Phase IV As-Built & Final Inspection Report & Partial Response Action Outcome Statement Wetlands, December

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Phase IV As-Built and Final Inspection Report and Partial Response Action Outcome Statement (RAO) - Wetlands

Former GE Facility (RTN# 3-0518) Wilmington, Massachusetts

Submitted to:

Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup I Winter Street, 9t Floor Boston, Massachusetts 02109

Preparedby:

TRC Environmental Corporation Boott Mills South Foot of John Street Lowell, Massachusetts 01852

TRC Project No.: E9202-5509-02180

December 2004 TABLE OF CONTENTS

1.0 INTRODUCTION...... 1-1 1.1 Purpose of R eport ...... 1-1 1.2 Overview of the Remedy Implementation Plan (RIP)...... 1-1 1.3 Tim eline ...... 1-2 2.0 PER IUTTING ...... 2-1 3.0 REMEDY IMPLEMENTATION...... 3-1 3.1 Site Preparation...... 3-1 3.2 Excavation and Dewatering Activities...... 3-2 3.2.1 Field Observations ...... 3-3 3.3 Sediment Disposal/Reuse...... 3-3 3.4 Backfilling and Site Restoration ...... 3-4 3.5 Wetland Restoration...... 3-6 4.0 LONG-TERM MONITORING AND MAINTENANCE FOR WETLAND RESTORATION...... 4-1 4.1 Photographic Stations ...... 4-2 4.2 Sampling Protocol...... 4-2 4.3 R eporting ...... 4-3 5.0 SUMMARY OF DEVIATIONS OF SIGNIFICANT MODIFICATIONS FROM REMEDY IMPLEMENTATION PLAN ...... 5-1 6.0 PHASE IV COMPLETION...... 6- 7.0 PARTIAL RESPONSE ACTION OUTCOME STATEMENT ...... 7-1 7.1 LSP O pinion...... 7-1 7.2 Feasibility of Achieving or Approaching Background...... 7-1

TABLES

Table 1-1. Project Timeline ...... 1-2 Table 3-1. Maximum Contaminant Concentrations for Imported Wetland Backfill...... 3-4 Table 3-2. Number of Trees, Shrub, Pterophyte, and Sedge Species...... 3-6

FIGURES

1-1 Site Plan 1-2 Wetland Area 3-1 Pre-excavation Survey 3-2 Post Excavation Survey and Limits of Remediation 3-3 Hummock-Hollow Topography and Restoration Detail 4-1 Wetland Monitoring Sampling Transect and Photographic Stations

L2004456 i APPENDICES

A- Photographs B- Permit Applications, Notifications, Certificates and Approvals C- Turbidity Barrier Specifications D- In-situ Pre-characterization E- Material Shipping Record and Log F- Lab Reports- Imported Backfill G- Imported Backfill Nutrient Testing H- Pre-existing Baseline Conditions I- Wetland Monitoring Documentation

12004-456 ii 1.0 INTRODUCTION

1.1 Purpose of Report

The following presents the As-Built Construction and Final Inspection Report for the Phase IV remediation activities of the Wetlands at the former General Electric (GE) Facility site located at 50 Fordham Road in Wilmington, Massachusetts. This report conforms to the Phase IV regulatory requirements under 310 CMR 40.0875 and 40.0878 of the Massachusetts Contingency Plan (MCP). The site is listed as a Tier IA site with Release Tracking Number 3-0518. This report summarizes all activities completed in accordance with the Phase IV Remedy Implementation Plan (RIP) - Wetlands, dated January 2004. An overall site map is shown in Figure 1-1. A close-up of the wetland portion of the site is shown in Figure 1-2.

The completion of Phase IV activities has resulted in a condition of no significant risk and a Permanent Solution for the wetlands portion of the site. This report also includes a Partial Response Action Outcome (RAO) Statement documenting that conditions in the wetlands portion of the site conform to the regulatory requirements of a Class A RAO under 310 CMR 40.1000 of the MCP.

1.2 Overview of the Remedy Implementation Plan (RIP)

As described in the Phase IV RIP (January 2004), the remedial action for the wetlands portion of the site included excavation and off-site reuse of sediments impacted by metals that resulted in a potential significant impact to ecological receptors. The remedial scope of work included the following:

o Implement all necessary safety, security, and erosion/sedimentation controls. o Re-direct water from existing outlets to a location downstream of excavation areas. o Removal of existing surface water as needed from excavation areas. a Removal of top twelve inches of wetland soil and sediment from excavation areas and place in a staging/dewatering area. a Collection and treatment of water from dewatered wetlands soil and sediments. o Backfill excavation areas. o Off-site disposal of removed sediments. o Restoration of wetland areas

The targeted remediation areas were identified based on the conclusions of the Stage II EnvironmentalRisk Characterization(ERC), dated January 2004. As shown in Figure 1- 2, they are identified as Area A, Area B, and Area C.

L2004-456 1-1 The Stage II ERC concluded that potential significant risk was present for ecological receptors (namely worms and other benthic organisms) in the identified areas due to elevated concentrations of lead, copper and zinc. There was no identified significant risk to human health. The source of the metals appears to be related to a historical release of fluids that contained oils and metals from outfall 002. Overtime, the oil compounds degraded, leaving the metals in the upper portions of the wetland sediments and soils.

The maximum depth for ecological receptor exposure in the soil and sediment is a depth of 6 inches. Therefore, removal and replacement of the wetland substrate (soil and sediment) was warranted.

The remediation of the wetlands areas is not based on numerical standards, but on calculated exposure concentrations derived from food web modeling, and toxicological testing of worms. The limits of the target remediation areas were determined using 1) a detailed topographic survey of the wetlands area that identified the low-lying areas that receive water from the outfalls (i.e., the point sources of contamination), 2) the concentrations of contaminants in the soil and sediment, and 3) the maximum ecological receptor depth (6 inches). With the removal of the upper foot of soils and sediments, and replacement with clean backfill, the entire area that originally posed a significant risk to ecological receptors would be eliminated. Using this risk-based remedial approach, post excavation testing for residual metals concentrations was unwarranted.

1.3 Timeline

Table 1-1 presents a project timeline summarizing the major construction activities completed to implement the remedy.

Table 1-1. Project Timeline Mobilization August 9, 2004 Install Sediment and Erosion Controls August 9-12, 2004 Clear and Grub August 9-12, 2004 Pre-Excavation Survey August 11, 2004 Wetland Backfill Delivered August 16,2004 Excavate Wetland Soils and Sediment September 7-10, 2004 Transportation and Disposal of Excavated Materials September 8-10, 2004 Place Imported Backfill September 13-14, 2004 Demobilize from Site September 16,2004 Wetland Restoration (Install Plants) October 5-8, 2004

Representative photographs of all the remediation and restoration activities are provided in Appendix A.

12004-456 1-2 2.0 PERMITTING

In accordance with the Federal Clean Water Act, Wetlands Protection Act, and local bylaws, TRC secured all of the necessary permits to perform the wetland remediation and restoration activities. The following permits and agency approvals were obtained:

o Notice of Intent (NOI) and Order of Conditions, North Reading Conservation Commission

o Programmatic General Permit (ACOE PGP) Category II, U.S. Army Corp of Engineers o 401 Water Quality Certification (WQC) for DEP File #245-1029, Massachusetts Department of Environmental Protection (MADEP) o Environmental Notification Form and Certificate of Approval, Massachusetts Environmental Policy Act (MEPA) Unit, Massachusetts Executive Office of Environmental Affairs

A copy of the permit applications, certificates and approvals, along with a summary of the permit requirements are provided in Appendix B.

L2004-456 2-1 3.0 REMEDY IMPLEMENTATION

3.1 Site Preparation

All construction work was performed by T Ford Company, Inc. of Georgetown, Massachusetts (contractor) and supervised by TRC. The contractor prepared the site by establishing work zones and installing sedimentation and erosion controls prior to conducting any excavation work. Traffic controls (cones and caution tape) were used to define the work area and the excavated soils and sediment staging area. Facility traffic was rerouted around the work zones.

A line of hay bales and silt fence was installed along the down stream edge of the parking lot to protect the wetland from parking lot run off and soil disturbing activities (i.e., temporary access roads) that are required in upland portions of the work zone. Trees, brush, dead wood and other vegetation were cleared from the access road alignments and the wetland Areas A, B, and C, as needed between August 9 and 12, 2004. Stumps were removed with a hydraulic excavator and the loose soils were shaken off onto the other soils scheduled for excavation. Cleared materials were disposed at an off-Site location. In lieu of the proposed gravel access roads, a plastic "Mabey Mat" was used to provide a stable access road that prevented rutting and minimized the potential for tracking soils onto the parking area. The use of the Mabey Mat minimized soil disturbance and eliminated the need to remove and dispose of the road gravel material at the end of the project.

Grubbing was not performed in the wetland outside of the three areas slated for remediation. Sedimentation controls were installed around the perimeter of Areas A, B and C after the completion of clearing in order to prevent impacted sediment and soil from exiting the work areas.

A staked turbidity barrier was used instead of the proposed "Excavation Containment Berm" to control sedimentation and to minimize the flow of surface water back into the excavation area. The turbidity barrier was constructed of an 18-ounce laminated vinyl- polyester fabric that was installed in a vertical position using stakes. The bottom of the fabric was placed in an 8-inch deep trench and backfilled to prevent water from flowing under the barrier. Once installed, the height of the barrier was 36 inches above the ground. Since the fabric is impermeable, the turbidity barrier functioned in the same fashion as the Excavation Containment Berm by preventing the migration of water in and out of the excavation area. Specifications for the turbidity barrier materials are provided in Appendix C. All sedimentation and erosion controls were installed by August 12, 2004.

Heavy rain flooded the wetland on August 14 and 15, 2004 and, as a result, excavation work was delayed until September 7, 2004 to wait for the water level in the wetland to subside.

L2004-456 3-1 3.2 Excavation and Dewatering Activities

The Contractor excavated wetland sediments and soils between September 7 and 10, 2004. In accordance with the PhaseIV RIPfor Wetlands, the top 12 inches of sediment and soil were removed. However, given the uneven topography of wetland, a pre- excavation survey was conducted to ensure that at least 12 inches of wetland substrate was removed.

In Area C, the lowest pre-excavation elevation was determined by surveying the local high and low points at 10 locations within the area of excavation. The survey results indicated that the southern half of the area was approximately four inches higher than the northern half. As a result, Area C was subdivided and excavated to two different elevations. The northern half was excavated to elevation 74.71 feet above mean sea level (msl). The southern half was excavated to elevation 75.01 feet above msl.

The surface of the sediment in Areas A and B was uniform and no special survey was needed to determine the depth of excavation. A minimum of 12 inches of sediments were removed from Areas A and B. The pre-excavation survey is shown on Figure 3-1, and the post-excavation survey with the limits of excavation is shown on Figure 3-2.

The original remedial design included the installation of berms at the outlets of the storm water culverts to create a sump from which storm water can be pumped and re-directed to a downstream wetland location during excavation activities. However, excavation was conducted during a time of dry weather and the berms were not needed. The water level in the wetland was below the ground surface and therefore the berm at the downstream limit of contaminated sediments was not needed to prevent water from the surrounding wetland from draining back into the area of sediment removal.

In order to facilitate the removal of sediments and wetland soils, the standing water within Areas A and C was removed and pumped through a particulate filter prior to discharge at a downstream location near Area B. Water was pumped at a maximum rate of 50 gallons per minute. A five by fifteen foot long bag constructed of non-woven geotextile was used as the particulate filter. Hay bales and silt fence were installed around the particulate filter bag to dissipate the energy of the water and prevent soil erosion or other disturbance of the wetland. The discharged water was sediment free and no erosion or wetland disturbance occurred during pumping activities. The minor amount of sediment that was retained by the bag filter was removed and combined with the excavated wetland soil for disposal.

The most upstream areas were excavated and removed first to ensure that downstream areas were not re-contaminated by the possible suspension and deposition of contaminated soils due to storm water flows. Accordingly, Areas A and B were excavated before starting Area C, and the excavation of Area C was conducted from north to south.

12004-456 3-2 Excavation equipment were supported on "Swamp Mats" to prevent disturbance of the underlying wetland soils. The Swamp Mats distribute the load of the equipment to decrease the bearing pressure thereby allowing the equipment to work on the surface of the soils without sinking.

Once excavated, the wetland sediments and soils were temporarily stockpiled within the area of excavation and allowed to gravity drain before stabilization and transportation for disposal. Lime was initially used as a stabilizing agent. However, the lime was difficult to manage and was not as effective as anticipated. Therefore, dry sawdust was selected as an alternative. Approximately 75 cubic yards of dry sawdust was mixed with the wetland soils and sediments immediately prior to loading the trucks for transportation. The sawdust successfully absorbed the excess water and prevented the development of free liquids during transportation.

Stabilization and direct loading of the trucks eliminated the need to stockpile the material in the parking lot for dewatering. Therefore, no water was generated and the need to treat the water was eliminated.

3.2.1 Field Observations

The wetland soil from Area C can be described as dark brown to black organic-rich silt and peat with abundant root mass from the cleared vegetation. Otherwise, the sediment that was excavated from Areas A and B can be described as brown silt and fine sands. Photographs of the excavated material can be found in Appendix A.

3.3 Sediment Disposal/Reuse

Prior to excavation, two in-situ 10-point composite samples of the soils and sediments were collected and analyzed at a laboratory for the purpose of chemical characterization for disposal. The samples were analyzed for TPH (Modified 8100), PCBs (EPA Method 8082), VOCs (EPA Method 8260), SVOCs (EPA Method 8270), arsenic, barium, cadmium, chromium, copper, lead, mercury, selenium, and zinc. The samples were also tested by Toxicity Characteristic Leaching Procedure (TCLP) to determine if the material is hazardous by characteristic for lead. The analytical parameters selected are listed in the Massachusetts Department of Environmental Protection Policy #COMM-97-001 as criteria for soil reuse at lined or unlined landfills. Results of the analyses indicated the concentrations of the constituents were below the maximum levels for reuse at Massachusetts lined or unlined landfills. Therefore, this material was accepted for daily cover use. The analytical laboratory report is included in Appendix D.

A total of approximately 520 cubic yards of wetland soils and sediment were excavated between September 8 and 10, 2004. The excavated soils and sawdust were trucked by Sam's Transportation, Inc. to the Fitchburg/Westminster Landfill operated by Waste Management, Inc. Transportation and disposal was documented using a MADEP Material Shipping Record & Log (Appendix E). Weight slips obtained from the disposal *0 facility indicate 392.45 tons of soil and sawdust was disposed at the landfill in 17 truckloads.

L2004-456 3-3 3.4 Backfilling and Site Restoration

The excavated wetland soils and sediments were replaced with 580 cubic yards of a high organic content compost material (Agresoil Wetland Soil produced by Agresource of Amesbury, Massachusetts). The imported compost material was temporarily stockpiled in the Equipment and Excavated Sediment/Soil Staging Area until placement. The stockpile was covered with a plastic tarp to prevent erosion and sedimentation.

Five samples of the imported compost material were collected and analyzed for metals, chlorinated herbicides, pesticides, and SVOCs prior to delivery to the Site to ensure that the levels of contaminants met the maximum concentrations allowed for backfilling. These maximum concentration values were developed by TRC, and correlate to background levels in "natural" soil (per MADEP guidance document). By meeting these criteria, all backfill used for the project would not pose a risk to the ecological receptors. Note that the background levels of cadmium, copper and zinc in soil are lower than the soil threshold levels for plants and invertebrates that were used in the Stage II ERC. Table 3-1 provides a summary of the criteria.

Table 3-1. Maximum Contaminant Concentrations for Imported Wetland Backfill Maximumn Concentration Contaminant (mg/kg) Antimony 1 Arsenic 20 0 Cadmium 2 Copper 40 Lead 100 Nickel 20 Selenium 0.5 Zinc 100 Acenaphthene 0.5 Acenaphthylene 0.5 Anthracene 1 Benzo(a)anthracene 2 Benzo(a)pyrene 2 Benzo(b)fluoranthene 2 Benzo(g,h,i)perylene 1 Benzo(k)fluoranthene 1 Chysene 2 Dibenzo(a,h)anthracene 0.5 Fluoranthene 4 Fluorene 1 Indeno(1,2,3-cd)pyrene 1 Methylnaphthalene,2 0.5 Naphthalene 0.5 Phenanthrene 3 Pyrene 4 Aldrin 0.03

12004-456 3-4 Table 3-1. Maximum Contaminant Concentrations for Imported Wetland Backfill Maximum Concentration Contaminant (mg/kg) Ganuna-BHC (Lindane) 0.1 Chlordane 1 4,4'-DDD 2 4,4'-DDE 2 4,4'-DDT 2 Dieldrin 0.03 Endosulfan I 20 Endosulfan II 20 Endrin 0.6 Heptachlor 0.1 Heptachlor Epoxide 0.06 Hexachlorobenzene 0.7 Methoxychlor 100

Results of the analyses indicate that the concentrations of the constituents analyzed were below the stipulated maximum concentrations shown in Table 3-1. Laboratory reports for this analysis are provided in Appendix F.

Further wetland disturbance and undesirable compaction of the soil was avoided by using a telescopic conveyor to place the compost. The conveyor was positioned on the upland edge of the wetland and the conveyor belt was extended (up to 110 feet) to precisely place the compost where needed.

The wetland floor was shaped to replicate the natural hummock-hollow topography observed throughout the wetland. The creation of the hummock-hollow microtopography provides a moisture gradient ranging from pools of standing water to drier hummock tops to support the varied microenvironments necessary to re-establish bog vegetation. The hummock-hollow topography was achieved by simply placing more compost in the areas of the hummocks (Figure 3-3). The height and depth of the hummocks and hollows were established relative to the Average Wetland Floor elevation, calculated to be 76.38 feet above ms] per the pre-excavation survey data.

Logs were uncovered during the wetland soil excavation and left at the surface for use as "nurse" logs in the wetland restoration. These provide a germination substrate for plant species and add a structural component for wildlife habitat

Topsoil seed and mulch were applied to all disturbed upland areas immediately after the wetland areas were backfilled. A fast growing annual rye grass seed with mulch was also applied by the hydro-seed method to Area C in order to establish a short-term, fast- growing grass to stabilize the hummocks against erosion.

The parking lot was swept clean prior to demobilization. The turbidity barrier around Area C and the hay bales and silt fence at the disturbed upland areas were left in place

L2004-456 3-5 until the wetlands restoration was complete and a sufficient stand of grass was established.

3.5 Wetland Restoration

As depicted in Figure 3-3, the restoration of Area C wetland was conducted on top of the re-established hummock-hollow terrain.

Prior to initiating the wetland restoration activities, a representative sample of the new wetland backfill was sent to the University of Massachusetts Soil and Plant Tissue Testing Laboratory for nutrient analysis. The results are presented in Appendix G. Per this analysis, TRC determined that the pH and nutrient levels were within the optimal range for plant growth. Therefore, adjustments via lime or fertilizer applications were unnecessary.

Wetland plant species were planted on October 5-8, 2004 by TRC personnel. In addition, assistance was provided by environmental studies students from the North Reading High School on October 8, 2004. Photographs of the student field trip and the hands-on wetlands restoration activity are provided in Appendix A.

The plants were purchased from New England Wetland Plants of Amherst, Massachusetts. Table 3-2 presents the species, number, size and spacing of the plants that were installed. Trees species include Acer rubrum (red maple). Shrub species include Vaccinium corymbosum (highbush blueberry), Rhododendron viscosum (swamp azalea), and flex verticillata(winterberry). Herbaceous species will include Onoclea sensibilis (sensitive fern), Osmunda cinnamomea (cinnamon fern), and Carex stricta (tussock sedge).

Table 3-2. Number of Trees, Shrub, Pterophyte, and Sedge Species Genus and Species Common Name Number Size Spacing (ft.) Tree Species Acer rubrum red maple 10 3-4 ft 20-30 Shrub Species Vaccinium corymbosum highbush blueberry 20 18-24 in. 5-10 Rhododendron viscosum I swamp azalea 20 18-24 in. 5-10 flex verticillata winterberry 20 18-24 in. 5-10 Pterophyte Species Osmunda cinnamomea cinnamon fern 100 1 gallon N/A container clumped Onoclea sensibilis sensitive fern 100 1 gallon N/A container clumped Sedge Species Carex stricta tussock sedge 100 2 in. plug N/A clump ed TOTAL 370

The shrub and sapling species were installed on the uppermost elevations on the hummocks, while the pterophytes (fern) and sedge species were installed on the intermediate and low hummock elevations (Figure 3-3). In addition to these species, an

L2004-456 3-6 herbaceous wetland seed mix was planted to aid in minimizing erosion and restricting the development of invasive plant species recruited from adjacent wetland areas. This seed mix contained the following species:

o Fringed Sedge (Carex crinata) o Bearded Sedge (Carex comosa) o Canada Manna Grass (Glyceria canadensis) o Lurid sedge (Carex lurida) o Blue vervain (Verbena hastata) o Green bulrush (Scirpus atrovirens) o Woolgrass (Scirpus cyperinus) o Joe-pye weed (Eupatoriadelphusmaculatus) o Chufa (Cyperus esculentus) o Hop sedge (Carex lupulina) o Boneset (Eupatoriumperfoliatum) o Red-Top panic grass (Panicum rigidulum)

The different species contained in this mix can tolerate some variation in the hydroperiod. Therefore, despite local variability in inundation regimes/topography, some or a number of different wetland plants within the seed mix will cover all of the restoration area. The emergent-dominated wetland plant community was selected to effectively out-compete purple loosestrife (Lythrum salicaria)and other invasive plant species.

The seed mix was applied via hand-broadcasting in September, 2004 at the recommended application rate for a wet meadow of 1lb/2500 SF.

L2004-456 3.7 4.0 LONG-TERM MONITORING AND MAINTENANCE FOR WETLAND RESTORATION

In accordance with the requirements set forth by the 401 WQC, TRC will monitor Area C for 5 years to: 1) ensure that the newly planted wetland species successfully grow, 2) control invasive species, and 3) replace plants as needed to ensure complete restoration of the area.

Specific requirements of the program include the following:

1) Control of nuisance species must be maintained for the 5-year monitoring period.

o If the occurrence is no greater than 100 stems per acre, individual species must be hand pulled, including roots, before the end of the flowering season. Plants must be removed and appropriately burned, or disposed of as an approved waste facility.

o If the occurrence becomes greater than 100 stems per acre, hand application of RODEO*, or comparable herbicide (as recommended by the Regulatory Branch of the New England ACOE) can be used. Written approval from the landowner and the MADEP must be obtained prior to application.

2) Photographic stations must be selected in the restoration area to document preexisting baseline conditions, and each subsequent monitoring inspection.

3) Monitoring Reports must be submitted twice each growing season:

o First report covers the beginning of the growing season submitted no later than July 30' o Second report covers the end of the growing season submitted no later than November 30"

4) Monitoring reports must include:

o Vegetation mapping; o A plant species list; and o Photographs documenting the extent of vegetation.

The wetland restoration will be considered successful by the MADEP if the wetland species supports 80 percent total cover with native species, and if invasive species (i.e., common and purple loosestrife) are not present.

If invasive species remain in the wetland restoration area at the end of the 5-year monitoring period, a letter must be sent to the MADEP requesting that the department make a determination that no further action be required and that the wetland restoration is complete.

L2004-456 4-1 4.1 Photographic Stations

To visually document plant community development and demonstrate conformance with the performance standards outlined in the Massachusetts Wetlands ProtectionAct 310 CMR 10.55(4)(b)(1-7), three photographic stations have been established within the wetland restoration area (Figure 4-1).

Prior to excavating the wetland soils TRC established the baseline conditions of the wetland. Within the footprint of the soil/sediment excavation, a dense stand of giant reed (Phragmitesaustralis) and purple loosestrife (Lythrum salicaria)was present. Intermixed with the giant reed stand were scattered red maple (Acer rubrum) stems. It is worth noting that the red maple stems were all dead at the time of the initial field visit.

Soils and sediments observed within the area of the soil/sediment excavation are classified as istosols, which are thick, organic soils colloquially referred to as peats or mucks. These organic soils approach nine feet in depth within the vicinity of the excavation footprint and have been mapped the Natural Resource Conservation Service (NRCS) as a Freetown muck. Photographs of the baseline conditions are presented in Appendix H.

4.2 Sampling Protocol

Quantitative sampling of the wetland plant community will also be undertaken using the techniques illustrated below. A single linear transect will be established that spans the entire width of the restoration area and intersects all environmental gradients. See Figure 4-1 for location of the sampling transect. Each end of the transect will be marked with a permanent wooden stake. Along the transect, 25cm x 50cm rectangular quadrats will be positioned at regular intervals and which will also be marked in the field. The same plots will be used during the second sampling season. In this manner, changes in plant percent cover and species composition over the five growing seasons can be accurately determined.

Percent cover will be determined by visually estimating both plant percent cover and the percent cover of bare substrate within each 25cm x 50cm rectangular quadrat. Once these data have been collected, each plant species encountered will be lumped into its respective USFWS indicator status category. Relative percent cover will be determined by simply dividing the percent cover total for a given class by the total percent cover for all species and bare space combined. In addition, the position of each plant species with respect to elevation above the water table will be recorded. The three qualitative elevation classes will include hummock, intermediate, and hollow.

All data will be recorded onto field data forms and then entered into EXCEL for subsequent analysis. Copies of the field data forms are provided in Appendix .

L2004-456 4-2 4.3 Reporting

The results of the data collection over the five seasons will be presented in a technical memorandum (two each year) and will make assessments demonstrating conformance with the performance standards enumerated in the Massachusetts Wetlands ProtectionAct 310 CMR 10.55(4)(b)(1-7).

L2004-456 4-3 5.0 SUMMARY OF DEVIATIONS OF SIGNIFICANT MODIFICATIONS FROM REMEDY iMPLEMENTATION PLAN

A summary of all significant deviations from the Phase IV RIP is provided below. Details of each are described in the previous sections.

o Excavation: Sediments were excavated to a depth of one foot from the lowest point measured in Area C. This ensured that a minimum of one-foot removal of sediment was achieved in all sections of Area C.

o Excavated Material Staging and Dewatering: The removed sediment was temporary stockpiled within the area of excavation and allowed to gravity drain before stabilization and disposal. Stabilizing agents included lime and sawdust.

L2004-456 5-1 6.0 PHASE IV COMPLETION

This report fulfills the MCP requirements for both the As-Built Construction Report and Final Inspection Report under 310 CMR 40.0875 and 40.0878. As discussed in the previous sections, the activities completed for the wetlands portion of the site were in accordance with the Wetlands RIP. The objective of the RIP was to remove metals-contaminated soils and sediments that could have a potential impact to ecological receptors. This objective was achieved as the soil and sediments that could affect the receptors were removed and replaced with a new clean backfill material. A condition of no significant risk now exists in the wetlands for the ecological receptors; a condition of no significant risk for human health had already existed. As such, the wetlands sediments have been remediated to a level that would allow unrestricted use without an Activity and Use Limitation.

Because of the achievement of the RIP goals, MCP Phase IV response actions for the wetlands portion of the site are considered to be complete with the submission of this report. No other response actions are required for the wetlands.

L2004-456 6-1 7.0 PARTIAL RESPONSE ACTION OUTCOME STATEMENT

7.1 LSP Opinion

A Partial Class A-2 RAO has been achieved for the wetlands soil and sediments portion of the Former GE site, based on and in accordance with the following (310 CMR 40.1035 & 310 CMR 40.1036):

o The source of oil and hazardous material on-site, resulting in the release to the wetlands has been controlled:

o Wetland soil and sediments significantly impacting receptors have been removed from the site;

o A Permanent Solution has been achieved;

o The levels of oil and hazardous material remaining in the wetlands do not result in a Condition of Significant Risk;

o Activity and Use Limitations are not required to maintain a Condition of No Significant Risk; and,

o An Operations and Maintenance system is not required to maintain a Condition of No Significant Risk

7.2 Feasibility of Achieving or Approaching Background

All sediments in Areas A and B were removed, and with it, all corresponding contamination. Therefore, the remediation resulted in achieving or approaching background in those areas. Sediments and soil in Area C were excavated to a depth of one-foot to remove the elevated metals concentrations. This top one-foot zone exceeded the limit of exposure for ecological receptors (i.e., 6 inches). The remaining sediments beneath the one- foot depth as well as soil and sediment downgradient of Area C did not pose a significant risk to ecological receptors. No data was collected beneath the one-foot depth in Area C, but previous investigations did indicate that metals were present at lower concentrations downgradient of Area C.

The downgradient extent for background purposes was never defined for Area C, but based on the existing data, the excavation would have to be expanded at least three times the size of Area C in order to achieve or approach background. Such excavation would disrupt a significant portion of the wetland area (minimum of three acres). Currently, the wetlands area is at a Condition of No Significant Risk to both human health and the environment. Additional excavation to achieve background would not result in a significant level of risk reduction. Therefore, additional remediation to achieve or approach background in the wetlands is not warranted or justified.

L2004-456 7-1 FEGURES

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1 1 APPEND]IX A

Photographs

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Phoio 1 \Iw of I wilandS prior to reCdiTAiIon acinI ihes. with1 purpIc lI I 111iI I I' reground

Photo 2 invasive species prcsent prior to renediation aciv ities (purple loosri fe and giantL reed) Photo 3 laSve speciere precIot pnior to retnedtluou actviies (gian reed)

PhoIo I ClearinIg ot Ara L II CI l5 N hh , riiai C i Areai C ( LS I lil p )t Ica 'qu ipllLl I

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Phoo E0 Timeer and sovnpi mat in Area C ucd to suppon heavy equipment). Phioto 7 'iew ofultLiill 0(2 Ar.M A, w illl smlii1W 4Iew ilerLItg.

Photo X of Seditneal :wd Erosion Controk along edgLe tf park ing Iot Photo 9 Vw o1 dwatero1, dilha rc point wih se.dimnit and erosion cOr

Photo I V e of dewarering disharg p It wiih sediment and erosi)n cinii l Photo [ I - V1w oU AiL'I U w ith cu1t;|i|11it h Iri pwLICe

Photo 12 Vew 0l Area C ruIth corLnmecni him aloiIg pe[inhr, Anld iu e sake in i0rcground. Photo 13 ()utItil 0U2 Arl.. A

Pholo 14 Iilnal e aitva ie actl tiic. in ArC (. Sun eymng used to conifirmi exavitioon depthIi. Photo 15 Con amued exetvat t Lof Area C.

Phot ki I6 Clo-up vicw of excavatld soil anil pcat froi Aret ( Pht 17 ( C~ nnIed ezxcI aLion of Area C. with stckpihnirg 1i drainW free liquids.

PhEo 18 ~ xcus anoIn and Murveying of OutCrlil 0(2 Area A Photo 19 - Arei C excavation looking eaVt

Photo 20 - Area A looking east Photo 21 Area C during cxcaivat-iol

Photo 22 - I cavated potion of Arci ( Photo 23 - E xcavaeId wthcod soils

Photo 24 - E xcavation of Arca C Photo 25 - Ioading wet Lad soil onto truck I(r dI.posIl

Photo 26 - Loading wetland soil onto nick Plio 7o 27 L I dirIIL wet L~t id 0

10(IO 28 - SaWdtst iLsed t0r Weo tid soil slabilia n Photo 29 Truck prepar ng to be loaded

Photo 30( - View of Arca B looking cast ......

Photo 31 - Covered s kokpiIc of imported wetIand back ill

Photo 32 - Imported weland backfil Phloto 33 TIscoupic convCOr for pLaCmg backtill

Photo 3-1 Luading hoppcr of 1elecupie cons eyor Phot kI - umocks du rig placeImCnt of balc k i

Phoo6Pacgjol.4 ,. Phuo 36 Placijig weiland backfi1I Photo 37 Controlf cons' eve or

PIlioto 38 raIng hutiock in wciland Photo 39 - PLacing backil[

Photo 40 - 1 oading hpper PhIot 41 - Backlilled wI ind area with hydrosccd

Photo 42 Area H ater backlili and hydroseed PhAto 43 - Renial ofihayhales after swcping parking lot cIrl

Photo 44 - North Reading If gh School studenits asimstig wi(h we land plant insIallation Photo 45 - Nonh Read Ig ligh School tudnCt APPENDI[X B

Permit Applications, Notifications, Certificates and Approvals

L2004-456 FORMER GE SITE

LIMITED WETLAND SOIL REMOVAL AND RESTORATION PROJECT 50 Fordham Road North Reading, MA 01887

REGULATORY REQUIREMENTS SUMMARY

The Limited Soil Removal and Restoration Project requires excavation and fill activities in a regulated wetland. These activities have been authorized under several regulatory jurisdictions with environmental permit conditions, including a:

> Order of Conditions from the North Reading Conservation Commission > Category II Programmatic General Permit (PGP) from the Army Corps of Engineers, and a, > State Water Quality Certification from the MA Department of Environmental Protection (DEP); including the technical letter issued to Derek Standish, DEP dated May 27, 2004 concerning the approach to water handling during construction.

The following summarizes the principal environmental permit conditions for the project. These conditions must be followed by the Contractor(s) to be in compliance with the project permit authorizations and the project Contract. Copies of all permit applications and permit authorizations will be provided to the Contractor by TRC in a Permit Notebook to kept on site during all activities.

PRE-CONSTRUCTION REQUIREMENTS

> Notifications - The Town of North Reading Conservation Commission (NRCC) must be notified in writing at least 48 hours in advance of any activity on the site. The NRCC must be given proof that the Order of Conditions has been recorded at the Registry of Deeds. Also, the DEP must be contacted by TRC and given the name, address, and phone number(s) of the person responsible for ensuring that all work complies with the Conditions of the Water Quality Certification and the Order of Conditions. > Erosion Control - A staked hay bale line shall be placed along the "limits of clearing" shown on the project Plans (Figure 2A) prior to any excavation. > DEP File No. - A 2 x 3-foot sign must be posted on the site indicating the DEP File number (#245-1029) prior to start of work activities. > Permits - A copy of all permit authorizations and the Notice of Intent with plans ah and restoration protocol shall be kept on site at all times by the site Supervisor.

L2004-456 DURING CONSTRUCTION REQUIREMENTS

> No stockpiles of material shall be stored within 100 feet of the wetland on the site.

> Hay bales and any other erosion controls shall be properly and continuously maintained until all disturbed areas have been permanently stabilized.

> Exposed soil surfaces shall be temporarily stabilized daily with straw or jute mesh until soil is permanently stabilized.

> Equipment operation in the wetland shall be performed on "swamp mats" or similar material so as to avoid rutting and incidental excavation of wetland areas.

> Mud and other loose soil tracked of swamp mats and on to pavement shall be swept or otherwise removed daily to avoid runoff into wetlands.

> Storage, maintenance or refueling of machinery is not permitted within 100-feet of the wetland.

> If a release of oil, grease, or hydraulic fluid, or any hazardous material occurs, TRC shall be contacted immediately. TRC will coordinate contacting the NRCC, the North Reading and the site facility hazardous coordinator immediately following any release.

> If additional "contaminated soil" is discovered, it shall be removed after verbal notification is given to the DEP by TRC. Following verbal notification, a letter and supplemental plan shall be sent to the DEP describing the extent and location of the additional contaminated soil. The area from which the contaminated soil is removed shall be restored according to the same plan and protocol specified in the Notice of Intent Application.

POST-CONSTRUCTION REQUIREMENTS

> All disturbed soils shall be permanently stabilized with a wetland seed mix specified by TRC and applied with cellulose hydroseed application and/or winter rye seed.

> Upon completion of the project, a registered P.E. shall certify and in writing that all work has been completed in accordance with the NRCC Order of Conditions.

L2004-456 Customer-Focused Solutions

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Notice of Intent

Former GE Site Limited Removal of Wetland Soil/Sediment and Restorationof Approxinately 0.2 Acres of Wetland Wilmington/North Reading, MA WOice OflTentq

Or accordance with the Massachusetts Wetlands Protection Act 310 CM R 10.00 et seq. and the Town of North Reading General Wetlands Protection By-Law

Former GE Site Contaminated Wetland Sediment/SoigD emova and Wetland Restoration North Reading, Massachusetts

Submitted to: North Reading Conservation Commission

Prepared by:

TRC Environmental Corporation Boott Mills South, Foot of John Street Lowell, Massachusetts 01852

January 2004 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of Ontent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Cityrrown A. General information

1. Project Location (Note: electronic filers will crick on button for GIS locator): 50 Fordham Road North Reading 01887 a. Steet Address b. CyTown c. Zip Code Latitude and Longitude, if Known: 423338 710810 CL Latitude 0, Longitude Map 2 Parcel 12 I. Assessors Map/lat Number -g. Parcel /Lot Number nportant: iLhenfilling out 2. Applicant >rms on the Paola Macchiaroli omputer, use TRC Environmental Corporation (TRC) nly the tab a. First Name b. Last Nane c.Company ey to move 31 Milk Street. 11th Floor our cursor - d. Mainng Address o not use the Boston MA 02109 -tum key. e. Citfrown f. State g. Zip Code (617) 350-3444 (617) 350-3443 [email protected] h. Phone Number L Fax Number J. Email address 3. Property owner (if different from applicant): ICheck if more than one owner Frank . Bomba Wilmington Realty Trust a. First Name b. Last Name c.Conpany 424 Broadway d. Maling Address lote: Somerville MA 02145 efore a. Cityrrown f. state g.Zip Code ompleting this 617 666-2600x222 -M )rm consult h. Phone Number L Fax Number -. Emai address our local onservatlon . 4. Representative (if any): ommission TRC Environmental Corporation (TAC) .garding any a. Firm iunicipal bylaw Paola Macchiaroli r ordinance, b. Contact Person Fist Name c. Contact Person Last Name 31 Milk Street, 11" Floor d. Mailing Address Boston MA 02109 e. CtyTown f.State g.Zip Code (617) 350-3444e (617) 350-3443 [email protected] h. Phone Number i. Fax Number J.Emal address 2 select if )u want to see 5. Total WPA Fee Paid (from Appendix A, Wetland Fee Transmittal Form): fetland Fee 525.00 250.00 275.00 ransmittal a.Total Fee Paid b. State Fee Paki c. Cftyfrown Fee Paid arm. 6. General Project Description: This project will Involve the removal of approximately 350.0 cubic yards of metals contaminated 0 wetland sediment/soil and the in-situ restoration of 9,637.8 square feet of disturbed wetland within the excavation footprint puterdoc -R*ePaes Pago 1 a Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of Intent - 1 Massachusetts Wetlands Protection Act M.G..L c. 131, §40 - ciyrown A. Genera Information (continued)

7. Project Type Checklist:

a. Single Family Home

b. Residential Subdivision

c. Limited Project Driveway Crossing d. [ Commercialindustrial

e. 0 Dock/Pier

J. Utilities

g. 0Coastal Engineering Structure

h. Agriculture - cranberries, forestry

i. 0Transportation i:- 0 Other

8. Property recorded at the Registry of Deeds for Middlesex a. County 102 b. Book 83 c. Page Number 19842 d. Certiscate # (if registerdland) 9. Buffer Zone Only is the project located only in the Buffer Zone of a bordering vegetated wetland, Inland bank, or coastal bank, coastal beach, coastal dune, or salt marsh? a. O Yes If yes, skip to Section C.

b. -No if no, check the resource areas to be affected by this project, directly below.

pakNwaaC mt. Pag20of2 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3"- Notice of ntent Massachusetts Wetlands Protection Act M.G.L c. 131, §40 ctyrro. B. Resource Area Effects 1. Inland Resource Areas

Check all that apply below. Attach narrative and any supporting documentation describing how the project will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location. nilne Users: clude your Resource Area Size of Proposed Alteration Proposed Replacement (fi any) >cument a. ansaction Bank -1. near feet 2. rmear feet imber b. | Bordering Vegetated 9, 637.8 (temporary impact) 9,637.8 (restored in-situ) 'rovided on Wetland 1.square feet 2. square feet >ur receipt age) with all .c. I Land Under 1.square feet 2. square feet ipplementary Waterbodles and formation you Waterways 3 cubic yards dredged ibmit to the apartment. d. ] Bordering Land - Subject to Flooding 1.square feet 2. square feet

3. cubic feet of flood storage lost 4. cubic feet of food storage replaced e. LI Isolated Land Subject to Flooding 1. square feet

2. cubic feet of flood storage lost 3. cubic feet of flood storage replaced f [1 Riverfront area

1. Name of Waterway (if available):

2. Width of Riverfront Area (check one):

25 ft. - Designated Densely Developed Areas only

S100Lft - New agricultural projects only o 200 ft. - All other projects

3.Total area of Riverfront Area on the site of the proposed project:

Square Feet 4. Proposed alteration of the Riverfront Area:

a. Total Square Feet b. Square Feet within 100 ft. c. Square Feet between 100 it.and 200 ft. s. Has an atematives analysis been done and is it attached to this NOI? O Yes 5 No

s. Was the lot where the activity Is proposed created prior to August 1, 1998?. Yes [ No aoromed- m. 05M Pens SdS Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of ntent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 11 M cityrrown B. Resource Area Effects (continued)

2. Coastal Resource Areas:

Check all that apply below. Attach narrative and supporting documentation describing how the. project will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location. )nline Users: iclude your Resource Area - Size of Proposed Alteration Proposed Replacement fit any) ocument .ansaction a.E] Designated Port Areas Indicate size under Land Under the Ocean, below umber b . L and Under the fCnan >rovided on 1. square f our receipt age) with all 2. Cubic yards dredged upplementary Indicate size under Coastal Beaches and/or Coastal Dunes formation you c.Q Barrier Beach ubmit to the below Iepartment d.fJ Coastal Beaches 1. Square feet 2. Cubic yards beach nourishment Coastal Dunes 1. Square feet 2. Cubic yards dune nourishment

1. El Coastal Banks 1.thisarfed Rocky Intertidal Shores g.0 1. Square feet Salt Marshes 1. Square feet 2. Sq fit restomation, rehab., or creation Land Under Salt Ponds 1.Square feet

2. Cubic yards dredged Land Containing Shellfish 1. Square feet 2. Square feet rsoration, rehab. A.O Fish Runs Indicate size under Coastal Banks, inland Bank, Land Under the Ocean, and/or inland Land Under Waterbodies and Waterways, above

1. Cubic yards dredged i. [I Land Subject to Coastal Storm Flowage - 1. Square feet

3. Limited Project: Is any portion of the proposed activity eligible to be treated as a limited project subject to 310 CMR 10.24 or 310 CMR 10.53? a. 0 Yes [I No If yes, describe which ronited project applies to this project: 310 CMR 10.53 (q) Assessment, monitoring, containment, mitigation, and remediation of the release of a hazardous material. emane ew M-o PgUetS Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of ntent 11Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 cutyrrown C. Bordering Vegetated Wetland Delineation Methodology

Check all methods used to delineate the Bordering Vegetated Wetland (BVW) boundary: inline Users: i. [ Final Order of Resource Area Delineation issued by Conservation Commission or DEP iclude your (attached) ocument ansaction .2. DEP BVW Field Data Form (attached) umber rovided on 3.0 Final Detennination of Applicability issued by Conservation Commission or DEP (attached) :ur receipt age) with all 4. O Other Methods for Determining the BVW Boundary (attach documentation): upplementary iformation you a. N 50% or more wetland indicator plants ubmit to the epartment. b. N Saturated/inundated conditions exist

c. 0 Groundwater indicators

d. Direct observation Dr all projectsr e. O Hydric soil indicators ' other *9 ease f- Credible evidence of conditions prior to disturbance tach a irrative cplaining how a resource ea was lineated. D. Other Applicable Standards and Requirements

1. Is any portion of the proposed project located in estimated habitat as Indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetland Wildlife published by the-Natural Heritage and Endangered Species Program?

a. Q Yes 0 No If yes, Include proof of mailing or hand delivery of NOI to: Natural Heritage and Endangered Species Program Division of Fisheries and Wildlife Route 135, North Drive Westborough, MA 01581 12/31, 2001 (Figures 4 and 5). Checked against July 2003 digital maps. b. Date of Map

2. For coastal projects only, is any portion of the proposed project located below the mean high water line or in a fish run? 0 Yes [ No If yes, include proof of mailing or hand delivery of NOI to: Massachusetts Division of Marine Fisheries 251 Causeway Street, Suite 400 Boston, MA 02114 . 0 Not applicable - project is in Inland resource area only

mftdoc"*MV.- off= neps r Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of intent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 * cityrrown D. Other Applicable Standards and Requirements (continued)

3. Is any portion of the proposed project within an Area of Critical Environmental Concern (ACEC)? If yes, proyide name of ACEC (see instructions to WPA Form 3 or DEP a- Yes . No ] Website for ACEC locations). Note: electronic filers click on Website.

b. ACEC

nllne Users: 4.. is any portion of the site subject to a Wetlands Restriction Order under the Inland Wetlands icude your Restriction Act (M.G.L c. 131, § 40A) or the Coastal Wetlands Restriction Act (M.G.L c. 130, § 105)? ocument ansaction a. IYes ONo umber' >rovided on >ur receipt 5. Is any activity within any Resource Area or Buffer Zone exempt from performance standards of the age) with all wetlands regulations, 310 CMR 10.00. ipplementary formation you a. [] Yes N No . If yes, describe which exemption applies to this project ibmit to the efpent. b. Exemption

6. Is this project subject to the DEP Stormwater Policy? a. 0 Yes N No b). If yes, stormwater management measures are required. Applicants should complete Appendix B: Stormwater Management Form and submit it with this form. c If no, explain why the project Is exempt: No creation of impervious areas. Runoff coefficents will remain unchanged upon completion of project.

E. Additional Information

Applicants must include the following with this Notice of Intent (NOI). See instructions for details. Online Users: Attach the document transaction number (provided on your receipt page) for any of the following information you submit to the Department

i. N USGS or other map of the area (along with a narrative description, if necessary) containing sufficient information for the Conservation Commission and the Department to locate the site. (Electronic filers may.omit this item.)

2. O Plans identifying the location of proposed activities (including activities proposed to serve as a Bordering Vegetated Wetland [BVWJ replication area or other mitigating measure) relative to the boundaries of each affected resource area.

pakmatke ft RD M Pae e Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of intent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 city/rown E. Additional Information (continued) , a 0 Other material identifying and explaining the determination of resource area boundaries shown-on plans (e.g., a DEP BVW Field Data Form). )nline Users: nclude your 4.0 Ust the titles and dates for all plans and other materials submitted with this NOI. locument 5.5 If there is more than one property owner, please attach a list of these property owners not ransaction listed on this form. iumber provided on e. Attach proof of mailing for Natural Heritage and Endangered Species Program, if needed. our receipt age) with all 7 Attach proof of mailing for Massachusetts Division of Marine Fisheries, if needed. upplementary iformation you .0 Attach Appendix A, see next page. ubmit to the )epartment. 9. Attach Appendix B, if needed.

F. Fees The fees for work proposed under each Notice of Intent must be calculated and submitted to the Conservation Commission and the Department (see Instructions and Appendix B. Wetland Fee Transmittal Form).

No fee shall be assessed for projects of the federal government the Department, or cities and towns of the Commonwealth.

Applicants must submit the following information (in addition to pages 1 and 2 of Appendix B) to confirm fee payment:

1797 12130/03 1. M- a Check Number 2. Check date 1796 12/30/03 3. State Check Nurnber 4. Check date TRC MacNeill 5. Payor name on chedc Frst Name 6. Payor name on chec Last Name

p~onOdoe POW7098 -Pem7 cia Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 3 - Notice of ntent Massachusetts Wetlands Protection Act M.G.L c. 131, §40 cayrrown G. Signatures and Submittal Requirements I hereby certify under the penalties of perjury that the foregoing Notice of Intent and accompanying plans, documents, and supporting data are true and complete to the best of my knowledge. I understand that the Conservation Commission will place notification of this Notice in a local newspaper at the expense of the applicant in accordance with the wetlands regulations, 310 CMR 10.05(5)(a).

I further certify under penalties of perjury that all abutters were notified of this application, pursuant to the remne of M.G.L , 40. Notice must be made in writing by hand delivery or certified mail (return ipt requesed) to all a ers within 100 feet of the property line of project location.

Signature of at

Signature of Property r (if diffe&i Data

- Signature of Representative (if any) Dale

For Conservation Commission: Two copies of the completed Notice of Intent (Form 3), Including supporting plans and documents; two copies of pages 1 and 2 of Appendix B; and the city/town fee payment must be sent to the Conservation Commission by certified -mail or hand delivery.

For DEP: One copy of the completed Notice of Intent (Form 3), Including supporting plans and documents; one copy of pages 1 and 2 of Appendix B; and a copy of the state fee payment must be sent to the DEP Regional Office (see instructions) by certified mail or hand delivery. (E-filers may submit these electronically.)

Other. If the applicant has checked the 'yes" box In any part of Section D, Item 3, above, refer to that section and the Instructions for additional submittal requirements.

The original and copies must be sent simultaneously. Failure by the applicant to send copies in a timely manner may result in dismissal of the Notice of Intent.

adomGd* w ea06g 5 Page at Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Appendix A - Wetland Fee Transmitta Form Massachusetts Wetlands Protection Act M.G.L c. 131, §40 uportant: A. Applicant Information then filling out ams on the - 1. Applicant: orputer, use nIy the tab Paola Macchiaroli TRC Environmental Corp. ey to move a. First Name b. Last Name c. Company 31 Milt, our cursor - reet, 11I Floor o not use the d. Mailing Address .tum key. Boston MA 02109 e. cityfrown f. State g. Zip code (617) 350-3444 h. Phone Number 2. Property Owner (if different): Frank Bomba Wilmington Realty Trust a. First Name b; Last Name c. company 424 Broadway d. Mailing Address Somerville MA 02145 e. cityrrown f. State g. Zip Code 617-66-2600 x 222 h. Phone Number 3. -Project Location: 50 Fordham Road North Reading a. Street Address b. Cityrown

>calculate ing fees, refer B. Fees the category Notice of Intent (Form 3) or Abbreviated Notice of e ist and Intent (Form 4): ,amples In )ction D of The fee should be calculated using the following six-step process and worksheet. Please see is fomt. Instructions before fillingout worksheet

Step 1fype of Activity: Describe each Wye of actiit that will occur in wetland resource area and buffer zone.

Step 2/Number of Activities: Identify the number of each type of activity.

Step 3ilndividual Activity Fee: Identify each activity fee from the six project categories listed in the instructions.

Step 4/Subtotal Activity Fee: Multiply the number of activities (identified in Step 2) times the fee per category (identified in Step 3) to reach a subtotal fee amount. Note: If any of these activities are In a Riverfront Area In addition to another Resource Area or the Buffer Zone, the fee per activity should be multiplied by 1.5 and then added to the subtotal amount.

Step 5/Total Project Fee: Determine the total project fee by adding the subtotal amounts from Step 4. Step 6/Fee Payments: To calculate the state share of the fee, divide the total fee in half and subtract $12.50. To calculate the city/town share of the fee, divide the total fee in half and add $12.50.

uOrn.doc=Appeni B* mcV124 Pago I s3 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Appendix A - Wetland Fee Transmittal Form Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Fees (continued) Step 1/rype of Activity Step 2/Number Step Step 4/Subtotal Activity of Activities 3/individual Fee Activity Fee

Hazardous Waste Cleanup 1 525.00 525.00

E Step &rotal Project Fee: 525.00 Step 6/Fee Payments: 525.00 Total Project Fee: a.To fee from step s 250.00 State share of filing fee: b. 1/2 totafee less $12.50 City/Town 275.00 share of filling fee m.U/2tota fee plus $12.5 Abbreviated Notice of Resource Area Delineation (Form 4A):

The fee Is calculated as follows (check applicable project type): 1. E single family house project a.feet of Bvw x$1.o= i. Total fee not to exceed $1,000 2 - al] other - projects a.feet of BVW x$1.0O= P.Total fee not to exceed $1,000 State share of filing fee: . 1/2 of total fee less $12.50 City/rown share of filing fee: 4 4.1/2 of total fee plus $12.50

paminldoc- Appendx Be rwv. 2/3tW Paae2cd3 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Appendix A - Wetland Fee Transmittal Form Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 C. Submittal Requirements

a.) Complete pages 1 and 2 and send with a check or money order for the state share of the fee, payable to the Commonwealth of Massachusetts.

Department of Environmental Protection Box 4062 Boston, MA 02211

b.) To the Conservation Commission: Send the Notice of Intent, Abbreviated Notice of Intent, or . Abbreviated Notice of Resource Area Delineation; a copy of pages 1 and 2 of this form; and the city/town fe, payment.

c.) To DEP Regional Office (see Instructions): Send the Notice of Intent, Abbreviated Notice of Intent, or Abbreviated Notice of Resource Area Delineation; a copy of pages 1 and 2 of this form; and a copy of the state fee payment (E-filers of Notices of Intent may Submit these electronically.)

ffrn.doc * AppendiBo rev. 120M Page3013 FormerGE Site Remediation and Monitoring Progrwn NOIAbutters List

ABUTTER NOTE h[CATION

I - AFFIDAVIT OF SERVICE

Under the Massachusetts Wetlands Protection Act

I, Paola E. Macchiaroli, PhD., hereby certify under the pains and penalties of pejury, that on January 5, 2004 1 gave notification by certified mail, return receipt requested, to abutters in compliance with the second paragraph of Massachusetts General Laws Chapter 131, Section 40, and the DEP Guide to Abutter Notification dated April 8,1994, in connection with the following matter

A Notice of Intent (NO) filed under the Massachusetts Wetlands Protection Act and the Town of North Reading General Wetlands Protection By-Law by TRC Environmental Corporation with the North Reading Conservation Commission on January 13,2004 for work associated with a property located at 50 Fordham Road. The proposed work is located in the Town of North Reading.

The form of the notification, and a list of the abutters to whom it was given and their addresses, are attached to this Affidavit of Service. Customer-FocusedSolutions

January 5, 2004

To: An Abuttes to the Proposed Contaminated Sediment/Soil Removal and Wetland Restoration Project at the Former General Electric (GE) Site (RTN 3-0518), North Reading, Massachusetts

Subject: Public Hearing regarding the Notice of Intent (NOI)

Dear Property Owner

This letter is to notify you that there will be a public hearing on January 13, 2004 regarding a Notice of Intent (NOI) filed in accordance with the Massachusetts Wetlands Protection Act and North Reading General Wetlands Protection By-law for the proposed removal of approximately 350 cubic yards of contaminated wetland sediment/soil and the restoration of the wetland disturbed by the excavation. The work will be performed on a portion of the Former GE Facility (Site) located at 50 Fordham Road in Wilmington, Massachusetts that extends into North Reading, Massachusetts. The proposed activity is being conducted as part of a site remediation at the former GE facility per the Massachusetts Contingency Plan (MCP).

If you have any questions, feel free to contact me at (617) 350-9997 or by email at [email protected]. If you wish to inspect a copy of the NOI for the proposed project, you may do so at the office of the Conservation Commission located in the North Reading Town Hall.

Sincerely

Paola E. Macchiaroli, Ph.D. Senior Project Manager cc: Amanda DeSantis - Lockheed Martin Corporation Gail Rymer - Lockheed Martin Corporation Jennifer Eck MeWeeney - MA DEP Frank Dardeno - Council for Wilmington Realty Trust

Boon Mts Sou, Foot of John Skeet e towel, Massochusefs 01852 Telephone 978-970-5600 - Fx 978453-1995 0 FonerGE Site Remediation and Monitoring Program NOIAbutters List

TOWN OF NORTH READING

CERTWIED LIST OF ABUTTERS (Certified December 9,2003)

1. Terminal Land and Building Corporation 1077 Gorge Boulevarde PO Box 471 Akron, OH 44309

2. One Fordham Road, LLC c/o Deloitte & Touche LLP PO Box 1282 Boston;MA 02117

3. Wilmington Realty Trust c/o Ametek Aerospace W 50 Fordham Road Wilmington, MA 01887

4. Town of North Reading Stickney Pumping Station/Water Department 235 North Street North Reading, Massachusetts 01864 FormerGE Site Remediation and MonitoringProgram NO] Supplementary Narrative

ATTACHMENT A

NOTICE OF INTENT (NO) SUPPLEMENTARY NARRATIVE FormerGE Site Remedialion and MonitoringProgram NOI Supplementary Narrative

TABLE OF CONTENTS

1.0 INTRODUCTION...... 1

2.0 BORDERING VEGETATED WETLAND (BVW) CHARACTERIZATION...... 2 2.1 Bordering Vegetated Wetland (BVW) Boundary Methodology...... 2 2.1.1 Survey of Wetland Boundary...... 2 2.2 Wetland Delineation Results...... 2

3.0 - RARE, THREATENED, AND ENDANGERED SPECIES......

4.0 ECOLOGICAL RISK CHARACTERIZATION ...... 4 4.1 Amphibians...... 4 4.2 Benthic Macroinvertebrates...... 4 4.3 Plants...... 5 4A Terrestrial Invertebrate Community...... 5 4.5 Wildlife Community...... 5 4.6 Sum m ary-. ----...... 5

9 5.0 REGULATED ACTIVITIES...... 5 5.1 Equipment Access...... 5 5.2 Sediment Excavation and Disposal Methodology...... 6

6.0 IMPACTS...... 8

7.0 MIITIGA rTION/RESTORATION ...... 7.1 Limited Project Performance Standards0...... 7.1.1., Alternatives Analysis...... 9 7.1.2 Avoidance and Minimization Assessment...... 9 7.1.2.1 Hydrology...... 10 7.1.2.2 Best Management Practices...... 10 7.1.2.3 Mitigation Measures...... 12 7.1.2.4 Lost Flood Storage Capacity...... 12 7.12.5 No Flow Obstruction...... 12 7.1.2.6 Temporary Structures and Temporary Alterations...... 12 7.1.2.7 Work During Frozen Ground Conditions...... 13 7.2 Bordering Vegetated Wetland Restoration...... 13 7.2.1 Substrate...... 13 7.2.2 Plant Species...... 13 7.2.3 Proposed Post-Construction Monitoring...... 15

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LIST OF TABLES

Table 1. BVW identified within the Area of Concern....---...... 3 Table 2. Temporary impacts by Resource Type...... 7 Table 3. Number of tree, shrub, pterophytes, and sedge species...... 13

LIST OF FIGURES

Figure 1 Site Location Map Figure 2A Limits of Areas of Concern and Proposed Remediation Areas Figure 2B Details 'Figure 3 Soils Map Figure 4 Priority Habitats of Rare Species. Figure 5 Estimated Habitats of Rare Wildlife and Certified Vernal Podls. Figure 6A Grading Schematic Figure 6B Planting Layout Schematic

LIST OF ATTACHMENTS

Attachnent 1 MADEP Bordering Vegetated Wetland Delineation Field Data Forms

Attachment 2 Photographs of Wetland Resource Areas

Photo 1. View of Phragmitesaustralis (giant reed) stand (Area C) slated for removal facing east. Photo 2. View of headwall, discharge pipe, and shallow pool associated with Outfall 002 (Area A) Photo 3. Close-up of the shallow pool associated with Outfall 002 (Area A). Photo 4. View of headwall and shallow pool associated with Outfall 001 (Area B). Photo 5. General conditions within Wetland A in the vicinity of Outfall 001 (Area B). Photo 6. View of somewhat less disturbed portions of Wetland A. Photo 7. General conditions within the 100-foot buffer zone.

ii Former GE Site Remediation and Monitoring Program NOI Supplementary Narrative

ATTACHMENT A

NOTICE OF INTENT (NOI) SUPPLEMENTARY NARRATIVE

1.0 INTRODUCTION

TRC Environmental Corporation (TRC) is under contract with Lockheed. Martin Corporation (LMC) to perform all response activities (investigation and remediation) as required by the Massachusetts Department of Environmental Protection (MADEP) at the former General Electric facility (Site) located at 50 Fordham Road in Wilmington, Massachusetts (Figure 1). This Notice of Intent (NOI) concerns itself with the remediation of three Areas of Concern (AOC) located within onsite wetlands. The three AOC's include Areas A and C, which collectively encompass a 0.2-acre (9,461.5 square feet) stand of Phragmitesaustralis (giant reed) that has developed upon sediments and soils contaminated with metals at the discharge associated with Outfall 002. The third - AOC has been designated Area B. Within Area B, 176.3 square feet of contaminated sediments are present at the discharge associated with Outfall 001. These AOCs were defined per TRC's Stage II Environmental Risk Characterization (ERC). For further details, see section 4.0. The AOCs are shown on Figure 2A.

A no action alternative was considered for these AOCs. However, no action would allow risk to ecological receptors to persist. Therefore, MADEP has mandated the removal of these impacted sediments and wetland soils.

TRC estimates that the remediation (via excavation) and restoration activities will -take approximately 3 weeks to complete. In addition, in order to minimize impacts to wetland flora and fauna, TRC intends to conduct the work in late winter/early spring 2004.

It remains unclear at this time how the wetland sediments and soils became contaminated. MADEP has suggested that prior site activities impacted the wetlands. These activities include (1) historical metal. finishing activities at the facility and (2) possible use of copper sulfate as an algaecide in the facility's non-contact cooling water system (that was periodically discharged to the outfalls as a permitted release). TRC's research. has revealed historic mining operations, and the placement of imported fill material within the wetland area. These activities may also have contributed to the observed impacts of today.

This Notice of Intent (NOI) concerns itself with the removal of approximately 356 cubic yards of the contaminated soil and sediment; the proper disposal of the soil and sediment; and finally the restoration of the disturbed wetland area.

The investigation and remediation activities are being conducted in accordance with the Massachusetts Contingency Plan (MCP), 310 CMR 40.0000. The site is listed as a Tier

I Former GE Site Remediation and Monitoring Program NOI Supplementary Narrative

IA site (Release Tracking Number 3-0518), with regulatory oversight being provided by the MADEP.

2.0 BORDERING VEGETATED WETLAND (BVW) CHARACTERIZATION

On November 22, 2002, a TRC Biologist delineated wetlands present within the vicinity - of the proposed'equipment access point and the proposed excavation area. Wetland boundaries were identified using both the wetland definitions provided in the Wetland Protection Act (310 CMR 10.55) and the MADEP guidance document entitled 'Delineating Bordering Vegetated Wetlands under the Massachusetts Wetlands Protection Act".

- 2.1 Bordering Vegetated Weiland (BVW) Boundary Methodology

The MADEP Wetlands Protection Act 310 CMR 10.00 et seq. outlines how to identify the parameters used in identifying the BVW boundary including: (1) the dominance test; and (2) wetland hydrology (including hydric soil indicators). This approach was used to identify all wetland boundaries. Data for all parameters are recorded in MADEP BVW (310 CMR 10.55) data sheets (Attachment 1).

2.1.1 Survey of Wetland Boundary

TRC first marked the wetland -boundaries with sequentially numbered pink and black flags labeled "Wetland Delineation". Each wetland boundary flag was then surveyed and located by Dunn & McKenzie, Inc. of Norfolk, Massachusetts. The boundary of AOC C, which coincides with the extent of an existing stand of giant reed, was mapped in the field by a TRC biologist. The boundary of this giant reed stand was flagged and then surveyed using a backpack mounted Global Positioning Satellite (GPS) unit (Trimble Navigation 12 Channel Pro XRS GPS system; position accuracy of 0.5 meters horizontal and 1-meter vertical). These data were then downloaded into a geographic information system (GIS).

2.2 Wetland Delineation Results

Within the vicinity of the proposed work one main wetland was identified, and is referred- to as Wetland A herein (Table 1). The wetland boundaries, in addition to the location of the proposed excavation and equipment access points, and associated construction details are depicted in Figures 2A and 2B.

Wetland A has undergone disturbance associated with surrounding development and the hallmarks of recently increased water levels were evident across the site including standing dead Chamaecyparisthyoides (Atlantic white cedar) and Pinus strobus (eastern white pine). Photos of Outfall 001, Outfall 002, and existing conditions within Wetland A are provided in Attachment 2.

2 FormerGE Site Remediation and MonitoringProgram NOI Supplementary Narrative

Table 1. BVW identified within the areas of concern. |Netland ID Flag Series Wetland Plant Community ClassificatIon| Netland A 1-65 PFO1/4 and PSS Notes: PFOI/4 = Palustrine Forested mixed (ratio of coniferous/deciduous) PSS = Palustrine scrub bmsh

- Wetland A is an expansive palustrine forested wetland with an extremely well developed understory. Dominant tree species within Wetland A include widely spaced white pine and Acer rubrn (red maple) stems with a roughly even diameter at breast height (dbh) distribution. Scattered stems of red maple and Betula allegheniensis (yellow birch) were noted along the edges of the white pine stand and rarely- yellow birch was observed within the interior of the stand. Within the understory, dense stands of Rhododendron viscosum (swamp azalea), Clethra alnifolia (sweet pepperbush), Vaccinium corymbosum (highbush blueberry) are present, and rarely, red maple and yellow birch saplings. Given the time of year, the only visible herbaceous species include Osmunda cinnamomea (cinnamqn fern), isolated patches of giant reed, Carex lurida (lurid sedge), and Symplocarpusfoetidus (skunk cabbage).

Within the vicinity of the proposed work, shrub and sapling. species predominate with dominant shrubs represented by sweet pepperbush, and highbush blueberry and.dominant sapling species represented by red maple. The prevalence of invasive species including giant reed and Lythrum salicaria(purple loosestrife) increases within and adjacent to the area of proposed excavation relative to other less disturbed portions of the swamp.

Wetland A contains thick organic peat deposits that are mapped by the NRCS as the Freetown series (figure 3). The Freetown series consists of very deep, very poorly drained organic soils formed in depressions or on level areas on uplands and outwash plains. Previous borehole profiles indicate that peat depths approach 8 feet within the vicinity of the proposed work. As observed in this wetland, the peat is dark (10YR 2/1), and possesses intermediate rubbed fiber content in the upper 12 inches. The odor of hydrogen sulfide (H2S) was particularly strong, indicating the presence of sulfate- reducing bacteria and reducing (anaerobic) conditions. The tree and shrub species that established on these peat deposits have developed a fairly firm lateral root network. This root network has, in turn, contributed to a mildly pronounced hummock hollow topography.

At the time of the field investigation, standing water was present to a depth of six inches.

3.0 RARE, THREATENED, AND ENDANGERED SPECIES

TRC reviewed the Massachusetts Natural Heritage & Endangered Species Program (MNHESP), MA Division of Fisheries and Wildlife Maps" to determine the presence/absence of (1) Estimated Habitats of Rare Wildlife and Certified Vernal Pools, and (2) Priority Habitats of Rare Species. Although an updated 2003 paper version of the estimated habitat maps has not yet been issued by the MNHESP, the 2001 maps provided

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in this NOI (Figures 4 and 5) were compared with GIS-based polygons to ensure that new areas had not been mapped in the interim. Based upon this comparison, no differences were noted.

According to the MNHESP mapping, neither Estimated Habitats of Rare Wildlife and Certified Vernal Pools, nor Priority Habitats of Rare Species are located on the site. However, there are priority habitats of rare species, and estimated habitats of rare wildlife - and certified vernal pools to the east and south of the area of concern, respectively. The most proximate boundary of all vernal pools and priority habitats mapped by MNIHESP coincides with a 0.5-mile radius originating from the proposed area of excavation.

4.0 ECOLOGICAL RISK CHARACTERIZATION

A qualitative ecological risk characterization of outfall sediments was initially conducted in 1996 (EMCON, 1998). The results of the qualitative analysis indicated that copper was detected at concentrations ranging from 9 mg/kg to 1,800 mg/kg, while lead concentrations ranged from 21 mg/kg to 250 mg/kg. In addition, zinc was detected above its screening benchmark, with concentrations ranging fron 25 mg/kg to 180 mg/kg.

Based on these findings, MADEP concluded that the metals detected within the sediments and surface soils of the wetland potentially affect ecological receptors directly via contact (e.g., benthic community inhabiting contaminated sediments) or by bio- accumulation within vegetation and invertebrates that are subsequently consumed by receptors occupying higher trophic levels.

Because of the limited scope of the previous studies, TRC conducted a quantitative Stage H Environmental Risk Characterization in 2003 to fully characterize the ecological risk to various receptors. The following provides a review of the data and the associated conclusions r6garding risk.

4.1 Amphibians

Based on detected surface water concentrations, and the presence of numerous amphibian larvae within the aquatic habitat associated with Outfall 002, there is no risk to amphibians.

4.2 Benthic Macroinvertebrates

Sediment concentrations of copper, lead, nickel and zinc detected at Outfalls 001 (Area 'B) and 002 (Areas A and C) are the above Probable Effect Concentrations (PEC) associated with impacts to benthic macroinvertebrates. Therefore, the benthic macroinvertebrate communities within these limited areas of aquatic habitat may be adversely affected by these metals.

4 FormerGE Site Remediation and MonitoringProgram NOI Supplementary Narrative

4.3 Plants Zinc concentrations in soil and plant tissue near Outfall 002 (Area C) exceed the benchmark associated with an adverse impact to vegetation (USEPA, 2000).

4.4 Terrestrial Invertebrate Community Copper and zinc concentrations in soil near Outfalls 002 (Area C) are above the benchmarks associated with adverse impacts to terrestrial invertebrates (USEPA, 2000) although toxicity testing of the surface soils dellected in the vicinity of Outfall 002 (along the downgradient edge of Area C) indicates that terrestrial invertebrates are unlikely to be affected by COC concentrations. However, risks to the terrestrial invertebrate community within Area C (upgradient of the sample location) are possible. Because Area C reveals risk to the plant community, Area C must be removed. Therefore further study regarding invertebrate risk was unnecessary.

-4.5 Wildlife Community Risk calculations indicate no significant risk at Area C near Outfall 002 for: . Mammalian herbivores (meadow vole) per detected concentrations in soil and plant tissue. Avian insectivores (marsh wren) per detected concentrations in invertebrate tissue. Mammalian insectivores (short-tailed shrew) - Risk calculations indicate a potential for significant risk near Outfall 002 (Area C and the downgradient 0.5 acre wetland area) from detected copper concentrations in soil and plant/invertebrate tissues.

. 4.6 Summary

Based on the findings of the Stage II ERC, Areas A, B, and C require remediation in order to meet the MCP standards and- requirements and achieve a condition of no significant risk.

5.0 REGULATED ACTIVITIES

All regulated activities relate directly to the removal of the contaminated soil and sediments, and the creation of access paths for construction equipment through the buffer zone and the wetland itself. The following sections discuss these activities in greater detail.

5.1 Equipment Access

Before any activities are conducted, sediment and erosion controls will be established to protect the wetland including haybales and silt fence. - Traffic controls such as cones, caution tape and orange snow fence will be used to define the work area and the

5 FormerGE Site Remediation and Monitoring Program NOI Supplementary Narrative

excavated soils and sediment staging area. Facility traffic will be re-routed around the work zones.

During the course of the wetland delineation and subsequent site visits, two access points were identified. The access points were selected on the basis of their potential to minimize the extent of bordering vegetated wetland and buffer zone impacts and facilitate equipment access. All access paths will measure approximately twelve feet in width. A 4-inch layer of gravel will be placed on the access route for stability.

- Minor cutting activities will take place along the upland-wetland border. It is presumed that all hardwoods and shrub species will regenerate following the cutting, i.e. via basal sprouts. The staging area for the construction trailer and equipment storage will be located on the existing parking lot. Clearing related to equipment access within the wetland will involve the removal of the entire giant reed stand along with small red maple saplings and shrub species including highbush blueberry. Note that the red maple stems observed within the excavation site ranged in diameter at breast height (dbh) from - 2-6 inches and many were classed as standing dead.

- 5.2 Sediment Excavation and Disposal Methodology

The sediments at the Outfall 001 and 002 (Areas A and B) will be removed prior to starting the wetland soil excavation in Area C.

Prior to excavation, berms will be constructed at the outlets of the storm water culverts to create a sump from which storm water can be pumped and re-directed to a downstream wetland location during excavation activities. A berm will -also be constructed at the downstream limit of contaminated sediments in order to prevent water from the surrounding wetland from draining back into the area of sediment removal. In order to facilitate the removal of sediments, the standing water within the bermed area will be removed and pumped through a particulate filter prior to discharge at a downstream location in the wetland. Water will be pumped at a maximum rate of 50 gallons. per minute. Engineering controls will be utilized to dissipate the energy of the water and prevent soil erosion or other disturbance of the wetland.

The top 12 inches of sediment will be excavated and transferred to the Excavated Material Staging Area for dewatering. Details on dewatering procedures are presented below.

Following the removal of sediments within Areas A and B, the contaminated soils within Area C will be addressed. First, the most upstream areas will be excavated and removed first in order to ensure that downstream areas are not re-contaminated by the possible suspension and deposition of contaminated soil due to storm water flows.

An "Excavation Containment Berm" will be constructed around the area of wetland soil- excavation (Area C) in order to contain potentially sediment-laden water from leaving the

6 Former GE Site Remediation and MonitoringProgram NOI Supplementary Narrative

excavation, and to prevent surrounding wetland surface water from draining back into the excavation. The top 12 inches of wetland soils in Area C will be excavated and transported to the "Excavated Material Staging Area" for management outside of the buffer zone. All excavation equipment will use "Swamp Mats" to prevent disturbance of the underlying wetland soils. The Swamp Mats distribute the load of the equipment to decrease the bearing pressure thereby allowing the equipment to work on the surface of the soils without sinking.

'Surface water may be removed from the area in order to facilitate excavation and backfilling. All surface water will be pumped through a particulate filter prior to discharge at a downstream location in the wetland. Water will be pumped at a maximum rate of 50 gallons per minute. Engineering controls will be utilized to dissipate the energy of the water and prevent soil erosion or other disturbance of the wetland.

Once excavated, the wetland sediments and soils will be dewatered to remove free liquids prior to transportation for. disposal. . Possible methods for sediment and soil dewatering/handling include, but are not limited to the following:

"Filter Boxes" Stockpiling in a temporary bermed area Stabilizing with reagent

FilterBox Option The "Filter Boxes" are 25-cubic yard roll-off containers that have a bottom compartment into which liquids can drain from soils placed in the box Fine particles are retained in the main compartment by a fine mesh or geotextile filter fabric that lines the container.

Stockpile Option If the stockpile approach is used, an area in the parking lot will be .lined with polyethylene plastic sheeting that will be draped over a continuous line of hay bales around the perimeter. The hay bales will form a berm that will contain the wet materials. A sump constructed of perforated pipe surrounded by crushed stone of filter fabric will be constructed in the bermed area from which water can be removed with a pump. The water will be treated on-Site as described above.

StabilizationOption - Portland cement and lime will react with the available free water resulting in a dry stable material that can be easily transported.

Depending on weather and site conditions, TRC will select the most appropriate options in order to minimize complications during the construction activities and best protect the wetland resource area.

7 FormerGE Site Remediation and Monitoring Program NOI Supplementary Narrative

TRC does not anticipate that the water collected during dewatering of sediment and soil will be contaminated. Furthermore, TRC does not anticipate that the volume will be abundant.

Therefore, all water that is collected by the dewatering procedures will be transferred to a temporary holding tank (frac tank) to be located outside of the 100-foot buffer zone. This will allow for additional settling of sediment. It will then be transferred by pump through particulate filters to remove any remaining suspended sediment, and routed to the existing on-site groundwater treatment system. This system was recently installed (August 2003), and designed for the treatment of impacted groundwater by volatile organic compounds. The groundwater is currently treated via an air stripper, followed by three 1000-lb granular activated carbon (GAC) units in series. It is then discharged to facility's storm drain system that connects to outfall 001. The discharge is permitted and - regulated per the National Pollutant Discharge Elimination System (NPDES) program, with monthly sampling and analysis of both system influent and effluent. Even though TRC expects that the collected water will not be impacted by metals, TRC can ensure that, if present, the metals will be removed via the system particulate filters (in addition to the filters provided at the holding tank area) as well as the system GAC units. The filters and any sediment that is collected at the bottom of the holding tank will be properly disposed.

* In addition, a composite sample of the soil and sediments will be collected and analyzed at a laboratory for the purpose of chemical characterization prior to disposal. The specific analyses will depend on the requirements of the disposal facility and are not known at this time. At a minimum, the sediments will be tested by Toxicity Characteristic Leaching Procedure (TCLP) to determine if the material is hazardous by characteristic for metals.

6.0 . IMPACTS

- The total area of estimated temporary impacts associated with equipment access and . wetland sediment removal listed by Impact Area is presented in Table 2. Although the temporary impacts to buffer zones are not regulated, TRC will strive to minimize such impacts throughout the field activities program. In addition, as shown on Table 2, temporary impacts to the BVW will exceed the MADEP threshold of 5,000 square feel These temporary impacts will be mitigated immediately following the excavation. The specific mitigating measures to be employed arid the wetland restoration plan are - discussed in the following sections.

7.0 MITIGATION/RESTORATION

7.1 Limited Project Performance Standards

Although this project qualifies as a Limited Project under the Massachusetts Wetlands Protection Act, the Limited Project status granted under 310 CMR 10.53 (3) is not

8 FormerGE Site Remediation and Monitoring Program NOI Supplementary Narrative recognized under the North Reading General Wetlands By-Law. (The town of North Reading evaluates such projects on a case-by-case basis.) TRC has elected to adhere to the performance standards cited for both Limited Projects (310 CMR 10.53(q)) and non- Limited Projects (310 CMR 10.55) as discussed below.

Per Limited Project requirements (310 CMR 10.53(q)), an 1) Alternatives Analysis, and an 2) Avoidance and Minimization Assessment are presented herein.

Table 2. Temporary Impacts by Resource Type RESOURCE TYPE IMPACTS MADEP* IMPACT SQUARE FEET (ACRES) THRESHOLD SQUARE FEET (ACRES) Buffer Zone TOTAL 1,566.47 SF (0.03) WA Area B (Outfall 001) 250.0 SF (0.005) N/A Area A/C (Outfall 002) 1,31 6.4 SF (0.03) N/A Bordering Vegetated 9,637.8 SF (0.22) 5,000 SF (0.11) Wetland (Wetland A) TOTAL Area B (Outfall 001) 176.3 SF (0.004) 5,000 SF (0.11) Area A/C (Outfall 002) 9,461.5 SF (021) 5,000 SF (0.11) As defined by the Massachusetts Wetlands Protection Act and enforced by the Massachusetts Department of Environmental Protection (MADEP).

7.1.1 Alternatives Analysis

As previously stated, a no action alternative was considered for the AOCs defined by the Stage II ERC. However, no action would allow risk to ecological receptors to persist Therefore, MADEP has mandated the removal of these impacted sediments and wetland soils.

7.1.2 Avoidance and Minimization Assessment

The Avoidance and Minimization Assessment is required to achieve, as best as possible, the following:

o Minimize hydrological changes; o Use BMP's; o Employ mitigating measures to protect the interests of the Wetlands Protection Act; o Compensate for lost flood storage capacity,

9 FormerGE Site Remediation and MonitoringProgram NOI Supplementary Narrative

o Prevent obstruction to flow by access road, assessment or monitoring devices; o Remove temporary structures within 30 days of the completion of the work. Temporary alterations to resource areas must be substantially restored to preexisting topography and hydrology. The disturbed areas must exhibit 75% vegetated cover within two seasons. Exposed soils must stabilized in accordance with USDA standards. o Work in resource areas only when the ground is sufficiently frozen.

As presented in the Avoidance and Minimization assessment provided below, this project has been specifically designed to: Meet project cleanup objectives; a Meet all performance standards of this Uiited Project category under the Massachusetts Wetlands Protection Act; and Meet all wetland performance -standards cited in the Town of North Reading Wetlands Protection By-Law & Regulations.

7.12.1 Hydrology

Changes to wetland hydrology will not occur. No permanent structures will be placed in the wetland. Furthermore, the only fill material to be placed within the wetland will include the organic substrate used to create the wetland restoration. This material will be placed in such a manner that it matches the existing wetland substrate.

7.1.2.2 Best Management Practices

Sediment and Erosion Controls

Wetlands and watercourses will be protected from direct impacts (e.g. siltation) through the implementation of Best Management Practices (BMP's) prepared as part of the site specific Erosion/Sediment Control Plan. The proposed BMP's will minimize erosion, migration of sediments, and adverse environmental impacts to Wetland A. These BMP's include the use of stabilized construction exits and haybale and/or silt fence barriers to minimize erosion and sedimentation outside the limits of construction.

The measures taken to provide effective sediment and erosion -control within the areas of construction are as follows:

1. Install stabilized construction exits and silt fence barriers. 2. Install remaining silt fencing and temporary sediment traps. 3. Seed all disturbed areas.

Sediment and erosion controls will be installed in those areas where the placement of additional topsoil and the removal of aboveground biomass are proposed. In this regard, geotextile fabric and haybales will be used in concert. This combination will effectively minimize sediment transport into onsite wetlands/watercourses. Sediment and Erosion

10 FormerGE Site Remediation and Monitoring Program NOI SupplementaryNarrative

control structures will be left in place until all exposed soil has successfully revegetated. At this time, temporary devices and structures to control and sedimentation in and around the mitigation site shall be disassembled and properly disposed. Sediment collected by these devices will be removed and placed upland in a manner that prevents its erosion and transport to a watercourse or a wetland.

The hay bales will be placed in a single row with the ends of adjacent bales tightly abutting one another. The bales will be securely anchored (except in the parking lot) by driving at least two stakes through each bale. For straw bale barriers placed in the parking lot, the bales will be fastened together with wooden stakes, rebar, wire or other acceptable means:

The straw bales will consist of straw from acceptable grasses and legumes, free from ..weeds, reeds, twigs, chaff, debris and other objectionable material or excessive amounts of seeds and grains. The straw will be securely bailed with wire of adequate size to allow for rusting while in use and still permit re-handling when the bale is in a saturated condition.

Th6 silt fence will be constructed of a non-rotting, ultraviolet light resistant woven polyester geotextile with sufficient strength for its intended purpose. The silt fencing will be installed in accordance with manufacturer's recommendations.

Swamp Mats

The surficial wetland sediments supporting this plant community consist primarily of a well-decomposed (sapric) muck that is very unstable. Due to the soft nature of the- substrate, special wetland crossing techniques will have to be employed in order to facilitate heavy equipment access and operation. It is proposed that Wetland A be crossed with the use of swamp mats.

A swamp mat is simply a 3-ply wooden mat, measuring 8 feet in width, 14 feet in length, ..and 6 inches in depth. Each mat weighs 3,100 lbs and is lifted by means of cable lifting eyes affixed to each end of the mat. Once the swamp mats are no longer needed, they will be removed.

Excavation Containment Berm

In the wetland areas, a bern will be constructed using the same wetland soil material to be used to backfill the Excavation in Area C. The berm will serve two functions; sediment-laden water will be contained within the area of excavation, and surface water from the surrounding wetland will be prevented from draining back into the excavation.

A sheet of poly plastic will be anchored beneath the berm and wrapped around the outside face of the berm to prevent surface water from draining back into the excavation. The berm soil will also have the capacity to filter out any sediment that becomes

11 FormerGE Site Remediation and MonitoringProgram NOI Supplementary Narrative

suspended in water that collects in the excavation. Similar materials have been sold commercially and successfully used on other projects in place of silt fence and hay bales as a "Filter Berm" to control sedimentation. The soil material of the berm will be used as a top dressing for the excavated areas once the excavations have been substantially backfilled and the disturbed areas are stabilized. The plastic sheeting will be removed and disposed at an off-Site location.

- Silt Bags

The silt bags will be constructed of a non-rotting, ultraviolet light resistant woven polyester geotextile with sufficient strength for their intended purpose. The silt bags will be placed just beneath the catch basin grate and the catch basin grate will be used to secure the silt bag§ in place.

7.1.2.3 Mitigation Measures

The disturbed portions of the wetland will be restored following the removal of the contaminated sediments. The wetland restoration plan provided in Section 7.2 discusses this in greater detail.

P7.1.2.4 Lost Flood Storage Capacity

No flood storage capacity will be lost as no permanent structures or additional fill will be placed within the bordering vegetated wetland.

- 71.2.5 No Flow Obstruction

The placement of clean fill in the excavation hole will not obstruct either surface of subsurface flow. Furthermore, swamp mat use is temporary and will not obstruct surface flow. The temporary access road will have minimal and temporary impacts to flow, diverting water around the road until work is complete. Once Final grading and restoration is complete, the diversion will be eliminated.

7.1.2.6 Temporary Structures and Temporary Alterations

Swamp mats will be only needed for the duration of excavation activities for operation and access of the heavy equipment, which will take place in the winter and may take as long as two weeks. The temporary impacts to wetland vegetation are assumed to be minimal and any compressed vegetation outside of the excavation area will swiftly regenerate following the removal of the swamp mats. Given that the placement of the* swamp mats will in no way remove or compromise the network of underground stems. Once the swamp mats are no longer needed, they will be removed.

All exposed soils within the buffer zone will be re-seeded, and subsequent revegetation will be documented with quantitative surveys and photographic stations.

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7.1.2.7 Work DuringFrozen Ground Conditions

As proposed, the excavation activities will occur in the late winter/early spring.

7.2 Bordering Vegetated Wetland Restoration

- The composition and structure of the wetland restoration will approximate the adjacent -wetland plant community (Wetland A), which is dominated by highbush blueberry, - swamp azalea, and sweet pepperbush. Scattered stems of red maple were observed throughout the wetland. Herbaceous species include Qsmunda cinnamomea (cinnamon fern), Onoclea sensibilis (sensitive fern), and lurid sedge.

It is propose that the planting of the wetland restoration area will take place in the early - spring and that all plant materials and seed mix be obtained from New England Wetland Plants located in Amherst, Massachusetts.

7.2.1 Substrate

As previously discussed, the area of contaminated soil will be excavated to a depth approximately 1.0 ft. below the surface elevation of the adjacent wetland. The material to be placed in the excavation will consist of approximately 350 cu. yds. of a mixture of loam, highly decomposed wood chips, and peat moss.

Grading of the wetland floor will be conducted to reconstruct the hummock-hollow topography observed throughout the wetland (Figure 6A). This will provide varied microenvironments that can be advantageous for the establishment of bog vegetation. The creation of the hummock-hollow microtopography will yield a moisture gradient ranging from pools of standing water to drier hummock tops. The hummock-hollow topography will be created with the backhoe during the deposition of the compost material within the excavation.

In addition to the creation of the hummocks, decomposed nurse logs will be placed in the wetland restoration area, to provide germination substrate for plant speci~s and add a structural component for wildlife habitat.

7.2.2 Plant Species

Proposed trees species include red maple (Table 3). Shrub species include highbush blueberry, swamp azalea, and flex verticillata (winterberry). Herbaceous species will - include sensitive fern, cinnamon fern, and Carex stricta (tussock sedge). All species will be planted in the spring and will be purchased from New England Wetland Plants located in Amherst, Massachusetts.

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Table 3. Number of trees.hrbntohveadsde snce. GENUS AND COMMON NUMBER SIZE SPACING SPECIES NAME (ft.) Tree Species . Acer rubrum red maple 10 3-4 ft - 20-30 Shrub Species Vaccinium highbush 20 18-24 in. 5-10 corymbosum bluebeny Rhododendron swamp azalea 20 18-24 in. 5-10 viscosum flex vetticilata winterberry 20 18-24 in. 5-10 Pterophyte Species Osmunda cinnamon fern 100 1 gallon N/A cinnamomea container clumped Onoclea sensibilis sensitive fern 100 1 gallon N/A container- clumped Sedge Species Carex stricta tussock sedge 100 2 in. plug N/A

______clumped TOTAL. 370

As proposed, shrub and sapling species will occupy the uppermost elevations on the hummocks, while the pterophytes (fem) and sedge species will occupy intermediate and low hummock elevations (Figure 6B). In addition to these species, it is proposed that a herbaceous wetland seed mix be planted to aid in minimizing erosion and restricting the development of invasive plant species recruited from adjacent wetland areas. This seed mix will contain the following species:

V, Fringed Sedge (Carex crinata) '7- Bearded Sedge (Carex comosa) V, Canada Manna Grass (Glyceria canadensis) Lurid sedge (Carexlurida) Blue vervain (Verbena hastata) V, Green bulush (Scirpus atroviens) Woolgrass (Scirpus cyperinus) Joe-pye weed (Eupatoriadelphusmaculatus) Chufa (Cyperus esculentus) Hop sedge (Carex lupulina) Boneset (Eupatoriumperfoliatum) Red-Top panic grass (Panicumrigidulum)

The different species contained in this mix can tolerate some variation in the hydroperiod. Therefore, despite local variability in inundation regimes/topography, some or a number

14 FormerGE Site Remediation and MonitoringProgram NOI Supplementary Narrative

of different wetland plants within the seed mix will cover all of the restoration area. The emergent-dominated wetland plant community was selected to effectively out-compete giant reed, purple loosestrife, and other invasive plant species, e.g. Phalarisarundinacea (reed canarygrass).

The seed mix will be applied via hydro-seeding. The seed will be applied in the early spring. The recommended application rate for a wet meadow is llb/2500 SF. Once the seed has 4een applied, a light mulch of clean straw mulch will be applied to the restoration surface.

7.23 Proposed Post-Construction Monitoring

TRC proposes to conduct a post-construction monitoring program of the restored wetland area for a period of two years to ensure that the area is responding positively to the restoration efforts, and to take measures to correct or enhance the area, if needed.

PhgoogrphicStations

To visually document plant community development and demonstrate conformance with the performance standards outlined in the Massachusetts Wetlands Protection Act 310 CMR 10.55(4)(b)(1-7), photographic stations will be established within the restoration area. Tn addition, quantitative amnpling of the wetland plant community will also be undertaken using the techniques illustrated below.

- SamplinjProtocol

A single linear transect will be established parallel to the property line and perpendicular to both contour intervals and environmental gradients within the restoration area. Each end of the transect will be marked with a permanent wooden stake. Along the transect,. .25cm x 50cm rectangular quadrats will be positioned at regular intervals that will also be marked in the field. The same plots will be used during the second sampling season.: In this manner, changes in plant percent cover and species composition over the two growing seasons can be accurately determined.

Percent cover will be determined by visually estimating both plant percent cover and the percent cover of bare substrate within each 25cm x 50cm rectangular quadrat. Once these data have been collected, each plant species encountered will be lumped into its respective USFWS indicator status category. Lastly, relative percent cover will be determined by simply dividing the percent cover total for a given class by the total percent cover for all species and bare space combined.

Individual shrub and tree species survival will be assessed visually. Those species that have died will be recorded and replaced.

15 Former GE Site Remediation and Monitoring Program NOI Supplementary Narrative

Reporting

The results of the data collection over the two seasons will be presented in a technical memorandum to the North Reading Conservation Commission and MADEP, and will make assessments demonstrating conformance with the performance standards enumerated in the Massachusetts Wetlands ProtectionAct 310 CMR 10.55(4)(b)(1-7).

16 FormerGE Site Remediation and Monitoring Program NOI Supplementary Narrative

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MINTISN OF- , -- March 10, 2003( Regulatory-]Division- -- CENAE-R-PEA PernitNumber 200400154

Attorney Frank Dardeno, Sr. The Wilmington Realty Trust 424 Broadway Somerville, Massachusetts 02145

Dear Mr. Dardeno:

We have reviewed your application to discharge approxiitately 350 cubic yards of fill material into 9,637.8 square feet of wetlands as part of a contaminated wetlands restoration project The-project will begin with the removal of approximately 350 cubic yards of wetland- soils cntaminated with metals and the in-situ restoration of 9,637.8 square feet of disturbed wetlands. Once the contaminated wetland soils are removed, the excavation will be backfilled with a clean wetland soil mix which will serve as a suitable substrate for wetland plants. Approximately 350 cubic yards of loam, highly decomposed wood chips, and peat moss will be used to re-establish the wetland substrate. The project will eliminate risk to ecological receptors as ruired by the Massachusetts Department of Environmental Protection under the WMassachusetts Contingency Plan. This work is located at 50 Fordham Road, North Reading, Massachusetts. The work is described on the enclosed plans entitled "Former GE-Site, Wilmington/North Reading, Massachusetts,"on-10 sheets numbered 2A, 2B-l to 2B-7,6A and 61, prepared by TRC Environmental Corporation, and dated December, 2003.

Based on the information you have provided, we have determined that the proposed activity, which includes a discharge of dredged or fill material into waters or wetlands, will have only minimal individual or cumulative environmental impacts. Therefore, this work is authorized as a Category II activity under the Federal permit, Massachusetts Programmatic General Permit (PGP).

This determination becomes valid only after the Massachusetts Department of Environmental-Protection (DEP) issues or waives the necessary 401 Water Quality Certification. In the event the State denies.401 Water Quality Certification, this determination becomes null and void. The address of the DEP Regional office for your area is provided in the enclosed PGP.

You must perform the activity authorized herein in compliance with all the terms and conditions of the PGP and any conditions placed on 401 Water Quality Certification including any required mitigation. Please review the enclosed PGP carefully, including the PGP conditions beginning on page 9, to familiarize yourself with its contents. You are responsible for complying with all of the PGP requirements; therefore, you should be certain that whoever does the work fully understands all of the conditions. You may wish to discuss the conditions of this * audhwioaoi with your Couuacur tu ensue connuaor can accomplish the work in a manner that conforms to all requirements. -2- <~3

If you change the plais 6rconstructfdn methods for work within our jurisdiction, lease contact us immediately-to dispuss modification of this authorization. This officen ust approve - any changes before you undertake them.

This authorization is valid until January 11,2007, which is two years from the Massachusetts PGP's expiationdate of January 11,2005, unless the Massachusetts POP is modified, suspended, or revoked, such that the activity would no longer comply with the terms and conditions of the Massachusetts POP.

This authorization requires you to notify us before beginning work and allow us to inspect the project. -Therefore, you must complete and return the enclosed Work Start Notification Form to this office no later than two weeks before the anticipated starting date.

Please note that this determination does not constitute an authorization to proceed until all other applicable Federal, state and local permits are obtained. Performing work not specifically authorized by this permit, starting work without obtaining other Federal, state and local . approvals, or failing to comply with the permit conditions may subject you to the enforcement provisions of our regulations.

If you have any-questions, please contact Kevin Kotelly of my staff at (978) 318-8703..

Sincerely,

rystal I. Gardner Chief, Permits & Enforcement Branch Regulatory Division

Enclosures *

Copies Furnished:

John McCulloch, U.S. EPA, Region 1, 1 Congress Street, Suite 1100-Mail Code CWQ, Boston, Massachusetts 02114-2023 Christopher Boelke, National Marine Fisheries Service, One Blackburn Drive, Gloucester, Massachusetts 01930-2298 Williaii eidermyer, U.S. Fish abd Wildlife Service, 70 Concord, New Hampshire 03301-5087 James Sprague, DEP Northeast Regional Office, Wetlands and Waterways, 1 Winter Street, Boston, Massachusetts 02108. Paola Macchiaroli, Ph.D., TRC Environmental Corporation, 31 Milk Street, 11* Floor, Boston, As Massachuset02l109 '44

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1 ' Application No.: 200300120 Effective Date: January 11, 2000 Applicant: General Public in the Expiration Date: January 11,2005 Commonwealth of Massachusetts Modification Date: June 30, 2003

DEPARTMENT OF THE ARMY PROGRAMMATIC GENERAL PERMIT COMMONWEALTH OF MASSACHUSETTS

The New England District ofthe U.S. Army Corps of Engineers (Corps) hereby modifies the previously issued Progranuatic General Permit (PGP). The POP expedites review of minimal impact work in coastal and iinlnd waters and wetlands within the Commonwealth of Massachusetts.

L. GENERAL CRMTRIIA: Activities with minimal impacts, as specified by the terms and conditions of this PGP and on the attached Definition of Categories, are either

Category1: Non-reporting. Eligible without screening (provided required local and State permits and required State certifications are received), or

Catego2: Reporting. Require screening and a written determination of eligibility under the general permit by the Corps after coordination with the U.S. Fish and Wildlife Service, U.S. Environmental Protection Agency and National Marine Fisheries Service, and the Massachusetts Coastal Zone Management (CZM) Office.

This PGP does not affect the Corps Individual Permit review process or activities exempt from Corps jurisdiction.

ILL ACTIfVITES COVERED: Work and structures that are located in, or that affect, navigable waters of the United States (regulated by the Corps under Section 10 of the Riven and Harbors Act of 1899); the discharge of dredged or fill material into waters of the United States (regulated by the Corps under Section 404 of the Clen Water Act); and the transportation of dredged material for the purpose of disposal in the ocean (regulated by the Corps under Section 103 of the Marine Protection, Research and Sanctuaries Act).

M1. PROCEDURES

A. State and LocaX Approvals For projects authorized pursuant to this PGP, when the following local or State approvals are also required, they must be obtained in order for this PGP authorization to be valid (applicants are responsible for ensuring that all required State licenses and approvals have been applied for and obtained): (a) Fhial Order of Conditions under the Massachusetts Wetlands Protection Act (WPA) (MGL c. 131 Section 40) must be obtained for activities subject to jurisdiction as defined in 310 CMR 10.02. (b) Waterways license or permit under MGL c. 91, from the Massachusetts Department of Environmental Protection (DEP) must be obtained for activities subject to its jurisdiction, also defined in 310 CMR 9.05. (c) Water Quality Certification is required for work in Corps jurisdiction involving a discharge of dredged or fill materials to waters of the U.S. Some projects require an individual Water Quality Certification (WQC), under Section 401 of the Clean Water Act, issued by the Massachusetts DEP before work can proceed (see Page 6 for 401 WQC requirements). (d) Coastal Zone Management: Any project that meets the terms and conditions of Category I of this PGP (i.e., non-reporting), has been determined to be consistent with the Massachusetts Coastal Zone Management (CZM) plan and does not require any additional CZM review. For work being screened under Category 2 of this PGP, the Corps will coordinate screening of any work in or affecting the coastal zone with the Office of Coastal Zone Management; for these projects the Corps will notify applicants if an individual CZM concurrence is required.

B. Corps Authorizations

CATEGORY 1 (Non-Reporting)

Activities in Massachusetts that: o Are subject to Corps jurisdiction (see Condition 2, Page 9), and o Meet the definition of Category 1 in Appendix A -Definition of Categories, and a Meet the conditions of the PGP listed on Pages 9 -16 may proceed without application or notification to the Corps provided the required Federal, State, and local authorizations are obtained.

Project proponents seeking Category 1 authorizations are not relieved of the obligation to comply with this PGP's general conditions (see Page 9) and other Federal laws such as the National Historic Preservation Act, the Endangered Species Act and the Wild and Scenic Rivers Act Therefore, consultation with the Corps and/or outside experts such as the Massachusetts Historical Commission and the appropriate Indian tribes is recommended when there is a high likelihood of the presence of resources of concern.

Although Category 1 projects are non-reporting, the Corps reserves the right to require an Individual Permit review ifthere are concerns for the aquatic enviromnent or any other factor of the public interest (see Condition 4 on Discretionary Authority, Page 9).

Work that is not subject to the State's WPA, but is subject to Corps jurisdiction, is eligible for Corps authorization under this PGP. Although an Order of Conditions is not required if the work is not subject to the WPA, this POP's review thresholds and requirements concerning WQC and CZM consistency apply. Such projects could include activities that are exempt from the WPA or activities in Federal wetlands that are not included in the WPA.

Jun 2003 Amcmdmmt 2 CATEGORY 2 (Reporting - Requiring Screening)

Eligibillty Criteria Activities in Massachusetts that are: o Subject to Corps jurisdiction, and o Meet the definition of Category 2 in Appendix A - Definition of Categories, and o Meet the conditions of the PGP listed on Pages 9 - 16,

Require written approval from the Corps These projects will be reviewed through interagency screening (see Federal Screening Procedures below) to determine whether such activities may be authorized under this POP. To be eligible and subsequently authorized, an activity must result in minimal impacts to the aquatic environment as determined by the Corps based on comments from the review team and the criteria listed above. Mitigation may be required to compensate for unavoidable impacts to ensure net effects of a project are minimal.

For Category 2 projects, applicants must obtain not only a written authorization from the Corps, but an Order of Conditions and certifications or waivers concerning WQC and CZM, as stated on Page 1. Applicants shall apply directly to the appropriate local Conservation Commission and/or DEP regional office (see Page 16 for addresses) for local and State approvals.

Consultation with the Corps and outside experts is required to ensure compliance with all of this POP's conditions, such as consultation with the Massachusetts Historical Commission and the appropriate Native American Indian tribes to ensure compliance with Condition 7. Also, note that the review thresholds under Categoy 2 apply to single and complete projects only (see Condition 5).

Apleation Procedures Applicants must apply directly to the Corps for all Category 2 projects using ENG Form 4345. Altematively, the Corps will accept DEP's WQC and Chapter 91 application fonns for its review provided the forms were already sent to the DEP. Applicants must use a Corps application form for all projects involving work that is not subject to State jurisdiction. Upon receipt ofthe application, the Corps will determine if it:

(1) requires additional information (see "information typically requirvd" below); (2) is appropriate for screening with the Federal resource agencies (see Category 2 Federal Screening Procedures below); (3) is ineligible under the terms and/or conditions of this PGP; or - (4) will require Individual Permit review, regardless of whether the terms and conditions of this POP are met, based on concerns for the aquatic environment or any other factor of the public interest (see Condition 4 on Discretionary Authority).

If open water disposal is proposed, the Corps will make a suitability determination, folly coordinated with the Federal resource agencies, before coordinating a project at ajoint processing meeting.

All Category 2 applicants shall submit a copy of their Corps, WQC or Chapter 91 application materials, or DEP's Environmental Notification Form, to the State Historic Preservation Officer at the Massachusetts Historical Commission (MHC) and the Wampanoag Tribal Historic Preservation Officer, the Stockbridge-Munsee and/or the Narragansett Tribal Historic Preservation Officers when applicable (see Page 17 for geographic areas of concern) to be reviewed for the presence of historic, Juno2003 Amndment 3 archaeological, or tribal resources in the permit area that the proposed work may affect Submittals to the Corps shall include information to indicate that ths has been done (a copy of the applicant's cover letter to MIHC and tribes. the DEP Environmental Notification Form's distribution list, or a copy of MHC and tribal response letters when applicable).

Information typically required. Not all information is necessary for all projects. (a) purpose of the project; (b) 8%"x11" locus map. 8 l"x1"plan views of the entire property and project limits with existing and proposed conditions (legible, reproducible plans required); (c) wetland delineation for site, Corps wetland delineation data sheets (see web site) and calculations of waterway and wetland impact areas (see Condition 2); (d) typical cross-section views of all wetland and waterway fill areas and wetland replication areas; (e) delineation of submerged aquatic vegetation, e.g., eelgrass beds, in tidal waters; (f) volume, type, and source of fill material to be discharged into waters and wetlands, including the areas (in square feet or acres) of fill in wetlands, below the ordinary high water in inland waters and below the high tide line in coastal waters; (g) mean low water, mean high water and high tide elevations in navigable waters; (h) limits of any Federal Navigation Project in the vicinity of the project area and State Plane Coordinates for the limits of the proposed work closest to the Federal Navigation Project; (i) alternatives analysis submitted to the DEP for WQC review, and/or additional information compiled on alternatives; (J) identify and describe potential impacts to essential fish habitat (see Condition 10); (k) photographs of wetland/waterway to be impacted.

Information typically required for dredging projects may include: (a) sediment testing, including physical, chemical and biological testing. For projects proposing open water disposal, applicants arc encouraged to contact the Corps as early as possible regarding sampling and testing protocols. Sampling and testing of sediments without such contact should not occur and if done, would be at the applicant's risk. (b) the volune of material and area in square feet to be dredged below mean high water; (c) existing and proposed water depths; (d) type of dredging equipment to be used; (e) nature of material (e.g. silty sand); (t) any existing sediment grain size and bulk sediment chemistry data for the proposed or any nearby projects; (g) information on the location and nature of municipal or industrial discharges and occurrence of any contaminant spills in or near the project area, location of the disposal site (include locus shet), (h) shellfish survey;- (i) identify and describe potential impacts to essential fish habitat (see Condition 10); () delineation of submerged aquatic vegetation, e.g., eelgrass beds;

Federal Screening Procedures

The Corps will review all complete applications for Category 2 projects at interagency screening meetings (or "joint processing" meetings) with the Federal resomce agencies (U.S. Fish & Wildlife Service, U.S. Environmental Protection Agency and National Marine Fisheries Service) to determine whether such activities may be authorized under this PGP. The

A=n 2003 Ameadnnt 4 Federal resource agencies will comprise the interagency review team. The Massachusetts CZM also attends the meetings and the Corps will notify applicants if an individual CZM consistency concurrence is required. Other State agency representatives frequently attend the meetings as advisors and for informal consultation purposes. The meetings are held at the Corps every three weeks, or coordinated as necessary to provide applicants with a timely response. The Corps and Federal resource agencies, at the branch chief or equivalent level, may agree on certain activities that do not need to be coordinated at these meetings.

If the Corps and Federal resource agencies determine that the activity is eligible for the PGP, the Corps will send an authorization letter directly to the applicant and a copy to the DEP regional office. Ifthe activity is not eligible under the POP or if the Corps determines that additional information is required. the Corps will notify the applicant in writing and Will send a copy of this notification to DEP.

For projects reviewed with the Federal agencies, the agencies may recommend within ten business days special conditions for projects to avoid or minimize adverse environmental effects and to ensure the terms and conditions of the PGP are met The Corps will determine that a project is ineligible under this POP and will begin its Individual Permit review procedures if any one of the Federal agencies, within ten working days of the screening meeting, expresses a concern within their area of expertise, states the resource or species that could be impacted by the project, and describes the impacts that, either individually or cumulatively, will be more than minimal.

This 10-day notice may be verbal and is not required to be fully documented, but must be confirned with a written response within an additional ten working days from the date of the verbal comment. - Written responses must be signed by the Federal resource agency field supervisor or branch chief as appropriate and must identify the affected resource within their area of expertise. The intent of the verbal notification is to allow the Corps to give timely notification to the applicant that additional information is needed and/or an Individual Permit may be required. The Corps may reinstate a project's eligibility under the PGP provided the Federal agencies' concerns are satisfied. The Federal resource agencies may request additional information within their area of expertise within ten working days of the screening meeting. This information shall be commensurate to the level of impact and agreed upon by the Corps. The agencies axe allowed an additional ten working days after their receipt of additional information to provide special conditions or a written Individual Permit request to the Corps.

Coastal Zone Managemnent Screening Procedures Category 2 projects that involve work in or affecting the coastal zone will be screened with CZM at the joint processing meeting or electronically if a CZM representative is not at the joint processing meeting. The CZM will make a determination, at joint processing or within 10 working days of receipt, that (1) CZM consistency may be waived; (2) CZM consistency may be waived provided CZM and the Corps agree to special conditions to protect the land or water uses or natural resources of the coastal zone; or (3) an individual CZM consistency concurrence will be required for the project. If CZM requires an individual CZM consistency concurrence, the Corps may issue a conditional letter, which will notify the applicant that the Federal authorization is not valid until CZM consistency concurrence is issued or waived by the Office of Coastal Zone Management. -0 June 2003 Amcnamnm 50 Minerals Management Service (MMS) Review Projects with construction of solid fill structures or discharge of fill that may extend beyond the coastline or the baseline from which the territorial sea is measured (ie., mean low water), must be coordinated with MMS, Outer Continental Shelf (OCS) Survey Group, pursuant to the Submerged Lands Act (43 USC. Section 13011315,33 CFR 320.4(f)). The Corps will forward project information to MMS for their review. MMS will coordinate their determination with the Department of the Interior (DOI) Solicitor's Office. The DOI will have 15 calendar days from the date MMS is in receipt of the project information to determine if the baseline will be affected. No notification within the fifteen-day review period will constitute a "no effect" determination. Otherwise, the solicitor's notification to the Corps may be verbal but must be followed with a written confirmation within ten business days from the date ofthe verbal notification. This procedure will be eliminated if the Commonwealth of Massachusetts provides a written waiver of interest in any increase in submerged lands caused by a change in the baseline resulting from solid fill structures or fills authorized under this PGP.

401 Water Ouality Certificftion For work in Corps jurisdiction involving a discharge to waters of the U.S., an Individual 401 Water Quality Certification (WQC) must be obtained from or waived by the Massachusetts DEP before work can proceed as authorized by this PGP for the following circumstances (pursuant to MGL C.21 Sections 26 - 53 and regulations at 314 CMR 9.00). The following are excerpted from the Massachusetts DEP regulations at 314 CMR 9.04: Activities Requiring an Application:

(1) More than 5000 SF Any activity in an area subject to 310 CMR 10.00 which is also subject to 33 USC 1251, et seq. and will result in the loss of more than 5000 SF cumulatively of bordering and isolatedvegetated wetlands and land under water.

(2) OutstandingResource Wate. Any activity resulting in any discharge of dredged or fill material to any Outstanding Resource Water. See 314 CMR 4.00 Massachusetts Surface Water Quality Standards at http://www.statnmu/depibwpiw/f es/314emr4.htm.

(3)Real &late Subdivision - Any discharge of dredged or fill material associated with the creation of a real estate subdivision, unless there is a recorded deed restriction providing notice to subsequent purchasers limiting the amount of fill for the single and complete project to less than 5000 square feet cumulatively of bordering and isolated vegetated wetlands and land under water and the discharge is not to an Outstanding Resource Water. Real estate subdivisions include divisions where approval is required and where approval is not required under the Subdivision Control Law, MGL. c. 41, §81K through 81GG. Discharges of dredged or fill material to create the real estate subdivision include but are not limited to the construction ofroads, drainage, sidewalks, sewer systems, buildings, septic systems, wells, and accessory structures.

(4) Activities Exempt wader MGL c. 131, f40. Any activity not subject to MGL. c. 131, §40, which is subject to 33 USC 1251, et seq. and will result in any discharge of dredged or fill material to bordering vegetated wetlands or land under water.

(5) Routine Maintenance Routine maintenance of existing channels, such as mosquito control projects or road drainage maintenance, that will result in the annual loss of more than 5000 square feet cumulatively of bordering and isolated vegetated wetland and land under water will be evaluated

June2003 Amend 6 under the criteria of 314 CMR 9.06. A single application may be submitted and a single certification may be issued for repeated routine maintenance activities on an annual or multi-year basis not to exceed five years.

(6) More than 5000 sq.ft. of IsolatedVegetated Wetlands. Any activity in an area not subject to jurisdiction of MGL. c. 131, §40 that is subject to 33 U.S.C;1251, et seq. (i.e., isolated vegetated wetlands) which will result in the loss of more than 5000 square feet cumulatively of bordering and isolated vegetated wetlands and land under water.

(7) Rare andEndangered Species Habitatin Isolated Vegetated Wetlands. Any activity resulting in the discharge of dredged or fill material to an isolated vegetated wetland that has been identified as habitat for rare and endangered species.

(8) Salt Marsh. Any activity resulting in the discharge of dredged or fill material in any salt marsh.

(9) Individual 404 Permit Any activity that is subject to an Individual Permit under Section 404 of the Clean Water Act by the Corps of Engineers.

(10).AgricuturalLimitedProjectAgricultural work, not exempt under MGL. c. 131, $40, referenced in and performed in accordance with 310 CMR 10.53(5). Provided the activity does not result in any discharge of dredged or fil material to an Outstanding Resource Water, such work will be presumed to meet the criteria of 314 CMR 9.06 where a comparable alternatives analysis is' performed by the Natural Resources Conservation Service and included in the Notice of Intent.

(11) DiscretionaryAuthority. Any activity where the Department invokes discretionary authority to require an application based on cumulative effects of activities, cumulative effects from the discharge of dredged or fill material to bordering or isolated vegetated wetlands or land under water, or other impacts that may jeopardize water quality. The Department will issue a written notice of and statement of reasons for its determination to invoke this discretionary authority not later than ten business days after its receipt of an Order of Conditions.

(12) DredgingGreater than 100 c.y. Any dredging or dredged material disposal of more than 100 cubic yards in navigable waters.

June 2003 Amendment 7- Eutergency Situations Procedures Emergency situations are limited to sudden, unexpected occurrences that could potentially result in an unacceptable -hazard to life, a significant loss of property, or an immediate, unforeseen, and significant economic hardship if corrective action requiring a permit is not undertaken within a time period less than the normal time needed to process an application under standard procedures. If an emergency situation requires action in less than 30 days after the occurrence, it qualifies for the amended notification procedures described below. Notification Procedures for Emergency Situations: Any project proponent may request emergency authorization from the Corps, however the Corps will determine if a project qualifies for these emergency situation procedures. The Federal resource agencies, the Massachusetts Historical Commission and the tribes will each designate an emergency contact and an alternate in the event the regular contact is unavailable. When an application for Category 2 work is received that the Corps determines is an "emergency" as defined above, the Corps will fax a copy of the plans and Determination of Eligibility to the agency representatives and their alternates. The resource agencies would then have sixteen working hours to notify the Corps if they have any comments on authorization of the project under the PGP. Objections to the Corps determiration of an "emergency" sitestion will not be accepted. If no response is received within two working days, the Corps will proceed with a decision on the application. If the resource agencies have comments on the proposal, they will have two working days to put their comments in writing. If written comments from the Federal agencies are not received within two working days, the Corps will proceed with a decision on the application. If a Federal agency requests that an Individual Permit be required for a project or requests modifications to the project based on concerns within their area(s) of expertise, the Corps will notify the applicant within one working day of receipt of that request that the project as proposed does not qualify for authorization under this POP and the emergency Individual Permit procedures may be followed. In any event, the Corps will notify the applicant within two working days of . commencement of the screening process as to whether the project may proceed under this PGP. Notification Rocedures for FEMA and MEMA Declared Emergency Situations. The Massachusetts DEP, Massachusetts Emergency Management Agency (MEMA), or the Federal Emergency Management Agency (FEMA) will notify the Corps within 24 hours of the occurrence of a disaster and advise the Corps of the nature of the occurrence and any known remedial and/or protective measures. The Corps will notify the emergency contact of the Federal resource agencies, the Massachusetts Historical Commission and the tribes that a disaster has occurred within one woring day ofbeing notified by the MA DEP, MEMA or FEMA. The Corps will work with FEMA, MEMA and the emergency contacts under the "Notification Procedures for Emergency Situations" section above to expedite authorization under this PGP.

W. CORPS AUTHORIZATIONS: INDIDUAL PERMI[T Work that is defined in the Individual Permit category of Appendix A - Definition of Categories or that does not meet the terms and conditions of this PGP will require an application for an Individual Permit from the Corps (see 33 CFR Part 325.1). The screening procedures outlined for Category 2 projects will only serve to delay project review in such case. The applicant shall submit the appropriate application materials (including the Corps application form) at the earliest possible date. General information and application forms can be obtained at our web site (See Page 17), or by calling (978) 318-8338,(800) 362-4367, or (800) 343-4789 outside of Massachusetts. Individual WQC and CZM consistency concurrence are required when applicable from the Commonwealth of Massachusetts before Corps permit issuance. Juno 2003 Amendment a V. PROGRAMMATIC GENERAL PERMIT CONDITIONS: The following conditions apply to activities authorized under this PGP, including all Category 1 (non-reporting) and Category 2 (reporting - requiring screening) activities: General Requirements 1. Other Permits: Authorization under this PGP does not obviate the need to obtain other Federal, state, or local authorizations required by law.

2. Federal Jurisdictional Boundaries. Applicability of this PGP shall be evaluated with reference to Federal jurisdictional boundaries. Applicants are responsible for ensuring that the boundaries used satisfy the Federal criteria defined at 33 CFR 328-329. These sections prescribe the policy, practice and procedures to be used in determining the extent of jurisdiction of the Corps of Engineers concerning "waters of the United States" and "navigable waters of the United States." Wetland boundaries shall be delineated in accordance with the January 1987 Corps of Engineers Wetlands Delineation Manual, located at http:/www.saj.usace.anny.mil/permit documents /S7manual.pdf. The U.S. Fish and Wildlife Service publishes the National List of Plant Species that Occur in Wetlands, located at http:/www.nwi.fws.gov. The Natural Resources Conservation Service (NRCS) publishes the current hydric soil definition, criteria and lists, located at http://www.statlab.iastate. edu/soils/hydric.

3. Mfinimal Effects. Projects authorized by this PGP shall have minimal individual and cumulative adverse environmental impacts as determined by the Corps.

4. Discretionary Authority. Notwithstanding compliance with the terms and conditions of this permit, the Corps retains discretionary authority to require an Individual Permit review based on concerns for the aquatic environment or for any other factor of the public interest [33 CFR 320.4(a)]. This authority is invoked on a case-by-case basis whenever the Corps detennines that the potential consequences of the proposal warrant Individual Permit review based on the concerns stated above. This authority may be invoked for projects with cumulative environmental impacts that are more than minimal or if there is a special resource or concern associated with a particular project that is not already covered by the remaining conditions of the PGP that warrants greater review. Whenever the Corps notifies an applicant that an Individual Permit may be required, authorization under this PGP is voided and no work may be conducted until the Corps Individual Permit is obtained or until the Corps notifies the applicant that further review has demonstrated that the work may proceed under this PGP.

5. Single and Complete Projects. This PGP shall not be used for piecemeal work and shall be applied to single and complete projects. All components of a single project shall be treated together as constituting one single and complete project and/or all planned phases of a multi-phased project. For linear projects, such as power lines or pipelines with multiple crossings, the "single and complete project" (i.e. single and complete crossing) will apply to each crossing of a separate water of the United States (i.e. single waterbody) at that location; except that for linear projects crossing a single waterbody several times at separate and distant locations, each crossing is considered a single and complete project, and may be reviewed for Category 1 eligibility. (However, individual channels in a braided stream or river, or individual arms of a large, irregularly-shaped wetland or lake, etc., are not separate waterbodies.) -Ifany crossing requires a Category 2 activity, then the entire linear project shall be reviewed as one project under Category 2. Also, this PGP shall not be used for any activity that is part ofan overall project for which an Individual Permit is required. June 2003 Amenftmn 9 6. Permit On-Site. For Category 2 projects the permittee shall ensure that a copy of this PGP and the accompanying authorization letter are at the work site (and the project office) authorized by this PGP whenever work is being performed, and that all personnel with operation control of the site ensure that all appropriate personnel perfonning work are fuly aware of its terms and conditions. The entire permit authorization shall be made a part of any and all contracts and sub-contracts for work that affects areas of Corps jurisdiction at the site of the work authorized by this PGP. This shall be achieved by including the entire permit authorization in the specifications for work The term "entire permit authorization" means this PGP and the authorization letter (including its drawings, plans, appendices and other attachments) and also includes permit modifications. If the authorization letter is issued after the construction specifi-cations, but before receipt of bids or quotes, the entire permit authorization shall be included as an addendum to the specifications. If the authorization letter is issued after receipt of bids or quotes, the entire permit authorization shall be included in the contract or sub-contract as a change order. Although the permittee may assign various aspects of the work to different contractors or sub-contractors, all contractors and sub-contractors shall be obligated by contract to comply with all environmental protection provisions contained within the entire PGP authorization, and no contract or sub-contract shall require or allow unauthorized work in areas of Corps jurisdiction.

National Concerns: 7. Historic Properties. Any activity authorized by this PGP shall comply with Section 106 of the National Historic Preservation Act. Information on the location and existence of historic resources can be obtained from the Massachusetts Historic Preservation Officer, the National Register of Historic Places, and the Wampanoag, Stockbridge-Munsee and Narragansett Tribal Historic Preservation Officers. See Page 17 for historic properties contacts and geographic areas of concern for each. Project proponents shall apply to the Corps for all projects that would otherwise qualify for Category 1 if there is the potential for an effect on a historic property within the permit area or any known historic property that may occur outside the permit area. Historic properties include those that are eligible for inclusion, but not necessarily listed on the National Register. If the permittee, during construction of work authorized herein, encounters a previously unidentified archaeological or other cultural resource within the area subject to Department of the Army jurisdiction that might be eligible for listing in the National Register of Historic Places, he/she shall immediately notify the District Engineer.

&.NationalLands. Activities authorized by this PGP shall not impinge upon the value of any National Wildlife Refuge, National Forest, National Marine Sanctuary (e.g. Stellwagen Bank) or any area administered by the National Park Service (e.g. Cape Cod National Seashore)

9. Endangered Species. No activity authorized under this PGP permit may affect a threatened or endangered species or a species proposed for such designation, as identified under the Federal Endangered Species Act (ESA) or which is likely to destroy or adversely modify the critical habitat of such species, or which would result in a "take" of any threatened or endangered species of fish or wildlife, or which would result iany other violation of Section 9 of the ESA protecting threatened or endangered species of plants. Applicants shall notify the Corps if any listed species or critical habitat is in the vicinity of the project and shall not begin work until notified by the district engineer that the requirements of the ESA have been satisfied and that the activity is authorized. Information on the location of threatened and endangered species and their critical habitat can be obtained from Otbe US. Fish and Wildlife Service and National Marine Fisheries Service (NMFS) (addresses listed on Page 16).

June 200 Anwnm=t 10 10. Essential Fish Habitat. As part of the PGP screening process, the Corps will coordinate with NMFS in accordance with the 1996 amendments to the Magnuson-Stevens Fishery and Conservation Management Act to protect and conserve the habitat of marine, estuarine and anadromous finfish, mollusks, and crustaceans. This habitat is termed "Essential Fish Habitat" (EF1), and is broadly defined to include "those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity." Applicants may be required to describe and identify potential impacts to EFH. Any work, except for exploratory drilling and borings for bridges, in streams in the Connecticut and Merrimack River watersheds that are stocked with Atlantic salmon (see attached lists) shall not be authorized under Category I of the MAPGP and must be screened for potential impacts to EFH. Conservation recommendations made by NMFS will normally be included as a permit requirement by the Corps. For additional information see the EFH list on Page 18 and the EFH regulations at 50 CFR Pat 600 (hittp//wwwjnmfsnoaa.gov). Additional information on the location of EFH can be obtained from NMFS. The NMFS contact information is provided on Page 16.

11. Wild and Scenic Rivers. Any activity that occurs in a component of, or within 0.25 mile up or downstream of the main stem or tributaries of a segment of, or that has the potential to alter flows within a river within the National Wild and Scenic River System must be reviewed by the Corps under the procedures of Category 2 of this PGP regardless of size of impact. This condition applies to both designated Wild and Scenic Rivers and rivers officially designated by Congress as study rivers for possible inclusion while such rivers are in official study status. The Corps will consult with the National Park Service (NPS) with regard to potential impacts of the proposed work on the resource values of the wild and scenic river. The culmination of this coordination will be a determination by the NPS and the Corps that the worlk (1) may proceed as proposed; (2) may proceed with recommended conditions; or (3) could pose a direct and adverse effect on the resource values of the river and an Individual Permit is required. If preapplication consultation between the applicant and the NPS has occurred whereby NPS has made a determination that the proposed project is appropriate for authorization under this PGP (with respect to Wild and Scenic River issues), this determination should be furnished to the Corps with submission of the application.

National Wild and Scenic Rivers System segments for Massachusetts as of December 1999, include: SudburylAssabet/Concord Rivers as follows: the Sudbury from the Danforth Street bridge in Framigham downstream to the confluence with the Assabetthe Assabet from 1,000 feet below the Damon Mill Dam downstream to the confuence with the Sudbury, and the Concord from the confluence of the Sudbury and Assabet downstream to the Route 3 bridge in Billerica; and Westfleld River as follows- East Branch from the Cummington/Wmdsor, MA, town line downstream to 0.8 mile upstream of the confluence with Holly Brook, the Middle Branch from the Peru/Worthington, MA, town line downstream to the confluence with Kinne Brook, and 0.4 mile of the Glendale Brook tributary from Clark Wright Road bridge to the confluence with the Middle Branch, and the West Branch from the railroad bridge 2,000 feet downstream of Becket Village in Becket MA, downstream to the Chester/Huntington, MA, town line. The NPS has designated the Taunton River from the confluence of the Town River and Matfield River in Bridgewater downstream to the Forge River in Raynham, MA as a study river.

12 Federal Navigation Project. Any structure or work that extends closer to the horizontal limits of any Corps Federal Navigation Project (see Appendii B) than a distance of three times the project's authorized depth shall be subject to removal at the owner's expense prior to any future Corps dredging or the performance of periodic hydrographic surveys.

Jua2003 AnNmm I I 13. Federal Liability. In issuing this permit, the Federal Government does not assume any liability for the following: (a) damages to the permitted project or uses thereof as a result of other permitted or unpennitted activities or from natural causes; (b) damages to the permitted project or uses thereof as a result of current or future activities undertaken by or on behalf of the United States in the public interest; (c) damages to persons, property, or to other permitted or unpermitted activities or structures caused by the activity authorized by this permit; (d) design or construction deficiencies associated with the pernitted work; (e) damage claims associated with any future modification, suspension, or revocation of this permit.

14. Navigation. There shall be no unreasonable interference with navigation by the existence or use of the activity authorized herein, and no attempt shall be made by the pennittee to prevent the full and free use by the public of all navigable waters at or adjacent to the activity authorized herein. The permittee understands and agrees that, if future operations by the United States require the removal, relocation, or other alteration of the structure or work herein authorized, or if, in the opinion of the Secretary of the Army or his authorized representative, said structure or work shall cause unreasonable obstruction to the flee navigation of the navigable waters, the permittee will be required, upon due notice from the Corps of Engineers, to remove, relocate, or alter the structural work or obstructions caused thereby, without expense to the United States. No claim shall be made against the United States on account of any such removal or alteration.

Minimizatio Ental mpacts: 15. Minimization. Discharges of dredged or fill material into waters of the United States, including wetlands, shall be avoided and minimized to the maximum extent practicable. Permittees may only fill those jurisdictional wetlands that the Corps authorizes to be filled and impact those wetlands that the Corps authorizes as secondary impacts. If not specifically authorized, any unauthorized fill or secondary impact to wetlands may be considered as a violation of the Clean Water Act

16. Heavy Equipment In Wetlands. Heavy equipment other than fixed equipment (drill rigs, fixed cranes, etc.) authorized to work within wetlands shall not be stored, maintained or repaired in wetlands, and as much as possible it shall not be operated there. Where construction requires the operation of heavy equipment in wetlands it shall not be located directly on wetland soils and vegetation; it shall be placed on mats that arc adequate to support the equipment in such a way as to minimize disturbance of wetland soil and vegetation. Other support structures that are less impacting and are capable of safely supporting equipment may be used with written Corps authorization Similarly, not using swamp mats during frozen, dry or other conditions may be allowed with written Corps authorization. An adequate supply of spill containment equipment shall be maintained on site.

17. Temporary FI. No temporary fill (e.g., access roads, cofferdams) shall be placed in waters of the U.S. (including wetlands) unless specifically authorized in writing by the Corps. If temporary fill is authorized it shall be stabilized and maintained during construction in such a way as to prevent its eroding into portions of waters of the U.S. where it is not authorized. o Unconfined temporary fill authorized for discharge into flowing water (rivers and streams) shall consist only of clean washed stone. o Temporary fill authorized for discharge into wetlands shall be placed on geotextile fabric laid on the pre-construction wetland grade; o Temporary fill shall be removed as soon as it is no longer needed, and it shall be disposed of at an upland site and suitably contained to prevent its subsequent erosion into waters of the U.S. June 2003 Anmmrnm= 12 o Waters of the US. where temporary fill was discharged shall be restored (see Condition 18). o If temporary fill is staged and then returned to its original location, e.g. sewer projects through wetlands, the original location shall be restored. o No temporary work shall drain a water of the U.S. by providing conduit for water on or below the surface.

18. Restoration. o Upon completion of construction, all disturbed wetland areas (the disturbance of these areas must be authorized) shall be stabilized with a wetland seed mix containing only plant species native to New England. o The introdetim or sread of invasive plant species in disturbed areas shall be controlled. o In areas of authorized temporary disturbance, if trees are cut they shall be cut at ground level and not uprooted in order to prevent disruption to the wetland soil structure and to allow stump sprouts to revegetate the work area, unless otherwise authorized. o Wetland areas where permanent disturbance is not authorized shall be restored to their original condition and elevation, which under no circumstances shall be higher than the pre-construction elevation. Original condition means careful protection and/or removal of existing soil and vegetation, and replacement back to the original location such that the original soil layering and. vegetation schemes are approximately the same, unless otherwise authorized.

19. Coastal Bank Stabilization. Projects involving reconstruction or maintenance of an existing coastal bank stabilization structure within Corps jurisdiction should be designed to minimize environmental effects to the maximum extent practicable (includes minimization of scour, etc.).

20. Sedimentation and Erosion Control. Adequate sedimentation and erosion control management measures, practices and devices, such as phased construction, vegetated filter strips, geotextile silt fences or other devices, shall be installedand properly maintained to reduce erosion and retain sediment on-site during and after construction. They shall be capable of preventing erosion, of collecting sediment suspended, and floating materials, and of filtering fine sediment These devices shall be removed upon completion of work and the disturbed areas shall be stabilized. The sediment collected by these devices shall be removed and placed at an upland location, in a manner that will prevent its later erosion into a waterway or wetland. All exposed soil and other fills shall be permanently stabilized at the earliest practicable date.

21. Waterway Crossing. (a) All temporary and permanent crossings of waterbodies shall be suitably culverted, bridged, or otherwise designed to withstand and to prevent the restriction of high flows, and so as not to obstruct the movement of aquatic life indigenous to the waterbody beyond the actual duration of construction. (h) There shall be no projects involving open trench excavation in flowing waters. However, these projects may qualify for Category 1 provided they utilize management techniques such as temporary flume pipes, culverts, cofferdams, etc. and maintain normal flows within the stream boundary's confines (see Appendix A, Endnote 2) so the work does not occur in flowing waters. Projects utilizing these management techniques must meet the other Category 1 requirements (see Appendix A, Page 1) and all of this PGP's terms and conditions. If not, they will require review under the Category 2 screening procedures. Projects proposing no management techniques to avoid open trench excavation will require an Individual Permit. (c) Temporary bridges, culverts, or cofferdams shall be used for equipment access across streams (note: areas of fill and/or cofferdams must be included in total waterway/wetlands impacts to determine applicability of this POP). (d) For projects that otherwise meet the terms of Category 1, in-stream June 2003 Amendmnt 13 construction work shall be conducted during the low flow period, July I to October 1 in any year. Projects that are not to be conducted during that time period arc ineligible for Category I and shall be screened pursuant to Category 2, regardless of the waterway and wetland fill and/or impact area.

22. Discharge of Pollutants. All activities involving any discharge of pollutants into waters of the United States authorized under this POP shall be consistent with the Massachusetts DEP's Stormwater Management Policy (as described in "Stormwater Management, Volume One: Stormwater Policy Handbook," March 1997, or subsequent versions), applicable water quality standards, effluent limitations, standards of performance, prohibitions, and pretreatment standards and management practices established pursuant to the Clean Water Act (33 USC 1251), and other applicable State and local laws. If applicable water quality standards, limitations, etc. are revised or modified during the term of this permit, the authorized work shall be modified to conform with these standards within six months of the effective date of such revision or modification, or within a longer period of time deemed reasonable by the District Engineer in consultation with the Regional Administrator of the Environmental Protection Agency. Applicants may presume that State water quality standards are met with issuance of the WQC.

23. Spawning Areas. Discharges in fish and shellfish spawning or nursery areas during spawning seasons shall be avoided. During all times of year, impacts to these areas shall be avoided or minimized to the maximum extent practicable.

24. Storage of Seasonal Structures. Coastal structures, such as pier sections and floats, that are. removed from the waterway for a portion of the year shall be stored in an upland location, located above mean high water and not in tidal wetlands.

25. Environmental Functions and Values. The permittee shall make every reasonable effort to carry out the construction or operation of the work authorized herein in a manner so as to maintain, as much as practicable, and to minimize any adverse impacts on existing fish, wildlife, and natural environmental functions and values.

Procedural Conditions: 26. Inspections. The pernittee shall allow the District Engineer or his authorized representative(s) to make periodic inspections at any time deemed necessary in order to ensure that the work is being performed in accordance with the terms and conditions of this permit The District Engineer may also require post-construction engineering drawings for completed work or post-dredging survey drawings for any dredging work.

27. Maintenance. The permittee shall maintain the work or structures authorized herein in good condition, including maintenance to ensure public safety. This does not include maintenance of dredging projects. Maintenance dredging is subject to the review thresholds on the attached Definition of Categories sheets, and/or any conditions included in a written Corps authorization.

28. Property Rights. This permit does not convey any property rights, either in real estate or material, or any exclusive privileges, nor does it authorize any injury to property or invasion of - rights or any infringement of Federal, State, or local laws or regulations.

Inne 200A nrnt 14 29. Modification, Suspension, and Revocation. This permit may be either modified, suspended, or revoked in whole or in part pursuant to the policies and procedures of 33 CFR 325.7. Any such action shall not be the basis for any claim for damages against the United States.

30. Restoration. The permittee, upon receipt of a notice of revocation of authorization under this permit, shall restore the wetland or waterway to its former conditions, without expense to the United States and as directed by the Secretary of the Army or his authorized representative. If the permittee fails to comply with such a directive, the Secretary or his designee may restore the wetland or waterway to its former condition, by contract or otherwise, and recover the cost from the permittee.

31. Special Conditions. The Corps may independently or at the request of the Federal resource agencies impose other special conditions on a project authorized pursuant to this PGP that are determined necessary to minimize adverse environmental effects or based on any other factor of the public interest Failure to comply with all conditions of the authorization, including special conditions, will constitute a permit violation and may subject the permittee to criminal, civil, or administrative penalties, or restoration.

32. False or Incomplete Information. If the Corps makes a determination regarding the eligibility of a project under this permit and subsequently discovers that it has relied on false, incomplete, or inaccurate information provided by the permittee, then the permit shall not be valid and the Government may institute appropriate legal proceedings.

33. Abandonment If the permittee decides to abandon the activity authorized under this PGP, unless such abandonment is merely the transfr of property to a third party, he/she must restore the area to the satisfaction of the District Engineer.

34. Enforcement cases. This PGP does not apply to any existing or proposed activity in Corps jurisdiction associated with an on-going Corps of Engineers or Enviromnental Protection Agency enforcement action, until such time as the enforcement action is resolved or the Corps and/or EPA determines that the activity may proceed independently without compromising the enforcement action;

Duration of Authorzation/Grandfatherng:. 35. Duration of Authorization. This PGP expires five years from the effective date listed at the top of Page 1. Activities authorized under Category 1 of this PGP that have commenced (i.e, are under construction) or are under contract to commence in reliance upon this PGP's authorization wili remain authorized provided the activity is completed within twelve months of this POP's expiration date. Activities authorized under Category 2 of this PGP will remain authorized in accordance with the project-specific date that the Corps provides to the permittee in the PGP authorization letter, unless: (a) the PGP is either modified or revoked, or (b) discretionary authority has been exercised on a case-by-case basis to modify, suspend, or revoke the authorization in accordance with 33 CFR 325.2(eX2). The permittee must be able to document to the Corps satisfaction that the project was under construction or contract by the appropriate date. Activities compj under the Category I or Category 2 authorizations of this PGP will contirue to be authorized by this POP after its expiration date.

June 200 Amendment 15 36. Previously Authorized Activities. (a) Activities completed under the authorizations of past PGP's that were in effect at the time the activity was completed will continue to be authorized by those PGP's. (b) Projects that have received written verification or approval from the Corps, based on applications made to the Corps prior to issuance of this PGP for the previous nationwide pernits, regional general permits, or letters of permission shall remain authorized as specified in each authorization. (c) Activities authorized pursuant to 33 CFR Part 330.3 CActivities occurring before certain dates') are not affected by this PGP.

VL CONTACTS FOR PROGRAMMATIC GENERAL PER MT:

1. FEDERAL U.S. Army Corps of Engineers .Wild and Scenic Rivem: Regulatory Branch National Park Service 696 Virginia Road North Atlantic Region Concord, Massachusetts 01742 15 State Street (978) 318-8335 Boston, Massachusetts 02109 (800) 343-4789 (ME, VT, NH, RI, CT) (617).223-5191 (800) 362-4367 (Massachusetts)

Federal Endangered Species and Essential Fish Habitat: Federal Endangered Species: National Marine Fisheries Service U.S. Fish and Wildlife Service One Blackburn Drive 70 Commercial Street, Suite 300 Gloucester, Massachusetts 01930 Concord, New Hampshire 03301 (978)281-9300 (603)223-2541

2. STATE OF MASSACHUSETTS Department of Environmental Protection (DEP): DEP Division of Wetlands and Waterways One Winter Street Boston, Massachusetts 02108 (617)292-5695

DEP Regional Offices: DEP-Western Regions DEP-Southeast Region Wetlands Protection Program Wetlands Protection Program 436 Dwight Street 20 Riverside Drive Route 105 Springfield, Massachusetts 01103 Lakeville, Massachusetts 02347 (413)784-1100 (508)946-2800

DEP-Central Region DEP-Northeast Region Wetlands Protection Program Wetlands Protection Program 627 Main Street' One Winter Street, 5 Floor Worcester, Massachusetts 01608. Boston, Massachusetts 02108 (508) 792-7650 (617)292-5500 Am 2003 Ammnd-nt. 16 Massachusetts Office of Coastal Zone Massachusetts Division of Marine Fisheries Management (CZM) Massachusetts Division ofMarine Fisheries Coastal Zone Management SE Marine Fisheries Station 251 Causeway Street, Suite 900 50A Portside Drive Boston, Massachusetts 02114 Pocasset, Massachusetts 02559 (617) 626-1200 (508) 563-1779

3. HISTORIC PROPERTIES: Massachusetts Historical Commission Wampanoag Tibal Historic The Massachusetts Archives Bldg. Preservation Officer 220 Morrissey Boulevard 20 Black Brook Road Boston, Massachusetts 02125 Aqninnab, MA 02535 (617) 727-8470 (508)645-9265 (617) 727-5128 (fax) (508) 645-3233 (fax) Area of conceM: All of Massachusetts Area ofco All of Massachusetts

Narragansett Tribal Historic Trbal Historic Preservation Officer Preservation Officer c/u Stockbridge-Munsee Community P.O. Box 700 P.O. Box 70 Wyoming, Rhode Island 02898 Bowler, Wisconsin 54416 (401)539-1190 (715) 793-3970 (401) 742-5048 (cell) Area of concer: West of Connecticut River (401) 5394217 (fax) 0 Area of concern: All of Massachusetts

4. ORGANIZATIONAL WEBSITES: Army Corps of Engineers www.nae.usace.army.mil (click "Regulatory/Pennitting") Corps of Engineem Headquarters w (click "Services for the Public") Environmental Protection Agency httj/www.epa.gov/owow/wetlands/ National Marine Fisheries Service www.mnfsoaa.gov U.S. Fish and Wildlife Service www.fwsmov National Park Service MA Executive Office of Env. Affairs, wwsbftat msvig MA Deptof Environmental Protection wwwste.masp (access the four regional offices) MA DEP, Division of Wetlands www~state~maausdep/brp/ww/xpwwhome~htnm MA DEP, Division ofWaterways MA Division of Marine Fisheries wwwstatemausdfwee/dmf/ MA Div. of Fisheries & Wildlife www.slatejna.usdfwele/dfwK/df toc.htm MA Endangered Species Program www.state .mus/dfwel/dfwnhesphedtage.htm MA Coastal Zone Management www.saenausczm MassGIS www.statehian.s/mgi/assgis.htm MA Historical Commission Wampanoag Tribe Narragansett Tribe Stockbridge-Munsee Tribe www.mohicaonco 0 JAne2003 Ammndmt 17 VH. ESSENTIL FISH HABITAT (EFH) Any fill in the following Waters of the U.S. in the specified towns must be reviewed under Category 2 of the MAPGP for potential impacts to EFH for Atlantic sahnon. The following streams are stocked with Atlantic salnon (Salmo salar). Please note that the mainstems of the Connecticut and Merrimack Rivers are Navigable waters of the U.S. and any fill in them must be reviewed under Category 2. Any questions on locations should be directed to the Corps.

Connecticut River Watershed Agawam Westfield River Ashfield: - Bear River, South River to Baptist Corner Road Athol: Millers River Becket Depot Brook, Shaker Mill Brook, Walker Brook to Spark Brook, West Branch Westfield River, Yokum Brook to Rudd Pond Brook Bernardston: Fall River Blandford: Wigwam Brook Buckland: Deerfield River Charlemont: Chickley River, Cold River, Deerfield to Pelham Brook, North River, Pelham Brook Chester: Middle Brunch Westfield River, Walker Brook, West Branch Westfield River Chesterfield: Child's Brook West Branch, Dead Branch, Tower Brook, Westfield River Colrain: North River, East Branch North River, West Branch North Rive, Green River Conway: Bear River, Deerfield River, Poland Brook, South River Cummington: Bartlett Brook, Child's Brook West Branch, Meadow Brook, North Branch Swift River to Stage Road, Swift River, Westfield Brook, Westfield River Deerfield: Deerfield River Basthampton: Manhan River to North Branch Manhan River, North Branch Manhan River Erving: Millers River Florida: Cold River Gill: Fall River Goshen: Swift River Greenfield: Allen Brook, Deerfield River, Fall River, Green River Hatfield: Mill River to West Brook, West Brook Hawley: Chickley River to King Brook, Mill Brook to Gorge Hill Road Huntington: Dead Branch to Westfield River, Little River, Middle Branch Westfield River Pond Brook to Searle Road, Roaring Brook to Mica Mill Road, West Branch Westfield River, Westfield River Leverett: Sawmill River Leyden: Green River Middlefield: Factory Brook, Middle Branch Westfield River to Tuttle Brook, West Branch Westfield River Montaque: Millers River, Sawmill River Montgomery: Westfield River, Roaring Brook Northampton: North Branch Manhan River Orange: Millers River - Plainfield: Bartlett Brook to Prospect Street, Meadow Brook to Gloyd Street Rome: Pelham Brook to Rice Brook Royalston: Millers River to Birch Hill Dam Russell: Bradley Brook, Potash Brook, Stage Brook,.Westfield River

Jum 2003 Amcment 18s Savoy: Cold River to Black Brook, Westfield River to Griffin Hill Road Shelburne: Allen Brook, Deerfield River, North River Shutesbury: Sawmill River Southampton: North Branch Manhan River Southwick: MunnBrook Washington: Depot Brook to Frost Road Wendell: Millers River Westfield: Little River to Munn Brook, Moose Meadow Brook to Mass Turnpike, Munn Brook, Westfield River Westhampton: Dead Branch, North Branch Manhan River to Northwest Road West Springfield: Westfield River Whately: West Brook to Haydenville Road Windsor: Westfield Brook to East Windsor Road, Westfield River Worthingtor Bronson Brook, Child's Brook West Branch, Little River to Goss Hill Road, Middle Branch Westfield River to Tuttle Brook

Merrimack River Watershed Pepperell: Nissitissit River to Nashua River, Nashua River from Nissitissit River to New Hampshire border

VSL AQUACULTURE GUIDELINES

NOTE: The following guidelines are excerpted from Corps Aquaculture Letter of Permission dated September 1,1991, with some modern clarifications.

Shellfish Aquacultural Facilities are used for bottom and/or suspended culturing and harvesting of bivalve mollusks in the inter-tidal and immediate sub-tidal area of navigable waters. Activities covered include: deployment and maintenance of buoys, rafts, trays, lines, and other equipment associated with the activity; discharge of minor quantities of fill material (ie. as mineral growth medium) and work, including seed placeme4, transplanting, temporary wet storage, and harvesting. Activity must be found to have minimal impacts on navigation and the environment and must meet the following specific criteria:

A. The area authorized for this activity shall not exceed 10 acres, except where the permittee is a duly authorized municipality, for which the maximum size shall be 25 acres;

B. The area and any elevated structures within it are marked in conformance with 33 CFR 64, and permittee has contacted the U.S. Coast Guard, FirstDisrict,Aids to Navigation Branch (617)223-3293 to coordinate the proper buoy markings for the activity. Buoys shall be deployed and maintained as appropriate.

C. No structure or device (except for marking buoys and as noted in D below) shall protrude more than i r above the substrate;

Amm 2003 Amn nt 19 D. Rafts and other floating equipment may be allowed to the extent that they cover no more than 10% of the project area, or 20,000 square feet, whichever is greater. An area shall be considered to be covered with floating equipment if normal navigation through the area is precluded. Projects which are in-place and authorized by the municipality (and State Division of Marine Fisheries if applicable) by 1 September 1991 which have areas containing floating equipment exceeding the aforementioned limits may be authorized if they meet the remaining criteria. All rafts shall be securely anchored to the bottom, and all "lines" shall be attached to fixed mooring points at both ends;

B. Any fill material imported to the project from off site (This is limited to mineralgrowth medium used in culture tray) shall be clean and of comparable grain size to the native substrate;

F. No activity shall occur within a distance of 25 feet from beds of eelgrass, widgeongrass, or saltmarsh, nor shall such vegetation be damaged or removed.

G. An activity shall be deemed not applicable under this PGP ifit can be shown that the activity, including any vehicular access, will have more than minimal negative impacts on avian resources such as, but not limited to: shore birds, wading birds, or members of the waterfowl group. This is meant to include migratory bird nesting, feeding or resting activities (see 50 CFR 10.13);

H. An activity shall be deemed not applicable under this POP ifit can be shown that the activity, including any vehicular access, will have more than minimal negative impacts on existing or naturally occurring beds or population of shellfish, marine worms or other invertebrates that could be used by humans, other mammals, birds, reptiles, or predatory fish.

L No activity nor vehicular access to an activity shall occur in such a way as to negatively impact coastal or freshwater wetlands, or any endangered or threatened species on either the Federal or Massachusetts species list

sIrECTr DATE

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Taatsk4W ,44 021--2524 MTT ROMNEY March 12, 2004 TeL (617) 626-1000 -ovERNOR Fax. (617) 626-1181 KERRYHEALEY - http:Hwww.mass.gov/envir LEUTENANTGOvERNOR. ELLEN ROY HERZFELDER SECRETARY

CERTIFICATE OF THE SECRETARY OF- ENVIRONMENTAL AFFAIRS- ON THE ENVIRONMENTAL NOTIFICATION FORM

-PROJECT NAME : Wetland Reitediation & Restoration. -PROJECT MUNICIALITY : 50. Fordham Road - North Reading & Wilmington PROJECT WATERSHED : Ipswich River EOEA NUMBER : 13211 PROJECT PROPONENT : TRC Environmental Corp. DATE NOTICED IN MONITOR February 11, 2004

Pursuant to the Massachusetts Environmental Policy Act (G. L. c. 30, ss. 61-62H) and Section 11.06. of the MEPA regulations (301 CMR 11.00), I determine that the above project does not require the preparation of an Environmental Impact Report (EIR). According to the Environmental Notification Form and the plans dated December 2003, the proposed project consists of the limited remoiral of wetland soil and the restoration of approximately 9,637 square feet- (sf) of wetlands at three areas of concern located on a.3.91Lacre parcel. Two areas are located -- at stormwater outfalls and the third area is located downgradient- . of one of the outfalls. This.proposed work is being conducted ir . .accordance with the Massachusetts Contingency Plan (MCP) in-order- to eliminate the risk posed by inorganic contaminants (copper, - lead, and zinc). The Department of Environmental Protection (DEP) is requiring the proponent to remove these impacted sediments and wetland soils. The proponent will remove about 350 cubic yards of soil from the 9,637 sf area and restore the disturbed wetlands. The project is subject to MEPA review pprsuant to Sections 1L.03(3)(b)(1}(d} because the project alters 5,000 or more sf of Bordering Vegetated Wetlands (BVW). It may require a Water. Quality Certification from.DEP. Qn January 22, 2004, the Prponent received an .Order. of Conditions as a iuntea project .from the North Reading Conservation Commission. A Programmatic

ifl xm,* mw af EOEA #13211 ENF Certificate March 12, 2O04

General Permit - Category II will be necessary from the U.S., Army Corps of Engineers. MEPA jurisdiction is limited to those aspects of the-project within the subject matter of state permits and areas that may have significant environmental impacts (wetlands and stormwater) .

The project's impacts to wetlands can 'be adequately handled -during the local, ,DEP and Federal permittiig processes. The prbponent -should demonstrate that the project has been designed to meet all performance .standards. DEP should- deal with these issues during project permitting.

I recommend that- the.proponent incorporate DEP's suggestions to comply with the Massachusetts Stormwater Management Policy's Redevelopment Standard for the exiSting development on the site. Rooftop runoff should be infiltrated and parking lot runoff should be treated to remove total annual suspended solids. DEP has recommended that the- snow remoVal and disposal-plan needs to be revised to avoid impact&s to wetland resource Areas-. The proponent also needs to ensure that parking lot sweeping occurs at least twice per year in fall and late spring:

Based on a review of the information provided by the proponent and after donsultation -with relevant-public agencies, I find that the -potential impacts of this project do not warrant' the preparation of an EIR and cari be pioperly addressed in the -- DEP and local permitting processes.

March 12, 2004 - Date --- len-Roy rz

cc:..-Nancy. Baker, DEP/NERO - -

Comments received:

TRC, 2/17/04. - TRC, 2/23/04 DEP/NERO, 3/2/04 -

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e6AmPv /d 02114-2524 - MITT ROMNEY March 12., 2004 TeL (617) 62-1000 GOVERMNOR Fax. (617) 626-1181

KERRY HEALEY . . http://www.mass.gov/envir uEUTENAT GOVERNOR. ELLEN ROY HERZFELDER SECRETARY

CERTIFICATE OF THE SECRETARY OF- ENVIRONMENTAL AFFAIRS - ON THE ENVIRONMENTAL NOTIFICATION FORM

- PROJECT NAME Wetland Remediation & Restoration. PROJECT MUNICIPALITY 50 Fordham Road - North Reading & Wilmington PROJECT WATERSHED Ipswich River - EOEA NUMBER 13211 PROJECT- PROPONENT : TRC Environmental Corp. DATE NOTICED IN MONITOR : February 11, 2004

Pursuant to the Massachusetts Environmental Policy Act (G. L. c. 30, ss'. 61-62H) and Section 11.06 of the MEPA regulations (301 CMR 11.00), I determine that the above project does not require the preparation of an Environmental Impact Report (EIR).

According to the Environmental Notification Form and the plans dated December 2003, the proposed project consists of the limited removal of wetland soil and the restoration of approximately 9,637 square feet- (sf) of wetlands at three areas of concern located on a 3.91-acre parcel. Two areas are located at stormwater outfalls and the third area is located downgradient. . of one of the outfalls. This.proposed work is being conducted in accordance with the Massachusetts Contingency Plan (MCP} inorder- to eliminate the risk posed by inorganic contaminants (copper, lead, and zinc). The Department of Environmental Protection (DEP) is requiring the proponent to remove these impacted sediments and wetland soils. The proponent will remove about 350 cubic yards of soil from the 9,637 sf area and restore the disturbed wetlands.

The project is subje.ct to MEPA review pursuant to Sections 1;L. 23(3)(b)(11(d) because the project alters 5,000 or more sf of Bordering Vegetated Wetlands (BVW). It may require a Water.. Quality Certification from.DEP. On January 22, 2004, the propoulenL .eceived an .rderL Of Cndirions as a limited pro-ject . from the North Reading Conservation Commission. A Programmatic EOEA #13211 ENF Certificate March 12, 2004

General Permit - Category II will be necessary from the U.S.: Army Corps of Engineers. MEPA jurisdiction is limited to those aspects of the project within the subject matter of state permits and areas that may have significant environmental impacts (wetlandn ahd stormwater).

The project's impacts to wetlands can be adequately handled -during the local, .DEP and Federal permitting processes. The proponent -should demonstrate that the project has been designed to meet all performance .standards. DEP should deal with these issues during project permitting.

. I recommend that- the.proponent incorporate DEP's suggestions. to comply with the Massachusetts Stormwater Management Policy's Redevelopment Standard for the existing development on the site. Rooftop runoff should be infiltrated and parking lot runoff should be treated to.remove total annual suspended solids. DEP has recommended that the- snow remoVal and disposal plan needa to be revised to avoid impacts to wetland resource 'areas. The proponent also needs to ensure that parking lot sweeping occurs at least twice per year in fall and late spring;

Based on a review 'of the information provided by the proponent and after consultation -with relevant-public agencies, I find that the -potential impacts of this project do not warrant the preparation of an' EIR and cari be properly addressed in the DEP and local permitting processes. -

March 12, 2004 Date -- . r

cc: Nancy Baker, DEP/NERO '

Comments received: ' -

TRC, 2/17/04. TRC, 2/23/04 DEP/NERO, 3/2/04

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3,LL 0 COMMONWEALTH OF MASSACHUSETITS ExECUTIvE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston - Northeast Regional Office ONE WINTER STREET, BOSTON, MA 02108 817-654-6500

Mr ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERR! HEALEY ROBERT W. GOLLEDGE, Jr. Lieutenant Governor Commissioner

July 14, 2004

Paola Macchiaroli Transmittal # W047758 TRC Environmental Corporation DEP File # 245-1029 31 Milk Street, Suite 1104 EOEA # 13211 Boston, MA 02109

RE: WATER QUALITY CERTIFICATION Application for: BRPWW10 - MAJOR FILL AND EXCAVATION PROJECTS

AT: Former GE Site 50 Fordham Road - North Reading

Dear Ms. Macchiaroli:

The Department of Environmental Protection (the "Departinent) has reviewed your application for Water Quality Certification, as referenced above. In accordance with the provisions of MGL c.21, §§26-53 and Section 401 of the Federal Clean Water Act as amended (33 U.S.C. §1251 etg q.), it has been determined there is reasonable assurance the proposed project will be conducted in a manner which will not violate applicable water quality standards (314 CMR 4.00) and other applicable requirements of state law.

The above-referenced project involves the excavation and removal of approximately 350 cubic yards (approximately 9,637 square feet) of contaminated wetland soil at three locations on the site. After the soil has been removed, the bordering vegetated wetlands will be restored in place. This work is being conducted in accordance with the Massachusetts Contingency Plan (MCP) (RTN 3- 0518) in order to eliminate the risk posed by inorganic contaminants (e.g. cbpper, lead and zinc) to ecological receptors in the area.

Based on a review of information provided and on observations made during a site inspection conducted on May 6, 2004, the Department finds that this project complies with the standards described under 314 CMR 9.06(3). No comments were received during the public comment period. Conditions relating to the construction of the project are included in the following

ThIsInruuoet b avahable In amtrnate fornmL CanfApe McCabe, ADA Cowdintr at 1-617-5541171. TDD Servce - -4-tM9-207. DEP on the Wodd Wide Weix httllwnmass.gov/dep a Pdited on Recyded Paper 2 401 WQC - Transmittal # W047758

Special Conditions.

The Department hereby grants a Water Quality Certification for this project subject to the following conditions to maintain water quality, to minimize impact on waters and wetlands and to ensure compliance with appropriate state law:

1. This project could result in a violation of the water quality standards adopted by the Massachusetts Division of Water Pollution Control. Therefore, reasonable care and diligence shall be taken by the contractor to assure that the proposed activity will not violate Class B standards.

2. All work shall be in accordance with the following documents and plans: o. Application for Water Quality Certificate received January 29, 2004, Transmittal Form # W047758 with attachments, including letters from Paola E. Macchiaroli, PhD, Senior Project Manager, TRC Environmental Corporation, dated May27, 2004 and July 7, 2004. o Plan entitled "Figure 2A, Limits of Areas of Concern and Proposed Remediation Areas" consisting of one (1) sheet, scale 1"=160', dated December 2003, not signed or stamped. o Plan entitled "Figure 2B, Details" consisting of one (1) sheet, various scales, dated December 31, 2003, not signed or stamped. o Plan entitled "Figure 6A, Grading Schematic" consisting of one (1) sheet, no scale, dated December 2003 with revisions through May 27, 2004, not signed or stamped. o Plan entitled "Figure 6B, Planting Layout Schematic" consisting of one (1) sheet, no scale, dated December 2003, not signed or stamped.

3 All work within a community shall conform to the following listed Orders of Conditions for that community issued pursuant to the Massachusetts Wetlands Protection Act (M.G.L. Chapter 131, § 40) unless otherwise conditioned herein or specified in writing by the Department:

o Order for DEP File # 245-1029 issued by the North Reading Conservation Commission, dated January 22, 2004.

4. If additional contaminated soil is discovered, it shall be removed after verbal notification is given to the Department. Following the verbal notification, a letter and supplemental plan shall be sent to the Department describing the extent and location of the additional contaminated soil. The area from which the additional soil is removed shall be restored according to the same protocol approved for the restoration of the bordering vegetated wetlands. This additional soil removal and wetland restoration will not require an amendment to the 401 Water Quality Certification. 3 401 WQC - Transmittal # W047758

5. The wetland restoration areas shall be monitored annually for 5 years. Photographic stations shall be selected in the restoration areas where photographs shall be taken of pre-existing baseline conditions and then during each subsequent monitoring inspection and submitted with the reports. The monitoring report shall include vegetation mapping, a plant species list and photographs documenting the extent of revegetation. For five full growing seasons, the monitoring schedule shall provide reports that shall be submitted twice each growing season with the first report covering the beginning of the growing season submitted no later than July 30th and the second report covering the end of the growing season submitted no later than November 30th. Wetland restoration will be considered successful if: the wetland supports at least 80 percent total cover with native species, and if invasive species [i.e. common reed (Phragmitesaustralis) and purple loosestrife (Lythrum salicaria)]are not present. If invasive species invade the wetland restoration areas, the following steps shall be implemented:

" Individual nuisance species plants shall be identified and hand pulled, including roots, before the end of the flowering season if their occurrence is no greater than 100 stems per acre. Plants shall be removed from the site and appropriately burned, or otherwise disposed of at an approved waste facility.

o If the invasive plant species population becomes greater than 100 stems per acre, hand application of RODEO*, or a comparable herbicide, as recommended by the Regulatory Branch of the New England District Anny Corps of Engineers shall be used. Application of herbicide shall occur following written approval from the landowner and the Department.

If, at the end of the aforementioned 5 year monitoring period, invasive species remain in the wetland restoration areas, a letter shall be sent to the Department which requests that the Department make a determination that no further action is required and that the wetland restoration areas are complete.

6. The Department shall be notified of any changes in plans affecting waters or wetlands. The Department will determine whether the change(s) requires a revision to this Certification.

7. Prior to the start of work, the applicant shall provide the Department with the name, address and phone number(s) of the person responsible for ensuring that all work complies with the conditions of this Water Quality Certification.

Section 61 Findings: Pursuant to M.G.L Chapter 30, Sections 61 to 62H inclusive (M.E.PA.) the project, as referenced in the Water Quality Certification Application, DEP Transmittal # W047758, was required to file pursuant to the implementation of the Massachusetts Environmental Policy Act adopted by the Secretary of Environmental Affairs. TRC Environmental Corporation filed an Environmental Notification Form (ENF) with MEPA referenced under EOEA # 13211 and noticed in the Environmental Monitor on February 11, 2004. A MEPA filing was necessary pursuant to Section 11.03(3)(b)l d. of the MEPA Regulations because the project alters 5,000 or more square feet of bordering vegetated wetlands and requires a 401 Water Quality Certificate from the Department The Secretary of Environmental Affairs rendered a decision on the project in the 4 401 WQC - Transmittal # W047758

Certificate issued on March 12,2004. The Department has reviewed the findings in the ENF Certificate and confirms that, in conjunction with the requirements set forth in this Certification, "...the potential impacts of this project do not warant the preparation of an EIR and can be properly addressed in the DEP and local permitting processes."

Failure to comply with this Certification is grounds for enforcement, including civil and criminal penalties, under MGL c.21 §42, MGL c21A §16, or other possible actions/penalties as authorized by the General Laws of the Commonwealth.

This Certification does not relieve the applicant of the obligation to comply with other appropriate state or federal statutes or regulations. This includes, but is not limited to, the conditions numbered 1 through 32 of the U.S. Department of the Army Programmatic General Permit, Commonwealth of Massachusetts.

NOTICE OF APPEAL RIGHTS

A) Appeal Rights and Time Limits Certain persons shall have a right to request an adjudicatory hearing concerning certifications by the Department when an application is required: (a) the applicant or property owner; (b) any person aggrieved by the decision who has submitted written comments during the public comment period; any ten (10) persons of the Commonwealth pursuant to MG.L. c.30A where a group member has submitted written comments during the public comment period; or (d) any governmental body or private organization with a mandate to protect the environment which has submitted written comments during the public comment period. Any person aggrieved, any ten (10)persons of the Commonwealth, or a governmental body or private organization with a mandate to protect the environment may appeal without having submitted written comments during the public comment period only when the claim is based on new substantive issues arising from material changes to the scope or impact of the activity and not apparent at the time of public notice. To request an adjudicatory hearing pursuant to M.G.L. c.30A, § 10, a Notice of Claim must be made in writing, provided that the request is made by certified mail or band delivery to the Department, with the appropriate filing fee specified within 310 CMR 4.10 along with a DEP Fee Transmittal Form within twenty-one (21) days from the date of issuance of this Certificate, and addressed to:

Docket Clerk Office of Administrative Appeals Departnrnt of Environmental Protection One Winter Street, 3" Floor Boston, MA 02108

A copy of the request shall at the same time be sent by certified mail or hand delivery to the issuing office of the Wetlands and Waterways Program at

Department of Enviromnental Protection, Northeast Regional Office One Winter Street, Sa Floor Boston, MA 02108

B) Contents of Hearing Request A Notice of Claim for Adjudicatory Hearing shall comply with the Department's Rules for Adjudicatory - Proceedings, 310 CMR 1.01(6), and shall contain the following information pursuant to 310 CMR 9.10(3):

(a) the 401 Certification Transmittal Number and DEP Wetlands Protection Act File Number; (b) the complete name of the applicant and address of the project 5 W047758 (c) eo401 WQC - Transmittal # (c) the complete name, address, and fax and telephone numbers of the party filing the request, and, ifrepresented by counsel or other represenative, the name, fax and telephone numbers, and address of the attorney; (d) if claiming to be a party aggrieved, the specific facts that demonstrate that the party satisfies the definition of "aggrieved person" found at 314 CMR 9.02; (e) a clear and concise statement that an adjudicatory hearing is being requested; (f) a clear and concise statement of(1) the facts which are grounds for the proceedings, (2) the objections to this Certificate, including specifically the manner in which it is alleged to be inconsistent with the Department's Water Quality Regulations, 314 CMR 9.00, and (3) the relief sought through the adjudicatory hearing, including specifically the changes desired in the final written Certification; and (g) a statement that a copy of the request has been sent by certified mail or hand delivery to the applicant, the owner (if different from the applicant), the conservation commission of the city or town where the activity will occur, the Department of Environmental Management (when the certificate concerns projects in Areas of Critical Environmental Concern), the public or private water supplier where the project is located (when the certificate concerns projects in Outstanding Resource Waters), and any other entity with responsibility for the resource where the project is located.

C) Filing Fee and Address The hearing request along with a DEP Fee Transmittal Form and a valid check or money order payable to the Commonwealth of Massachusetts in the amount of one mundred dollars ($100) mst be mailed to:

Cornonwealth of Massachusetts Department of Environmental Protection Commonwealth Master Lockbox PO Box 4062 Boston, MA 02211

The request will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver. The filing fee is not required if the appellant is a city or town (or municipal agency), county, or district of the Commonwealth of Massachusetts. or a municipal housing authority. The Department may waive the adjudicatory hearing filing fee pursuant to 310 CMR 4.06(2) for a person who shows that paying the fee will create an undue financial hardship. A person seeking a waiver must file an affidavit setting forth the facts believed to support the claim of undue financial hardship together with the hearing request as provided above.

Should you have any questions relative to this permit, please contact Derek Standish at (617) 654-6611.

truly yours,

ames . Section Chief Wetlands and Waterways Program

cc: North Reading Conservation Commission, Town Hall, North Readin, MA 01864 Crystal L Gardner, Department ofthe Army, New England District, Corps of Engineers, 696 Virginia Road, Concord, MA 01742-2751 Customer-Focused Solutions F

TRC Reference No. E9202-5402-02250 VIA EMAIL and U.S. MAIL July 7,2004

Mr. Derek Standish Massachusetts Department of Environmental Protection Division of Waterways One Winter Street Boston, MA 02108

Subject: 401 WQC DEP #245-1029 Wetland Remediation and Restoration Project Former GE Facility Site (RTN 3-0518) 50 Fordham Road Wilmington, Massachusetts

Dear Mr. Standish:

Per today's phone conversation, I have enclosed the following discussion regarding TRC's plan to control nuisance species as it relates to the Wetland Remediation and Restoration project for the above-referenced project.

Nuisance Species Control

As part of the remediation activities to remove contaminated soils, TRC will remove to the extent -possible, the rootstock of nuisance/invasive species during excavation.

Once the remediation and restoration activities are complete, TRC will then monitor the restored wetland area for the growth of the nuisance invasive wetland plants (hydrophytes) including the most aggressive common reed (Phragmitesaustralis) and purple loosestrife (Lythnom salicaria),and take appropriate control actions, if necessary, to ensure the successful re-vegetation of the proposed wetland species in the restoration area for the duration of three years (we propose semi-annual monitoring site visits).

Since the restored wetland is located within a wetland complex that is dominated by common reed, the most effective defense to the invasion of common reed or purple loosestrife would be a dense 100 percent soil cover of vegetation with well-established root systems. Given that the common reed and purple loosestrife are known to be shade intolerant species, the successful re-vegetation of the shrub and tree species that will provide shade cover will assist in controlling these species.

In an effort to enhance the proposed plan to grow wetland plant species in the restoration area, TRC will also include annual rye in the seed mix to ensure rapid growth and dense vegetation cover.

In the event that the restoration area is invaded with nuisance species, TRC proposes the following methods to control these species during the three-year re-vegetation perioc

31 Milk Sweet, Suite 1104 e Boston, Massochusets 02109 Telephone 617-350-3444 e Fox 617-350-3443 Mr. Derek Standish July 7, 2004 Page2of2

" Individual nuisance species plants will be identified and hand pulled, including roots, before the end of the flowering season if their occurrence is no greater than 100 stems per acre. Plants will be removed from the site and appropriately burned, or otherwise disposed of at an approved waste facility.

o If the invasive plant species population becomes greater than 100 stems per acre, hand application of RODEO', or a comparable herbicide, as recommended by the Regulatory Branch of the New England District ACOE will be used. Application of herbicide will only be at the approval of the landowner and the DEP.

Should you have any questions regarding the proposed monitoring and control plan, please do not hesitate to contact my office.

Sincerely,

Paola E. Macchiaroli, Ph.D. Senior Project Manager

CC: Mary Trudeau, North Reading Conservation Commission Kevin Cotelli, Army Corps of Engineers Bruce Hoskins, CPI Steve Damiano, TRC Greg Mischel, TRC

OntnrInc "N Customer-Focusedi Solutions E I L E

ii Customer-Focused Solutions

TRC Reference Number E9202-5402-02250

January 29, 2004

Massachusetts Department of Environmental Protection Division of Wetland and Waterways, 5t* Floor One Winter Street Boston, MA 02108

Subject: Application for 401 Water Quality Certification Limited Removal of Wetland Soil/Sediment and Restoration of Approximately 0.2 acres of Wetland (File Number 245-1029)

Reference Site: Former General Electric (GE) Site (RTN 3-0518) Wilmington and North Reading, Massachusetts B Reviewer

Enclosed please find an application for a 401 Water Quality Certification (WQC) to support the limited removal of impacted wetland soil, and restoration of the same wetland area (approximately 0.2 acreas in size) at the former General Electric (GE) site on 50 Fordham Road in Wilmington, Massachusetts. The wetland is on a portion of the site that is located in North Reading, Massachusetts. This work is being conducted in accordance with the requirements of the Massachusetts Department of Environmental Protection (MA DEP) per the Massachusetts Contingency Plan (MCP) in order to eliminate risk posed by inorganic contaminants (e.g. copper, lead and zinc) to ecological receptors in the area. This submittal is in response to a notification letter received from your office dated January 16, 2004 (File Number 245-1029).

Concurrently, TRC is submitting to the Executive Office of Environmental Affairs (EOEA)- MEPA Unit the requisite Environmental Notification Form (ENF).

To date, TRC submitted a Notice of Intent (NOI) to the Town of North Reading on January 5, 2004, which was subsequently approved on January 13,.2004, and an order of conditions was issued. In addition, TRC submitted to the U.S. Army Corps of Engineers Regulatory Branch an Application for a Programmatic General Permit (PGP)- Category II (per 33 CFR 325) on January 27, 2004.

The enclosed application is accompanied by project specific information and submittals to facilitate your review. The package includes:

* ' BRP WW 10 Application Form V Transmittal form Copy of the Public Notice for the BRP WW 10 Application with proof of publication

Boott Mills South, Fool of John Street e Lowell, Massachusetts 01852 Telephone 978-970-5600 * Fax 978-453-1995 0 Massachusettes Department of Environmental Protection- Wetland Program January 29, 2004 Page 2 of 2

/ Copy of the Environmental Notification Form (ENF) submitted to the EOEA- MEPA unit / Copy of the Department of the Army Application for a Programmatic General Permit (PGP)- Category II, including: = Application Form Agency Letters a Order of Condition issued by the North Reading Conservation Commission / Copy of the Notice of Intent (NOI) submitted to the North Reading Conservation Commission, including: a Application Form Abutter Notification o Bordering Vegetated Wetland Characterization Rare, Threatened, and Endangered Species o Ecological Risk Characterization Regulated Activities a Impacts Mitigation/Restoration (including Alternatives Analysis - Section 7.1.1) Supplemental pertinent information (plans, wetland delineation, wetland description, photos, etc)

our intention to complete the remediation of the impacted wetland during the late winter/early spring so minimize impact to the surrounding wetland and avoid disturbance to amphibian breading that occurs in ate spring. In addition, by completing the restoration activities in early spring, the new plantings will significantly benefit from a full growing season.

Should you have any questions regarding the on-going characterization and remediation of the Site, or the work associated with this application, you can contact Ms. Rodine Lamkin at the MA DEP, or myself at 617- 350-9997.

Thank you for your assistance on this matter.

Sincerely,

Paola E. Macchiaroli, Ph.D. Senior Project Manager

Enclosures

CC: Mary Trudeau- Agent, North Reading Conservation Commission Bruce Hoskins-CPI Environmental Services Ron Helgerson- LMC (w/o enclosures) Gail Rymer- LMC (w/ Public Notice)

T RC cusAnnr-Fcused sdotion Applcatuwn for 401 Water aLDTHIty CrtDfQcat©n- F1ll and ExcawaIon Projects n Waters and Wetands

BRP WW 10 Major Project CerHficaion

In accordance with 314 CMR 9.00 et seq.

0 Llmited Remova off We~tand Soi/Sedimen and Restoration off Approxmately 0.2 acres of Wetand Former GE Site (RTh 3-0518) 50 Fordham Road Wilmington/North Reading, Massachusetts

Submitted to:

Massachusetts Department of Environmental Protection Northeast Regional Office Division of Wetlands, 5"' Floor One Winter Street Boston, MA 02108

Prepared by:

TRC Environmental Corporation Boott Mills South, Foot of John Street Lowell, Massachusetts 01852

January 2004 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands and Waterways W 047758 BRP WW 10 Major Project Certification Transmitta Numnber 0 BRP WW II Minor Project Certification 401 water Quality Certification for Fill and excavation Projects In waters and Wetlands

A. Applicant Information rportant: Vhen SN out 1. Which permit category are you applying for? xms on #w omper, niy the tabuse key |BRPWW10 ElBRPWW11 >moveyour usor -do not se the return ey. 2. Applicant/Owner: TRC Environmental Corporation (TRC) Name 31 Milk Street, Suite 1104 Address . Boston MA 02109 City/rown State Zip Code 0 Paola Macchiaroli, Ph.D. Contact Person (617) 350-9997 Telephone (hone) (work)

3. Authorized Agent TRC Environmental Corporation (TRC) Name 31 Milk Street, Suite 1104 Address Boston MA 02109 cityrrown State Zip Code Paola Macchiaroli, Ph.D. Contact Person (617) 350-9997 Telephone (home) (work)

t01 Fom.doc *07/01 BRP WW 10, 11 *-Pagel1f4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands and Waterways W 047758 BRP WW 10 Major Project Certification Transmital Numnber 41 BRP WW 11 Minor Project Certification 401 water Quality Certification for Fill and excavation Projects in waters and Wetlands

B. Project Information

1. Project Location: 50 Fordham Road-with wetland located in North Rem Address Wilmington MA 01887 c"yfrown State Zip Code Tumer Pond and the Ipswich River Nearest or Adacent Waterbody

2. Project Name (ifany): Limited removal of wetland soil/sediment and restoration of approximately 0.2 acres of wetland.

3. a. Describe project purpose:

This project will involve the excavation of approximately 350.0 cubic yards of metals impacted wetland soil/sediment and the restoration of 9,637.8 square feet of disturbed wetland within the excavation footprint. The restoration will include-the placement of new wetland soil within the excavation and replanting with wetland plant species.

This work is being conducted per the requirements of the MADEP under the Massachusetts Contingency Plan (RTN 3-0518).

See attached NOI application and Order of Conditions for more details.

b. Is the project

E water-dependent 0 non water-dependent

01 Fonmdoc * BRPP7W01 WW 10, 11 - Page 2 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands and Waterways W BRP WW 10 Major Project Certification TTBIISTI Number BRP WW 11 Minor Project Certification 401 water Quality Certification for Fill and excavation Projects In waters and Wetlands

B. Project nformation (cont) 4. a. provide a brief description of the proposed project (See Application Instructions and include a copy of the Notice of intent, if any.):

Refer to Notice of Intent Attachment, Sections 5.9, 6.0, and 7.0.

*b. Notice of Intent File number (if any): 245-1029

5. Identify the loss in square feet of each type of resource area (see Application Instructions for additional information.): a. Bordering vegetated wetland: 9,637.8 - To be restored as part of project Net loss equals 0. b. Isolated vegetated wetland: 0 Square feet ___ c. Land under water 0 square feet 0 d. Total cumulative loss of a. + b. + c.: 0

e. Salt marsh: 0 square feet

6. a. Will the proposed project occur in any wetlands or waters designated as "Outstanding Resource Waters"? D Yes 0 No

If yes has public notice been published in the Environmental Monitor?

o Yes ] No - b. Is this project a subdivision or any part of a Yes CNo subdivision? a. Is the project categorically subject to 0 Yes MEPA? L No If yes, has final action been taken? O Yes 0 No If yes, please include copy of MEPA 0 certificate.

401 Form.doc - 07/01 BRP WW 10, 11 &Page 3 Of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands and Waterways W047758 BRP WW 10 Major Project Certification Transmitta Numbert BRP WW 11 Minor Project Certification 401 water Quality Certification for Fill and excavation Projects in waters and Wetlands

B. Project information (cont) 7. Atematives Analysis:

As related to the project purpose, attach a detailed description of alternatives to the proposed project that were considered and why none are available that avoid adverse impacts to wetlands and waters.

If no alternatives are available, describe how the activity will minimize or mitigate the adverse impacts to wetlands and waters.

See application instructions for information required. Attach required documentation.

Refer to the Notice of Intent Attachment, Section 7.1.1 C. Additional Information 1.. Is any of your proposed work exempt from the Massachusetts Wetlands Protection Act or-taking. place in a federal non-state wetland? D yes If yes, see Application Instructions for additional 5No information needed. S 2. Public notice to a newspaper of general circulation within the area of the proposed activity must be published within 10 days of the date of this application. Is proof of public notice submitted?. 0Yes [I No (See Application Instructions for additional information)

D. Certification Application is hereby made for water quality certification. Appcamr Signature

*1certify that I am familiar with the work proposed and that to the best of my knowledge and belief the information contained in this application Is true, Agenrs signature complete, and accurate" Paola Macchiaroli, Ph.D. Print Name 1/29/04 Date

01 Form.doc - 07/01 BRP WW o, 11 - Page 4 of 4 Hand-enter Your Transmittal Number 2 X Your unique Transmittal Number can be accessed through DEP's web sie or by callng the DEP Inoline as listed on the last page of this document MassachusettsDepartment of EnvironmentalProtection Transmittal Form for Permit Application and Payment

. Please type or cint A separate ransmittal Form must e completed for each ermit application.

-. Your check should o made payable to 10 Commonwealth of lassachusetts. lease mal your heck along with a opy of this form to: EP, P.O. Box 4062, oston, MA 02211. Street Address 31 Milk Street, Suite 1104 . Three (3) copies of Cityf/own State Zip Code Telephone Number 11s form will be Boston MA 02109 (617)350-9997 ext eeded Contact e-mail address {optional) opy I (the original) tust accompany your mrmli application. py 2 must Name of-Facility, Site or Ind~dual DEP Facft Number (ifKnown) your fee Former GE Site (RTN 3-0518) Street Address e-mal addiress, be 50 Fordham Road (opfional): for your City/ToWn -state zip code - Telephone Number ords Wilon MA . 0187 -. ()ext.- Poa Maccharal, PhD. . Both fee-paying poatcouin~o nd exempt applicants utst mall a copy of Nam of indbfdual or Firm TRC Envirofnmtal is transnilttai form to Corporatio (TRC) EP, P.O. Box 4062, Address oston, MA 02211 31 Milk Street Suite 1104 City/Town State Zip Code Telephone Number or DEP Use Only Boston .MA 02109 (617) 350999 et emit No. - Contact edd LPNumber (21 E only) Date___ Paola Macchiaroni, PA.D. evewwr____I_

6 -7 this project subject to MEPA review? l yes [ no yes, Indicate the projec's EOEA file number (assigned when an Environmental Notification Form Is submitted to the MEPA unit) DEA # . Is an Environmental Impact Report Required? ( yesO no , this application part of a larger project for which two or more DEP permIts are being or will be sought? 0 yes - no . st any other DEP permits that apply to this project

Ions: 0 Fee Exempt* (city. town or municipal housing authority)(state agency if fee is $100 or less) o HardshIp Request (payment exdensions according to 310 CMR 4.04(3)(c) O Alternative Schedule Project (accordig to 310 CMR 4.05 and 4.10) There are no fee exemptins for 21E mre rdless of anrmkant sts *The, 2E gmrmslrrm ppfewmtu 1 & O z oo 6 Doar Amount 400.00 - Date: 1/29104 IrZ9104 'lease make check payable to the Commonwealth of Massachusetts and mail check andI oneDate. copy of this form to DEP. P.O. Box 1062, Boston, MA 02211 .. :oan Proof of Pubec Nodicadon

FormerGE Site Limited Removal of Wet/and SoilSediment and Restoration of Approximately 0.2 Acres of Wetland Wilmington/North.Reading,MA PUBLIC NOTICE

Pursuant to State Water Quality Certification (314 CMR 9.05), notice is hereby given of a 401 Water Quality Certification application for the limited removal of soil from a wetland and the restoration of approximately 0.2 acres of wetland. The proposed work is located on a portion of a parcel in North Reading, with an address of 50 Fordham Road in Wilmington, MA. The applicant who will perform the work is TRC Environmental Corporation. Additional information may be obtained from Paola Macchiaroli, PhD., Senior Project Manager, TRC, 31 Milk Street, Suite 1104, Boston, MA 02109, (617) 350-9997. Written comments should be addressed within twenty-one days of this notice to: MADEP Northeast Regional Office, Division of Wetlands and Waterways, 5 hfloor, I Winter Street, Boston, MA 02108. Any group of ten persons, any aggrieved person, or any governmental body or private organization with a mandate to protect the environment who submits written comments may appeal the Department's Certification. Failure to submit written comments before the end of the public comment period may result in the waiver of any right to an adjudicatory hearing. Copy of the Application for Department of the Army Permit

Former GE Site Limited Removal of Wetland SoilSediment and Restorationof Approximately 0.2 Acres of Wetland Wilmington/North Reading,MA. 0 APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT OMB APPROVAL NO. 0710-0003 (33 CFR 325) Expires June 30, 2000 ublic burden for this collection of Information is estimated to average 10 hours per response, although the majority of applications should 'e ours or less. This includes the time for reviewing Instructions, searching existing data sources, gathering and maintaining the data dflompleting and reviewing the collection of informaton- Send comnments regarding this burden estimate or any other aspect of this onnation. Including suggestions for reducing this burden, to Department of Defense, Washington Headquarters Service Directorate Operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington, VA 22202-4302; and to the Office of Management and ,, Paperwork Reduction Project (0710-0003), Washington. DC 20503. Respondents should be aware that notwithstanding any other ;Ion of law, no person shall be subject to any penalty for falling to comply with a collection of information f it does not display a currently DUB control number. Please DO NOT RETURN your form to either of those addresses. Completed applications must be submitted to the :t Engineer having jurisdiction over the location of the proposed activity. PRIVACY ACT STATEMENT wies: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404,33 USC 1344; Marine Protection, Research and uaries Act, 33 USC 1413, Section 103. Principal Purpose: Information provided on this form will be used in evaluating the application for a t Routine Uses: This information may be shared with the Department of Justice and other federal, slate, and local government agencies. 'Ission of requested information is voluntary, however, if Information is not provided the permit application cannot be evaluated nor can a (be Issued. One set of original drawings or good reproducible copies which show the location and character of the proposed activity must ached to this application (see sample drawings and Instructions) and be submitted to the District Engineer having Jurisdiction over the Dn of the proposed activity. An application that Is not completed In full will be returned.

ffEMS BELOW TO BE FILLED BYAPPLICANT} PLICANTS NAME 8. AtJTHORIZED AGENTS NAME AND 7T.E (an agweinn prr 'Ia Macchiaroli, Ph.D. Sr. Project Manager TRC Environmental Corporation (TRC)

PLICANT'S ADDRESS 9. AGENTS ADDRESS [ilk Street, I Ith Floor 31 Milk Street, I Ith Floor on, MA 02109 Boston, MA 02109

PLt S PHONE NOS. W/AREA CODE 10. AGENTS PHONE NOS. WIAREA CODE a. Residence nes$S- (617) 350-3444 b. Business (617) 350-3444 STATEMENT OF AUTHORIZATION y authorize, TRC Environmental Corporation to act ki my behalf as my agent in the processing of this apprication and to furnish, upon 1,supplemental information in support of this permit application.

- 1/2604 APPLICANTS SIGNATURE DATE

NAME, LOCATION AND DESCRIPION OF PROJECT OR ACTIVITY tOJECT NAME OR TITLE (eiucson) mer GE Site- Contaminated Sediment/Soil Removal and Wetland Restoration

ME OF WATERBODY, IF KNOWN jusa*ca) 14. PROJECT STREET ADDRESS VqasucatJ >t Applicable 50 Fordham Road North Reading, MA 01887 CATION OF PROJECT Middlesex Massachusetts. COUNTY STATE rHER LOCATION DESCRIPTIONS. IF KNOWN. ev kseens

AN STO THE SITE

n Concord, MA: Take 2A to Interstate 95 North. Merge onto 1-93 N via Exit 378 toward Concord, NH. Take the Concord SL exit (Exit 39) vard Rte 28/N. Reading. Stay straight to go onto Concord Street. Turn left onto Fordham Road. Take right into Ametek Aerospace.

IRM 4345, Jul 97 FDITION OF FFR 9MIS IPwnnnan- CFCW-AmI 18. Nature of Activity (oesnsCmorgmfctecxdo aMates) This project will involve the removal of approximately 350.0 cubic yards of metals contaminated wetland sediment/soil and the in situ restoration of 9,637.8 square feet of disturbed wetland.

9. Project Purpose gnesree me ressoerm'pose erVi pqb4 see bflttums)

The purpose of the proposed activity is to eliminate risk to ecological receptors as required by the Massachusetts Department of Environmental Protection under the Massachusetts Contingency Plan (MCP) 310 CMR 40.0995.

USE BLOCKS 20-2 IF DREDGED ANDR FILL ATERIAL IS TO BE DISCHARGED 0. Reason(s) for Discharge Once the-contaminated soil/sediment is removed, the excavation will be backfilled with a clean wetland soil mix This will serve as a suitable substrate for wetland plants.

1. Type(s) of Material Being Discharged and the Amount of Each Type inCubic Yards

A total of approximately 350 cubic yards of loam, highly decomposed wood chips, and peat moss will be used to re-esfablish the wetland substrate.

t Surface Area In Acres of Wetlands or Other Waters Filed f"ce kua*ums 9,637.8 square feet of wetland will be restored following sediment/soil excavation.

3. Is Any Portion of the Work Already Complete? Yes - No XJLFYES. DESCRIBE THE COMPLETED WORK

of Adjoinlng Property Owners. Lessees. Elc., Whose Prope"t Adjoins the Watertody (Ifmore than can be entered hee' se attach a supplemental Wat). See attached Abutters List in the Notice of Intent.

List of Other Certillcations or Approvals/Dentals Received from other Federal, State or Local Agencies for Work Described inThis Apptlication.

AGENCY TYPE APPROVAL* IDENTIFICATION NUMBER DATE APPLIED DATE APPROVED DATE DENIED Conservation Comn Order of Conditions 245-1029 January 5,2004 January 13,2004

>id include but is not restricted to zoning, buiktng and flood plain permits Application Is hereby made for a pernit or permits to authorize the work described in this application. I certify that tie information in this application Is complete and accurate. I further certify that I possess the authority to idertake the work described herein or am acting as the duty autzm agent of the applcanLt

C~~c~t4~p l/26104 _____

SIGNATURE OF APPLICANT DATE SIGNATURE OF AGENT DATE

the application must be signed by the person who desires to undertake the proposed activity (appcant) or i may be signed by a duly authorized agent ifthe statement in block 11 has been lined out and siuied.-

I Section 1001 provkies that Whoever, in any manner wilin the jurisdiction of any department or agency of the United States wiguhzIy aisW, conceals, or covers up any trick scheme, or disguises a material fact or makes any false, fictitious or aternerts or representatons or makes or uses any false writng or document knowing same to contain any false, fictious or >lent statements or enry, shalt be fined not more than $10,000 or imprisoned not more than five years or bot. Customer-Focused Solutions

January 27, 2004

State Historic Preservation Officer Massachusetts Historical Commission The Massachusetts Archives Bldg. 220 Morrissey Boulevard Boston, Massachusetts 02125

- Subject: Section 404 Programmatic General Permit Removal of Contaminated Sediment/Soil and Wetland Restoration Project Former General Electric (GE) Site (RTN 3-015)- 50 Fordham Road.- North Reading, Massachusetts

Dear Preservation Officer

TRC Environmental Corporation (TRC) has submitted a Programmatic General Permit (Category II) notification to the U.S. Army Corps of Engineers (USACE) under Section 404 of the Clean Water Act. The permit application is for limited excavation and removal of sediment and soil within a wetland area located at the Former GE Facility at 50 Fordham Road in Wilmington, Massachusetts with wetland extending into North. Reading, Massachusetts. The purpose of the sediment/soil excavation is to reduce the ecological risks posed by inorganic contaminants (i.e. copper, lead and zinc). Approximately 9,638 square feet of disturbed wetland will be restored following the sediment/soil excavation.

Enclosed please find a copy of the USACE notification as well as a copy of the Notice of Intent application (in accordance with the Massachusetts Wetlands Protection Act) that details the proposed work activities at the site. We request your assistance in identifying- -the presence of historic or archaeological resources within the proposed work areas.

Thank you in advance for your assistance. I you have any questions or require additional information, please do not hesitate to call me at (617) 350-9997. Sincerely,

Paola Macchiaroli, Ph.D. Senior Project Manager

Boon Mills South, Foot of John Sreet - Lowell, Mossochusetts 01852 Telephone 978-970-5600 o Fox 978-453-1995 cc: Crystal Gardner - U.S. Army Corps of Engineers Bruce Hoskins, CPI Environmental Services Ron Helgerson - Lockheed Martin Corporation Gail Rymer - Lockheed Martin Corporation Frank Dardeno, Esq. - Council for Wilmington Realty Trust

TRC Customer-Focused Solutions

January 27, 2004

Wampanoag Tribal Historic Preservation Officer 20 Black Brook Road Aquinnah, Massachusetts 02535

Subject- Section 404 Programmatic General Permit Removal of Contaminated Sediment/Soil and Wetland Restoration Project Former General Electric (GE) Site (RTN 3-015) 50Fordham-Road North Reading, Massachusetts

Dear Preservation Officer-

TRC Environmental Corporation (TRC) has submitted a Programmatic General Permit (Category II) notification-to the U.S. Army Corps of Engineers (USACE) under Section 404 of the Clean Water Act. The permit application is for limited excavation and removal of sediment and soil within a wetland area located at the Former GE Facility at 50 Fordham Road in Wilmington, Massachusettswith wetland extending into North Reading, Massachusetts. The purpose of the sediment/soil excavation is to reduce the ecological risks posed by inorganic contaminants (i.e. copper, lead and zinc). Approximately 9,638 square feet of disturbed wetland will be restored following the sediment/soil excavation.

Enclosed please find a copy of the USACE notification as well as a copy of the Notice of Intent application (in accordance with the Massachusetts Wetlands Protection Act) that details the proposed work activities at the site. We request your assistance in identifying. the presence of historic, archaeological, or tria resources within the proposed work- area.

Thank you in advance for your assistance. If you have any questions or require additional information, please do not hesitate to call me at (617) 350-9997. Sincerely.

Paola Macchiaroli, PhD.- Senior Project Manager

Boon Mills South, Foot of John Sireedl Lowel, Massachusetts 01852 Telephone 978-970-5600 * Fox 978-453-1995 49 cc: Crystal Gardner - U.S. Army Corps of Engineers Bruce Hoskins, CPI Environmental Services Ron Helgerson - Lockheed Martin Corporation Gail Rymer -Lockheed Martin Corporation Frank Dardeno, Esq. - Council for Wilmington Realty Trust

IRC Ons Customer-Focused Solutions -

January 27, 2004

-Narragansett Tribal Historic Preservation Officer P.O. Box 700 Wyoming, Rhode Island 02898

Subject: Section 404 Programmatic General Permit Removal of Contaminated Sediment/Soil and Wetland Restoration Project Former General Electric (GE) Site (RTN 3-015) 50 Fordham Road North Reading, Massachusetts

bear Preservation Officer

TRC Environmental Corporation (TRC) has submitted a Programmatic General Permit (Category 11) notification to the U.S. Army Corps of Engineers (USACE) under Section 404 of the Clean Water Act. The perit application is for limited excavation and removal of sediment and soil within a wetland area located at the Former GEFacility at 50 Fordham Road in Wilmington, Massachusetts with wetland extending into North Reading, Massachusetts. The purpose of the sediment/soil excavation is to reduce the ecological risks posed by inorganic contaminants (i.d. copper, lead and zinc).. Approximately 9,638 square feet of disturbed wetland will be restored following the sediment/soil excavation.

Enclosed please find a copy of the USACE notification as well as a copy of the Notice of Intent application (in accordance with the Massachusetts Wetlands Protection Act) that details the proposed work activities at the site. We request your assistance in identifying the presence of historic, archaeological, or tribal resources within the proposed work areas.

Thank you in advance for your assistance. If you have any questions or require additional information, please do not hesitate to call me at (617) 350-9997. Sincerely,

Paola Macchiaroli, Ph.D. Senior Project Manager

Boon Mis South, Foot of John Street e Lowed, Massachusens 01852 Telephone 978-970-5600 * Fox 978-453-1995 . cc:.- Crystal Gardner- U.S. Army Corps of Engineers Bruce Hoskins, CPI Environmental Services Ron Helgerson - Lockheed Martin Corporatiop Gail Rymer - Lockheed Martin Corporatioh Frank Dardeno, Esq. - Council for Wilmington Realty Trust

Tac. WPA Form 5,- Oider of Conditions issued by the North Reading Conservation Commission

Former GE Site Limited Removal of Wetland SoilSediment and Restoration of Approximately 0.2 Acres of Wetland Wilmington/North Reading, MA Massachusetts Department of Environmental Protection DEP Vil Number Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions P"edbyDEP Massachusetts Wetlands Protection Act M.G.L c. 131, §40

A. General Onformation r-N - mportant: Co From: Vhen filling Put forms on North-Reading ae computer, Conservation Commission 3w r ise only the -4 C b key to . This issuance if for (check one): niove your ursor - do ~( Order of Conditions ot use the etum key. 5] Amended Order of Conditions To: Applicant: Property Owner (if different from applicant): TRC Environmental Corp/Paola Maccharoli - Frank Bomba/Wlrington Realty Trust Name Name 31 Milk Street, I" Floor 424 Broadway Mafiing Address Maing Addmss Boston MA 02109 Somerville MA 02145 City/Town state Zip Code Cityrrown State Zip Code 1. Project Location: S 50 Fordham Road North Reading Street Address COWyrown MA 01864 - Assessors Map/Plat Number Parce/Lot Number 2. Property recorded at the Registry of Deeds for Middlesex 102 83 County Book Page 19842 Certiicate (if registered land) 3. Dates:

January 5, 2004 January 13, 2004 January 22, 2004. - Date Notice of Intent Filed Date Pubic HeauIng Closed Date of Issuance - 4. Final Approved Plans and Other Documents (attach additional plan references as needed): Former GE Site Wilmington/North Reading, MA - 12131/03 Title Date Former GE Site, Wilmington/North Reading, MA. Figure 2A, Limits of areas of concern and proposed remediation areas 12/03 5. Final Plans and Documents Signed and Stamped by:

Name 6. Total Fee: $525.00 (from Appendix B: Weand Fee Transmittal Form)

Page lot Massachusetts Department of Environmental Protection DEP Fe Numbec Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions ledxbyDEP Massachusetts Wetlands Protection Act MG.L. c. 131, §40 B. Findings

Findings pursuant to the Massachusetts Wetlands Protection Act: Following the review of the above-referenced Notice of Intent and based on the information provided in this application and presented at the public hearing, this Commission finds that the areas in which work Is proposed is significant to the following Interests of the Wetlands Protection Act. Check all that apply:

Public Water Supply Land Containing Shellfish O Prevention of Pollution

Private Water Supply Fisheries 0 Protection of Wildlife Habitat

Groundwater Supply . Storm Damage Prevention 0 Flood Control

Furthermore, this Comrnmission.hereby finds the project, as proposed, Is: (check one of the following boxes)

Approved subject to: the following conditions which are necessary, in accordance with the performance standards set forth in the wetlands regulations, to protect those Interests checked above. This Commission orders that all work shall be performed in accordance with the Notice of intent referenced above, the following General Conditions, and any other special conditions attached to this Order. To the extent that the following conditions modify or differ from the plans, specifications, or other proposals submitted with the Notice of Intent, these conditions shall control. Denied because: [] the proposed work cannot be conditioned to meet the performance standards. set forth in the wetland regulations to protect those interests checked above. Therefore, work on this project may not go forward unless and until a new Notice of Intent is submitted which provides measures which are . adequate to protect these interests, and a final Order of Conditions Is Issued.

[] the Information submitted by the applicant is not sufficient to describe the site, the work, or the effect of the work on the interests identified In the Wetlands Protection Act Therefore, work on this project may not go forward unless and until a revised Notice of Intent is submitted which provides sufficient information and includes measures which are adequate to protect the Act's interests, and a final Order of Conditions is issued. A description of the specific information which is lacking and why it is necessary is attached to this Order as per 310 CMR 10.05(6)(c).

General Conditions (only applicable to approved projects)

1. Failure to comply with all conditions stated herein, and with all related statutes and other regulatory measures, shall be deemed cause to revoke or modify this Order.

2. The Order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private property or invasion of private rights.

3. This Order does not relieve the permittee or any other person of the necessity of complying with all other applicable federal, state, or local statutes, ordinances, bylaws, or regulations.

Page 2d? Massachusetts Department of Environmental Protection DEPPile Number Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions PMWded bDEP Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Findings (Cont.) 4. The work authorized hereunder shal be completed within three years from the date of this Order unless either of the following apply. a. the work is a maintenance dredging project as provided for in the Act; or b. the time for completion has been extended to a specified date more than three years, but less than five years, from the date of issuance. If this Order is intended to be valid for more than three years, the extension date and the special circumstances warranting the extended time period are set forth as a special condition in this Order.

5. This Order may be extended by the issuing authority for one or more periods of up to three years each upon application to the issuing authority at least 30 days prior to the expiration date of the Order. 6. Any fill used in connection with this project shall be dean fill. Any fill shall contain no trash, refuse, rubbish, or debris, including but not limited to lumber, bricks, plaster, wire, lath, paper, cardboard. pipe, tires, ashes, refrigerators, motor vehicles, or parts of any of the foregoing.

7. This Order is not final until all administrative appeal periods from this Order have elapsed, or if such an appeal has been taken, until all proceedings before the Department have been completed.

8. No work shall be undertaken until the Order has become final and then has been recorded In the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land -upon which the proposed work is to be done. In the case of the registered land, the Final Order shall also be noted on the Land Court Certificate of Title of the owner of the land upon which the proposed work is done. The recording information shall be submitted to this Conservation Commission on the form at the end of this Order, which form must be stamped by the Registry of Deeds, prior to the commencement of work.

9. A sign shall be displayed at the site not less then two square feet or more than three square feet In size bearing the words, "Massachusetts Department of Environmental Protection" [or, iMA DE"] -FileNumber -245-1029 .

10. Where the Department of.Environmental Protection is requested to issue a Superseding Order, the Conservation Commission sha be a party to all agency proceedings and hearings before DEP.

11. Upon completion of the work described herein, the applicant shall submit a Request for Certificate of Compliance (WPA Form 8A) to the Conservation Commission.

12. The work shaD conform to the plans and special conditions referenced in this order.

13. Any change to the plans Identified in Condition #12 above shall require the applicant to inquire of the - Conservation Commission in writing whether the change is significant enough to require the filing of a new Notice of Intent.

14. The Agent or members of the Conservation Commission and the Department of Environmental Protection shall have the right to enter and inspect the area subject to this Order at reasonable hours to evaluate compliance with the conditions stated in this Order, and may require the submittal of any data deemed necessary by the Conservation Commission or Department for that evaluation.

WPAFOrm S Page 3&7f Rev.02=0 Massachusetts Department of Environmental Protection DEP File Number Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions PwvddbyDEP Massachusetts.Wetlands Protection Act M.G.L. c. 131, §40

B. Findings (cont.) 15. This Order of Conditions shall apply to any successor in interest or successor in control of the property subject to this Order and to any contractor or other person performing work conditioned by this Order.

16. Prior to the start of work, and if the project involves work adjacent to a Bordering Vegetated Wetland, the boundary of the wetland in the vicinity of the proposed work area shall be marked by wooden stakes or flagging. Once in place, the wetland boundary markers shall be maintained until a Certificate of Compliance has been issued by the Conservation Commission. 17. All sedimentation barriers shall be maintained In good repair until all disturbed areas have beenfully stabilized with vegetation or other means. At no time shall sediments be deposited in a wetland or water body. During construction, the applicant or his/her designee shall Inspect the erosion controls on a daily basis and shall remove accumulated sediments as needed. The applicant shall Immediately control any erosion problems that occur at the site and shall also Immediately notify the Conservation Commission, which reserves the right to require additional erosion and/or damage prevention controls it may deem necessary. Sedimentation barriers shall serve as the limit of work unless another limit of work line has been approved by this Order.

-Special Conditions (use additional paper, if necessary):

see attached

Findings as to municipal bylaw or ordinance

Furthermore, the North Reading hereby finds (check one that applies): conservaton comnission Q that the proposed work cannot be conditioned to meet the standards set forth in a municipal ordinance or bylaw speciflcar -

Name Munlcpl Ordnance or Bylaw

Therefore, work on this project may not go forward unless and until a revised Notice of Intent is submitted which provides measures which are adequate to meet these standards, and a final Order of Conditions is Issued. that the folowing additional conditions are necessary to comply with a municipal ordinance or bylaw, specifically: North Reading General Wetland Protection Bylaws Name Municipal Onrance or Bylaw

The Commission orders that al work shal be performed in accordance with the said additional conditions and with the Notice of Intent referenced above. To the extent that the following conditions modify or differ from the plans, specifications, or other proposals submitted with the Notice of intent the conditions shall control.

Pag. 4 o r DEP Massachusetts Department of Environmental Protection File Number Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions Provided by DEP Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Findings (cont.)

Additional conditions relating to municipal ordinance or bylaw: see attached

This Order Is valid for three years, unless otherwise specified as a special condition pursuant to General Conditions #4, from the date of issuance.

January 22, 2004 Date

This Order must be signed by a majority of the Conservation Commission. The Order must be mailed by certified mail (return receipt requested) or hand delivered to the applicant. A copy also must be mailed or hand delivered at the same time to the appropriate Department of Environmental Protection Regional Office (see Appendix A) and the property owner (if different from applicant). Signatures:/ s / /1

On the 13th Of January, 2004 Day Month and Year before me personally appeared

William Reed, Martha Cregan, Paul Dick, and Eenore Ministeri to me known to be the perso escribed in and who executed the foregoing instrument and acknowl g he/sh x ted the same as his/her free act and deed.

- - --- ovember 1. 2007- NotA'Public My CommissiM p This Order is issued to the applicant follows:

[] by hand delivery on [ by certified mail, return receipt requested, on January .22, 2004 Date Dale

Pagesd Massachusetts Department of Environmental Protection DEP Fie Numben Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions ProvidedbyDEP Massachusetts Wetlands Protection Act M.G.L c. 131, §40 C. Appeals The applicant, the owner, any person aggrieved by this Order, any owner of land abutting the land subject to this Order, or any ten residents of the city or town in which such land is located, are hereby notified of their right to request the appropriate DEP Regional Office to issue a Superseding Order of Conditions, The request must be made by certified mail or hand delivery to the Department, with the appropriate filing fee and a completed Appendix E: Request of Departmental Action Fee Transmittal Form, as.provided in 310 CMR 10.03(7) within ten business days from the date of issuance of this Order. A copy of the request shall at the same time be sent by certified mail or hand delivery to the Conservation Commission and to the applicant, if helshe is not the appellant.

The request- shall state clearly and concisely the objections to the Order which is being appealed and how the Order does not contribute to the protection of the interests identified In the Massachusetts Wetlands Protection Act, (M.G.L c. 131, § 40) and is Inconsistent with the wetlands regulations (310 CMR 10.00). To the extent that the Order is based on a municipal ordinance or bylaw, and not on the Massachusetts Wetlands Protection Act or regulations, the Department has no appellate jurisdiction.

D. Recording infornation -This Order of Conditions must be recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also.be noted in the Registry's Grantor Index under.the name of the owner bf the land subject to the Order. In the case of registered land, this Order shall also be noted on the Land Court Certfcate of Tite of the owner of the land subject to the Order of Conditions. The recording Informnation- on Page 7 of Form 5 shall be submitted to the Conservation Commission listed below.

North Reading consewalon Commtsson

Page O7 DEP File Number Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands 245-1029 WPA Form 5 - Order of Conditions Provided by DEP Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

D. Recording Information (cont.)

Detach on dotted ine, have stamped by the Registy of Deeds and submit to the Consenvation Commission.

To: North Reading Conservason Commnisson

Please be advised that the Order of Conditions for the Project at: 50 Fordham Road North Readino MA 245-1029 ProjeocaiLon DEP File Number

.Has been recorded at the Registry of Deeds of

County Book Page

for

Prperty Owner

and has been noted in the chain of titie of the affected property in:

Book Page

in accordance with the Order of Conditions Issued on:

Date

If recorded land, the instrument number Identifying this transaction Is:

Insummnd Number

If registered land, the document number identifying this transaction is:

Document Number

Signature of Appfcant 0

WPA FomnS Page 7a 7 Re.02* 18. iNo work shall commence until the North Reading Conservation Commission has received a copy of the recorded Order of Conditions bearing the registrys recording information on the Order. The Conservation Agent shall not sign off on any building permits without proof of recording at the Registry of Deeds.

19. No work shall commence until all erosion controls and mitigation measures are in place as shown on the approved plans. The North Reading Conservation Commission shall be notified, in writing, upon installation of all erosion controls.

20. The applicant shall notify the North Reading Conservation Commission, in writing, forty-eight (48) hours. before any activity commences on the project site.

21. The haybale line shown on the approved plans shall define the limit of work . No work shall occur beyond that limit.

22. The North Reading Conservation Commission or its agent(s) reserves the right to enter and inspect the premises at any time in order to apevaluate compliance With this Order, the North Reading General Wetlands Protection Bylaw and the Massachusetts Wetlands Protection Act The -North Reading Conservation Commission may reQuire the submission of any data, deemed necessary by the Commission, in order to evaluate compliance with this Order, the North Reading General Wetlands PrOtection By Law and the Wetlands Protection Act.

23. This Order shall apply to any successor in control or successor in interest of the property described in the Notice of Intent and accompanying plans.

24. This Order applies only to those resource areas approved to be altered or areas where work is approved within 100 feet of resource areas as shown on the approved plans. NO work in or within 100 feet of any other resource area is permitted.

25. No slopes shall be steeper than.two (2) feet horizontal to one (1)foot vertical unless specifically approved by the Commission.

26. Any departures from or revisions to the approved plans shall be "iittec to the North Reading Conservation Commission prior to Mplementation for a determination of its impact. The North Reading Conservation Commission reserves the right to impose additional conditions in order to protect the interests of the Wetlands Protection Act. Failure to comply with the approved plans may result in the issuance of daily fines, as allowed by the North Reading General Wetlands Protection Bylaw, or revoking of the permit

27. No logs, stumps, boulders or foreign materials shall be buried in or within 100 feet of any resource area.

28. No stockpiles of material shall be stored in or within 100 feet of any resource area.

29.= Storage or maintenance of machinery shall not be permitted inor within 100 feet of any resource area. 30. Erosion controls shall be properly and continuously maintained until all disturbed areas have been permanently stabilized. 31. All disturbed or exposed soil surfaces shall be temporarily stabilized DAILY with hay, straw, mulch, jute mesh or any other protective covering and/or method approved by the U.S. Department of Agriculture Soil conservation Service until they can be permanently stabilized as shown on the approved plans or as indicated elsewhere in this Order. 32. The developer or contractor responsible for the projects completion shall be notified of, and understand the requirements of this Order. A copy of the approved plans and this Order shall be on site while activities regulated by this Order are being performed 33. No discharge or spillage of fuel, oil, or other pollutants into any area subject to protection under the Act shall result from this project If during any phase of site preparation, construction, or cleanup, there. occurs a spill or discharge of fuel, oil, or other pollutant, the North Reading Conservation Commission and the town hazardous waste coordinator shall be notified immediately by the applicant. 34. No de-icing chemicals or salts shall be used where runoff/drainage will be discharged into wetlands. This condition shall remain in perpetuity and shall be recorded as such on the Certificate of Compliance. 5. Upon completion of the project, a registered Professional Engineer, preferably the design engineer, shallsubmit a letter stating that all work has been completed in accordance with this Order and the approved plans. The letter shall also request that a Certificate of Compliance be issued by the North Reading Conservation Commission. No Certificate of Compliance will be issued until all disturbed areas have been properly and permanently stabilized.

36. An "As-Built" plan, prepared by a Registered Professional Engineer, preferably the design engineer, shaill be submitted to the Ifforth Reading Conservation Commission with the request for a Certificate of Complance. The As-Built plan shall detail any structures, walls, driveways, subsurface sewage disposal systems, 'andscaping features or other activities constructed within the jurisdiction of the Order: Finish grades shall be specified on the As-Built Any deviations from the approved plans must be clearly noted. Customer-Focused Solutions

TRC Reference No. E9202-5402-02250 VIA FAX and U.S. MAIL

May 27,2004

Mr. Derek Standish Massachusetts Department of Environmental Protection Division of Waterways One Winter Street Boston, MA 02108

Subject: 401 WQC DEP # 245-1029 Wetland Remediation and Restoration Project Former GE Facility Site (RTN 3-0518) 50 Fordham Road Wilmington, Massachusetts

Dear Mr. Standish:

As a follow-up to our site visit on May 6,2004, 1 have prepared the following letter to outline the discussed enhancements to the Wetland Remediation and Restoration project for the above-referenced project. We believe that these enhancements, made subsequent to the submittal of the 401 Water Quality Certification Application, are important to the successful completion of the remediation and restoration work at the Site.

Approach Modifications to Mmimize Water Handling

As presented in the 401 Water Quality Certification Application, the remediation work will be performed in a fashion so as to minimize working in wet conditions as well as minimize the volume of water generated during any dewatering operations. Specifically, to minimize water handling, an Excavation Containment Berm will be constructed to surround the excavation. This will prevent the inflow of surrounding water as well as prevent the discharge of suspended sediments to the surrounding wetland.

As an enhancement to the program, TRC now plans to 1) excavate the targeted wetland area in small discrete sections, and 2) use successive lines of silt fence and hay bales along the downgradient edge of each section to isolate contaminated soils from the resulting clean excavated area. This approach will prevent the discharge of affected soil to the surrounding wetland as well as create a "retention basin" that will provide settling for suspended solids prior to discharge of water back to the surrounding wetland.

The work will proceed in phases, starting at the eastern side (i.e. downgradient side) of the targeted area, moving back toward the parking area (i.e. upgradient side). This modification to the approach should provide additional protection against the discharge of impacted sediments as well as minimize the amount of water that is removed from the wetland during excavation.

31 Milk Street, Site 1104 * Boskon, Massachusetts 02109 Telephone 617-350-3444 - Fox 617-350-3443 Mr. Derek Standish May 27,2004 Page 2 of 2

Stabilization of Backftlled Area

Given that the remediation work is now planned for late-summer, not an optimum time for restoration planting, there probably will be a hiatus between the remediation/ backfiling phase of the project and the final restoration/shrub planting phase of the project. As you know, the best time for shrub planting would be in the fall when the plants are dormant.

TRC now plans to stabilize 6f the backfilled area by seeding with annual rye grass immediately following the backfilling and grading activities. The annual rye grass should take root and stabilize the backfilled material until the final restoration activities are complet An appropriate mulch may also be applied (e.g., straw).

Possible Enlargement of Remediation Area

As you acknowledged during our meeting, it is possible that the excavation may extend slightly beyond the limits indicated in the application. Although this is not expected, TRC would like to adopt your suggestion to obtain a permit that would accommodate a potential re-alignment or slight expansion of the remediation areas. This would obviate the need to amend the permit and allow for a more streamlined, cost-effective and timely remediation project with full compliance with the MCP. Revised Figure

On a final note, I have enclosed a revised copy of Figure 6A (Grading Schematic) for the project that depicts the correct depth of excavation. Specifically, the depth of excavation is now depicted as 12 inches below the minimnum wetland floor elevation.

Should you have any questions, please do not hesitate to contact my office. Sincerely,

Paola E. Macchiaroli, Ph.D. Senior Project Manager Enclosure

CC: Mary Trudeau, North Reading Conservation Commission Kevin Cotelli, Army Corps of Engineers Bruce Hoskins, CPI Steve Damiano, TRC Greg Mischel, TRC I I 0 I..- ~ bd L y z e0 05

E0 6

LANbmonl'e APPEND]X C

Turbidity Barrier Specifications

12004-456 y barriers

BARRIER TYPE MA-TE R I A L DE S CR I P TI O N I In M ETAED 10 us. (423 gi) ununaCed Viflyi-polyester 1nbric (Nee sptenl a t 22 oz. 1517 VI) vinyl-conted pciytswer rabn (note 1} (me, Ejwli) 7.5 or. (176 gr) wven plyp'Opylne filter rabik (sce sper

5/i Iach {1.0 cmrn po ro yine rnpc vertdia edge reiinforcemnt #4 bren rlIed rim grouninet efly hook and 4 Inch (l0 cm] elect vin counectors top 1.uid bn a - u.nsninui streas ptUes located at 40ble ind rh0 punket 1/4 inch . m v e el chairn balilnt ri/Iin ich (.79 cm) ivanlied ied ci min ballasi 7 j*.- 0/L in 1.70 cn) fx29, VingLat: Mnulv, steeI top ind tunor - du it li di44C kf 9-WS foam flotation - net pounds kg) butoyancy pr (no (turte 31 wnDf l'oot (1.53 i) standard depth or curtain (nnit 4) W* 5 t n (193 nil cLanIdard enrgth of cim'tiL (inote 5) 100 lbot 130.6 mi mandard length of curluln (notr 5 Nelcav DI22 ot. coualed abrir is fot'mendrd rot Type 1 rurtain deIjhs gractr liit 10 reet Th Mfor fabrie uaed in il/pe iuriets millut tw herl cemin. hose senmIrre awn. (3) Afloyzncy is Incrrcsed art curtains or speail depths In prmide grcale frenbuord, (4) Any special depth or brrer wilt be supplied to order. 15) Any pnetial JengLb of barrier wil be supplicd 10 order. F A D U 5F5C I F I U A T 1 0 8 CHARACTERISTIC 18 OUNCELANATED 22 OUNCECOATED FILTER FAB1UC CON.cLRUCT1N . . vinyl Coaled VriG uiler wovrn potyprorpytrne hn...' elcrh ______0 Qo/1000 WOVIrI pmlyruirr T IarMlh91,0n1w' sT.ua4- hunn, perw:;rt:. va T 12W11NM 2sbswr -24tb lldliawrr40lb i P/I s3 i iir heur z. f crIn a r li R1lbs wnr -59 i

HYI)ROSsATIC0 TNC d per iquare p qtppenn) (n'hl,

6 ft., maximum (1.83 m) *1.~

E E S.-..-

r-- stakes not included C 4- Slope in "N HINNEOMMM "11:

STAKED hardam are continuous fabric panele used to contain run-off onthe aite or diraet itIo retention amas. The fabric curtain has a heat seaed hem along the top edge and Is Approximately 44 Inches wide. Atrench 8 inches deep is dug along the perimeter line, aid stakes are driven every 6feet on the down slope ide of the trench. The lower edge of the curain Isplaced inthe trench and tha tonoh I lthen back filled. The upper portion of the oud4n to attached tg the stakes Qth sluple, wire or nylon Met keeping C the top ol the fabie about 36 inohe Above grade. The system works well in porous tolls on moderately sloped altes. EC A CORPO ATE MEMBER CANVAS PRODUCTS, INC. I-[ 1 couwmwcen sneemca 39181"721 8C:6G .AAS.7PU&/H O1E zo 39Vd 28 ~SJSI~diJN3 NVIN'8Pg6tg 986LG APPENDIX D

In-situ Pre-characterization

L2004-456 03/11/2004 18:54 19782759754 DCAM PAGE 0 1

T FORD COMPANY. 9NCa

DATE: August 12, 2004

TO: Greg Mischel

COMPANY: TRC

FAX 978-453-1995

FROM: Dan Galante

Numxr ofpages includig cover: 14

COMMENTlS:

Greg, Attached is the data summary table and back up analytical for the in-siu - testigg that was perfomed on the wetland soils in Wilmignn Even tough one test per 750 tons seemed to be OK with both Bruce Hoinas and the receiving ficIlity, we performed two samples in tho ven the quanities or something else eng. As youl see ftrom the data, the soils me well below the minimn requirements for reuse at a MA tined landfill. Thave birad ibis frimnn to bot Paola and Bruce. (I faxed to 603-524-7476 for Bruce - please doubl-check hA number if you can). Please review and let me know ifthere Is anything else Ineed to get Bruce so he can genrate the LSP replacement opinion letter befor he goes on vacation. Upon receipt of tw letter, I will forward to Waste branagcnent and schedule the removal of the soils for early next week (weather permitting). (Note: As discussed, 'm out of the office but available at 508-726-4086) Thanks,

*- 90 118 TENEYSTRET- GEORGETOWN, MA 01833 -978-352-506 -FAX 978-352-7943 * i *- 08/11/2004 18:54 19782759754 DCAM PAGE 02

Chemical Criterin Data Summary TEG -SituWetand Sampling TRC - Wilnington, MA

.& Se.a eana FaAter TRCWILM-01 TRCWL- (FTMf

TPH (ppn) 2300 2209 5,000 Arsenic (ppr 928 4-59 40

cdiu(ppm) 1.64 3.72 80

Crennu (pm) 26.8 248 1000 Lead (pW=) 123 190 2000

Mercury (pm) BD AL 10

Towi VOCe (pp)ODL BDL 4

T9d PCB (ppm) aDL BDL <12

Total SVOCa (ppn) DDL BDL1 100

TcL( ppM MW) na na na - n

NOTES: a) Contaminant leavd are based on the DTEP Policy COMM-97-O01 - Lined Landfli na -Not Anlyzed ND - Not Detected abow the lbntey Method Dection Limit (MDL) (4.., Below Dateation Lmit, BDL). NA - Not Appicable, No TCLP TC Limit has beta etbehd. NC - Not Calculated

40 08/11/2004 18:54 19782759754 DCAM PAGE 03

Environmental Laboratories, Inc. 587 East Middle Turnpike. P.O.Box 370, Manchester, CT 06040 TeL (860) 6454102 Fax (860) 645.0823

Atw MW. Dan Celante Draft Progress Report *k T Ford Company August 11, 2004 118 Tenne Street Georgetown, MA 01833

Sample Information Custody Information Date Time Matrix: SOIL Collected by- 08/10/04 0:00 Location Code: TFORD Received by: KJB 08/10/04 15:15 Rush Request: RUSH24HR Analyzed by: see 'By" below P.O.#: 0446 SDG .D.: CAF77437 Laboratory Data Phoenix ID.,: AF77444 Client ID: WILMINGTON WETLANDS TRC-WILM 01 Parameter Result RL Units Date Time By Reference

Siver BDL 0.5 nag/Kg 08/11/04 MH 6010/E20.7 Arsenic 928 1 08/1104 MH 6010/E200.7 mg/Kg ariurn 41-6 0.5 08/11/04 MH 6010I200.7 Cadmium 1.64 0.5 mg/Kg 08/11/04 MH 6010/E200.7 Chrornium 26.8 0.5 mg/Kg 08111/04 MH 6010/E200.7 Copper 791 5.0 mgfKg 08/11/04 MH 6010/E200.7 Mercury - Soil BDL 0.10 rmg/kg 0=11104 RS SW-7471 Lead 123 0.5 mg/Kg 08/11/04 MH 6010/E2005 Seleniun BDL 2.5 08/11/04 MH 6010/E200.7 ra/g TCLP Copper 0.087 0.01 08/11/04 MW E131VSW6010 mg/L TCLP I.ead 0.017 0.015 o/ 11/04 MH E1311/SW010 TCLP Zinc 1.73 0.01 08/11/04 NH E1311SWO Zic 172 0.5 mg/Kg 08/1104 MH 601/E200.7 PercentSolid 16 %9 08/11/04 C/D I160.3 Conducdvity 82 1.0 nos/cm 08/11/04 JD SM2510B Merury Digestin Completed 08/1 1/04 DM SW7471 Soil Extraction for PCB Completed 08/11/04 ABI 3545/3550 Soi Exm. for Send- Vol Completed 08/11/04 E/C SW3550/3545 TCLP Extraction Metals Completed 08/10/04 PL EPA 1311 Total Metals Diest Completed 08/10/04 AG SW846 -3050 TCLP MeaEs Digeson Completed 05/11/04/ DM SWS46 - 3005 Extraction of TPH MOD 8100 SM Completed 08/11/04 A/ 3550/5030 Polychlorinatd Blphenyls

Page 29 of 40 08/11/2804 18: 54 19782759754 DCAM PAGE 04

Client ID- WILMINGTON WETLANDS TRC-WILM 01 Phoenix I.D.: AF77444 Parameter Result RL Units Date Time By Reference PCB-1016 ND 400 ug/Kg 0811/04 JH SW 8082 PCB-1221 ND 400 08/1 1/04 JH SW 8082 PCB-1232 ND 400 ug/Kg 08/11/04 JH SW 8082 PCB-1242 ND 400 08/11/04 JR SW8082 ug/Kg PCB-1248 ND 400 08//11/04 JH SW8082 ug/Kg PCB-1254 ND 400 08/11/04 JH SW 8082 Ug/Kgug/Kg PCB-1260 ND 400 08/11/04 JH SW 8082 ug/Kg PCB-1262 ND 400 ogfTg 08/11/04 JH SW 8082 PCB-1268 ND 400 08/1104 JH SW8082 QA/QC Sirrogates %DCBP (Suwgate Rec) 55 08/11/04 JH SW 8082 % % TCMX (Surrogate Rec) 08/11/04 JH SW 8082

TPH by CC (Extractable Products) Fue10l#4 ND 50 mg/kg 08/11/04 JRB 8100Modified Fuel Oil #6 ND 50 m/kg 08/11/04 JRB 8100Modified Ful Oil#2 /Diesel Fuel ND 50 08/11/04 JRB 8100Modifted Kerosene ND 50 mg/kg 08/11/04 JRB 8100Modhified Motor OR* 50 08/11/04 JRB 8100Modifted nVg Other Oil (Cutting & Lubricating) ND 50 mg/kg 08/11/04 IRB BIacModifed a Unidentifed 2300 50 mgs/kgs 08/11/04 JRB 8100Modifted QA/QC Surrogates % n-Pentacosane Interference % 08/11/04 JRB 810OModified

Volatiles 1,13,2-Tetrachloroethane ND 180 Ug/Kg 08/11/04 RM SW8260 11,1-Trchloredthane ND 160 ag/Kg 08/11/04 RMU SW80 1,1,2-Tetradhloroethane ND 160 ug/Kg 0W/11/04 RM SW826M I,1,2-Trcloroetane ND 160 UVCg 08/11/04 RM Swsz6 1.1-Dichloroethane ND 160 0811/04 RM Swuaso ug/Kg 1,.1-Diloroethene ND 160 ug/Kg 08/1104 RM SW8260 13-DichoMopropene ND 160 ug/Kg 08111/04 RM SWO26G 12.3-Thlrobensene ND 160 ug/Kg 08/11/04 RM SW8260 L,2,3-Trilropropane ND 160 08/11/04 RM SWaz6o ug/Kg 1,2,4-Trkhlorobakene ND 160 8 08/11/04 FM sw8260 I2,4-Trinetylbenzene ND 160 08/11/04 ug/Kg RM SW8260 1,2-Dlbrorno-3-chloropropane ND 160 08/11/04 RM sWm80 ug/Kg L2-Dichlorobenzene ND 160 08/1104 RM SW8260 ug/Kg 1,2-Dkloroethene ND 160 08/11/04 RM SW8260 ag/Kg 1,2-Dkhlorpropane ND 160 08/111/04 RM SW8260 ug/Kg 1,3,5-Trmethylbenzene ND 160 08/11/04 PM SW8280 ug/Kg ND 160 08/11/04 RM SW8260 L3-DPchlrobenzenn ug/Kg . 1,3-Dkhloropropane ND 160 08/11/04 RM SW8260 Page 30of4VQ 08/11/2004 18:54 19782759754 DCAM PAGE 05

Client ID: WILMINGTON WETLANDS TRC-WILM 01 Phoenix LD.: AF77444 Parameter Result RL Units Date Time By Reference 1.4,Dichlorobenene ND 160 ug/Kg 08/11/04 RM SWa260 2,2-Dkiloropropane ND 160 ug/Kg 0811/04 RM SW8260 2-Chlorotdluene ND 160 ag/Kg 08/11/04 RM SWS260 4-Chlorotoluene ND 160 ug/Kg 08/11104 RM SW8260 Berzeno ND 160 fg/Kg 08/11/04 RM SW8260 Bromobenzene ND 160 ug/Kg 08/11/04 RM SWB260 Bromochloromethane ND 160 ug/Kg 08/11104 RM SW8260 Bromodichloromethane ND 160 ug/Kg 08/11/04 RM SW8260 Bromoforo ND 160 ug/Kg 08/11/04 RM SW8260 Bromomethane ND 160 ug/Kg 0/11/04 RM SW8260 Carbon tetrachlorld e ND 160 ug/Kg 08/11/04 RM SW8260 Chlorbenrene ND 160 ug/Kg 08/11/04 RM SW8260 Chloroethane ND 160 ug/Kg 08/11/04 RM SW8260 Chloroform ND 160 g/Kg 08/11/04 RM SW8260 Chloromethane ND 180 ug/Kg 08/11/04 RM SW8260 ds-l2.Dichloroethene ND 160 ug/Kg 08/11/04 RM SW8260 ds-1,3-Drloropropene ND 160 ug/Kg OW11/04 RM SWSz6 Dibromnochloromethane ND 160 ug/Kg OW11/04 RM SW6260 Dibromoerhane ND 160 fg/Kg 08/1104 RM SW8280 Dibromomezhwae ND 160 ig/Kg 08/11/04 RM SW8260 Dichlorodifluoromethne ND 160 rg/Kg 08/11/04 RM SWB260 Ethylbenzene ND 160 ug/Kg 08/11/04 RM 5W8260 Heachorobumdtene ND 10 UMg/Kg 08/11/04 RM SW8260 Isopropylbenene ND 160 ug/Kg 081104 RM sW8260 m&p-Xylene ND 160 ig/Kg 08/11/04 RM SW820 Methyl Ethyl Ketone ND 940 ug/Kg 08/11/04 RM sW8260 Methylt-butyl ether (MTBE) ND 310 ug/Kg 08/11/04 RM SW8260 Methylene choride ND 160 ug/Kg 08/11/04 RM SWB260 n-Butylbenzee ND 160 ug/Kg 08/11/04 RM SW80 n-Propylbenzemn ND 160 ug/Kg 08/11/04 RM SWZO Naphthalene ND 100 ug/Kg 08/11/04 RM SWS26O o-Xylene ND 160 ug/Kg 08/11/A4 RM SW820 p-Isopropyltoluene ND 160 Ug/Kg 08/11/04 PM SW8260 sec-Butylbenaee ND 160 ug/Kg 08/11104 RM SW8260 Styrene ND 160 ug/Kg 08/11/04 RM SW8260 tert-Butylbemne- ND 100 ug/Kg 0811/04 RM Swa2 Tetrachloroethene ND 160 ug/K 08/11/04 RM SW6O Toluene ND 160 Ug/Kg 08/11/04 RM SWB2E0 Total Xylenas ND 100 ug/Kg 08/11/04 RM SW8260 trans-1,2-Dichloroethene ND 160 ug/Kg 08/11/04 RM SW8260 trans-1,3-Dichoropropene ND 160 ug/Kg 08111/04/M SWa26m TrIchloroetne ND 160 ug/Kg 0s/11/04 RM SW8Z60 a flkhbloronmethun ND 160 ug/Kg 08/11/04 RM SW8260 chloride ND 160 rig/Kg 08/111/04 RM SW8260

Page 31 of 40 0'8/11/2004 18:54 19782759754 DCAM PAGE 06

Client ID: WILMINGTON WETLANDS TRC-WILM 01 PhoenIx LID.: AF77444 Parameter Result RL Units Date Time By Reference QA/QC Surrogates % 12-dichlorbenzene-d4 119 % 08/11/04 RM SW8260 % Bronofluorobenzene 93 % 08/11/04 RM SW8260 %Dibromofluoromethmne 110 % 08/11/04 RM SWZ6 %Tokene-dS 97 % 08/11/04 RM SW8260

Semivolatiles 1.2,4-Trichlorobenzene Nt 660 ug/Kg 08/11/04 DRC SW 8270 1,2-Dlchlorobenzene ND 660 ug/Kg 08/11/04 DRC SW8270 1,2-DIphenyhydrazine ND 660 tg/Kg 08/11/04 DRC SW8270 L,3-Didlarobnenw ND 660 ug/Kg 08/11/04 DRC SW 8270 L4-Dichlorbenzene ND 660 ug/Kg 08/11/04 DRC SW 8270 2,4,5-Trlchlorophenol NP 660 ug/Kg 08/11/04 DRC SW 8270 2.4,6-Trichlarophenol ND3 550 g/Kg 08/11/04 DRC SW 8270 2,4-Dichloruphenol ND 660 vg/Kg 08/11/04 DRC SW 5270 2,4-Dtnethylphenol ND 660 ug/Kg 08/11/04 DRC SW 8270 ZA-Dinitrophenol ND 3200 ug/Kg 08/11/04 DRC SW 8270 2,4-Dftrtrotoluene ND 660 ug/Kg 08/11/04 DRC SW 8270 2,6-Dichlropheno1 ND 660 tg/Kg 08/11/04 )C SW 8270 2.6-Dinitrotluene ND 860otg/Kg 08/11/04 DRC SW 8270 2hlornnaphthalene ND 660 ug/Kg 08/11/04 DRC SW 8270 2-ChIAropheno1 ND 660 ug/Kg 08/11/04 DRC SW 8270 2-Methylnaphthalene ND 660 ug/Kg 08/1104 DRC SW 8270 2-Methyiphenol (o-creso ND 660 ug/Kg 08/11/04 DRC SW8270 2-Nitroarline ND 3200 ug/Kg 08/11/04 DRC SW 8270 2-Nitrophenol ND 660 ug/Kg 08/11/04 DRC SW8270 3&4-Methylphenol (mt&p-crso) ND 860 ug/Kg 08/11/04 DRC SW 5270 3,3-Dichlorbenzlne ND 1300 ug/Kg 0811/04 DRC SW 8270 3-Mtroaniline ND 3200 ug/Kg 08/11/04 DRC SW 8270 4,6-Dintro-2-methylphenol ND 3200 ug/Kg 08/11/04 DRC SW 8270 4-Bromophenyl phenyl ether ND 660 ug/Kg 08/11104 DRC SW 8270 4-Chlore-3-methylphenol ND 1300 ug/Kg 08/1104 DRC SW8270 4-Chloroanlline ND 1300 ug/Kg 08/11/04 DRC SW8270 4-Chlorphenyl pheny ether ND 660 ug/ig 08/11/04 DRC SW 8270 4-Niroardline ND 3200 g/Kg 08/11/04 DRC SW8270 4-Nitrophenol ND 3200 ug/Kg 08/11/04 DRC SW 8270 Acenaphtneue N) 660 ag/Kg 09/11/04 DRC SW 8270 Acnnaphhylene ND 60 tag/Kg 08/11/04 DRC SW 8270 Anthwacene ND 660 g/K8 08/1/04 DRC SW 8270 Derm(anthrcene NJ) 660 ug/Kg 08/1 1/04 DRC SW8270 Bernidine ND 660 Utg/Kg 08/11/04 DRC SW 8270 Denzo()pyrene ND 660 ug/Kg 08111/04 DRC SW8270 Bzo(b)fluoranrheve ND 660 ug/Kg 08/11/A4 DRC SW 8270

Page 32 of 40 08/11/2884 18:54 19782759754 DCAM PAGE 07

Client ID; WILMINGTON WETLANDS TRC-WILM 01 Phoenix LID.: AF77444 Paraneter Result RL Units Date Time By Reference Benzo(ghlperylene ND 560 ag/Kg 08/11/04 DRC SW 8270 Benzo~k)fluoranthene ND 660 ug/Kg 08/11/04 DRC SW 8270 Bezock acid ND 3200 ug/Kg 08/11104 DRC SW 8270 Benzyl alcohol ND 1300 ug/Kg 08/11/04 DRC SW8270 Bonzyl butyl phthalate ND 660 vg/Kg 08/11/04 DRC SW 8270 BIs(2-chloroethoxy)methane ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(2-chlorOethy)ethe ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(2-chloroisopmpyl)ether ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(2-ethylhexylphthalate ND 660 Ug/Kg 08/11/04 DRC SW 8270 Chrysene ND 660 og/Kg 06/11/04 DRC SW 8270 Di-n-butypthalate ND 660 ug/Kg 08/11/04 DRC SW 8270 Di-n-octylphthalate ND 660 ugfKg 08/11/04 DRC SW 8270 Diben(a,h)anthacene ND 660 ug/Kg 08/11/04 DRC SW 8270 Dibenmfuran ND 660 Ug/Kg 08/11/04 DRC SW 8270 Diethyl phthnlate ND 660 ug/Kg 08/11/04 DRC SW 8270 Dlnethylphthalate ND 660 ag/Kg 08/11/04 DRC SW 8270 uoranthene ND 660 ag/Kg 08/11/04 DRC SW 5270 Fluorene ND 60 ug/Kg 08/11/04 DRC SW 8270 Hexachlombenzene ND 6M0 ug/Kg 08/11/04 DRC SW8770 Hexachlorobutadmne ND 660 ug/Kg 08/111/04 DRC SW 8270 S xchlorocyclopentadiene ND 660 ug/Kg 08/11/04 DRC SW 8270 Hexachloroethane ND 660 ug/Kg 08/11/04 DRC SW 8270 Inden(1.2Safjpyrene ND 660 ug/Kg 08/11/04 DRC SW 87O Isophozone ND 60 ug/Kg 08/11/04 DRC SW 8270 N-Nitmsod1-n-propylamnine ND 660 ug/Kg 08/11/4 DRC SW 8270 N-Nitrosodhnethylamine ND 660 tg/Kg 08/11/04 DRC SW 8270 N-Ntrosodiphenylamine ND 860 ug/Kg 08/11/04 DRC SW 8270 Naphthalene ND 660 ug/Kg 08/11/04 DRC SW 8270 Nitrobenzene ND 660 ug/Kg 08/11/04 DRC SW 8270 Pentadlorphenol N 060 ug/Kg 08111/04 DRC SW8270 Phenanthene ND 660 ag/Kg 08/11/04 DRC SW 8270 Phenol ND 660 ug/Kg 08/11/04 DRC SW 8270 Pyrene ND o0 ug/Kg 08/11/04 DRC SW 8270 Pyrdine ND 660 ug/Kg 08/11/04 DRC SW 8270 QA/QC Surrogates %24,6-TrIbromophenoI 87 % 08/11/04 DRC SW 8270 %2-Fhwrobipheny1 67 08/11/04 DRC SW 8270 %2-Fluorophenol 54 % 08/11/04 DRC SW 8270 %Nitrobenzene-d5 54 % 08/ 1/04 DRC SW 8270 % Phenol-d5 59 % 08/11/04 DRC SW 8270 %Terphenyl-d14 43 % 08/11/04 DRC SW 8270

Page 33 of 40 08/11/2004 18:54 19782759754 DCAM PAGE 08

Comments: ND-Not detected 3DL = Below Detection Limit RL- Reporting Limit *Petrolew, Jd*owbwn chranatogam wast a perfet math with any ofthe staulsnds. but mast drely resembles ntor al. "' Elevawd mrdrs are due to matmr ixierference. If there are any questions regarding this data, please call PhDenix Client Services at extension 200. PLEASE NCTE: THIS PROGRESS REPORT IS CONSIDERED PRELIMINARY DATA. THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

Page 34 of 40 0'8/11/2004 18:54 19782759754 DCAM PAGE 09

Environmental Laboratories, Inc. 587 East Middle Tunpilw, P.OBox 370. Manchester. CT 06040 TeL (80) K5-1102 Fax (860) 645.0823

FOR: Attn: Mr. Dan Calante Draft Prowess Report T Ford Company August 11, 2004 118 Tenne Street Georgetown, MA 01833

Sample Information Custody Information Date Time Matrix: . SOIL Collected by: 08/10/04 0:00 Location Code: TFORD Received by- KJB 08/10/04 15:15 Rush Request: RUSH24HR Analyzed by: see "By"below P.O.#: 0446 SDC I.D.: CAF77437 Laboratory Data Phoenix I.D.: AF77445 Client ID: WILUNGTON WETLANDS TRC-WILM 01A Parameter Result RL Units Date Time By Reference

0.892 0.5 wWgKgs 08/11/04 MH 6010/E200.7 . Silver Arsenic 4.59 1mg/Kg 08/11/04 6010/E200.7 Barium 37 0.5 mg/'Kg 08/11/04 MH 6010/E200.7 Cadmium 3.72 08/11/04 MH 6010/E200.7 Chromium. 24.8 0.5 mg/Kg 08/11/04 MH 6010/1200.7 Copper 1070 5.0 mgfKg 08/11/04 MR 6010/200.7 Mercuty - Sail BDL 0.10 rag/kg 08/11/04 RS SW-7471 Lead 190 0,5 mgKg 08/11/04 MH 6010/200.7 Selerdum BDL 2.5 mgfKg 08/1104 MH 6010E200.7 TCLP Copper 0.188 0.01 mgt'L 08/11/04 MR E1311/SW01o TCLP Lead 0.034 0.015 mg/L 08/11/04 MR E131I/SW8010 TCLP Zinc 1,96 0.01 mg/L 08/11/04 MH E1311/SW6010 Zic 470 0.5 mg/Kg 08/11/04 MH 6010/200.7 Percent Solid 15 08/11/04 C/D E160.3 Condctvty 120 1-0 umhos/crn 08/11/00 JD SMZ510B MecOry Un Completed 08/11/04 DM SW7471 Soil Extaction for PCB Completed l8/11/04 AB/ 3545/3550 Soil Ext for Semi- Vol Completed 08/11/04 B/c SW3550/3545 TCLP ExhctraonMetals Completed 08/1W04 PL EPA 1311 TotalMetalsDigest Completed 08/10/04 AG SW846 - 3050 TLP Meta Dign Completed 08/11/04 DM SW846 -3005 Etracton of TPH MOD 8100 SM Completed 08/11/04 AB/ 3550/5030 *Polychlorinated Biphenyls

Page 3 of 40 65/11/2004 18:54 19782759754 DCAM PAGE 10

Client UD: WILMINGTON WETLANDS TRC-WILM 01A Phoenix ID.: AF77445 Parameter Result RL Units Date Time By Reference

PCB-3016 ND 400 ug/Kg 08/11/04 JH SW 8082 PCB1221 ND 400 ugfKg 0811/04 JH SW8082 PCB-1232 ND 400 ug/Kg 08/11/04 JH SW 8082 PC3)-1842 ND 400 ug/K~g 08/1104 JH SW 8082 PCB 1248 ND 400 ug/Kg 0&11/04 JH SW 8082 PC- 1254 ND 400 ugfKg 0811/04 JH SW 8082 PCB-1260 ND 400 ug/Kg 08/11/04 JHR SW 808Z PCs-1253 ND 400 08/11/04 JH SW 8082 PCB-1268 ND 400 ug/Kg 08111/04 JH SW 802 QA/QC Surrogates % DCBP (Surrogate Rc) 52 %6 0811/04 JH SW 8082 % TCMX (Surrgate REc) 78 %6 0811/04 SH SW 8082

TPH by CC (Extractable Products) Fue Oil #4 ND 50 mg/kg 0811/04 JRB 8100Modified Fuel On #6 ND 50 mg/kg 08/11/04 JRB 8100Modified Fuel 011#2 / Diesel Fuel ND 50 mg/ft DW1104 JRB 8100Modified Kerosene ND 50 08/11/04 JRB 81OModified Motor Oil 50 08/11/04 JRB 8100Modified Other Oil (Cuttng &Lubrdcating) ND 50 mg/kg 08/11/04 JRB 8100Modified . Unidentified 2200 50 mg/kg 08/111/04 JRB 8100Modified QA/QC Surrogates % n-Pentscosane Interference %6 05/11/04 JRB 8100MadiftIed

Volatiles 1,1,,2-Tetrachloroethane ND 170 ug11cs 08/11/04 RM SW8260 1,1,1-Triloroethane ND 170 ug/Kg 08/11/04 RM SW8260 1,12.2-Tetrachloroetane ND 170 u9ft 08/11/04 RM SW8860 g/Kg .12-Trichlooethee ND 170 u OM11/04 RM SWS260 1.1 -Dithloroethane ND 170 ug/Kg MumIZV0 RM SW826O 1,1-Dichloroethene ND 170 ug/Kg 08/11/04 RM SW8260 J..Dichlropw ND 370 U 0811/04 RM SW8260 1,,3-Trichorobenrzee ND 170 u 08/11/04 RM SW8260 1A3-Trkhloropropene ND 170 g/Kg 0811/048 RM SW8280 g/Kg 1,2.4-Trichlorobenzene ND 170 u 08 1104 RM sW8z6o 12,4-Trmethy1benzene ND 170 u 08/11/04 FM SW860 1,2-Dibromo-3-chloroprupane ND 170 g/Kg W1 1/04 RM SW260 g/Kg 1.2-Dichlorobenzene ND 170 u 08/11/04 RM SW8260 1,2-Diloroethane ND 170 u 08/1/04 RM SW8260 g/Kg 1,2-Dichlropropane ND 170 u 08/11104 RM SW8260 g/Kg9 1.3,5-Trimethylbeme ND 170 U ow1D4 RM SW260 g/Kg 1,3-Dichlombenzen ND 170 u 08/11V04 SW826g g/Kg . ,3-Dichloropropane ND 170 u 08//04 RM SW8260 Page 36 of 40 0b/11/2004 1B: 54 19782759754 DCAM PAGE 11

Client ID: WILMINGTON WETLANDS TRC-WILM 01A Phoenix ED.: AF77445 Parameter Result RL Units Date Time BY Reference 1,4-Dchlorobe ND 170 ug/Kg 01/4 EM 8W820 2,2-Dichoropropane ND 170 ug/Kg 08/11m EM SWBZ8O 2-Chlrtoluene ND 170 ug/Kg 08/11/04 RM SW&0 4-Chorotoluene ND 170 ug'Kg 0811/04 RM SW.ze Denzene ND 170 tg/Kg 08/1V04 PM 5W8260 Bromobenzene ND 170 ugKg 0811/04 RM SW8Z0 Bromachromethane ND 170 ug/Kg 08/11/04 RM SWBZOO Bromodilorornetban ND 170 ug/Kg 08/11M4 RM SWSz Bromoform ND 170 ug/Kg 08/11/04 M SWSE0 Bromomethane ND 170 g/Kg 08/11/04 PM swam Carbon trachlrde ND 170 ug/Kg U8/11/0 RM SUM Chlorabenzene ND 170 tg/Kg 08/11/04 PM S"6 Chioroethane ND 170 uag/Kg 08/li/s M SW8260 Chloroform ND 170 ug/Kg 08/11/ M SW8260 Chloromethane ND 170 ug/Kg 08/11/04 PM SWSZSO ds-L2-Dichoroethene ND 170 ug/Kg 081104 PM SWB26 ds-1.3-Dichlrvprpene ND 170 ug/Kg 08/11/04 RM 3W8260 Dibromochloromethane ND 170 ug/Kg O8V11/04 RN 3W836 Dibromoethane ND 170 ug/Kg 08/11/04 EM SW8280 Dibromomethane ND 170 ug/Kg 0811/94NPM SW8 Dichlarodifluoromethane ND 170 0g/Kg8/11/04 PM SW Etylbenzene ND ND 10170 ta/Kgw(gKg 08/11/041/ RM SWSZ6SW8260 Hexchlarabutadiene ND 170 tg/Kg 08/11/04 PM SW8ZO Lopropylbnene ND 170 ug/Kg 0w1/04 P M m&p-Xylene ND 170 ag/Kg - 11/04 RM SWB Methyl Ethyl Ketne ND 1000 ug/Kg 0811/04 RM SWS2BO Methyl t-buty ether (kIBE) ND 330 ug/Kg 0811/04 RM SWUM Merhylene chloride ND 170 tg/Kg 0110 RM swam n-Butybenzene ND 170 tg/Kg 081104 EM SW n-Propylbenne NP 170 ug/Kg 08110 kM SWEC Naphthalene ND 170 ug/Kg 0811/04 RM 5W820 o-Xylene ND 170 ug/Kg 08/1104 EM SW8zQ p-lsopropyltoluene ND 170 ug/Kg 0811/04 Pm swam sec-Butylbenzene ND 170 ug/Kg 0811/04 RM W820 Styrne ND 170 utg/Kg 11 RM SW 0 tert-Buglbenene ND 170 ug/Kg 011/04 PM SWS8 Tetrachloroethene ND 170 ugflB 08/11/04 EM SWSSO Touene ND 170 tug/Kg 0811/04 RM SWZ Total Xylenes ND 170 ug/Kg 08/11/04 PM SW 60 ans-1,2-Dhoroetbene ND 170 tAg/Kg 0 104 RM $WO trans-1,3-Dihloropropene ND 170 ug/Kg 0811104 RM SW Trchloroethene ND 170 utg/Kg 11/04 M SW 60 rilro~mffuommethane ND 170 USog/V0Kg W86 NDe 170 tag/Kg 08/11/04 RM SWU26 Pag 37 of 40 88/11/2004 18:54 19782759754 DCAM PAGE 12

Client ID: WILMINGTON WETLANDS TRC-WILM 01A Phoenix LD.: AF77445 . Parameter Result RL Units Date Time By Reference QA/QC Surrgates % L2-dclorobenzee-d4 119 % 08/11/04 RM SW8260 %Bromoffuorobnen 95 % 08/11/04 RM SW8260 %Dibrmofhromethane 109 % 08/11/04 RM SWU260 96 '1ee-d8 98 % 08/11/04 RM SW8260

Semivolatiles 1,24-Trichlorobenmen ND 660 ug/Kg 08/1 U04 DRC SW 8270 1,2-Dichlorobermene N) 600 ug/Kg 08/11/04 DRC SW 8270 L2-Dipbenythydazine ND 660 ug/Kg 08/11/04 DRC SW 8270 1,3-Dchlorobenzun ND 660 ug/Kg 0811/04 DRC SW 8270 1,4-Dkhlorobenzene ND 660 ug/Kg 08/11/04 DRC SW 8270 2,4,5-Tdchloropbenol ND 50 tag/Kg 08/11/04 DRC SW 8270 2,4,s-Tdchkorophenol NP 650 u"g 08/11/04 DRC SW 6270 2,4-Dchlorophenol ND 660 ug/Kg 08//d4 DRC SW 8270- 2A-Dnethylphenol ND 560 g/Kg 08/11/04 DRC SW 8270 2,4-Dinitrophenol ND 3200 ug/Kg 08/11/04 DRC SW 8270 2A-Dkitratuluene ND 660 ug/Kg 08/11/04 PRC SW 8270 2.6-Dichlorophenol ND 660 ug/Kg 08/1/04 DRC SW 8270 2.6.DLnroteuene ND 6w ug/Kg 08/11/04 DRC SW 8270 O 2-Chloronaphthalene ND 660 ug/Kg 08/11/04 DRC SW 8270 2-Clorophenol ND 660 ug/Kg 08/11/04 DRC SW 8270 2-Methylnaphthalene ND 660 ug/Kg 08/11/04 DRC SW 8270 2-Methylphenol (o-cre ND 660 ug/Kg 08/11/04 DRC SW 8270 2-Nitanfitne ND 3200 ug/Kg 08/11/04 DRC SW 8270 2-Nitropbenol ND 860 g/Kg 08/11/04 DRC SW 8270 3&4-Methylphenol (m&p.aso1) ND 660 ug/Kg 08/11/04 t)RC SW 8270 3,3'-Dlchlorobenddine ND 1300 ug/Kg 08/11/04 DRC SW8270 3-Niuaniitw ND 3200 ug/Kg 08/11/04 DRC SW 8270 4,8-Dinro-2.methylphenol ND 3200 ug/Kg 08/11/04 DRC SW8270 4-Broruopherylphenylethr ND 660 ug/Kg 08/11/04 DRC SW8270 4-Chloro-3-methylphenol ND 1300 vg/Kg 08/11/04 DRC SW 8270 4-Chloroaniline ND 1300 ug/Kg 08/11/04 DRC SW 8270 4-Chlorophenyl phenyl ether ND 660 ug/Kg 08/11/04 DRC SW8270 4-Ntroallizne ND 3200 ug/Kg 08/11/04 DRC SW 8270 4.Nitophwnol ND 3200 Ug/Kg 08/11/04 DRC SW8270 Acenaphthene ND 860 ug/Kg 08/11/04 DRC SW8270 Acenaphthylene ND 660 rg/Kg 08/11/04 DRC SW 8270 Anthracen ND 60 w8/Kg 08/11/04 DRC SW 8270 Benz(a)arbracene ND 660 og/Kg 08/11/04 DRC SW 8270 Benddine ND 660 ug/Kg 08/11/04 DRC SW 8270 Benzoa)pyrene ND 660 ug/Kg 08/11/04 DRC SW8270 nzo(b)furanene ND 660 Ug/Kg 08/11/04 DRC SW 8270 08/11/2004 18:54 19782759754 DCAM4 PAGE 13

Client ID: WILMINGTON WETLANDS TRC-WILM 01A Phoenix LD.: AF77445 S Parameter Result RL Units Date Time By Reference Benzo(Shi)perylene ND 660 ag/Kg 0/11/04 DRC SW 8270 Benzo(k)fluorambene ND 550 ug/Kg 08/11/04 DRC SW8270 Benzic add ND 3200 ug/Kg 08/111/04 DRC SW 8270 Berwylalcohol ND 1300 tg/kg 08/11/04 DRC SW 8270 Benzyl butyl phthnlato ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(z-chloroethoxy)methm ND 660 ag/Kg 08/11/04 DRC SW 8270 Bis(2-chloroethyl)ether ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(24 roop apyl)ether ND 660 ug/Kg 08/11/04 DRC SW 8270 Bs(2-ethylhexyDphthfiaae ND 660 ugfKg 08/11/04 DRC SW 8270 Cluysene ND 660 tag/Kg OW11/04 DRC SW 8270 Di-n-butylphthalate ND 60 ug/Kg 08/11104 DRC SW B270. Di-n-ottyiphthalae ND 80 ug/Kg 08/1104 DRC SW 8270 Dibenz(aVandracene ND- 660 ug/Kg 08/111/04 DRC SW 8270 Dibenzfurnw ND 660 ug/Kg 08/11/04 DRC SW 8270 DletAyl phthalate ND 660 ug/Kg 08/11/04 DRC SW 8270 Dimethyphthalate ND 660 ug/Kg 08/11/04 DRC SW 8270 Fluoranthene ND 660 ug/Kg 08/11/94 DRC SW 8270 Fhorene ND 660 ug/Kg 08/11/04 )RC SW 8270 Hexachlorobenzne ND 660 'g/Kg 08/11/04 DRC SW 8270 Hexachorobutadiene ND 660 ug/Kg 08/11/04 DRC SW 8270 Hexachorcydopentadiene ND 660 ug/Kg 08/11/04 DRC SW 8270 Sexachloroetane ND 660 ug/Kg 08/11/04 DRC SW 8270 Inden(1,2,3-cd)rene ND 660 ug/Kg 08/11/04 DRC SW 8270 EsophWooe ND 660 ug/sg 08/11/04 DRC SW 8270 N-Nltrosodi-n-popylamine ND 860 ag/Kg 08/11/04 DRC SW 8270 N-Ntrosodhmethylamine ND 660 ug/Kg 08/11/04 DRC SW8270 N-Nltrosodiphenylandne ND 660 ug/Kg 08/11/04 DRC SW 8270 Napbthalene ND 600 ug/Kg 0$/11/04 DRC SW 8270 NItrobenzene ND 660 ug/Kg 08/11/04 DRC SW 8270 Fentachlorophenol ND 660 ug/Kg 08/11/04 DRC SW 1270 Phenanthrene ND 680 Ug/Kg 08/11/04 DRC SW 8270 Phenol ND 660 ug/Kg 08/11/04 DRC SW 8270 Pyrene ND 660 ug/Kg 08/11/04 DRC SW8270 Pyridie ND 660 ug/Kg 08/11/04 DRC SW 8270 QA/QC Surrogates % 2,4,6-Trlhromopinl 85 % 08/1104 DRC SW 8270 % 2-Huorobiphenyl % 11/ 4 DRC SW 8Z70 % 2-Fluorophenol 54 % 08/1104 DRC SW 8270 % Ntrobenene-d5 50 % 08/11/04 DRC SW 8270 %Phenol-d5 6 % 08/11/04 DRC SW 8270 %Terphenyl-d34 62 % 08/11/04 DRC SW 8270

Page 3 of 40 08/11/2004 18:54 197B2759754 DCAM PAGE 14

Comments: ND-Not dotected BDL - Below Detection Limit RL=Reporting Limit Petoubydrbonchomgamw t a perfect match witbWthe standA but moot doselyrsembas mowo dl * Elevatedmdirs are due to matix interhren. If there are ny questions regarding this data, please call Phoenix Client Services at extension 200. PLEASE NOTE: THIS PROGRESS REPORT IS CONSIDERED PRELIMINARY DATA. THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

Page 40 of 40 APPENDIX E

Material Shipping Record and Log

L2004-56 Massachusetts Department of Environmental Prtection Bureau of Waste Prevention Material Shipping Record & Log TrckngNumber For the shipment of contaminated soil, urban fill, and dredge materials not subject to management under section 310 CMR 40.0035 nor manifesting under 310 CMR 30.000

IMPORTANT: SLocation Information This form is NOT to be used for the 1. Provide the following information on the location where the waste was generated: shipment of remediatioi - Releasename(optin wastes subject to management under section 310 tooaid CMR 40.0035 of v-,-4 WA the Massachu- Ciy/rosn Slate zip Cx setts Contingency Plan nor is it to be 2. Date/Period of generation: 5. Ust additional tracking documents associated with this used in lieu of a /jO f document hazardous waste Tigqq04 manifest for FmM To hazardous waste or recyclable 3. U.S. EPA IDnumber: materials subject to the Massachu- setts Hazardous Waste Regula- 4. 21E rel se: tions 310 CMR 30.000. yes o no MGeneratorinformation 0 1. Provide t following generator information: U&JAV te) a r ca sp Naw~ ' )Ofo ccZcdr

sbeafless B. A-'> 20 a i7 CtyTon state Zipcode

Telegce runir arid tamsion

IS] Owner and/or Operator Information

1. If the owner and/or operator is different from the generator as indicated in Section R provide the following information:

Check applicable: [ owner 0 0perator

conact n"ne Ttk

city/Tos state Zip C elg-3n0x- ctno Tekphw~mfftw *dafis

Rev. 3/94 page 1 of 5 Massachusetts Department of Environmental Protection Bureau of Waste Prevention Material Shipping Record & Log ra"ng""umr For the shipment of contaminated soil, urban fill, and dredge materials not subject to management under section 310 CMR 40.0035 nor manifesting under 310 CMR 30. 000 I TransporterCommon Carrier Information

1. Provide the following information: S kASTiA so- Tranp3ara rianste i sent (i tabe) Laning swe (if tiabe)

3 A A 019 3 3 cyUfITs zip

W Receiving Facility Information

1. Provide the following information on the receiving facility: Lg&~Ag a

el -r,, 051-. AkA~ d647:3

bm.9-7B Sla1t-764e zip CO& Te10Wqnuwn''aid~ 2. Type of facility:

o asphalt batch/cold mix o Indfill/disposall o thermal processing E] asphalt batch/hot Mix Qlandfill/daily cover o landfill/structural fill O other:

3. Permit number:jWJW\ 0172- W Description of Material Check all that apply:

1. a. " 1 5 dredge material 0 fill 3. Type of contamination:

b. Description: a. [O gasoline 0 diesel fuel 0 #2 oil 0 #4oil KdcrWJ NW] wcc o #6oil ] waste oil ] kerosene 5 jet fuel b. 0 Debris:

C demolition E] vegetative D inorganic c. Classification: 0 MIT 5 USDA D USAEC 0 ASEE c. t6er: IC ot CoppQ -X 'V-c 2. 0 Other:

0 tksake

Rev. 3194 Page 2 of 5 Massachusetts Department of Environmental Protection Bureau of Waste Prevention

Material Shipping Record &Log rackingNumber For the shipment of contaminated soil, urban fill, and dredge materials not subject to management under section 310 CMR 40.0035 nor manifesting under 370 CMR 30.000 [ Description of Material (coMn.)

4. Constituents of concern (check all that apply): 7. Estimated volume of materials:

OEAs E Cd 0 Cr & 0Hg 0 Na PCBs cahc? E HVOCs E PATH 0 VOCs E PAHs E BNAs Otbk Yartt 0 TPH El Other:

TW1S

desaibe

5. Analyses performed (check all that apply): 8. Contaminant source (check one/specify): 4 9g Elr Na (34

9. Indicate which waste characterization support documentation is attached: 6. Screening performed: o site history information A t) weP Elmpling and analytical methods/procedure I1aboratory data E field screening data

If supporting documentation is not appended fostumrm Used provide an attachment stating the date and in connection with what document such information was previously submitted to the facility

Qualified Environmental Professional Opinion M

Nae orgwartion

Tea Mberkntex

I have personally examined and am familiar with the information contained on and submitted with this form. WIcl Based on this information, it is my opinion that the testing and 6L4 assessment actions undertaken were adequate to characterize the waste, and that the facility or location can accept wastes with the characteristics described in this submittal. I am tin aware that significant penalties including, but not limited to, possible fines and imprisonment may result if I willfully submit information which I know to be false, inaccurate, or materially incomplete!

Rev. 3/94

A *~ Massachusetts Department of Environmental Protection Bureau of Waste Prevention

Material Shipping Record & Log Tracing Nurnr For the shipment of contaminated soil, urban fill,and dredge materials not subject to management under section 310 CMR 40.0035 nor manifesting under 310 CMR 30.000 W Certification of Generator

'I certify under penalties of law that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this certification, and that, based on my inquiry of those individuals immediately responsible for obtaining the 9--2--o4 information contained herein is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, Mum Qno ' inaccurate, or incomplete information. -Pr Lo6cV-\scesA&#twf Coipf-3

U Acknowledgment of Receipt by Receiving Facility

RTevi Faily

RseVa ap/n

Rev. 3/94 Page 4 of 5 Massachusetts Department of Environmental Protection Bureau of Waste Prevention Material Shipping Record & Log Tracking Number For the shipment of contaminated soil, urban fill, and dredge materials not subject to management under section 310 CMR 40.0035 nor manifesting under 310 CMR 30.000 Li Load Information LOAD I: LOAD 0: -

Note: Make additional copies of this tSiirajnidfritydVW- offilly page as necessary. Atereciit ebfrmnehul

Tine rmed Timeremied

Wedshipnt Twdshiprfe

Thmdshman Ti dshimrt

Tn/Traawesaion

Trdrrjistak

Lad size(Qtc jgdsos) ' Load sie (abic yrdnn)

LOAD 0: LOAD #:

S~wD u-mr-

RecYving acility

DaterMed - DatereoMi

Timreimik rimerecimti lint (Me Date dshprt 11medshipmer Timedshpip t DA*T hra tg~~

Tnfr/Tiarrafstatin TukItarttgisathim~

Trail regita6a Traikr regiski

Load size(atc ya&As) Load size (cicpydsms)

L9j Log Sheet Volume Information

Page _ of _ Toal wliu spge (bic yntAtms)

TotalWrkdkvrd (c"c ywds4ans)

Toaf camird axdtis pag (aic yrdtmns)

Rev. 3/94 Page 5 of 5 &Alf-lm %J .. J~' J. .3, tkt I '.301 rgtz 02 3 vt*n

Oxemical Criterin Data Summary TFCI In-Situ Wedand Sampling TRC- Wilmington, MA

- .--- Res ~vt TRCWRM-01 TaCWRM-W1 VTF

TPH (poi 2300 2200 3,000 Anewic(ppOQ 928 4.59 40

cA-tu-(pp 1.64 3.72 80

rmimi4pn) 26.8 24,8 1000 Lad(p".) 123 120 2000

Muewty (Pm) BDL BDL 10 Tautvoca(ppm) BDL BD 4

TOW PCB (ppm) BDL BDL C

,TE asvoo (ppow UD EDL 100

Tcr. (ppj L) un a a a a

a) cotmit Ivcs are bam d -n the MDEP Policy COM -974O01 - Lied Land6Hl na -N t Aaalywd D -Not Uetd above a borday Mdthod Detctian Limit (MDL) (e., BelowfDtcdoa LUmit BDL). NA-Not AppiableNo TCLP TC Lin has beec*Utbho NC -Not Calculated L"Ut ±±t ZAI.WV .* ±LJ . ruUI . t .4 i.-*' I-AUEi 03

Environmental Laboratories, Inc. 587 Et Middle Twnpike. P.Q-ox 370. Mancheser. Gr 0600 TeL (860) 645-1102 Fax (80)645-823

FOR: Att Mr. Dan Galante Draft Progress Report TFord Company August 11, 2004 118 Tenne Street Georgetown, MA 0188$

Sample Information Custody Information Date Time Matrix: SOIL Collected by- 08/10/04 0:00 Location Code: TFORD Recetved by: KJB 08/10/04 15:15 Rush Request: RUSH24HR Analyzed by: see 'By" below P.O.#: 0446 SDG I.D.: GAF77437 Laboratory Data Phoenix LD,: AP77444 Client ID: WILMINGTON WETLANDS TRC-WI.M01 Parameter Result RL Units Date Time By Reference

Silver BDL 0-5 mgfKg 08/11/04 MH 6010/1200.7 Arsent 928 1 mwfg 08/11/04 MH 6010/E200.7 4LB 0.5 ngfKg 08/11/04 MH 6010/E200.7 Cadmium 1.64 03 mg/Kg 08/11/04 MH 6010/E200.7 Chroinum 28 0.5 mwlCa 08/11/04 MH 6010/E200.7 Copper 791 5.0 mgfKg /1104 MH 601WE200.7 Meruy- Sol] BDL 0.10 mg/kg 08/11/04 RS SW-7471 Lead 123 0.5 mgKg 08/11/04 MH 010/E0Z0.7 Selenium BDL 25 mgfKg 08/11/04 MH 6010/E200.7 TCLP Copper 0.087 0.01 mg/L 08/11104 M1H E1311/SW6010 TCLP Lead 0-017 0.015 mg/L 08/11/04 MH E1311/SW6010 TCLP Zinc 1.73 0.01 mg/L 08/11/04 MH Zh 17Z 0.5 MgfKg 08/1I/04 MH 6010/E200.7 Percent Solid 16 %6 08/11/04 c/Dp E2160-3 - Conductvty 82 1.1 umbos/cmn 08/11)04 JD SM25iOB Mercry Digsdn Completed 06/11/04 DM SW7471 Soil Extraction for PCB Completed 08/1 1/04 AW 3545/3550 Sodl1ic. for Semi- Vol Comleed 08/11/04 /Ci SW3550/3545 TCLP Extraction Metals Completed 08110A4 PL EPA 1311 Total Metals Di6esr Completed 08110/04 AG SWS40 - 3050 TCLP Me*ab Dgsn Conpleed 08/1104 DM SW46 -3005 Extracdon of TPH MOD 8100 SM Completed 08/11/04 AB/ 3550/5030 Polychlorlnated Biphenyls

E P*ge 29 of 40 U01/411,XUUL* j . .. r I 4t )) J LMA-v i'Ati 04

Client ID WLMINGTON WIELANDSTRC-WILM 01 Phoenix ID.-: AF77444 Parameter Result RL Units Date Time By Reference PCB-1016 ND 400 ug/K~g 08/11/04 JH SW B082 PCB-1221 ND 400 ug/Kg 08/11/04 JH SW 8082 PCB-1232 ND 400 ug/K~g 08/11/04 JH SW 8082 PCB-1242 ND 400 08/11/04 JH SW8082 Ug/Kgug/Kg PCB-1248 ND 400 0811/D4 JRK SW 8082 ug/Kg PCB1254 ND 400 ugflg 08/11/04 JH SW 5082 PCB-1260 ND 400 ug/Kg 08/11104 JH SW 8082 PCB-122 ND 400 ug/Kg 08111/04 JH SW 8082 PCB-1268 ND 400 0811/04 JH SW80 QA/QC Surrogates %DCP (surogate Rec) 55 %6 08/11/ JH SW 808Z % TCMX (Surrevate Req a?- %8 0W/L/04 JH SW 8082

TPH by GC (Extractable Products) Fu 09#4 ND 50 08/11/04 JRB 8100Modified mg/kg Fuel Ol #6 ND 50 mg/kg 08/11104 iRB 81OModifted Fue 0*21 DIesel Fuel ND 50 08/11/04 JRB 8100Modified Kerosene ND 50 mg/kg 08/11/04 JRB 8100Modified Motor O* 50 08/i1/04 JR.B 810OModifted mg/kg Othe Oil (Cutting & Lubricating) ND 50 Mgtnv8kg 08/11/04 JRB 80ooMdtfled Urddendifed 2300 50 0811/104 JRB 810OModifted

Surrogates .QAIQC%n-Penacosanm Interference 08/1/4 JRB 8100Modified

Volatiles 1,1,1,2-Tetrachiomoethane ND 160 0/11/04 RM Sw8260 1.1 ,1-Trichlorwethane ND 160 08/11/04 RM 1,1,22Tetrachloroethane ND 160 08/11/04 SW8260SWS200 1,1,2-Trkhiiroethane ND 160 08/11/04 RM SWaz6D ug/Kg 1.1-Dichloroethane ND 160 08/11/04 RM SWs80 ug/Kg 1,1-Dkbloroethene ND 160 08/11/04 RM SW87.60 ug/K~g L,-Dwchoropropene ND 160 08/11/04 RM SW8260 u/Kg 1,2-3-Trchcobermene ND 160 08/11/04 RM SWS26O ug/Kg I ,2,3-Trhdwopropane ND 160 uglKg 08/31/04 RM SW8260 I1Z4-Trcilorobenzene ND 160 08/11/04 PM SW8260- ug/K~g 12,4-Trmethyberenee ND 10 ug/Kg 08/11/D04 SWB200 1,2-Dibrma3-hloropropone ND 160 ug/Kg 0&'/1104 RM SWB260 RM 12-Dkblorobenzene ND 160 %g/Kg8 08/11/04 RM Sw8260 1,2-Dkhloroethane ND 160 08/11/04 RM SW8260 I,2-Dkhloropropene ND 160 08/11/04 RM RM SWuaso 1.3,5-Trimethylbenzene ND 08/11/04 SW8260 160 ugfKg RM 1,3-DVhkwobenzene ND 160 08/11/04 SWS260 ND ug9/Kg

Page 30 Of 40 J.A1".1rPiL t15

ClIunt JD: WILMINGTON WETLANDS TRC-WILM 01 Phoenix La AF77444 Parameter Result RL Units Date Time By Reference

1.4-DichlorobenMe ND 160 ug/Kg 08/1104 RM SWB260 2,2-Dkcbloropropane ND 160 ug/Kg 08/1104 RM SW8260 2-Chlorotoluene ND 160 ug/Kg 08/11104 RM SW8260 4-Chlorotoluene ND 150 tg/Kg 0811/04 RM SW8260 Bemene ND 100 ug/Kg 08/11/04 RM SW8200 Bromobenzene NI) 160 ug/Kg 08/11/04 RM SW8260 BroMochbromethane ND 160 ug/Kg 08/11/04 RM SW8260 Bromodchoromethane ND 160 ug/Kg 08/11/04 RM SW8260 Bromofor ND 160 Ug/Kg 08/11/04 RM SW8260 Bromomethane ND 160 ug/Kg 08/11/04 RM SW8260 Carbon etradrWke ND 160 ug/Kg 08/11/04 RM SW8260 Chlorobemen ND 10 uAg/Kg 0811/04 RM SW260 Chlroedane ND 10 ugfKg 08/11/04 RM SWS260 Chloroform ND 160 ug/Kg 08/11/04 RM SWU260 Chloromethane ND 180 ug/Kg 08/11/04 RM SW8260 ds-12-Dichlorethene ND 160 ug/Kg 08/11/04 RM SW8260 ds-1,3-Dirboropropene ND 160 g/Kg 08/11/04 RM $W8260 Dibromochlommethan ND 160 ug/Kg 08/11/04 RM SW8260 Dihromnoethne ND 160 lg/Kg 08/11/04 RM SW8260 Dfbrmontherme ND 160 tag/Kg 08/11/04 RM SW8260 Dichlorodfluorometm ne ND 160 tg/Kg 08/11/04 RM SW8260 Ethylbenzene ND 160 ug/Kg 08/11/04 RM SW8Z2O SHeachlorobutadiene ND 10 ug/Kg 08/11104 RM SW8260 Isopropylbenzene ND 10 tg/Kg 08/11/04 RM sW820 m&p-Xylene ND 160 8g/Kg 08/11/04 PM SWa26m Methyl Ethyl Kewme ND 940 ug/Kg 08/1/04 RM SW8260 Methyl t-butyl edr (4TBE) ND 310 UMg/Kg 0811/04 RM SW8260 Medyene chlordw ND 10 uag/Kg 08/11/04 RM SWBM26 n-Butylbenze ND 160 ug/Kg 08/11/04 RM SW8260 n-Propylbenene . ND 160 ug/Kg 08/11/04 -RM SWs26o Naphtwlene ND 1&) ug/Kg 08/11/04 RM SWS26 o-Xylene ND 10 ug/Kg 08/11/04 RM SW8260 p-JopropylIoUene NJ) 160 Ug/Kg 08/11/04 FM SW8260 sec-Butylbenzeme ND 160 ug/Kg 08/11/04 RN SW8260 Styrene ND 160 ug/Kg 08/1/04 RM SW8280 text-Butylbemene ND 160 ug/Kg 08/11/04 RM SW8260 Tetrachlnroethene ND 160 ug/Kg 08/11/04 RM SWU80 Toluene ND 160 ag/Kg 08/11/04 RM SWS26Q Tot Xylens ND 160 Ug/Kg 08/11/04 RM SW3260 tWa-1,2-Dicbloroetheoe ND 160 tg/Kg 08/11104 RM SWeS0 ans-1,3-Dkhloropropene ND 160 ug/Kg 0/11/04 RM SW8260 Trkihoetene ND 160 ug/Kg 08/11/04 RM SW8260 Tricbloroftaromethae ND 160 ug/Kg 08/11/04 RM SW8260 Vinyl chloride ND 160 ag/Kg 08/11/04 RM SW8260 Page 31 sf 40 -E-.1 .~lL:f;flt- A4P r0bb tIE)f~

CUent.ID: WILMINGTON WETLANDS TRC-WILM 01 Phoenx ED.: AE77444 Parameter Result RL Units Date Time By Reference

QA/QC Surrogates % 12-dichlorobene-d4 119 %081114 RM SW826 %Broumfluurobenene 93 % 081104 RM SW826 % Dibromflueronethane 110 96 11104 RM SWSZ 96 Tpluw-d8 97 08/11/04 RM SW8260

Semivolatiles 12,4-Trtchlorbenem ND 660 ug/Kg 08/11/04 DRC SW 8270 .2-DIhlorcbe3zwe N) 660 ug/Kg 08/11/04 DRC SW8270 1.2-Diphenylhydrazne NID 660 tg/Kg 08/11/04 PRC SW8270 1,3-Dchlorobenzene ND 680 qtg/Kg 08/1104 DRC SW 8270 ,4-Dchlonrobnzene ND 660 utg/Kg OW1/04 DRC SW 8270 245-Trchlorophenol NV 660 U8/Kg 08/11/04 DRC SW 8270 2A,8-Trchrowphenol ND 580 ug/Kg 08/11/04 DRC SW8270 2,4-Dlchlrophenol - ND 660 ug/Kg U8/11/04 DRC SW 8270 2,4-DIethiphewno ND 660 uag/Kg 08/i1/04 DRC SW 8270 2A-Dinitropbenol ND 3200 utg/Kg 08/11/04 DRC SW827 2,4-DrtuAoluene ND 60 ug/Kg 08/11/04 DRC SW am 2,6-Dchborophenol ND 660 Ug/Kg 08/11/04 DRC SW8270 2.6-Dinltrotoluene NP o60 tg/Kg 08/1104 DRC SW 8270 2-Chlom naphthalene ND 660 Ug/Kg 08/11/04 DRC SW 8270 . 2-Chlorcphenol ND 660 ugKg 08/11/04 DRC SW 8270 2-Methylnaphbdane ND 660 ug/Kg 0 M/11/04 DRC SW 8270 2-Methypheno (o-creso) ND 660 ug/Kg 08/11/04 DRC SW8270 2-Nitroanine ND 3200 u/K 06/11/04 DRC SW 8270 2-Nitrophenol ND 660 ug/Kg 08/11/04 DRC SW 8270 3&4-Methylphenol (M&p-cresol) ND> 660 tg/Kg 08/11/04 DRC SW 8270 3,3-Dichorobenzidine ND 1300 ug/Kg 0811/04 DRC SW 8270 3-Nioauline ND 3200 ug/Kg 08/11/04 DRC SW 8270 4,6-Dinttro-2-methylphenol ND 3200 ag/Kg 08/11/04 DRC SW 8270 4-Bromopheayl phenyl ether ND 660 ag/Kg 08)11/04 DRC SW 8270 4-Chloro-3-nethylphenol ND 1300 ag/Kg 08/11/04 DRC SW8270 4-Chloroanglne ND 1300 ug/Kg 08/11/04 DRC SW8270 4-Chlorohen phenyl ether ND 660 ug/Kg 08/11/04 DRC SW 8270 4-Nitronlie ND 3200 ug/Kg 08/11/04 DRC SW 8270 4-Nitrophenol ND 3200 Ug/Kg 08/11/04 DRC SW 8270 Acenaphthen- NJ) 660 Ug/Kg 08/11/04 DRC SW 8270 Ateoaphtyene ND 060 ag/Kg 0811/04 DRC SW 8270 - Anthrac ND 060 ag/Kg 08/11/04 DRC SW ?TO Bena)andacene ND 660 ug/Kg 08/11/04 DRC SW 8270 Benzidine ND 660 ug/Kg 0wi1/01 DRC SW 8270 Denzo(a)pyrene ND 660 ug/Kg 08/11/04 DRC SW8270 Benzo(b)fluornthee ND 60 ug/Kg 08/11/04 DRC SW 8270

Page 3Z of 40 ~MbL ti!

ClientID: WILMINGTON WETLANDS TRC-WILM 01 Phoenix LD.: AF77444 Parameter Result RL Units Date Time By Reference

Benzo*perylee ND 860 ug/Kg 08/11/04 DRC SW8270 Benzo uoranthene ND 660 ug/g 08/11/04 DRC SW 8270 Benzoc add ND 3200 g/Kg 08/11/04 - DRC SW6270 Benzyl alcohol ND 1300 ug/Kg 08/11/04 DRC SW 8270 Bnzylbyl phthalate ND 660 ug/Kg 08/11/04 DRC SW8270 Bjs(2-chlorothoxy)methane NP 660 ug/g 08K 11V04 DRC SW8270 Bis(2-chloroethleter ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(2-choriopWD py)ether ND 660 Vg/Kg 08/11/04 DRC SW 8270 Bis(2-ety"yphthalate ND 560 Ug/Kg 08/11/04 DRC SW 8270 Chysene ND 660 tg/Kg 08/11/04 DRC SW 8270 D1-n-bty1hthaate ND 660 vgKg 08/111/04 DRC SW 8270 Dl-n-octylphthalate ND 6w ug/g 08/11/0 DRC SW8270 Diben(a,h)anthracene ND 660 ag/Kg 08/11/04 DRC SW8270 Dibenmfurmn ND 660 g/Kg 08/11/04 DRC SW8270 DIethl pbthulate NJ) 660 ug/Kg 08/11/04 DRC SW 8270 DinethyphWhlate ND 00 ug/Kg 08/11/04 DRC SW 8270 Fluorantene ND 660 Ug/Kg 08/11/04 DRC SW8270 Fluorene ND 660 ug/Kg 08/11/04 DRC SW 8270 ND 660 ug/Kg 08/11/04 DRC SW 8270 Haachlorobutadene ND 660 ug/Kg 08/11/04 PRC SW 8270 Hexachlorocydopentadiene N) 60 tg/Kg 08/11/04 DRC SW 8270 Hexcooethane ND 660 ug/Kg 08/11/04 DRC SW 8270 DRC SW8270 V Inden(1.2,3-a1pyren ND 660 ug/Kg 08/11/04 bsophrone ND 660 ug/Kg 08/1 /04 DRC SW 8270 N-Ntnnsodn-nppyamne ND 660 ag/Kg 08/11/04 DRC SW8270 N-N-os h m ND 660 ag/Kg wi1/04 DRC SW 8270 N-Nftrosodiphenymnke ND 660 ug/Kg 08/11/04 DRC SW 8270 Naphbhalene ND 660 ug/Kg 08/11/04 DRC SW 8270 Nltrobenzem ND 660 tag/Kg 08/11/04 DRC SW 8270 Pentachloropbenol ND 660 ug/Kg 08/11/04 DRC SW8270 Phenanthrene ND 660 Ug/Kg 08/11/04 DRC SW 8Z70 Phenol ND 60 ug/Kg 08/11/04 DRC SW 8270 Pyrene ND 660 ug/Kg 08/11/04 DRC SW8270 Pyrkiine ND 660 ug/Kg 08/11/04 PRC SW 8270 QA/QC Surrogates %2,4.6-Tribromophenol 87 %6 08/11/04 DRC SW 8270 % 2-Fbaobiphenyl 67. % 08/11/04 DRC SW 8270 %2-Flturophenol 54 % 08/11/04 DRC SW 8270 %Nitrobenzene-d5 54 % 08/1104 DRC SW 8270 . %Phenol-d5 59 %6 08/11/04 DRC SW 8270 %Terphenyl-d14 43 % 08/11/04 DRC SW8270

Page 33 of 40 MW m zoItZJ4 10:04 ir1 r or r oo r ow PAGE E)9

Environmental Laboratories, Inc. 587 East Middk Tumpik, P.OBox 370, Manchester, a 08040 TeL (WO0)M4l11Z Fax (860) 645-0823

Draft Progress Report FOR Atn: Mr. Dan Calante August 11, 2004 118 Tenne Street Georgetown, MA 01833

Sample Information Custody Information Date Time Matrix: . SOIL Collected by: 08/10104 0:00 Location Code: TFORD Received by- KJB 08/10/04 15:15 Rush Request: RUSH24HR Analyzed by: see "By"below P.O.#: 0446 SDC LD.: CAF77437 Laboratory Data Phoenix LW AF7445m Client ID: WILMINGTON WETLANDS TRC-WIvM 01A Parameter Result RL Units Date Time By Reference

Silver 0.892 0.5 mgfKg 08/11/04 MH 6010/E20.7 4.59 08/11/04 Mi 6010/E200.7 ArserWd 37 0.5 m/Kg 08/11/04 MH 6010/E20.7 Cadadum 3.72 0.5 Dmg/Kg 08/11/04 MH 60101E200.7 Chromkim .24.8 0.5 ng/Kg 8/11104 MH 6010/9200.7 Copper- 1070 5.0 mgKg 08112/04 MR 60101E200.7 Mercury - Soil BDL 0.10 ug/kg 08a104 RS SW.7471 Lead 190 O's mgKg 0/11104 MR 6010/E200.7 Selenium BDL 2.5 mDKg 08/I1104 MH TCLPCopper 0.188 0.01 mgIL 08/11/04 UK E1311/SWB0lo TCLP Lmad 0.034 O015 mgIL 08/11/04 MHR E1311/SW610 TCLP Zic L6 0.01 mg/L 08/11/04 MH E1311/W6010 470 0.5 mrgKg 0811/04 MH 6010/E20.7 Percent Solid 15 08/11104 CD E160.3 Conducdvty 120 1.0 umhodcm 08/U4 JD SM2510B mercury D*gStion Completed 08/11/04 DM SW7471 Soil Extraction for PCB Comp-etd W)/1/04 AB/ 354s/3550 Soil Ext. for Sent- Vol Completed 08/1104 E/C SW3550/3545 TCLP Extracdon Metals Completed 08/10/4 PL EPA 1311 Total Metals Digest Completed 08/10/04 AG SW846 - 3050 TCLP Meras Dgesom Completed 08/11/04 DM SW846 - 3005 ETroaction of TPH MOD 8100 SM Completed 08111104 AB/ 3550/5030 Polychlorinated Biphenyls I Page 35 of 40 Ubi mlf 2 t itg1: LUAM PAGE 18

Client 1D: WILMINGTON WETLANDS TRC-WILM 01A Phoenix 1,D-: AF7445 Parameter Result RL Units Date Time By Reference

PCB-1016 ND 400 ug/Kg 08/11/04 JH SW 8082 PCB-Z2I ND 400 ug/Kg 08/11/04 JH SW8082 PCB-1232 ND 400 ug/Kg 08/11/04 JH SW 808Z PCB-1242 ND 400 ugIKg 08/11/04 JH SW 8082 PCB 1248 ND 400 ug/Kg 0W11/04 Jl SW 8082 PCB-1254 ND 400 ug/Kg 08/11/04 JH SW 8082 PC1260 ND 400 ug/Kg 0811/04 JH SW 8082 PC3-125 ND 400 ug/Kg 0811/04 JH SW 8082 PCB-1268 ND 400 UVgKg 08/11/04 JH SW 8082 QA/QC Suraogates % DCBP (SUogate Rec) 52 %6- 08/111/04 JH SW 3082 % TCMX (Srrgate Rec) 78 08/11/04 JM SW 808

TPH by CC (Extractable Products) Fue10i #4 ND 50 mg/kg 08/1 1/06 JRB 810OOModifted Puel Oil #6 ND 50 mgkg 08/11/04 JRB 81OMcdified Fuel 011#2 / Diesel Fuel ND 50 mg/kg 08/11/04 JRB 8100Modifned Kerosene ND 50 08/11/04 JRB 8100Madined Motor Oil MR 50 mg/kgm3/kg 0811/04 JRB 8100Modified Other oil (Cutting & Lubricating) ND 50 0811/ JRE 810lModified Undenbfed 2200 50 mg/kg 08/1/ M JRB S1OOModified w AJQC Sunrgates % n-Pentacnsane Interference '6 08/11/04 JRB 8100Modified

Volatiles 1,1,1,2-Tetrachloroethane ND 170 08/1104 RM sw8280 1,1,1-Trichloretbane - ND 170 08/11/04 RM SW8260 .12.2-Tetachloroethane ND 170 RM SWW260 08/11/04 1,1,2-TchloroethAm . ND 170 VgKg RM SW8260 1,1-Dchlroethane ND 170 08/11/04 RM 1.1-Dichoroethene ND 170 08 /1/04 RM 1,1.DichlAroprpem ND 370 08/11/04 RM SW8260 4ft 1, 3-Trichlorobenzene ND 170 08/11/04 RM SW8260 123-Trichloroprpmne ND 170 /Kg 08/111/04 RM SW8280 12,4-Trichlorobenzene NP 170 RM 08/11104 SW8260 1 4-'hnethylbemenew ND 170 0811/04 RM SW8260swsme 1,2-DIbromo-3-chloropramne ND 170 ug/Kg 08/1 1/04 RM 1,2-Dichlorobemene ND 170 W/Kg 08/11/04 RM SW8260 SW8260 1,2-Dchoroetane NV 170 ON11/04 RM SW8260 1,2-DkWvpropane ND 170 08/1104 RM sw8260 1A3S-Trrnethylbemne ND 170 08/11/04 RM wAfg SWBZ6OSW8260 1,3Dichlorobenzne NPD 170 ug/Kg 08/104 RM ND 170 JiM swazeo Pa 36 of 40 Vom111zoo0 10;Z4 ItOzIL (3)IOL& jkwm PAGE 11

Client ID: WILMINGTON WETLANDS TRC-WILM 01A Phoenix LD.: AF77445 Parameter Result RL Units Date Time By Reference O4-Dichlorobenene ND 170 ug/Kg 08/11/04 RM SW826O U2-Dichloropropane ND 170 ug/Kg 08/11/04 RM SW8260 Z-Cblrutoluene ND 170 ug/Kg 08/11/04 RM SWB260 4-ChJirtoltWne ND 170 ug/Kg 08/11/04 PM SW8260 Beene ND 170 ug/Kg 08/11/04 RM SWS260 Bromobenzene ND 170 ug/Kg 08/11/04 RM SW8260 Bromochloromethane ND 170 ug/Kg 08/i/04 RM SW8260 Bromdkhloromthan ND 170 ug/Kg 08/11104 RM SWB260 Bromofonn ND 170 ug/Kg 08/11/04 RM SWSZ26 Bromomethane ND 170 ug/Kg 08/11/04 RM SW8280 Carbonteuhiodde ND 170 08/11104 RM SW8260 Chlorobentee ND 170 08/11/04 RM SW8260 ug/Kg Chloroethane ND 170 08/I1/04 RM SW8260 Chloroform ND 170 ug/Kg 08/11/04 RM SW8260 Chlommethane ND 170 ug/Kg 08/11/04 RM SWR260 cis-I,2-Dkhloroethene ND 170 08/11/04 RM SWS260 ug/Kg cs.3-Dichloropropene ND 170 08/111/04 RM SW8260 ug/Kg Dibromochloromedhane ND 170 08/11104 RM SW8260 ug/Kg Dibromoethane ND 170 08/11/04 RM SW82W0 ug/K~g Dibromomethane ND 170 08/11/04 RM SW8260 ug/Kg Dichlorodifluoromethane ND 170 08/11/04 RM SW8260 ND 170 08/11/04 RM SWB80 ND 170 ug/Kg 08/11/04 RM SW8260 Isoprpybenzene ND 170 08/111/04 RM SW86 vg/Kg m&p-Xylene ND 170 ug/Kg o8/11/04 RM SW8260 Methyl Ethy Ketone ND 1000 ug/K~g 08/11/04 RM SWS260 Meth t-butyl ether (MIE) ND 330 ug/Kg 08/11/04 RM SW82S0 Mechylene chloride ND 170 08/11/04 RM SWS260 n-Butylbenzene ND 170 ugflg 08/11/04 RM SWSZ26 n-Propylbenzne ND 170 ug/Kg 08/11/04 RM SWH260 Naphthalene ND 170 08/11/04 RM SWS200 o-Xylene ND 17) uig/Kg 08/11/04 RM SW8260 p-sopropyltoluene ND 17U ug/Kg 08/11104 RM SWB260 sec-Butylbeene ND 170 ugKg 08/11/04 RM SW8260 Styre ND 170 ug/K~g 08/11/04 RM SW80 vert-Buwylbezene ND 170 ug/K~g 08/11/04 RM SWS260 Tetrachloroerhene ND 170 - 08/11104 RM SW8260 ug/K~g Toluene ND 170 08/11/04 RM SW8260 ug/Kg Total Xylenes ND 170 08/11/04 RM SW6o0 u/Kg trans1,2-Dichoroetbene ND 170 u/Kg uans-L3-Dlchrropene ND 170 08/11/04 RM SWSZ60 ug/Kg Trhldoroethene 170 08/11104 RM SW8260 ug/Kg Triclorofluormethane ND 170 08/1104 RM SWS260 * illchiloride ND 170 0W/11/04 RM SW8260

Page 37 of 40 lti(itZ013 iu: q itsiuztranq [JDAM PAGE 12

ClientID: WILMINGTON WETLANDS TRC-WILM 01A Phoenix LD.: AF77445 Parameter Result RL Units Date Time By Reference QA/QC Surrogates % 1,2-chlorobenzene-d4 119 08/11/04 RM %6 SW8260 %7 08/11U04 RM Broofluorobenzene %6 SWa260 %DIbromofhuoromethane 109 08/11/04 RM %6 SW260 %TOlueze-dS 98 08/11/04 RM SW8260

Semivolatiles 1,2A-Trichlorobenzene ND 660 ug/Kg 08/11/04 DRC SW8270 12-Dihlorobenene NID o60 ug/Kg owl 1/04 DRC SW 8270 1,2-Uphenyly*atine ND 660 ug/Kg 08/11/04 DRC SW 8270 13-Dicblorobenmne ND 660 ug/g 08/11/04 DRC SW 8270 i,4-Dhlorobenzene ND 66D 08/1w1/04 DRC SW 8270 5w ug/Kg 2,4,5-Tdlchlrpheno1l ND 660 pgfKg 08/11/04 DRC SW 8270 2,4,6-TdlchloropbenoI ND 660 vg/Kg 08/11/04 DRC SW 8270 2,4-Diclorphelol ND 660 ug/Kg 0811/04 DRC SW8270- 2A-Dirnethylphenol ND 660 ug/Kg 08/11/04 DRC SW 8270 2.4-Ditrophenol ND 3200 ug/Kg 08/11/04 DRC SW 8270 2,4-Dintrotoluene NP 660 ugfl~g 08/11/04 DRC SW 8270 2.6-Diebloophnol1 ND 60 ug/Kg 08/11/04 DRC SW 8270 2.6Dnirotoluene ND 660 08/11/04 DRC SW8270 ug/Kg 2-Choonaphthle~ne ND 660 08/10 DRC SW 8270 ug/Kg ND 660 06/11/04 DRC SW 8270 ug/K~g . 2-Medylnaphthalene2-WCorphenl ND 660 08/11/04 DRC SW 8270 2-Mebyiphenol (o-cresoD) ND 660 ug/Kg 05/11/04 DRC SW 8270 2-Nitranwtne ND 3200 08/11/04 DRC SW 8270 ug/Kg 2-Nltropenol ND 60 08/1104 DRC SW 8270 ug/Kg 3&4-Metbylphenol (m&p-caeso) ND 0 kl 1/04 DRC SW8270 "g/Kg 3,5-Dkorobenzidine ND 1300- 08/1104 DRC SW 8270 ug/Kg 3-Nitroannin ND 3200 ug/Kg 08/11/04 DRC SW 8270 ug/Kg 4,6-Dntro-2-methylphen ND 3200 08/11/04 DRC SW8270 ug/Kg 4-Brawophenylphenyl ether ND 660 08/11/04 DRC SW8270 ug/Kg 4thloro-3-methypbennl ND 1300 08/11/04 DRC SW $270 u&/Kgug/Kg -447Chloroandlirne ND 1300 08/11/04 DRC SW 8270 ug/~g 4-CNdrpheny phenyl ether ND 660 08/11/04 DRC SW 8270 u8/Kg 4-Nitroanlline ND 3200 08/11/04 DRC SW 8270 ug/Kg 4-Nrophenol ND 3200 08/11/04 DRC SW 8270 ug/Kg Acenphthenw ND 60 06/11/O4 DRC SW8270 ug/Kg Atenaphthylene ND 660 ug/Kg 08/11/4 DRC SW 8270 Anthramne ND 660 08/11/04 DRC SW 270 ug/Kg Bez(a)aruhracene ND 860 ug/Kg 08/11/04 DRC SW8270 Benzkne ND 660 08/11/04 DRC SW 8270 Benzo(a)pyrene ND 08/1/04 DRC SW8270 o00660 Beno(b)flwranthene ND 08/11/D DRC SW 8270

PePe 38 of 40 tn±11aZt'Q it3 : / Z1 b~i/bI4 DCAM PAGE 13

,Client:ID: WILMINGTON WETLANDS TRC-WILM 01A Phoenix LD.: AF77445 Parameter Result RL Units Date Time By Reference Bern(ghoperyne ND 660 ag/Kg 08/11/04 DRC SW 8270 Berzo=k)fluoranthene ND 660 ug/Kg 08/11104 DRC SW 8?70 Benot add ND 3200 ug/K~g 08/11104 DRC SW8270 Berylaimhol ND 1300 ug/Kg 08/11/04 DRC SW 8270 phthalate ND 660 08/11/04 DRC SW 8270 Benzyl buty ug/Kg Bis(Z-hloroexffy)methawe ND 680 08/1 1104 DRC SW 8270 ug/Kg Bis(2-dhlroedhyIether ND 660 08/11/04 DRC SW 8370 ug/Kg Bis(2-chlobopropyl ether ND 660 08/11/04 DRC SW8270 ug/Kg ND 660 08/11/04 DRC SW8270 Bis(2-ehybeayphthuate ag/Kg ND 60 08/11/04 DRC SW 8270 Chrysene ug/Kg DlI-n-buxtylphthalate ND 660 08/11/04 DRC SW 8270. ug/Kg ND 660 03/1 V4 DRC SW8270 Di-notyphtalare ag/Kg D9enz(a.b)nhracene ND G0 08/11/04 DRC SW 8270 vgfigag/Kg Dibenmfn - ND 660 08111/04 DRC SW82ao ug/Kg Diethyl phtulate ND 660 08/11/04 DRC SW 8270 u8/Kg ND 660 08/11/04 DRC SW8270 ug/Kg ND 6w 08/11/04 DRC SW 8270 1%oranthene u8/Kg Flurene ND 660 08/11/04 DRC SW 8270 Hexachlorbenzene ND 660 wig/Kg 08/11104 DRC SW8270 Hexachorobutadiene ND 6w 08111/04 DRC SW8270 ug/Kg ND 660 0811/04 DRC SW 8270 HexcItarocydcopentdiene ag/Kg Hexacloroethane . ND 660 08/11/04 DRC SW8270 ug/Kg (nx1,2,3-c<0pyrene ND 660 08/1/04 DRC SW 8270 ag/K; 08/11/04 Xsophoone, ND 60 DRC SW 8270 N-Nltrosadi-n-prpylamine ND 660 ag/Kg 08/11/04 DRC SW8270 N-Nrrsodimethylamine ND 660 ag/Kg 08/11/04 DRC SW8270 N-N1trosodiphenylWine ND 880 tug/Kg 08/11/04 DRC SW 8270 Naphthalene ND 660 ug/K~g 08/11/04 DRC SWs70 Nitrbenzene ND 660 ag/Kg 08/11/04 DRC SW8270 Pentachlorophenoo ND 660 ug/Kg 08/11/04 DRC SW 8270 Pheathrener ND 660 ag/Kg 08/11/04 DRC SW B270 Phenol NDO 660 ug/Kg 08/11/04 DRC SW8270 ug/Kg 08/11/04 Pyre ND 660 DRC SW8270 Pyrwine ND 60 ug/Kg 08/11/04 DRC SW 8270 QA/QC Surrogates %2,46-Trbromophenl 85 %6 08/11/04 DRC SW 8270 % 2-Fluorcbtphenyl 85 %6 08/11/04 DRC SW8270 % 2-F rphenol 54 %6 08/11/04 DRC SW 8270 % Nitrobenzmene-d5 50 %6 08/11/04 DRC SW 827Q %Phenol-d5 62 %6 08/11/04 DRC SW8270 96 Terphenyl414 62 %6 08/11/04 DRC SW 8270

Pago 39 of 40 1 Cut w I zI00 o 1; os ziwfluz3jnq LuM PAGEPAE 14

Cominents: ND-Not detected BDL - Below Detection Limit RL=Reporting Limit "Pcleumbydrocarbon chrmngram wntwapufct mvatchwith nr he standmrd, but most dos*ey-m-=*mmr alL *I Elevated md' en Owaw mauxinterfruv. If there are any questions regarding this data, please call Phoenix Client Services at extension 200. PLEASE NOTE: THIS PROGRESS REPORT IS CONSIDERED PRELIMINARY DATA. THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

Page 40 of 40 Site History

Wetlands Remediation Former GE Facility 50 Fordhan Road, Wilmington, MA

September 2004

A synopsis of earlier investigations involving the collection of samples within the wetland area is presented below. This synopsis is focused on metal contamination, as these contaminants are the focal point of the Stage I1ERC that was conducted within the wetland.

A Phase II Report was prepared by Goldberg-Zoino & Associates, Inc. (GZA) and submitted to MADEP in April 1990. As part of this Phase II investigation, one sediment sample each was collected from Outfalls 001 and 002 and analyzed for volatile organic compounds. (VOCs) and semi-volatile organic compounds (SVOCs). In general, low levels of VOCs and several phthalates were detected in the two sediment samples. However, no sediment or surface soil samples were collected from the adjacent wetlands and analyzed for metals. As part of this Phase H report, an Ecological Risk Characterization of the wetlands described the habitats present and potential ecological receptors that may inhabit the wetland cover types. Although significant risks to ecological receptors were not anticipated, additional sediment sampling of petroleum- related compounds was recommended to evaluate the risk posed by these contaminants (GZA, 1990).

A Phase IESupplemental Investigation was conducted by Wehran Engineering Corporation (Wehran) in November 1991. Five sediment samples (WL-1 through WL-5) were collected from the wetland near the edge of the paved parking area and downgradient of Outfall 001 at a depth of 0 to 2 feet and analyzed for VOCs, SVOCs and priority pollutant metals (Wehran, 1991). VOCs were detected at low levels while several petroleum-related contaminants were detected at elevated concentrations at sample location WL-5. In addition, several metals were detected above ecological screening benchmarks (discussed in Section 2 of this ERC) associated with adverse effects to macrobenthic invertebrates and/or plants. These metals included arsenic, cadmium, copper, lead, nickel and zinc.

In December 1991, a Public Health and Ecological Risk Characterization Report was submitted to MADEP to supplement the Phase II Investigation (ADL, 1991). This report used the previous sediment/soil sampling results and four additional sediment/surface soil samples (WL-6 through WL-9) collected from the wetland located east of Outfalls 001 and 002. These additional samples were collected in November 1991 by Wehran and analyzed for various constituents including priority pollutant metals. All four of these samples were collected further east of samples WL-1 through WL-5. Sample WL-S appears to have been located within an area of upland fill (Udorthents, wet substratum), whereas sample locations WL-6, WL-7, and WL-9 were within the Freetown muck soil type (Wehran, 1992). The Ecological Risk Characterization concluded that contaminants were not significantly impacting the wetlands (as represented by samples WL-6 through WL-9). Although the wetlands area immediately adjacent to the parking lot (referred to as the "drainage ditch" in the report and represented by samples WL-1 through WL-5) contained elevated levels of metals that may affect some plants, microbes and invertebrate species in this area, the low levels (as detected in WL-6 through WL-9) were not expected to pose a significant risk to the larger wetland complex adjacent to the Site.

A Second Supplemental Phase II Investigation was submitted to MADEP in December 1992 (Wehran, 1992). Although nine additional sediment/surface soil samples were collected within the wetland in the vicinity of Outfall 001, these samples were analyzed for total petroleum hydrocarbons (TPH) only.

In October 1993, a Phase III Remedial Action Plan (RAP) was submitted to MADEP that recommended excavating and disposing of contaminated sediments (with elevated TPH levels) in the vicinity of Outfall 001 and Outfall 002. In November 1995, MADEP conditionally approved the sediment remediation activities near these outfalls until contaminants of concern approached background levels (if feasible).

In 1996, EMCON (formerly Wehran) conducted additional sediment sampling to update and more accurately delineate the extent of sediments in the vicinity of Outfalls 001 and 002 prior to initiating remediation activities. A total of 12 sediment/surface soil samples were collected adjacent and downgradient of Outfall 001 while 3 samples were collected near Outfall 002. TPH concentrations were noted to have decreased from the December 1992 sampling results although metals remained at elevated concentrations.

A qualitative ecological risk characterization was conducted as part of the 1996 study that involved: 1) the sampling of macroinvertebrates, and 2) a comparison of "impacted" sediment areas that may impact vertebrate indicator species to the total population of these indicator species that may inhabit the large wetland complex. Concentrations of several metals (notably copper and lead) were significantly elevated over sediment screening benchmarks. Copper was detected at concentrations ranging from 9 mg/kg to 1,800 mg/kg, while lead concentrations ranged from 21 mg/kg to 250 mg/kg. In addition, zinc was detected above its screening benchmark, with concentrations ranging from 25 mg/kg to 180 mg/kg. The results of this study were submitted to MADEP in January 1998 in a letter report that concluded that a condition of No Significant Risk existed at the outfalls (EMCON, 1998). This conclusion was based on similarities between macroinvertebrate communities near the outfalls and within two "reference" locations. In addition, the area of impacted wetland comprised a small proportion of the total wetlands area; therefore, potential vertebrate receptors were unlikely to experience a significant reduction in their local subpopulations (defined as less than 20 percent decrease).

In December 1998, MADEP issued a written response to the qualitative ecological risk assessment requiring that either a quantitative Stage II Environmental Risk Characterization be conducted or that sediment remediation be undertaken (MADEP, 1998). A letter was submitted to MADEP in February 1999 by Lockheed Martin Corporation indicating that a Stage U Environmental Risk Characterization would be conducted: The letter also requested clarification regarding the scope of the investigation. In November 2001, MADEP replied that TRC could either proceed with remediating the sediments as previously approved, or conduct a Stage II Environmental Risk Characterization on the wetlands to address metal contaminants detected within previous sampling events. MADEP concluded that concentrations of TPH detected in the sediment samples are attributable to "normal" discharges of stormwater runoff and no further action was required for these constituents.

A compilation of the data collected to date is provided in TRC's Scope of Work- Stage H Environmental Risk Characterization (January 2002). The Stage 11 Environmental Risk Characterization concluded that there was some risk to ecological receptors. However, the wetland soils and sediments do not pose an unacceptable risk to human receptors.

Analytical data, including the pre-characterization data collected in August 2004, indicate concentrations of metals are below MCP reportable concentrations. Therefore, a Bill of Lading is not required and a Material Shipping Record will be used to track shipping of excavated wetland soils from the site to the disposal facility. APPEND[X F

Lab Reports- IEmported Backfdl

L2014-456 88/11/2004 19:49 19782759754 DCAM PAGE 01

T FORD COM PANY INC

DATE: August 12, 2004

TO: Greg Mischei

COMPANY: TRC

FAX #: 978-453-1995

FROM Dan Ganw

Number of pages including cover:, 17

COMMEZNTS:

Gre&

Attached is the additional analytical for the off-site wetland bacKdill to be used at the Wihmington te. The results previously sent for appoval wee for 0-100 cubic yards and these four sets ofresults are for 100-200, 200-300, 300-400, and 400-500 cubic yads. Please review and let me knw if you have any counnts. The rults look prety gd to me aco the boa& We are temaTivdly shedhhng to receive these materials on-site early next week if accepable to TRC.

Thanks,

Dan

* * * 118 TENNEY STREET - GBORGETOWN MA 01533 - 978-352-S606 - FAX 978-352-7943 * * 08/11/2004 19: 49 19782759754 DCAM PAGE 02

A ~ S V

.4-J pmMuft 'K Environmental Laboratories. Inc. 587 East Middh Tunipk P-.Bw 370, Mnchaster, C 08040 IttL WO6 545-1102 Fog OW0 645-082

Attn: Mr. Dan Galante Draft Progress Report FOR T Ford Company August 11, 2004 118 Tenne Street Georgetown, MA 01833

Sample Information Custody Information Date Time Matrix: SOIL Collected by: 08/10/04 0:00 Location Code: TFORD Received by: KJB 08/10/04 15:15 Rush.Request: RUSH24HR Analyzed by: see "By" below P.O.#: 0446 SDG LD.: CAF77437 Laboratory Data Phoenix LD.: AF77437 Client 10: WILMINGTON WETLANDS A MARBLE-02A Parameter Result RL Units Date Time By Reference

3.25 1 mgfKg 08/11/04 MH 6010/200.7 Cadidum BDL 0.5 mg/Kg 08/11/04 MH 60101E200.7 copper 39,2 0.i gKg 08/11/04 6010/E200.7 Nickel 14.4 0.5 mg/Kg 08/11/04 MH 6010/E200.7 'Lead 78.6 / 0.5 mg/Kg 0811/104 MH 6010E2007 Antimony BDL 5 ng/Kg 08/11/04 MH 6010/E200.7 Selenium BDL 2.5 mg/Kg 08/1/04 MH 6010/E200.7 Zinc 9.3 V/ 0-5 mopKg 08/11/04 MM 6010/E2003 Percent Solid 75 0/11/04 C/D E160-3 p1H 7-77 0.10 pH Units 08/10/04 23:00 CD E150.1/SW9045 Soil Extraction for Herbidide Completed 08/10/04 H/R 8151 Sofl Pxt. for Pestfdde Conpleted 08/11/04 AS/ 3545/3550 Sol Ext, for Semi- Vol Completed 0811/04 AB/ SW355/345 Total Metals Digest Completed 08/10V04 AG SW846 -3050 Chlorinated Herbicides 2.4.5-T ND 20 ug/Kg 0811/04 KCA SW8151A 2.4.5-TP (ilvex) ND 20 ug/Kg 08111/04 KCA SW8151A 2,4-D ND 300 ug/Kg 08/11/04 KCA SWB151A 2,4-DB ND 100 ug/Kg 08/11/04 KCA SW8151A Delspon ND 500 ug/Kg 08/111/04 KCA SW8151A Dkmnba ND 30 ug/Kg 08/11/04 KCA SWS151A Dichloroprp NP 100 ug/Kg 08/11/04 KCA SW8ISIA . Dinoseb ND 10 ug/Kg 08/11/04 KCA SW8151A

Pago I Of 40 C pp~~4 kt~ Y{ I(IDa 0,57uL1 Nfr /000 08/11/2004 19: 49 19782759754 DCAM PAGE 03

Client 11: WILMINGTON WETLANDS A MARBLE-02A Phoenix L.D: AF77437 Parameter Result RL Units Date Time By Reference

QA/QC Strmgates % DCAA (Surrogate Rec) 67 % 08/11/04 KCA SW8151A

Pesticides - Soil 4A'-DDD ND 32 08/11/04 KCA SW8081 ug/K~g 4,4'-DDE ND 32 08/11/04 KCA SWesi8 ug/Kg NP -3? -08/11/04 KCA SW808I uigfg a-BHC ND 18 08/11/04 KCA Swa0m Alddn ND 16 ugixg 08/11/04 KCA SW808 1 b-BHC ND 16 ug/Kg 08/11/04 KCA ug/Kg Chlordane 160./ 66 08/11/04 KCA ug/Kg d-BHC ND 16 08/11/04 KCA SW8081 ug/Kg Pleidrin ND 7.0 08/11/04 KCA SW8081 Wymi Endosulfan I ND 16 ug/K~g 08/11/04 KCA SW808 EndosultanIU ND 32 p8/Kg 08/1104 KCA SWI8081 Endosulfansulfate ND 32 ug/Kg 08/1/04 KCA SW8081 Endfrin ND 32 ug/Kg 08/11/04 KCA Enddn aldehyde ND 32 ug/Kgug/Kg 08/11/04 KCA swa081 g-RHC ND 16 ug/Kg 08/11/04 KCA SW8081 SW$08 Hepshlor ND 13 ug/Kgug/K~g0gftg 08/11/04 KCA sw800 He :unr epcxiq ND is 98/W/04 KCA Methoxychlor ND' 160 08/11/04 KCA SW8081 Toxaphene ND 160 08/11/04 KCA SW8081 QA/QC Surrogates *%DCBP (Sutrroga Rec) 67 4% 08/11/04 KCA SW8081 % TCMX (Surrogate Rec) 79 % 08/11/04 KCA SWB808

Semivolatiles ,24-Trkhlorobenzene ND w Ug/Kg 08/11/04 DRC SW 8270 1,2-Dkhkobenzne ND 660 08/1 1/04 DRC SW 8270 1,2-DipheyHUydrane ND .6w ug/Kg 01/11/04 DRC SW 8270 ug/Kg L3.Dkhlorobenze ND 660 Ug/Kg 08/11/04 DRC SW 8270 1,4-ichlorobenzene ND 60 ug/K~g 08/11/04 DRC SW 8270 24S-Trichlorophenol ND 660 ug/Kg 08/11/04 DRC SW8270 24,6-Trchloropbenol ND o60 pg/Kg 08/11/04 PRC SW 8270 2,4-DtchlorophenWo ND 660 ug/Kg DRC SW 8270 .08/11/04 2A-Dimethylphenol ND 660 ug/Kg DRC SW 8270 08/11/04 24.Dnitrpherol ND 3200 uag/Kg DRC SW 8270 08/11/04 24-Dinitroroluene ND 660 pg/Kg DRC SW 8270 08/11/04 2,6-DichloWbpheol ND 660 uag/Kg 08/11/04 DRC SW 8270 Z,6-Dnitrotoinenp ND G0 ug/Kg 08/11/04 DRC SW 8270 ND 660 08/11104 DRC SW8270 O2-Chlorophenol2.Chlornaphthtrene ND 660 uag/Kg 08/11/04 DRC SW 8270 Far 2I Qf 40 08/11/2004 19:49 19782759754 DCAM PAGE 04

Client ID: WILMINGTON WETLANDS A MARBLE-02A Phoenix I.D.: AF77437 Parameter Result RL Units Date Time By Reference W 2-Methyinaphthalene ND 660 Ug/Kg 08/11/04 DRC SW 8270 2-Methylphenol (o-creso) ND 660 08/11/04 DRC SW 8270 ug/Kg 2-Nitroantne ND 3200 OV11104 DRC SW 8270 2-Nitrophenol ND 660 ug/Kg 06/11/0 DRC SW8270 ug/Kg 3&4-Merhylphenol (u&p crosol ND 860 08/11/04 DR)1C SW 8270 ug/~g 3,3'-Didlorbenzdie ND 1300 08/1 1/04 DRC SW 8270 ug/K~g 3-Nitroaniline ND 3200 D0/11/04 DRC SW 8270 ug/Kg 4,6-Dntro-2-methypenol ND 3200 0811/04 DRC SW 8270 ug/Kg 4.Bronnpbey phenyl ether ND 660 08/11/04 DRC SW 8270 ug/Kg 4-Chloro-3-methylphenol ND 1300 08/11/04 DRC SW870 ug/K~g 4-Chloroanrne - ND 1300 08/11/04 DRC SW 8270 ug/Kg 4-Chlorophenyl phenyl ether ND 660 08/11/04 DRC SW 8270 ug/K~g 4-Nitroanine - NDY 3200 01 1/04 DRC SW 6270 4-Nitraphenal ND 3200 ugfcg 0/11/04 DRC SW8270 Acenmphthene ND 860 ug/Kg 08/11/04 DRC SW 8270 Acenaphthyiene ND 660 08/11/04 DRC SW 8270 ugKg Anthracene ND 60 UWKS owz 104 DRC SW 8270 Benz4a)antlkecene ND 660 08/11/04 DRC SW8270 Benidine ND 660 0/11/04 DRC SW 8270 ug/Kg Bem(a)pyrene ND) 560 08/11/04 DRC SW 8270 ug/Kg Benzo(b)fluranrmene ND 660 08/11/04 DRC SW 8?70 ug/Kg Bemo(ghi)perylene ND 660 08/11/04 DRC SW 8270 usg/Kg Demzo0k)Duranthee ND 60 0911DeV DRC SW 8210 ug/Kg Bemoic add ND 3200 08/11/04 DRC SW8270 ug/Kg BeMylalcohol ND 1300 UVgO1 08/11/04 DRC SW8270 ug/Rg Benzyl btyl phthalate ND 60 0811/104 DRC SW8270 ugftgug/Kg Bis(2-chloroethexy)nethane ND 660 0/11/04 DRC SW 8270 ug/Kg Bis(2.chloruthypethr ND 660 08/11/0 DRC SW 8270 ug/K~g Bis(Z-chloroisoprOpy)ether ND 660 0/11/04 DRC SW 8270 Bi(2-ethylhe~yphtha1ate ND 660 08/1104 DRC SW 8270 ug/g Chryserne. ND 60 08111/04 DRC SW 8270 Ug/Kg Di-n-butylplthalate ND ug/Kg 08/11/04 DRC SW8270 660 i-jvoctylphthlbae NP 660 ug/Kg 08/11/04 DRC SW 8270 Dibenz(a,htantbrawne ND 660 08/11/04 DRC SW 8270 uglag Dbezmofura ND 660 08111/04 DRC SW 8270 ug/Kg Diethyl phtbhlate ND 660 08/11/04 DRC SW 8270 Dimethylphthalate ND 600 08/11/04 DRC SW 8270 Fluorantbene ND 660 ugfgug/Kg 08/11/04 DRC SW 8270 Fbuorene ND 660 08/11/04 DRC SW 8270 HeacNorbezene ND 660 08/11/04 DRC SW 8270 ug/Kg Helorot6utadiene ND 08/11/04 DRC SW 8270 660 Hexachlococycopentdiene ND 08/1 1/04 DRC SW 8270 600 Heachloroethns ND 660 ugKg 0/11/04 DRC SW 8270 .Indeno(12,3-od4pyreneND 0/11/04 DRC SW 8270 08/11/2004 19: 49 19782759754 DCAM PAGE 05

Client ID: WILMINGTON WETLANDS A MARBLE-OZA - Phoenix LD.: AF77437 1 Parameter Result RL Units Date Time By Reference Isophorone ND 660 ug/Kg 08/11104 DRC SW 8270 N-Nltrosodl-n-propylmnine ND 680 ug/Kg 08/1104 DRC SW 8270 N-Ntrosodhnethylanine ND 680 ug(Kg 08/11/04 DRC SW 8270 N-Nitrasodiphienfamtne ND -860 ug/Kg 08/11/04 DRC SW 8270 Ntapht1wiene ND 860 108/1104 DRC SW 8270 Nitrobxmzene ND 60 ug/Kg 0/1 1/04 DRC SW 8270 Pentailorophenol ND 60 ug/Kg 08/11/04 DRC SW 8270 Phenanthrne ND 660 ug/Kg 08/11/04 DRC SW 8270 ug/Kg Phenol ND 08/11/04 DRC SW 8270 Pyrene ND 660 ug/Kgugftg 08/11/04 DRC SW 8270 Pyrine ND Ow 08/111/04 DRC SW 8270 QA/QC Surrogates %24,6-Tribronophenol 101 %6 08/11/0 DRC SW 8270 %8 -Fluorobphenyl %6 08/11/04 DRC SW8270 %2-luwrophenol 64 %6 08/11/04 DRC SW 8270 %Ntrobenzene-d5 64 %6 08/11/04 DRC SW 8270 %Phenol-d5 74 %6 08/11/04 DRC SW 8270 %Terphenyl-d14 81 08/11/04 DRC SW 8270

Comments: ND-Not dewcted BDL - Below Detection Limit RL=Reporting Limit

If there are any questions regarding this data, please call Phoenix Client Services at extension 200. PLEASE NOTE: THIS PROGRESS REPORT IS CONSIDERED PRELIMINARY DATA. THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

r'W 1 of 49 68/11/2004 19: 49 19782759754 DCAM PAGE 06

PHCffffift Environmental Laboratories, Inc. 587 East Middle Turnpike, P.O.Box 370, Mwier, CT 06040 T&L(86MW645-1I03 Five("a)64-0M2

Draft Progress Report OR Att: M;Dan a te August 11, 2004 118 Tenne Street Ceorgetown, MA 01833

Sample Information Custody Information Date Time Matrix:. SOIL Collected by: 08/10/04 0:00 Location Code: TFORD Received by- KJB 08/1004 15:15 Rush Request: RUSH24HR Analyzed by: see "By"below P.O.#: 0446 SDG ID.: CAF77437 Laboratory Data Phoenix ID.: AF77438 Client ID: WILMINGTON WETLANDS A MARBLE-=F2 Parameter Result RL Units Date Time By Reference

Arse*dc 3.7 / I mg/Kg 08/11/04 MH 0010/E200.7 .Cadium BDL 0.5 mg/Kg 08/11/04 MR 6010(E200.7 copper 34,3,- 0.5 mgWKg 08/11/04 MNH 60101E200.7 Nickel 13,1 / 08/11/0 MH 6010/E200.7 Lead 85.6 / 0.5 mg/Kg 08/U04 MH 6010/E200.7 Antimony BDL 5 ngiKg 08/11/04 MH 6010/E200.7 Selentum BDL 25 mg/Kg 08/1104 MH 6010/E200.7 Zinc 97,2-/ 0.5 mg/Kg 08111/04 6010/EW0.7 Percnt Solid 71 08/11/04 C/D E160.3 PH 7.71 0.10 pH Units 08/10104 23:00 CD E150.1/SW9045 Sod Extraction for Herbidde Completed 08/10/04 H/R 8151 SoU Lt. for Pesddde Completed 08/11/04 AB/ 3545/3550 Soil Ext. for Semi- Vol Completed 08/11/04 AB SW355O/3545 Total Metals Digest Completed 08/10/04 AG SW846 - 3050 Chlorinated Herbicides z,4,S-T ND 20 ug/Kg 08/11/04 KCA SW151A 2,4,-TP (Sive) ND 20 ug/Kg 08/1 104 KCA SW8151A 2,4-D ND 100 ug/Kg 08/11M KCA SW8151A 2A.DB ND 100 ug/Kg 08/11/04 KCA SW8151A Dalapon ND 500 ug/Kg 08111/04 KCA SWS151A Dicamba NID 30 ug/Kg 08/11/04 KCA SW8151A Dichoropop- ND IU ug/Kg 08/11/14 KCA SW8151A NP 10 ug/Kg 08/11/04 KCA SW8151A

)Pqgp 5 of 40 88/11/2004 19: 49 19782759754 DCAM PAGE 07

Client ID: WILMINGTON WETLANDS A MARBLE-02B Phoenix I.D.: AF77438 Parameter Result RL Units Date Time By Reference V QA/QC Surrogates %DCAA (Surrogate Rec) 87 %6 08/11/04 KCA SW8151A

Pesticides - Soil 4.4' -DDD ND 32 Ug/Kg 08/11/04 KCA SW808I 4,4'-DDE ND 32 08/11/04 ICA SW8081 L4 -OPT ND 3? ON//04 KCA SW8081 ug/K~g a-BHC ND i6 08/11/04 KCA SW8081 ug/Kg Aldrin ND 16 08/111/04 KCA SWOS8I uzg/Kg b-BHC ND 16 08/11/04 KCA SWBU8I ug/Kg Chlordane 150,/ 66 08/11/04 RCA SW8081 ug/Kg d-BHC ND 16 08/11/04 KCA SW8081 Deldfrin ND 7.0 08/11/04 KCA SW8081 ug/Kg Endosulfan I ND 10 08/111/04 KCA SW081 Endosulfan1! ND 32 ug/Kg 08/11104 KCA SW081 EndosulfansuIte ND .32 ug/Kg 08/11/04 KCA SW8081 Endrin ND 32 ug/Kg 08/11/04 KCA SW8081 Endrn aldebyde ND 32 RCA SWSOS8 ug/Kg g-BHC ND 16 08/11/04 KCA SW8081 ug/~g 0W1 1/04 HepacNor ND 13 08/11/04 KCA SW801- gg/Kg erpctchlr epoxfde ND to 9811/04 KCA SW?0*1 O ng/Kg Methoxychlor ND 10 08/11/04 KCA SW88T Trxaphene ND 160 ug/Kg 08/11/04 KCA SW8O81 QA/QC Surrogates %DCBP (Surrgate Rec) 68 08/11/04 KCA SWSO01 % %TCMX (Surrogate Rep) 73 08111/04 KCA SW8081

Semivolatiles 1,4-Trlcbotobuane ND 660 091 1/04 DRC SW8270 ,2-Dichorobenzene ND 660 ugKg 08/11/04 DRC SW8270 ug/Kg 12-Dipbergyhydrazine ND 860 08/11/04 DRC Sw 8270 , 3-DJchlorobsnzene ND 060 08/11/04 DRC SWUM2 ug/Kg 1,4-Dichrobenzene ND 660 ugfg 08/11/04 DRC SWBZ70 2,4,5-Trkhlrnopbenol ND 08/11/04 DRC SW8270 2.4.-Trkhlorophesnol ND 0811/04 DRC SW 8270 ug/KgS 2,4-Dichlorophenol ND 660 ug/Kg 08/11/04 DRC SW 6270 ug/Kg 24-Dhoethylphenol ND 660 ug/Kg 0l11104 DRC SW8270 ug/Kg9 2,4-Dinitrphenol ND 6600 08/11/04 DRC SW 8270 ug/Kg 2A-Dntrotcluene ND 660 08/11104 DRC SW 8270 660 ug/K~g 2,6-Dkhlorophenol ND 08/11/04 DRC SW 8270 2-0-Dinitrotuuene ND 660 08/11/04 DRC SW 660 ug/Kg 8270 -Chtorcmpbthelene ND o8/1I1/04 DRC SW U270 o6w60 .Chlorophenol ND 08/11/04 DRC SW 8270 j~ipof 40 08/11/2004 19: 49 19782759754 DCAM PAGE 08

Client ID: WILMINGTON WETLANDS A MARBLE-02B Phoenix ID.: AF77438 a Parameter Result RL Units Date Time By Reference w 2-Methynphthalen 660 ug/Kg 08/11/04 DRC SW8270 2-Metbylphenol (o-creso 660 ug/K~g 08/11/04 DRC SW 8270 2-Nitroandlne 3200 ug/Kg 08/11/04 DRC SW 8270 Z-NtropheAol . 660 ugKg Og/11/04 DRC SW8270 3&4-Methylphenol (m&pamsa9 eo ugKg 08/11/04 DRC SW 8270 3,T-Dfchlcrobenzldine 1300 ug/Kg 0811104 DRC SW 8270 3-Nitroanilinet 3200 ug/Kg 08/11/04 DRC SW 8270 4,6-Dinitro-methbyphenol 3200 uWKg 08/111/04 DRC SW 8270 4-Bromphenyl-pheyl eder 580 ug/Kg 08/11/04 DRC SW8270 4-Chlor3-methyiphenol 1300 ug/Kg 0811/04 DRC SW 8270 4-Chclmoantne 1300 uag/Kg 011/(04 DRC SW 8270 4 -Chorophenyl phenyl ether 660 ug/IKg 08/11/04 DRC SW 8270 4-itroaniline 3200 uag/Kg w11/04 DRC SW 8270 4-Nitrophenol 3200 ug/Kg -08/11/014 DRC SW 8270 Acenaphthene 60 08/11/04 DRC SW 8270 ug/Kg Acenaphthylene 660 08/11/04 DRC SW B270 ug/Kg Anthracene 660 08/11/04 DRC SW 8270 uag/Kg Denz(aandracene 660 0811/04 DRC SW 8270 uag/Kg Bemidine 660 08/11/04 DRC SW 8270 uag/Kg Bemo(a)pyrene 660 08/11/04 DRC SW 8270 uag/Kg 660 08/11/04 DRC SW 8270 .Benzc(b)fluorantheneuag/Kg Benzogh)peryene ow ug/Kg 08/11/04 DRC SW 8270 Denzoc(k)fnuranthene 660 ugfKg 08/11/04 DRC SW8270 Bemoic acid 3200 ug/Kg 08/31/04 DRC SW8270 Bemyl akcohol 1300 08/11/04 DRC SW8270 ug/Kg Benzyl htyl phdhate 660 08/11/04 DRC SW 8270 uig/Kg Bis(-chloroehoy)nethene 0811/04 DRC SW8270 860 uag/Kg Bb(2-chloroethyeerw 08/11/0.4 DRC SW 8270 660 u/Kg Bis(2-chlorolsopropyether 08/11/04 DRC SW8270 Sw ug/Kg Bis(2-ethylhexy~pbthalate 08/11/04 DRC SW 8270 60 uag/Kg chrysene 08/11/04 DRC SW 8270 860 ug/K~g DI-n-butylphthalate 660 ug/Kg 08/1/04 DRC SW 8270 ug/Kg DJ-mocxylphtalate 0/11/04 DRC SW8270 660 ug/Kg Dibenz(slanthracene 08/11/04 DRC SW8270 uag/Kg Dibenznfuran 660 08/11/04 DRC SW 8270 tag/Kg Diethyl phthalt 660 0811/04 DRC SW 8270 660 Dlmetbylphthalate 08/11/04 DRC SW 8270 uag/Kg Fluoranthene 660 08/11/04 DRC SW 8270 tag/Kg 60 08/11/04 DRC SW 8270 Hexachorobenzene 60. tag/Kg 08/11/04 DRC SW8270 Hexacbloroebutadimne 60 uag/Kg 08/11/04 DRC SW8270 660 08/11/04 DRC SW 8270 660 uag/Kg 08/1/04 DRC SW 8270 udn(1,23-cd4pyrene 660 08/11/04 DRC SW 8270 Pjge 7 Of 40 09/11/2004 19: 49 19782759754 DCAM PAGE 09

Client ID: WILMINGTON WETLANDS A MARBLE42B Phoenix LD.: AF77438 f Parameter Result RL Units Date Time By Reference w Ishorone ND 660 ng/Kg 08/11/04 DRC SW8270 N-Nitrosodi-n-propylamine ND 660 ug/Kg 08/11/04 DRC SW 8270 N-Nitrosodirnethylanine ND 660 ugIKB 01 1/04 DRC SW 8270 N-Nftsodiphenylarnine ND 660 ug/Kg 08/11/04 DRC SW 8270 lNqhthalene ND 660 ugKg 08/11/04 DRC SW827U Nitrobenzene ND 660 ug/Kg 0/11/04 DRC SW 8270 Penclorophenol ND 660 ugKg 08/11/04 DRC SW8270 Phenannthne ND 660 ug/Kg 08/11/04 DRC SW 8270 Phenol ND 660 ug/Kg 08/11/04 DRC SW 8270 Pyrene ND 660 ug/Kg 08/11/04 DRC SW 8270 ND 60 ug/Kg 03111/04 DRC SW8270 QA/QC Surrogates % 2.4,6 Tdbromopbcnol 111 %6 08/11104 DRC SW sz70 %2-Fluambiphenyi 79 %6 08/11104 DRC SW 8270 %2-Fluorophenl 65 %6 08111/04 DRC SW 8270 %Nitrobenzene-d 63 %6 08/11/04 DRC SW 8270 %Phenol-d5 69 %6 08/11/04 DRC SW 8270 %Terphenyl-d14 89 0811/04 DIRC SW 8270

Comments: NDNot detected BDL = Below Detection Limit RL=Reporting Limit

if there are any questions regarding this data, please call Phoenix Client Services at extension 200. PLEASE NOTE: THIS PROGRESS REPORT IS CONSIDERED PRELIMINARY DATA THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

Nage of 40 08/11/2004 19:49 19782759754 DCAM PAGE 10

Environmental Laboratories, Inc. 587 East Middle Turnpike, F.O.Box 370. Marchester, CT 08040 Tel (80)645-1102 Fax(860) 645-0823

FOR Atr M. Dan olnte Draft Progress Report T Ford Comnpany August 11, 2004 118 Tenne Street Georgetown, MA 01833

Sample Information Custody Information Date Time Matrix: SOIL Collected by: 08/10/04 0:00 Location Code: TFORD Received by- KJB 08/10/04 15:15 Rush Request: RUSH?4HR Analyzed by: see 'By" below P.O.*: 0446 SDG LD.: CAF77437 Laboratory Data Phoenix I.D.: AF77440 Client ID: WILMINOTON WETLANDS A MARBLB-D Parameter Result RL Units Date Time By Reference

3.49 - I mg/Kg 08/11/04 MH 6010/2=00,7 Samilun BDL 0.5 mg/Kg 08/11/04 MH 6010/EZ00.7 Copper 42 -/ 0.5- pg/Kg 08/1104 MH 0010/E?00.7 Nickel 12.2 / 0.5 mgg 08/11/04 MH 601WE200.7 79.9 0.5 08/1104 6010/52003 Lead mgfKg MM Andmony BDL 5 mgKg 08/11/04 MH 6010/E2D.7 Seblenum .BDL 2.5 mng/Kg 08/11/04 MH 6010/E200.7 ZIc 942 0.5 mg/Kg 08/11/04 MR 601 0/E200.7 Percent Solid 73 08/11/04 CD E160,3 pH 7.77 0.10 pH Unite 0W10/04 23:00 CD E150.1/W9045 Soil Estracion for Herbtdde Completed 08/10/04 HM 8151 Soil Ext for Pesddde -Completed 08/11/04 AN/ 3545/3550 Soi Ext for Seni- Vol Completed 08/11/04 AB/ SW3550/3545 Total Metals Digest Completed 08/10/04 AG SW845 - 3050 Chlorinated Herbicides 2A5-T ND 20 ug/Kg 08/11/04 KCA SW8151A 24S-TP (Silvex) ND 20 ug/Kg 08/11/04 KCA SW8151A 24-D ND 100 ogfKg KCA SW8151A Z4-DB ND 100 0/1 1/04 KCA SW8151A uzg/Kg Dalapan ND 500 08/11/04 KCA SW151A ug/Kg Dlcamba ND 30 ug/Kg 08/11/04 KCA SW8151A Dichieroprop ND 100 08/11/04 KCA SW8151A . Dinseb ND 10 ug/Kg 08/11/04 KCA SWlI51A

Pge13 of 49 08/11/2004 19: 49 19782759754 DCAM PAGE 11

Client ID: WILMINGTON WETLANDS A MARBLE-02D Phoenix LD.: AF77440 Parameter Result RL Units Date Time By Reference

QA/QC Surrogates % CMAA (Surrogate Rec) 83 % 081 1104 KCA SW8151A

Pesticides - Soil 44' DDD ND 32 ugfg 08/11/04 KCA swe08' C -DDE ND 32 0811/04 KCA SW8081 4,4 -pDT NP 3? 08/.1104 KCA 3W8081 a-BHC Np 18 ugKg 08/11/04 KCA SW8081 ND 16 WKg 08/11/04 KCA SW8081 b-BHC ND 16 08/11/04 KCA Sw8081 Chlordane 130/ 66 ug/Kg 08/11/04 KCA Sw8081 d-BHC ND 16 08/11/04 IKCA SW8081 DPidrin N13 7.0 ugfKg 0811/04 KCA SW8081 Endosulfan II ND 16 08/11/04 KCA sWm081 ug/Kg ND 32 08/11/04 KCA swa081 Endosulfan ufate ND 32 08/11/04 KCA SW8081 Enidrin ND) 32 ug/Kg 08111/04 KCA SW8081 Endrin aldehyde ND 32 811/04 KCA SWs881 ug/Kg g-BHC ND 16 08/11/04 KCA SW8081 ugncg Heptackdor ND 13 08111/04 KCA SW8i8 S eptachlkr pcne ND yg/Igug/Kg 08/11/04 KCA Merhagcblor ND 160 ug(Kg 08/11/04 KCA SW081 Toxphene ND 160 08/11/04 KCA QA/QC Surrogates % DCBP (Surrogate Rec} 50 96 08/11/04 KCA SWSO0I % TCMX (Surrogate Rec) 70 96 0811/04 KCA SW5081

Semivolatiles L2,4-Trichlorobenzene ND 660 08/11/04 DRC SW8270 1.2-Dlblorbemene ND 660 ug/Kg 08/11/0i DRC SW8270 12-DIphenyihydazine ND 860 ug/Kg 08/21/04 DRC SW 8270 13jchlorobenzenet ND 08/11104 PRC SW 8270 6380 ug/Kg 1.4-Dichlorobenzene ND 08/11/04 DRC SW8270 ug/Kg Z.45-Trjehlorophenol ND 660 08/11/04 DRC SW 8270 660 ug/ Kg 2A.-TrIchrophenol ND 08/11104 DRC SW 8270 ug/Kg 2A-Dicropheno ND 680 -08/11/0 DRC SW8270 660 24-Dimethylpheno1 ND ug/~g 08/11/06 DRC SW8270 2A4-Datrophenol ND 3200 ug/Kg 08/11/04 DRC SW8870 2,4-Dinirrotoluene ND 660 ug/Kg 08/11/04 DRC SW 8270 2,6-Dlchiorophenol ND 60 08/11104 DRC SW 8270 Z,6-DinWtoinenc ND 660 08/11/04 DRC SW8270 u/Kg 2-Chloromnaphthalene NDw 660 08/11/04 DRC SW8270 2-Chlorophenol ND 660 08/11/04 DRC SW 8270

. Pe 14 pf 40 09/11/2004 19:49 19782759754 DCAM PAGE 12

Client ID: WILMINGTON WETLANDS A MARBLE-02D Phoenix ID.: AE77440 Parameter Result RL Units Date Time By Reference Z-Methy1nphtzha1ene ND 660 ug/Kg 08/11/04 DRC W 8270 2-Methylphenol (o-cresQ ND 660 ug/Kg 08/11/0 DIE SW8270 2-Nitroaniline ND 3200 ug/Kg 08/11/0 RO sw 8270 2-Nitrophenol ND 660 ug/Kg oNsM DRC SW'8270 3&4 Methylphenol (m&p-crso9 ND 860 utg/Kg 0/ 4 DR SW8270 3.3-Dichlorobenirine ND 1300 ug/Kg 08/11/04 PR SW 8270 3-Nivantlkine ND 3200 u/g 08/1104 DR SW 827D 4,6-Dinitro-Z-methylphenol N) 3200 ugg 08/11/04 RO SW 8270 -- Bromkophnylphenylether ND 660 uglKg 08/11/04 DRC SW 8270 4-Chloro-3-methylphenl ND 1300 ug/Kg 08110 DRC SW8270 4-ChlWoanillne ND 1300 ug/Kg 0511/04 DRO SW 8Z70 4-Chlorophenyl phanyl ether ND 660 ug/Kg 08/11/04 DRO SW 8270 4-Nitroardiine ND 3AX) ug/Kg 081104 D1C SW 8270 4-Nitrophenol ND 3200 ug/Kg 0811/04 DRC SW8270 Acenaphthene ND 660 ug/Kg 011/0 DR SW 87 Acenaphthylene ND 660 ug/Kg 08/11/04 PRO SW 8270 Anthracene P 660 ug/Kg 0811/04 ORC SW3270 Ben(a)antbracene ND 660 ug/Kg 0i/ DRO SW6270 Benridine ND 660 qg/Kg 08/11/04 )RC'SW 87 Ben(a)pyrene ND 660 ug/Kg 0811/04 DRC SW8270 Benz(b)flucrmnthee ND 660 ug/Kg 08/114 DRC SW8ZTO Benzo(ghwperylene ND 800 ug/Kg 0/0 RO SW 8270 Bzo otn ND 660 g/Kg 08/1 R SW 8270 Benzoic acid ND 3200 ug/Kg 011/04 PRO SW 8270 Benqyl alcohol ND 1300 ug/Kg 08/104 DRC SW8270 Benzyl butyl phthaate N) 660 ug/Kg 08/1/ PRO SW870 B~s(2-chloraethary)methane ND 660 . ag/Kg 08/11/0 PRO SW 8270 Bis(2-chloroethyer ND 660 ug/Kg 08/12/04 DRO SWS7 Bis(2-chloroisopropyfether ND 660 ug/Kp 08/11/04 DE SW 8270 Bis(2-ethyhanyophthalae ND 660 ug/Kg 015/1/04 PRO SW 8270 Chrysene ND 660 ug/Kg 011V04 PRO SW 3270 Di-n-butylphthalat. NP 660 utg/Kg os/04 DRO SW a27 Dj-n-octylphtbalat ND 660 ug/Kg Q11/4 RO SW 0270 Dibenz(a.hWanthracene ND 660 ug/Kg 0811/04 PR SW 8270 Dlbenofuran ND 660 Ug/Kg 0811/04 DRC SWO870 DIehyl pbthalate ND 660 ug/Kg 0811/04 DRC SW 8270 Dimedylphthalate ND 660ou/Kg 0/ 4 PRO SW 270 Fluoranthene ND 660 tag/Kg 0/1104 PRO SW8270 Fluorene ND 660 tug/Kg 081 104 DR SW 8270 Hexachlorobenzene ND 60 ug/Kg 08/1/4 DR SW 8271 Hexachkonoutadiene ND 660 tg/Kg 08/ IPO SW8270 Hexchlorocyclopentadfene ND 860 ug/Kg 011/04 P SW 8270 N 660 K 0/11/04 DRC SW 8270 (=12,3-ccopyrsne ND 660 z/Kg 08/11/04 DRC SW 8270

,Ng 15 of 4U1 08/11/2004 19: 49 19782759754 DCAM PAGE 13

Client ID: WILMINGTON WETLANDS A MARBLE-02D Phoenix 1D.. AF77440 Parameter Result RL Units Date Time By Reference Isopharme ND 660 ug/Kg 011/04 DRC SW 8270 N-Nitrosodi-n-propylamine ND 660 ug/Kg 08/104 DRO SWU870 N-Nilusodlmethylamine ND 660 ugig 08/11/ DRC SW 8270 N-Nitrosodiphenyamine ND 660 ugPKg 81104 DRO SW 8270 Naphthalene ND 660 ug/g 0811104 DRO SW8270 Nitrobenzne ND 660 ugKg 08/1 V04 PRO SW 8270 Pentachloropheol ND 660 ug/Kg 0811104 DRC SW 8270 Phenanthmne ND 660 ug/Kg nan 1104 PRO SW 20 Phenol N) 660 uWKg 08/1 V04 P SW 8270 Pyrene ND 660 ug/Kg 08/11/04 DRO SW8270 Pyridine ND 8D 8 0811/ PRO SW 5Z70 QA/QC Surrogates % 2,48-Tribrumophenol 90 08111/04 DRO SW 8270 % Z-Fluoroblphenyl 73 %w 014 DRO SW 8270 962-uumphenol 56 %0&ZRA4 PRO SW 8270 % Nkrobenene-dS 54 % 08/11/04 PR- SW 8270 * Phenol- 59 % I08/11/04 DRC SW 8270 56Tephenyl-d14 708/11/04 DRC SWZ71D

it Below D e cton Limt L=Reporng Ut~r , Comments: N=Not detected B If there are any081/4DR questi onsfgtisdt.p l Phoei b evie etnsio200.W87 ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARThINT.

Pee 10 9r40 08/11/2004 19:49 19782759754 DCAM PAGE 14

PhM U k-S.- Environmental Laboratories, Inc. 587 East Middle Turnpike, P..Box 370. MWxheiter, CT 06040 Tel. (SW0-645w-1IME Fax%(86 645-0623

FOR Attn: Mr. Dan Galante Draft Progress Report T Ford Company August 11, 2004 118 Tenne Street Georgetown, MA 01833

Sample Information Cus tody Information Date Time Matrix: SOIL Coll ected by: 08/10/04 0:00 Location Code: TFORD Rec eived by KJB 08/10/04 (5:15 Rish Request: RUSH24HR Ana lyzed by: see "3y" below P.O.#: 0446 SDG 1D.: GAF77437 Laboratory Data Phoenix I.D.! AP77442 Client 10: WILMINGTON WETLANDS A MARBLE-02F Parameter Result RL Units Date Time By Reference

Arsmdt 3.59 / 1 mWKg 06/1V04 MH 6010/E200.7 Cadwiumn 0.5 mg/Kg 08/11/04 MH 6010[E200,7 Copper 0,5 08/11/04 MKt 6010/g200.7 ig/Kg Nickel 14.2 / 0.5 08/11/04 MH 6011/E200.7 Lead 65.6 / 0.5 mg/Kg 08/11/04 MH 601 /E200-7 Antimony BDL 5 08/11/04 MH 6010/E200.7 Selenium BJDL 2.5 mg/Kg 0811/04 MH 60102E00.7 Zinc 93.3 0-5 mK 0&/11/04 MH 6010/E200.7 Percent Solid 74 1 W/11/04 C/D B160.3 PH 7.81 0.10 pH Units 08/10/04 23:00 CD E150.1/SW9045 Soil Extraction for Herdciwe Completed 08/1L4 WR 815 Soil Ext. for Pesticide Completed 08/L04 AB/ 3545/3550 Soil at for Semi- Vol Completed 08/11/04 AB/ SW3550/3545 Total Metals Digest Cowplete4 0/10/04 AG SWS46 - 3050 Chlorinated Herbicides Chlorinated Herbicides Pending ug/Kg SW8151A

Pesticides - Soil 4.4'-DDD) ND 32 ug/Kg 08/11/04 KCA SW8081 4,4'.DDE ND 32 ug/Kg 08/11/04 KCA SWB8M1 44' -DDT ND 32 ug/Kg 08111/04 KCA swee a-RHC ND 16 ugKg 08/11/04 KCA SW8081 *kht- ND 16 tg/Kg 08/11/04 KCA SW801

Pq: 21 (if 49 PAGE 15 68/11/2664 19:49 19782759754 DCAM

Client ID: WILMINCTON WETLANDS A MARBLE-02F Phoenix ED.: AF77442 .Parameter Result RL Units Dae Time By Reference b-BHC ND 16 Wg/Kg 08/1l/GRCA SWSI Chlordane 150 66 ug/Kg 011/ MCA SW"I d-BHC ND 16 ug/Kg 0/11 RCA SW808Z DieldrIn ND 7.0 ug/Kg 08/11104 RCA SWOBI Endksullan I ND 10 Ug/Kg 01/X 1/04 RCA SWBOS Endosufan U ND 32 ug/Kg 08/11/04 CA SW/Kg1 Endosufan sulfate ND 32 ug/Kg 08/1 RCA SWSOS Endrin ND 32 Ug/Kg 081104 CA SW8081 Endrin aldehyde ND 32 ug/Kg 0811/04 KCA SWMZ g-BHC ND 16 vg/Kg 08/1/M4CA SWMI Heptachlor ND 13 ug/Kg GWI1/4 KUA 5W80 Heptachlor epoxide ND 16 ug/Kg 08/1V04 ICA $W800 Methoxydlor NP 160 ug/Kg 08111/04 CCA SWM Toxaphene ND 160 ag/Kg 011/04 RCA 5W8081 QA/QC Srrogates %DCBP (SurrogateRec) 63 % 0811104 RCA SIM I % TCI (Surrate Rec) 72 08/11/04 KCA SW808I

Sernivolatiles 1,2,4-Tdchvhmbe e ND O60 ag/Kg 08/11/04 DRC SW 82701 1.12-Dirqbenne NP M6gig 08/11/04 C SWp l,2-Denyhyd i ND 60 tag/Kg 08/11/04 DRC SW 8270 ,3-Tblorobenzeae ND O60 tKg 08/11/04 DRC SW 8270 1A-Dfrorenzena ND 66D a/Kg 08/11/04 DC SW 8270 .ZA,5&ThQri phenol ND 8w uKg I08/11/04 KC SW8270 2,L,6-Tdchloropbvol ND) 5w0 usKg 08/11/04 DRC SW 8270 ZA-Dtchloropbeni ND 660 1/Kg 08/11/04 DRG SW 8071 2,4-Direthyipbenol ND 660 ug/Kg 08/11/04 DRC SW 8270 ,4-ilttmphesl ND 3200 ug/Kg 08/11/04 DRC SW8270 2A4-Dftditwtokuen NI) 660 ag/Kg 0811/0 DRC SWB270 ZAS-Dichl enOl ND 660 ug/Kg 08/11104 DRC SW 8270 Z.6-DnI~trIue ND 60 ig/Kg wl08/11/04 DRC SW 8270 2.CNoTmiaphtb~lOD NI) O0 ug/Kg 08/11/0 DRC SW 8270 2-ChIophenol ND 660 tg/Kg 08/11/04 DRC SW &0 2-Methymphrhate ND 6 g/Kg 08/11/04 DRC SW 8270 * 2-MeTiphelADInito)phenlete (o-cren ND 660300 uag/Kgug/Kg 08/11/0408/11/04 DRCD)RC SW 82798270 Z-NitrOhimne ND 320 ug/Kg 08/11/04 DRC SW 8270 f,-Diphenli ND 60 ug/Kg 08/1/04 DRC SW 8270 13-DichylOenen&p O ND O ug/Kg 08/11/04 DRC SW 8270 3A-DkhioobenizeLne2-Methylnaphthalenepw.;Z ND 661300 4gKug/Kg 08/11/0481/0 DRCR0W87 SW8270 3Aiuosnfic e ND 320 ug/Kg 08/11/04 DRC SW8270 46-Dino2-methylphe nol ND 320 ug/Kg 0/11/04 DRC SW 8270

gK g 081104 D RC SW 8270 2-Com phenl to=ND 660 PAGE 16 08/11/2004 19:49 19782759754 DCAMl

Client ID: WILMINGTON WETLANDS A MARBLE-02F Phoenix LD.: AF77442 Parameter Result RL Units Date Time By Reference

4-Choro-3-metklphenol ND 1300 ug/Kg 08/11/04 DRC SW 8270 4-Chloroannine ND 1300 ug/Kg 08/11/04 DRC SW8270 4-Chorophenyl phenyl ether ND 660 ug/Kg -0811/04 DRC SW 8270 4-Ninoanim ND 3200 ug/Kg 08/11/04 DRC SW 8270 4-Nitrophenol ND 3200 ug/Kg 08/11/04 DRC SW 3270 Acenaphthene ND 660 ug/Kg 08/1104 DRC SW 8270 Aenaphthyene ND) 660 ug/Kg 08/11/04 DRC SW 8270 Antbracene ND 660 ug/Kg 08/11/04 DRC SW 8270 Benz(a)andracene ND 660 ug/Kg 08/11104 DRC SW 8270 Benzidine ND 660 ugKg 08/11/04 DRC SW 8270 Benzo(a)pyrene ND o00 ug/Kg 08/ 1/04 DRC SW 8270 Benzo(b)fHloraotene ND 660 ug/Kg 08/11/04 DRC SW 8270 Bem(gOperyene - ND 660 ug/Kg 08/11/04 DRC SW 8270 Benzokdfluwranthene ND 660 ug/Kg 08/11/04 DRC SW 8270 Benzic add ND 3200 u/KgS 08/11/04 DRC SW 8270 Benzyi alcohol ND 1300 ug/Kg 08/11/04 DRC SW8270 Benzyl butyl phthalate ND 660 ug/Kg 08/11/04 DRC SW 8270 Bts(2-chloeboxy)medwn ND 660 u/Kg 08/11/04 DRC SW8270 B1s(Z-ddroethyoether. ND 660 g/Kg 08/11/04 DRC SW 827Q Bis(2-chloroisopropy1)ether ND 660 ug/Kg 08/11/04 DRC SW 8270 Bis(2-ethyLhexyphthalate ND 660 ug/Kgm 08/11/04 DRC SW 8270 ChryOene ND 660 ug/Kg 08/11/04 DRC SWUM70 DI-n-bNtylphtbalate ND 660 ug/Kg 08/11/04 DRC SW 8270 Di-n-octy1phthalate ND 660 ug/Kg 011/04 DRC SW 3270 Dbenz(a,b)antrane ND 660 ug/Kg 08/111/04 DRC SW8270 Dibenfuran ND 660 ug/Kg 0811/04 DRC SW 8270 Diethyl phthalate ND 660 U0g/Kg 08/11/04 DRC SW 8270 DIJethylphthalate ND) 660 ug/Kg 08/11/04 DRC SW 8270 Fluoranthene ND 660 ug 08111/04 DRC SW0270 Fluorene NDP M60 ug/Kg 08/11/04 DRC SW 8270 Hexarbloronze ND 60 utg/Kg 08/11/04 DRC SW 8270 HwXhorbutadne ND 660 tg/Kg 08/31104 DRC SW8270 Jezarblrocydopentadiene NP 650 ug/Kg 08/11/04 DRC SW 8270 Hexacdroene ND 660 ug/Kg 08111/04 DRC SW 8270 Inden(A23-cd)yrene ND 860 ug/Kg 08/11/04 DRC SW8270 Isophorone ND 660 ug/Kg 08/111/04 DRC SW 8270 N-Nftrosodi-n-propylamine ND 60 ug/Kg 08/11/04 DRC SW 8270 N-Nitrosodnethylandne ND 660 ug/Kg 08/11/04 DRC SW 8270 N-Nitrosdiphenylamine ND 660 ug/Kg 08/11/04 DRC SW 8270 Nephthalene ND 660 ug/Kg 0811/04 DRC SW8270 Nitrobenzene ND 660 ug/Kg 08/11/04 DRC SW8270 Pentaclorophenol ND 560 ug/Kg 0=11/04 DRC SW 8270 Phenantuene ND 60 ug/Kg 08/11/04 DRC SW 8270 0;enol ND 660 tug/Kg 0W11/04 DRC SW8270 Phg?3 of 40 PAGE 17 08/11/2004 19:49 19782759754 DCAM

Client ID: WILMINGTON WETLANDS A MARBLE-OZF Phoenix I.D.: AF77442 a Parameter Result RL Units Date Time By Reference S Pyrne ND 660 ugfKg 08/11/04 DRC SW 8270 Pyridine ND 660 Ugg 08/11/04 DRC SW 8270 QA/QC Surrogates %2,4,6-TrIbramophenol 85 %6 08/11104 DRC SW 8270 %2-Flwrcbphayl 68 %6 08/11/04 DRC SW 8270 % 2-Fuorophenlo1 43 08/11/04 DRC SW8270 %6 %Nitrobezene-d5 43 08/11/04 DRC SW 8270 %6 %Phenol-d5 53 08/11/04 DRC SW 8270 96 %Terphenyl-d14 74 08/11/04 DRC SW 8270

Comments: ND==Nor detected BDL =, Below Detection Limit RL=Reporting Limit

If there are any questions regarding this data, please call Phoenix Client Services at extension 200. PLEASE NOTE: TIS PROGRESS REPORT IS CONSIDERED PRELIMINARY DATA. THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

Pege 24 of 40 08/11/2004 14:03 978-352-7943 TFORD CO INC PAGE 01

T FOR D COMPA NY, INC.

DATE: August 10, 2004

TO: Greg Mischel

COMPANY: TRC

FAX #: 978-453-1995

FROM: Dan Galante

Number of pages including cover: 5

COMMENTS:

Greg.

Attached are the first analytical test results for the proposed wetland soil for Wilmington. These are the analytical results for the material I had sent you rhe agricultural / organic analysis for previously. The soils pass all requirements of table 02221-1. This test is performed for 0-100 cubic yards as per the testing requirements of TRC. Please review and let me know if you have any questions. We intend to maybe even deliver the material starting on Friday of this week depending upon how the survey and subsequent excavation progresses.

Thanks,

Dan

FACS1MLETRA1qSIMITAL-

The in'omaon contained in ths factimile message is confidential inf1maton imended onlyfor the indiidual or named entity named above. If he reader-6f this message Is not iWnended recipient you are hereby notified that any disseminaticn, distribution, or c Upyof his fbcsimilc is stictly prohibited. If you hive received tins acimile inerojlsenotifyus immediately bytclphone. Thiank Yeu.

* 118 TENNEY STREET - GEORGETOWN, MA 01833 - 978-352-5606 - FAX 978-352-7943 * * * 08/11/2004 14:63 978-352-7943 TFORD CO INC PAGE 02

Environmental Laboratories, Inc. 587 Ent Middle Turnpike. P.O.Box 370. Manchester. CT 06040 Tel. (860) 645-1102 Fu (860) 64548

FOR: Att: Mr. Don Galante Draft PIrogress 0Repo0t T Ford Company August 06, 2004 11 Tenne Street Georgetown, MA 01833

Sample Informton Cut1od Iinfo rnation Date Matrix: SOIL Collected by: 07/30/04 0:00 Location Code: TFORD Received by: JKJ B 08103/04 16:00 Rush Request: RUSH## Analyzed by: see "By" below P.O.#: 0446 SDG I.D.: GAF75634 Laboratory Data Phoenix I.D.: AF75637 Client ID: WILMINGTON WETLANDS A MARBLE-02 Parameter Result RL Units Date Time By Reference

O Arsenic 2.58/ I mg/Kg 08/05/04 MH 601 0/E20.7 Cadmium DOLL/ 0.5 mg/Kg 08/05104 MH 6010/E2O.7 Copper 31.1/ 0.5 mg/Kg 08/05/04 MR1 6010/E200.7 Nickel 10.2/ 0.5 mg/Kg 08/55/04 MH 6010/E200.7 Lead 77.6" 0.5 mg/Kg 08/05/04 MR 6010/F200.7 Antimony RDLV S mg/Kg 08/05/04 MH 6010/E200.7 Selenium UDlJ 2.5 mg/Kg 08/05/04 6010/F200.7 Zinc 93.3 V 0.5 mg/Kg 01/05/04 MH 6010/E00.7 M Percent Solid 76 08/04/04 E1l603 pH 7.51 0.10 pH UnlIt. 08/03/04 23.00 CD ESO.1/5W9045 Soil Extraction for Herbicide Complered 0/4/M H/M 8151 Soil Ext for Pesticide Completed 08/04/04 B/H 3545/3550 Soil Ext for Semi- Vol Completed 08/03/04 B/H SW3S50/3545 Total Metals Digest Completed 08/03/04 AG SW846 - 3050 Chlorinated Herbicides 2,4,5T ND 20 ag/Kg 08/06/04 KCA SW8151A 2.4.5-TP (Silvex) ND 20 ug/Kg 08/06/04 KCA SW8151A 2,4-D ND 100 ug/Kg 08/06104 KCA SW8151A 2,4-DB ND 100 ug/Kg 08/06/04 KCA SW8151A Dalapon ND 500 mg/Kg 08/06/04 KCA SW315iA Dlcamba ND 30 ag/Kg 08/6/04 KCA SWISIA Dichloroprop ND 100 08/06/04 KCA SW8151A inoseb ND 10 mg/Kg 08/06/04 KCA SWilSIA

Page 13 of 16 88/11/2004 14:03 978-352-7943 TFORD CO INC PAGE 03

Client IDt WILMINGTON WETLANDS A MARBLE-02 Phoenix .D.: AP75637 Parameter Result RL Units Date Time By Reference

OA/OC Sunmates % DCAA (Surrogate Rec) 67 % 08/06/04 KCA SW8151A

Pesticide - Soil 4,N -DD ND 32 ug/Kg 08/05/04 KCA SW8G81 4,4? -DDE ND 32 08/03/04 KCA SWI081 4, -DDT ND 32 1gKg 08/05/04 KCA SWasO1 ug/Kg e-BHC ND 16 qg/Kg 08/05/04 KCA SW8981 Aldrin ND 16 ogWKg 08/05/04 KCA SWO081 b-BHC ND 16 og/Kg 08/05/04 KCA SWR81 Chlrdane 140L/ 66 ug/Kg 08/0/04 KCA SWOM8 d-BHC ND 16 ag/Kg 05/05/04 KCA SWRORI Dieldrin ND 7.0 ug/Kg 8/5/04 KCA SW8081 Endosulfan I ND 16 /5/0&95M KCA SW8081 Endosulfani 11 ND 32 ag/Kg 08/05/04 KCA SWm0i Endosufan sulfate ND 32 ug/Kg 08/MS/04 KCA SWOR1 Endrin ND 32 mug/Kg 08/05/04 KCA SWOM1 ug/kg Endrln aldehyde ND 32 ug/Kg 08/05/4 KCA SW8081 g-BHC ND 16 08/05/04 KCA SW8081 Heptachlor ND 13 08/05/04 KCA SWUO1 ug/Kg Heptachior epoxide ND 16 08/05/04 KCA SW81 ug/Kg Methoxychlor ND 160 ug/Kg 08/05/04 KCA Sw8081 ug/Kg Toxaphene ND 160 08/05/04 KCA SWI081

OA/OC SurrErotes % DCBP (Surrogate Roe) 70 08/05/04 KCA SW8081 % TCMX (Surrogate Rec) s0 08/05/04 KCA SWW08

Semjivolatiles 1,2,4-THchtombenzene ND 330 ugKg 08/05/04 KCA SW 3270 1,2-Dlchlorobenzens ND 330 08/05/04 KCA SW 8270 mg/Kg 1,2-Diphonyihydrazine ND 330 08/05/04 KCA SW 8270 1,3-Dlchlorobenzene ND 330 08105/04 KCA SW 8270 1,4-Dichorobenzene ND 330 ag/Kg 08/05/04 KCA SW 8270 2,.5-Trichloropheno ND 330 08/05/04 KCA SW 8270 2,4,6-Trichlorophenol NDo 330 08/05/04 KCA SW 8270 ug/Kg 2,4-Dichlorophenot ND 330 08/05/04 KCA SW 8210 mg/Kg 2.4-Dimethylphenol ND 330 08/05/04 KCA SW 8270 mg/Kg 2,4-Dinltrophenol ND 1600 08/05/4 KCA SW 870 2.4-Dinitratluene ND 330 ug/cg 08/05/04 KCA SW 8270 2.6-Dichlomphenol ND 330 08/05/04 KCA SW 8270 * 2,6Dinitrotoluene ND 330 g/Kg 08/05/04 KCA SW 8270 2-Chloronaphthalene ND 330 ng/~Kgug/Kg 08/05/4 KCA SW 5270 2-Chlorophenol - ND 330 "g/g 08/05/04 KCA SW 8270 Psge 14 of 16 08/11/2004 14:03 978-352-7943 TFORD CO INC PAGE 04

Client 1m: WILMINGTON WETLANDS A MARBLE-02 Phoenix .D-: AF75637 Parameter Result RL Units Date Time By Reference

2-Methylnaphthalene ND 330 ug/Kg 08/05/04 KCA SW 8270 24Methylphenol (a-cresol) ND 330 ug/Kg 08/05/04 KCA SW 8270 2-Nitroaniline ND 1600 ugKCg 08/05/04 KCA SW 8270 2-NitrophenoI ND 330 US/Kg 08/05/04 KCA SW 8270 3&4-Methytphenol (rp&p-crwsl) ND 330 ug/Kg 08/5/04 KCA SW 8270 3.3'-Dihlorobenzldine ND 660 ug/Kg CR105/04 KCA SW 8270 3-Nitroanline ND 1600 ug/Kg 08/05/04 KCA SW 8270 4,6.Dinitro-2-methylphenol ND 1600 a/Kg 08R 04 KCA SW 8270 4-Bramophenyl phenyl ether ND 330 ng/Kg 68/05/04 KCA SW 8270 4-Chloro-3-methylphenol ND 660 ng/Kg 08/05/04 KCA SW 8270 4-Chloroaniline ND 660 ug/Kg 08/05/04 KCA SW 8270 4-Chiorophenyl phenyl ether ND 330 ug/Kg 08/05104 KCA SW 8270 4-Nitrcmnine ND 1600 ug/Kg 05/05/04 KCA SW 0270 4-Nitrophenol ND 1600 ug/Kg 08/05/04 KCA SW 3270 Acenephthene ND 330 ug/Kg 08/05/04 KCA SW 8270 Acenaphthylene ND 330 ug/g 08/05/104 KCA SW 8270 Anthracene ND 330 ug/K 08/05/04 KCA SW 8270 Benz(a)anthracene ND 330 ug/Kg 08/05/04 KCA SW 8270 Benzidine ND 330 Ug/Kg 09/05/04 RCA SW 9270 Benz(a)pymne 470/ 330 ag/Kg 0805/04 KCA SW 8270 Benm(b)fluoranthene ND 330 jg/Kg 08/05/04 KCA SW 8270 Benzo(ghi)perylene ND 330 UM/Kg 08/05/04 KCA SW 8270 Benzo(kfluoranthene ND 330 . g/Kg 08/05/04 KCA SW 8270 Benzic acid ND 1600 ug/Kg 08/05/4 CA SW 8270 Benzyi alcohol ND 660 ug/Kg 08/05/04 KCA SW 8270 Benzyt butyl phthalate ND 330 ug/Kg 08/05/04 KCA SW 8270 Eis(2-chloroethoxy)methane ND 330 ug/Kg 08/05/04 KCA SW 8270 Bis(2-chloroethyl)ether ND 330 ug/Kg 08/05/04 KCA SW 8270 Bis(2-chloroisopropyl)ether ND 330 ug/Kg 08/05/04 KCA SW 8270 Bls(2-ethy1hexyl)phthalate ND 330 ug/Kg 08/m4 KCA SW 8270 Chrysene ND 330 ug/Kg 08/05/04 KCA SW 8270 DI-n-butytphthalate ND 330 ug/Kg 08/05/04 KCA SW 8270 DI-n-octylphthalate ND 330 ug/Kg 09/05/04 KCA SW 3270 Dibenz(a.h)anthracene ND 330 u/Kg 08/05/04 KCA SW 3270 Dibenofuran ND 330 ug/Kg 08/05/04 KCA SW 8270 Diethyl phthelate ND 330 Mg/Kg 08/05/04 KCA SW 3270 Dimethylphthalate ND 330 ug/Kg 08/05/04 KCA SW 8270 Fluorenthene ND 330 ug/Kg 08/05/04 KCA SW 8270 Fluorene ND 330 u-o/Kg 08/05/04 KCA SW 8270 Hexachlombenzene ND 330 ug/Kg 08/05/04 KCA SW 8270 Hexachlorobutadiene N) 330 ug/Kg 08/05/04 KCA SW 8270 Hexachomcyclopentadiene ND 330 mg/Kg 08/05/04 KCA SW 8270 Haxachloroethane ND 330 g/JKg 08/05/04 KCA SW R270 Indeno(1.2.3-cd)pyrene NO 330 ug/Kg 08/05/04 KCA SW 8270

Pap 15 of 16 68/11/2004 14: 03 978-352-7943 TFORD CO INC PAGE 05

. r-

Client ID: WILMINGTON WETLANDS A MARBLE-02 Phoenix I.D.: AF75637 Parameter Result RL Units Date Time By Reference Isophorone ND 330 u/Kg 0/05/04 KCA SW 5270 N-Nitrosodi-n-propylamlne ND 330 0105/04 KCA SW 8270 N-Ntrosodimethylamine ND 330 ug/kg 08105/04 KCA SW 8270 u*K; N-Nitrosodiphanymaine ND 330 08/05/04 KCA SW 8270 ug/Kg Naphthlene ND 330 08/05/04 KCA SW 8270 ug/Kg Nitrobenzene ND 330 08/05/04 KCA SW 8270 Pentachlorophenol ND 330 ug/Kgeg/Kg 08/05/4 KCA SW 8270 Phenanthrne ND 330 08/05/04 KCA SW 8270 ag/Kg Phenol ND 330 08/05/04 KCA SW 8270 Pyrune ND 330 ag/Kgog/Kg 08/05/04 KCA SW 8270 Pyridine ND 330 08/05/04 KCA SW 8270 OA/OC Surrosates

% 2,4,6-Tribramophenol 11 % * 08/05/04 KCA SW 8270 % 2-Fluorobiphenyl 62 % 08/05/04 KCA SW 8270 % 2-Ruorophenol 52 08/05/04 KCA SW 8270 % Mtrobenzene-d5 93 08/5/04 KCA SW 8270 % Phenol-d5 % 75 08/05/04 KCA SW 8270 % TerphenyfId14 52 08/05/04 KCA SW 8270 a W Comments: ND=Not detected BDL = Below Detection Limit Ri-Reporting Limit

If there are any questions regarding this data, please call Phoenix Client Services at extension 200. PLEASE NOTE: THIS PROGRESS REPORT IS CONSIDERED PRELIMINARV DATA. THE RESULTS ENTERED HAVE NOT BEEN EXAMINED BY OUR QA/QC DEPARTMENT.

Page 16 of 16 APPENDIX G

Imported Backfil Nutrient Testing

L200"-56 SUBMITTAL NO 02221-2

DATE: 7/29104

PROJECT: WETLAND AREA - FORMER GE FACILITY - Wilmington, MA Contract No. E9202-5503-02300

CLIENT: CONTRACTOR: TRC T FORD COMPANY, INC. Boott Mills South 118 Tenney Street Foot of John Street Georgetown, MA 01833 Lowell, Massachusetts 01852

Specification Section 02221 Subcontractor/Supplier: Drawing No. Detail No. Copies. NIA

Comments/Remarks:

Organic and pH Test Results on Imported Wetland Backfill Mix

Contractor's Review Statement: Architect/Engineers Review Stamp:

I certify that I have reviewed the attached submittal information for compliance with the Plans and Specifications including, but not limited to review of dimensions, products and coordination with adjacent construction.

BY:

DATE: DTIf 7b/29/204 11:19 19783B84198 AGRESOURE PAGE 02

Jul 08 04 04*46p Umass Soil Testing 41354511931 r. I

SOIL ANALYSIS RED)ORT FOR RISEARCE 07/02/04 SOIL AND PLANT TISUB TEBSTING LMB LAD WNWBR: 8040628-132 WEST EXPERIMENT STATION BAG NUMBEhR: s5838 TWhIVERSITY 01 MAS&sACUSETTs AmmRST, "A 01003 SOIL NZIGET* 4.59 g/Sac AGROURCE CONCERO t 100 MAIN ST - T. GOULD PMEEBURY, NA 01913

ANALYSIS RUWQRT

SA74PLE ID: MA.LEHBAD ROIL SOIL TYPE. SOIL PH 7.6 ALUM rNuM (AL) 18 PPM ( oil Raue: 10-300) SUFFER PH 7.2 DRGM TC NT 13.6 Bsirable range 4-0t. NaTRIENT L PPMPVs LOW HIGH VaR2 HIGH PHOSPHORUS '~' 30" POTASSIUM 731 CALCM 4240 KVDDXXXXXX XX lMM3GTUJSC4 (MGI) 432 AMMONIUM (N04-N) f XX20C 00000[ NITRATE (NO3-K)(=X0 50 CATION EXCH CAP FRC SASEDINT RATURATIO 29-1 MaO/loe go 7.2 MGm13.3 CAm79.6

MICRONWTRIENT PPM SOI RkANsG6 MCROnINsT PPM SOL Rim Boron (T'"1.7 0.1-2.0 Copper (u)F 1. o.278.0 Manganese (Mn) 2B.1 3 - 20 Iron (Fel S.0 1.0- 40 Zinc Zn) 0.1 0.1- 70 ExRCTED LEAD (PB) 6 PPM. RSTDtATID TOTAL LEAD is 104 PPM. ETRACT CADMntM CD) 0.1 Fn SXTRACTI MumICK Ni) 0.1 PPM. lTRACTRID CHROMIUM (CR) 0.1 ?WM. COMMENTS

COMPUTIR PROGRAM & RECOMMNDATIONS BY DEPT OF PLAT & SOn. SCI UMASS-AMHERST. ,7/29/2004 11:19 19783B94198 AGRESOURE PAGE 02 Jul 00 04 04.40p Umass Soil Testing 4135451831 p.1

SOIL ANALYSIS REPORT FOR RESEARCH 07/02/D4

WOI1 A= PLANT TIsU TESTING LABM LAD tUMBR: 5040628-132 WEST EXPERIMENT STATION RAG NUMBER: S(89 tmnvmsrn orO AS6ACOUSTTS AMMTRSr MA 01003 SOIL WEIGRT. 4.S9 g/Eoc AGSSOIRCE CONCERNSk 100 MIN ST - T. GOULD AMEBBURY, MA 01913

AnALXBS$ RMi'RW SMPLA ID: MMtLEHBAD BOIL SOIL TYPE. SOIL PH 7..6 ALUMT1 (AL) 10 PPM (oil Ranget 10-300) BUFFER PH 7.2 ORGANIC mM' 13; 4t. sirable range 4-84. 3*UTRIUJJT LEVELS PPM LOi HIGH van, HIGH flOPRUSD -F30- POTASSIUM (() 751 CALCIUm (CA) 4240 MASR3BZUM (MG) 432 1 AMMONIUM (NQ4-N) 6 XC0XXXXXXX NITRATE N03-N) Do XXXXXX10DDD CATION EXCH CAP FERCW BABE ATUtRATION 29.1 M"/10O Ki 7.2 MGn13 .3 CAM79.6

1CRQWNTRIENT PPM BOILRANG MICRONLTRINW PPM SOIL RANGS Baron (~ 1-7 ~~- 0.1-2.o Cpper (TU7 1 .r 0.3"9.D Mang=tee (Mn) 28.1 3 - 20 Iron (F 8.0 1.0- 40 zinc (E) 0.I 0.1- 70 EXTRACTED LEAD (PB) 6 PPM. 3STIATED TOTAL LEAD IS 104 PM. EXTRACTED CADMIUM (CD) 04 ppM, EKTRACTED WICKEL NI) 0.1 PPM. EXTRAC CRMUHi (CR) 0.1 PPM. COMMENTS

COMT=TR ROGRAM & RECONADNDATIONS BY DEPT OF PLA14T r. SOIL SCI UMASS-AMH3RST. APPENDDX H

Pre-existing Baseline Conditions

L2004-456 I igure . View aL L2artiig ptI f Welirnd Sampling TrInec ('I facinhge northmest into tIie wetlanid restora t Io n ara. This is also thc location of I'ItograiiphIc Station I Figure 2 Vw of wekialShe reseranon area taken near OutflI 002. 1his poin i tT hchnof Phot$ognaphic Staoto 2. I igurc 3 View of pre exising co ndit 1 uthm the wethind restOrati ara, Noe .r rudrum ( red Inple) saplings in addition to he 1 n11 sne spelces /'hragmfite

Wetand Monitoring Documentation

L2004-456 0