance,
Advisories to be
Considered
Guidelines for Carcinogenic Risk
Assessment - EPA/630/P-03/001F
NEW ADDITION
TBC
These guidelines provide guidance on
conducting risk assessments involving
carcinogens.
Considered as part of this FYR.
Federal Criteria, Guidance,
Advisories to be
Considered
Supplemental Guidance for Assessing
Susceptibility from Early-Life Exposure to
Carcinogens - EPA/630/R-03/003F
NEW ADDITION
TBC
This provides guidance on assessing risk
to children from carcinogens.
Considered as part of this FYR.
Federal Criteria, Guidance,
Advisories to be
Considered
Human Health Assessment Cancer Slope
Factors (CSFs)
NEW ADDITION
TBC
CSFs are estimates of the upper-bound
probability of an individual developing
cancer as a result of a lifetime exposure to
a particular concentration of a potential
carcinogen.
Considered as part of this FYR.
Federal Criteria, Guidance,
Advisories to be
Considered
Guidance on Remedial Actions for
Superfund Sites with PCB Contamination -
EPA-540-G-90-007 (August 1990)
NEW ADDITION
TBC
EPA Guidance for evaluating risks posed
by PCBs at Superfund sites. Used to
develop risk-based cleanup standards.
Considered as part of this FYR.
State Criteria, Guidance,
Advisories to be
Considered
Massachusetts Drinking Water Guidelines
TBC
MassDEP Drinking Water Guidelines
provide health-based values for chemicals
other than those with established MCLs.
These guidelines continue to be
periodically updated and remain
TBCs.
4
-------
TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
Resource Conservation and Recovery Act
(RCRA) Subtitle C; Hazardous Waste
Identification and Listing Regulations - 42
U.S.C. §6901 et seq.; 40 C.F.R. Parts 260-
262 and 264
NEW ADDITION
TBC
Federal standards used to identify,
manage, and dispose of hazardous waste.
Massachusetts has been delegated the
authority to administer these RCRA
standards through its state hazardous waste
management regulations. These
provisions have been adopted by the State.
Hazardous waste is managed
appropriately as part of the
remedy.
Federal Regulatory
Requirements
RCRA - General Facility Requirements (40
CFR 264.10 to 264.18). Alternatives SC-10
and MOM-2.
Relevant and
Appropriate
General facility requirements outline
general waste security measures,
inspections, and training requirements.
These requirements remain
relevant and appropriate and
have been complied with.
Federal Regulatory
Requirements
RCRA - Incineration Requirements (40
CFR 264 Subpart 0). Alternative SC-10.
Relevant and
Appropriate
Principal Organic Hazardous Constituents
(POHC) are to be destroyed to 99.99
percent destruction and removal
efficiency, stringent particulate and HCL
limits are imposed.
The Explanation of Significant
Differences (ESD) eliminated
on-site incineration component
required by the ROD in favor of
off-site incineration and disposal
of soil from Wildwood, NEP
and Olympia. In-situ soil vapor
extraction (SVE) with activated
carbon treatment is now being
used on the UniFirst property (in
addition to pump and treat as an
enhancement). Therefore, these
requirements are no longer
relevant and appropriate.
Federal Regulatory
Requirements
RCRA - Land Disposal Restrictions (40
CFR 268). Alternatives SC-10 and MOM-2
Relevant and
Appropriate
Provides treatment standards and
schedules governing land disposal of
RCRA wastes and of materials
contaminated with or derived from RCRA
wastes.
The ESD eliminated on-site
incineration component required
by the ROD in favor of off-site
incineration and disposal of soil
from Wildwood, NEP and
Olympia. Waste materials
potentially impacted by RCRA
wastes may still require disposal
from time to time and thus this
ARAR is relevant and
appropriate.
1
-------
TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
Toxic Substances Control Act (TSCA);
PCB Remediation Waste -15 U.S.C. 2601
et seq.; 40 C.F.R. 761.61(c)
NEW ADDITION
TBC
This section of the TSCA regulations
provides risk-based cleanup and disposal
options for PCB remediation waste based
on the risks posed by the concentrations at
which the PCBs are found. Written
approval for the proposed risk-based
cleanup must be obtained from the
Director, Office of Site Remediation and
Restoration, USEPA Region 1.
Federal Regulatory
Requirements
TSCA - PCB Incineration Requirements (40
CFR 761.70(a)(2). Alternative SC-10.
Applicable
Contaminated soil in excess of 50 ppm
PCB concentration must be incinerated to
a 99.9999 percent destruction efficiency.
The ESD eliminated on-site
incineration component required
by the ROD in favor of off-site
incineration and disposal of soil
from Wildwood, NEP and
Olympia. Therefore, these
requirements are no longer
applicable, as there are no
present plans for off-site PCB
disposal via incineration.
Federal Regulatory
Requirements
RCRA - Generator and Transporter
Responsibilities (40 CFR 262 and 263).
Alternatives SC-10 and MOM-2.
Relevant and
Appropriate
Provides standards for packaging, labeling,
marking, placarding, accumulating, and
manifesting hazardous waste prior to and
for off-site disposal.
These requirements remain
relevant and appropriate.
Federal Regulatory
Requirements
RCRA - Container Requirements (40 CFR
264 Subpart I). Alternatives SC-10 and
MOM-2.
Relevant and
Appropriate
This regulation sets forth RCRA
requirements for use and management of
containers at RCRA facilities.
These requirements remain
relevant and appropriate and
have been complied with. On-
site treatment systems continue
to generate RCRA regulated
waste materials and must
comply with container
requirements.
2
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
CWA National Pollutant Discharge
Elimination System (NPDES) (40 CFR 122
to 125). Alternatives MOM-2.
Applicable
Provides permitting process for surface
water body point source discharges. The
NPDES permit program is administered by
authorized states (Massachusetts is not
currently authorized).
Treated water is discharged to a
storm sewer at UniFirst.
Compliance monitoring is
conducted monthly. At Grace,
treated water is discharged to
Snyder Creek. Compliance
monitoring is conducted
monthly. Treated water at
Wildwood is discharged to the
Abeijona River. Compliance
monitoring is conducted
monthly. These requirements
remain applicable and are being
complied with.
Federal Regulatory
Requirements
Clean Water Act; Toxic Pollutant Effluent
Standards - 40 CFR 129
NEW ADDITION
Relevant and
Appropriate
Regulates surface water discharges of
specific toxic pollutants, specifically
certain pesticides and PCBs.
Any water generated from the
pump and treat systems and
during installation and
management of
monitoring/extraction wells
is/will be treated to meet
applicable toxic pollutant
discharge standards (if regulated
contaminants are present) where
the water is to be discharged to
surface waters.
Federal Regulatory
Requirements
Clean Water Act, National Recommended
Water Quality Criteria (NRWQC) - 33
U.S.C. § 1314, 40 CFR Part 131
NEW ADDITION
Relevant and
Appropriate
NRWQC are provided by EPA for
chemicals for both the protection of human
health and the protection of aquatic life.
They are used to establish monitoring
standards for surface waters and
sediments, if required for the remedial
action.
These requirements remain
relevant and appropriate and
have been complied with.
3
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
Safe Drinking Water Act; National primary
drinking water regulations, Maximum
Contaminant Levels 42 U.S.C. § 300f et
seq.; 40 C.F.R. 141, Subparts B and G-
NEW ADDITION
Relevant and
Appropriate
Federal drinking waters standards used as
groundwater monitoring standards when
contaminated media left in place. The
standards arecused as groundwater
monitoring standards until groundwater
cleanup is achieved.
These requirements remain
relevant and appropriate.
Federal Regulatory
Requirements
Safe Drinking Water Act; National primary
drinking water regulations, Maximum
Contaminant Level Goals - 42 U.S.C. §
300f et seq.; 40 C.F.R. 141, Subpart F
NEW ADDITION
Relevant and
Appropriate for
non-zero
MCLGs only;
MCLGs set as
zero are To Be
Considered.
Federal drinking waters standards used as
groundwater monitoring standards when
contaminated media left in place.
Standards used as groundwater monitoring
standards until groundwater cleanup is
achieved.
These requirements remain
relevant and appropriate.
Federal Criteria, Guidance,
Advisories to be
Considered
EPA Health Advisories
NEW ADDITION
TBC
Federal risk-based standards for
groundwater used as groundwater
monitoring standards when contaminated
media left in place. Risk-based standards
developed using these advisories used as
groundwater monitoring standards until
groundwater cleanup is achieved.
Serves as the risk basis for
manganese in OU1 groundwater.
Federal Criteria, Guidance,
Advisories to be
Considered
Summary of Key Existing EPA CERCLA
Policies for Groundwater Restoration -
OSWER Directive 9283.1-33 (June 26,
2009)
NEW ADDITION
Relevant and
Appropriate
Guidance on developing groundwater
remedies at CERCLA sites. Groundwater
remediation standards called for in this
guidance will be satisfied as long as
groundwater cleanup will be achieved
through operating the pump and treat
systems and ICs are established, that will
prevent exposure to contaminated
groundwater until cleanup standards are
achieved.
These requirements remain
relevant and appropriate.
4
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Criteria, Guidance,
Advisories to be
Considered
Generation of investigation derived waste -
USEPA OSWER Publication 9345.3-03 FS
(January 1992)
NEW ADDITION
Relevant and
Appropriate
Guidance on the management of
Investigation-Derived Waste (IDW) in a
manner that ensures protection of human
health and the environment. IDW
generated will be managed based on
guidance standards.
These requirements remain
relevant and appropriate.
Federal Criteria, Guidance,
Advisories to be
Considered
OSWER Technical Guide for Assessing
and Mitigating the Vapor Intrusion Pathway
from Subsurface Vapor Sources to Indoor
Air - OSWER Publication 9200.2-154
(June 2015)
NEW ADDITION
Relevant and
Appropriate
EPA guidance for addressing vapor
intrusion issues at CERCLA sites.
Applicable to redevelopment
activities.
Federal Regulatory
Requirements
DOT - Transportation of Hazardous Waste
Requirements (49 CFR 171 to 179).
Alternatives SC-10 and MOM-2.
Relevant and
Appropriate
These regulations set forth DOT
requirements for transportation of
hazardous waste. Transporters of
hazardous waste are subject to both DOT
and EPA enforcement of the regulations.
Consequently, the DOT and EPA
coordinate their efforts to obtain
compliance with both the RCRA and
Hazardous Materials Transportation
Action (HMTA) regulations.
These requirements are off-site
requirements and are not
ARARs per se. All applicable
requirements will be met.
Federal Regulatory
Requirements
RCRA - Tank Requirements (40 CFR 264
Subpart J). Alternative SC-10.
Relevant and
Appropriate
Provides design and operating
requirements for RCRA waste treatment
facilities utilizing tanks.
These requirements remain
relevant and appropriate. Note
that none of the PRP sites use
tanks to store or treat hazardous
waste at this time.
Federal Regulatory
Requirements
RCRA - Preparedness and Prevention (40
CFR 264.30 to 264.31). Alternatives SC-10
and MOM-2.
Relevant and
Appropriate
This regulation requires that facilities be
designed, constructed, maintained, and
operated to minimize the possibility of a
fire, explosion, or any unplanned sudden
or non-sudden release of hazardous waste
or hazardous waste constituents to air, soil,
or surface water which could threaten
human health or the environment.
These requirements remain
relevant and appropriate and
have been complied with.
5
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
RCRA - Contingency Plan and Emergency
Procedures (40 CFR 264.50 to 264.56).
Alternatives SC-10 and MOM-2.
Relevant and
Appropriate
This regulation outlines the requirements
for contingency planning and emergency
procedures to be used for explosions, fires,
etc.
These requirements remain
relevant and appropriate and
have been complied with.
Federal Regulatory
Requirements
RCRA - Manifesting, Recordkeeping, and
Reporting (40 CFR 264.70 to 264.77).
Alternatives SC-10 and MOM-2.
Relevant and
Appropriate
This regulation specifies manifesting,
recordkeeping and reporting requirements
for RCRA facilities.
These requirements remain
relevant and appropriate and
have been complied with.
Federal Regulatory
Requirements
RCRA - Closure and Post Closure (40 CFR
264 Subpart G). Alternative SC-10.
Relevant and
Appropriate
This regulation details the specific
requirements and performance standards
for closure and post-closure care of
hazardous waste facilities.
Closure requirements may be
relevant and appropriate to soil
clean ups.
Federal Regulatory
Requirements
RCRA, Air Emission Standards for Process
Vents - 40 C.F.R. Part 264, Subpart AA
NEW ADDITION
TBC
Standards for process vents for air
treatment systems for RCRA wastes that
have total organic concentrations of 10
ppm or greater. RCRA emissions
standards not delegated to the State.
Applicable, if VOC emissions over 10
ppm or greater; Relevant and Appropriate,
if less than 10 ppm.
If air treatment of VOCs is
required, emission standards for
any process vents, if present,
will be achieved.
Federal Regulatory
Requirements
RCRA, Air Emission Standards for
Equipment Leaks - 40 C.F.R. Part 264,
Subpart BB
NEW ADDITION
TBC
Standards for preventing air equipment
leaks for systems that treat RCRA wastes
that have total organic concentrations of
10 ppm or greater. RCRA emissions
standards not delegated to the State.
Standards for preventing air
emission leaks from treatment
systems for VOCs will be
achieved, if applicable.
Federal Regulatory
Requirements
OSHA - General Industry Standards (29
CFR 1910). Alternatives SC-10 and
MOM-2.
Applicable
This regulation specifies the 8 hour time -
weighted average concentration for
various chemicals/compounds; site control
procedures; training; and protective
clothing requirements for worker
protection at site remediation projects.
These requirements are not
environmental standards and
therefore, are not ARARs.
However, they are health and
safety requirements that are
required to be met.
6
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
OSHA - Safety and Health Standards (29
CFR 1926). Alternatives SC-10 and
MOM-2.
Applicable
This regulation specifies the type of safety
equipment and procedures to be followed
during construction and excavation
activities.
These requirements are not
environmental standards and
therefore are not ARARs.
However, they are health and
safety requirements that are
required to be met.
Federal Regulatory
Requirements
OSHA - Recordkeeping, Reporting and
Related Regulations (29 CFR 1904).
Alternatives SC-10 and MOM-2.
Applicable
The regulation outlines the recordkeeping
and reporting requirements for
occupational injuries and illness for an
employer under OSHA.
These requirements are not
environmental standards and
therefore are not ARARs.
However, they are health and
safety requirements that are
required to be met.
Federal Regulatory
Requirements
TSCA - Marking of PCBs and PCB Items
(40 CFR 761.40 to 761.45). Alternative
SC-10.
Applicable
50 ppm PCB storage areas, storage items,
and transport equipment must be marked
with the HL mark.
These requirements have been
complied with, when needed.
Federal Regulatory
Requirements
TSCA - Storage and Disposal (40 CFR
761.50 to 761.79). Alternative SC-10.
Applicable
This requirement specifies the
requirements for storage and
disposal/destruction of PCBs in excess of
50 ppm. These PCB-contaminated soils
would have to be disposed of or treated in
a facility permitted for PCBs, in
compliance with TSCA regulations.
Treatment must be performed using
incineration or some other method with
equivalent destruction efficiencies.
The storage requirements were
complied with during soil
excavation. Disposal
requirements applied to, and
were complied with, for PCB-
impacted soil that was shipped
off-site.
Federal Regulatory
Requirements
TSCA - Records and Reports (40 CFR
761.180 to 761.185). Alternative SC-10.
Applicable
This regulation outlines the requirements
for recordkeeping for storage and disposal
of >50 ppm PCBs.
These requirements were
complied with.
7
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Regulatory
Requirements
CAA - National Air Quality Standards for
Total Suspended Particulates (40 CFR
129.105, 750, now 40 CFR Part 50.6 and
50.7). Alternatives SC-10 andMOM-2.
Applicable
This regulation specifies maximum
primary and secondary 24 hour
concentrations for particulate matter.
When first promulgated, total suspended
particulate matter (TSP) was chosen as the
size indicator for particulate matter (PM)
regulation. Subsequently, PM has been
modified to include size specific standards
forPMlO (particulate matter 10
micrometers or less in diameter) and
PM2.5 (particulate matter 2.5 micrometers
or less in diameter), respectively.
Compliance with this regulation,
including potential fugitive dust
levels, is applicable.
Federal Regulatory
Requirements
Clean Air Act (CAA), Hazardous Air
Pollutants; National Emission Standards for
Hazardous Air Pollutants (NESHAPS) -
42.U.S.C. § 112(b)(1); 40 C.F.R. Part 61
NEW ADDITION
Relevant and
Appropriate
The regulations establish emissions
standards for 189 hazardous air pollutants.
Standards set for dust and other release
sources.
Remedial activities, including
air discharges from the pump
and treat system and excavation
and management of
monitoring/extraction wells, are
implemented in accordance with
these rules. No air emissions
from remedial activities will
cause air quality standards to be
exceeded. Dust standards will
be complied with during
excavation and management of
materials within the OU.
8
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
Federal Criteria Guidance
Advisories to be
Considered
RCRA - Proposed Air Emission Standards
for Treatment Facilities (52 FR 3748,
February 5, 1987). Alternatives SC-10 and
MOM-2.
TBC
This proposal would set performance
standards for RCRA treatment facility air
emissions for VOCs. The final rule (55 FR
25454) is dated June 21, 1990, with
typographical errors corrected on April 26,
1991 (56 FR 19514).
Applies to the control of air
emissions from hazardous waste
treatment, storage, and disposal
facilities (TSDF) that are already
required to have a RCRA permit
to reduce VOC emissions from
facilities managing organic
hazardous waste through the
installation, operation, and
maintenance of control
equipment, leak detection and
repair, and recordkeeping and
reporting.
Federal Criteria Guidance
Advisories to be
Considered
EPA Groundwater Protection Strategy.
Alternative MOM-2.
TBC
EPA Classifies groundwater into three
categories depending on current, past or
potential use. This serves as a guide for
protection of the resource.
The Wells G&H aquifer is a
Class IIB aquifer (potentially
usable aquifer). The requirement
for Class IIB standards to be
attained following remediation.
Federal Criteria Guidance
Advisories to be
Considered
USEPA office of Solid Waste and
Emergency Response, Directive 9355.0-28;
Air Stripper Control Guidance. Alternative
MOM-2.
TBC
Establishes guidance on the control of air
emissions from air strippers used at
Superfund sites for groundwater treatment.
These requirements are TBC for
the Wildwood vapor collection
system and have been complied
with. At this time, the Unifirst
system does not employ air
stripping, but rather activated
carbon treatment.
State Regulatory
Requirements
Massachusetts Wetlands Protection
Requirements (310 CMR 10.00).
Alternatives SC-10 and MOM-2
Applicable
These requirements control regulated
activities in freshwater wetlands, 100 year
floodplains, and 100 foot buffer zones
beyond these areas. Regulated activities
include virtually any construction or
excavation activity. Performance standards
are provided for evaluation of the
acceptability of various activities. The
Wetland Protection Act was most recently
amended in October 2014.
Activities at the Source Areas
governed by this requirement are
complete. No PRP facility is
proposing work in a wetland.
9
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Massachusetts Waterways Licenses (310
CMR 9.00). Alternative MOM-2
Applicable
Controls dredging, filling, and other work
in water of the Commonwealth. These
regulations were most recently amended in
March 2017.
The centralized treatment
facility for the Wells G&H
Source Areas is no longer a
component of the remedy;
therefore, these requirements are
not applicable to OU-1.
State Regulatory
Requirements
Massachusetts Certification for Dredging
and Filling (314 CMR 9.00). Alternative
MOM-2.
Applicable
Establishes water quality-based standards
for filling activities (CWA Section 401).
These regulations were most recently
amended in October 2014.
Source area pumping and central
area treatment require placement
of pipes under and across the
Abeijona River. Proper
measures were taken to avoid
contravention of water quality
standards (i.e., turbidity) during
installation of pipes, thereby
complying with the ARAR. The
Central Area treatment facility is
no longer a component of the
remedy; therefore these
requirements are not applicable.
State Regulatory
Requirements
Surface Water Discharge Permit Program
Requirements (314 CMR 3.00). Alternative
MOM-2.
Applicable
Provides permitting process for surface
water body point discharges. These
regulations provide that discharges to
waters of the Commonwealth shall not
result in exceedances of MA Surface
Water Quality Standards (MSWQS). This
requirement is generally aligned with
CWA NPDES.
Water discharges to the
Abeijona River (e.g., UniFirst
system discharges) are treated to
ensure that violations of the
MassDEP water quality
standards for that water body do
not occur. These regulations
have not been amended since
2007 (prior to submittal of the
third FYR).These requirements
remain applicable and have been
complied with.
10
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Surface Water Quality Standards (314
CMR 4.00) Alternative MOM-2.
Applicable
This regulation consists of surface water
classifications which designate and assign
uses and water quality criteria necessary to
sustain the designated uses. These
regulations were amended in December
2013.
Water discharges to the
Abeijona River (e.g., UniFirst
system discharges) are treated to
ensure that violations of the
MassDEP water quality
standards for that water body do
not occur. The Abeijona River
continues to be designated a
Class B water body. These
requirements remain applicable
and have been complied with.
State Regulatory
Requirements
Groundwater Discharge Permit Program
(314 CMR 5.00). Alternative MOM-2.
Applicable
This regulation consists of groundwater
classifications which designate and assign
uses, and water quality criteria necessary
to sustain the designated uses. Unless the
State determines that the groundwater is
not an underground source of drinking, all
ground waters of the Commonwealth are
designated as a source of potable water
supply.
This regulation does not apply at
this time as there are no
discharges to groundwater per
the regulation, but would need to
be considered if groundwater
discharge was selected as a
discharge option.
State Regulatory
Requirements
Groundwater Quality Standards (314 CMR
6.00). Alternative MOM-2.
Applicable
This regulation consists of groundwater
classifications which designate and assign
uses, and water quality criteria necessary
to sustain the designated uses.
This regulation has been
rescinded as revisions to 314
CMR 5.00 (see above),
promulgated in December 2016,
eliminated the need for this
regulation. The requirements of
314 CMR 6.00 are no longer
published.
11
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Massachusetts Supplemental Requirements
for Hazardous Waste Management
Facilities-314 C.M.R. 8.03
NEW ADDITION
Relevant and
Appropriate
This regulation outlines the additional
requirements that must be satisfied in
order for a RCRA facility to comply with
the NPDES regulation. Any water
generated during operation of the pump
and treat system or during
extraction/monitoring well drilling or
maintenance that meets hazardous waste
standards will be treated to meet NPDES
standards, if the water is to be discharged
to surface waters.
These requirements are relevant
and appropriate and have been
complied with.
State Regulatory
Requirements
Massachusetts Drinking Water Regulations
Maximum Contaminant Levels (MCLs) and
Maximum Contaminant Level Goals
(MCLGs) (310 CMR 22.00)
Relevant and
Appropriate
Massachusetts MCLs establish levels of
contaminants allowable in public drinking
water supplies. The Massachusetts MCLs,
listed in 310 CMR 22.00, consist of
promulgated EPA MCLs which have
become effective, as well as
Massachusetts-specific MCLs. The
regulations were last promulgated on
March 11, 2016. Massachusetts Maximum
Contaminant Levels (MCLs) and
Maximum Contaminant Level Goals
(MCLGs) are specified for numerous
contaminants, including inorganic and
organic chemicals. For the most part, the
numerical criteria are identical to Federal
SDWA MCLs and MCLGs, although there
are several additional chemicals that have
criteria.
The MCL for arsenic in drinking
water has decreased since the
1988 Endangerment
Assessment. Arsenic
concentrations in OU-1 should
be further evaluated to
determine if currently associated
with a risk above regulatory
guidelines. Groundwater is not
being used at OU-1;
nonetheless, these requirements
remain relevant and appropriate.
State Regulatory
Requirements
Air Emission Limitations for Unspecified
Sources of Volatile Organic Compounds
(310 CMR 7.18(17)) Alternative MOM-2.
Relevant and
Appropriate
No person shall cause, suffer, allow or
permit emissions from the facility in
excess of an emission rate achievable
through the implementation of reasonably
available control technology (RACT) as
required in an emission control plan and
regulatory schedule.
The requirements remain
relevant and appropriate since
the OU-1 treatment systems
continue to generate VOC
emissions (i.e., Wildwood and
Unifirst).
12
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Hazardous Waste Management
Requirements (310 CMR 30.00).
Alternatives SC-10 and MOM-2.
Relevant and
Appropriate
These regulations provide comprehensive
monitoring, storing, recordkeeping, etc.
programs at hazardous waste sites. These
regulations were amended in January
2015.
The requirements remain
relevant and appropriate. Since
the OU-1 treatment systems
continues to generate RCRA
regulated wastes.
State Regulatory
Requirements
Hazardous Waste Incinerator Air Emission
Requirements 310 CMR 7.08(4).
Alternative SC-10.
Relevant and
Appropriate
Provides air emission requirements for
hazardous waste incinerators. Principal
Organic Hazardous Constituents (POHCS)
destroyed to 99.99 percent, PCBs to
99.9999 percent. Particulate, HCL and CO
emissions also controlled.
The ESD eliminated on-site
incineration component required
by the ROD in favor of off-site
incineration and disposal of soil
from Wildwood, NEP and
Olympia. Therefore, these
requirements are no longer
relevant since off-site
incineration of wastes from OU-
1, if utilized, will not take place
in Massachusetts.
State Regulatory
Requirements
Ambient Air Quality Standards for the
Commonwealth of Massachusetts (310
CMR 6.00). Alternatives SC-10 and
MOM-2.
Applicable
This regulation specifies primary and
secondary ambient air quality standards to
protect public health or welfare from
anticipated adverse effects of pollutants
such as particular matter, carbon
monoxide, ozone, sulfur dioxide, nitrogen
dioxide, and lead.
These requirements remain
applicable and have been
complied with. Contaminated
soils may still require removal
and hence, the requirements
would be applicable (e.g,
particulate matter).
State Regulatory
Requirements
Air Pollution Control Regulations (310
CMR 7.00). Alternatives SC-10 and
MOM-2.
Applicable
Regulates new sources of air pollution to
prevent air quality degradation. Requires
the use of "Best Available Control
Technology" (BACT) on all new sources.
These regulations were amended in June
2014 (Asbestos Regulatory Reform) and
additional amendments have been
proposed by MassDEP.
These requirements are
applicable for the Wildwood
vapor collection system and
These requirements apply to the
UniFirst soil vapor extraction
and treatment (SVET) system
and are being complied with.
State Regulatory
Requirements
Prevention & Abatement of Air Pollution
Episodes & Emergencies (310 CMR 8.00)
Applicable
Regulation to prevent ambient air
concentrations from reaching levels which
would constitute significant harm, or
imminent and substantial endangerment to
the health of persons.
These requirements remain
applicable and have been
complied with.
13
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TABLE C3 - ACTION-SPECIFIC ARARS AND TBCs
WELLS G&H SITE - OU-1
FEDERAL OR STATE
ARAR
REQUIREMENTS
ORIGINAL
(ROD)
STATUS
REQUIREMENT SYNOPSIS AND
APPLICATION FOR THE RI/FS
FIFTH FIVE-YEAR
REVIEW
State Regulatory
Requirements
Employee and Community Right-to-Know
Requirements (310 CMR 33.00).
Alternatives SC-10 and MOM-2.
Applicable
Establishes rules for the dissemination of
information related to toxic and hazardous
substances to the public.
These requirements remain
applicable and have been
complied with.
State Guidance and
Advisories
Massachusetts Standard References for
Monitoring Wells - WSC-310-91
NEW ADDITION
Applicable
Guidance on locating, drilling, installing,
sampling and decommissioning
monitoring wells. Monitoring wells will be
established, maintained, and
decommissioned in accordance with these
guidance standards
These requirements are
applicable.
14
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Appendix D
Site Inspection Information
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Site Inspection Summary
The inspection of the five OU1 Source Area Properties was conducted on 2/18/2019 and 2/19/2019. In
attendance were David Sullivan, LSP, and Jeffrey Hansen, PH, of TRC, on behalf of the EPA RPM. The
purpose of the inspection was to assess the protectiveness of the remedy.
The following individuals attended inspections for the respective SDs:
• Grace Property: Clayton Smith, Project Coordinator - de Maximis, Inc.; Van Sawyer, Technical
Services Manager - GES, and operator of the groundwater extraction and treatment system; and
Paul Bucens of W.R. Grace.
• UniFirst Property: Tim Cosgrave, Director of EHS for UniFirst and O&M Manager for
GWETS.
• Wildwood Property: Peter Cox, PG, Project Manager - AECOM and Edward Zygarowski,
O&M Manager for GWETS and AS/SVE System, also of AECOM.
• NEP Property: Jeff Hamel, LSP and Project Manager - Woodard and Curran, Inc.; and
• Olympia Property: Christene Binger, Associate Professional Hydrogeologist - Geolnsight.
The inspections included visual inspection of each Source Area Property for site access, record keeping,
and remedy implementation and monitoring activities. Overall, the site inspections indicated that
remedies at the Source Area Properties are being effectively implemented. Pertinent findings are
summarized below by Source Area Property:
Grace Property (February 18, 2019)
Site Access and Security
At the time of the inspection, the Grace Property was undergoing development resulting in public access
to the property. Portions of the property immediately adjacent to Washington Street have been developed
as eateries and are currently accessible to the public. The building housing the GWETS is located on the
rear half of the property that is currently undergoing development as a hotel and restaurant. The GWETS
building is locked when O&M personnel are not on-site and equipped with a security system. There have
been no reported incidents of vandalism during the FYR period. A visitors' log is maintained in the
treatment building.
GWETS
The groundwater treatment system was observed to be in good condition. At the time of inspection, where
appropriate, equipment and sampling points were properly identified and operating, and no leaks were
observed. Two of the three active recovery wells (RW-17 and RW-20) were also observed and were
appropriately secured. Snow cover and access constraints associated with the property development
hindered the observation of the third active recovery well (RW-22RE). The outfall for treated
groundwater at Snyder Creek was observed to be unobstructed and in good condition. An O&M log for
the system is maintained on-site and was up-to-date. No unexpected changes in cost or scope of O&M or
frequent repairs were reported and no optimization opportunities specific to the site inspection were
identified. However, Mr. Smith and Mr. Sawyer noted the inherent challenges in operating an aging
system.
1
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Monitoring Well Network
Snow cover and ongoing development activities precluded locating and observing all site monitoring
wells. However, the following observations were noted:
• Observed wells were found to be locked or secure;
• Some wells in Washington Street need to be raised; and
• Some wells are boxed in base course and will need further adjustment when final asphalt is laid
out.
While not directly related to the protectiveness of the remedy, it is recommended that all monitoring wells
be located and assessed when snow cover disappears, and the development has been completed to assess
maintenance needs for the monitoring network, if any.
UniFirst Property (February 19, 2019)
Site Access and Security
The perimeter chain-link fence controlling access to the property was in good condition and signage
(authorized access only) is posted on the door to the treatment facility. Sampling ports for SVE wells are
located behind walls and are accessed by a locked door at each SVE well location. No incidents of
vandalism were reported during the inspection.
GWETS
The existing groundwater treatment system infrastructure was observed to be in good condition. At the
time of inspection, where appropriate, equipment and sampling points were properly identified and
operating, and no unusual leaks were observed. O&M staff visit the site on a weekly basis. Maintenance
records are maintained off-site at UniFirst's Office in Wilmington; however, recent records were provided
for review during the site inspection. No unexpected changes in cost or scope of O&M or frequent repairs
to the groundwater treatment system were reported and no immediate optimization opportunities specific
to the site inspection were identified.1 During the inspection, the wellheads for both recovery wells (UC-
22 and EX-1) were observed and found to be secure and in good condition. Mr. Cosgrave reported that
EX-1 was not pumping at the desired rate to maintain the target water level elevation on the day of the
inspection and that trouble-shooting was ongoing to rectify this issue.
SVET System
Mr. Cosgrave reported that the Johnson Company of Montpelier, Vermont provides routine O&M
services for the SVET. The infrastructure for the SVET system was observed to be in good condition and
operating. Observed SVE wells were secure at the time of inspection. No unexpected changes in cost or
scope of O&M or frequent repairs to the SVET system were reported and no optimization opportunities
specific to the site inspection were identified.
Monitorins Well Network
Due to snow cover, not all of the flush mounted wells could be located or observed. However, observed
wells and monitoring probes located inside the building were found to be properly secured. Covers for
1 Following SVE, UniFirst agreed during the previous FYR period to prepare a work plan to perform 1SCO
treatment to address residual DNAPL beneath the east side of the UniFirst Building near monitoring well UC-8.
2
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some of the observed flush-mounted wells outside the building were missing bolts and at least one
location with a stick up (i.e., PZ1S/D) did not have a lock. Flush-mount wells were not opened during
inspection as the covers were frozen in place. In the Year 25 Annual Report, DP37D, UC31M and
UC3 ID were found to be sand locked. According to Tim Cosgrave, the Johnson Company is currently
working on a plan to restore these wells. Although wells outside the building are within a fenced area, the
property is accessible to the public during operating hours and some wells are located outside the fence.
All wells monitored for water levels/water quality for the UniFirst remedy should be inspected after snow
cover has melted to identify wells that need to be secured and/or require maintenance.
Wildwood Property (February 18, 2019)
Site Access and Security
The north, east and south sides of the Wildwood Property are fenced, and the east side is bordered by the
Aberjona River, which discourages trespassing. Fencing observed during the inspection appears to be in
good condition. Access to the Wildwood Property is through a gated gravel road off Cedar Street with a
warning sign indicated restricted access. The gate is reported to be locked when O&M or sampling
personnel are not present on-property. The GWETS building is locked and equipped with a security/alarm
system when O&M personnel are not on-property. There have been no reported incidents of vandalism
during the FYR period an no evidence of trespassing was observed during the inspection. A site security
log for site visitors is maintained in the treatment building.
GWETS
The existing groundwater treatment system infrastructure was observed to be in good condition and
maintenance was up-to-date. Where appropriate, equipment and sampling points were properly identified
and operating, and no leaks were observed. O&M staff visit the property on a regular basis. Maintenance
logs are maintained at the treatment system building. No unexpected changes in cost or scope of O&M
were reported and no immediate optimization opportunities specific to the site inspection were identified.2
Mr. Cox and Mr. Zygarowski noted the inherent challenges in operating an aging system (e.g., difficulty
in finding off-the-shelf part; in some cases, parts need to be fabricated). During the inspection, the
wellheads for recovery wells BW-18RD(LO)DR and BW-19R were observed. The well heads are below
ground in a protective enclosure; however, the recovery well enclosures are not locked.
SVET System
The infrastructure for the SVET system was observed to be in good condition. No unexpected changes in
cost or scope of O&M were reported. Optimization of the AS/SVE portion of the remedy is part of an
ongoing conversation with EPA and is being completed in a phased manner. A work plan has been
submitted by the SD to implement Phase I expansion and radius of influence testing in the northern
portion of the treatment cell (AECOM, 2018). Approval of the work plan is pending. Off-gas treatment
has been disconnected temporarily with EPA approval. Off-gas treatment will resume, as warranted,
pending installation of additional recovery wells and/or air sparge wells that increase VOC concentrations
in influent.
2 EPA is working with the SD to locate and install additional recovery wells to capture and treat contaminated
groundwater not currently captured by existing wells. Modifications to the treatment system may be required
pending assessment of flow rates and water quality of additional recovery wells. EPA is also engaged in discussions
with the SD regarding pilot testing ISCO in deep bedrock in the vicinity of deep bedrock well BW-6RD(LO). These
discussions are ongoing.
3
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Monitoring Well Network
Not all wells could be located or observed because of snow cover or safety concerns (e.g., icy conditions
on wooden boards to wells in Abeijona wetlands). However, protective covers at several well locations
were not locked/secured, reportedly because the property is fenced, access is via a locked gate which
limits access, and O&M personnel are routinely present. It was also noted that at least one well located in
an area subject to periodic flooding (BSW-14) did not have an expansion plug to prevent surface water
from entering the well. A comprehensive assessment of all wells is recommended once snow cover
disappears to identify wells requiring maintenance, if any.
NEP Property (February 18, 2019)
NEP currently docs not have an active remediation system. The only activities currently ongoing at the
property in association with the remedy is groundwater monitoring. No unexpected changes in cost or
scope of O&M or frequent repairs were reported and no optimization opportunities specific to the site
inspection were identified.3
The trailer housing the mothballed AS/SVE system is located behind the NEP building behind a gate that
is locked when personnel are not at the facility and the trailer itself is locked. With the exception of NEP-
3 which had a PVC expansion plug, wells were observed to be locked during the site inspection.
Olympia Property (February 19, 2019)
No system is currently active at the Olympia Property, therefore O&M consists of groundwater
sampling and periodic oxidant injection (i.e., ISCO) activities.
Site Access and Security
The Olympia Property is accessed through the locked gate at the entrance to the Wildwood Property. A
chain-link fence surrounds the property and access is controlled by a second locked gate in the chain-link
fence. The fence was in generally in good condition at the time of inspection and no indication of
trespassing or vandalism was observed.
Monitoring/Injection Well Network
Monitoring wells located inside the fenced area were observed to be unlocked, most without covers.
Several monitoring wells had sampling tubing protruding from the well, and PVC casing extends above
the steel protective casing at several location. Although the property is surrounded by fencing, the
fencing is unlikely to deter a determined trespasser. For this reason, it is recommended that all wells
should be properly secured between monitoring and injection events.
3 In 2016, PCE and TCE were detected in deeper bedrock groundwater above cleanup goals. Further characterization
is planned as part of OU2 investigations to further assess the extent of impacts in deeper bedrock groundwater.
Decisions concerning active pump and treat of deeper bedrock groundwater will follow.
4
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Five-Year Review Site Inspection Checklist
I. SITE INFORMATION
Site name: New England Plastics (NEP)
Date of inspection: 02.18.2019
Location and Region: Woburn, MA (EPA Region 1)
EPA ID: MAD980732168
Agency, office, or company leading the five-year
review: EPA
Weather/temperature: Cold, cloudy
~ Monitored natural attenuation
~ Groundwater containment
~ Vertical barrier walls
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
~ Access controls
~ Institutional controls
~ Groundwater pump and treatment
~ Surface water collection and treatment
¦ Other - Soil Vapor Extraction [SVE] and Air Sparging (AS) operated 1998-2000 and was shut down
in March 2000. Monitoring of overburden and shallow bedrock groundwater is conducted every other
year (i.e., biennially).
Attachments:
Inspection team roster attached
~ Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M site manager Jeff Hamel. Woodard & Curran. LSP Vice President
Name Title
Interviewed B|at site ~ at office ~ by phone Phone No. 978-317-3635
Problems, suggestions; ~ Report attached
2. O&M staff Assigned as needed by Jeff Hamel
Name
Interviewed Dat site ~ at office ~ by phone Phone No.
Problems, suggestions; ~ Report attached
(see above)
Title
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, etc.) Fill in all that apply. Not applicable.
Agency
Contact
Name
Problems; suggestions; ~ Report attached
Title
Date Phone no.
Agency
Contact
Name
Problems; suggestions; ~ Report attached
Title
Date Phone no.
-------
4.
Other interviews (optional) ~ Report attached.
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
O&M Documents
¦ O&M manual
¦ As-built drawings
¦ Maintenance logs
l Readily available
l Readily available
¦Readily available
Up to date
l Up to date
l Up to date
~ N/A
~ N/A
~ N/A
Remarks Monitoring plan and checklist for SVE/AS system was kept on-site while system was active.
System trailer is on-site and documents were maintained in the trailer.
Site-Specific Health and Safety Plan ~ Readily available ¦ Up to date ~ N/A
¦ Contingency plan/emergency response plan ~ Readily available ¦ Up to date ~ N/A
Remarks HASP kept up to date at office and taken in the field when field work is (i.e.. monitoring)
Is performed.
O&M and OSHA Training Records ¦ Readily available ¦ Up to date ~ N/A
Remarks According to Mr. Hamel. OSHA training records are maintained at offices of Woodard &
Curran.
Permits and Service Agreements
~ Air discharge permit
~ Effluent discharge
~ Waste disposal, POTW
~ Other permits
Remarks
~ Readily available
~ Readily available
~ Readily available
~ Readily available
~ Up to date
~ Up to date
~ Up to date
~ Up to date
N/A
N/A
N/A
N/A
Gas Generation Records
Remarks
~ Readily available ~ Up to date ¦ N/A
Settlement Monument Records
Remarks
~ Readily available
~ Up to date
IN/A
Groundwater Monitoring Records ¦ Readily available
Remarks Maintained at offices of Woodard & Curran.
I Up to date ~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
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Leachate Extraction Records ~ Readily available ~ Up to date ¦ N/A
Remarks
9. Discharge Compliance Records
~ Air ~ Readily available ~ Up to date ¦ N/A
~ Water (effluent) ~ Readily available ~ Up to date ¦ N/A
Remarks
10. Daily Access/Security Logs ~ Readily available ~ Up to date ¦ N/A
Remarks: No visitors other than for annual sampling, coordinated in advance with the property owner
(NEP).
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house ¦ Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
~ Other Woodard & Curran is under direct contract to NEP.
2. O&M Cost Records
~ Readily available ~ Up to date
~ Funding mechanism/agreement in place
Original O&M cost estimate ~ Breakdown attached
Approximately $10.000 per groundwater sampling event.
Total annual cost by year for review period if available - (Not available)
From
To
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: None noted.
Five-Year Review Inspection
Wells G&H Superfund Site
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V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable ~ N/A
A. Fencing
1. Fencing damaged ~ Location shown on site map ~ Gates secured ¦ N/A
Remarks Gated to prevent vehicle access to back of site, otherwise not a fenced site. Gates were open
for site inspection but are reportedly secured when no one present and access not needed to back of Site.
B. Other Access Restrictions
1. Signs and other security measures ~ Location shown on site map ~ N/A
Remarks: Gates are locked at night and on weekends when NEP workers are not present. No signs or
security systems are used. The trailer is locked.
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes ~ No ¦ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No ¦ N/A
Type of monitoring (e.g., self-reporting, drive by)
Frequency
Responsible party/agency
Contact
Name Title
Date
Phone no.
Reporting is up-to-date
~ Yes
~ No
¦ N/A
Reports are verified by the lead agency
~ Yes
~ No
¦ N/A
Specific requirements in deed or decision documents have been met
~ Yes
~ No
¦ N/A
Violations have been reported
~ Yes
~ No
¦ N/A
Other problems or suggestions: ~ Report attached
2. Adequacy ~ ICs are adequate ~ ICs are inadequate ¦ N/A
Remarks
D. General
1. Vandalism/trespassing ~ Location shown on site map ¦ No vandalism evident
Remarks
2. Land use changes on site ¦ N/A
Remarks
3. Land use changes off site ~ N/A
Remarks Increased density of development in the general area of Woburn.
VI. GENERAL SITE CONDITIONS
A. Roads ¦ Applicable ~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 4 of 60
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1.
Roads damaged ~ Location shown on site map ¦ Roads adequate ~ N/A
Remarks
B.
Other Site Conditions
Remarks: Monitoring wells were observed to have protective casings and were locked at the time of site
inspection.
VII. LANDFILL COVERS ~ Applicable ¦ N/A
A.
Landfill Surface ~ Applicable ~ N/A
1.
Settlement (Low spots) ~ Location shown on site map
Areal extent Depth
Remarks
~ Settlement not evident
2.
Cracks ~ Location shown on site map
Lengths Widths Depths
~ Cracking not evident
Remarks
3.
Erosion ~ Location shown on site map
Areal extent Depth
Remarks
~ Erosion not evident
4.
Holes ~ Location shown on site map
Areal extent Depth
Remarks
~ Holes not evident
5.
Vegetative Cover ~ Grass ~ Cover properly established ~ No signs of stress
~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks
6.
Alternative Cover (armored rock, concrete, etc.) ~ N/A
Remarks
7.
Bulges ~ Location shown on site map
Areal extent Height
Remarks
~ Bulges not evident
8.
Wet Areas/Water Damage ~ Wet areas/water damage not evident
~ Wet areas ~ Location shown on site map Areal extent
~ Ponding ~ Location shown on site map Areal extent
~ Seeps ~ Location shown on site map Areal extent
~ Soft subgrade ~ Location shown on site map Areal extent
Remarks
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Wells G&H Superfund Site
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9.
Slope Instability ~ Slides ~ Location shown on site map ~ No evidence of slope instability
Areal extent
Remarks
B.
Benches ~ Applicable ¦ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
1.
Flows Bypass Bench
Remarks
~ Location shown on site map ~ N/A or okay
2.
Bench Breached
Remarks
~ Location shown on site map ~ N/A or okay
3.
Bench Overtopped
Remarks
~ Location shown on site map ~ N/A or okay
C.
Letdown Channels ~ Applicable ¦ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement
Areal extent
~ Location shown on site map ~ No evidence of settlement
Depth
Remarks
2.
Material Degradation
Material type
~ Location shown on site map ~ No evidence of degradation
Areal extent
Remarks
3.
Erosion
Areal extent
~ Location shown on site map ~ No evidence of erosion
Depth
Remarks
4.
Undercutting
Areal extent
~ Location shown on site map ~ No evidence of undercutting
Depth
Remarks
5.
Obstructions Type
~ No obstructions
~ Location shown on site map Areal extent
Size
Remarks
6.
Excessive Vegetative Growth Type
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
~ Location shown on site map Areal extent
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Remarks
D.
Cover Penetrations ~ Applicable ¦ N/A
1.
Gas Vents ~ Active ~ Passive
~ Properly secured/locked ~ Functioning ~ Routinely sampled
~ Evidence of leakage at penetration ~ Needs Maintenance
~ N/A
Remarks
~ Good condition
2.
Gas Monitoring Probes
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
3.
Monitoring Wells (within surface area of landfill)
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
4.
Leachate Extraction Wells
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
5.
Settlement Monuments ~ Located
Remarks
~ Routinely surveyed
~ N/A
E. Gas Collection and Treatment ~ Applicable ¦ N/A
1.
Gas Treatment Facilities
~ Flaring ~ Thermal destruction
~ Good condition ~ Needs Maintenance
Remarks
~ Collection for reuse
2.
Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance
Remarks
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks
F.
Cover Drainage Layer ~ Applicable
¦ N/A
1.
Outlet Pipes Inspected ~ Functioning
Remarks
~ N/A
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Wells G&H Superfund Site
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2.
Outlet Rock Inspected
Remarks
~ Functioning
~ N/A
G.
Detention/Sedimentation Ponds ~ Applicable
¦ N/A
1.
Siltation Areal extent
Depth
~ N/A
~ Siltation not evident
Remarks
2.
Erosion Areal extent Depth
~ Erosion not evident
Remarks
3.
Outlet Works
Remarks
~ Functioning ~ N/A
4.
Dam
Remarks
~ Functioning ~ N/A
H. Retaining Walls
~ Applicable ¦ N/A
1.
Deformations
Horizontal displacement
~ Location shown on site map ~ Deformation not evident
Vertical displacement
Rotational displacement
Remarks
2.
Degradation
Remarks
~ Location shown on site map
~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
¦ N/A
1.
Siltation ~ Location shown on site map ~ Siltation not evident
Areal extent Depth
Remarks
2.
Vegetative Growth ~ Location shown on site map
~ Vegetation does not impede flow
Areal extent Type
~ N/A
Remarks
3.
Erosion
Areal extent
~ Location shown on site map
Depth
~ Erosion not evident
Remarks
4.
Discharge Structure
Remarks
~ Functioning ~ N/A
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VIII. VERTICAL BARRIER WALLS ~ Applicable ¦ N/A
1.
Settlement ~ Location shown on site map ~ Settlement not evident
Areal extent Depth
Remarks
2.
Performance Monitoring Tvpe of monitoring
~ Performance not monitored
Frequency ~ Evidence of breaching
Head differential
Remarks
IX.
GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable ¦ N/A
A.
Groundwater Extraction Wells, Pumps, and Pipelines ~ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing, and Electrical
~ Good condition ~ All required wells properly operating ~ Needs Maintenance ~ N/A
Remarks: SVE/AS system is mothballed.
2.
Extraction 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
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ¦ N/A
1.
Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks
C.
Treatment System ~ Applicable ¦ N/A
1.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
~ Air stripping ~ Carbon Adsorbers
Filters Bag
~ Additive (e.g., chelation agent, flocculent)
Five-Year Review Inspection
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Page 9 of 60
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~ Others
~ Good condition ~ Needs Maintenance
~ Sampling ports properly marked and functional
~ Sampling/maintenance log displayed and up to date
~ Equipment properly identified
~ Quantity of groundwater treated annually Totalizer readings
~ Quantity of surface water treated annually None
Remarks Groundwater logs and separate monthly sampling log.
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
4. Discharge Structure and Appurtenances
¦ N/A ~ Good condition ~ Needs Maintenance
Remarks
5. Treatment Building(s)
~ N/A ~ Good condition (esp. roof and doorways) ~ Needs repair
~ Chemicals and equipment properly stored
Remarks: Other than minor evidence of mice, the trailer for the mothballed SVE/AS system is in
reasonably good condition/serviceable.
6. Monitoring Wells (pump and treatment remedy)
¦ Properly secured/locked ¦Functioning ¦ Routinely sampled ¦ Good condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks: Some wells not visible due to snow cover/private property access issues. Observed
monitoring
Were locked at the time of inspection
D. Monitoring Data
Monitoring Data: M Is routinely submitted on time M Is of acceptable quality
Monitoring data suggests: For overburden and shallow bedrock, concentrations are declining and the plume
appears to be contained to the property. For deeper bedrock, limited data suggests concentrations in two
wells have decreased but have increased ant NEP A.
~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining
D. 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
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X. OTHER REMEDIES
If there are remedies applied at the site which are 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. None
XL 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 to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
The remedy for NEP included AS and SVE. which was intended to reduce concentrations in soil and
overburden groundwater to cleanup goals in the Record of Decision (ROD). The SVE/AS System was
effective in addressing Record of Decision (ROD) cleanup levels in unsaturated soils and significantly
reducing concentrations of trichloroethene (TCE) and tetrachloroethene (PCE) in groundwater. The
system has been shut-down since 2000. Overburden and shallow bedrock groundwater is presently
monitored every other year (biennially) and shows downward trends. During the most recent monitoring
event in 2017. two wells (one in overburden and one in shallow bedrock) had PCE concentrations
remaining above ROD cleanup levels and these concentrations were decreasing. In 2016. three deeper
bedrock wells were sampled. Concentrations in two of the wells were less than concentrations observed
in 1990 but remain above MCLs. In the remaining well, concentrations had increased above MCLs. On-
going analysis of deep bedrock groundwater quality by EPA suggests that groundwater extraction and
treatment of deeper bedrock groundwater mav be necessary to achieve cleanup levels specified bv the
ROD in deeper bedrock groundwater..
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 protectiveness of the remedy.
No O&M issues were identified as part of the site inspection that call into question the protectiveness of the
remedy implemented on behalf of NEP.
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, which suggest that the protectiveness of the remedy may be
compromised in the future.
None noted.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None based on the site inspection.
Five-Year Review Inspection
Wells G&H Superfund Site
Page 11 of 60
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Table 1 - Inspection Team Rooster
5-Year Inspection Team Members
Company
Jeffrey S. Hansen, PH
TRC
David M. Sullivan, LSP
TRC
Interviewed Staff
Company
Jeff Hamel, VP, LSP, LEP
Woodard & Curran
Page 12 of 60
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Five-Year Review Site Inspection Checklist
I. SITE INFORMATION
Site name: W. R. Grace
Date of inspection: February 18, 2019
Location and Region: WoburnUSEPA Region 1
EPA ID: Wells G&H MAD980732168
Agency, office, or company leading the five-year
review: TRC
Weather/temperature: Cold, cloudy
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
~ Access controls
~ Institutional controls
¦ Groundwater pump and treatment
~ Surface water collection and treatment
~ Other
Attachments: ¦ Inspection team roster attached see Table 1 ~ Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M site manager Clayton Smith Project Coordinator, de maximis. Inc.
Name Title
Interviewed ¦ at site ~ at office ~ by phone Phone no. (781) 929-8427
Problems, suggestions; ~ Report attached
2. O&M staff Van Sawyer Technical Services Manager. Groundwater & Environmental Services. Inc.
Name Title
Interviewed ¦ at site ~ at office ~ by phone Phone no. 978-392-0090
Problems, suggestions; ~ Report attached Typical difficulties associated with managing an aging system.
Team members on attached Table 1
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, etc.) Fill in all that apply.
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
4. Other interviews (optional) ~ Report attached.
~ Monitored natural attenuation
¦ Groundwater containment
~ Vertical barrier walls
Note: Meghan Proia is the O&M
Manager for this site for GES.
Not present for interview.
Clayton Smith coordinates on
behalf of W.R. Grace.
Page 13 of 60
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III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents
¦ O&M manual Dated 10/4/02 ¦ Readily available ¦ Up to date ~ N/A
¦ As-built drawings ¦ Readily available ¦ Up to date ~ N/A
¦ Maintenance logs ¦ Readily available ¦ Up to date ~ N/A
Remarks: As-built drawings for current system layout are kept on-site and posted on the wall.
Maintenance logs are kept in file cabinet in treatment plant and were current. Additional
details documented in onsite O&M journal.
2. Site-Specific Health and Safety Plan ¦ Readily available ¦ Up to date ~ N/A
¦ Contingency plan/emergency response plan ¦ Readily available ¦ Up to date ~ N/A
Remarks:
3. O&M and OSHA Training Records ~ Readily available ¦ Up to date ~ N/A
Remarks: Van Sawver (GES) keeps OSHA training certifications back at the GES office in
Westford. Massachusetts. None are maintained on-site.
4. Permits and Service Agreements
~ Air discharge permit None ~ Readily available ~ Up to date ~ N/A
~ Effluent discharge None ~ Readily available ~ Up to date ~ N/A
~ Waste disposal, POTW None ~ Readily available ~ Up to date ~ N/A
~ Other permits None ~ Readily available ~ Up to date ~ N/A
Remarks: Discharge to Snyder Creek is per agreement with the City of Woburn.
5. Gas Generation Records ~ Readily available ~ Up to date ¦ N/A
Remarks:
6. Settlement Monument Records ~ Readily available ~ Up to date ¦ N/A
Remarks:
7. Groundwater Monitoring Records ~ Readily available ¦ Up to date ~ N/A
Remarks: Maintained off-site at the office. There is regular annual reporting to EPA, most recently
for 2018.
8. Leachate Extraction Records ~ Readily available ~ Up to date ¦ N/A
Remarks:
Page 14 of 60
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9. Discharge Compliance Records
~ Air ~ Readily available ~ Up to date ¦ N/A
¦ Water (effluent) ~ Readily available ¦ Up to date ~ N/A
Remarks: Maintained off-site at the office. Submitted in Annual Reports, most recently for 2018
Tested monthly.
10. Daily Access/Security Logs ¦ Readily available ¦ Up to date ~ N/A
Remarks: Current access logs are on-site. The treatment building is also locked and equipped with a
security system.
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house ¦ Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
~ Other At the time of the Site visit. Grace contracted with GES for routine O&M.
2. O&M Cost Records
¦ Readily available In Annual Reports ~ Up to date
~ Funding mechanism/agreement in place
Original O&M cost estimate ~ Breakdown attached
About $160.000-$275.000 per year over the last 9 to 10 past 5 years.
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: Treatment system is steady-state. Recent additional costs are associated
with the 3 year extraction well shutdown program. Approximately 2 years ago, had to rebuild
compressor for pneumatic pump for recovery wells.
Page 15 of 60
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V. ACCESS AND INSTITUTIONAL CONTROLS ¦ Applicable ~ N/A
A. Fencing
1. Fencing damaged ~ Location shown on site map ¦ Gates secured ~ N/A
Remarks: Fence altered due to construction. No fencing present in back of property near Snyder Creek.
Some monitoring wells are outside of fenced property.
B. Other Access Restrictions
1. Signs and other security measures ~ Location shown on site map ~ N/A
Remarks: Treatment building and locked and alarmed.
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes ~ No ¦ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No ¦ N/A
Type of monitoring (e.g., self-reporting, drive by)
Frequency
Responsible party/agency
Contact
Name Title
Date
Phone no.
Reporting is up-to-date
~ Yes
~ No
¦ N/A
Reports are verified by the lead agency
~ Yes
~ No
¦ N/A
Specific requirements in deed or decision documents have been met
~ Yes
~ No
¦ N/A
Violations have been reported
~ Yes
~ No
¦ N/A
Other problems or suggestions: ~ Report attached
2. Adequacy ~ ICs are adequate* ~ ICs are inadequate ¦ N/A
Remarks:
D. General
1. Vandalism/trespassing ~ Location shown on site map ¦ No vandalism evident
Remarks: None
2. Land use changes on site ~ N/A
Remarks: Considerable land-use changes on the site property with a hotel and several restaurants
under construction (one restaurant is open for business presently). Vapor mitigation systems in place for
new buildings constructed as part of the development.
3. Land use changes off site ~ N/A
Remarks: Traffic alterations to Washington Street and increased density of commercial development in
nearby areas of Woburn.
VI. GENERAL SITE CONDITIONS
A. Roads ¦ Applicable ~ N/A
Page 16 of 60
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1.
Roads damaged ~ Location shown on site map ¦ Roads adequate ~ N/A
Remarks: Roadways, access corridors and narking areas are in various stages of completion associated
with site rc-development.
B.
Other Site Conditions
Remarks: Hotel grand opening in August. Other re-develooment items on individual timelines.
VII. LANDFILL COVERS ~ Applicable ¦ N/A
A.
Landfill Surface ~ Applicable ¦ N/A
1.
Settlement (Low spots) ~ Location shown on site map
Areal extent Depth
Remarks
~ Settlement not evident
2.
Cracks ~ Location shown on site map
Lengths Widths Depths
~ Cracking not evident
Remarks
3.
Erosion ~ Location shown on site map
Areal extent Depth
Remarks
~ Erosion not evident
4.
Holes ~ Location shown on site map
Areal extent Depth
Remarks
~ Holes not evident
5.
Vegetative Cover ~ Grass ~ Cover properly established ~ No signs of stress
~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks
6.
Alternative Cover (armored rock, concrete, etc.) ~ N/A
Remarks
7.
Bulges ~ Location shown on site map
Areal extent Height
Remarks
~ Bulges not evident
8.
Wet Areas/Water Damage ~ Wet areas/water damage not evident
~ Wet areas ~ Location shown on site map Areal extent
~ Ponding ~ Location shown on site map Areal extent
~ Seeps ~ Location shown on site map Areal extent
~ Soft subgrade ~ Location shown on site map Areal extent
Remarks
Page 17 of 60
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9.
Slope Instability ~ Slides ~ Location shown on site map ~ No evidence of slope instability
Areal extent
Remarks
B.
Benches ~ Applicable ¦ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
1.
Flows Bypass Bench ~ Location shown on site map ~ N/A or okay
Remarks:
2.
Bench Breached ~ Location shown on site map ~ N/A or okay
Remarks:
3.
Bench Overtopped ~ Location shown on site map ~ N/A or okay
Remarks:
C.
Letdown Channels ~ Applicable ¦ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement ~ Location shown on site map ~ No evidence of settlement
Areal extent Depth
Remarks:
2.
Material Degradation ~ Location shown on site map ~ No evidence of degradation
Material type Areal extent
Remarks:
3.
Erosion ~ Location shown on site map ~ No evidence of erosion
Areal extent Depth
Remarks:
4.
Undercutting ~ Location shown on site map ~ No evidence of undercutting
Areal extent Depth
Remarks:
5.
Obstructions Type ~ No obstructions
~ Location shown on site map Areal extent
Size
Remarks:
6.
Excessive Vegetative Growth Type
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
~ Location shown on site map Areal extent
Remarks:
Page 18 of 60
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D.
Cover Penetrations ~ Applicable ¦ N/A
1.
Gas Vents ~ Active ~ Passive
~ Properly secured/locked ~ Functioning ~ Routinely sampled
~ Evidence of leakage at penetration ~ Needs Maintenance
~ N/A
Remarks:
~ Good condition
2.
Gas Monitoring Probes
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
3.
Monitoring Wells (within surface area of landfill)
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
4.
Leachate Extraction Wells
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
5.
Settlement Monuments ~ Located
Remarks:
~ Routinely surveyed
~ N/A
E. Gas Collection and Treatment ~ Applicable ¦ N/A
1.
Gas Treatment Facilities
~ Flaring ~ Thermal destruction
~ Good condition ~ Needs Maintenance
Remarks:
~ Collection for reuse
2.
Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable
¦ N/A
1.
Outlet Pipes Inspected ~ Functioning
Remarks:
~ N/A
2.
Outlet Rock Inspected ~ Functioning
~ N/A
Page 19 of 60
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Remarks:
G.
Detention/Sedimentation Ponds ~ Applicable
¦ N/A
1.
Siltation Areal extent
Depth
~ N/A
~ Siltation not evident
Remarks:
2.
Erosion Areal extent Depth
~ Erosion not evident
Remarks:
3.
Outlet Works
Remarks:
~ Functioning ~ N/A
4.
Dam
Remarks:
~ Functioning ~ N/A
H. Retaining Walls
~ Applicable ¦ N/A
1.
Deformations
Horizontal displacement
~ Location shown on site map ~ Deformation not evident
Vertical displacement
Rotational displacement
Remarks:
2.
Degradation
Remarks:
~ Location shown on site map
~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
¦ N/A
1.
Siltation ~ Location shown on site map ~ Siltation not evident
Areal extent Depth
Remarks:
2.
Vegetative Growth ~ Location shown on site map
~ Vegetation does not impede flow
Areal extent Type
~ N/A
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map
Depth
~ Erosion not evident
Remarks:
4.
Discharge Structure
Remarks:
~ Functioning ~ N/A
VIII. VERTICAL BARRIER WALLS
~ Applicable ¦ N/A
1.
Settlement
~ Location shown on site map
~ Settlement not evident
Page 20 of 60
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Areal extent Depth
Remarks:
2.
Performance Monitoring Type of monitoring
~ Performance not monitored
Frequency ~ Evidence of breaching
Head differential
Remarks:
IX.
GROUNDWATER/SURFACE WATER REMEDIES ¦ Applicable ~ N/A
A.
Groundwater Extraction Wells, Pumps, and Pipelines ¦ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing, and Electrical
¦ Good condition ¦ All required wells properly operating ~ Needs Maintenance ~ N/A
Remarks: Wells are pneumatic, not electrical. Compressors are electrically powered.
2.
Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
¦ Good condition ~ Needs Maintenance
Remarks: Observed two of three active recovery wells (RW-17 and RW-20) - See photos
3.
Spare Parts and Equipment
¦ Readily available ¦ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks: Extra pumps are available on site.
_
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ¦ N/A
1.
Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks:
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
C.
Treatment System ¦ Applicable ~ N/A
1.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
~ Air stripping ¦ Carbon adsorbers
Filters Bag filter
~ Additive (e.g.. chelation agent, flocculenf) None
¦ Others Holding tank
¦ Good condition ~ Needs Maintenance
¦ Sampling ports properly marked and functional Yes
¦ Sampling/maintenance log displayed and up to date Log available
Page 21 of 60
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¦ Equipment properly identified.
¦ Ouantitv of groundwater treated annually Totalizer readings
~ Ouantitv of surface water treated annually None
Remarks: Groundwater loss and separate monthly samoline los.
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:
4.
Discharge Structure and Appurtenances
~ N/A ¦ Good condition ~ Needs Maintenance
Remarks Discharge is to wetland at edse of Snvder Creek above water surface (see ohoto)
5.
Treatment Building(s)
~ N/A ¦ Good condition (esp. roof and doorways) ~ Needs repair
~ Chemicals and equipment properly stored
Remarks: No chemicals stored on site.
6.
Monitoring Wells (pump and treatment remedy)
¦ Proocrlv secured/locked (see note) ¦ Functioning ~ Routinely sampled ~ Good condition
~ All required wells located ¦ Needs Maintenance ~ N/A
Remarks: Some wells under Washington Street need to be raised. Three on sidewalk have new road
boxes. Observed wells were locked/secure. Some wells were inaccessible due to snow cover and could
not be located or observed. A comprehensive inspection of monitorine wells should occur in SDrinu or
summer to assess if wells require repair. Some wells are boxed in base course and will need further
adiustment when final asphalt is laid out. Stick lid wells are in sood order.
D. Monitoring Data
Monitoring Data
¦ Is routinely submitted on time ¦ Is of acceptable quality
Monitoring data suggests:
¦ Groundwater plume is effectively contained ¦ Contaminant concentrations are declining (Overall
general, concentrations have declined. At some wells
where ROD cleanup goals are exceeded,
concentrations do not appear to be declining)
D.
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 are remedies applied at the site which are 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.
Vapor barrier/passive ventine installed for new buildines on site bv developers. All are passive svstems.
Installation based on discussions with EPA for orotectiveness of occupants.'
Page 22 of 60
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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 to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
The remedy is groundwater containment bv pump and treat to meet ROD cleanup levels for the shallow
aquifer with the UniFirst extraction well supplying deep aquifer containment (the systems are designed to work in
concert). Based on the site inspection and interview with Clayton Smith (de maximis). Van Sawyer (GES). and
Paul Bucens (Grace) the groundwater treatment system and extraction well pumps are operational. No
observations were made during the inspection that call into question the effectiveness or function of the remedy.
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 protectiveness of the remedy.
O&M staff visit the site on a regular schedule and perform monthly recovery well water levels to check
that thev are operating properly. Based on observations during the site inspection, there were no concerns that
call into question the protectiveness of the remedy. See also comments above in "A".
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 protectiveness of the remedy may be
compromised in the future.
No unexpected changes in cost or scope of O&M or frequent repairs were reported by Clayton Smith.or
Van Sawyer. However, both noted that it is an aging system and challenges inherent with maintaining
such systems.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Mr. Smith suggested further reducing the number of operating extraction wells and scaling back on
monitoring well network would be desired modifications.
Page 23 of 60
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Table 1. W. R. Grace Inspection Team Rooster
5-Year Inspection
Team Members
Company
Jeffrey S. Hansen, PH
TRC
David M. Sullivan, LSP
TRC
Interviewed PRP Staff
Clayton Smith
De maximis, Inc.
Van Sawyer
Groundwater & Environmental Services, Inc. (GES)
Paul Bucens
W.R. Grace
-------
Five-Year Review Site Inspection Checklist
I. SITE INFORMATION
Site name: Wildwood
Date of inspection: 02.18.2019
Location and Region: Woburn, MA (EPA Region 1)
EPA ID: MAD980732168
Agency, office, or company leading the five-year
review: TRC
Weather/temperature:
Light snow, cold
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: Soil vapor extraction (SVE) and air sparging (AS).
Attachments: ¦ Inspection team roster attached ~ Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M site manager Pete Cox Project Manager
Name Title
Interviewed ¦ at site ~ at office ~ by phone Phone No.: 978-764-4257
Problems, suggestions; ~ Report attached
2. O&M staff Eddie Zvearowski Plant Operator
Name Title
Interviewed Bat site ~ at office ~ by phone Phone No.: 781-935-5523 (site telephone)
Problems, suggestions; ~ Report attached: Managing an aging system. Parts difficult to come by - in some
instances, need to be fabricated.
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, etc.) Fill in all that apply. Not applicable.
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Five-Year Review Inspection
Wells G&H Superfund Site
Page 25 of 60
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4.
Other interviews (optional) ~ Report attached.
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
O&M Documents
¦ O&M manual Binder on site office shelf ¦Readily available ¦ Up to date ~ N/A
¦ As-built drawings ¦ Readily available ¦ Up to date ~ N/A
¦ Maintenance logs Bound log book ¦ Readily available ¦ Up to date ~ N/A
Remarks: Office is neat and well organized. As-Built drawings in office of treatment system building.
Site-Specific Health and Safety Plan
¦ Contingency plan/emergency response plan
Remarks HASP is from 2017.
l Readily available
l Readily available
l Up to date
l Up to date
~ N/A
~ N/A
O&M and OSHA Training Records ¦ Readily available
Remarks: Copies are kept in on-site file cabinet in the site office.
I Up to date ~ N/A
Permits and Service Agreements
~ Air discharge permit ~ Readily available
~ Effluent discharge ~ Readily available
~ Waste disposal, POTW ~ Readily available
~ Other permits ~ Readily available
Remarks: Suverfund requires only that the substantial requirements of permits are met - no permits
are formally issued.
~ Up to date
~ Up to date
~ Up to date
~ Up to date
N/A
N/A
N/A
N/A
Gas Generation Records
Remarks:
~ Readily available
~ Up to date
N/A
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
N/A
Groundwater Monitoring Records ¦ Readily available ¦ Up to date
Remarks: Maintained off-site but reported monthly, quarterly and annually to EPA.
~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 26 of 60
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8. Leachate Extraction Records ~ Readily available ~ Up to date ¦ N/A
Remarks
9. Discharge Compliance Records
¦ Air ¦ Readily available ¦ Up to date ~ N/A
¦ Water (effluent) ¦ Readily available ¦ Up to date ~ N/A
Remarks: Maintained off-site and information provided in quarterly and annual reports to
EPA.
10. Daily Access/Security Logs ¦ Readily available ¦ Up to date ~ N/A
Remarks: Sign in sheet is kept in silc office.
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house ¦ Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
~ Other
2. O&M Cost Records
¦ Readily available ~ Up to date
¦ Funding mechanism/agreement in place
Original O&M cost estimate: Approx. $270.000/vear ~ Breakdown attached
Provided in annual reports for Year 17 - May 2014 through April 2015 and Year 18 - May 2015 - May
2016. Not provided in annual reports covering 2017 and 2018.
Total annual cost by year for review period if available
From
To
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: Nothing beyond normal wear and tear. Air compressors are showing their
age, for example, and will need servicing or replacement in the near future.
Five-Year Review Inspection
Wells G&H Superfund Site
Page 27 of 60
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V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable ~ N/A
A. Fencing
1. Fencing damaged ~ Location shown on site map ¦ Gates secured ~ N/A
Remarks: Site is completely fenced except for the Abeijona River shoreline.
B. Other Access Restrictions
1. Signs and other security measures ~ Location shown on site map ~ N/A
Remarks: Signage on both sets of gates on entrance road from Salem Street. The treatment system
building is locked and equipped with a security and alarm system when O&M personnel are not on-site.
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes ~ No ¦ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No ¦ N/A
Type of monitoring (e.g., self-reporting, drive by)
Frequency
Responsible party/agency
Contact
Name Title
Date
Phone no.
Reporting is up-to-date
~ Yes
~ No
¦ N/A
Reports are verified by the lead agency
~ Yes
~ No
¦ N/A
Specific requirements in deed or decision documents have been met
~ Yes
~ No
¦ N/A
Violations have been reported
~ Yes
~ No
¦ N/A
Other problems or suggestions: ~ Report attached
2. Adequacy ~ ICs are adequate ~ ICs are inadequate ¦ N/A
Remarks:
D. General
1. Vandalism/trespassing ~ Location shown on site map ¦ No vandalism evident
Remarks: It's been over a decade since the site experienced vandalism.
2. Land use changes on site ¦ N/A
Remarks:
3. Land use changes off site ~ N/A
Remarks: Increased density of development in the local area.
VI. GENERAL SITE CONDITIONS
A. Roads ¦ Applicable ~ N/A
_l_ Roads damaged ~ Location shown on site map ¦ Roads adequate ~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 28 of 60
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Remarks Dirt road/gravel entrance and cross-site road.
B.
Other Site Conditions
Remarks: Snow covered site due to recent weather. Eddie, the site svstem operator, flagged all wells
used in regular sampling to facilitate locating snow covered wells.
VII. LANDFILL COVERS ~ Applicable
¦ N/A
A.
Landfill Surface ~ Applicable ¦ N/A
1.
Settlement (Low spots) ~ Location shown on site map
Areal extent Depth
Remarks:
~ Settlement not evident
2.
Cracks ~ Location shown on site map
Lengths Widths Depths
~ Cracking not evident
Remarks:
3.
Erosion ~ Location shown on site map
Areal extent Depth
Remarks:
~ Erosion not evident
4.
Holes ~ Location shown on site map
Areal extent Depth
Remarks:
~ Holes not evident
5.
Vegetative Cover ~ Grass ~ Cover properly established ~ No signs of stress
~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks:
6.
Alternative Cover (armored rock, concrete, etc.) ~ N/A
Remarks:
7.
Bulges ~ Location shown on site map
Areal extent Height
Remarks:
~ Bulges not evident
8.
Wet Areas/Water Damage ~ Wet areas/water damage not evident
~ Wet areas ~ Location shown on site map Areal extent
~ Ponding ~ Location shown on site map Areal extent
~ Seeps ~ Location shown on site map Areal extent
~ Soft subgrade ~ Location shown on site map Areal extent
Remarks:
9.
Slope Instability ~ Slides ~ Location shown on site map
Areal extent
~ No evidence of slope instability
Five-Year Review Inspection
Wells G&H Superfund Site
Page 29 of 60
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Remarks:
B.
Benches ~ Applicable ¦ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
1.
Flows Bypass Bench
Remarks:
~ Location shown on site map ~ N/A or okay
2.
Bench Breached
Remarks:
~ Location shown on site map ~ N/A or okay
3.
Bench Overtopped
Remarks:
~ Location shown on site map ~ N/A or okay
C.
Letdown Channels ~ Applicable ¦ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement
Areal extent
~ Location shown on site map ~ No evidence of settlement
Depth
Remarks:
2.
Material Degradation
Material type
~ Location shown on site map ~ No evidence of degradation
Areal extent
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map ~ No evidence of erosion
Depth
Remarks:
4.
Undercutting
Areal extent
~ Location shown on site map ~ No evidence of undercutting
Depth
Remarks:
5.
Obstructions Type
~ No obstructions
~ Location shown on site map Areal extent
Size
Remarks:
6.
Excessive Vegetative Growth Type
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
~ Location shown on site map Areal extent
Remarks:
Five-Year Review Inspection Page 30 of 60
Wells G&H Superfund Site
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D.
Cover Penetrations ~ Applicable ¦ N/A
1.
Gas Vents ~ Active ~ Passive
~ Properly secured/locked ~ Functioning ~ Routinely sampled
~ Evidence of leakage at penetration ~ Needs Maintenance
~ N/A
Remarks:
~ Good condition
2.
Gas Monitoring Probes
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
3.
Monitoring Wells (within surface area of landfill)
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
4.
Leachate Extraction Wells
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
5.
Settlement Monuments ~ Located
Remarks:
~ Routinely surveyed
~ N/A
E. Gas Collection and Treatment ~ Applicable ¦ N/A
1.
Gas Treatment Facilities
~ Flaring ~ Thermal destruction
~ Good condition ~ Needs Maintenance
Remarks:
~ Collection for reuse
2.
Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable
¦ N/A
1.
Outlet Pipes Inspected ~ Functioning
Remarks:
~ N/A
2.
Outlet Rock Inspected ~ Functioning
Remarks:
~ N/A
Five-Year Review Inspection Page 31 of 60
Wells G&H Superfund Site
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G.
Detention/Sedimentation Ponds ~ Applicable
¦ N/A
1.
Siltation Areal extent
Depth
~ N/A
~ Siltation not evident
Remarks:
2.
Erosion Areal extent Depth
~ Erosion not evident
Remarks:
3.
Outlet Works
Remarks:
~ Functioning ~ N/A
4.
Dam
Remarks:
~ Functioning ~ N/A
H. Retaining Walls
~ Applicable ¦ N/A
1.
Deformations
Horizontal displacement
~ Location shown on site map ~ Deformation not evident
Vertical displacement
Rotational displacement
Remarks:
2.
Degradation
Remarks:
~ Location shown on site map
~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
~ N/A
1.
Siltation ~ Location shown on site map ~ Siltation not evident
Areal extent Depth
Remarks:
2.
Vegetative Growth ~ Location shown on site map
~ Vegetation does not impede flow
Areal extent Type
~ N/A
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map
Depth
~ Erosion not evident
Remarks:
4.
Discharge Structure
Remarks :
~ Functioning ~ N/A
VIII. VERTICAL BARRIER WALLS
~ Applicable ¦ N/A
1.
Settlement
Areal extent
~ Location shown on site map
Depth
~ Settlement not evident
Five-Year Review Inspection Page 32 of 60
Wells G&H Superfund Site
-------
Remarks:
2.
Performance Monitoring Type of monitoring
~ Performance not monitored
Frequency ~ Evidence of breaching
Head differential
Remarks:
IX.
GROUNDWATER/SURFACE WATER REMEDIES ¦ Applicable ~ N/A
A.
Groundwater Extraction Wells, Pumps, and Pipelines ¦ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing, and Electrical
¦ Good condition ¦ All required wells properly operating ~ Needs Maintenance ~ N/A
Remarks: Most flow comes from BW-19R (approx. 24 gum). BW-18RD(LO)DR operated manually on
intermittent basis due to low yield (approx. 2000 gal per month). See photos of well heads.
2.
Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
¦ Good condition ~ Needs Maintenance
Remarks: Maintenance needs are up to date. No leaks observed.
3.
Spare Parts and Equipment
¦ Readily available ¦ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks: Stored inside the treatment building over the roof of the office.
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ¦ N/A
1.
Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks
C.
Treatment System ¦ Applicable ~ N/A
1.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
¦ Air stripping ¦ Carbon Adsorbers
Filters Bag and sand filter
~ Additive (e.e.. chelation agent, flocculent)
~ Others
¦ Good condition ~ Needs Maintenance
¦ Sampling ports properly marked and functional
¦ Sampling/maintenance log displayed and up to date - Kept in a bound log.
¦ Equipment properly identified
¦ Quantity of groundwater treated annually Totalizer readings (see Annual Reports for details).
Five-Year Review Inspection Page 33 of 60
Wells G&H Superfund Site
-------
~ Ouantitv of surface water treated annually None
Remarks: Groundwater loss and separate monthly sampling log.
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A ¦ Good condition ~ Needs Maintenance
Remarks: Ud to date and maintained and labeled.
3.
Tanks, Vaults, Storage Vessels
~ N/A ¦ Good condition ¦ Proper secondary containment ~ Needs Maintenance
Remarks: The treatment building serves as secondary containment. No evidence of leaks observed.
4.
Discharge Structure and Appurtenances
~ N/A ¦ Good condition ~ Needs Maintenance
Remarks: Discharge to storm sewer and then to the Aberiona River (manhole/catch basin in Salem
Street). In oast years, sometimes treated discharge water froze in catch basin. Has not occurred this year.
5.
Treatment Building(s)
~ N/A ¦ Good condition (esp. roof and doorways) ~ Needs repair
¦ Chemicals and equipment properly stored
Remarks: Cleaning compounds for system stored in "Flammables" cabinet in treatment building.
6.
Monitoring Wells (pump and treatment remedy)
~ Properly secured/locked ¦Functioning ¦ Routinely sampled ¦ Good condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks: Protective covers were not locked/secured on many of the wells rcDortcdlv because the site is
fenced and access is via a locked gate. BSW-14 did not have an expansion plug to prevent surface water
from entering the wells. Note not all wells could be located or observed because of snow cover or safety
concerns (e.g.. icy conditions on wooden boards to wells in Aberiona wetlands).
D. Monitoring Data
Monitoring Data
¦ Is routinely submitted on time ¦ Is of acceptable quality
Monitoring data suggests: Containment and effectiveness are part of a wider conversation with EPA.
~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining
D.
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 are remedies applied at the site which are 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.
Soil vapor extraction / air sparging (SVE/AS) is a maior part of the Wildwood remedy. No monitoring
issues have been noted. Optimization of the SVE/AS portion of the approved remedy is part of an ongoing
conversation with EPA. Off-gas treatment has been disconnected temporarily with EPA approval. Off-gas
treatment will resume if warranted pending installation of additional recovery wells and/or air sparge wills
Five-Year Review Inspection
Wells G&H Superfund Site
Page 34 of 60
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that increase VOC concentrations in influent.
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 to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
There are ongoing discussions with EPA regarding remedy optimization alternatives. Implementation of
proposed alternatives is pending agreement with EPA as to next steps forward.
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 protectiveness of the remedy.
No issues were identified to suggest a lack of protectiveness. It is an aging system that has O&M challenges that
are not atypical of other aging systems. Attentive O&M personnel continue to maintain the system's
functionality.
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, which suggest that the protectiveness of the remedy may be
compromised in the future.
As noted above, it is an aging system. Problematic elements lately include the compressors which will require
servicing or replacement to maintain their functionality/performance. However. O&M staff are aware of and are
monitoring this issue to assure continued operation of the treatment system.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
There has been dialog with EPA on optimization of the remedy operation, including the need for additional air
sparging and recovery wells as well as pilot testing of in-situ chemical oxidation as an enhancement to the pump
and treat remedy. EPA anticipates that implementation and further assessment of these optimizations will occur
over the next five years.
Five-Year Review Inspection
Wells G&H Superfund Site
Page 35 of 60
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Table 1 - Inspection Team Rooster
5-Year Inspection Team Members
Company
Jeffrey S. Hansen, PH
TRC
David M. Sullivan, LSP
TRC
Interviewed Staff
Company
Pete Cox
AECOM
Eddie Zygorowski
AECOM
Page 36 of 60
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Five-Year Review Site Inspection Checklist
I. SITE INFORMATION
Site name: UniFirst
Date of inspection: 02.19.2019
Location and Region: WoburnUSEPA Region 1
EPA ID: Wells G&H MAD980732168
Agency, office, or company leading the five-year
review: TRC
Weather/temperature: Cold, bright, and sunny.
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: Supplemented with soil vapor extraction (SVE)
Attachments: ¦ Inspection team roster attached Table 1 ~ Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M Site Manager Timothy M. Cosgrave O&M Manager. UniFirst
Name Title
Interviewed ¦ at site ~ at office ~ by phone Phone no.: 978-658-8888 x4332
Problems, suggestions; ~ Report attached
2. O&M staff: See above (some O&M, primarily SVE System, subcontracted to the Johnson Company, as well)
Name Title Date
Interviewed ~ at site ~ at office ~ by phone Phone no.
Problems, suggestions; ~ Report attached
Team members: on attached Table 1 (Johnson Company not in attendance at time of site visit).
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, etc.) Fill in all that apply. Not applicable.
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Page 37 of 60
-------
4.
Other interviews (optional) ~ Report attached.
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1.
O&M Documents
¦ O&M manual* HPS, December 2008 ¦ Readily available ¦ Up to date ~ N/A
¦ As-built drawings ** ¦ Readily available ~ Up to date ~ N/A
¦ Maintenance logs ~ Readily available ¦ Up to date ~ N/A
Remarks Maintenance record hardcopy keot off-site in the UniFirst office in Wilmington (recent files
were provided at the site for the inspection). O&M manual was on-site (December 2008 pump
and treat/Mav 2015 SVE). Electronic versions of documents are accessible from onsite via
internet.
* SVE O&M Manual May 2015
** Also kept electronically on computer.
2.
Site-Specific Health and Safety Plan ~ Readily available ~ Up to date ~ N/A
~ Contingency plan/emergency response plan ~ Readily available ~ Up to date ~ N/A
Remarks Health and Safety Plan and Contingency Plan being revised.
3.
O&M and OSHA Training Records ¦ Readily available ¦ Up to date ~ N/A
Remarks: Kent at UniFirst office in Wilmineton. MA
4.
Permits and Service Agreements
~ Air discharge permit None ~ Readilv available ~ Ud to date ¦ N/A
~ Effluent discharge None ~ Readilv available ~ Up to date ¦ N/A
~ Waste disposal. POTW None ~ Readilv available ~ Up to date ¦ N/A
~ Other permits None ~ Readilv available ~ Up to date ¦ N/A
Remarks: Superfund reauired that substantial reauirements that would reauire a permit are met:
however, no formal permits are issued.
5.
Gas Generation Records ¦ Readily available ¦ Up to date ~ N/A
Remarks: SVE flow rates are kept off-site and reported to EPA annuallv.
6.
Settlement Monument Records ~ Readily available ~ Up to date ¦ N/A
Remarks:
7.
Groundwater Monitoring Records ¦ Readily available ¦ Up to date ~ N/A
Remarks: Groundwater monitoring records are kept off-site and reported to EPA annuallv.
8. Leachate Extraction Records ~ Readily available ~ Up to date ¦ N/A
Remarks:
9.
Discharge Compliance Records
¦ Air ¦ Readily available ¦ Up to date ~ N/A
¦ Water (effluent) ¦ Readily available ¦ Up to date ~ N/A
Remarks: Discharge compliance records are kept off-site. Volatile organic compounds (VOCs) in
Page 38 of 60
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treated effluent and discharge volume reported in annual reports to EPA. VOCs in SVE influent, flow
rate, and mass removal by treatment reported monthly and annually to EPA.
10. Daily Access/Security Logs ¦ Readily available ¦ Up to date ~ N/A
Remarks: A site visitor log is maintained on-site. Older copies stored offsite.
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
¦ PRP in-house ¦ Contractor for PRP (Johnson Company also assists PRP w/O&M)
~ Federal Facility in-house ~ Contractor for Federal Facility
~ Other
2. O&M Cost Records
~ Readily available ¦ Up to date
~ Funding mechanism/agreement in place
Original O&M cost estimate: not sure ~ Breakdown attached
Total annual cost by year for review period if available
Costs provide via email subsequent to site visit. The cost data below are compiled during UniFirst's fiscal year,
which starts in late August (e.g., FY18 represents roughly September 2017 through August 2018).
FY2018 = $106,223
FY2017 = $156,024
FY2016 = $200,420
These numbers include all costs of contractors, laboratories, equipment repair and replacement, but does not
account for in-house Unifirst labor. As the SVE system has settled in, the costs of operation have been going
down.
From
To
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons None.
SVE supplemental treatment increased O&M costs, but this cost increase was not unanticipated.
V. ACCESS AND INSTITUTIONAL CONTROLS ¦ Applicable ~ N/A
A. Fencing
1. Fencing damaged ~ Location shown on site map ¦ Gates secured ~ N/A
Remarks Fencing OK: chain link
B. Other Access Restrictions
Page 39 of 60
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1. Signs and other security measures ~ Location shown on site map ~ N/A
Remarks: Authorized access sign on interior door to treatment facility.
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes ~ No ¦ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No ¦ N/A
Type of monitoring (e.g., self-reporting, drive by)
Frequency
Responsible party/agency
Contact
Name Title
Date
Phone no.
Reporting is up-to-date
~ Yes
~ No
¦ N/A
Reports are verified by the lead agency
~ Yes
~ No
¦ N/A
Specific requirements in deed or decision documents have been met
~ Yes
~ No
¦ N/A
Violations have been reported
~ Yes
~ No
¦ N/A
Other problems or suggestions ~ Report attached
2. Adequacy ~ ICs are adequate* ~ ICs are inadequate ¦ N/A
Remarks:
D. General
1. Vandalism/trespassing ~ Location shown on site map ¦ No vandalism evident
Remarks: None
2. Land use changes on site ~ N/A
Remarks: None
3. Land use changes off site ~ N/A
Remarks: Nearby Grace Property undergoing redevelopment. Incremental increases in development
density in the general area.
VI. GENERAL SITE CONDITIONS
A. Roads ¦ Applicable ~ N/A
1. Roads damaged ~ Location shown on site map ¦ Roads adequate ~ N/A
Remarks: Site area surrounding building is paved. South side of building is parking area. Paved access
along north, east, and west sides of building. Parking lot condition OK.
B. Other Site Conditions
Remarks: Snow cover due to recent weather. Some wells could not be located or observed due to snow
ewer
VII. LANDFILL COVERS ~ Applicable "N/A
A. Landfill Surface
Page 40 of 60
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1.
Settlement (Low spots)
~ Location shown on site map ~ Settlement not evident
Areal extent
Depth
Remarks:
2.
Cracks
~ Location shown on site map ~ Cracking not evident
Lengths Widths
Depths
Remarks:
3.
Erosion
~ Location shown on site map ~ Erosion not evident
Areal extent
Depth
Remarks:
4.
Holes
~ Location shown on site map ~ Holes not evident
Areal extent
Depth
Remarks
5.
Vegetative Cover ~ Grass
~ Cover properly established ~ No signs of stress
~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks:
6.
Alternative Cover (armored rock, concrete, etc.) ~ N/A
Remarks:
7.
Bulges
~ Location shown on site map ~ Bulges not evident
Areal extent
Height
Remarks:
8.
Wet Areas/Water Damage
~ Wet areas/water damage not evident
~ Wet areas
~ Location shown on site map Areal extent
~ Ponding
~ Location shown on site map Areal extent
~ Seeps
~ Location shown on site map Areal extent
~ Soft subgrade
~ Location shown on site map Areal extent
Remarks:
9.
Slope Instability ~ Slides
~ Location shown on site map ~ No evidence of slope instability
Areal extent
Remarks:
B.
Benches ~ Applicable
~ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
Remarks:
1.
Flows Bypass Bench
~ Location shown on site map ~ N/A or okay
Remarks:
Page 41 of 60
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2.
Bench Breached ~ Location shown on site map ~ N/A or okay
Remarks:
3.
Bench Overtopped ~ Location shown on site map ~ N/A or okay
Remarks:
C.
Letdown Channels ~ Applicable ¦ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
Remarks:
1.
Settlement ~ Location shown on site map ~ No evidence of settlement
Areal extent Depth
Remarks:
2.
Material Degradation ~ Location shown on site map ~ No evidence of degradation
Material type Areal extent
Remarks:
3.
Erosion ~ Location shown on site map ~ No evidence of erosion
Areal extent Depth
Remarks:
4.
Undercutting ~ Location shown on site map ~ No evidence of undercutting
Areal extent Depth
Remarks:
5.
Obstructions Type ~ No obstructions
~ Location shown on site map Areal extent
Size
Remarks:
6.
Excessive Vegetative Growth Type
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
~ Location shown on site map Areal extent
Remarks:
D.
Cover Penetrations ~ Applicable ¦ N/A
1.
Gas Vents ~ Active ~ Passive
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
~ Evidence of leakage at penetration ~ Needs Maintenance
~ N/A
Remarks:
Page 42 of 60
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2. Gas Monitoring Probes
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
3. Monitoring Wells (within surface area of landfill)
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
4. Leachate Extraction Wells
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
5. Settlement Monuments ~ Located
Remarks:
~ Routinely surveyed
~ N/A
E. Gas Collection and Treatment ~ Applicable ¦ N/A
1. Gas Treatment Facilities
~ Flaring ~ Thermal destruction
~ Good condition ~ Needs Maintenance
Remarks:
~ Collection for reuse
2. Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance
Remarks:
3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks:
F. Cover Drainage Layer ~ Applicable
¦ N/A
1. Outlet Pipes Inspected ~ Functioning
Remarks:
~ N/A
2. Outlet Rock Inspected ~ Functioning
Remarks:
~ N/A
G. Detention/Sedimentation Ponds ~ Applicable
¦ N/A
1. Siltation Areal extent Depth
~ N/A
~ Siltation not evident
Remarks:
2. Erosion Areal extent Depth
Page 43 of 60
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~ Erosion not evident
Remarks:
3.
Outlet Works
Remarks:
~ Functioning ~ N/A
4.
Dam
Remarks:
~ Functioning ~ N/A
H. Retaining Walls
~ Applicable ¦ N/A
1.
Deformations
Horizontal displacement
~ Location shown on site map ~ Deformation not evident
Vertical displacement
Rotational displacement
Remarks:
2.
Degradation
Remarks:
~ Location shown on site map ~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable ¦ N/A
1.
Siltation ~ Location shown on site map ~ Siltation not evident
Areal extent Depth
Remarks:
2.
Vegetative Growth ~ Location shown on site map ~ N/A
~ Vegetation does not impede flow
Areal extent Type
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map ~ Erosion not evident
Depth
Remarks:
4.
Discharge Structure
Remarks:
~ Functioning ~ N/A
VIII. VERTICAL BARRIER WALLS ~ Applicable "N/A
1.
Settlement
Areal extent
~ Location shown on site map ~ Settlement not evident
Depth
Remarks:
2.
Performance Monitoring Type of monitoring
~ Performance not monitored
Frequency ~ Evidence of breaching
Page 44 of 60
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Head differential
Remarks:
IX. GROUNDWATER/SURFACE WATER REMEDIES "Applicable ~ N/A
A.
Groundwater Extraction Wells, Pumps, and Pipelines ¦ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing, and Electrical
~ Good condition ~ All required wells properly operating ¦ Needs Maintenance ~ N/A
Remarks: Extraction well UC-22 working fine. Supplemental extraction well EX-1 not pumping at
desired rate on the day of the site visit. Trouble-shooting on-going.
2.
Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
¦ Good condition ~ Needs Maintenance
Remarks: Maintained and replaced as needed.
3.
Spare Parts and Equipment
¦ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks: Snare well duihd for UC-22 maintained on site. The duihd in EX-1 is easv to d roc lire if
needed (i.e.. Grundfos brand).
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ¦ N/A
1.
Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks:
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
C.
Treatment System ¦ Applicable ~ N/A
1.
Treatment Train (Check components that apply)
~ Metals removal None ~ Oil/water separation None ~ Bioremediation None
~ Air striDDina ¦ Carbon adsorbers (Both Groundwater and soil vaoor systems).
Filters Multimedia (sand and bae filter)
~ Additive (e.s.. chelation asent. flocculent) None
~ Others
¦ Good condition ~ Needs Maintenance
¦ Sampling ports properly marked and functional Yes
~ Saind 1 ina/inaintenanee los displayed and lid to date On coniDiitcr
¦ Equipment properly identified Yes
~ Ouantitv of groundwater treated annuallv Varies - orovided in annual O&M/Annual Rcoorts to
EPA.
~ Quantity of surface water treated annually N/A
Remarks:
Page 45 of 60
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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:
4.
Discharge Structure and Appurtenances
~ N/A ~ Good condition ~ Needs Maintenance
Remarks: Actual tie-in to storm sewer was not been observed. Effluent piping runs underground
beneath Olvmpia Ave.
5.
Treatment Building(s)
~ N/A ¦ Good condition (esp. roof and doorways) ~ Needs repair
~ Chemicals and cauiDinent properly stored
Remarks: Building was neat, sample ports and controls were easily accessible.
6.
Monitoring Wells/Points (pump and treatment and SVE remedy)
¦ Properly secured/locked ~ Functioning ¦ Routinely sampled (annually) ~ Good condition
~ All required wells located ¦ Needs Maintenance ~ N/A
Remarks: Due to snow cover, not all of the flush mounted wells could be located or observed. However,
observed wells and monitoring probes located inside the Building were found to be properly secured.
Covers for some of the observed flush-mounted wells were missing bolts and at least one well with a
stick up did not have a lock. Wells were not opened during inspection (e.g., covers for flush-mounted
wells were frozen in place). In the 25 year Annual Report, DP37D, UC31M and UC3 ID were found to
be sand locked. According to Tim Cosgrave, the Johnson Company is currently working on a plan to
restore these wells. Although wells outside the building are within a fenced area, the site is accessible to
the public during operating hours and some wells are located outside the fence. Therefore, all wells
monitored for water levels/water quality for the UniFirst Remedy should be inspected after snow cover
has melted to identify wells that need to be secured and/or require maintenance.
D. Monitoring Data
Monitoring Data
¦ Is routinely submitted on time ¦ Is of acceptable quality
Monitoring data suggests: *According to T. Cosgrave (UniFirst)
¦ Groundwater plume is effectively contained * ~ Contaminant concentrations are declining
D.
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 are remedies applied at the site which are 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 has been added during this five-vear review period as an additional treatment. The
SVE svstem appears to be in sood condition and operating as designed. SVE performance is reported
monthly and annually to EPA. The inspection revealed no issues with the SVE system.
Page 46 of 60
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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 to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
An objective of the groundwater treatment system is prevent off-property migration of contaminated
groundwater from the UniFirst Property. In 2015. a supplemental extraction well (EX-1) was installed in
overburden capture impacted groundwater at the southwest corner of on the UniFirst Property. EX-1 in
combination with UC-22 achieves this objective. A second objective of the treatment system is to reduce the
concentrations of VOCs in groundwater to cleanup levels identified in the Record of Decision. The treatment
system continues to extract contaminated groundwater and over time, should reduce concentrations of VOCs to
cleanup levels. However, elevated VOC mass in the form of residual dense non-aaueous phase liquid (DNAPL)
is present beneath the eastern portion of the building. Aggressive remedial enhancements to the existing pump
and treat system could reduce the timeframe to achieve cleanup goals.
EPA's primary objectives for the SVE system is to reduce VOC mass and concentrations of VOCs in soil to soil
cleanup levels presented in the ROD and reduce the potential for vapor intrusion into the building. The S VE
system 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. Soil
data has not been collected in the past five years to assess current concentrations in soil.
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 protectiveness of the remedy.
O&M staff visit the site on a weekly basis. There were no concerns identified that call into question
the protectiveness of the remedy.
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 protectiveness of the remedy may be
compromised in the future.
No unexpected changes in cost or scope of O&M were reported by Tim Cosgrave. Tim also indicated
that the system has had minimal downtime over the past 5 years.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None based on site inspection alone. The addition of extraction well EX-1 has optimized capture, and
the SVE system has resulted in the capture of VOCs to mitigate vapor intrusion into the building with collateral
removal of VOCs from soil. In-situ DNAPL treatment, when path forward on this aspect is agreed to with EPA,
will help reduce overall timeframe of the cleanup.
Page 47 of 60
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Table 1. UniFirst Inspection Team Rooster
5-Year Inspection Team Members
Company
Jeffrey S. Hansen, PH
TRC
David M. Sullivan, LSP
TRC
Interviewed PRP Staff
Timothy M. Cosgrave
UniFirst
-------
Five-Year Review Site Inspection Checklist
I. SITE INFORMATION
Site name: Olympia
Date of inspection: 02.19.2019
Location and Region: Woburn, MA (EPA Region 1)
EPA ID: MAD980732168
Agency, office, or company leading the five-year
review: TRC
Weather/temperature:
Cold, sunny, bright
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 - In Situ Chemical Oxidation (ISCQ). Last targeted amendment injections took place in
November 2018 at southeast corner near MW-217 monitoring well cluster according to Christene Binger
oF Geolnsight.
Attachments: ¦ Inspection team roster attached ~ Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M site manager Christene Binger
Name Title
Interviewed ¦ at site ~ at office ~ by phone Phone No. 978-679-1600 (office)
Problems, suggestions; ~ Report attached Status quo routine (inject, check, inject)
2. O&M staff Cam Simmons (not in attendance) Project Scientist
Name Title
Interviewed ~ at site ~ at office ~ by phone Phone No. 978-679-1600
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, etc.) Fill in all that apply. Not applicable.
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ~ Report attached
Five-Year Review Inspection
Wells G&H Superfund Site
Page 49 of 60
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4.
Other interviews (optional) ~ Report attached.
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
O&M Documents (There is no site building for this source area. Records kept at Littleton, MA office).
~ O&M manual ~ Readily available ~ Up to date ¦ N/A
¦ As-built drawings ~ Readily available ¦ Up to date ~ N/A
~ Maintenance logs ~ Readily available ~ Up to date ¦ N/A
Remarks: As-built diagram for wells/trenches and injection information provided in reports submitted
to EPA.
Site-Specific Health and Safety Plan ~ Readily available ¦ Up to date ~ N/A
~ Contingency plan/emergency response plan ~ Readily available ~ Up to date ~ N/A
Remarks: Available at Geolnsight Office in Littleton. MA
O&M and OSHA Training Records ~ Readily available
Remarks: Available at Geolnsight Office in Littleton. MA
~ Up to date ~ N/A
Permits and Service Agreements
~ Air discharge permit
~ Effluent discharge
~ Waste disposal, POTW
~ Other permits
Remarks: None
~ Readily available
~ Readily available
~ Readily available
~ Readily available
~ Up to date
~ Up to date
~ Up to date
~ Up to date
N/A
N/A
N/A
N/A
Gas Generation Records
Remarks:
~ Readily available
~ Up to date
N/A
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 50 of 60
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7. Groundwater Monitoring Records ~ Readily available ~ Up to date ~ N/A
Remarks: Available at Geolnsight Office In Littleton. MA. Periodic reporting to EPA.
Leachate Extraction Records ~ Readily available ~ Up to date ~ N/A
Remarks:
9. Discharge Compliance Records
~ Air ~ Readily available ~ Up to date ~ N/A
~ Water (effluent) ~ Readily available ~ Up to date ~ N/A
Remarks:
10. Daily Access/Security Logs ~ Readily available ~ Up to date ~ N/A
Remarks: Site access through Wildwood Site. Gates locked when site personnel not present. Olvmpia
site is fully fenced with a locked gate at this time.
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house ¦ Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
~ Other
2. O&M Cost Records
~ Readily available ~ Up to date
~ Funding mechanism/agreement in place
Original O&M cost estimate ~ Breakdown attached
No O &M. Periodic injections only with monitoring. No instrumentation, power, pumps, etc.
Total annual cost by year for review period if available
From
To
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
From
Date
To
Date
Total cost
~ Breakdown attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: None
Five-Year Review Inspection
Wells G&H Superfund Site
Page 51 of 60
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V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable ~ N/A
A. Fencing
1. Fencing damaged ~ Location shown on site map ¦ Gates secured ~ N/A
Remarks: Site is fully fenced and gates are secured/locked.
B. Other Access Restrictions
1. Signs and other security measures ~ Location shown on site map ~ N/A
Remarks: Sign on gate at beginning of road leading to the site through Wildwood Property.
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes ~ No ¦ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No ¦ N/A
Type of monitoring (e.g., self-reporting, drive by)
Frequency
Responsible party/agency
Contact
Name Title
Date
Phone no.
Reporting is up-to-date
~ Yes
~ No
¦ N/A
Reports are verified by the lead agency
~ Yes
~ No
¦ N/A
Specific requirements in deed or decision documents have been met
~ Yes
~ No
¦ N/A
Violations have been reported
~ Yes
~ No
¦ N/A
Other problems or suggestions: ~ Report attached
2. Adequacy ~ ICs are adequate ~ ICs are inadequate ¦ N/A
Remarks:
D. General
1. Vandalism/trespassing ~ Location shown on site map ¦ No vandalism evident
Remarks:
2. Land use changes on site ~ N/A
Remarks: Recent vegetation clearing along railroad by Keolis.
3. Land use changes off site ~ N/A
Remarks: Generally increased development in local area.
VI. GENERAL SITE CONDITIONS
A. Roads ¦ Applicable ~ N/A
_l_ Roads damaged ~ Location shown on site map ¦ Roads adequate ~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 52 of 60
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Remarks Gravel/dirt road, wooden bridge.
B.
Other Site Conditions
Remarks: Snow form recent weather. First sate into Olvmpia site frozen to the ground.
VII. LANDFILL COVERS ~ Applicable
¦ N/A
A.
Landfill Surface ~ Applicable ¦ N/A
1.
Settlement (Low spots) ~ Location shown on site map
Areal extent Depth
Remarks:
~ Settlement not evident
2.
Cracks ~ Location shown on site map
Lengths Widths Depths
~ Cracking not evident
Remarks:
3.
Erosion ~ Location shown on site map
Areal extent Depth
Remarks:
~ Erosion not evident
4.
Holes ~ Location shown on site map
Areal extent Depth
Remarks:
~ Holes not evident
5.
Vegetative Cover ~ Grass ~ Cover properly established ~ No signs of stress
~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks:
6.
Alternative Cover (armored rock, concrete, etc.) ~ N/A
Remarks:
7.
Bulges ~ Location shown on site map
Areal extent Height
Remarks:
~ Bulges not evident
8.
Wet Areas/Water Damage ~ Wet areas/water damage not evident
~ Wet areas ~ Location shown on site map Areal extent
~ Ponding ~ Location shown on site map Areal extent
~ Seeps ~ Location shown on site map Areal extent
~ Soft subgrade ~ Location shown on site map Areal extent
Remarks:
9.
Slope Instability ~ Slides ~ Location shown on site map
~ No evidence of slope instability
Five-Year Review Inspection Page 53 of 60
Wells G&H Superfund Site
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Areal extent:
Remarks
B.
Benches ~ Applicable ¦ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
1.
Flows Bypass Bench
Remarks:
~ Location shown on site map ~ N/A or okay
2.
Bench Breached
Remarks:
~ Location shown on site map ~ N/A or okay
3.
Bench Overtopped
Remarks:
~ Location shown on site map ~ N/A or okay
C.
Letdown Channels ~ Applicable ¦ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement
Areal extent
~ Location shown on site map ~ No evidence of settlement
Depth
Remarks:
2.
Material Degradation
Material type
~ Location shown on site map ~ No evidence of degradation
Areal extent
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map ~ No evidence of erosion
Depth
Remarks:
4.
Undercutting
Areal extent
~ Location shown on site map ~ No evidence of undercutting
Depth
Remarks:
5.
Obstructions Type
~ No obstructions
~ Location shown on site map Areal extent
Size
Remarks:
6.
Excessive Vegetative Growth Type
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
~ Location shown on site map Areal extent
Remarks:
Five-Year Review Inspection
Wells G&H Superfund Site
Page 54 of 60
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D.
Cover Penetrations ~ Applicable ¦ N/A
1.
Gas Vents ~ Active ~ Passive
~ Properly secured/locked ~ Functioning ~ Routinely sampled
~ Evidence of leakage at penetration ~ Needs Maintenance
~ N/A
Remarks:
~ Good condition
2.
Gas Monitoring Probes
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
3.
Monitoring Wells (within surface area of landfill)
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
4.
Leachate Extraction Wells
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
5.
Settlement Monuments ~ Located
Remarks:
~ Routinely surveyed
~ N/A
E. Gas Collection and Treatment ~ Applicable ¦ N/A
1.
Gas Treatment Facilities
~ Flaring ~ Thermal destruction
~ Good condition ~ Needs Maintenance
Remarks:
~ Collection for reuse
2.
Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable
¦ N/A
1.
Outlet Pipes Inspected ~ Functioning
Remarks:
~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 55 of 60
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2.
Outlet Rock Inspected
Remarks:
~ Functioning
~ N/A
G.
Detention/Sedimentation Ponds ~ Applicable
¦ N/A
1.
Siltation Areal extent
Depth
~ N/A
~ Siltation not evident
Remarks:
2.
Erosion Areal extent Depth
~ Erosion not evident
Remarks:
3.
Outlet Works
Remarks:
~ Functioning ~ N/A
4.
Dam
Remarks:
~ Functioning ~ N/A
H. Retaining Walls
~ Applicable ¦ N/A
1.
Deformations
Horizontal displacement
~ Location shown on site map ~ Deformation not evident
Vertical displacement
Rotational displacement
Remarks:
2.
Degradation
Remarks:
~ Location shown on site map
~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
¦ N/A
1.
Siltation ~ Location shown on site map ~ Siltation not evident
Areal extent Depth
Remarks:
2.
Vegetative Growth ~ Location shown on site map
~ Vegetation does not impede flow
Areal extent Type
~ N/A
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map
Depth
~ Erosion not evident
Remarks:
4.
Discharge Structure
Remarks:
~ Functioning ~ N/A
Five-Year Review Inspection
Wells G&H Superfund Site
Page 56 of 60
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VIII. VERTICAL BARRIER WALLS "Applicable ~ N/A
1.
Settlement ~ Location shown on site map ~ Settlement not evident
Areal extent Depth
Remarks:_Treatment cell surrounded by sheet pile wall.
2.
Performance Monitoring Type of monitoring
~ Performance not monitored
Frequency ~ Evidence of breaching
Head differential
Remarks:
IX.
GROUNDWATER/SURFACE WATER REMEDIES ¦ Applicable ~ N/A
A.
Groundwater Extraction Wells, Pumps, and Pipelines ~ Applicable ¦ N/A
1.
Pumps, Wellhead Plumbing, and Electrical
~ Good condition ~ All required wells properly operating ~ Needs Maintenance ¦ 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 ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ¦ N/A
1.
Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks:
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
C.
Treatment System ~ Applicable ¦ N/A
1.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
~ Air stripping ~ Carbon Adsorbers
Filters
~ Additive (e.e.. chelation agent, flocculenf)
~ Others
Five-Year Review Inspection
Wells G&H Superfund Site
Page 57 of 60
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~ Good condition ~ Needs Maintenance
~ Sampling ports properly marked and functional
~ Sampling/maintenance log displayed and up to date
~ Equipment properly identified
~ Quantity of groundwater treated annually
~ Quantity of surface water treated annually
Remarks: Contaminated groundwater and soil treated through periodic injection of in-situ chemical
oxidant (sodium permanganate*) through wells, direct push points and trenches.
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:
4. Discharge Structure and Appurtenances
¦ N/A ~ Good condition ~ Needs Maintenance
Remarks:
5. Treatment Building(s)
¦ N/A ~ Good condition (esp. roof and doorways) ~ Needs repair
~ Chemicals and equipment properly stored
Remarks:
6. Monitoring Wells (pump and treatment remedy)
~ Properly secured/locked ¦Functioning ~ Routinely sampled ~ Good condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks: The vast majority of monitoring wells and the treatment cell is inside a chain link fence:
however: the fence could be crossed with minimal difficulty. Wells inside the fenced area were not locked:
numerous wells had no covers or plugs and several wells had sample tubing protruding from the wells. Some
wells were bent on an angle. Reportedly, the wells have been evaluated formally for integrity for some time.
Wells outside the fenced area were locked but tubing protruded out from beneath the cover which could be pulled
out bv hand. Assessment of well integrity warranted and wells should be secured with locking caps/plugs.
D. Monitoring Data
Monitoring Data (Not on a regular schedule, but reported annually to EPA.)
¦ Is routinely submitted on time ¦ Is of acceptable quality
Monitoring data suggests:
~ Groundwater plume is effectively contained ¦ Contaminant concentrations are declining
Some asymptotic declines noted by Geolnsight.
D. 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
Five-Year Review Inspection
Wells G&H Superfund Site
Page 58 of 60
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X. OTHER REMEDIES
If there are remedies applied at the site which are 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. None
XL 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 to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
The remedy consists of injection of chemical oxidant (i.e.. 1SCQ) to destroy organic contamination in
groundwater and adsorbed to shallow soils. Monitoring data shows some contaminant concentration reduction
has been achieved since injections began. Most recent injections were in November 2018. which focused on the
area of the MW-217 well cluster at southeast corner of the treatment cell
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 protectiveness of the remedy.
With no active system onsite. onsite O&M consists of groundwater sampling and periodic oxidant injection.
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, which suggest that the protectiveness of the remedy may be
compromised in the future.
None. Geolnsight follows an iterative approach of 'treat and check' to advance progress at the site.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None, based on site inspection alone.
Five-Year Review Inspection
Wells G&H Superfund Site
Page 59 of 60
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Table 1 - Inspection Team Rooster
5-Year Inspection Team Members
Company
Jeffrey S. Hansen, PH
TRC
David M. Sullivan, LSP
TRC
Interviewed Staff
Company
Christene Binger
Geolnsight, Inc.
Five-Year Review Inspection
Wells G&H Superfund Site
Page 60 of 60
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