SEVENTH FIVE-YEAR REVIEW REPORT FOR
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
ROCKINGHAM COUNTY, NEW HAMPSHIRE

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Prepared by

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

D DV A NI	Digitally signed by BRYAN

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OLSON

Bryan Olson, Director	Date

Superfund and Emergency Management Division


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Table of Contents

LIST 01 ABBREVIATIONS & ACRONYMS	2

I.	INTRODUCTION	4

Site Background	4

FIVE-YEAR REVIEW SUMMARY FORM	5

II.	RESPONSE ACTION SUMMARY	7

Basis for Taking Action and Response Actions	7

Status of Implementation	9

Institutional Controls	11

Systems Operations/Operation & Maintenance (O&M)	13

III.	PROGRESS SINCE THE PREVIOUS REVIEW	15

IV.	FIVE-YEAR REVIEW PROCESS	16

Community Notification, Community Involvement and Site Interviews	16

Data Review	16

Site Inspection	22

V.	TECHNICAL ASSESSMENT	22

QUESTION A: Is the remedy functioning as intended by the decision documents?	22

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid?	24

QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?	32

VI.	ISSUES/RECOMMENDATIONS	33

Other Findings	33

VII.	PROTECTIVENESS STATEMENT	34

VIII.	NEXT REVIEW	34

APPENDIX A - REFERENCE LIST	A-l

APPENDIX B - SITE CHRONOLOGY	B-l

APPENDIX C - SITE MAPS	C-l

APPENDIX D - EPA NEWS RELEASE	D-l

APPENDIX E - INTERVIEW FORMS	E-l

APPENDIX F - DATA REVIEW TABLES AND FIGURES	F-l

APPENDIX G - SITE INSPECTION CHECKLIST	G-l

APPENDIX H - SITE PHOTOGRAPHS	11-1

APPENDIX I - REVIEW OF CLEANUP LEVELS	1-1

APPENDIX J - VISL OUTPUT	J-l

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LIST OF ABBREVIATIONS & ACRONYMS

AGQS

Ambient Groundwater Quality Standard

ALM

Adult Lead Methodology

ARAR

Applicable or Relevant and Appropriate Requirement

AROD

Amended Record of Decision

AST

Aboveground Storage Tank

ATSDR

Agency for Toxic Substances and Disease Registry

BLL

Blood Lead Level

bgs

Below Ground Surface

CASRN

Chemical Abstracts Service Registry Number

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

CIC

Community Involvement Coordinator

COC

Contaminant of Concern

DCA

Dichloroethane

DCE

Dichloroethene

EPA

United States Environmental Protection Agency

ERRCO

Environmental Resource Recovery Corporation

ESD

Explanation of Significant Differences

ESV

Ecological Screening Value

ETBE

Ethyl Tertiary Butyl Ether

FFS

Focused Feasibility Study

FYR

Five-Year Review

GMP

Groundwater Management Permit

GMZ

Groundwater Management Zone

HFPO-DA

Hexafluoropropylene Oxide Dimer Acid (Gen-X)

HHRA

Human Health Risk Assessment

HiPOx

High-Pressure Oxidation

HQ

Hazard Quotient

IC

Institutional Control

IRIS

Integrated Risk Information System

IUR

Inhalation Unit Risk

KES

Keefe Environmental Services

MAROS

Monitoring and Remediation Optimization System

MCL

Maximum Contaminant Level

MNA

Monitored Natural Attenuation

MOM

Management of Migration

MRL

Minimal Risk Level

1-ig/dL

Micrograms per Deciliter

l-ig/L

Micrograms per Liter

mg/kg

Milligrams per Kilogram

mg/kg-day

Milligrams per Kilogram per Day

mg/m3

Milligrams per Cubic Meter

mg/L

Milligrams per Liter

MtBE

Methyl Tert-Butyl Ether

MW

Monitoring Well

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NHDES

New Hampshire Department of Environmental Services

NPL

National Priorities List

ng/L

Nanograms per Liter

O&M

Operation and Maintenance

OLEM

Office of Land and Emergency Management

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ou

Operable Unit

PCE

T etrachloroethene

PFAS

Per- and Polyfluoroalkyl Substances

PFBA

Perfluorobutanoic Acid

PFBS

Perfluorobutane Sulfonic Acid

PFHxA

Perfluorohexanoic Acid

PFHxS

Perfluorohexane Sulfonate

PFNA

Perfluorononanoic Acid

PFOA

Perfluorooctanoic Acid

PFOS

Perfluorooctane Sulfonate

PPRTV

Provisional Peer Reviewed Toxicity Value

PRP

Potentially Responsible Party

ppb

Parts per Billion

ppm

Parts per Million

ppt

Parts per Trillion

RAO

Remedial Action Objective

RfC

Reference Concentration

RfD

Reference Dose

RI

Remedial Investigation

ROD

Record of Decision

RPM

Remedial Project Manager

RSL

Regional Screening Level

SAP

Sampling and Analysis Plan

tBA

tert-Butyl Alcohol

TBC

To Be Considered

TCE

Trichloroethene

tBA

tert-Butyl Alcohol

UU/UE

Unlimited Use and Unrestricted Exposure

VISL

Vapor Intrusion Screening Level

VOC

Volatile Organic Compound

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I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy 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 Code of Federal Regulations (CFR) Section
300.430(f)(4)(ii)), and considering EPA policy.

This is the seventh FYR for the Keefe Environmental Services Superfund Site (the Site). The triggering action for
this policy review is the completion date of the previous FYR. The FYR has been prepared because hazardous
substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and
unrestricted exposure (UU/UE).

The Site consists of two operable units (OUs). OU1 addressed immediate hazards emanating from the lagoon on
site (also described as "Barrels and Lagoon" or "Lagoons and Surrounding Soils"). The remedial action
associated with OU1 was completed prior to the second FYR. OU2 addresses source control and management of
migration (MOM) (i.e., the groundwater remedy). This FYR Report focuses on the remedial implementation
associated with OU2 MOM, which included the extraction and treatment of groundwater to remove
concentrations of volatile organic compounds (VOCs) and modification to monitored natural attenuation (MNA)
in 2017. This review includes an overview of the Site, remedial action objectives (RAOs) and remedy
components. Remedial protectiveness continues to be evaluated using the most recent monitoring data along with
a series of supporting evaluations involving groundwater flow and MNA.

EPA conducted this FYR. Participants included EPA remedial project manager (RPM) Cheryl Sprague, risk
assessor Paulina Do, attorney Man Chak Ng and community involvement coordinator (CIC) Kelsey Dumville.
Other participants included Michael Summerlin from the New Hampshire Department of Environmental Services
(NHDES), and Johnny Zimmerman-Ward and Ali Cattani from EPA FYR support contractor Skeo. The review
began on 12/12/2022.

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

Site Background

The Site's 17-acre parcel is located at 256 Exeter Road (Old Route 101) in Epping, Rockingham County, New
Hampshire (See Figure 1). Keefe Environmental Services (KES) operated a chemical waste storage and bulking
facility on site from 1978 until 1981, when it voluntarily filed for bankruptcy. Many waste storage containers,
including 4,100 drums, four 5,000-gallon and four 10,000-gallon aboveground storage tanks (ASTs), dumpsters
containing sludges and contaminated soils, and a 700,000-gallon lined storage lagoon (former lagoon, Figure 1)
were abandoned at the Site. Solvents, acids, caustics, heavy metals, paint sludges, waste oils and organic
chemicals were improperly stored, managed and otherwise disposed of at the Site. Facility operations led to both
shallow soil and groundwater contamination on and off site. Groundwater extraction and on-site treatment
operations were initiated in 1993 and removed from service in December 2011, following years of optimization
actions. Environmental monitoring of groundwater under non-pumping conditions has been ongoing since 2012;
the remedy was amended to MNA in September 2017.

The Town of Epping (Town) owns the former Keefe property, which consists of the former groundwater
treatment plant building, open space surrounded by forested uplands and lowland wetlands. A small, historic
cemetery is located on part of the former Keefe property. The Town uses the former treatment plant building for
storage. Two intermittent streams are on site. One stream drains a wetland area to the northwest and flows

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northwesterly toward the Piscassic River via a small, unnamed brook. A second intermittent stream in the
southern portion of the Site receives drainage from other areas and flows eastward from a wetland area toward the
Fresh River (Figure 1). These two rivers eventually join one another near the Town of Newfield, about 3.2 miles
northeast of the Site. Nearby commercial properties include an active recycling and composting facility
(ReSource Waste Services, formerly Environmental Resource Recovery Corporation [ERRCO]), a dragway and a
firearms training facility. Several residential properties are south of the Site, along Exeter Road and Indian River
Road. The Site's former Keefe property remains secured by the original Keefe fence with a locked and gated
entrance. Additional locked gates allow for access to monitoring wells beyond the former Keefe property.

Depth to groundwater across the Site varies from about 3 feet to 7 feet below ground surface (bgs) in the central
area of the Site to less than 2 feet bgs near the southwest wetland area. Groundwater occurs in both an overburden
and bedrock aquifer. A groundwater and surface water divide is present on the western part of the Site. This
divide directs groundwater and surface water flow in two separate flow directions, including a northwest
component and a southeast component (Figure 1). Vertical flow in the overburden and bedrock aquifers is
generally downward in the central area of the Site and upward in the vicinity of the wetland boundary areas.

The ERRCO facility abuts the northern and eastern parts of the Site. Though several production wells are in use,
there is no potable water supply well. The homes next to the Site receive drinking water from private wells
installed in the deep bedrock portion of the aquifer (typically depths greater than 300 feet bgs). Drinking water
wells along Exeter Road and Indian River Road have been sampled routinely since 2003, and no contaminants of
concern (COCs) have been detected. More detailed descriptions of the Site are in the Site's 1988 Record of
Decision (ROD), as amended in 2017, and the Site's 2017 Focused Feasibility Study (FFS) Report.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Keefe Environmental Services

EPA ID: NHD092059112

Region: 1

State: NH

City/County: Epping/Rockingham County

NPL Status: Final

Multiple OUs? Yes

Lead agency: EPA
Author name: Cheryl Sprague
Author affiliation: EPA

Has the site achieved construction completion? Yes

REVIEW STATUS

Review period: 12/12/2022 - 9/10/2023
Date of site inspection: 5/8/2023
Type of review: Policy
Review number: 7
Triggering action date: 9/10/2018

Due date (fiveyears after triggering action date): 9/10/2023

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Figure 1: Site Vicinity Map

Waste Services

Ltf.em'etery

New England

BpfagwaVjjj

i i Keefe Property

l^i) Former Lagoon Area

Wetland Area

Approximate Location
of Surface Water/
Groundwater Divide

Approximate Location
of Hydraulic Barrier

—Fence

	 Stream

Koofo Pnuirnnmonfal Qori/iroe /If	Disclaimer. This map and any boundary lines within the map are approximate and

XT iVCClw d I VII Ul III ICI llal OCI VILCO y iVCO J	subject to change. The map is not a survey. The map is for informational purposes

only regarding EPA's response actions at the Site. Map image is the intellectual
i Superfund SitG	property of Esri and is used herein under license. Copyright © 2020 Esri and its

^ Skeo

licensors. All rights reserved. Sources: Esri, Esri Community Maps Contributors, ©

OpenStreetMap, Microsoft, Esri, HERE, Garmin, SafeGraph, GeoTechnologies, Inc.

City of Eppincj, Rockingham County, New Hampshire metimasa, usgs. epa, nps. us census Bureau, usda, Maxar, u.s. epas cmce

			((		of Mission Support; Data Steward; U.S. EPA's Office of Land and Emergency Last Modified: 8/23/2023

I	I	I	I	I	I	Management - NPL Superfund Site Boundaries (EPA Public 2022) and the 2021

0	200 400 600 800 1,000 Feet	Annual Monitoring Report.

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II. RESPONSE ACTION SUMMARY

Basis for Taking Action and Response Actions

In 1981, the abandoned KES property included a 700,000-gallon lined waste lagoon constructed above grade. Due
to threats to the environment, EPA led an emergency cleanup to draw down wastes to avoid overflow of the
lagoon. EPA and the state also removed stored drums and other containers from the Site from 1981 to 1982. In
March 1983, the state, through a cooperative agreement with EPA, removed about 4,100 55-gallon drums, four
5,000-gallon and four 10,000-gallon ASTs, and seven dumpsters from the Site. EPA listed the Site on the
Superfund program's National Priorities List (NPL) in September 1983.

Remedial investigation (RI) activities took place from 1983 to 1988. The Site's 1988 RI Report stated that surface
runoff from the Site (primarily from overflow of the lagoon) pooled in low-lying areas and resulted in four zones
of shallow soil contamination that were delineated and characterized by high organic vapor concentrations in soil
gas samples. Groundwater was contaminated with VOCs, present in both the shallow bedrock and overburden
aquifers. The distribution of contaminants at the Site suggested the existence of two possible source areas of
contamination: the central part of the Site, in the vicinity of the chemical bulking and storage area, and a
secondary source area, located in a wetland at the southwest corner of the Site. This area received most of the
surface runoff.

Hazardous substances were brought to, stored and/or released to the subsurface at the Site; the primary
contaminants of concern and the basis for the OU2 groundwater cleanup are VOCs. The 1988 ROD included
chemicals of concern (COCs) for both soils and groundwater based on chemicals that could result in unacceptable
levels of human health risk through potential leaching to and/or contaminant concentrations exceeding acceptable
levels or maximum contaminant levels (MCLs). The shallow soil COCs were met soon after the signing of the
1988 ROD. The 2005 ESD included 1,4-dioxane as a COC. The 2017 AROD included several chlorinated
breakdown products, found in groundwater in excess of the state ambient groundwater quality standards (AGQS).

The Site's 1988 Human Health Risk Assessment (HHRA) indicated potential future unacceptable risk from
ingestion of contaminated groundwater. The 1988 HHRA did not find unacceptable risk at the Site from ingestion
of or dermal contact with contaminated soils or contact with contaminated surface water for current or future use.
The HHRA update in 2005 confirmed that VOCs in groundwater, including 1,4-dioxane and trichloroethene
(TCE), were found to present an unacceptable risk if site groundwater is used as a source of potable water in the
future.

Ecological risks were not evaluated in the HHRA or the update. EPA evaluated ecological risks as part of the
2013 FYR. EPA found that no ecological concerns associated with the low levels of VOCs (including 1,4-
dioxane) present in surface water.

OU1 -Lagoon and Surrounding Soils

On November 15, 1983, EPA issued the OU1 ROD. It mandated decommissioning of the 700,000-gallon lagoon
and removal of the lagoon contents as well as removal of all waste containers, lagoon solid wastes and
contaminated soils next to the lagoon, with disposal of the materials at a regulated facility. The 1983 ROD did not
specify RAOs but stated the OU1 remedy objective was to reduce and/or eliminate direct contact hazards at the
Site emanating from the lagoon and any off-site migration that could result via surface runoff or groundwater
contamination from potential liner failure.

OU2 - Source Control and MOM

EPA issued a ROD for OU2 on March 21, 1988. It included source control and MOM components. EPA updated
the OU2 remedy with Explanations of Significant Differences (ESDs) in 1990 and 2005, and an Amended Record
of Decision (AROD) in 2017.

The 1988 ROD provided separate RAOs for source control and MOM, as follows:

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Source Control RAOs

•	Prevent or mitigate further releases of contaminants to surrounding environmental media.

•	Eliminate or minimize the threat posed to public health or welfare, or the environment from the source
area.

•	Reduce the volume, toxicity or mobility of hazardous substances, pollutants and contaminants.
MOM RAOs

•	Prevent or mitigate migration of contaminants beyond their current extent.

•	Eliminate or minimize the threat posed to public health, welfare and the environment from the current
extent of contaminant migration.

The 2017 AROD addressed the risk related to ingestion of groundwater, should on-site overburden or bedrock
groundwater be developed as a source of drinking water in the future. The MOM RAOs developed for the 1988
ROD were revised by the 2017 AROD, as follows:

•	Prevent potential ingestion by a future worker or recreational user to groundwater impacted by the Site
with VOCs (including 1,4-dioxane), semi-volatile organic compounds or inorganic contaminants at
concentrations that exceed applicable or relevant and appropriate requirements (ARARs) or risk-based
standards.

•	Restore groundwater within the groundwater management zone (GMZ) to its beneficial use as a potential
drinking water supply by meeting ARARs, including federal maximum contaminant levels (MCLs) and
state AGQS or, in their absence, by meeting risk-based standards.

•	Limit migration of VOCs (including 1,4-dioxane), semi-volatile organic compounds and inorganic
compounds in groundwater beyond the GMZ at concentrations that exceed ARARs or risk-based
standards.

The source control component consisted of vacuum extraction for an area of shallow contaminated soils. The
MOM component included extraction and on-site treatment of groundwater to remove site-related VOCs. In June
1990, EPA issued an ESD to remove the requirement of vacuum extraction.

In 2003, the presence of 1,4-dioxane was first detected in groundwater samples collected at the Site. The
groundwater treatment system was modified by the Site's 2005 ESD from an air stripping configuration to the
high-pressure oxidation (HiPOx) system to address the 1,4-dioxane and a cleanup level of 3 micrograms per liter
(fig/L) was set for 1,4-dioxane. The 2005 ESD also documented a soil cleanup action completed in 2004 (see
Status of Implementation section below).

While the cleanup actions performed since 1981 significantly removed contaminant mass and reduced
contaminant concentrations, groundwater contamination remains elevated above drinking water standards at the
Site. The 2017 AROD revised the groundwater remedy from pumping and treatment to monitored natural
attenuation (MNA). The MNA remedy includes the following components:

•	Long-term monitoring to evaluate the efficacy of MNA to attain cleanup levels, including monitoring at
the site boundaries for plume migration.

•	Establishment and/or maintenance of institutional controls (e.g., GMZ, local ordinance) to eliminate the
potential drinking water exposure pathway.

•	FYRs to assess the protectiveness of the remedy.

Cleanup Levels

The 1988 ROD established soil cleanup levels (Table 1). The 1990 ESD documented that subsequent sampling
showed soil concentrations were already below these cleanup levels. As documented in the 2005 ESD, soil
samples collected in 2003 were compared to NHDES Method 1 soil criteria based on residential use or
background (metals). All soil in excess of these standards was removed in 2004 (see the Status of Implementation
section).

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Table 1: Soil Cleanup Levels

(¦<>(¦

Soil ( loiinup l.c\i*rh
(.uii/Uii)

Benzene

20.8

1,2-Dichloroethane (DCA)

3.5

1,1-Dichloroethen (DCE)

22.8

Tetrachloroethene (PCE)

91.0

TCE

31.5

Notes:



|ig/kg = micrograms per kilogram

a. Established in the Site's 1988 ROD.

b. Cleanup goals for soils based on an excess cancer risk of 5.7 x 10~5

through ingestion of groundwater.

Groundwater cleanup levels were established in the 1988 ROD and amended in the 2005 ESD and 2017 AROD.
The 2005 ESD based the 1,4-dioxane cleanup level on available risk data and, in September 2005, NHDES
promulgated the same value as an AGQS. The cleanup levels for the remaining contaminants, benzene,
tetrachloroethene (PCE), TCE, 1,1-dichloroethene (DCE), and 1,2-dichloroethane (DCA), were set in the 1988
ROD based on MCLs. The 2017 AROD also required the cleanup of chlorinated compound breakdown products,
currently found in groundwater in excess of AGQS, including 1,1-DCA and vinyl chloride.

Table 2 includes the cleanup levels set in 1988 for the original compounds and the cleanup level for 1,4-dioxane
set in the 2005 ESD, as well as the cleanup level for degradation daughter products that currently exceed their
drinking water standards as set in the 2017 AROD.

Table 2: Groundwater Cleanup Levels

( onl;imiil;inl of

( loiinii|) l.c\i-r

liiisis

Concern (( ()( )

lUli/l.)



Benzene

5

MCL

1,2-DCA

5

MCL

1,1-DCE

7

MCL

PCE

5

MCL

TCE

5

MCL

1,4-dioxane

3b

State AGQS

Vinyl chloride

2°

MCL

1,1-DCA

81°

State AGQS

Notes:





a. Established in the Site's 1988 ROD, unless otherwise specified.

b. Established in the Site's 2005 ESD.



c. Established in the Site's 2017 AROD.



Status of Implementation

OU1 - Lagoon and Surrounding Soils - Completed

In 1983, EPA and the state removed all the waste and containers, including the waste in the lagoon and the liner
and disposed of the contaminated material, as well as highly contaminated soil adjacent to the lagoon, at a
regulated facility.

OU2 - Source Control and MOM

Source Control - Completed

The source control component consisted of vacuum-enhanced extraction for an area of shallow contaminated
soils. In June 1990, EPA issued an ESD to remove the 1988 ROD requirement of vacuum-enhanced extraction,

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when sampling showed that the concentrations of VOCs in shallow overburden soils were already below the soil
cleanup standards specified in the 1988 ROD.

In 1992, soil excavated from near the source area to construct the infiltration trench for the groundwater treatment
system was placed into the former lagoon. From 1993 to 2005, precipitation percolated through these soils. The
resulting leachate was captured and treated by the groundwater treatment system, until contamination was no
longer detected in the leachate. As described in the 2005 ESD, soil sampling confirmed only a small volume of
these soils still contained semi-volatile organic compounds at levels of potential concern related to future contact
and ingestion. This soil was excavated and disposed of at an off-site landfill. That action was followed by the
dismantling of the lagoon system and the regrading and reseeding of this area, completing the cleanup of site
soils. These activities were recorded in the 2005 ESD.

In 2017, more soil samples were collected in the central source area as part of the 2017 FFS. Based on the soil
results, which were below risk-based screening levels, EPA determined that potential exposure to site soils via
future residential or recreational use, including the regrading of site soils for those uses, would not result in an
unacceptable risk.

MOM - Ongoing

The MOM component included extraction and on-site treatment of groundwater to remove site-related VOCs. In
1993, the groundwater extraction, treatment and re-infiltration system was completed and began operating.
The groundwater extraction and treatment system operated continuously from 1993 through December 2011,
extracting and treating over 149 million gallons of groundwater.1 After years of active remediation to control the
migration of contaminants and reduce the mass and concentration of contaminants, it became apparent that while
the current pump-and-treat remedy has performed as expected, continued operations would not be a cost effective
means to complete the attainment of cleanup standards in groundwater. The groundwater treatment system ceased
operations in December 2011, after it was deemed to no longer be needed to contain the contaminants within the
plume or to be cost effective, given the reduced mass loading.

MNA investigations from 2012 through 2014 found that conditions at the Site would allow for and support
sustainable natural biodegradation processes to reduce concentrations of 1,4-dioxane to drinking water standards.
More information on these investigations is available in the Site's 2014 MNA Technical Memorandum.

The 2015 and 2016 groundwater data indicated that the chlorinated solvents, originally found in the central source
area have since degraded, and the remaining exceedance found of these chlorinated compounds (PCE and TCE)
are currently near their cleanup levels at the southern downgradient edge of plume (Figure C-3 in Appendix C).
The lateral extent of 1,4-dioxane is significantly larger than that of other VOCs, which is typical for this
compound due to its increased solubility and mobility in groundwater (Figure C-2 in Appendix C). EPA
conducted more investigations to support the 2017 FFS. These supplemental reports presented groundwater
investigations and analyses and offered new information that allowed for the review, comparison, and selection of
MNA as the preferred remedy in the 2017 AROD.

In 2017, EPA selected MNA as the amended groundwater remedy based on the following information:

•	There are no current users of groundwater at the Site. Therefore, there are no current risks.

•	Studies performed since 2008 indicate that pumping and treatment is no longer an efficient means to
reduce contamination to meet cleanup levels, and MNA would attain cleanup levels in about the same
timeframe.

•	The plume has stabilized at the current boundaries, following the shutdown of the pump-and-treat system
in 2011 and site studies show that natural processes, including dispersion and advection, along with

1 The groundwater treatment system was modified by the Site's 2005 ESD from an air stripping configuration to the HiPOx
system.

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natural occurring bacterial populations present in groundwater, will support the continued degradation of
the chlorinated organics as well as 1,4-dioxane, the primary groundwater contaminant.

The remedy includes long-term groundwater performance monitoring to determine progress and efficacy of
MNA. Institutional controls will be maintained or established for groundwater contamination associated with the
Site to eliminate potential drinking water exposure pathways (the Institutional Controls section of this FYR
Report provides more information).

The updated remedy is expected to prevent ingestion of contaminated groundwater at the Site while allowing
natural processes to reduce residual concentrations to drinking water levels. The AROD indicated that the lower
concentration areas will attain cleanup levels in about 34 years, while the higher-concentration central source area
may require up to 175 years to allow residual contamination (primarily 1,4-dioxane) to diffuse from the materials
and attain cleanup levels.

NHDES's contractor conducts semi-annual monitoring including groundwater, residential drinking water and
surface water. The Data Review section of this FYR Report provides more information on the current extent and
magnitude of groundwater contamination.

In 2021, NHDES decommissioned the former groundwater treatment plant. Clean Harbors Environmental
Services removed residual waste for off-site disposal. About 1,400 gallons of liquid, non-hazardous waste was
removed. An additional estimated 3,000 pounds of solid waste and an estimated 8,000 pounds of liquid waste
classified as hazardous waste containing PCE and TCE were removed from the Site. Decommissioning work
consisted of removing the internal components (e.g., the filter press, filter vessels, pumps, blowers, electrical
wiring) and piping associated with the treatment system. The sump and drain were filled with concrete to
decommission the subsurface components. System components were removed from the Site for disposal or
recycling, where applicable. A final walkthrough took place in 2021, prior to transferring the former treatment
plant building to the Town so they can use it for storage.

Institutional Controls

In January 2006, a GMP issued to the Town identified the groundwater monitoring program and established a
Groundwater Management Zone (GMZ), which is an area within which groundwater is monitored and use is
managed due to the presence of groundwater contaminants that exceed state AGQS.

In January 2010 and again in 2017 as part of site optimization activities, several new monitoring well couplets and
deep bedrock monitoring wells were installed to support an expansion of the GMZ and provide additional
monitoring near the GMZ boundaries.

The GMZ established in the 2018 GMP includes land, or portions of land, on four separate but contiguous
properties, all located in the Town (see Table 3 below and Figure 2).

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Table 3: Summary of Planned and/or Implemented Institutional Controls (ICs)

Mcdiii.
engineered
coin nils, iiml
sire.is lliiil do nol
support I 1 /I 1.
h.ised on

I'll ITCH 1
conditions

ICs
Needed

ICs ( idled
lor in llic
Decision
Documents

lmp;iclcd Piircel(s)

IC

OI)jec(i\e

Tide of l(
Inslriimenl
Implemented
iind Diile

Groundwater

Yes

Yes

Tax Map-
Lot# 38-
025

256 Exeter Road
Epping, NH 03042

Owned by
Town of
Epping

Monitor
groundwater
until cleanup
levels have
been attained.

GMP
GWP-198710024-
E-003
Approved:
02/24/2018

Groundwater

Yes

Yes

Tax Map-Lot#: 38-

020 (portion)
Deed ref: 3470-1844

20 Indian River Road
Epping, NH 03042

Monitor
groundwater
until cleanup
levels have
been attained.

GMP
GWP-198710024-
E-003
Approved:
02/24/2018

Groundwater

Yes

Yes

Tax Map-Lot#: 38-

027 (portion)
Deed ref: 3103-2880

ReSource Services

(ERRCO)
270 Exeter Road
Epping, NH 03042

Monitor
groundwater
until cleanup
levels have
been attained.

GMP
GWP-198710024-
E-003
Approved:
02/24/2018

Groundwater

Yes

Yes

Tax Map-Lot#: 38-

019 (portion)
Deed ref: 5329-0123

16 Indian River Road
Epping, NH 03042

Monitor
groundwater
until cleanup
levels have
been attained.

GMP
GWP-198710024-
E-003
Approved:
02/24/2018

The initial 2006 GMP was issued as part of the site transition from EPA, under the long-term remedial action
program to NHDES. A Notice of Groundwater Management Permit was recorded in the Rockingham County
Registry of Deeds for each GMP, referencing all properties in the GMZ. Within the GMZ, groundwater use must
be monitored and managed until groundwater has been restored.

The most recent GMP was issued in February 2018 and expired on February 23, 2023. NHDES did not renew the
permit with the Town. Nonetheless, the monitoring requirements, which had been performed under all of the
former GMPs, continue to be conducted by NHDES. Institutional controls, in the form of deed notices for the
properties in the GMZ, will need to be reviewed and updated to provide information or notification of
groundwater contamination at the Site and the ongoing monitoring and management of the use of groundwater
until site groundwater cleanup levels are attained.

12


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Systems Operations/Operation & Maintenance (O&M)

The current remedy for the Site is MNA for groundwater. Therefore, there were no active remediation or system
operations during this FYR period. O&M activities for the Site currently involve:

•	Groundwater sampling of VOCs and various attenuation parameters to support natural attenuation
assessment and determination of long-term protectiveness.

•	Inspection and maintenance of the integrity of the groundwater monitoring network.

•	Groundskeeping.

The Town generally conducts groundskeeping activities on the former Keefe property, including mowing and the
maintenance of the building and fence. While the fence is not required as part of the remedy, there is no plan to
remove the fence. NHDES contractor Weston Solutions conducts maintenance of the groundwater monitoring
network. Prior to transferring control of the property to the Town in 2021, Weston Solutions identified necessary
well repair and maintenance items. The items identified included minor repair work to well heads, repainting and
labeling wells outside of the fenced area, clearing vegetation from around well heads, and well decommissioning
tasks. These activities took place in June and December 2021.

In October 2018, six new monitoring wells, consisting of three well couplets (MW-60C and MW-60D, MW-61C
and MW-61D, and MW-62C and MW-62D) that include a shallow bedrock ("C" designation) well and a deep
bedrock ("D" designation) well, were installed in deep bedrock boreholes MW-60, MW-61 and MW-62.

NHDES conducts well repairs annually as part of the spring sampling events. In addition, well redevelopment
efforts were performed prior to the fall 2022 sampling event at wells that are not part of the current monitoring
program.

13


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Figure 2: Institutional Control Mar





i i Keefe Property

GMZ Boundary

Estimated extent of 1,4-
dioxane cleanup goal
exceedances (2021)

Estimated extent of VOC

Q	| exceedances (excluding 1,4-

dioxane) (2021)



Parcels within the GMZ
Boundary

Epping
Brentwood

c

\



%>

Kpofa Pnuirnnmontsl Qorx/iroc /l/'PQ\	Disclaimer: This map and any boundary lines within the map are approximate and subject to

iVCClU CI IVII VSlllllClllal OtJI VIUCo [ixuOj	change. The map is not a survey. The map Is for informational purposes only regarding EPA's

response actions at the Site. Map image is the intellectual property of Esri and is used herein
Q. ¦ rtorfI inH Citn	under license. Copyright © 2020 Esri and Its licensors. All rights reserved. Sources: Esri,

OUpCI lUllvl Oil"	Maxar, Microsoft, Map data © OpenStreetMap contributors, Microsoft, Facebook, Inc. and its	^ lx/*\ /"\ *

affiliates, Esri Community Maps contributors, Map layer by Esri, Esri Community Maps

City of Epping, Rockingham County, New Hampshire

|	1	1	1	1	1	Office of Mission Support; Data Steward: U.S. EPAs Office of Land and Emergency Lasi	'zu

n	„nn	_nr.	ar.n	. nnn c ,	Management - NPL Superfund Site Boundaries (EPA Public 2022) and the 2021 Annual

u	ouu	ouu	i ,uuu reel	Monitoring Report.

i

^ Skeo

14


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III. PROGRESS SINCE THE PREVIOUS REVIEW

Table 4 includes the protectiveness determinations and statements from the 2018 FYR Report. Table 5 includes
the recommendations from the 2018 FYR Report and the status of those recommendations.

Table 4: Protectiveness Determinations/Statements from the 2018 FYR Report

()l #

Prok'ClixciK'NN DiMiTiiiiiiiilion

PmU'iiiteiiess Siaicnu'iil

1

Protective

OU-1 - Source Control:

The remedy at OU1 has met soil cleanup goals, is complete and therefore
is protective of human health and the environment.

2

Short-term Protective

OU-2 - Management of Migration (MOM):

The remedy at the Site is currently protective of human health and the
environment as envisioned in the 1988 ROD, as modified, in the short-
term, because the soil component of the remedy has been successfully
completed, and ICs are in place and are currently effective in managing
exposure to contaminated groundwater at the Site. In order for the remedy
to be protective in the long-term, the following actions need to happen:
(1) Further evaluation is required for PFAS [per- and polyfluoroalkyl
substances] in groundwater to determine whether they pose an
unacceptable risk to future users of groundwater in the GMZ and if it is
present in nearby residential drinking water supply wells; and
(2) Cleanup standards need to be attained.

Sitewide

Short-term Protective

The remedy is protective in the short-term. In order for the remedy to be
protective in the long-term, groundwater cleanup levels, selected in the
1988 ROD, the 2005 ESD, and the 2017 AROD need to be achieved and
further evaluation of whether PFAS in groundwater poses a potential
unacceptable risk to future users of groundwater is needed.

Table 5: Status of Recommendations from the 2018 FYR Report

()l #

Issiio

Kccommciuhilion

( II ITCH 1
Sliilus

( iinvnl Impk-mcnlaliun Sliilus
Description

( oiii plot ion

Dale (if
applicable)

2

PFAS have
been detected
in groundwater
above
screening
levels.

Site-specific screening
levels indicate that further
evaluation is needed to
determine if PFAS are
contaminants of concern.
Sampling for PFAS at the
nearby residential
drinking water wells
should be included.

Completed

Residential wells were first sampled
in 2019 and are currently sampled
in accordance with Sampling and

Analysis Plans (SAPs).
Perfluorooctane sulfonate (PFOS)
was the only PFAS detected during

each sampling event. The
compound was only detected at the
DW-2 location. The reported PFOS
concentrations at DW-2 in spring
and fall 2021 were 10.2 nanograms

per liter (ng/L) and 10.9 ng/L,
respectively. They were below the

established AGQS of 15 ng/L;
however, they were above the EPA
Regional Screening Level (RSL) of
4 ng/L. This location was not
sampled in 2022 because the
residence is no longer occupied.
The Data Review section of this
FYR Report provides more
information on the PFAS sampling
results.

5/27/2020

15


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IV. FIVE-YEAR REVIEW PROCESS

Community Notification. Community Involvement and Site Interviews

EPA issued an online news release in January 2023 to announce that the FYR was underway. A copy of the news
release is included in Appendix C. The results of the review and the completed FYR Report will be made
available on EPA's site profile page at www.epa.gov/superfund/keefe.

During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy that has been implemented to date. The results of these interviews are summarized below. Appendix D
includes the completed interview forms.

Michael Kanarek, project manager from NHDES O&M contractor Weston Solutions, indicated that the cleanup
and monitoring activities are proceeding in compliance with state and federal guidelines and adequately protecting
human health and the environment. Mr. Kanarek observed contaminant concentrations have fluctuated following
the treatment system shutdown in 2011 but have remained in historical ranges and show an overall decreasing
trend since 2008. Weston Solutions completes monitoring activities semi-annually and monitoring well
inspections and maintenance are conducted ahead of each monitoring round.

Data Review

NHDES and its contractor Weston Solutions conduct semi-annual monitoring in accordance with the Sampling
and Analysis Plans (SAPs) (most recently updated in 2022). The results are reported in spring data submittals and
annual reports. This FYR reviewed the 2019, 2020, 2021 and 2022 annual reports.

The current sampling program is performed biannually, in the spring and fall of each year. The spring sampling
includes a limited number of wells and surface water locations currently analyzed primarily for 1,4 dioxane with
VOC analysis from selected wells. The spring sampling round provides additional monitoring of 1,4-dioxane at
site boundary wells, especially near the adjacent homes; collection of additional MNA parameters to study the
effectiveness of the selected remedy; and monitors the effects of seasonal variability on-site contaminant
concentrations as groundwater table and plume stabilization post-cessation of the pump-and-treat remedy is
observed. The fall sampling round is more comprehensive, providing an annual snapshot of most groundwater
monitoring wells, area drinking water supply wells, and select surface water locations. The primary focus of the
current sampling activities is to assess the progress of natural attenuation of the residual 1,4 dioxane and VOC
concentrations present in site groundwater. Per- and polyfluoroalkyl substances (PFAS) sampling has occurred
since 2017 in site groundwater and since 2019 in residential wells.

Figure F-l in Appendix F shows monitoring network.

Overall, the data review has shown that:

•	Results from the 2022 monitoring indicate that exceedances of groundwater cleanup levels remain within
the GMZ boundary, in the North Area, Central Area and South Area, while overall decreasing trends in
downgradient concentrations are seen for total VOCs and 1,4-dioxane in both the overburden and bedrock
aquifers, as well as in discharges to surface water.

•	1,4-Dioxane continues to be the leading contributor to total VOC concentrations at the Site.

•	In 2022, six compounds (benzene, TCE, 1,1-DCE, 1,1-DCA, vinyl chloride and 1,4-dioxane) were
observed at concentrations above their cleanup levels in groundwater.

•	No site-related VOCs were detected in surface water sampled in 2022.

•	Consistent with past results, no site-related VOCs were detected in residential drinking water sampled in
fall 2022. Of the VOCs detected, none were present at concentrations exceeding NHDES AGQS.

16


-------
•	A review of the MNA parameter data collected indicates that the primary degradation pathway at the Site
is reductive dechlorination assisted or inhibited to varying degrees by the redox state of the groundwater
as it flows through the complex hydrogeologic regime.

•	PFAS were detected in site monitoring wells above EPA RSLs and state AGQS. The current extent of
PFAS is shown in Figure F-l 1 in Appendix F.

•	PFAS were not detected in nearby active drinking water supply wells sampled in 2022, and all reporting
limits were lower than state AGQS and EPA RSLs. PFOS was detected at the DW-2 location in spring
and fall 2021 at 10.2 nanograms per liter (ng/L) and 10.9 ng/L, respectively. While these results were
below the established AGQS of 15 ng/L, they are above the EPA RSL of 4 ng/L. This location was not
sampled in 2022 because the residence is no longer occupied.

Water Level Monitoring

Groundwater potentiometric surface maps are generated for the fall sampling event (in all aquifer zones) and
spring sampling events (overburden only). The spring and fall 2022 potentiometric maps are provided in Figures
F-2 through F-5 in Appendix F. From the topographic high point where the former groundwater extraction plant
sits, overburden groundwater flows laterally in a radial pattern to the northwest, west, south and southeast. As the
groundwater flows laterally toward the lowland areas of the Site, it bifurcates toward the northern tributary that
feeds into the Piscassic River and to the south where it is intercepted by the larger wetland system and directed
east toward the Fresh River. The groundwater flow observed during this FYR period continues to show a
groundwater divide in both the overburden and shallow bedrock with a northwest and southeast component,
which is consistent with the Conceptual Site Model (Figure C-l in Appendix C). The larger wetland area/stream
network south of the Site tends to function as a hydraulic barrier to contaminant migration in the overburden and
shallow bedrock, preventing migration of COCs beyond the southern site boundary.

Groundwater Monitoring

As part of the 2020 Annual Report, Weston Solutions evaluated the groundwater monitoring program using
Monitoring and Remediation Optimization System (MAROS) software. The MAROS analysis results and review
of data confirmed the 1,4-dioxane plume in the two primary flow directions as receding and attenuating in the
northern flow direction and adjusting to cessation of groundwater extraction in the southern flow direction and
attenuating at the leading edge of the plume.

The 2022 Annual Report provided an evaluation of the current trends. Six compounds continue to exceed
groundwater cleanup levels: benzene, TCE, 1,1-DCA, 1,1-DCE, vinyl chloride and 1,4-dioxane. Consistent with
historical data, 1,4-dioxane continues to be the leading contributor to total VOC concentrations.

The horizontal extent of the VOC exceedances (excluding 1,4-dioxane) is located within the residual source area
and in a small area in the southeast corner of the Site around EW-2 (Figure F-6 in Appendix F). The horizontal
extent of all VOC exceedances in November 2022 has decreased when compared to October 2015 with some
fluctuation observed. VOCs (excluding 1,4-dioxane) were not detected in 12 wells in November 2022 (CDM-8,
CW-6C, KES-4B, MW-50, MW-51, MW-53A, MW-53C, MW-54A, MW-55C, MW-62C, MW-62D and PW-1).
Of the wells noted, all are boundary wells except CW-6C, KES-4B and PW-1. The VOC detections are located
downgradient of the source area along each of the groundwater flow paths to northwest, south and southeast of the
residual source area. The area of residual VOC impacts continues to shrink and is consistent with recent
observations in 2021.

17


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(ggjg# (5EEW0

@03M0a



Disclaimer This map and any boundary lines within the map are approximate and
subject to change. The map is not a survey. The map is for informational purposes only
regarding EPA's response actions at the Site. Map image is the intellectual property of
Esri and is used herein under license. Copyright © 2020 Esri and its licensors. All
rights reserved. Sources: Esri, Map data © OpenStreetMap contributors, Microsoft,

Facebook, Inc. and its affiliates, Esri Community Maps contributors. Map layer by Esri,	QK0O

City of Epping, Rockingham County, New Hampshire Esri Community Maps Contributors, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,

SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US Census Last Modified" 8/23/2023
I	I	I	I	I	I	Bureau, USD A, Maxar, U.S. EPA's Office of Mission Support; Data Steward: U.S.

0	200	400	600	800	1,000 Feet	EPA's Office of Land and Emergency Management - NPL Superfund Site Boundaries

(EPA Public 2022) and the 2021 Annual Monitoring Report.

Keefe Environmental Services (KES)
Superfund Site

Figure 3: Detailed Site Mai

Epping
Brentwood

i i Keefe Property
© Bedrock Monitoring Well

Deep overburden monitoring well
O Residential Well

© Shallow Overburden Monitoring Well
S3 Surface Water Sample Location
MW-54A Site Boundary Well

18


-------
The highest concentrations of 1,4-dioxane are present in source area wells MW-A, MW-Q1 and MW-58 (all
screened in the overburden; maximum concentration of 195 (ig/L in April 2022 at MW-58; the cleanup goal is 3
(ig/L). The horizontal distribution of 1,4-dioxane is shown in Figure F-7 in Appendix F. Results for 1,4-dioxane
from 2015 to present suggested that source area concentrations may continue to be reaching equilibration to non-
pumping conditions. Data collected to date provide further evidence of plume stabilization and that, in general,
the downgradient portions of the groundwater plume appear to be stable or decreasing as natural attenuation
processes continue to degrade the plume. Increases in 1,4-dioxane concentrations have been observed in the north
area since fall 2016 but are within recent fluctuations observed since the groundwater treatment plant was shut
down in 2011.

Sampling and analysis for MNA parameters are limited to nine wells across four zones identified as the Source
Zone (MW-Q1, MW-58 and MW-59), the Intermediate Zone (CDM-1A), the Downgradient Zone (CDM-11), and
the Boundary Zone (MW-51, MW-53A, MW-62C and MW-62D). All zones are generally considered anaerobic
with dissolved oxygen concentrations lower than 2 milligrams per liter (mg/L), indicating the microorganisms
have nearly completed the oxygen-reducing reactions. The low concentrations of dissolved oxygen observed at
the Site are favorable for natural biodegradation of chlorinated solvents.

The 2022 Annual Report also included a qualitative evaluation of groundwater trends (referred to as a Geographic
Area Trend Evaluation). This evaluation includes the segregation of VOC and 1,4-dioxane data into three
geographic areas within the Site that closely mimic the different groundwater flow directions present at the Site,
including the North Area, Central Area and South Area, as shown in Figure F-8 in Appendix F. Graphical
representations of average concentrations of 1,4-dioxane, total VOCs and selected VOCs are presented in Figure
F-8 in Appendix F. Trends in the North Area are evaluated using data from four monitoring wells (CDM-1 A,
EMW-2, EMW-3 and KES-4B) and one surface water location (SW-2) that represent concentrations to the
northwest and downgradient of the residual source area. Only monitoring locations CDM-1A, EMW-2 and EMW-
3 exceeded the groundwater cleanup level for 1,4-dioxane (3 j^ig/L) in 2022, which is consistent with recent
historical concentrations. Trends in the Central Area data set include data from eight wells (EMW-1, EW-95-2,
EW-97-1, EW-97-2, EW-97-3, MW-A, MW-Q1 and MW-Q2) located in and immediately downgradient of the
source area, including locations with the highest detected VOC and 1,4-dioxane concentrations.

The primary VOCs detected in this area are 1,4-dioxane, 1,1-DCA and 1,1-DCE. VOC concentrations in
November 2022 reached a peak average concentration. The extent of the rebound suggests relatively high
concentrations of VOCs continue to diffuse from the soil matrix into groundwater. Trends in the South Area were
evaluated using results from six wells (CDM-9, CDM-11, CDM-12A, EW-1, EW-2 and KES-2B) and two surface
water locations (SW-1 and SW-4). The South Area includes the topographically low area south/southeast and
downgradient of the source area that discharges groundwater to an unnamed tributary to the Fresh River.
Concentrations of VOCs with exceedances of groundwater cleanup levels (including 1,4-dioxane) in 2022 in the
South Area show no significant differences from concentrations detected a year prior, and the total VOC
concentrations reported show a comparatively small decrease from 2021. Although concentrations have fluctuated
following the treatment system shutdown in 2011, they have remained within historical ranges and show
decreasing concentrations overall since 2008. NHDES and its contractor Weston Solutions will continue to
monitor the progression of MNA at the Site.

Surface Water Monitoring

Surface water samples were analyzed for 1,4-dioxane (spring and fall) and VOCs (fall only). Three surface water
locations (SW-1, SW-2 and SW-4) were included in each sampling event. These locations are along the two
tributaries draining surface water from the Site (Figure 3).2 Surface water location SW-2 is on the tributary
draining northwest toward the Piscassic River, and locations SW-1 and SW-4 are on the tributary draining
southeast toward the Fresh River (Figure 3).

2 Surface water location SW-1 was dry during the November 2020 sampling event. Location SW-5, located downstream, was
sampled instead. During the fall 2022 sampling event, an insufficient amount of water was present at SW-2. Therefore, the
sampling location was moved to SW-2B, which is located southwest and upgradient of the Site.

19


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During this FYR period, 1,4-dioxane was the only COC detected. 1,4-Dioxane has been detected in monitoring
locations SW-1 and SW-2. 1,4-Dioxane concentrations from 2018 to 2020 at both locations were lower than 1
|ig/L and consistent with historical detections. 1,4-Dioxane was not detected in the samples collected from SW-1
and SW-4 in fall 2021 or fall 2022.

No cleanup levels have been established for 1,4-dioxane in surface water. Results pertaining to PFAS are
discussed below.

As reported in the 2018 FYR Report, EPA determined that the low-level 1,4-dioxane concentrations observed in
the intermittent streams are not known to pose potential risk to human health or the environment but do allow for
an understanding of the fate and transport pathways for contaminants in groundwater and further support the
finding that the hydrology at the Site minimizes groundwater contaminant migration beyond the site boundary.

Drinking Water Monitoring

The current sampling program included the collection of samples from nine residential wells during the annual
November sampling event. A ninth well (DW-9) was added to the sampling program because it was discovered
that an additional drinking water well had been recently installed on one of the monitored properties, where DW-1
is also located. However, only seven of the residential wells were sampled in 2022 due to access limitations at two
of the properties. Drinking water samples were not collected at DW-2 and DW-6. At both locations, Weston
Solutions was unsuccessful in attempts to contact the resident(s), which included contact by phone prior to the
sampling event and by knocking on doors several times during the sampling event. At DW-2, the house appears to
be abandoned. At DW-6, nobody was at the residence, and there were no working outside spigots from which a
sample could be collected. Samples are analyzed for 1,4-dioxane, VOCs and PFAS. The PFAS results are
discussed in the next section.

Table F-l in Appendix F provides a summary of sample results. 1,4-Dioxane was not detected at or above
laboratory reporting limits (lower than 0.2 |ig/L) in any of the samples during this FYR period. Other COCs have
also not been detected above the laboratory reporting limits (0.5 |ig/L).

Methyl tert-butyl ether (MtBE) was detected at a concentration of 1.6 |ig/L (2021) and 2.6 |ig/L (2022) in the
sample collected from DW-1, an order of magnitude below its AGQS of 13 |ig/L. This observation is consistent
with historical concentrations of MtBE detected in prior sampling rounds at this location. Carbon disulfide was
detected for the first time in the sample from DW-1 that was collected in November 2021. It was detected at a
concentration of 1.2 |ig/L. more than an order of magnitude lower than its AGQS of 70 |ig/L. Carbon disulfide
was also detected in November 2022 at 0.56 |ig/L at DW-8. Toluene was detected in the sample from DW-9 that
was collected in December 2022, at a concentration of 8.0 (ig/L, significantly below its AGQS of 1,000 (ig/L.
MtBE, carbon disulfide and toluene are not COCs at the Site but will continue to be monitored.

PFAS

The presence of PFAS in groundwater was confirmed in fall 2017. PFAS were detected in source area
groundwater above EPA Regional Screening Levels (RSL) and NHDES AGQS. Since 2017, Weston Solutions
has monitored PFAS in groundwater and surface water. Since 2019, Weston Solutions has monitored PFAS
compounds in residential drinking water.

PFAS are emerging contaminants for which NHDES established AGQS for four compounds: 12 nanograms per
liter (ng/L) for PFOA, 11 ng/L for perfluorononanoic acid (PFNA), 18 ng/L for perfluorohexane sulfonate
(PFHxS) and 15 ng/L for perfluorooctane sulfonate (PFOS). Consistent with standard practices for screening to
identify COCs during an RI at a Superfund site, EPA developed screening levels for groundwater using EPA's
RSL for a residential child. These RSLs were updated by EPA in May 2022 and May 2023. They are now 6 ng/L
for PFOA, 4 ng/L for PFOS, 5.9 ng/L for PFNA, 39 ng/L for PFHxS, 600 ng/L for perfluorobutane sulfonic acid
(PFBS), 1,800 ng/L for perfluorobutanoic acid (PFBA), 990 ng/L for perfluorohexanoic acid (PFHxA) and 6 ng/L
for hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as "GenX") for a residential child. EPA
has not established MCLs for any PFAS. Table F-2 in Appendix F provides the PFAS sampling results.

20


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Groundwater

Groundwater wells were sampled for PFAS annually from 2017 through 2020. Groundwater locations were not
sampled for PFAS in 2021 but were sampled again in 2022. Analytical results through November 2020 indicate
that only PFOA and/or PFOS were detected at concentrations exceeding their respective AGQS and EPA RSLs
(Figure F-9 in Appendix F). The AGQS were exceeded at monitoring locations CDM-1A, CW-3A, EMW-1, EW-
97-1, EW-97-2, MW-A, MW-Q2, MW-51, MW-55A and MW-58. EPA RSLs were exceeded at these locations as
well as at CDM-7 and CDM-12A. PFOA is the more prevalent compound and exceedances were generally
located in the overburden. The highest PFAS concentrations have continued to be found in MW-58, where PFOA
concentrations between 2018 and 2022 were 404 ng/L, which exceeds the state AGQS of 12 ng/L and the EPA
RSL of 6 ng/L.

In spring 2022, two overburden groundwater monitoring locations (MW-51 and MW-55A) were sampled for
PFAS analysis. Both PFOA and PFOS were detected at concentrations at or above their regulatory limits in MW-
51. During the fall 2022 sampling event, 35 monitoring wells were sampled for PFAS. Regulated compounds
PFOA, PFOS, PFNA and PFHxS were detected in the samples collected from CW-3A and MW-51. The
compounds PFOA, PFOS, and PFHxS (MW-51 only) were detected at concentrations exceeding their respective
AGQS. The compounds PFOA and PFOS were detected above their respective EPA RSL and AGQS and PFHxS
was detected at concentrations above the AGQS at the following monitoring locations:

•	CDM-1A (PFOA)

•	CDM-9 (PFOA)

•	CW-2A (PFOA and PFOS)

•	CW-2C (PFOA)

•	CW-3A (PFOA and PFOS)

•	CW-3B (PFOA)

•	EMW-1 (PFOA)

•	EMW-2 (PFOA and PFOS)

•	EW-95-2 (PFOA)

•	EW-97-1 (PFOA and PFOS)

•	KES-2D (PFOA and PFOS)

•	KES-4B (PFOA and PFOS)

•	MW-Q1 (PFOA and PFOS)

•	MW-Q2 (PFOA and PFOS)

•	MW-X (PFOA)

•	MW-51 (PFOA, PFOS, and PFHxS [AGQS only])

•	MW-58 (PFOA)

No PFAS were detected in the samples collected from CDM-13, CW-4A, CW-4C, CW-6C, MW-50 and MW-
55C.

The extent of the PFOA plume as of 2022 is shown in Figure F-l 1 in Appendix F.

In November 2022, the sample from MW-51 had one of the highest concentrations of PFOS (70.1 ng/L) and the
only concentration of PFHxS exceeding its AGQS at the Site (27 ng/L). In addition, the total PFAS concentration
detected in MW-51 is higher than any other well at the Site, and the concentrations of PFOA and PFOS detected
in the site wells immediately upgradient in the direction of the Site (e.g., CW-6A, KES-4B and CDM-1A) are all
lower. A review of available PFAS sampling data from the adjacent ReSource Waste Services property, located to
the north and east of the Site (Figure F-12 in Appendix F) indicate that total PFAS are also generally higher in
samples collected from within the ReSource Waste Services property, with concentrations an order of magnitude
higher (and greater than 1,000 ng/L) in some instances. NHDES is investigating whether PFAS contamination
from the ReSource Waste Services Property may be migrating into the northern portion of the Site.

21


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Drinking Water

Concurrent with groundwater sampling in spring and fall 2021, samples were collected from one and six private
drinking water supplies (respectively) for analysis of PFAS. Of these, only PFOS was detected in the sample
collected from DW-2 at concentrations of 10.2 ng/L and 10.9 ng/L (spring and fall 2021, respectively), which is
below the AGQS of 15 ng/L but above the EPA RSL of 4 ng/L. As last confirmed in spring 2023, this residence
remains unoccupied. NHDES and its contractor check for occupancy prior to sampling events and will continue to
monitor the residence. No PFAS compounds were detected in DW-1, DW-3, DW-4, DW-5 or DW-7 (Figure F-10
in Appendix F).

Drinking water supply wells DW-1, DW-3, DW-4, DW-5, DW-7, DW-8 and DW-9 were sampled for PFAS in
fall 2022. Consistent with previous results, PFAS compounds were not detected in any residential drinking water
supply well sampled. Historically, PFAS have been detected in well DW-2, which was unavailable for sampling
in 2022.

Surface Water

Supplemental surface water sampling for PFAS in April 2020 included collection of samples from 12 locations
along tributaries to the Fresh River and Piscassic River. Both PFOA and PFOS were detected in all surface water
sampling locations (except for the sample collected for SW-9, in which only PFOS was detected) and generally
make up the majority of PFAS measured and detected. The highest concentrations are detected in the northern
part of the Site at SW-2, SW-10 and SW-11. The highest PFOA concentration in 2020 was 16.5 ng/L at SW-2.
The highest PFOS concentration in 2020 was 26.8 ng/L at SW-2. Surface water quality criteria for PFAS
compounds have not yet been established. Ecological screening values (ESVs) have been developed to support
screening-level ecological risk assessments where PFAS have been detected in soils and surface waters. This FYR
Report compared the maximum detected results to the Region 1 ESVs and determined there to be no exceedances
(see Question B below for more information).

Site Inspection

The site inspection was conducted on 5/8/2023. In attendance were Michael Summerlin with NHDES, Michael
Kanarek from Weston Solutions, and Johnny Zimmerman-Ward and Ali Cattani from EPA FYR support
contractor Skeo. The purpose of the inspection was to assess the protectiveness of the remedy. Appendix G
includes the completed site inspection checklist. Appendix H includes photographs from the site inspection.

The Site's former Keefe property is fenced, and all access gates were locked. Site inspection participants met at
the former treatment plant building, which is now used by the Town for equipment storage. Participants
proceeded to tour the Site, observing the monitoring wells and surface water sampling locations. Monitoring wells
were newly painted, and all locations were secured. Several trees were down, and some of the trees were resting
on the fence. NHDES and Weston Solutions indicated they will notify the Town. The fence is not part of the
remedy. However, the Town and NHDES do not have plans to remove the fence. No trespassing has been noted at
the Site and no issues were observed that would affect the protectiveness of the remedy.

V. TECHNICAL ASSESSMENT

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

Question A Summary:

Yes. The remedies continue to be protective of human health and the environment. More details are provided
below.

Remedial Action Performance

The OU1 remedy was completed in 1983, with the removal of the 700,000-gallon lagoon. No further remedial
action was required for OU1.

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The 0U2 remedy consisted of source control and MOM components. The source control component, vacuum
extraction, was removed by the 1990 ESD because soil concentrations were already below standards. Later soil
sampling confirmed only a small volume of these soils still contained semi-volatile organic compounds at levels
of potential concern related to future contact and ingestion and, as such, these soils were excavated and disposed
of in an off-site landfill. In 2017, more soil samples were collected within the central source area as part of the
2017 FFS. Based on the soil results, which were below risk-based screening levels, EPA determined that potential
exposure to site soils via future residential or recreational use, including the regrading of site soils for those uses,
would not result in an unacceptable risk.

The MOM component included extraction and on-site treatment of groundwater to remove site-related VOCs. In
1993, the groundwater extraction, treatment and re-infiltration system was completed and began operating. The
groundwater extraction and treatment system operated continuously from 1993 through December 2011,
extracting and treating over 149 million gallons of groundwater. The pump-and-treat system performed as
expected, significantly reducing the mass, concentration and extent of the plume. It operated for 18 years,
including rebound periods. The groundwater treatment system ceased operations in December 2011, after it was
deemed to no longer be needed to contain the contaminants within the plume or to be cost effective, given the
reduced mass loading. The 2017 AROD selected MNA for the amended groundwater remedy. The remedy
includes long-term groundwater performance monitoring to determine progress and efficacy of MNA.
Groundwater, surface water and residential drinking water monitoring are ongoing.

Data collected during this FYR period indicate that 1,4-dioxane source area concentrations may continue to be
reaching equilibration to non-pumping conditions. Data collected to date provide further evidence of plume
stabilization and that, in general, the downgradient portions of the groundwater plume appear to be stable or
decreasing as natural attenuation processes continue to degrade the plume.

Monitoring of nearby residential water supply wells continues. Consistent with historical results, 1,4-dioxane and
other VOCs of concern have not been detected above laboratory reporting limits.

The presence of PFAS in groundwater was confirmed in fall 2017. PFAS were detected in source area
groundwater above EPA screening levels and NHDES AGQS. Since 2017, Weston Solutions has monitored
PFAS in groundwater and surface water. Since 2019, Weston Solutions has monitored PFAS compounds in
residential drinking water. PFAS compounds PFOA, PFOS and PFHxS were detected above state AGQS and
EPA RSLs in site groundwater. NHDES is evaluating potential off-site sources of PFAS. Drinking water supply
wells DW-1, DW-3, DW-4, DW-5, DW-7, DW-8 and DW-9 were sampled for PFAS in fall 2022. Consistent with
previous results, no PFAS compounds were detected in any residential drinking water supply well sampled in
2022. The only exception to this is PFOS has been detected in well DW-2 historically, which was unavailable for
sampling in 2022. As last confirmed in spring 2023, this residence remains unoccupied. NHDES and its
contractor check for occupancy prior to sampling events and will continue to monitor the residence.

Implementation of Institutional Controls and Other Measures

The 1988 ROD, as modified in 2017, required the establishment and/or maintenance of institutional controls (such
as a groundwater management zone or a local ordinance) to eliminate the potential drinking water exposure
pathway. The GMZ establishes a zone within which elevated concentrations of contaminants can remain above
drinking water standards until cleanup levels are attained. A GMP was issued for the Site in 2006, revised in 2013
and 2017, and renewed on February 24, 2018. The current GMP expired on February 23, 2023. However, NHDES
will continue to perform the monitoring requirements required under the GMP. Institutional controls, in the form
of deed notices for the properties in the GMZ, will need to be reviewed and updated to provide information or
notification of groundwater contamination at the Site and the ongoing monitoring of the groundwater until site
groundwater cleanup levels are attained. However, this will not affect the short-term protectiveness of the remedy
as monitoring and management of the use of groundwater continues to be addressed by NHDES.

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QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of
the remedy selection still valid?

Question B Summary:

No. There have been changes in toxicity values, exposure factor assumptions and cleanup levels since the 1988
ROD and 2017 AROD, as discussed below. Since remedy selection, emerging contaminant PFAS have been
detected in groundwater at levels above EPA's RSLs and state AGQSs. The changes described do not impact the
protectiveness of the remedy because groundwater at the Site is not currently in use, and the monitoring
requirements, which had been performed under all of the former GMPs, continue to be conducted by NHDES.
Residential wells are sampled for PFAS. With the exception of PFOS, no PFAS compounds were detected in
drinking water samples. PFOS was detected most recently at concentrations of 10.2 ng/L and 10.9 ng/L (spring
and fall 2021, respectively), which is below the NH AGQS of 15 ng/L but above the EPA RSL of 4 ng/L. As last
confirmed in spring 2023, this residence remains unoccupied.

Changes in Standards and To Be Considered Criteria (TBCs)

New standards (federal or state statutes and/or regulations), as well as new TBC guidances, should be considered
during the FYR process as part of the protectiveness determination. Under the NCP, if a new federal or state
statute and/or regulation is promulgated or a new TBC guidance is issued after the ROD is signed, and, as part of
the FYR process it is determined that the standard needs to be attained or new guidance procedures followed to
ensure that the remedy is protective of human health and the environment, then the FYR should recommend that a
future decision document be issued that adds the new standard as an ARAR or guidance as a TBC to the remedy.

EPA guidance states:

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

In the 2017 AROD, groundwater cleanup levels were based on ARARs (e.g., MCLs and more stringent NHDES
AGQS), as available. In addition to the cleanup levels established in the 1988 ROD for TCE, PCE, benzene, 1,2
DCA and 1,1-DCE and the cleanup level for 1,4-dioxane included by the 2005 ESD, additional cleanup levels
were included in the 2017 AROD for 1,1-DCA and vinyl chloride.

There have been no changes to MCLs for the groundwater COCs listed since the 2017 AROD (Table 1-1 in
Appendix I). However, a newly promulgated decrease of the state AGQS for 1,4-dioxane (0.32 |ig/L) became
effective on September 1, 2018. The current site groundwater cleanup level of 3.0 |ig/L for 1,4-dioxane equates to
a carcinogenic risk of 6.5 x 10"6, which is still within EPA's acceptable risk range. Thus, the existing cleanup goal
remains protective, and the remedy does not need to be modified to the new AGQS of 0.32 ug/L for 1,4-dioxane
at this time.

The 1988 ROD established soil cleanup levels based on the protection of groundwater. This FYR conducted a
screening level risk review of these soil cleanup levels (Appendix I, Table 1-2). Under a residential use scenario,
several of the soil cleanup levels are outside EPA's acceptable cancer risk management range and exceed the
noncancer hazard quotient of 1. As part of the 2017 FFS, EPA conducted a screening and risk evaluation of all

24


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available soil data for potential residential and/or recreation use of the Site. The results are included in the 2017
FFS, Appendix B. Upon a screening of the combined available soil data at the Site against the residential
RSLs (current as of May 2016), there were no exceedances of the RSLs. EPA determined in the FFS that
exposures to site soil via future residential or recreational scenario would not result in unacceptable risk, if any.

Per- and Polvfluoroalkvl Substances (PFAS) (Federal)

In May 2022, EPA issued updated noncancer reference dose (RfD) values for several PFAS compounds which
result in the following RSLs at hazard quotient (HQ) target 0.1:

•	PFOA: 6 ng/L (equivalent to parts per trillion [ppt])

•	PFOS: 4 ng/L

•	PFNA: 6 ng/L

•	PFHxS: 40 ng/L

•	HFPO-DA (Gen-X): 6 ng/L

The RfD values for PFOA, PFOS, PFNA and PFHxS are based on Agency for Toxic Substances and Disease
Registry (ATSDR) minimal risk levels (MRLs) for ingestion exposure.

The RfD value for HFPO-DA (Gen-X) is based on a chronic oral RfD from EPA's Office of Water, which is
3 x 10"6.

In May 2021, EPA issued an updated noncancer RfD for PFBS. PFBS has a chronic oral RfD of 3 x 10~4. The
RSL for PFBS is 600 ng/L.

In December 2022, EPA released a new oral RfD of 1 x 10~3 milligrams per kilogram per day (mg/kg-day) for
PFBA based on a new Integrated Risk Information System (IRIS) value. Previously, no RfD was available for
PFBA. The RSL for PFBA is 1,800 ng/L.

In April 2023, EPA released a new oral RfD of 5 x 10^ mg/kg-day for PFHxA based on a new IRIS value.
Previously, no RFD was available for PFHxA. The RSL for PFHxA is 990 ng/L.

PFAS (State)

In July 2020, New Hampshire promulgated state MCLs for the following four PFAS, individually or combined,
into the state's Safe Drinking Water Act:

•	PFOA: 12 ppt

•	PFOS: 15 ppt

•	PFHxS: 18 ppt

•	PFNA: 11 ppt

Current state law requires that AGQS be the same value as any MCL established by NHDES, and also that they
be at least as stringent as health advisories set by EPA.

At this time, EPA has made no determination of whether these state standards will need to be added as an ARAR
for the Site. They should, however, be used as screening values for PFAS compounds, along with the RSLs. For
purposes of this FYR, EPA has evaluated the PFAS data collected against EPA's RSLs and the state's PFAS
MCLs.

The presence of PFAS in groundwater was confirmed in fall 2017. PFAS were detected in source area
groundwater in excess of EPA screening levels and NHDES AGQS. Since 2017, Weston Solutions has monitored

25


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PFAS in groundwater and surface water. Since 2019, Weston Solutions has monitored PFAS compounds in
residential drinking water.

Analytical results through November 2020 indicate that only PFOA and/or PFOS were detected at concentrations
exceeding their respective AGQS and EPA RSLs. The AGQS were exceeded at monitoring locations CDM-1A,
CW-3A, EMW-1, EW-97-1, EW-97-2, MW-A, MW-Q2, MW-51, MW-55A and MW-58. EPA RSLs were
exceeded at these locations as well as at CDM-7 and CDM-12A. PFOA is the more prevalent compound and the
current extent of the PFOA/PFOS plume at the Site is shown in Figure F-10 in Appendix F. Table 6 lists the
concentrations.

Table 6: PFOA and PFOS Exceedances of AGQS and/or EPA RSLs (ng/L





CDM-I A

<

'?

'•J

1

1

r-

i

2

w

<-i
1

r-

i

2

w

<

1


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PFAS (Summary)

The current extent of the PFOA/PFOS plume at the Site is shown in Figure F-10 in Appendix F. Groundwater at
the Site is not currently in use, and the monitoring requirements, which had been performed under all of the
former GMPs, continue to be conducted by NHDES. NHDES plans to sample more wells during the fall 2023
groundwater monitoring event to further refine the distribution of PFAS across the Site.

1,4-Dioxane (Federal)

Using 2013 updated IRIS toxicity information and the standard Superfund risk assessment approach, EPA's
carcinogenic risk range of 10"6 to 10"4 for 1,4-dioxane equates to a concentration range of 0.46 (ig/L to 46 (ig/L
(parts per billion [ppb]).

1,4-Dioxane (State)

In September 2018, NHDES modified its AGQS for 1,4-dioxane from 3.0 (ig/L (ppb) to 0.32 (ig/L (ppb). The
current groundwater cleanup level of 3.0 (ig/L (ppb) for 1,4-dioxane equates to a carcinogenic risk of 6.5 x 10~6,
which is still within EPA's acceptable 10~6 to 10~4 risk range. Thus, the existing cleanup goal remains protective,
and the remedy does not need to be modified to the new AGQS of 0.32 (ig/L (ppb) for 1,4-dioxane at this time.

1,4-Dioxane (Summary)

The highest concentrations of 1,4-dioxane are present in source area wells EMW-1, MW-A, MW-Q1 and MW-
58. The horizontal distribution of 1,4-dioxane is shown in Figure F-7 in Appendix F. Results for 1,4-dioxane
since 2015 suggested that source area concentrations may continue to be reaching equilibration to non-pumping
conditions. Data collected to date provide further evidence of plume stabilization and that, in general, the
downgradient portions of the groundwater plume appear to be stable or decreasing as natural attenuation
processes continue to degrade the plume. Groundwater at the Site is being monitored and not currently in use
and nearby residential water supply wells are being monitored.

Changes in Toxicity and Other Contaminant Characteristics

2022 cis-1,2-Dichloroethvlene (cis-l,2-DCE) Noncancer Toxicity Value

In October 2022, EPA released a noncancer reference concentration (RfC) of 4 x 10~2 milligrams per cubic meter
(mg/m3) for cis-1,2-DCE, based on a provisional peer reviewed toxicity value (PPRTV) screening value.
Previously, no RfC was available for cis-1,2-DCE.

The 1988 ROD and 2017 AROD did not establish a cleanup level for cis-1,2-DCE. Cis-1,2-DCE is detected in
groundwater but is below its state AGQS and EPA MCL (70 (ig/L). Therefore, the change in the noncancer
toxicity value does not affect the protectiveness of the remedy.

2022 PFBA Noncancer Toxicity Value

In December 2022, EPA released a new oral RfD of 1 x 10~3 mg/kg-day for PFBA based on a new IRIS value.
Previously, no RfD was available for PFBA.

PFBA has been sampled during PFAS groundwater monitoring events. Detections ranged from 2.0 ng/L to 58.0
ng/L, which are below EPA's RSL of 1,800 ng/L. There were no detections in residential wells. The
protectiveness of the remedy is not impacted because the detections are below the RSL.

2022 PFOA Noncancer Toxicity Value

In May 2022, EPA released an updated oral RfD of 3 x 10~6 mg/kg-day for PFOA, based on the ATSDR MRL.
The new value indicates that PFOA is more toxic from noncancer health effects and would result in an increased
noncancer risk.

The maximum detected concentration of PFOA between 2018 and 2022 was 404 ng/L in monitoring well MW-58
in 2022, which exceeds the PFOA RSL of 6 ng/L. Several other wells reported concentrations of PFOA above the
RSL. There were no detections in residential wells. The laboratory reporting limits are lower than 2 ng/L, which is
below the RSL. Groundwater use on and near the Site is monitored and managed by NHDES. There is no current

27


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use of groundwater at the Site and nearby residential water supply wells continue to be monitored. As such, there
is no change to the protectiveness of the remedy.

2022 PFOS Noncancer Toxicity Value

In May 2022, EPA released an updated oral RfD of 2 x 10~6 mg/kg-day for PFOS, based on the ATSDR MRL.
The new value indicates that PFOS is more toxic from noncancer health effects and would result in an increased
noncancer risk.

The maximum detected concentration of PFOS between 2018 and 2022 was 93.2 ng/L in monitoring well CW-2A
in 2022, which exceeds the PFOS RSL of 4 ng/L. Several other wells reported concentrations of PFOS above the
RSL. Residential well results were all below detection (maximum reporting limit of 4 ng/L), except the results at
DW-2. PFOS concentrations at DW-2 ranged from 6.2 ng/L to 10.9 ng/L. This residence is not occupied. NHDES
and its contractor check for occupancy prior to sampling events and will continue to monitor the residence.
Groundwater use on and near the Site is monitored and managed by NHDES.

2022	PFNA Noncancer Toxicity Value

In May 2022, EPA released an oral RfD of 3 x 10~6 mg/kg-day for PFNA, based on the ATSDR MRL. Previously,
no RfD was available for PFNA.

PFNA has been detected at three wells during this FYR period (most recent concentrations were 2.19 ng/L at CW-
3A, 1.88 ng/Lat MW-51 and 2.6 ng/L at MW-55A) below the RSL of 6 ng/L. Residential well results were all
below detection (maximum reporting limit of 4 ng/L). Groundwater use on and near the Site is monitored and
managed by NHDES. Detections of PFNA do not impact protectiveness because groundwater where PFNA is
detected is not in use.

2023	PFHxA non-cancer toxicity value

In April 2023, EPA released a new oral RfD of 5 x 10^ mg/kg-day for PFHxA based on a new IRIS value.
Previously, no RfD was available for PFHxA.

The maximum detected concentration of PFHxA between 2018 and 2022 was 147 ng/L in monitoring well MW-
51 in 2022, lower than than the PFHxA RSL of 990 ng/L. Residential well results were all below detection
(maximum reporting limit lower than 2 ng/L). NHDES monitors and manages groundwater use on and near the
Site. There is no impact on protectiveness because groundwater is not in use where PFHxA was detected, and
results for residential wells are all below detection.

2022 PFHxS Noncancer Toxicity Value

In May 2022, EPA released an oral RfD of 2 x 10~5 mg/kg-day for PFHxS, based on the ATSDR MRL.

Previously, no RfD was available for PFHxS.

The maximum detected concentration of PFHxS between 2018 and 2022 was 27.0 ng/L in monitoring well MW-
51 in 2022, lower than the PFHxS RSL of 40 ng/L. Residential well results were all below detection (reporting
limit lower than 2 ng/L). Groundwater use on and near the Site is monitored and managed by NHDES. There is
no impact on protectiveness because no one is using the groundwater where PFHxS was detected, and results for
residential wells are all below detection.

2022 HFPO-DA (Gen-X) Noncancer Toxicity Value

In May 2022, EPA released an oral RfD of 3 x 10~6 mg/kg-day for HFPO-DA, also known as Gen-X, based on an
oral RfD available from EPA's Office of Water. Previously, no RfD was available for HFPO-DA.

HFPO-DA has not been detected in groundwater or residential wells. Therefore, there is no impact on the
protectiveness of the remedy. The maximum reporting limit was 48.2 ng/L. Groundwater use on and near the Site
is monitored and managed by NHDES.

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2021 PFBS Noncancer Toxicity Value

In May 2021, EPA released an oral RfD of 3xl0~4 mg/kg-day, based on an EPA PPRTV (USEPA, 2021a). The
new value indicates that PFBS is more toxic from noncancer health effects and would result in an increased
noncancer risk.

The maximum detected concentration of PFBS between 2018 and 2022 was 48.3 ng/L in monitoring well MW-51
in 2022, which is lower than the PFBS RSL of 600 ng/L. PFBS was not detected in residential wells (maximum
reporting limit of 4 ng/L, which is lower than the RSL). Groundwater use on and near the Site is monitored and
managed by NHDES. There is no impact on protectiveness because no one is using the groundwater where PFBS
was detected, and results for residential wells are all below detection.

2021 Ethyl Tertiary Butyl Ether (ETBE) Cancer and Noncancer Toxicity Values

In August 2021, EPA finalized a noncancer oral RfD and a noncancer inhalation RfC for ETBE based on new
IRIS toxicity values. Additionally, EPA finalized a value for inhalation unit risk (IUR), based on a new IRIS
cancer value. Previously, no toxicity values were available for ETBE.

ETBE is analyzed in residential wells but has never been detected. The reporting limit in 2022 was 0.50 (ig/L. The
current EPA RSL is 70 j^ig/L. There is no impact on the protectiveness of the remedy.

2021 tert-Butvl Alcohol (tBA) Cancer and Noncancer Toxicity Values

In August 2021, EPA finalized a noncancer oral RfD and a noncancer inhalation RfC for tBA based on new IRIS
toxicity values. Additionally, EPA finalized an oral slope factor for tBA based on a new IRIS cancer value.
Previously, no toxicity values were available for tBA.

Analysis of samples from residential wells did not detect tBA. Reporting limits in 2021 were 15 (ig/L. The EPA
RSL for tBA is 150 (ig/L. There is no impact on the protectiveness of the remedy.

2020 Trans-1,2-Dichloroethylene Noncancer Toxicity Value

In November 2020, EPA finalized a new RfC for trans-1,2-dichloroethylene based on a new PPRTV. There
previously was no RfC fortrans-l,2-dichloroethylene.

Trans-1,2-dichloroethylene is analyzed for but has not been detected on site. Therefore, there is no impact on the
protectiveness of the remedy.

Lead in Soil Cleanups

EPA continues to examine the science around lead exposure. Updated scientific information indicates that adverse
health effects are associated with blood lead levels (BLLs) at lower than 10 micrograms per deciliter (j^ig/dL).
Several studies have observed "clear evidence of cognitive function decrements in young children with mean or
group BLLs between 2 and 8 |ig/dL."

Based on this updated scientific information, EPA is including an evaluation of potential lead risks with a goal to
limit exposure to residential and commercial soil lead levels such that a typical (or hypothetical) child or group of
similarly exposed children would have an estimated risk of no more than 5% of the population exceeding a 5
(ig/dL BLL. This is based on evidence indicating cognitive impacts at BLLs below 10 (ig/dL. A target BLL of 5
(ig/dL reflects current scientific literature on lead toxicology and epidemiology that provides evidence that the
adverse health effects of lead exposure do not have a threshold.

EPA's 2017 Office of Land and Emergency Management (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 (ALM). These updates are
based on the analysis of the National Health and Nutrition Examination Survey 2009-2014 data, with
recommended updated values for baseline blood lead concentration being 0.6 (ig/dL and geometric standard
deviation being 1.8.

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Using updated default Integrated Exposure Uptake Biokinetic Model and ALM parameters at a target BLL of 5
(ig/dL, site-specific lead soil screening levels of 200 parts per million (ppm) and 1,000 ppm are developed for
residential and commercial/industrial exposures, respectively.

Lead was assessed in site soils as part of the 2005 HHRA. The range of concentrations of lead found in soil
samples collected within the top 10 feet of the ground surface was 3.3 ppm to 16.2 ppm, which is below both the
residential and commercial screening levels. Based on these sampling results, there is no unacceptable risk to
human health from exposure to lead in site soils expected from future use of the site property and there is no
impact on the protectiveness of the remedy.

Changes in Risk Assessment Methods

There have been no changes to risk assessment methods since the previous FYR.

Changes in Exposure Pathways

There have been no changes in exposure pathways since the previous FYR. Current exposure to groundwater is
not considered a complete exposure pathway, as groundwater within the GMZ is not in use and groundwater in
use by residents, outside the GMZ, is monitored by NHDES. Therefore, only a hypothetical future groundwater
exposure pathway could occur if groundwater is used as drinking water in the future.

There have been no changes in land use or conditions since the previous FYR but the currently anticipated future
use of the Site's former Keefe property, owned by the Town of Epping, New Hampshire, is unknown. Any
development will likely involve regrading of the soils on the property. A screening and risk evaluation of all
available soil data was performed for potential residential and/or recreational use of the Site as part of the 2017
FFS. This screening and risk evaluation was performed by an EPA Region 1 risk assessor using combined soil
data presented in the 1987 Supplemental Remedial Investigation Report by Camp Dresser & McKee, Inc., the
2005 Baseline Human Health Risk Assessment by Woodard & Curran, and recent data collected from source area
soils and analyzed by the EPA Region 1 laboratory. Because risks from site soils had been assessed previously,
this risk evaluation was performed as a conservative risk evaluation of the maximum detected concentrations with
the risk ratio approach instead of a conventional, full-scale risk assessment. The results of that screening indicated
that exposures to site soils via future residential or recreational scenarios would not result in unacceptable risk and
would not change the conclusions of the HHRA.

Therefore, the risk estimates based on the original exposure assumptions are still protective of human health
because they are generally more conservative than the currently recommended exposure factors.

2021 Development ofESVs for PFAS

ESVs have been developed to support screening-level ecological risk assessments where PFAS have been
detected in soils and surface waters. The ESVs, developed for eight PFAS, represent PFAS concentrations in soil
and surface water at or below which chronically exposed biota are not expected to be adversely affected and
ecological risks or other impacts are unlikely.

The ESVs support the screening-level steps (steps 1 and 2 of eight steps) of EPA's Ecological Risk Assessment
Guidance for Superfund, and may be applied at sites undergoing investigation for the historical release or disposal
of PFAS, to identify whether PFAS levels pose potential unacceptable ecological risks. Sites that have
concentrations of PFAS that exceed ESVs may require further investigation in a baseline ecological risk
assessment, which in turn may support risk-management decisions and actions to reduce risks. These ESVs are
solely for use in conducting screening-level ecological risk assessments and are not recommended or intended for
use as default cleanup values.

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The ESVs were developed for the following media and receptors:

•	Soils for invertebrates.

•	Soils for plants.

•	Soils for avian and mammalian wildlife.

•	Surface water for freshwater and marine aquatic biota.

•	Surface water for aquatic-dependent avian and mammalian wildlife.

The ESVs can be found in Derivation of PFAS Ecological Screening Values (M. Grippo, J. Hayse, I.
Hlohowskyj, and K. Picel, Environmental Science Division, Argonne National Laboratory, September
2021). NHDES and its contractor Weston Solutions screened on-site surface water for PFAS compounds
in 2019 and 2020. This FYR Report compared the maximum detected results to the Region 1 ESVs (see
Table 6). While there are no designated ecological receptors for the Site, the evaluation which compared the
detected results in surface water to the Region 1 ESVs indicate no exceedances and therefore surface waters at the
Site would not be expected to pose an ecological risk.

Table 8: Surface Water PFAS Results, 2019 to 2020

I'l-'AS ( (impound

IP A Region 1 IISY

Miiximum Dckckd



liifi/l.)"

( onconli'iilion
(20 l'J-2020)1'
lug/l.)

PFBA

64,600

9.49 (SW-1)

PFHxA

28,800

12.6 (SW-2f

PFOA

307,000

26.2 (SW-2)

PFBS

400,000

3.45 (SW-2)

PFOS

22,600

35.0 (SW-11)

Notes:





All units are in ng/L.





a. Table 3-3, Freshwater Chronic Exposure ESVs for Aquatic Life, 2021

Derivation of PFAS Ecological Screening Values,
b. From Table 7 of the 2021 Annual Report.

c. Duplicate sample was collected at this location; the higher result from
the parent and the duplicate is shown.

Vapor Intrusion

2018 EPA Vapor Intrusion Screening Level (VISL) Calculator

In February 2018, EPA launched an online VISL calculator that 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. The User's Guide provides further details on how to use the VISL calculator:
https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator.

The 2005 HHRA evaluated the indoor air pathway and determined exposure to site-related COCs via inhalation of
indoor air was not a significant exposure pathway. This FYR evaluated potential vapor intrusion risk to the former
groundwater treatment facility, which the town is now using as a storage building located on site using EPA's
VISL calculator and recent groundwater data from shallow overburden well MW-Q1 (2021 data), which is within
150 feet of the building and has detected concentrations of VOCs (Figure 3). There are other shallow overburden
wells near the building like CW-3A and MW-Z. However, these wells have not been sampled during this FYR
period and historical concentrations were non-detect. MW-Q1 is a source area well and had the highest 1,4-
dioxane concentration in 2021 in the shallow overburden. Based on this conservative screening-level evaluation,
vapor intrusion is not a concern at the Site at this time because detected concentrations correspond to risks that
fall within EPA's risk management range of 1 x 10"6 to 1 x 10"4 and the corresponding noncancer HQ is below
EPA's point of departure of 1 (Appendix J). In addition, the vapor intrusion exposure pathway at the Site is

31


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incomplete as there are no occupied buildings on site. However, if site conditions or land use change, vapor
intrusion may need to be reevaluated.

Expected Progress Toward Meeting RAOs

The RAOs described in the 2017 AROD included new or modified RAOs and retained RAOs from the 1988 ROD
for groundwater. Soil RAOs have been met previously for the Site.

The 2017 AROD selected the use of MNA and continued monitoring and management of groundwater within a
GMZ. The remedy is being implemented in accordance with the ROD remedy, as modified, and therefore is
progressing as expected toward meeting RAOs. The 2017 AROD required monitoring to assure the efficacy of the
MNA remedy and to assess the long-term protectiveness and the attainment of cleanup levels in the predicted
timeframes. The identification of PFAS in site groundwater since the 2017 ROD continues to require
investigation. However, the finding of PFAS in groundwater is not expected to impact the remedy protectiveness
because the groundwater plume is stable, groundwater is monitored and managed, and residential wells are
sampled by NHDES. NHDES will continue to perform all required monitoring and management of the use of
groundwater.

QUESTION C: Has any other information come to light that could call into question the protectiveness of
the remedy?

Yes. Since the issuance of the ROD, as amended, the following has come to light; but, as summarized below is
not likely to affect the protectiveness of the remedy, once completed.

The expected impacts of climate change in New England pose increasing risks to contaminated sites. Increases in
air and water temperature, precipitation, flooding and periods of drought may result in altered fate and transport
pathways and exposure assumptions, impaired aquatic habitats, dispersal of contaminants, damage to remediation
related structures and, ultimately, ineffective remedies. At coastal sites, saltwater impacts made more likely by
sea-level rise may cause corrosion of remediation equipment and impair restoration efforts. Increased frequency
of extreme weather events may cause damage or releases at sites, impairing remedial efforts where remedies have
not been adequately designed to protect against these risks.

The risks posed by climate change in New England are not expected to alter the protectiveness of the remedy at
the Site because there are no ongoing operations which could be impacted by power outages and the elevation of
the Site indicates it is at low risk for flooding.

32


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VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

()l (s) without Issues and Recommendations Identified in the l-'Yk:

OU1

Issues and Recommendations Identified in the l-'Yk:

OU(s): 2

Issue Category: Institutional Controls

Issue: The most recent GMP issued was in February 2018, and expired on February 23,
2023. NHDES did not renew the permit with the Town of Epping. Nonetheless, the
monitoring requirements, which had been performed under the GMPs, will continue to be
conducted by NHDES.

Recommendation: Institutional controls, in the form of deed notices for the properties
in the GMZ, will need to be reviewed and updated to provide information or notification
of groundwater contamination at the Site and the ongoing monitoring of the groundwater
until site groundwater cleanup levels are attained.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA/State

9/10/2025

OU(s): 2

Issue Category: Changed Site Conditions

Issue: PFAS compounds PFOA, PFOS and PFHxS were detected above state AGQS and
EPA RSLs in site groundwater. NHDES is evaluating potential off-site sources of PFAS.

Recommendation: Determine whether PFAS should be a site COC based on the
concentrations found in groundwater and assess potential impact from the migration of
PFAS from an off-site source and whether additional action is needed to address PFAS in
groundwater.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA/State

9/10/2026

Other Finding

In addition, the following recommendation was identified during the FYR and may improve performance
monitoring of the remedy, but does not affect current and/or future protectiveness:

• PFOS was previously detected in the sample collected from residential well DW-2 at 10.2 and 10.9
ng/L in 2021. However, the property is now abandoned. While the water supply well is not in use,
annual monitoring of this well should continue to assess PFAS concentrations.

33


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VII. PROTECTIVENESS STATEMENT

Protectiveness Statement(s)

Operable Unit:	Protectiveness Determination:

1	Protective

Protectiveness Statement:

The remedy at OU1 has met soil cleanup goals, is complete and therefore is protective of human health and the
environment.

Protectiveness Statement(s)

Operable Unit:	Protectiveness Determination:

2	Short-term Protective

Protectiveness Statement:

The remedy at OU2 is currently protective of human health and the environment in the short term because the
soil component of the remedy has been successfully completed and the modified groundwater remedy, MNA, is
being implemented as required. NHDES is conducting institutional control required monitoring, which is
currently effective in managing exposure to contaminated groundwater at the Site. For the remedy to be
protective over the long term, the following actions need to be taken:

•	Review and update institutional controls, in the form of deed notices for the properties in the GMZ, to
provide information or notification of groundwater contamination at the Site and the ongoing
monitoring of the groundwater until site groundwater cleanup levels are attained.

•	Determine whether PFAS should be a site COC based on the concentrations found in groundwater and
assess the potential impact of the migration of PFAS from an off-site source and whether additional
action is needed to address PFAS in groundwater.

Sitewide Protectiveness Statement

Protectiveness Determination:

Short-term Protective

Protectiveness Statement:

The remedy is protective in the short term. For the remedy to be protective over the long term, groundwater
cleanup levels, established in the 1988 ROD, the 2005 ESD and the 2017 AROD, need to be achieved,
institutional controls will need to be reviewed and updated, and further evaluation of whether PFAS in
groundwater poses a potential unacceptable risk to future users of groundwater is needed.

VIII. NEXT REVIEW

The next FYR for the Keefe Environmental Services Superfund site is required five years from the completion
date of this review.

34


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APPENDIX A - REFERENCE LIST

ATSDR. 2021. Toxicological Profile for Perfluoroalkyls. https://www.atsdr.cdc.gov/toxprofiles/tp20Q.pdf.

EPA. 1983. Superfund Record of Decision: Keefe Environmental Site, NH. EPA Office of Emergency and
Remedial Response, November 1983.

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

EPA. 1988. Record of Decision, Keefe Environmental Services Waste Site, Epping, New Hampshire. EPA
Region 1, March 1988.

EPA. 1990. Explanation of Significant Differences, Keefe Environmental Services Superfund Site, Epping, New
Hampshire. EPA Region 1, June 1990.

EPA. 2005. Declaration for the Explanation of Significant Differences, Keefe Environmental Services Site,
Epping, New Hampshire. EPA Region 1, June 2005.

EPA. 2014. Human Health Evaluation Manual, Supplemental Guidance: Update of Standard Default Exposure
Factors Memorandum. OSWER Directive 9200.1-120.

EPA. 2017. Amended Record of Decision, Keefe Environmental Services Superfund Site, Epping, New
Hampshire. EPA Region 1, September 2017.

EPA. 2017. Transmittal of Update to the Adult Lead Methodology's Default Baseline Blood Lead Concentration
and Geometric Standard Deviation Parameters Memorandum, May 17, 2017. OLEM Directive 9285.6-56.

EPA. 2018. Sixth Five-Year Review Report for Keefe Environmental Services Superfund Site, Epping, New
Hampshire. EPA Region 1, September 2018.

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

EPA. 2021. Provisional Peer-Reviewed Toxicity Values for Perfluorobutane Sulfonic Acid (PFBS) and Related
Compound Potassium Perfluorobutane Sulfonate. Office of Research and Development, Center for Public Health
and Environmental Assessment. EPA/690/R-21/001F. 2021.

EPA. 2021. Recommendations on the Use of Chronic or Subchronic Noncancer Values for Superfund Human
Health Risk Assessments Memorandum, May 26, 2021. Office of Land and Emergency Management,
Washington, D.C. 2021.

EPA. 2021. Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its
Ammonium Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as "Gen-X Chemicals." Office of
Water, Health and Ecological Criteria Division, Washington, D.C., October 2021.

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

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

EPA. Regional Screening Level Tables. Available at https://www.epa.gov/risk/regional-screening-levels-rsls-
generic-tables.

A-l


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M. Grippo, J. Hayse, I. Hlohowskyj, and K. Picel. 2021. Derivation of PFAS Ecological Screening Values,
Environmental Science Division, Argonne National Laboratory, September 2021.

Weston Solutions, Inc. 2020. 2019 Annual Monitoring Report, Long-term Environmental Monitoring Program,
Keefe Environmental Services Superfund Site. Weston Solutions, Inc., May 2020.

Weston Solutions, Inc. 2021. 2020 Annual Monitoring Report, Long-term Environmental Monitoring Program,
Keefe Environmental Services Superfund Site. Weston Solutions, Inc., June 2021.

Weston Solutions, Inc. 2021. Spring 2021 Data Submittal, Keefe Environmental Services Superfund Site. Weston
Solutions, Inc., June 2021.

Weston Solutions, Inc. 2022. 2021 Annual Monitoring Report, Long-term Environmental Monitoring Program,
Keefe Environmental Services Superfund Site. Weston Solutions, Inc., June 2022.

A-2


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APPENDIX B - SITE CHRONOLOGY

Table B-l: Site Chronology

l.\C'll(

Diilc

New Hampshire Bureau of Solid Waste Management and Department of Public Health
Services ordered Keefe to clean up leaking storage tanks, ruptured drums, contaminated soils
and latex wastes.

April 1, 1979

Keefe filed for bankruptcy protection and abandoned the Site. EPA initiated cleanup actions.

January 1981

EPA declared an emergency at the Site due to the overflow potential of the on-site lagoon.
EPA's Field Investigative Team Contractor began a site investigation and stabilization of the
on-site lagoon.

February 1981

EPA hired a contractor to remove imminent health hazards, storage tank contents and
dumpsters.

July 1982

The state, through a cooperative agreement with EPA, removed about 4,100 55-gallon drums,
four 5,000-gallon and four 10,000-gallon ASTs, and seven dumpsters from the Site.

March 1983

Resource Technology Services, Inc. completed drum and bulk waste removal.

August 1983

EPA listed the Site on the NPL.

September 8, 1983

EPA issued the OU1 ROD.

November 15, 1983

EPA completed the decommissioning of the lagoon.

February 1984

EPA completed the OU2 ROD.

March 21, 1988

EPA issued an ESD removing the 1988 ROD requirement for soil vapor extraction.

June 1990

EPA constructed the groundwater collection and treatment plant.

1993

EPA issued the Site's first FYR Report.

February 1993

Operations at the groundwater treatment plant commenced.

April 1993

EPA issued the Site's second FYR Report.

September 1997

EPA issued the Site's third FYR Report.

March 2003

EPA and NHDES initiated a phased groundwater sampling program to evaluate the nature
and extent of 1,4-dioxane in site groundwater.

May 2003

Contaminated soils in the former lagoon, originating from the 1992 construction of the
groundwater collection trench, were excavated and taken off site for disposal at an approved
regulated landfill.

August to
September 2004

EPA began operating the HiPOx system to facilitate destruction of 1,4-dioxane.

January 2005

EPA conducted a baseline HHRA.

May 2005

EPA issued an ESD to establish cleanup goal for 1,4-dioxane in groundwater and
to document the change in the treatment of groundwater from air stripping to the HiPOx
system, the off-site disposal of lagoon soils, and the decommissioning of select monitoring
wells that were in disrepair or no longer required for long-term monitoring.

June 2005

The Site transferred from an EPA-led long-term remedial action project to a state-led long-
term O&M project. A GMP application was submitted to NHDES.

June 2005

A GMP was granted as part of the site transition from EPA, under the long-term remedial
action program to NHDES.

January 2006

EPA issued the Site's fourth FYR Report.

July 2008

The groundwater extraction and treatment system was taken offline.

December 2011

NHDES approved a revised GMP.

February 2013

EPA issued the Site's fifth FYR Report.

September 2013

EPA conducted a technical MNA evaluation.

April 2014

NHDES issued a revised GMP.

January 2017

EPA published the Site's FFS and Proposed Plan.

June 2017

EPA signed the Site's AROD.

September 2017

NHDES completed the first round of PFAS sampling in site groundwater.

November 2017

A third GMP was issued requiring annual groundwater elevation monitoring and groundwater
and surface water sample collection and analysis.

February 2018

EPA issued the Site's sixth FYR Report.

September 2018

NHDES and its contractor sampled residential drinking water for PFAS compounds.

November 2020

NHDES and its contractor Weston Solutions oversaw the decommissioning of the
groundwater treatment plant.

May 2021

B-l


-------
Figure C-l: Conceptual Site Model

APPENDIX C - SITE MAPS3

	

NORTHWEST R^DW

RESOURCE WASTE
SERVICES

V

APPROXIMATE
LOCATION OF
HYDRAULIC
BARRIER

BEW-1.CW-3B
^k.C*-3A

,V — -"trench cwi-io i	Tn

' \ Z>TTj VV>

* * V .yS\.\ /

t

APPROXIMATE EjCTENT OF
PRESUMED SOURCE AREA

i
t

ESTIMATED EXTENT OF

DCCif>|jA| i d niOVAMF

U^A

NEW ENGLAND
DRAG//A Y

LEGEND
BEDROCK MONIIORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRESS

TAX MAP & LOT NUMBER

DISCHARGE INFILTRATION & COLLECTION

TRENCHES

ROAD OR DRIVEWAY

DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY

AND/OR INTERPRETED SITE WETLANDS

KES PROPERTY BOUNDARY

APPROXIMATE RESIDENTIAL PROPERTY

BOUNDARY

SITE BOUNDARY

STREAM

FENCELINE

FLOW DIRECTION

BUILDING

DEMOLISHED ON SITE BUILDING
GRAPHIC SCALE

APPROXIMATE KALE IN FEET

SOURCE:

FIGURE 2. SITE PLAN. BY WOODARD & CURRAN. DATED MAY
2014. TOWN OF EPPING TAX MAP NO. 38. TOWN OF BRENTWOOD
TAX MAP NO. 203. WESTON FIELD OBSERVATIONS. AND GPS
DATA COLLECTED IN DECEMBER. 2015.



i^^^Enviroi

Environmental
Services

2021 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPER FUND SITE
258 EXETER ROAD. EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PROJ. NO. 404

CONCEPTUAL SITE MODEL

DATE

JAN 2022
OATE
jAN 2022

DATE
JAN 2022

SCALE
AS SHOWN

W.O. NO.

20139.003.003

DCURE NO.

4

3 Source: The Site's 2017 AROD.

C-l


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Figure C-2: 1,4-Dioxane Distribution in Groundwater and Surface Water, November 2016

LEGEND
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL
POTABLE WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION
STREET ADDRESS
TAX MAP & LOT NUMBER
DISCHARGE INFILTRATION & COLLECTION
TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY
AND/OR INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY
APPROXIMATE RESIDENTIAL PROPERTY
BOUNDARY

EXPANDED GMZ BOUNDARY
STREAM
FEN CELINE
FLOW DIRECTION
BUILDING

DEMOLISHED ON SITE BUILDING
1,4 DIOXANE CONCENTRATION IN ug/L
NON-DETECT
NOT SAMPLED

1,4 DIOXANE CONTOUR LINE WITH VALUE
NnTre.	(DASHED WHERE INFERRED)

1)	IF A DUPLICATE SAMPLE WAS COLLECTED AT A LOCATION, THE HIGHER OF THE TWO
CONCENTRATIONS S POSTED.

2)	J - VALUE IS ESTIMATED DUE TO QUALITY CONTROL CRITERIA EXCEEDING
ACCEPTABLE RANGES.

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD & CUR RAN, DATED MAY 2014, TOWV OF EPPING
TAX MAP NO. 38, TOWN OF BRENTWOOD TAX MAP NO. 203, WESTON FIELD
OBSERVATIONS, AND GPS DATA COLLECTED IN DECEMBER, 2015.

FOCUSED FEASIBILITY STUDY
KEEFE ENVIRONMENTAL SERVICES SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE

1,4 DIOXANE DISTRIBUTION
IN GROUNDWATER AND SURFACE WATER
NOVEMBER 2016

W.O. NO.
20133.003.002

SCALE

AS SHOWN

C-2


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Figure C-3: VOCs Exceeding Cleanup Levels, 2016

ENVIRONMENTAL
RESOURCE RETURN
CORPORATION

MW-58

AGQS

4/16

11/16

12/16

1.1 DICHLOROETHENE

7

NS

NS

7

BENZENE

5

NS

NS

8

MW-59

AGQS

4/16

11/18

12/16

1.1 DICHLOROETHENE

7

NS

NS

36

1.2 DICHLOROETHANE

5

NS

NS

6

MW-A

AGQS

4/16

11/16

12/16



1,1 DICHLOROETHENE

7

NS

34

NS

—

MW-55A

AGQS

4/16

11/16

12/16

TCE

5

2U

9.8

NS

VmW-5SA
^MW-56C



. NEW ENGLAND
J DRAGWAY

LEGEND
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL
POTABLE WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION
STREET ADDRESS
TAX MAP & LOT NUMBER
DISCHARGE INFILTRATION & COLLECTION
TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY AND/OR
INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY
APPROXIMATE RESIDENTIAL PROPERTY
BOUNDARY

EXPANDED GMZ BOUNDARY
STREAM
FENCELINE
FLOW DIRECTION
BUILDING
DEMOLISHED ON SITE BUILDING
ESTIMATED EXTENT OF VOC EXCEEDANCES

0*15?- NOT	
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3/23/23, 12:45 PM

APPENDIX D - EPA NEWS RELEASE

EPA to Review Cleanups at Six New Hampshire Superfund Sites this Year | US EPA

An official website of the United States government

A frill United States
mMKmEnvironmental Protection	MENU

IbbI M rnAgency

SearchEPA.gov

News Releases; Region 01 

CONTACT US 

EPA to Review Cleanups at Six
New Hampshire Superfund
Sites this Year

January 18,2023

Contact Information

Jo Anne Kittrell (kittrell.joanne@epa.gov)

(817) 918-1822

BOSTON (Jan. 18,2023) - The U.S. Environmental Protection Agency (EPA) will
conduct comprehensive reviews of completed cleanup work at six National Priority List
(NPL) Superfund sites in New Hampshire this year.

The sites will undergo a legally required Five-Year Review to ensure that previous
remediation efforts at the sites continue to protect public health and the environment.

"Throughout the process of designing and constructing a cleanup at a hazardous waste
site, EPA's primary goal is to make sure the remedy will be protective of public health
and the environment, especially for communities that have been overburdened by
pollution," said EPA New England Regional Administrator David W. Cash. "It is
important for EPA to regularly check on these sites to ensure the remedy is working
properly and New Hampshire communities continue to be protected."

https://www.epa.gov/newsreleases/epa-review-cleanups-six-new-hampshire-superfund-sites-year	1/5

D-l


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3/23/23,12:45 PM	EPA to Review Cleanups at Six New Hampshire Superfund Sites this Year ( US EPA

The Superfund Sites where EPA will conduct Five-Year Reviews in 2023 are listed below
with web links that provide detailed information on site status as well as past
assessment and cleanup activity. Once the Five-Year Review is complete, its findings will
be posted to the website in a final report.

Five-Year Reviews of Superfund sites in New Hampshire to be completed in 2023:

Fletcher's Paint Works and Storage, Milford

Kearsarge Metallurgical Corp., Conway

Keefe Environmental Services, Epping

Mottolo Pig Farm, Raymond

South Municipal Water Supply Well, Peterborough

Tibbetts Road, Barrington

More information:

The Superfund program, a federal program established by Congress in 1980,
investigates and cleans up the most complex, uncontrolled, or abandoned hazardous
waste sites in the cou ntry and EPA endeavors to facilitate activities to return them to
productive use. In total, there are 123 Superfund sites across New England.

Superfund and other cleanup sites in New England 

EPA's Superfund program 

Contact Us  to ask a question, provide feedback,
or report a problem.

LAST UPDATED ON JANUARY 18,2023

https://www.epa.gov/newsreieases/epa-review-cleanups-six-new-hampshire-superfund-sites-year

D-2


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APPENDIX E - INTERVIEW FORMS

ki:i:i i: i:\mi«)\mi:.m ai. skryk i:ssi pkrit ndsiti:
m ye-year reyieny iyieryiew form

Site Name: kccl'c Linironmcnlal Sen ices

EPA ID: NHD092059112

Subject name: Michael Kanarek

Subject affiliation: Weston Solutions project
manager	

Subject contact information: 43 North Main Street, Concord, NH 03301; 603-656-5400

Interview date: 5/24/23

Interview time: 3:45 p.m.

Interview format (circle one): In Person

Phone

Mail

Email

Other:

Interview category: O&M

1.	What is your overall impression of the project, including cleanup, maintenance, and reuse activities (as
appropriate)? The project includes environmental monitoring activities and is proceeding in compliance
with state and federal guidelines. There are no current active cleanup, maintenance or reuse activities
at the Site, though the Town is considering options for reuse of the Site.

2.	What is your assessment of the current performance of the remedy in place at the Site? That the remedy is
adequately protecting human health and managing further impacts on the environment.

3.	What are the findings from the monitoring data? What are the key trends in contaminant levels that are being
documented overtime at the Site? Contaminant concentrations have fluctuated following the treatment
system shutdown in 2011, but they have remained within historical ranges and show decreasing
concentrations overall since 2008. And while the presence of PFAS has been confirmed at the Site, there
is insufficient data to establish concentration trends.

4.	Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.
Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there
is not a continuous on-site O&M presence. There is no continuous O&M presence. Weston previously
performed monthly site checks, but on June 29, 2021, site O&M responsibilities were returned to the
Town. Monitoring well inspections are completed semi-annually ahead of each monitoring round. Any
required monitoring well maintenance activities are conducted on an as-needed basis.

5.	Have there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the
remedy? Please describe changes and impacts. Site O&M requirements have changed, as noted in
response to question No. 4, with responsibility transferring to the Town. The sampling program was
modified in 2021, as noted in the response to question No. 7.

6.	Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so,
please provide details. In the transfer of the Site to the Town, the former treatment plant had to be
decommissioned, but those costs were anticipated.

7.	Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and
any resulting or desired cost savings or improved efficiencies. As part of the 2020 Annual Monitoring
Report, the groundwater monitoring program for the Site was evaluated using the Monitoring and
Remediation Optimization System (MAROS) software. Based on the MAROS analysis, VOC sampling
was reduced in frequency and scope and some wells were removed from the sampling rounds. The
monitoring program is also regularly reviewed in order to streamline efforts whenever possible.

E-l


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8.	Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the
Site? No.

9.	Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report? Yes.

E-2


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Figure F-l: Site Plan

APPENDIX F - DATA REVIEW TABLES AND FIGURES4

RESOURCE WASTE
SERVICES

DISCHARGE -
INFILTRATION
TRENCH

OW-9

VA'-.A

COLLECTION
TRENCH

CEMETERY

KES-2B

-STAFF
GAUGE
—CDM-11

38-021

DW-4|

EPPING

BRENTWOOD

• MW—202

W-50C * SW-IO

/' \ /

/ SW-2^ 5W.2B

MW-eOC-^-rou,

^ OrfW-3^V. *	J

i NEW ENGLAND
J DRAGWAY

LECEND
ReSOURCE WELL
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION
STREET ADDRESS
TAX MAP & LOT NUMBER
DESIGNATED AS SITE BOUNDARY WElL
SITE CROSS SECTION LOCATION

	 	 DISCHARGE INFILTRATION & COLLECTION

TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD

PATH

NATIONAL WETLANDS BOUNDARY

AND/OR INTERPRETED SITE WETLANDS

KES PROPERTY BOUNDARY

APPROXIMATE RESIDENTIAL

PROPERTY BOUNDARY

SITE BOUNDARY

STREAM

FEN CELINE

FLOW DIRECTION

BUILDING

DEMOLISHED ON SITE BUILDING
GRAPHIC SCALE

SOURCE:	APPROXIMATE SCALE If

FIGURE 2, SITE PLAN, 3Y WOODARD & CURRAN, DATED MAY
2014, TOWN OF EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD
TAX MAP NO. 203, WESTON FIELD OBSERVATIONS, AND GPS
DATA COLLECTED IN DECEM3ER, 2015.

Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD. EPPING. NEW HAMPSHIRE
NHDES SITE NO. 198710024/lPROJ. NO. 404

SITE PLAN

DATE

JAN 2023

DATE
JAN 2023

SCALE

S SHOWN

W.O. NO.

20139.003.004
FIGURE NO.

4 Source: The Site's 2022 Annual Monitoring Report.

F-l


-------
Figure F-2: Overburden Potentiometric Surface Map, April 2022

NEW ENGLAND
DP. AG WAY

\ ^

RESOURCE

WASTE
SERVICES

38-027

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD & CURRAN, DATED MAY
2014-, TOWN OF EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD
TAX MAP NO. 203, WESTON FIELD OBSERVATIONS, AND GPS
DATA COLLECTED IN DECEMBER, 2015.





-







Environmental

CONCORD

tH HAMPSHIRE



SPRING 2022 DATA SUBMITTAL
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 19B710024/PR0J. NO. 404

SHALLOW OVERBURDEN GROUNDWATER
POTENTIOMETRIC SURFACE MAP
APRIL 2022

DRAWN

55

DATE
JUN 2022

DCS. ENG.

DAT
JUK 2022

VI.0. NO.

jcj.oc:

CHECKED

DHB

DATE
JUN 2022

SO Al t
AS SHOWN

REVISION

"IGURE NO.

RESOURCE WAS ft
SERVICES

LEGEND
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRESS

TAX MAP & LOT NUMBER

DISCHARGE INFILTRATION & COLLECTION

TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY

AND/OR INTERPRETED SITE WETLANDS

KES PROPERTY BOUNDARY

APPROXIMATE RESIDENTIAL PROPERTY

BOUNDARY

SITE BOUNDARY

STREAM

FENCEUNE

FLOW DIRECTION

BUILDINC

DEMOLISHED ON SITE BUILDING
GROUNDWATER ELEVATION
GROUNDWATER CONTOUR
LINE WITH ELEVATION
{DASHED WHERE INFERRED)

INFERRED GROUNDWATER FLOW
DIRECTION

1. DEPTH-TO-WATER DATA ARE NOT SHOWN FOR
WELLS UNDER ARTESIAN COND TIONS.

GRAPHIC SCALE

200 100	0	100 200

~
4-

NOTE:

F-2


-------
Figure F-3: Overburden Potentiometric Surface Map, October 2022

LEGEND
RESOURCE WELL
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTiON WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRESS

TAX MAP & LOT NUMBER

DISCHARGE INFILTRATION & COLLECTION

TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD

NATIONAL WETLANDS BOUNDARY
AND/OR INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY
APPROXIMATE RESIDENT. PROPERTY
BOUNDARY
SITE BOUNDARY
STREAM
FEN CELiNE
FLOW DIRECTION
BUILDING

DEMOLISHED ON SITE BUILDING
GROUNDWATER ELEVATION
GROUNDWATER CONTOUR
UNE WITH ELEVATION
(DASHED WHERE INFERRED)

INFERRED GROUNDWATER FLOW
DIRECTION

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD & CURRAN, DATED MAY
2014, TOWN OF EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD
TAX MAP NO. 203. WESTON FIELD OBSERVATIONS, AND GPS
DATA COLLECTED IN DECEMBER, 2015.

Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PROJ. NO. 404

SHALLOW OVERBURDEN GROUNDWATER
POTENTIOMETRIC SURFACE MAP
OCTOBER 2022

DATE

W.D. MO.
70139.00.

F-3


-------
Figure F-4: Shallow Bedrock Potentiometric Surface Map, October 2022

RESOURCE WASTE
SERVICES

GRAPHIC SCALE

~
*
+
4-

i NEW ENGLAND
DRAGWAY

LEGEND
ReSOURCE WELL
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION
STREET ADDRESS
TAX MAP & LOT NUMBER
DISCHARGE INFILTRATION & COLLECTION
TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY
AND/OR INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY
APPROXIMATE RESIDENTIAL PROPERTY
BOUNDARY
SITE BOUNDARY
STREAM
FENCELINE
FLOW DIRECTION
BUILDING

DEMOLISHED ON SITE BUILDING
GROUNDWATER ELEVATION
GROUNDWATER CONTOUR
LINE WITH ELEVATION
(DASHFD WHFRE INFERRED)

INFERRED GROUNDWATER FLOW
DIRECTION
NOTE;

DEPTH-TO-WATER DATA ARE NC^ SHOWN FOR WELLS UNDER

ARTESIAN CONDITIONS.

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD Sc CURRAN, DATE") MAY
2014, TOWN OF EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD
TAX MAP NO. 203, WESTON FIELD OBSERVATIONS, AND GPS
DATA COLLECTED IN DECEMBER, 2015.

/f*

^^^^nviroi

Environmental
Services

RESOURCE

WASTE
SERVICES

\

nJ

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING. NEW HAMPSHIRE
NHDES SITE NO. 198710024/PROJ. NO. 404

SHALLOW BEDROCK GROUNDWATER
POTENTIOMETRIC SURFACE MAP
OCTOBER 2022

DA~E

JAN :

W.O. NO.
i 20159.003.004

DATE
JAN 2023

F-4


-------
Figure F-5: Deep Bedrock Potentiometric Surface Map, October 2022

GRAPHIC SCALE

123 -

LEGEND
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WElL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRESS

TAX MAP & LOT NUMBER

DISCHARGE INFILTRATION & COLLECTION

TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY

AND/OR INTERPRETED SITE WETLANDS

KES PROPERTY BOUNDARY

APPROXIMATE RESIDENTIAL PROPERTY

BOUNDARY

SITE BOUNDARY

STREAM

FENCEUNE

FLOW DIRECTION

BUILDING

DEMOLISHED ON SITE BUILDING
GROUNDWATER ELEVATION
GROUNDWATER CONTOUR
INE WITH ELEVATION
(DASHED WHERE INFERRED)

INFERRED GROUNDWATER FLOW DIRECTION

+EW-1

NEW ENGLAND
DP. AC WAY

NOTE:

DEPTH—TO-WATER DA~A ARE NO^

ARTESIAN CONDITIONS,

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD & CURRAN, DATED MAY
2014, TOWN OF EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD
TAX MAP NO. 203, WESTON FIELD OBSERVATIONS, AND GPS
DATA COLLECTED IN DECEMBER, 20^5.

RESOURCE

WASTE
SERVICES

\

Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PROJ. NO. 404

DEEP BEDROCK GROUNDWATER
POTENTIOMETRIC SURFACE MAP
OCTOBER 2022

SCALE
AS SHCW

F-5


-------
Figure F-6: VOCs Exceeding Cleanup Levels, November 2022

APPROXIMATE RESIDENTIAL PROPERTY
BOUNDARY

	 	 	 	 SITE BOUNDARY

IFGFND
ReSCURCE WELL
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WEL.
EX TRACTlON WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRE5S

TAX MAP & LOT NUMBER

DISCHARGE INFILTRATION & COLLECTION

TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY AMD/OR
INTERPRETED SITE WFTI ANDS

4"
*
4-

IZZ1

NOTES:

•) NS - NOT SAMPLED

2)	J - CONTAMINANT NOT DETECTED AT OR ABOVE THE LABORATORY
REPORTING LIMIT,

3)	ALL UNITS ARE IN MICROGRAMS PER UTER (ng/L)

4)	1.4—DiOXANE CONCENTRATIONS THAT EXCEED ACQS ARE PROVIDED ON
FIGURE 10.

5)	AGQS - AMBIENT GROUNDWATER QUAI.iTY STANDARD

6)	CLEANUP LEVELS (CI s) WERE UPDATED IN THE 2017 AMENDED
RECORD Or DECISION (ROD). AGQS IS SHOWN.

7)	ir A DUPLICATE SAMPLE WAS COLLECTED AT A LOCATION, THE HIGHER
OF "HE TWO CONCENTRATIONS IS POSTED.

FENCEUNE
FLOW DIRECTION
BUILDING

DEMOLISHED ON SITE BUILDING
ESTIMATED EXTENT OF VOC EXCEEDANCES
(EXCLUDES 1,4-DIOXANE)

SQUfiCE:

FIGLRE 2, SITE PLAN, BY WOQDARD & CURRAN, DATEC MAY 2D'4, TOWN OF
EPP'-NC TAX MAP NO. 38. TOW CF BRENTWOOD TAX MAP NO. 2C.1, WESTON
FIELD OBSERVATIONS. AMD GPS DATA COLLECED IM DECEMBER. 2015,

Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PROJ. NO. 404

CONCENTRATIONS OF VOCs IN
GROUNDWATER EXCEEDING CRITERIA
NOVEMBER 2022

SCALE
AS SHC

RESOURCE WASTE
SERVICES

NEW ENGLAND
DRAGWAY

EPPING
BRENTWOOD

I	

F-6


-------
Figure F-7: 1,4-Dioxane Distribution in Groundwater and Surface Water, November 2022

38-025

RESOURCE WASTE
SERVICES

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PR0J. NO. 404

1,4-DIOXANE DISTRIBUTION IN
GROUNDWATER AND SURFACE WATER
NOVEMBER 2022

DRAWN

55

DATE

JAN 2023

DES. ENG.

DAT!

JAN 2023

VI.0. MO.

CHECKED
KS

DATE

SO Al t
AS SHOWN

REVISION

"IGUPE NO.

10

38-019 ,		\

• L-	/

DW—9	/

9 MW-202

NGIES;

1)	IF A D^LCATE SAMPLE WAS COLLECTED AT A LOCATION,
THE HIGHER OF THE TWO CONCENTRATIONS IS FCSTED

2)	DATA REPORTED IN MICROGRAMS PER LITER (w/i).

LEGEND
ReSOURCE WELL

MONITORING LOCATION INCLUDED IN
2013 BAITED BIO-TRAP® STUDY
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRESS

TAX MAP & LOT NUMBER

DISCHARGE INFILTRATION & CCL ECTlON

TRENCHES

ROAD OR DRIVEWAY

DIRT/GRASS ROAD

PATH

NATIONAL WETLANDS BOUNDARY

AND/OR INTERPRETED SITE WETLANDS

KES PROPERTY BOUNDARY

APPROXIMATE RESIDENTIAL PROPERTY

BOUNDARY

SITE BOUNDARY

STREAM

FEN CELINE

flow direction

BUILDING

DEMOLISHED ON SITE BUILDING
1,4—DIOXANE CONCENTRATION
NON-DETECT
NOT SAMPLED

1,4—DIOXANE CONTOUR LINE WITH VALUE
(DASHED WHERE INFERRED)

4
*

^EMETE^Y

F-7


-------
Figure F-8: Trend Analysis by Geographic Area, 2004 to 2022

1 Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PRQJ. NO. 404

PATH

jt	jt NATIONAL WETLANDS BOUNDARY

- AND/OR INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY

		APPROXIMATE RESIDENTIAL PROPERTY

BOUNDARY

	 	 	 	 SITE BOUNDARv

	 STREAM

			o				 FENCE LINE

NOTES:

1)	HALF THE VALUE OF THE DETECTION LIMITS WERE USED FOR
ALL "NON-DETECT" RESULTS AS REPORTED BY THE LABORATORY

2)	TOTAL VOC DATA PRESENTED IN THE ABOVE TREND ANALVSIS
GRAPHS INCLUDES RESULTS FROM COMPOUNDS WHICH
CORRESPOND TO THE 1988 ROD CONTAMINANTS OF CONCERN, THE
2005 ESD FOR ',4-DIOXANE, AND ADDITIONAL COCs. THESE
INCLUDE: BENZENE, 1,2—DICHLOROETHANE, 1,1—DICHLOROETHENE,
TRICHLOROETHENE, AND TETRACHLOROETHENE (FROM 1988 ROD),
1,1 -DICHLOROETHANE, VINYL CHLORIDE, AND 1,4-DIOXANE.

AVERAGE CONTAMINANT CONCENTRATION
TREND ANALYSIS BY GEOGRAPHIC AREA
2004 TO 2022

DRAWN

SS

DATE

JAN

2023

DE5. ENG.

DATE

JAN 2023

W.O. NO,

20139.003.004

CHECKED
KS

DATE
JAN

2023

SCALE
AS SHOWN

REVISION

FIGURE NO.

14

DIRT/GRASS ROAD

LEGEND

•	ReSOURCE WELL

4"	BEDROCK MONITORING WELL

+	BEDROCK EXTRACTION WELL

+	DEEP OVERBURDEN MONITORING WELL

+	EXTRACTION WELL

+	SHALLOW OVERBURDEN MONITORING WELL

+	SHALLOW OVERBURDEN EXTRACTION WELL

•	RESIDENTIAL WELLS
®	MANHOLE

a	SURFACE WATER SAMPLE LOCATION

256	STREET ADDRESS

38-025	TAX MAP & LOT NUMBER

>- +	EXTRACTION SYSTEM PIPING

—-	FLOW DIRECTION

I I	BUILDING

|^H	DEMOLISHED ON SITE BUILDING
ROAD OR DRIVEWAY

F-8


-------
Figure F-9: PFOA and PFOS in Groundwater, 2022

1 Environmental
Services

LEGEND

•	ReSOURCE WELL

4- BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
4" DEEP OVERBURDEN MONITORING WELL
+ EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
4- SHALLOW OVERBURDEN EXTRACTION WELL

•	RESIDENTIAL WELLS
® MANHOLE

a SURFACE WATER SAMPLE LOCATION
256 STREET ADDRESS
¦025 TAX MAP 8c LOT NUMBER

		 DISCHARGE INFILTRATION &

COLLECTION TRENCHES
ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

jt * * NATIONAL WETLANDS 30UNDARY

- AND/OR INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY

	APPROXIMATE RESIDENTIAL

PROPERTY BOUNDARY

		SITE BOUNDARY

	 STREAM

—°			o	FENCELINE

— FLOW DIRECTION
BUILDING

DEMOLISHED ON SITE BUILDING



2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING. NEW HAMPSHIRE
NHDES SITE NO, 196710024/frRQJ. NO. 404

CURRENT GROUNDWATER SAMPLING
RESULTS FOR REGULATED PFAS

DRAWN

SS

DATE

JAN 2023

DE5. ENG.

DATE

JAN 2023

W.O. NO,

20139.003.004

CHECKED

MRK

DATE
JAN 2023

SCALE
AS SHOWN

REVISION

FIGURE NO.

12A

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD & CURRAN, DATED MAY 20U, TOWN OF
EPPING TAX WAP NO. 38. TOWN OF 9RENTW00D TAX MAP NO. 203, WESTON
FIELD OBSERVATONS, AND GPS DATA COLLECTED IN DECEMBER 2015.

Compound

NHDES
AGQS
(ngA)

EPA Health
Advisory

(ngA)

PFOA

12

6

PFOS

15

4

PFNA

11

5.9

PFHxS

IB

39

NOTES:

All data are reported in nanogrcms per liter

(ngA).

AGQS = Ambient Groundwater Quality Standards
per

Env-Or 600 Contaminated Site Management.

PFOA = Perfluoro-n-Octanoic Acid (CAS No.
335-67-1)

PFOS = Perfluorooctane Sulfonic Acid (CAS No.
1763-23-1)

PFNA = Per'luorononanoic Acid (CAS No.
375-95-1)

PFHxS = Perfluorohexanesulfonic Acid (CAS No.
355-46-4)

Regjlcted compounds not shown in the sample
results on this figure were not detected above
laboratory reporting limits.

U = Analyte not reported at or above the
applicable laboratory reporting limit,
ND = non-cetect

Interim Cleanup Levels have not been established
for PFAS.

~NOVEMBER 2017 PFOS concentrations on t.nis
figure have been converted from sulfonate to acid

RESOURCE ,
WASTE SERVICES,

F-9


-------
Figure F-10: PFOA and PFOS in Surface Water and Drinking Water

RESOURCE WASTE
SERVICES

CW-6A/
CW-6C

is.a/ie.p

38-016

DISCHARGE-
INFILTRATION
V TRENCH

OW—9

OM5-2 EMW-1^-1
	 BM7-1-	L

MW-QV

PFOS

Cbtrrtrm7r
TRENCH

CEMETERY

KES-29

-STAFF
GAUGf.

38-021

DW-4I

NOTES:

All dato are reported In nanograms per liter (ng/L),

AQQS — Ambient Groundwater Quality Standards per

Env—Or 600 Contaminated Site Management.

PFOA = Perfluoro—n—Octanoic Acid (CAS No. 335—67—1)

PFOS = Perfluorooctane Sulfonic Acid (CAS No. 1763—23—1}

PFNA = Perfluorononanoic Acid (CAS No. 375—95—1)

PFHxS = Perfluorohexanesulfonic Acid (CAS No. 355—46—4)

Regulated compounds not shown in the sample results on this

Tigure were not detected above laboratory reporting limits.

U = Analyte not reported at or above the applicable laboratory

reporting limit.

ND = non-detect

Interim Cleanup Levels have not been established for PFAS.

RESOURCE

WASTE
SERVICES

Surface water quality criteria have not been promulgated.

SOURCE:

FIGURE 2, SITE PLAN, BY WOODARD & CURRAN, DATED MAY 201^, TOWN OF
EPPING TAX WAP NO. 38, TOWN OF BRENTWOOD TAX MAP NO, 203. WESTON
FIELD OBSERVATIONS. AND GPS DATA COLLECTED IN DECEMBER 2015.

LEGEND

•	ReSOURCE WELL
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL

4" DEEP OVERBURDEN MONITORING WELL
+ EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
4- SHALLOW OVERBURDEN EXTRACTION WELL

•	RESIDENTIAL WELLS
® MANHOLE

a SURFACE WATER SAMPLE LOCATION
256 STREET ADDRESS
¦025 TAX MAP 8c LOT NUMBER

		 DISCHARGE INFILTRATION &

COLLECTION TRENCHES

ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAw WETLANDS 30UNDARY

AND/OR INTERPRETED SITE WETLANDS

KES PROPERTY BOUNDARY

APPROXIMATE RESIDENTIAL

PROPERTY BOUNDARY

SITE BOUNDARY

STREAM

FENCELINE

FLOW DIRECTION

BUILDING

DEMOLISHED ON SITE BUILDING

PFOA

PFOS



PFNA

PFHxS



Compound

NHDES
AGQS

(ngA)

EPA Health
Advisory

(ngA)

ND

ND



ND

ND

ND ond <6

NO and <4



ND and <5.9

ND ond <18

^ond<12

i^rj^15

£5^in<^11

PFOA

12

6



PFOS

15

4

260









PFNA

11

5.9







PFHxS

IB

39

LAND
AY

GRAPHIC SCAlE

Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 196710024/ERQJ. NO. 404

PFOA AND PFOS CONCENTRATIONS IN
SURFACE WATER AND DRINKING WATER

DATE
JAN 2023

SCALE
AS SHOWN

W.O. NO.
20139.003.004
" FIGURE NO.
	12B

F-10


-------
Figure F-ll: Approximate Distribution of PFAS in Groundwater

PFOA
ND
ND ond <6
>6 ond <12

DRAWN

S5

DATE
JAN 2023

DCS. ENG.

DAH
JAN 2023

W.O. NO.

,'j jcj.oc-

CHECKED

MRK

DATE

SO Al t
AS SHOWN

REVISION

-IGUPE NO.

12C

LEGEM!

•	ReSOJRCE WELL

4"	BEDRGCK MONITORING WELL

+	BEDROCK EXTRACTION WELL

DEEP OVERBURDEN MONITORING WELL

+	EXTRACTION WELL

4-	SHALLOW OVERBURDEN MONITORING WELL

+	SHALLOW OVERBURDEN EXTRACTION WEI

•	RESIDENTIAL WELLS
®	MANHOLE

A	SURFACE WATER SAMPLE LOCATION

256	STREET ADDRESS

-025	TAX MAP & LOT NUMBER

	DISCHARGE INFILTRATION &

COLLECTION TRENCHES

I ROAD OR DR'VEWAY
_ DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY
" AND/OR INTERPRETED SITE WETLANDS
= KE5 PROPERTY BOUNDARY

	APPROXIMATE RESIDENTIAL

PROPERTY BOUNDARY

— 	 SITE BOUNDARY

	 STREAM

FENCELINE
—- FLOW DIRECTION
I I BUILDING

DEMOLISHED ON SITE BUILDING
I I APPROX, EXTENT OF PFOA EXCEEDANCES
APPROX. EXTENT OF PFOA AND
PFOS EXCEEDANCES
APPROX. EXTENT OF PFOA, PFOS, AND
PFHxS EXCEEDANCES

25.9 aid <11

24 and <15

Compound

NHDES
AGQS

(ngA)

EPA Health
Advisory

(ngA)

PFOA

12

6

PFOS

15

4

PFNA

11

5.9

PFHxS

18

39

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 19B710024/PRQJ. NO. 404

PFAS EXCCEEDANCES IN
GROUNDWATER

SOURCE:

FIGURE 2, SiTE PLAN, QY WOODARD & CURRAN, DATED WAY 2014, TOWN OF
EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD TAX MAP NO, ?03, WESTON
FIELD OBSERVATIONS, AND CFS DATA COLLECTED IN DECEMBER 2015.

MW-01

NOV 22

p™
PFOS

128

MM

\

N

RESOURCE v

WASTE X
SERVICES

NEW ENGLAND
DRAGWAY

i

I

\±

NOTES:

All da la ere repartee 'n nanograms per i;er
(ng/L).

AGQS = Ambient Groundwater Quality Standards
per

Env—Or 600 Contaminated Site Management.
PFOA = Pe'fluorcoctanoic Acid (CAS No.
335—67—1)

PFOS = Perti-joroactariesulfonic Acid (CAS No-
1763-23-1)

PFMA = Pen'luorononanoic Acid (CAS No.
375-95-1)

PFHxS = Perfluorohexaresulfonic Acid (CAS No.
355-46-4)

U = Anclyte not reported a: or obove the
applicable loborctory reporting limit.
ND = non-detect

inter'm Cleanup Levels have rot bean establ'shed

F-ll


-------
Figure F-12: Approximate Distribution of PFAS in ReSource Waste Services and Select Site Groundwater

LEGEND
ReSQURCE WELL
BEDROCK MONITORING WELL
BEDROCK EXTRACTION WELL
DEEP OVERBURDEN MONITORING WELL
EXTRACTION WELL

SHALLOW OVERBURDEN MONITORING WELL
SHALLOW OVERBURDEN EXTRACTION WELL
RESIDENTIAL WELLS
MANHOLE

SURFACE WATER SAMPLE LOCATION

STREET ADDRESS

TAX MAP & LOT NUMBER

	DISCHARGE INFILTRATION &

COLLECTION TRENCHES
ROAD OR DRIVEWAY
DIRT/GRASS ROAD
PATH

NATIONAL WETLANDS BOUNDARY
AND/OR INTERPRETED SITE WETLANDS
KES PROPERTY BOUNDARY
APPROXIMATE RESIDENTIAL
PROPERTY BOUNDARY
SITE BOUNDARV
STREAM
FENCEUNE
FLOW DIRECTION
BUILDING

DEMOUSHED ON SITE BUILDING
APPROX. EXTENT CF PFOA EXCEEDAN CIS

PFOA



PFOS



PFNA

PFHxS



Compound

NHDES
AGQS
(ngA)

EPA Health
Advisory

(ngA)

ND



ND



ND

ND

ND and <6



ND and <4



ND and <5.9

ND and <18

26 and <12



>4 ond <15



25.9 and <11





PFOA

12

6













PFOS

15

4













PFNA

11

5.9





PFHxS

18

39

NOTES:

All data ore reoorred in nanograms per liter (ng/L).

AGQS - Amoient Groundwa:er Quality Stardcrds per
Env—Or 600 Contaminates S'te Management.

PFOA - Perfluorooctsnac Acid {CAS Mo. 335-67-1)

PFOS — Perfluorooctanesulfonte Acid (CAS No. 1763—23—1)
PFNA = Perfluoronononoic Acid (CAS No. 375-55-')

PFHxS — Perfliiorohexanesulfonic Acid (CAS No. 355-46—4)
II = Analytp not reported at or obove the applicable
laboratory reporting limit.

ND - non-detect

>onup Leva's have not been established for PFAS.

SOURCE:

FIGURE 2, SiTE PLAN, BY WOODARD & CURRAN, DATED WAY 2014, TOWN OF
EPPING TAX MAP NO. 38, TOWN OF BRENTWOOD TAX MAP NO, ?03, WESTON
FIELD OBSERVATIONS, AND GPS DATA COLLECTED IN DECEMBER 2015.

Environmental
Services

2022 ANNUAL MONITORING REPORT
KEEFE ENVIRONMENTAL SERVICES SUPERFUND SITE
256 EXETER ROAD, EPPING, NEW HAMPSHIRE
NHDES SITE NO. 198710024/PROJ. NO. 404

ReSOURCE WASTE SERVICES AND
SELECTED KEEFE SITE GROUNDWATER
SAMPLING RESULTS

W.O. MO.
70139.00.

SCALE
AS SHC

F-12


-------
Table F-l: Drinking Water Sampling Results - Select VOCs















rganic L

ompounds (VULs) pg/L













VOCs of Concern

Other VOCs











g

u





£





















2,

Jj

3

£

M

















£



s

s

JS

13

s

S

*



1



$







a

£





8
J

1

£







U

a







a



a

Q



g

Q



CQ

g

§



Well ID

Address

Samp le Date

t

S









FH-

I

S





u

MCL

NE

5

5

7

5

5

NE

2

13

NE

tooo

NE

ACQS

3

J

5

7

5

5

SI

2

13

600

1,000

70

KES_DW-1

16 INDIAN RIVER

9/2/2003



<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5







3/18/2004

<1.0























5/21/2008

<2.0























11/17/2009

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/2/2010

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2011

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/12/2012

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

0.8

<10

<0.5

<0.5

11/14/2013

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

O.S

<10

<0.5

<0.5

11/11/2014

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

1.0

<10

<0.5

<0.5

11/11/2014 DUP

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

1.0

<10

<0.5

<0.5

10/19/2015

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

0.9

<10

<0.5

<0.5

10/19/2015 DUP

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

0.8

<10

<0.5

<0.5

11/8/2016

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

1.3

<10

<0.5

<0.5

11/8/2016 DUP

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

13

<10

<0.5

<0.5

11/9/2017

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

1A

<10

<0.5

<0.5

11/9/2017 DUP

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

15

<10

<0.5

<0.5

11/8/2018

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

0.87

<10

<0.5

<0.5

11/8/2018 DUP

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

0.85

<10

<0.5

<0.5

11/7/2019

<0.142

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

0.86

<5



<0.5

11/7/2019 DUP

<0.142

<0.5
<0.5

<0.5
<0.5

<0.5
<0.5

<0.5
<0.5

<0.5
<0.5

<0.5
<0.5

<0.5
<0.5

054

<5



<0.5

11/13/2020

<0.15

11

<5

If

<0.5

11/13/2020 DUP

<0.144

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

11

<5

15

<0.5

1 1/5/2021

<0.147

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

1.6

<5

<0.5

IB

1 1/5/2021 DUP

<0.144

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

1.5

<5

<0.5

12

11/11/2022

< 0.153

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

2.6

<5

<0.5

<0.5

11/11/2022 DUP

<0.153

< 0.5

<0.5

< 0.5

< 0.5

<0.5

<0.5

< 0.5

2.1

< 5

< 0.5

<0.5

KES_DW-2

20 INDIAN RIVER

9/4/2002



















<10



<0.5

9/2/2003



<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

3/18/2004

<1.0























9/15/2006

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

5/21/2008

<2.0























11/17/2009

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/2/2010

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2011

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/12/2012

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/14/2013

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/11/2014

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

10/19/2015

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2016

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/9/2017

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2018

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/7/2019

<0.142

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

11/13/2020

<0.144

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

11/5/2021

<0.147

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

KES_DW-3

242 EXETER ROAD

9/4/2002



















<10



<0.5

9/2/2003



<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

3/18/2004

<1.0























9/15/2006

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

5/21/2008

<2.0























11/17/2009

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/2/2010

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2011

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/12/2012

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/14/2013

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/11/2014

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5







11/12/2014



















<10

<0.5

<0.5

10/19/2015

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2016

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/9/2017

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2018

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/7/2019

<0.142

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

1 1/5/2021

<0.144

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

11/11/2022

<0.15

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

KES_DW-4

246 EXETER ROAD

9/4/2002



















<10



<0.5

9/2/2003



<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

3/18/2004

<1.0























9/15/2006

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

5/21/2008

<2.0























11/17/2009

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/2/2010

<2.0

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2011

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

12/12/2012

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/14/2013

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

10/19/2015

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2016

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/9/2017

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/8/2018

<0.2

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<10

<0.5

<0.5

11/7/2019

<0.15

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

6.6

<0.5

<0.5

11/13/2020

<0.144

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

1 1/5/2021

<0.15

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

11/11/2022

<0.17

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<0.5

<5

<0.5

<0.5

F-13


-------












VolaWeU

rgaiuc L

ompounds (VUUs) pg/L













VOCs of Concern

Other VOCs

Well ID

Address

Sample Date

g

1

.3
Q

£
8

i

ca

£
3

"5

S

1

.a

Q


-------
Table F-2: Summary of PFAS in Groundwater, Drinking Water and Surface Water









Carbcaylic Acids

Sulfonates/Suitcnic Acids

Monitoring Well ID

Site
Boundary
Location

Suaiigraphir Unit

Sanfile Date

3

a

1

1 ^

II,

3

¦H

i

B -

If

rk*

5

4

1-

!i

3

3

1_

ii

1

1

| SS.

If

3

3
(

If

n

1

a

I

H

i &

¦A

%
a

I

5

II

1

ii

3

3

l

| £
1



?
S t

I

Is

II
Ii

I

8

II

S £
"S 3
1 *

1 B

S § 5?

Ill



6?

a £2

l ^

P

J 1

11?

ill



!
3 £

t E
III

1

1

i_

ii

If

2	=

¦§

1 -

li-
lts

I 2







CAS Ho

375-22-4

2706-90-3

307-244

375-85-9



375-95-1

335-76-2

2058-94-8

307-55-1

72629-94-8

376-06-7

67905-19-5

16517-11-6

45187-15-3

375-73-5

2706-914

108427-53-8

3554 64

375-92-8

45298-90-6

1763-23-11







AGOS (ng/L)

na



na

na

12

! 1

ta

na



na

na

na

na

na

na



na

18



na

15







GSL (t>g/L)

na

na

na

na

6*

5.9*

ra

na

na

na



na

na

600*

600'



39*

39*



4'

4*







swoc

na

na

na

na

na

na

na

na

na

na

ra

na

na

na

na

na

na

na

ret

na

na







SWSUn«/U

na



na

na

304

256

na

na

na

na

na

na

na

30,200

30.200

na

1,750

1.750

na

203

203

GmwubnUet Stwqrks

KES BEW-1



BED



9.91

3.97

<1 9

<1.9

4.06

<1 9

<1 9

<19

<1.9

<1.9

<1 9

-

-



<1 9

<19



<19

<1 9



-







11/8/2017

<2

<2

<2

<2

38

<2

<2

<2

<2

<2

<2

-

-

<2





<2



<2

29

29







4/16/2019







<3.7

23

<3.7

















<37





<37







KES CDM-1A



SOB

4/16/2019 DUP







<3.8

20

<3.8

















<3 8





<3.8













11/7/2022

=1.8

<18

<1 8

1.83

33.7

<1.8

<18

<1.8

<1.8

<1.8

<18

-





<1.8

<1.8



<1.8

<1.8











::

<1.8

<1 8

<1.8

1.82

34

<18

<18

<1.8

<1.8

<1.8

<18

..

_



<1.8

<1.8



<1 8

<18











11/4/2019







<4

<4

<4











..





<4





<4





-

KES CDM-4A

X

SOB

11/9/2020

<1 88

<1 S8

<1 88

<188

5.72

<1 ss

<1 88

<1 88

<1 88

<1 88

<188

<3.76

<376



<188

<188



<1 88

<188











11/8/2022

<1 83

<1 83

<1.83

<1.83

392

<1 83

<1.83

<1.83

<1 83

: 1 n

<1.83

-

-

-







<1 83

<1 83



-







11/8/2017

<2

<2

<2

<2

93

<2

<2

<2

<2

<2

<2

-

-

<2









<2

<2

<2

KES CDM-7

X

SOB

4/16/2019







13 B

<4

<4

















<4





<4













11/7/2022

<1 81

<1.81

<1 81

<1.81

342

<1 81

<1.81

<1.81

<1.81

<1.81

<1.81









<181



<1.81

<1.81





KES CDM-8

X

DOB

j.i, -

<1 84

<1.84

<1.84

<1.84

2.22

<1 84

<1.84

<1.84

<1 84

<1.84

<1.84









<1.84



<1.84

<1.84





KES CDM-9



SOB

11/9/2022

cl 94

<1.94

<1 94

<1.94

12.2

<1 94

<1.94

<1.94

<1 94

<1.94

<1.94







<1.94

<194



<1.94

<1.94





KES CDM-11



DOB

11/8/2022

<1 74

<1 74

<1 74

<1.74

1.75

<1 74

<1.74

<1.74

<1 74

<1.74

<1.74









<174



<1.74

<174





KES_CDM-12A



SOB

11/6/2017

IB

<2

<2

<2

9.3

<2

<2

<2

<2

<2

<2



-

<2





<2



<2

12

12





11/6/2017 DUP

<2

<2

<2

<2

9J

<2

<2

<2

<2

<2

<2



-

<2





<2



<2

11

11

KES CMD-13

X

SOB

11/9/2022

<1.81

<1 81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81









<1.81



<1.81

<1.81





KES CW-2A



SOB

11/1Q/2022

4.51

3.14

1.0

4.79

40.9

<1 86

<1 86

<1.86

<1 86

<1 86

<1.86

-

-

-



<186



<1 86

<1 86

-

-

KES CW-2C



BED

11/10/2022

<1 85

<1 85

<1 85

<1 85

12.2

<1 85

<1.85

<1.85

<1 85

<1 85

<1.85

-

-

-



<185



<1 85

<185

-

--

KES.CW-3A



SOB

11/9/2017

25

2 3

5 3

5.6

33

<2

<2

<2

<2

<2

<2



-

<2









<2

25

25



11/11/2022

6.62

3.74

6.51

654

44.5

2.19

<1.74

<1.74

<1.74

<1.74

<1.74







<1.74

<1.74



734

<1.74

-

-¦

KES CW-3B



DOB

11/11/2022

36.0

<1 89

<1 89

<1.89

45.4

<1 89

<1 89

<1.89

<1 89

<1 89

<189

-

-

-



<1 89



<1 89

<1 89

-

-

KES CW4A



SOB



<1 85



<1 85

<1.85

s--.

<1 85

<1 85

<1 85

<1 85

<1 85

<1.85

-

-

-



<185



<1 85

<185

--

--

KES CW-4C



BED

11/9/2022

<1 84

<1 84

<1 84

<1.84

<1 84

<1 84

<1.84

<1.84

<1 84

<1 84

<1.84









<184



<1.84

<184





KES CW-5C



BED

11/8/2022

<1.82

<1.82

<1.82

<1.82

2.10

<1 82

<1.82

<1.82

<1 82

<1.82

<1.82









<1.82



<1.82

<1.82

-



KES CVS-6A



SOB

u/ifvaa»

<1.8

<1.8

<1 8

<1.8

6.82

<1.8

<18

<18

<1.8

<1.8

<1 8

-



-

<1 8

<1.8



<1 8

<18

-

-

KES CW-6C



BED

11/10/3023

<1 85



<1.83

-







<183



<1.83

<1 83





KES EW-2



SOB

11/9/2022

<1.86

<1.86

<1.86

<1.86

8.92

<1 86

<1.86

<1.86

<1.86

<1.86

<186







<1.86

<1.86



<1.86

<1.86





KES EW-95-2



EW

11/8/2022

3.46

<1.93

<1.93

<1.93

13.9

<1 93



<1.93

<1 93

<1.93

<1.93







<1.93

<1 93



<1 93

<1.93



-







11/9/2017

21

<2

25

29

70

<2

<2

<2

<2

<2

<2

--

-

<2









<2

22

22

KES EW-97-1



EW

4/24/2018

-



-

<4

47

<4





--











<4





<4















2j6

239

2M

25

69.5

<1 87

<1.87

<1.87

<1.87

• 1.S7

<1.87







<1.87

<1.87



<1.87

<1.87





KES_EW-97-2



EW

4/23/2018

-

-



<3.6

29

<3.6





-











<36



-

<3 6









11/11/2020

2.54

2.15

2.86

2JS7

781



<1.85

<1.85

<1.85

<1.85

<1.85

<3.71

<3.71





<1.85



<1.85

<1.85





KES KES-2B



SOB

11/7/2017

¦ 2

<2

<2

<2

<2

<2

<2

<2

<2

<2J

<2J

-

-

<2





<2



<2

2J

2a

KES KES-2D



SOB

11/11/2022

<1.79

'

<179

<179

19.2



<1 79

<179

<179

<1 79

<1.79

¦







<179



<1 79

<179





KES KES-4B



SOB

11/11/2022

2.46

2.41

334

2J58

19.7

<: S3

<1.82

<1.82

<1.82

<1.82

<1.82









<182



1.99

<1 82











11/9/2017

TP

4.7

6.2

3.8

94

<2

<2

<2

<2

<2J

<2J





<2





<2

-

<2

12

12

KES MW-A



DOB

4/24/2018

-

-

--

<38

95

<3 8

--



-











<3 8



-

<3 8













4/24 2013 DUP

¦¦





<38

100

<3 8





-¦











<38



¦¦

<38







KES MW-Q1



SOB

11/7/2022

1.86

1.88

2.74

3119

126

<1 83

<1.83

<1.83

<1 83

<1.83

<183







<1.83

<183



<1.83

<1.83











11/9/2017

<2

<2

<2

<2

43

<2

<2

23

<2

<2

<2

-



<2





<2



<2

16

16

KES_MW-Q2



BED

4/23/2018

--

--

--

<3.8

46

<38





--







¦¦



<3 8



--

<3.8













11/10/2022

<1.87

<1 87

<1.87

<1.87

41.6

<1 87

<1 87

<1.87

<187

<1.87

<1.87







<1.87

<1,87

--

<1 87

<187





KES MW-X



BED

1 1 ..M,'.

¦ i ¦

<19

3J2

3-37

37.2

<19

<19

<19

<1.9

<1.9

<1 9



-

-

<1.9

<19



2.74

<1 9











11/8/2017

<2

<2

<2

<2

<2

<2

<2

<2

<2

<2

<2





<2





<2



<2

<2

<2

KES MW-50

X

SOB

11/4/2019







<4

<4

<4









-

-

-

-

<4





<4













11/7/2022

<1 84

<1 84

<1 84

<1.84

<184

<1 84

<1 S4

<1.84

= 1 84

<1 84

<1 84

-

-

-

<184

<184



<1 84

<184



-







11/8/2017

<2

<2

<2

<2

36

<2

<2

<2

<2

<2J

<2J

-

-

<2





<2



<2

<2

<2

KES MW-50C

X

BED

•viirjji"







<3.8

<3.8

<38













-



<3.8





<3.8













11/7/2022

<1 81

<1.81

<1.81

<1.81

5.41


-------








Sulfonates / Sulfonic Acids (tc*

t)

Potential Precursors



Parameter (alcubticns

Monitoring Well ID

Site
Boundary

l.oraiinn

Slraiigraphic Unit



2.

a

3 £
5 t

•i

l

ii

IS

§ _

I o

1 S £

Pi

S?

§s

i &
| a

13
il
11

ill

fills.

is

a °

11

1 s

a &

til
ip

§ w

fi O

Ii

J]

III

i

!* g | £

flli

i!
II
11 -

ill
tie

Sis

tl^
nn

ii

I&

I!

H

i

1

5c

ot>

<
z.
o

5

^ .
"i £

°

1
1
!

h

1

jig

In

1
1

|iS

Sis

Si
3

a

£?
£

§.
3

5

i?
if

i 2
e i

II

» o

ii

i

<
O.

1

a
|

1

i

S-
? =

I

H

i

3

h







1763-23-1

474511-07-4

335-77-3

126105-34-8

754-91-6

24448-09-7

1691-99-2

2355-31-9

2991-50-6

31506-32-8

-4 1-1- '. u . :

919005-14-4

13252-13-6

39108-34-4

27619-97-2

120226^50-0

756426-58-1

763051-92-9















15

na

na



na

na

ra

na

na

na

na

na

na

na

na

na

na

na

na

na

na

ra







4'

na

na

na

na

na

na

na

na

na

na

na

6*

na

na

na

na

na

na

na

na

na







na

na

na

na

na

na

na

na

ra

na

na

na

na

na

na

na

na

na

na

na

na

na







303

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

drounbraler Sanpks







¦CES BEW-1



BED

236

<1.9

<1.9



<1.9





<1.9

<15

<19







<1.9

<1.9







6 A

203

632%

31.6%









-

<2

-

<4J

















<4

<4







41

41

92 9%

lujjs;







<37

-



-























-





23

23

100 0%

in i i;;

MS CDM-1A



SOB

<38





























-





20

20

i ¦

100 .i;:







9.74

<1.8

<1.8



<1 t





<1.8

<1.8

<18







<1.8

<1.8







43.4

453

77.6%

96.0%







9JJ4

<1.8

<1 8



<11





<1.8

<1.8

<18







<1.8

<1.8







43.fi

455

77 9%

96.0%







<4



































ND

ND

na

ra

KES CDM4A

X

SOB

258

<1.88

<1.88

<188

<1.88

<47

<47

<1.88

<1.88

<18.8

<18.8

<

88

<47

<1.88

<1.88

<4.7

<1.88

<1.88

83

8 J

68.9%

100%







<1.83

<1.83

<1.83

-

<1.83







<1.83

<1.83

<183

..



-

<1.83

<1.83







392

3.92

100.0%

lOCP/o















<4J

















<4









93

9 J

100%

100%

KES CDM-7

X

SOB

<4

-



























-





13.0

13 j0

na

ra







<1.81

<181



..

:











<2



<4J





--











<4



-





59.0

615

72.8%

95.9%

KES_MW-Q2



BED

16









¦¦

¦¦

















-





62.0

62J0

74 2%

100.0%







15J

<187

<187



<187





<187

<187

<187







<1 87

<1,87

-





56.7

56.7

734%

im p%

•CES MW-X



BED

111)

<19

<1 9

-

<19



¦¦

<1.9

<19

<19







<1.9

<1.9

-





50.9

574

73 0%

887%











<2



<4J

















<4









ND

ND

na

ra

KES MW-50

X

SOB

<4

-



-





























ND

ND

ca

na







<1 84

<1.84

<1.84



<1 84



-

<1.84

<184

<184







<1 84



-





ND

ND

na

ra









-

<2

-

<4J

















<4



-





3j6

3.6

100%

100%

KES MW-50C

X

BED

<3 8

-

-

-























¦¦





ND

ND

na

na







<1.81

<1 81

<181

-

<181





<1 81

<181

<181







<181

<1.81







5.41

5.41

100%

100%









46

-



-























-





73.9

124

19%

60%









296



































47.2

5911

19%

80%

KES_MW-51

„

SOB

258

<1.83

<1.83

<1.83

<1.83

<458

<45.8

<1.83

<1.83

<18.3

<18.3

<1.83

<45.8



<1.83

<4

58

<1.83

<1.83

655

313.8

38 6%

21%



54 J J3

<1 91

<1.91

-

<1.91

-





<1.91

<1.91

<191

-





-











751

149.5

16 0%

50%







542 J3

<188

<1.88

-

<1.88

-

--

<1 88

<188

<188

-

-

-



<188





-

74.7

150.5

15 9%

50%







701

<1 81

<181

-

<1.81

-

-

<1 81

<181

<181

-

-

-



<1 81







1558

615.6

34 5%

25%

KES_MW-53A

v

DOB



-

<2

-

<4J

















<4



-





ND

ND

na

ra



<4





























-





ND

ND

na

ra

KES_MW-53C

..

BED





<2

-

<4J











-





<4

<4

-





ND

ND

na

ra



<4

-

-

-



-









-



-





--





ND

ND

na

ra

KES_MW-54A



DOB

<384

-

-

-













-

















ND

ND

na

ra





<1.81

<181

<181

<181

<181

<45 2

<45.2

<181

<181

<181

<18.1

<181

<452

<1.81

<1.81

<4.52

<1 81

<181

ND

ND

na

ra

F-16


-------








Carbcotylie Acids

Sulfonates / Sulfonic Acids

Moniloriie Well ID

Site
Boundary
Location

Stratigrapliir Unit

Sanplo Date

3

3

M

i_

I ^

n

5

a

it
!

6	—

t£
If
11

?
a

if

fs

S
*

M

I

tE

II

J*

:

E

I



E

3

3

1

I I
s <
f e
1 &

%

If



I
£

3
¦H

I

1

HI
i ?
1 i

1

1 t
m

1

|

h

!
a

If

8 °

h

|f

III

¦3

1

Isl

!
;

¦ £

i I

111

.

<

,

,



Is

ill

1

1

|e

£ t



is

•iS a

a £

5 E







CAS No.

375-22-4

2706-90-3

307-24-4

:i

335-67-1

375-95-1

335-76-2

2058-94-8

307-55-1

72629-94-8

376-06-7

67905-19-5

16517-11-6

45187-15-3

375-73-5

2706-91-4

108427-53-8

355-46-4

375-92-8

45298-90-6

1763-23-ll







AGOS (ng/L)

na

na

na

na

12

11



na

na

na

na

na

na

na

na



na

18

na

na

15







GSL (nR/t.)

na

na

na

na

6*

5 9*



na

na

na

na

na

IB

600'

6001

aa

39*

39*

na

4*

4'

KES_MW-54C



BED

11/5/2019







<3 84

<3 84

<3.84









-

-

-



<3 84





<3 84









11/10/2020

<1.79

1.81

<179

<179

<179

<1.79

<1.79

<1.79



1.79

<179

<1.79

<358

<358



<179

<179



<1.79

<1.79











4/24/2018







3S

37

<3.8





-

-









IS



--

<3.8













4/17/2019

-

-

-

15 B



16

<3.8



-

-











4.2



-

<3.8







KES MW-55A

X

SOB

11/10/2020

5.7

101

15.7

2.43

11.1

2.6

<1.84

<134

<184

<184

<1 84

<367

<367



<1 84

<1 84

-

<184

<1.84











4/20/2022

34.1

70.6

663

6.98

9.32

<1.95

<1.95

<1.95

<1.95

<1.95

<1.95







7.98

<1.95

--

<1.95

<1.95











11/9/2022

11.8

194

23.5

2.85

6.82

<1.82

<1.82

<182



182

<1.82

<1.82







2.33

<1 82

-

<1.82

<1 82











4/24/2018

-

-

-

<3.8

<3.8

<3,8



-













<3.8



-

<3.8







KES.MW-55C

X

BED

11/5/2019







<4

<4













-

-



<4





<4







11/10/2020

<1.82

<1 82

<1 82

<1 82

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<3.64

<3.64



<1.82

<1.82



<1.82

<1.82











11/9/2022

<1.78

<178

<1 78

<1 78

<1 78

<1.78

<1.78

<1.78



1.78

<1.78

<1.78



¦¦



<178

<1.78



<1.78

<1.78











11/7/2017

64

<2

35

3 A

260





<2

<2

<2J

<2J

-

-







<2



<2





KES_MW-58



DOB

4/23/2018







6S

210





-













<4



-

<4











11/10/2022

2.05 J

1.94

4.48

6.08

404

<1.78

<1.78

<1.78

<1.78

<1.78

<178

-

-



<178



1.78



<1.78

<1.78











11/10/2022 DUP

<1.76 J

2J1S

4.23

5 9

395

<1.76

<1.76

<1.76



176

<1.76

<176







<176

<1 76

-

<176

<1 7 6











11/5/2018

--

-

--

11J2

<3.8

<3 8



-

--











<3.8



-

<3.8







KES MW-60C



BED

11/5/2019







<4

<4













-

-



<4





<4













11/9/2020

<1 85

<1.85

<1.85

<1 85

<1.85

<1.85

<1.85

<1.85



1.35

<1.85

<1.85

<3.69

<3.69



<1.85

<1.85



<1.85

<1.85











11/5/2018







<38

<3.8

<3.8

















<3.8





<3.8







KES_MW-60D



BED

4/16/2019

-

-

-

<38

<3.8

<3 8



-

-











<3.8



-

<3.8









11/4/2019

-

-



<4

<4





-

-











<4



-

<4













11/9/2020

<1.83

<1.83

<1.83

-I : .

<1.83

<1.83

<1.83

<1.83

<1.83

<1.83

<1.83

<3.66

<3.66



<1.83

<1 S3



<1.83

<1.83











11/7/2018

-

-



<3.8

<3.8

<3.8



-

-

-





-



<3.8



-

<3.8







KES MW-61C



BED

11/4/2019







<4

<4

<4











-

-



<4





<4













11/9/2020

<1 81

<1 81

<1 81

<1 81



1 81

<1.81

<1.81

<1.81



1.81

<1 81

<1 81

<361

<3 61



<181

<1 81



<1.81

<1.81











11/6/2018





~

<3.9

<3.9

<3.9

















<3.9





<3.9













11/6/2018 DUP

-

-

-

<3.9

<3.9

<3.9



-













<3.9



-

<39







KES_MW-6ID



BED

11/4/2019

--

-

--

<4

<4

<4



-

-







--



<4



--

<4









11/4/2019 DUP

••

-

-

<3 44

<3 44

<344



~

¦¦











<344



-

<3.44













11/9/2020

<1.81

<181

<1.81

<181

<181

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<3.62

<362



<1.81

<1.81

-

<1.81

<181











1 l/P/2020 DUP

<178



<178

-i ;;



178

<178

<178

<178



178

<178

<178

<3 55

<355



<1.78

1 ;

-

<178

<1 78











11/6/2018

-

-

¦

<38

<3 8





¦

-











<3.8



-

<38







KES MWn52C

X

BED

11/5/2019

--

-

-

<4

<4





--













<4



-

<4













11/9/2020

<1.8

<18

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<3.6

<3.6



<1.8

<1.8



<1.8













11/6/2018

--

-

-

<3.9

<3.9

<3.9



--

--

-









<3.9



--

<39







KES MW-62D

X

BED

11/5/2019

--

-

-

<4

<4





-

-

-





-



<4



-

<4













11/9/2020

<1,8

<1.8

<1.8

<1.8

<1.8

<1.8

<18

<1.8

<1 8

<1.8



<3.6

<3.6



<1.8

<1.8

-

<1.8

<1.8











4/17/2019





-

<3.8

<3.8

<3.8

















<3.8





<3.8







KES PW-1

X

BED

11/6/2019

--

-

-

<3 76

<3 76

<3.76



-

--

-









<376



-

<3 76













11/10/2020

<183

<183

113

<1 83



183

<1 83

<1.83

<1.83

<183

<183

<183

<3 66

<366



<1 83

<1 83

-

<1.83

<1 83





F-17


-------






Sulfonates / Suit an it Acids (cant)

Potential Precursors



Parameter Calculations

Monitoring Well ID

Site
Boundary
Location

Siratigraphir Unit

1

1 _
1 I
11?.

|

If
If

1 -

8 g

fas.

HI

a

Q
| £
S&-
"S*

If
l|
£1

1.

Hi

||
1 S

jit

111

Ih
12

j

til
Sia

a

tiil

11

1 -a

lis
IP

Ik

h?
sip
• IIs
=? 11!

1!

fi

11
h

S

«]

111

sit

I

I r;
I f*
^11

n s a

3IfS

S
i

lis

i
1

Jig-

,

A:
s

X

£?
s

c
3

%

"j

1
(

5

j

Ii
ii

0
X

z

1

<
u.
cu

1
1

1
£

£ 5

Iff

1

i
a

Q

£ M

Z <
i a.







1763-23-1

474511-07-4

335-77-3

126105-34-8

754-91-6

24448-09-7

1691-99-2

2355-31-9

2991-50-6

31506-32-8

4151-50-2

919005-14-4

13252-13-6

39108-34-4

27619-97-2

120226-60-0

756426-58-1

763051-92-9



na

na

na







15

na

na

na

na

ra

na

na

na

na

na

na

ra



na

ra

na

ra

na

na

na

na







4'

na

na

na

na

na

na

na

na

na

na

na

6"



na

na

na

na

na

na

na

na

KES_MW-54C



BED

<3 84

-

-

-































ND

ND

na

na



<179

<179

<179

<1.79

<1 79

<447

<44 7

<179

<179

<17.9

<17.9

<179

<447

<1.79

<179

<447

<



<1.79

WD

2

na

na







93





































463

102

79.9%

45.3%







12





































28.0

47

57.1%

59.3%

KES MW-55A

X

SOB

185

<1 84

<1 84

¦ . £4



<45.9

<459

<1.84

<184

<184

<18.4

<1.84

<459

<1 84

<1 84

<4 59

<1 84

<1 84

322

66

34.5%

48.7%







7.08 J3

<1 95

<1.95









<1.95

<1 95

<19.5



--

-

<1.95

<1 95









164

195

56.8%

84%







10 J5

<1.82

<182









<1 82

<182

<18.2







<1.82

<1 82

-





174

113

39.2%

22.5%







<38

















-



-







-





ND

ND

na

na

KES.MW-55C



BED

<4

-













-











-





--



ND

ND

na

na



<182

<1.82

<1.82

<1 32



<45 6

<45.6

<1 82

<1 82

<182

<18.2

<182

<45 6

<1.82

<182

<4.56





<182

ND

ND

na

na







<1.78

<1.78

<1.78

-

<178







<1.78

<178

<17.8



-

-

<1.78

<1.78





-

ND

ND

na

na







-

-

<2



<4J















-





<4









260

273

100%

95 1%

KES.MW-58



DOB

<4







































210

217

100%

96.9%



2D2

<1.78

<178

-



-



<178

<178

<178



-



<1.78

3.7 J

-

-



40611

424 3

100%

95.7%







152

<1.76

<1.76



<1.76





<1.76

<176

<17.6







<1.76

<1.76 J







3965

ma

100%

97.0%







<3 8



































ND

n

na

na

KES MW-60C



BED

<4

-



-

















--













ND

ND

na

na







21

<1.85

<1.85

<1.85

<1.85

<462

<46.2

<185

<185

<18.5

<18.5

<185

<462

<1.85

<185

<462

<



<1.85

21

2.1

na

100.0%







35





































39

3.9

na

100.0%

KES.MW-60D



BED

<3 8





























-





ND

ND

na

na



<4

















-



















ND

ND

na

na







<1.83

<1.83

<1.83

<1.83

<1.83

<45.8

<45.8

<1.83

<1.83

<18.3

<18.3

<183

<45 8

<1.83

<1 83

<4 58

<



<1.83

ND

ND

na

na







<3 8





































ND

ND

na

na

KES MW-61C



BED

<4

--



-































ND

ND

na

na







<1 81

<1 81

<1.81

= 1 S!

<1.81

<45 2

<45.2

<181

<181

<181

<18.1

<181

<45 2

<181

<181

<452

<



<181

ND

ND

na

na







<3.9





































ND

ND

na

na







<39





















-







-





ND

ND

na

na

KES.MW-61D



BED

<4





























-





ND

ND

na





<344





































ND

ND

na

na







<1.81

<1.81



<1.81



<45.2



5.2

<1.81

<1.81

<18.1

<18.1

<1.81

<45.2

<1.81

<1.81

<4.52

<



<1.81

ND

ND

na

na







< 1 78

<1.78

<178


-------








Carboxylic Acids

Sulfonates / Sulf onic Acid s

Monitoring Well ID

Site
Boundary
Location

Stratignqihir Unit

Sanple Date

1

A

L

it

9

3

M

I

II

1 i

a

%

1

II

a

*

I

It

II

il

S
*

£

1

1;

IS

3

A!

1

| 2.

1

li

a

3

M

I

il

1|
li

1

I

if

if-

a

a

i

1!
II

i g

S

3

1

S _

I

IS



f

n

a
§

il

l

is

3

<
§

3

3

1 *

£ 3 a.

s a«

111

¦a
i

s _

11

m

I

t

h
li

III

111

A

!
j

1

si

§

i e
hi
nf



o
u.

|

fit
I'll







CAS No

375-22-4

2706-90-3

307-24-4

375-85-9

335-67-1

375-95-1

335-76-2

2058-94-8

307-55-1

72629-94-8

376-06-7

67905-19-5

16517-11-6

45187-15-3

375-73-5

2706-91-4

108427-53-8

355-46-4

375-92-8

45298-90-6

1763-23-1'







AGQS (ng/L)

na

na

na

na

12

11

~a

~a

na

na

na

na

na

na

na

na

na

18

na

na

15







GSL (nt/l)

na

na

na

na

6>

59*

na

na

na

na

na

na

na

600'

600'

na

39*

39*

na

4'

4*

ReSoarre Groundwater Surples (collected by others)

SB-01-GW



8-12 ft bus

1/14/2022

43

140

150

54

100

32

0JJ3 J

<2.1

<2.1

<2.1

<2.1







32

7.4



41

11J

-

_

SB -02-GW



5-9 ft bgs

1/24/2022

87

170

200

55

96

43

057 J

<19

<1.9

<1.9

<1.9







39

52



28

12 J







16-20 ft bgs

1/24/2022

5.2

74

95

65

14

Q69 J

<1.8

<18

<1.8

<1.8

<1.8

_





2.1

0.72 J



31

<1.8

_







2-6 ft bgs

1/20/2022

<4.7

<19

<19

<19

<19

<19

<1.9

<19

<1.9

<1.9

<1.9

-





0.65 JI

<1.9



<19

<19

-

-

SB -03-GW



16-20 ftbgs

1/21/2022

<4 5

<13

<1.8

<18

<18

<1 8

<1.8

<18

<18

<1.8

<1.8

-





<1 8

<1.8



<18

<18

-

-





37-41 ft bgs

1/24/2022

<6.1

<2.4

<2.4

<24

0.73 J

<24

<2.4

<24

<2.4

<2.4

<2.4

-





2111

<2.4



<24

<24

-

-

SS-04-GW



8-12 ft bgs

1/12/2022

30

40

34

17

21

2.7

2 6

<1.8

<1.8

<1.8

<1.8







27

31



12

<18





SB-05-GW



8-12 ft bgs

1/12/2022

23 J

95

81

33

91

40

23

<1.8

<1.8

<1.8

<1.8







0501

<1.8



12 J

<1.8







20-24 ft bgs

1/12/2022

31

93

110

31

54

40

053 J

<2.1

<2.1

<2.1

<2.1

-





8.7

If 1



10

11 J

--



SB -06-GW



8-12 ft bgs

1/25/2022

60

97

130

391

58

50

058.1

<18

<1.8

<1.8

<1.8

-





39

12 J



13

<18



-



18-22 ft bRs

1/25/2022

39

84

130

39

53

2j6

<1.8

<1.8

<1.8

<1.8

<18

-





19

2.6



15

0.65.1

-

-

SB-07-GW



2-6 ft bgs

1/20/2022

2D J

050 J

0.87 J

059 J

20

<18

<1.8

<18

<1.8

<1.8

<1.8

-





<1.8

<1.8



<1.8

<18

-

-



2-6ftbgsDUP

1/20/2022

<4 3

<1.7

056 J

047 J

13 J

<1.7

<1.7

<1.7

<1.7

<1.7

<1.7







<1.7

<1.7



<1.7

<17





SB -08-GW



5-9 ft bgs

1/19/2022

93

280

230

77

66

<20

<20

<20

<20

<20

<20







66

9.7 J



27

<20

-

--

S-09-GW



8-12 ft bgs

1/15/2022

12

16

18

12

19

047 J

<1.8

<18

<1.8

<1.8

<1.8

_





9.7

13 J



3.7

<1 8

-

-

SB-10-GW



10-14 ft bgs

1/18/2022

24 J

O.flO J

0.98 J

<19

11 J

<19

<19

<19

<1.9

<1.9

<1.9

-





1J5J

<1.9



0P1 J

<19

-

-

SB-ll-GW



5-9 ft bgs

1/18/2022

<4 7

<1.9

<19

<1.9

20

<19

<1.9

<19

<1.9

<1.9

<1.9

-





0.70 J

<1.9



14 1

<1.9

_

-

SB-12-GW





1/19/2022

<4 7

<1.9

<1.9

047 J

055 J

<19

<1.9

<19

<1.9

<1.9

<19

.





<19

<1.9



<1.9

<1.9

-

¦-







7/23/2021

2.11

2.77

3.22

<2.02

6.34

<2.02

<2.02

<2.02

<2.02

<2.02

<2.02







<2.02





<2.02

<2.53











10/26/2021

357

2.68

2.81

20

455

<1.98

<1 98

<1.98

<1.98

<1 98

<198







<1.98





<1.98

<2.47

_

_

MW-101



SOB

11/19/2021

18

40.8

413

15.2

22.1

<1.92

<1 92

<1 92

<1 92

<1 92

<192

-





8.91





5.73

<1.92

-

-



12/21/2021

3.S9

4.01

3.46

22

4.45

<2.04

<2 04

<204

<2 04

<2 04

<204

-





<2.04





<2 04

<2.04

-

-







3/30/2022

5J

35

63

4 9

95

<17

<1.7

<17

<1.7

<1.7

<1.7







12 J

<1.7



1.7

<1.7



¦







3/30/2022

4.6

35

5 9

45

84

<1.6

<1.6

<1.6

<1.6

<1.6

<1.6







11 J

0.45 J



1.7

<1.6

-

-







7/23/2021

4.92

11.8

13 J)

54

12

<2.05

<2.05

<2.05

<2.05

<2.05

<2.05







<2.05





4.23

<2.56





MW-102





10/26/2021

<1 98

3.45

3.19

-1.93

5.02

<1.98

<1.98

<1.98

<1 98

<1.98

<1.98







<1.98





<1.98

<2.48

_

-



SOB

11/19/2021

<2 01

2.94

4.13

<2.01

3.21

<2.01

<2 01

<201

<2 01

<2 01

<201

-





<2.01





<201

<2.01

-

-







12/21/2021

<2 01

2.24

2.47

<2.01

<2 01

<201

<2 01

<2.01

<2 01

<2 01

<201

-





<2.01

--



<2 01

<201

-

-







3/30/2022

33 J

4.7

55

24

45

0.96 J

<1.6

<1.6

<1.6

<1.6

<1.6







13 J

<1.6



20

<16











7/23/2021

60.6

246

211

73.4

180

9.51

3.86

<2.0

<2.0

<2.0

<2.0







443





37

<2.51

-

-

MW-103





10/26/2021

73.4

206

234

90.3

142

752

4.49

<1.93

<1.93

<1.93

<1.93







573





423

<2.41







SOB

11/19/2021

66.9

188

202

75.1

138

10.2

4.21

<2.0

<2.0

<2.0

<2.0

-





513





353

<2.0

-

-







12/21/2021

85 J

322

290

90.1

163

12.2

4.1

<207

<207

<2.07

<2.07

_





532





47.4

<2.07

-

-







3/30/2022

87

280

310

100

150

13

40

<17

<1.7

<1.7

<1.7

-





43

6.S



34

li J



-







7/23/2021

765

329

291

81.5

163

10.8

2.28

<2.02

<2 02

<2 02

<2.02







28





38

351



-

MW-104





10/26/2021

205

989

706

229

282

185

6.16

<1.98

<1.98

<1.98

<1.98







625





715

5.2







SOB

11/19/2021

141

522

407

177

224

18.2

476

<2.06

<2.06

<2.06

<2.06







45 S





58.7

405











12/21/2021

139

652

438

163

267

15.9

3.99

<2 06

<2 06

<2 06

- V

-





504





573

338

-

_







3/30/2023

140

570

480

190

260

16.1

<20

<20

<20

<20

<20

-

-



62

11 J



63

50 J

-

-







7/23/2021

40

153

163

48.5

99.6

4.77

<1 96

<1 96

<1 96

<1 96

<196

-

-



17J5





191

<245

-

-

MW-105





10/26/2021

9.97

24.5

29.2

133

27.2

2.61

<2.02

- J J

<202

<2.02

<2.02







453





735

<2.02







SOB

11/19/2021

30.1

51.4

46.2

13.9

34.9

2.29

<2.04

<2.04

<2.04

<2.04

<2.04







525





8.04

<2.04











12/21/2021

22i

64.6

48

18.6

481

258

<2 09

<2.09

<2.09

<2.09

<2.09







517





555

<2.09



-







3/31/2022

120

270

390

81

110

60 J

<20

<20

<20

<20

<20

-





28

631



25

<20

-

-







7/22/2021

<1 96

<1 96

<1 96

<1.96

<1 96

<1.96

<1 96

<1 96

<1 96

<1 96

<196

-





<1.96





<1 96

<2.45



-

Water SupplyWdl



BED

10/26/2021

<2 04

<2 04

<2 04

<2.04

<204

<204

<2 04

<2 04

<2 04

<2 04

<2.04

-





<204





<2 04

<2.55

-

~







11/19/2021

<1.96

<1.96

<1 96

-1 96

<1 96

<1.96

<1 96

<1.96

<1 96

<1.96

<1.96







<1.96





<1.96

<1.96





MW-201



SOB

3/31/2022

<4.5

<1.8

<1.8

<1.8

21

<18

<1.8

<1.8

<1.8

<1.8

<1.8







0.52 J

<1.8



10 J

<1.8





MW-202



SOB

3/31/2022

88

190

230

73

96

53

<1.7

<17

<1.7

<1.7

<1.7

-





45

43



19

1.7

...

-

MW-203



SOB

3/31/2022

32

47

74

29

65

7 3

25

<18

<1.8

<1.8

<1.8

-





15

3.4



20

12 J

-

-

MW-204



SOB

3/31/2022

30

61

95

32

61

3.7

<1.9

<19

<1.9

<1.9

<1.9







14

3A



18

0-O9 J

-

-

MW-205



SOB

3/31/2022

23

30

43

21

34

li J

<1.9

<19

<1.9

<1.9

<1.9

•





16

2.7



12

<19



--

F-19


-------








Sulfonates/Sulf

~nit Acids (cant)

Potential Precursors



Parameter Calculations

Monitoring Wdl 10

Site
Boundary
Location

Stratigram hie Unit

.

a £
% *

.

I

fe
3

3

§

! 3
e s-

III

Sf
Q

U

Is

II

ill
m

i§

P

li

ill

fe O

'

<5,

w

0

1

1

¦S

3

3

1

* 1 ~
i | a

fl Ig
i 1 ii

i?

it
Ill

1 h

Iff

i III

13

J £

s c

If
II

?!

s

3

M

-I
Jig

° *g §

sit

1 II.
1 fl
511

1
1

I i s
c I

zU

1
!

| f £

E J £
21 a

1

X '

5.

Sn

*
g
§

1

63
s *

11

j|

o S

A. O

jj

II
?I|

a

u
Q

Z

1

3

u-
£

3

1

1

i

2*

K Q

1

i

ls

z <







1763-23-1

474511-07-4

335-77-3

126105-34-8

754-91-6

24448-09-7

1691-99-2

2355-31-9

2991-50-6

31506-32-8

4151-50-2

919005-14-4

13252-13-6

39108-34-4

27619-97-2

120226-60-0

756426-58-1

763051-92-9

na

na











15

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na







4*

na

tu

na

na

na

na

na

na

na

IB

na

6*

na

na

na

na

na

na

na

na

na

ReSource Groundwater Sanqdes (collected by others)







SB-C1-GW





23 B

<2 1

<21

-

<2.1





<21

<3 2









<3.2

6X1

-





167.2

601.6

59.8%

28%

SB-02-GW



5-9ftbRS

35

<19

<19

-

<1.9





<1 9

<2 9









<2.9

95

-





1633

730.8

588%

22%



16 20 ft bgc

44

<1.8

<1.8



<1.8





<1.8

<2.7









<2.7

<4.4







22.2

54.2

63.1%

41%





2-6 ft bRS

<1.9

<19





<1.9





<19

<2.8









<28

<47







MD

0.65

na

na

SB-03-GW



i 111:

<1.8

<1.8

<1.8

-

<1.8





<18

<2.7









<2.7

<4.5







ND

ND

na

na





37-41 ft bgs

<2.4

<2.4

<24

-

<2.4





<24

<3.7









<3.7

<6.1







0.73

2.8

100 0%

26%

SB-04-GW



8-12 ft bra

32 B

<1.8

<1.8



<1.8





<1.8

<2.7









<27

<4.4







67.7

221.4

31.0%

31%

SB-05-GW



-!!'•

37

<18

<18

-

<1.8





<18

<2.7



-





<27

<44







51.3

77j6

17.7%

66%



20-:- ft buE

29B

<21

<2.1

.

<2.1





<2.1

<3.1









<3.1

<5.2







97.0

374.5

55.7%

26%

SB-06-GW



8-12 ft bra

39

<1.8

<1.8



<1.8





<1.8

<2 7









<2.7

75







115 JO

490.0

50.4%

23%



13-22 ft bp

IS

<18

<18

-

<1.8





<18

<26



..





<26

12







88.6

414.9

59 8%

21%

SB-07-GW



2-4 ft bgs

0.59 J

<1 8

<18

-

<18





<18

<2.7



-





<2.7

<4.4







26

6.9

77.2%

38%



- c :1 tpr L'-Jl

<1.7

<1.7

<1.7



<1.7





<1.7

<2.6









<26

<4.3







13

23

1000%

100%

SB-08-GW



5-9 ft bRS

63

<20

<20

-

<20





<20

<30









<30

<50







1561)

911.7

42.3%

17%

SE-09-GW



8-12 ft bgs

14 JIB

<18

<1.8

-

<1.8





<18

<27









<2.7

<4.5







24.6

93j6

77.3%

26%

SB-10-GW



10-14 ft bgs

26

<1.9

<1.9



<1.9





<1.9

<2.9









<2.9

<4.8







65

105

16.9%

62%

SB-ll-GW



5-9 ft bRs

26

<19

<19



<1.9





<19

<28









<2.8

<47







6J)

6.7

33.3%

90%

SB-I2-GW



4-8 ft bRS

<1.9

<1.9

<19

-

<19





<19

<2 8









<2.8

<47







0.85

132

100 0%

64%







4.52



<2.78



144





<2.02

<2.66









<2.28

<2.02







10.9

334

58.4%

33%







<1.98



<2.72



4112





<1.98

<2.69









<2.23

<1.98







4 j6

20D

100 0%

23%

MW-101



SOB

259

..



-

<192





<1 92

<1 92









<1.92

<1 92







30.4

154.6

72.6%

20%





<2.04

-

<2.04



<2 04





<2.04

<2.04









<2.04

<204







45

1SD

100.0%

25%







1j6 JB

<17

<1.7



0.47 J





<1.7

<2.5









<2.5

<4.2







12.8

343

74.2%

37%







1.3 JB

<16

<1.6



054 J





<16

<2.5









<2.5

<4.1







11.4

32JS

73.7%

35%







6X1



<282

-

8.79





<2.05

<2.69









<2 31

<2.05







22.2

670

54.0%

33%

MW-I02





3.25



<2.72



114





<1.98

<2.60









<2.23

<1.98







83

263

60.7%

31%



SOB

366



<2.01

.

<2 CI





<2.01

<2.01









<2.01

<2.01







65

135

46.7%

49%







256

-

<2.01

-

<2 01





<2.01

<2.01









<2.01

<2.01







3D

7.7

na

39%







45

<1.6

<1.6



<1.6





<1.6

<2.4









<2.4

21 J







12.3

31.6

39.2%

39%







923



<2.76



336





<20

<2.63









<2.26

4.29







3182

995.9

56.5%

32%

MW-103





80

-

<266



18 3





<193

<2.53









956

<1 93







2721

965.9

52 2%

28%



SOB

84

-

<20



<2.0





<2.0

<2.0









<2 0

7.69







2675

862.7

51.6%

31%







95



<2.07



<207





<2.07

<2.07









<2.07

9.82







3116

11721

51.3%

27%







S9B

<17

<17

-

<1.7





<1.7

<2 6



--





<26

92







286 JQ

112715

524%

25%







122

-

<2.78

-

24.7





<2.02

<2.66









<2 28

14







333 S

11S4.6

48.8%

28%

MW-104





117



<2.72



84





<198

<2.60









<2.23

19.2







4896

27204

57.6%

18%



SOB

105

..

<2.06

.

<2 06





<2.06

<2.06









<2.06

12.4







4055

21913

55.2%

19%







116



<2.06

-

<2 06





<2.06

<2.06









<2.06

12.1







456.2

19181

58.5%

24%







100 B

<20

<20



<20





<20

<30









<30

<50







4390

18971)

59.2%

23%







426

..

<2.70



324





<196

<2.58









<2.21

6.0S







1661

626.7

60.0%

27%

MW-105





16 4

-

<2.77



43





<2.02

<2.65









<2 27

<2.02







53.6

139.4

50.8%

38%



SOB

213

..

<2.04



<204





<2.04

<2.04









<204

3.28







66.5

216.7

52.5%

31%







254



<2.09



<209





<2.09

<2.09









<2.09

3.91







81.6

244.4

58.9%

33%







43 B

<20

<20



<20





<20

<30









<30

<50







1840

10793

59.8%

17%







<1.96

-

<27



831





<196

<2.58









<221

<1 96







ND

83

na

na

Water SupplyWell



BED

<2.04



<28



<2 04





<2.04

<2.67









<2.29

<204







HD

ND

na

na







<196

-

<1 96

-

<196





<196

<1.96





..



<196

<1 96







ND

ND

na

na

MW-201



SOB

23

<1.8

<18

-

<1.8





<1.8

<2 7





-



<27

<4 5







54

5.9

38.9%

91%

MW-202



SOB

71B

<1.7

<1.7



<1.7





<1.7

<2.6









<2.6

61







1913

829.4

50.2%

23%

MW-203



SOB

60 B

<1.8

<1.8



0.77 J





2.7

32









14 J

61







1523

370.6

42.7%

41%

MW-204



SOB

20 Bl

<19

<19

-

<1.9





<19

<2 8



--

--



<28

<47







102.7

339.3

594%

30%

MW-205



SOB

13 BI

<1.9

<1.9



<1.9





<1.9

<2.8









<2.8

66







60.6

202.9

56.1%

30%

F-20


-------








CarbcotyScAcids

Sulfonates/Sulfonic Acids

Monitoring Weil ID

Site

Boundary

Location

So adgraphir Unit

Sairple Date

3

I

•H

t_

II

IE
It

S

3

M

if

3 t

11

«!

M

L

e 5-

=1

33

3

M
!

f£

ll

a

Z

i

1;
is

3

¦H

I

is
J!*

3
%

1

¦So

1 I

It

I

M

Is

II

itR

1

M

I

a

35

ii

i &

a

-a

M

I

s

II

1

I I

1 1

¦X

ll
1!

.H

I

S

P
I i
§ £
¦5 a

Is

1 ,

B § =•
§ § cr

lis



{fl-
ag

f

h
n

is

1 I
lis

111

¦S
i

1 I

nisi

I E

18®
fit

1

I

i_

II
i§
,ii &

|

!L

i $ si
i * s?
lag
£ if.







CAS Ho

375-224

2706-90-3

307-244

375-85-9

335-67-1

375-95-1

335-76-2

2058-94-8

307-55-1

72629-94-8

376-06-7

67905-19-5

16517-11-6

45187-15-3

375-73-5

2706-914

108427-53-8

35546-4

375-92-8

45298-90-6

1763-23-1"







AGOSCns/L)

IB

na

na

na

12

11

na

na

na

na

na

na

na

na

na

na

na

18

na

na

15







GSL(nfi/L)

ta

na

na

na

6"

5 9*

na

na

na

IB

na

na

na

600'

600'

na

39*

39'

na

4'

4'

Drinking Water SampLs







11/13/2020

-



<1.9

<1.9

<1.9

<1.9

<1.9

<1.9

<1.9

<1.9

<1.9







<19



-

<1.9













11/13/2020 DUP

-



<1.9

<1.9

<1.9

<1.9

<1.9

<1.9

<1.9

<1.9

<1.9







<1.9



-

<1.9







KES-DW-1



BED

11/5/2021

<1.85

<1.85

¦ i

<1.85

<1.85

¦ i::

<1.85

<1.85

<1.85

<1.85

<185







<1 35

<1.85



<185

<1.85









11/5/2021 DUP

<1.89

<1.89

<189

<1.89

<1.89

<1.89

<1.89

<1.89

<1.89

<1.89

<189







1 3?

<1.89

-

<1.89

<1.89











11/11/2022

<1.86

<186

<1.86

<1.86

<1.86

<1.86

<1.86

<1.86

<1.86

<1.86

<186







<1 86

<1.86



<1.86

<1.86











11/11/2022 DUP

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<1.82

<182







-1 :¦ J

<1.82

-

<182

<1.82





KES_DW-1B



BED

11/7/2019

-

-

-

<4

<4

<4

-

-

-

-

-

-

-



<4



-

<4

-

-

-



11/7/219 DUP

-

-

-

<4

<4

<4

-

-

-

-

-

-

-



<4

-

-

<4

-

-

-







11/7/2019

-

-

-

<4

<4

<4

-

-

-

-

-

-

-

-

<4

-

-

<4



-









6/18/2020

<1 93

<1 93

<1 93

<1.93

<193

<1 93

<1 93

<1 93

<1.93

<1 93

<1 93

<3 86

<386

-

<193

<1.93

-

<1 93

<193

-

-

KES DW-2



BED

11/13/2020

-

-

<18

<18

<1.8

<1.8

<1.8

<1.8

<18

<18

<1.8

-

-

-

<1 8



--

<1.8



-

-







4/29/2021

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.83

<1.81

<1.81

<1.81

<3.62

<3.62

-

<1.81

<1.81

-

<1.81

<1.81

-

-







11/5/2021

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81



-



<1.81

<1.81

-

<1.81

<1.81

_

-







11/7/2019

-

-

-

<3.76

<3.76

<3.76

..

-

-



-

-

-

-

<3.76

-



<3.76



-



KES DW-3



BED

11/5/2021

<1.77

<1.77

<1 T7

<1.77

<1.77

<177

<1.77

<1.77

<1.77

<1.77

<1.77

-

-

-

<1 77

<1.77

-

<1.77

<1.77

-









11/11/2022

<1:8

<1.8

<1.8

<18

<18

<1.8

<18

<1.8

<1.8

<1.8

<18

¦





<1.8

<1.8

-

<1.8

<18

¦









11/7/2019



_



<3.76

<376

• . 'o





_









_

<3.76



_

<3.76





-

KES_DW4



BED

11/13/2020

-

-

<18

<1.8

<1.8

<1.8

<18

<1.8

<1.8

<1.8

<1.8

-

-

-

<1 8

-

-

<1.8



-

-



11/5/2021

<182

<182

<1 82

<182

<182

<1 82

<182

<1 12

<182

<182

<182

-

-



<1 82

<1 82

-

<182

<1 82

-

-







11/11/2022

<186

<1 86

<1 86

<1.86

<1 86

<1 86

<186

<1 86

<186

<186

<186

-

-

-

<1 36

<1 86

-

<186

<1 86

-

-







11/7/2019

-

-

_

<3.72

<3 72

<3 U

-

_

-



_

-

-

-

<372

-

_

<372



-

-

KES_DW-5



BED

11/13/2020

-

-

<1.7

<1.7

<1.7

<1.7

<17

<1.7

<1.7

<1.7

<1.7

-

-

-

<1.7

-

-

<1.7



-

-



11/5/2021

<1.87

<187

<1.87

<1.87

<1.87

<1.87

<1.87

<1.87

<1.87

<1.87

<1.87

-

-



<1.87

<1.87

-

<1.87

<1.87

-

-







11/11/2022

<1.86

<1.86

-1 £ c

<1.86

<186

<1.86

<1.86

I 8 6

<1.86

<1.86

<1.86



-

-

-1 36

<1.86

-

<1.86

<1.86

-



KES DW-6B



BED

11/7/2019







<3.76

<3.76

<3 7o

















<3.76





<3.76













11/7/2019







<3.76

<3.76

<376

















<3.76





<3.76







KES_DW-7



BED

11/13/2020

-

-

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

<1.8

-

-

-

<1.8

-

-

<1.8

-



-



11/5/2021

<1 84

<184

<134

<1.84

<1 84

<1.84

<1.84

<1 84

<1.84

<1 84

<1 84



-



<1 84

<1.84

-

<184

<1 84

-

-







11/11/2022

<1 82

<1.82

<1 82

<182

<182

<1 82

<182

<1 82

<182

<1 82

<1 82

-

-

-

<1 82

<1.82

-

<182

<1 82

-

-







11/7/2019

_

_

-

<3.76

<376

<3.7«

-

_

-

-

-

-

-

-

<376



-

<3 76

-

-

-

KES DW-8



BED

11/13/2020

-

-

<1.8

<1.8

<1.8

<1.8

<18

<1.8

<1.8

<1.8

<1.8

-

-

-

<1.8

-

-

<1.8



-

-







11/11/2022

<1.76

<176

<1 76

<1.76

<176

<176

<1.76

<176

<1.76

<1.76

<176

-

-

-

<176

<176

-

<176

<176

-

-

KES DW-9



BED

12/15/2022

<184

<1.84

<1 84

<1.84

<184

<184

<184

<1.84

<1.84

<1 34

<1.84



-



<1 84

<1.84

-

<184

<1.84

-



Surface Water Soirptes

KES_SW-12





5/22/2019

856

348

3.75

3.26

115

<181

<181

<181

<181

<181

<181







!

<1.81

-

<181

<1.81









4/16/2020

<189

<189

- l 89

<1 89

3

..1 89

<189

<189

<189

<1.89

<1 89

<379

<379



..1 89

<1 89

-

<189

<1 89

-



KES SW-9





4/16/2020

<182

<182

<1 82

<1.82

<182

<1.82

<182

<182

<1.82

<182

<1.82

<364

<364



<1 82

<1.82

--

<182

<1.82





KES SW-8





4/16/2020

<1.81

<1.81

<181

<1.81

157

<1.81

<1.81

<1.81

<1.81

<1.81

<1.81

<3.62

<3.62



<1.81

<1.81



<1.81

<1.81





KES SW-7





4/16/2020

<1.80

<1.80

<1 80

<1.80

151

<1.80

<1.80

<1.80

<1.80

<1.80

<1.80

<3.60

<3.60



-1 j.j

<1.80



<1.80

<1.80





KES SW-6



Fresh River

4/16/2020

<183

<183

-113

<1.83

3J8

<183

<183

<183

<1.83

<1.83

<1 83

<3.66

<3 66



- 1 JI

<1.83

¦

<183

<1.83





KES SW-5



4/16/2020

<1.80

<180

•: • i

<1.80

3.1

<1 80

<1.80

-1 r

<1.80

<1.80

<1 80

<361

<3.61



<1 30

<1 80

-

<180

<1.80





KES_SW-4





5/22/2019

5.77

3.29

2.90

2.73

6.62

<1 86

<1 86

<1 86

<1 86

<1 86

<1 86



-



<1 86

<186

-

<1 86

<186

-







4/16/2020

<1.84

<1.84

<1 84

<1.84

2.15

<1 84

<1.84

<1-84

<1.84

<1.84

<1.84

<3.68

<3.68



<1.84

<1.84



<1 84

<1.84





KES SW-3





4/16/2020

<2.30

<2.30

'2ii

<2.30

3.76

<2 30

<2.30

<2.30

<2.30

<2.30

<230

<4.61

<4.61



<2.30

<2.30

-

<2.30

<2.30

-

-

KES_SW-1





5/22/2019

949

358

448

356

134

<2 07

<2.07

<207

<2.07

<2.07

<207



~



<2.07

<2.07

-

<2.07

<2.07

-

-





4/16/2020

<1.82

<1.82

<1 82

<1.82

3.48

<1 82

<1.82

<1 82

<1 82

<1 82

<182

<364

<3.64



<1.83

<182

-

<1 82

<182

-

-

KES_SW-U

„



5/22/2019

256

7.75

947

5.64

20.2

<1 89

<1.89

<1 89

<1 89

<1 89

<1 89



-

-

2,67

<189

-

<1 89

<189

¦¦

-





4/16/2020

<1.85

337

435

2.34

11.5

<1 85

<1.85

<1 85

<1.85

<1.85

<185

<3.70

<370



<1 35

<185



<1 85

<185





KES SW-10





4/16/2020

<1.78

356

443

2.24

11.1

<1.78

<1.78

<1.78

<1.78

<1.78

<1.78

<3.56

<3.56



154

<1.78



<1.78

<1.78









PiscassicRjver

5/22/2019

331

S56

12.2

7.00

26.2

<1 94

<1.94

<1 94

<1.94

<1.94

<194







343

<194

-

<1 94

<194



-

KES_SW-2





5/22/2019 DUP

337

852

12JS

7.43

25.8

-I 92

<1.92

<1 92

<1.92

<1 92

<192

-

-



345

<192

-

2.22

<192

--

-





4/16/2020

<1.96

438

6

3.0S

15.8

= l 9t

<1 96

<1 96

<1 96

<1 96

<1 96

<3 92

<3 92



244

<196

-

<1 96

<196

-

-







4/16/2020 DUP

<1.96

4.72

6.21

3.09

16.5

<1 96

<1 96

<1 96

<1.96

<1 96

<1.96

<3.92

<3.92



256

<196



<1 96

<1.96





F-21


-------






Sulfonates / Sulfonic Acids (cct

t)

Potential Precursors



Parameter Calculation

Monitoring Well ID

Site
Boundary
L oration

Stratigraphir Unit

1 _
1 1

;

I
I

3

§

a g

2 I -

iff

C?
Q

If

P

L

if £
In

f

11

til

Is

II

!i
til

"Is

a

•3

Jfl
pill

|:

I

O
f—

t.

li*
till
PP i.

I £

I	g
if

II

ft

3

¦a

m

ih
In

_ 6

i *i

11|

Hi
sis
3*lfi?

1
1

lis

III

I
i

III

|
i

I-

*16

5 E§

III

P 3

3

1

h

ti

11

ij

=

afi*

3

i
i

<
jl

1

1

s

I

1

i

Z*

1

Q







1763-23-1

474511-07-4

335-77-3

126105-34-8

754-91-6

24448-09-7

1691-99-2

2355-31-9

2991-50-6

31506-32-8

4151-50-2

919005-14-4

13252-13-6

39108-34-4

27619-97-2

120226-60-0

756426-58-1

763051-92-9

na

na











15

na

na

na

na

na

tia

na

na

na

na

na

na

na

na

na

na

na

na

ra

na

na







4'

na

na

na

na

M

na

na

na

na

IB

na

6*

na

na

na

na

na

na

na

na

na

Drinking Water Samples













<1.9













<1.9

<1.9





<1.9

<1.9







<1.9

<1.9

ND

ND

na

na







<1.9













<1.9

<1.9





<1.9

<1.9







<1.9

<15

ND

ND

na

na

KES-DW-1



BED

<1.85

<1.85

<1.85



<185





<1.85

<1.85

<185

-





<1 85

<1 85

-





ND

ND

na

na



<189

<1.89

<1.89



<189

-

-



<189

<189







<189

<1.89

-





ND

ND

na

na







<186

<186

<1.36



<186

-

-



<186

<186

-





<186

<1.86

-





ND

ND

na

na







<182



182

<132



<1 82







<182

<182

-





<182


-------








Carbcwylic Acids

Sulfonates/Sulfonic Acid s

Monitoring Well ID

Site
Boundary
Location

Stratigraphic Unit

Sanple Date

1

.a

J

Je

S

-a

M

it

if

if*

S

%

1 £

H

a

%

M

1

ME

if

I

¦U

1

1?

1 o

2. &

a
3

lE
§ <
I®

a

•a

a
%

i!
ii

i a

n

p.

a

%

!

Ii
I ¦

*

¦h

1

la

E -s



%
a £

j
'

<
1
t

a

%

1

8

it
ii

f 3
la

g sa

i 3 s?

m

•1

1

1 ^
1 «

Sag

1

1

Is

P

I*

III
f«i

I

1
*

$
a £

I E

lit

§
i

!_
!&
is

Ii

\
,

s

!a

iS

4 t







CAS No

375-22-4

2706-90-3

307-244

375-85-9

335-67-1

375-95-1

335-76-2

2058-94-8

307-55-1

72629-94-8

376-06-7

67905-19-5

16517-11-6

45187-15-3

375-73-5

2706-91-4

108427-53-8

355-46-4

375-92-8

45298-90-6

1763-23-11







AGQS(nR/L)

na

na

na

na

12



na

na

na

na

na

na

na

na

na

na

na

18

na

na

15







GSL (nfi/L)

na

na

na

m

6*

5 9'

na

na

na

na

na

na

na

600*

600*

ta

39*

39*

na

4*

4*

Field Quality Control Outvies 3





11/9/2017

<2

<2

<2

<2

<2

<2

<2

<2

<2

<2

<2

-

-

<2

-

-

<2

-

<2

<2

<2





4/23/2018

-

-

-

<3 6

<36

<3 6

-

-

-

-

--

-

--

-

<3.6

-

-

<3.6

-

--

-

EQUIP BLANK



11/5/2018

-

-

-

<3.8

<3 8

<3 8

-

-

-

-

-

-

-

-

<38

-

-

<3.8

-

-

-

(water level meler)



4/16/2019

-

-

-

<38

<38

<3 8

-

-

-

-

-

-

-

-

<3.8

-

-

<38

-

-

-





11/4/2019

-

-

-

4.57

<4

<4

-

-

-

-

-

-

-

-

<4

-

-

<4

-

-

-





11/9/2020

<1.92

<192

<192

<192

<1.92

<1.92

<192

<192

<192

<192

<192

<3.84

<3.84

-

<1 92

<1 92

-

<1 92

<1 92

-

--

EQUIP BLANK



11/6/2019

-

-

-

<4

<4

«



-



-

-



-

-

<4

-

-

<4

-

-



(submersible pump)



11/9/2020

<1.84

<1.84

<1.84

<1 84

<1.84

<1.84

<1.84

<1 84

<1.84

<1.84

<1.84

<3.68

<3.68

--

<1.84

<1.84

-

<1.84

<1 84

-¦

-





11/8/2022

<1.92

<1.92


-------








Sidfonates / SuK onic Acids (coi

t)

Pot entia 1P recur sors



Parameter Calculations

Monitoring WeU ID

Site
Boundary
Location

Stratlgraphlr Unit



a £
% &

.
!

L

i

3

§ _

1 s

11"
lie

lie.

<»
a

1I

11

Hi

1*

its

ill

f

S '

£
c

1

I	w

a P

II
11

3

3
a

1 *

=? b i I

II

P *

il-

III

W :§ W

S&3&

fill

* sii

SI

IS
= f
si

ti

fl

c

^ (

<
o
§

4»g

II!
! rs

2 § a

5.1 s

nil1?

1
1

! i®
lis

I

i

1! 1
HI

Si

i

e?
£

3

a

3

fl

If

II

If
?i

I

3

63

Q

Z

1

<

fc

2

1

I

|2
i

II
*?,

1

§3

z <







1763-23-1

474511-07-4

335-77-3

126105-34-8

754-91-6

24448-09-7

1691-99-2

2355-31-9

2991-50-6



4151-50-2

919005-14-4

13252-13-6

39108-34-4

27619-97-2

120226-60-0

756426-58-1

763051-92-9

na

na

na

na







15

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na

na







4'

na

na

na

na

na

na

na

na

na

na

na

6'

na

na

na

na

na

na

na

na

na

Field OuaUtv Control SantpUs 1













-

<2

-

<4J

-

-

-

-

-

-

-

-

<4

<4

-

-

-

ND

ND

na

na





<3 4

-



-

-

-





-

-

-

-





-

-

-





-

-

ND

ND

na

na

EQUIP BLANK



<3.8

-

-

-

-

-





-

-

-

-





-

-

-

-

-

-

ND

ND

na

na

(waterlewd meter)



<3.8

-



-

-

-

-

-

-

-

-

-

-

-



-

-

-

ND

ND

na

na





<4

-

-

-

-









-



-







-

-

-

-

-

-

ND

4.6

na

na





<192

<1.92

-

<1.92

-

<48

<48

<1.92

<1 92

<19.2

<19.2

<1.92

<48

<192

<1.92

<4.8

<1.92

<1 92

ND

ND

na

na

EQUIP BLANK



<4





-

-

-





-

-

-







-





-

-

-

ND

ND

»

„

(subtneraWe pump)



<1 84

<184



<184

-

<46

<46

<1,84

<184

<184

<18.4

<184

<46

<184

88.8

<4 6

<184

<1 84

ND

8SJi

na

na





<192



192

<192



<192









<1.92

<192

<192

-





-

<152

<1 92





-

--

ND

ND



na





-

-

<2

-

<4J

-

-

-

-

-



-

-

<4

<4

-

-

-

ND

ND

na

na





<4

-



-

-

-

-

-

-

-



-

-

-



-

-

-

ND

ND

na

na





<4























-











-



ND

ND



«





<4

"



-

-

-





-

-

-







-





-

-

-

ND

ND









<178



178

<1.78

-

<1.78

-





<1,78

<1.78

-



-

-

<1.78

<178

"

-

-

ND

ND

»

»







-

-

-

-

-





-

-

-

-

-

-

-

-

-

-

-

ND

ND









<4

-



-

-

-

-

-

-



-

-

-

-

-

"

-



ND

ND

»

»





<187

<1.87

<1.87

<1.87

<1.87

<46.8

<468

<1.87

<1.87

<18.7

<18.7

<187

<46.8

<187

<1.87

<468

<1.87

<1.87

ND

ND









<185



185



<185

<185

<462

<462

<1,85

<185

<18.5

<185

<185

<46.2

<1.85

<1.85

<4.62

<185

<1 85

ND

ND

»

na

FIELD BLANK

na

<2.0

<2,0



<2,0

<2.0

<50.1

<50 1

<2.0

<2.0

<20

<20

<2.0

<50,1

<2.D

<2.0

<5.01

<2.0

<2.0

ND

ND



na





<1.7

-

-

-



-

-

<1.7

<17

-

-



7

<1.7

<1.7

<1-7

-

<1.7

<1.7

ND

ND









<1.91



191

<1,91

<151



<478

<47.8

<1.91

<1.91

<19.1

<19.1

<191

<47.8

<191

<1.91

<4.78

<1.91

<1 91

ND

ND









<1.84

<1.84

<1.84





-





<1.84

<1.84

<18.4



-

-

<1.84

<1.84





-



ND

ND









<1.75



175

<1.75



<1.75





<1,75

<1.75

<17.5









<1.75

<1,75







ND

ND









<189

<1.89

<1.89



<1.89

-

-

<1,89

<1 89

<189

~





-

<1.89

<1.89

-

-

-

ND

ND

n

na





<1.88

<1.88

<1.88



<1.88

-





<1.88

<1.88

<188

-

-

-

<1.88

<1.88





-

-

ND

ND

»







<1.85

<1.85

<1.85



<1.85

-





<1.85

<1.85

<18.5







-

<1.85

<1.85

"

-

-

ND

ND









<1.95



1.95

<1.95













<1.95

<195

<19.5







-

<195

<1.95





-

-

ND

ND

na

na









<2



<4J



















<4

<4







ND

ND

na

na





<4



































ND

ND

na

na





<4

-

-

-

-









-

-

-

-

-

-

-

-

-

-

-

ND

ND

na

na





<4

-

-

-

--

-





-

-

-

-

-

-

-



-

-

-

ND

ND



na





<185

<1/85

<185

--

<1 85

-





-

<185

-1

-





-

<185

<185

-

-

-

<4

ND

na

na





<4

-



-

-

-





-

-

—

-





-

-



-

-

-

ND

ND

na

na

TRIP BLANK





<4

-









































ND

ND

na

na





<1.86



1.86

<1.86

<1.86

<1.86

<46.6

<46.6

<1.86

<1.86

<18.6

<18.6

<186

<46,6

<1.86

<1.86

<4.66

<1.86

<1 86

ND

ND

na

na





<1.79

<179



<179

<1.79

<44 8

<44 8

<1.79

<179

<179

<17.9

<179

<44.8

<179

<1 79

<4 48

<179

<1 79

ND

ND

na

na





<185



185



<185

<185

<46 4

<464

<1.85

<185

<185

<18.5

<185

<46.4

<185

<1 85

<4 64

¦

1 85

<1 85

ND

ND

na

na





<1.7

-



-

<17







<1.7

<1.7

-

~

<1.7

<1.7

<1.7

<1.7





<1.7

<1.7

ND

ND

na

na





<1.94



1.94

<1.94

<1.94

<1.94

<48.5

<485

<1.94

<1.94

<19.4

<19.4

<1

y4

<48.5

<194

<1.94

<4.85

<1.94

<1 94

ND

ND

na

na





<1.86



186

<1.86



<1.86









<1.86

<1.86

<18.6









<1.86

<1.86









ND

ND

na

na





<1.78



178

<1.78

-

<178

-

-

<1.78

<1.78

<17.8



-¦

-

<1.78

<1.78

-

-



ND

ND

na



F-24


-------
Staff o nsf es / Sulfa nic Acids

[4] « Numbtt of fluormaeiJcsrbon charefot perfiuomatedcsbCKjriie Kids	f - , j r~ al ] flueroalkyl substances	ND*> not detected

[4S] "Number offtuotsrialtdcM-ban Aansr^parf^tiniiedsifan**®	r - 1 ii ' ^ira-dea	t FT T - I ? f- *i j a ' j 1i it i+ ft tt t i -c -

AOQS» AiftUertOiouridwttet QuditySUtictardper Err*-0t600 CortamimtedSiU: Man&gemeri E t l--i ~ix * 2m	'i t t- idiiih i1 »t>- ! l-flif ¦>* U >• 1 Hi d i u i sj Wife	1-1 1 m rj i"* »»nl i *n him j ¦" \ ! jnLf t a i! » k j nJl i "a as.

SWQC - Surface W*« Quality Strncl* ( established by U S Erwonrnw#* Protection Agwwy	V h ibsi'phitt t ewd interval eo-mingnuiiiplf Strang aphjc units	)- * t- fid > - t ifi t ^ « Imi b -"it iiHi i m nt r-ti- waiscn

IL. itz & 1 uenl Zone	E" Jill i _ i 13 iL l«ii i I

-= AaalyasPiTotcmdiRtsel	ft bgs = fertWowycittdsurfsce

ingPFOA. PFOS. PFNA md FFHxS



ih.tir—" b.j :•.!-. r -:-x\ ::t •.••i; i

*Th	¦¦'¦:¦¦¦ ¦	: ¦¦	is wa111 t 1 It'jf In- -itf'-ic t 1i I -i t) qsiotjent t" I L H-- i* ^rs^ylssenccsififtise<} preset, sit site-	giars ths AGQS, whjchare	fen-fe

QSle>u

1 The AGQSioNt'*'Hampshire Code of Acituisstrtrtive Rotes Esiv-Ocouir^ariaituniite L If'' ivm J " 1 V i i 3 >	if ' i ^	t^nrrrhi • i„l  11 I ! 11 n „1

1 A total of uptotarji-twnFFAS conxpc"orate'*«« messursdbvthe sralvsw t«pcrted ®1 u > i ji-rfir i-it f - t	tt 1 iti 11 x\ s , i i	hnnrfl

3 Fieldqii^itjrecntrol ssmjJcs w«c cdlectedinil-* fieldpr lb? prcc^iiir i. ix> 1: n.^w =

F-25


-------
APPENDIX G - SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST



L SITE INFORMATION

Site Name: Keefe Environmental Services

Date of Inspection: Mav 8. 2023

Location and Region: Epping, New Hampshire,

EPA ID: NHD092059112

Region 1

Agency, Office or Company Leading the Five-Year
Review: EPA Resion 1

Weather/TemDerature: Sunnv. 65

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



PI Other:



Attachments: ^ Inspection team roster attached

1 1 Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager



Name

Title Date

Interviewed | | at site Plat office |~~|bv phone Phone:

Problems, suggestions r~| Report attached:



2. O&M Staff



Name

Title Date

Interviewed |~~| at site |~~| at office |~~| b\ phone Phone:

Problcms/siiaacstions |~~| Report attached:



3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency

response office, police department, office of public health or environmental health, zoning office,

recorder of deeds, or other city and county offices). Fill in all that apply.

Agencv NHDES



Contact Michael Summerlin Site Manaser

Name Title Date Phone

Problems/sussestions PI Rcoort attached:



Agencv



Contact Name



Title Date Phone

Problems/sussestions PI Rcoort attached:



Agencv



Contact



Name Title Date Phone

Problems/sussestions PI Rcoort attached:



Agencv



Contact



Name Title Date Phone

Problems/sussestions PI Rcoort attached:



G-l


-------


Asencv
Contact

Name Title
Problcms/suaacstions |~~| Report attached:

Date

Phone



4.

Other Interviews (optional) EH Report attached:









Michael Kanarek, Weston Solutions

HI. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents









M O&M manual ^ Readily available

^ Up to date

~ n/a





~ As-built drawings EH Readily available

~ Up to date

IK|n/a





~ Maintenance logs EH Readily available

~ Up to date

Kl n/a





Remarks:







2.

Site-Specific Health and Safety Plan

~ Readily available

~ Up to date E

I N/A



~ Contingency plan/emergency response plan

~ Readily available

~ Up to date £<

| N/A



Remarks:







3.

O&M and OSHA Training Records

Remarks:

~ Readily available

~ Up to date E

|N/A

4.

Permits and Service Agreements









~ Air discharge permit

~ Readily available

~ Up to date £<

| N/A



~ Effluent discharge

~ Readily available

~ Up to date E

|N/A



~ Waste disposal, POTW

~ Readily available

~ Up to date E

|N/A



I-! Other Dcrmits:

~ Readily available

~ Up to date £<

| N/A



Remarks:







5.

Gas Generation Records

Remarks:

~ Readily available

~ Up to date E

|N/A

6.

Settlement Monument Records

Remarks:

~ Readily available

~ Up to date £<

| N/A

7.

Groundwater Monitoring Records

^ Readily available

M Up to date EH N/A



Remarks:







8.

Leachate Extraction Records

~ Readily available

EH Up to date £<

| N/A



Remarks:







9.

Discharge Compliance Records









~ Air EH Readily available

~ Up to date

M N/A





~ Water (effluent) EH Readily available

~ Up to date

M N/A





Remarks:







10.

Daily Access/Security Logs

~ Readily available

EH Up to date E

|N/A

G-2


-------
Remarks:

IV. O&M COSTS

1. O&M Organization



1 1 State in-house

Contractor for state

1 1 PRP in-house

1 1 Contractor for PRP

I~1 Federal facility in-house

1 1 Contractor for Federal facility

n



2. O&M Cost Records



1 1 Readily available

1 1 Up to date

1 1 Funding mechanism/agreement in place ^ Unavailable

Orieinal O&M cost estimate:

1 1 Breakdown attached

Total annual cost by year for review period if available

From: To:

I-! Breakdown attached

Date Date

Total cost

From: To:

I-! Breakdown attached

Date Date

Total cost

From: To:

I-! Breakdown attached

Date Date

Total cost

From: To:

I-! Breakdown attached

Date Date

Total cost

From: To:

I-! Breakdown attached

Date Date

Total cost

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons:



V. ACCESS AND INSTITUTIONAL CONTROLS ^Applicable ~ N/A

A. Fencing

1. Fencing Damaged ~ Location shown on site map ~ Gates secured ^ N/A

Remarks: Several downed trees were restine on the fence alone the northern boundary of the fenced area.

However, the fencins was not damaeed. NHDES will contact the Town and reauest removal of the

downed trees.

B. Other Access Restrictions

1. Signs and Other Security Measures

~ Location shown on site map ~ N/A

Remarks: Siens are dresent at the entrance sates indicating no tresrassine. The main entrance also had a

sisn that identified the Site bv name and provided contact information.

C. Institutional Controls (ICs)

G-3


-------
Date



Phone

I~1 Yes

~

No

[XI N/A

I~1 Yes

~

No

[XI n/a

IEI Yes

~

No

~ n/a

I~1 Yes

~

No

[XI n/a

1.	Implementation and Enforcement

Site conditions imply ICs not properly implemented	~ Yes E| No ~ N/A

Site conditions imply ICs not being folly enforced	~ Yes No ~ N/A

Type of monitoring (e.g., self-reporting, drive by): Self-monitoring
Frequency: Semi-annual
Responsible party/agency: NHDES

Contact Michael Summerlin	Site Manager 			

Name	Title

Reporting is up to date
Reports are verified by the lead agency

Specific requirements in deed or decision documents have been met
Violations have been reported
Other problems or suggestions: ~ Report attached

2.	Adequacy	^ ICs are adequate	~ ICs are inadequate	~ N/A
Remarks: The current GMP has expired. However, monitoring requirements are being met.

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:	

VI. GENERAL SITE CONDITIONS

A. Roads ~ Applicable ^ N/A

1. Roads Damaged	~ Location shown on site map ~ Roads adequate ~ N/A

Remarks:	

B. Other Site Conditions

Remarks: Generally, the Site is well maintained and all monitoring wells are locked and well marked.
VII. LANDFILL COVERS	~ Applicable [XI N/A

VIII.	VERTICAL BARRIER WALLS	~ Applicable ^ N/A

IX.	GROUNDWATER/SURF ACE WATER REMEDIES ^Applicable ~ N/A

A.	Groundwater Extraction Wells, Pumps and Pipelines	~ Applicable ^ N/A

B.	Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A

C.	Treatment System	~ Applicable ^ N/A

D.	Monitoring Data

1. Monitoring Data

G-4


-------
Is routinely submitted on time	^ Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained ^ Contaminant concentrations are declining

E. Monitored Natural Attenuation	

1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked	^ Functioning ^ Routinely sampled

All required wells located	~ Needs maintenance

Remarks:	

X. OTHER REMEDIES

If there are remedies applied at the Site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
	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 designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).

The current groundwater remedy consists of MNA. Semi-annual monitoring is ongoing and results are
reported in annual reports as well as data submittal reports (in the spring). Data collected during this FYR
period indicate that attenuation is occurring and conditions remain favorable for continued degradation of
VOCs in groundwater. PFAS investigations are ongoing. The residential drinking water wells remain
unimpactedbv site contamination. PFAS was detected at one residence, below the state AGOS. This
	residence is unoccupied. Institutional controls in place rcslricl the use oF groundwater on silc.	

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.

The maintenance of the groundwater monitoring well network is adequate.

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.

None at this time.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None at this time.

Good condition
~ N/A

G-5


-------
APPENDIX H - SITE PHOTOGRAPHS

eefe Environmental

Services Site

OPERATED FOR

Hampshire Department of Environmental Services
Environmental Protection Agency

BY

AK2SS2JCUWN

' -derations

Signage at entrance

Former groundwater treatment building

H-l


-------
Former lagoon area

gIP t ¦'

Former discharge infiltration area

H-2


-------
Surface water sampling point 2A

Wetland and area near SW-4

H-3


-------
DM1-A and MW60C&D

H-4


-------
EMW-3

it am.

H-5


-------
APPENDIX I - REVIEW OF CLEANUP LEVELS

Table 1-1: Groundwater Cleanup Level Review

( onlaminanl of
Concern i ('()(')

( Icaniip I.cm'I

Basis

( unvnl MCI.'

(fiji/l.)

( iinvnl Stale
ACQS1'
(uii/l.)

(hiiniio

Benzene

5

MCL

5

5

None

1,2-DCA

5

MCL

5

5

None

1,1-DCE

7

MCL

7

7

None

PCE

5

MCL

5

5

None

TCE

5

MCL

5

5

None

1,4-dioxane

3

State AGQS

Not established

0.32

More stringent

Vinyl chloride

2

MCL

2

2

None

1,1-DCA

81

State AGQS

Not established

81

None

Notes:

a. EPA's National Primary Drinkine Water Standard, located at httDs://\
drinkine-water/national-Drimarv-drinkine-water-reeulations (acccsscc

vww.coa. eov/eround-water-and-
I 5/22/2023).

nt34 l/files/documents/2020-

b. NHDES AG
0 l/Env-Or'X

OS. located at httos://www.des.nh.eov/sites/e/files/ehber

20600.odf (accessed 5/22/2023).

Table 1-2: Residential Risk Screening of Soil Cleanup Levels

( onlaminanl of
Concern K ()( )

Soil Cleanup
l.c\cl
(fili/ksi)

Kcsiricnlial
Soil KM .-'(nig/kg)

C.iiK'cr Kisk1'

Noncancer
HQ1

1 \ III' Risk

110= 1.0

Lie ii/ci ic

:u s

l:

82

2 x 10-'

0.3

1,2-DCA

3.5

0.46

31

8.0xl06

0.1

1,1-DCE

22.8

—

230

--

0.01

PCE

91.0

24

81

4.0 x 10"6

1.0

TCE

31.5

0.94

4.1

3.0 x 10"5

7.7

Notes:

- = not applicable; toxicity criteria not established.

Bold = exceeds EPA risk management range of lxlO 6 to lxlO 4 and/or noncancer HQ of 1.0.

a.	Current EPA RSLs available at https://www.epa.eov/risk/reeional-screenine-levels-rsls-eeneric-tables
(accessed 5/15/2023).

b.	The cancer risks were calculated using the following equation, based on the fact that RSLs are derived
based on 1 x 10~6 risk: cancer risk = (cleanup level cancer-based RSL) x 10~6.

c.	The noncancer HQ was calculated using the following equation: HQ = cleanup level noncancer-based
RSL.

d.	RSL for cis-l,2-DCE, which is more stringent than the RSL for trans-1,2-DCE.

1-1


-------
APPENDIX J - VISL OUTPUT

Evaluated using November 2021 data from well MW-QI
Commercial Vapor Intrusion Risk	4

Temperature





Site

VI















(°C)\







Indoor Air

Carcinogenic

VI

VI











for







Concentration

Risk

Carcinogenic

Hazard

VI





Chronic



Groundwater





CAS

Cia\

CDI

Risk

CDI

Hazard

IUR

IUR

RfC

RfC

Vapor



Chemical

Number

(ug/m3)

(ug/m3)

CR

(mg/m3)

HQ

(ug/m3)-1

Ref (mg/m3)

Ref

Concentration

Mutagen?

Benzene

71-43-2

2.95E-01

2.41 E-02

1.88E-07

6.73E-05

2.24E-03

7.80E-06

I

3.00E-02

IRIS

25

No

Dichloroethane. 1,1-

75-34-3

1.91E+00

1.55E-01

2.49E-07

4.35E-04

-

1 60E-06

C

-



25

No

Dichloroethane, 1,2-

107-06-2

2.32E-01

1.89 E-02

4.91 E-07

5.29E-05

7.55E-03

2.60E-05

I

7.00E-03

PPRTV

25

No

Dichloroethylene, 1,1-

75-35-4

2.45E+00

2.00E-01

-

5.60E-04

2.80E-03

-



2.00E-01

IRIS

25

No

Dioxane, 1,4-

123-91-1

3.47E-02

2.83E-03

1 42E-08

7.93E-06

2.64E-04

5.00E-06

I

3.00E-02

IRIS

25

No

T etrachloroethylene

127-18-4

-

-

-

-

-

2.60 E-07

I

4.00E-02

IRIS

25

No

Trichloroethylene

79-01-6

3.42E-01

2.79 E-02

1.14E-07

7.81 E-05

3.91 E-02

4.10E-06

I

2.00E-03

IRIS

25

Mut

Vinyl Chloride

75-01-4

-

-

-

-

-

4.40E-06

I

1 00E-01

IRIS

25

Mut

*Sum



-



1.06E-06

-

5.19E-02

-



-



-



Output generated 20JUN2023:15:38:21

J-i


-------