Stephen Johnson, BWSC, NERO

4 MON\WEALTH OF MASSACHUSET L EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMFNT OF ENVIRONMENTAL PROTECTION ONE WINTER ! rREET. BOSToN. MA 02103 617-29. q00

Aki 'V 1 C TRI 'M )X

DA vin STRCJH Commnissamn

MEMORANDUM

TO: Cynthia Weidner, BWSC, NERO Stephen Johnson, BWSC, NERO THROUCH: Carol Rowan West, ORS FR OM: Nancy Bertinger, ORS 46 Maureen Vallatini, ORS DATE: December 18, 1997 SUBJECT: Review and Comments on Draft Environmental R sk Characterizatzon W orkpan fOr the Pair Shop Pond Sie, Welesly, T A November 14, 1997

Background

The Departmenm of Environmental Protection (the "Department") and Wellcsley College have been paruicipatig in facilitated discussions, regarding the Paint Shop Pond Site, for the last year. Recent discussions have focused on the environmental risk assessment whiich will be conducted at the site pursuant to 310 CMR 40,C995. Several drafts of the environmental risk assessment scope of work have been generated; the most recent version entitled the Draft Environmental Risk CharacteNzarion Workplan for the Paint Shop Pond Sire, Wellesl y, MA Nvember 14, 1997 (the "Workplan").

The Workplan was discussed at two facilitation meetings held on December 1, 1997 and DeLember 5, 1997. The comments and discussion provided below reflect the discussions held at those sessions.

General Comments

1. The natural historv survey proposed to measure wildlife species composition and habitat use is essentially a qualitative survey. This survey is an important component of the risk assessment Ithat it will support the identification of potential receptors. The survey report should include the identification of any migratory bird species that are likely to use the available habitat.

Owing to the natural temporal and spatial variability in the occurrence and distribution of wildlife, the results of the survey will not necessarily provide an accurate, independent

DEP On de Wond WIde Web rritp '/w magnet scam,rn usdep n Prnbe-d: vri Recycled Papef

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measure of effects. Therefore, ORS would not recommend placing a high weight on the survey results in the risk characterization.

2. Table 1 lists concentrations of metals in fish, vascular plants, sediment, surface water as independent measurement endpoints. These data will provide measures or estimates of exposure only; none by itself is a measure of effects. Environmental media and biota concentrations must be evaluated with respect to published benchmarks or toxicity data in order to assess risk.

3. The Workplan identifies several situations which will consider the use of benchmark and/or literature values in the assessment. ORS does not recommend an unconditional approval of this approach, since the proposed values have not yet been identified. It was mutually agreed, at the December 5, 1997 meeting, that summary documents of toxicity data would be submitted as interim documents for Departmental review and approval.

Lake Waban and Paint Shop Pond

4. The proposal specifies collecting one water and one sediment sample from each of 5 Lake Waban locations for the laboratory fish embryo toxicity tests, and placing a fish embryo exposure chamber at each of those locations for the field-based toxicity tests. This study is designed to include locations with a range of contaminant concentrations; it does not specify replication of tests at individual locations or at multiple locations with similar contaminant concentrations. The intent is to evaluate differences toxicity along a concentration gradient using regression analysis. ORS is concerned that the study will not be sufficiently sensitive to detect toxic effects that may occur at a specific concentration. In order to discern adverse effects, it may be necessary to conduct multiple tests at the same concentration (or at similar concentrations).

ORS recommends revising the plan for sample collection and exposure chamber placement so that replicate tests will be conducted at individual location. Wellesley may opt to do replicate tests (and collect replicate samples) from different locations of similar contaminant concentrations, instead of from single locations. It is important to recognize, however, that this approach runs a greater risk of producing ambiguous results due to variability among sampling locations in chemical and physical factors other than the target contaminants that could affect the outcome.

The necessary sample size should be determined using available information on variability in the effects to be measured.

5. The Workplan specifies that benthic community measurements will be conducted along a gradient of contamination. ORS recommends that the plan be revised to ensure a sufficient sample size is collected from a location (or group of locations) with high sediment contaminant concentrations so that an adverse effect on the benthic community, if present, would be detected. 3

The sample size should be determined by the biologically relevant mean difference in abundance and biomass and the natural variability in those parameters. The relevance to food supply adequacy of the proposed relative mean difference of 50% abundance should be documented.

6. The Workplan presents an example of how various combinations of results might be evaluated in a weight-of-evidence approach. ORS believes this is a very useful illustration of the process. The example presented, however, has not been evaluated for substantive comment.

7. The potential benefits of adding benthic invertebrate tissue analysis to the Workplan should be considered further. Tissue residue analysis could provide valuable data on exposures of fish, wildlife and benthic organisms.

Wetlands

8. The assessment of the wetlands is proposed as a 2 step process. The discussion of the wetlands assessment includes a number of measurement endpoints. The Workplan should clearly state that for purposes of determining whether Step 2 is necessary, the focus in Step 1 of the process is on tissue concentration endpoints.

9. It would be helpful if the wetlands discussion identified which measurement endpoints will be evaluated qualitatively.

10. It was agreed at the December 5, 1997 meeting that a flowchart would be included to better illustrate the 2-step process for the wetlands assessment.

11. The wetlands assessment identifies in footnote 5 that additional work may be needed as part of the Phase III evaluation for the site. ORS feels that this discussion should be more detailed and identify for future reference that this additional Phase III work may include additional field work including, but not limited to, sample collection and analysis and toxicity testing.

12. Assessment Endpoint Wetland 3 is identified as Maintenance ofwelands and wetland function. The inclusion of this assessment endpoint should be clarified and more fully discussed.

Terrestrial

13. The food chain model assessing wildlife exposures should include exposures associated with drinking water, in addition to incidental ingestion of soil and prey consumption. V 4V

Risk Characterization and Development of Target Levels

14. Figure 4 describing the development of target levels was inadvertently left out of the report; pursuant to our discussions on December 1, 1997 it will be included in a revised Workplan.

15. ORS has not formally reviewed the approach described the paper attached in Appendix C entitled Two Wildlife Exposure Models to Assess Impacts at the Individual and Population Levels and the Efficiency of Remedial Actions. It was not apparent whether this approach was actually being proposed for use at the site, or was only being considered for possible future use. Given that the food chain model will be submitted at a later date for the Department's review, perhaps the development of target levels should be included in that submittal. AGENDA

PROGRAM LAKE WABAN ANALYTICAL

September 15, 1997 Wall Experiment Station

LIMITS AND METHODS I. SELECTION OF DETECTION

ON AVAILABLE LABORATORIES BASED II. SELECTION OF APPROPRIATE FUNDING FOR INTERNS

III. SAMPLING PLAN TIMELINE/SCHEDULE

IV. LOGISTICS AND EQUIPMENT'

V. TRIAL RUN

VI. 'CLEAN" SAMPLING TECHNIQUES

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Page 2 Required Methodology for Metals - Lake Wabin Asseoment Piosar I

SEDIMENTS - METALS*

HUMAN HEALTH Analyte Method Holding Acceptable Number Plan A* Plan A Plan B*"' Plan B Time Detection I (WES) (contract (WES) (contract Limit (mgl<.g) lab) 'lab) Pb 6010A 6 months 0.35 200 Cr (tot) 6010A 6 months 0.05 200 Cr (V) 3060A 40-200 Al 6010A 6 months 0.35 40 As 6010A 6 months 0.15 40 Ba 6010A 6 months 0 05 40 Cd 6010A 6 months 0.06 40 Cu 6010A 6 months 01 40 NI 6010A 6 months 0.15 40_ Se 6010A 6 months 0.5 40 Ag 6010A 6 months 0.05 40 Zn 6010A 6 mpjb, 0.05 40 CN (tot) 90108 (' months ) 5 40 PAC I 0.27 40

ECOLOGICAL (all samples also analyzed for grain size and SEMIAVS) Anatyte Method Holding Acceptable Number Plan A" Plan A Plan BI" Plan B Time Detection I (WES) (contract (WES) '(contract Limit (mg/kg) lab) Ilab) Pb 6010A 6 months 0.35 52 Cr (t) 6010A 6 months 0.05 Cr (VI) 3060A Al 6010A 6 months 0.35 As 1600A 6 months 0.15 Ba 601OA 6 months 0.05 Cd 6010A 6 months 0.05 Cu 6010A 6 months 0.1 Ni 6010A 6 months 0.15 Se 6010A 6 months 0.5 Ag 6010A 6 months 0.05 Zn 6010A 6 months 0.05 CN (tot) 90108 6 months 51

EXTENT Analyte Method Holding Acceptable Number Plan A** Plan A Plan B* Plan B Time Detection (WES) (contract (WES) (contract Limit (mg/kg) lab) Ilab) Pb 6010A 6 months 0.35 92 Cr (tot) 6010A 6 months 0,05 92 Cr (VI) 3060A 18-92 Al 6010A 6 months 0,35 18 As 6010A 6 months 0.15 18 Ba 6010A 6 months 0.05 1 16 Cd 6010A 6 months 0.05 16 Cu 6010A 6 months 0.1 18 Ni 6010A 6 months 0.15 18 So 601OA 6 months 0.5 16 Ag 601DA 6 months 0.05 18 Zn 6010A 6 months 0.05 18 ON (tot) 901DB 6 months 5 18

TOTAL SEDIMENT SAMPLES

Program Requirements: All sediment samples will be analyzed for total chromium and total lead. All sediment samples will be screened for hexavalent chromium. Subsequent to the screening, samples may be analyzed for hexavalent chromium. Based on the initial lead and chromium results, 20% of the samples will be analyzed for the other COCs; aluminum, arsenic, barium, cadmium, copper, nickel, selenium, silver, zinc and total cyanide. 20% of the sediment samples being collected for human health risk assessment purposes must also be analyzed for PAC,

-- Plan A: WES hires two intems

- Plan B: WES doesn't hire two interns

Page 2 V I' 0 Sheet3

Page 3 Reoulrdi'ethedolv for Metals -Lake Waban Asnsment Progra

SURFACE WATER

HUMAN HEALTH Analyte Method Holding Acceptable Number Plan A Plan A Plan B Plan B Time Detection I (WES) (contract (WES) (contract Limit (mglkg) lab) Pb - total 6 months 651 Cr - total 6 months 651 Cr (VI) -tota 24 hours 65 Al - total 6 months 65 As - total 6 months 1 65 Ba - total 6 months 65 Cd - total 6 months 65 Cu - total 6 months 65 Ni - total 6 months 65 Se - total 6 months 65 Ag - total 6 months 65 Zn -total 6 months __ 65 CN - total 14 days 65 PAC 14 days 65 TSS 65 Turbidity 651 Hardness 65

ECOLOGICAL Analyte Method Holding Acceptable Number Plan A** Plan A Plan B* Plan B Time Detection [ (WES) (contract (WES) (contract lab) (mg/kg) - 301 lab) Pb - total Limit Pb - dissolved 30 Cr - total 30 Cr - dissolved I30 Cr (Vt) - total 30 Cr (VI) - dissolved 30 Al - total 30 Al - dissolved 301 As - total 301 As - dissolved 30 Ba - total 30 Ba - dissolved 30 Cd - total 30 Cd - dissolved 30 CU - total ______30 ______Cu - dissolved WabanAssessmentP30rograrn Ni - total ______30 ______Ni - dissolved 1______30 ______Se -total ______1___ 30 ______

Se -dissolved _ __ __ 30 ______Ag - total ____J______30 ______Ag -dissolved ______30 ______Zn - total A0 Plan B*** Plan6 Zn - dissolved A1PlanB***Pl30an B CN -total 30 CN -dissolved 30 TSSot l 30 Turbidityoved 30 Hardness 30 CNtota__ -__ 30 Plan A: WES hires two interns

ZPlan BoWES doesn hire two interns

Page 3 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston - Northeast Regional Office 10 Commerce Way, Woburn, MA 01801 (781) 932-7600

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary

DAVID B. STRUHS Commissioner

December 29, 1997

Assistant Vice President for Administration and Community Affairs Wellesley College 106 Central Street Wellesley, MA 02181-8258 Attn: Mr. Barry F. Monahan

RE: WELLESLEY - Paintshop Pond, Route 135; DEP RTN 3-0462; Extension of Interim Deadline

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a letter from East Coast Engineering, Inc., dated December 26, 1997, requesting an extension of the Interim Deadline established by DEP for the submittal of an evaluation of exposures at Lake Waban as part of an Immediate Response Action. An extension was requested due to the late receipt of the surface water and sediment data from the laboratory. DEP approves an extension of this Interim Deadline to January 9, 1998.

Please direct any questions regarding this matter to Cynthia Weidner at the letterhead address or 781/932-7720.

Very truly yours,

Cynthia Weidner Stephen M. Johnson Environmental Analyst Chief, Site lanageme ection Bureau of Waste Site Cleanup

a Printed on Recyded Paper cc. Wellesley BOH, ATTN: Dr. Robert Katz East Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738, ATTN: Christine LeBlanc Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Wendy Heiger-Bernays Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Charlie Menzie DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: Paul Galvani, Esq. DEP/NERO, ATTN: Jeffrey Mickelson, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos Office of the Attorney General, Environmental Protection Division, 200 Portland Street, Boston, MA 02114, ATTN: Matthew Brock, Esq. Wellesley College, 106 Central Street, Wellesley, MA 02181-8258, ATTN: William Reed, Vice President of Finance and Administration

Page 2 *0~ 4 East Coast Engineering, INC.

December 26, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Ms. Cynthia Weidner

Reference: Request for Interim Deadline Extension, Former Paint Factory Site, Wellesley, Massachusetts, DEP'RTN 3-0462

Dear Cynthia:

East Coast Engineering, Inc., on behalf of Wellesley College, is requesting an extension of the interim deadline from January 2, 1998 to January 9, 1998 for completing the Imminent Hazard Evaluation of sediment and surface water data for Lake Waban. This request is based on the fact that Woods Hole Group did not deliver the surface water data until December 16, 1997 (originally expected for December 10, 1997), and that revised sediment data for the northern shoreline was received by East Coast and Menzie-Cura on December 22, 1997.

If you have any questions, please feel free to contact me at (508) 748-2460 or Barry Monahan at Wellesley College (617) 283-2386.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. Steve Johnson, DEP - Northeast Region Ms. Susan Santos, FOCUS Group Ms. Wendy Heiger-Bernays, Menzie-Cura & Associates

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax:- (508) 748-2553 _z'asf'Coast Lnneering, *N4. %W )

December 26, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Ms: Cynthia Weidner

Reference: Request for Interim Deadline Extension, Former Paint Factory Site, Wellesley, Massachusetts, DEP RTN 3-0462

Dear Cynthia:

If you have any questions, please feel free to contact me at (508) 748-2460 or Barry Monahan at Wellesley College (617) 283-2386.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. Steve Johnson, DEP - Northeast Region Ms. Susan Santos, FOCUS Group Ms. Wendy Heiger-Bernays, Menzie-Cura & Associates

P. O. Box 745 15 6A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 DEC-26-1997 12.27 EAST CDPST ENG. P.01

J. ..ngneering, INC.

Post-it* Fax Note 7971 Q.

OJ' Dt pt o December 26, 1997

Fax 0 Fax 0

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Ms. Cynthia Weidner

Reference Request for Interim Deadline Extension, Former Paint Factory Site, Wellesley, Massachusetts, DEP RTN 3-0462

Dear Cynthia:

East Coast Engineering, Inc., on behalf of Wellesley College, is requesting an extension of the interim deadline from January 2, 1998 to January 9, 1998 for completing the Imminent Hazard Evaluation of sediment and surface water data for Lake Waban. This request is based on the fact that Woods Hole Group did not deliver the surface water data until December 16, 1997 (originally expected for December 10, 1997), and that reyised sediment data for the northern shoreline was received by East Coast and Menzie-Cura on December 22, 1997.

If you have any questions, please feel free to contact me at (508) 748-2460 or Barry Monahan at Wellesley College (617) 283-2386.

Sincerely,

EAST COAST ENGINEERING, iNC.

Christine R. LeBlanc Principal

cc: Mr Barry Monahan, Wellesley College Mr. Steve Johnson, DEP - Northeast Region Ms Susan Santos, FOCUS Group Ms. Wendy Heiger-Bernays, Menzie-Cura & Associates

P. 0. Box 745 156A Front Street Marion, MA 02738-0745 Tel (508) 748- 4O0 Fax: (508) 748-2553

TOTPL P.01 COMMONWEALTH OF MASSACHUSETTS ' VC EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION TEN COMMERCE WAY, WOBURN, MA 01801 781-932-7600

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary DAVID B. STRUHS Commissioner

VIA FACSIMILE AND US MAIL

December 19, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pona, Route 135, DEP RTN 3-0462; DRAFT ENVIRONMENTAL RISK CHARACTERIZATION WORKPLAN

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a document entitled Draft Environmental Risk Characterization Workplan for the Paint Shop Pond Site, Wellesley, MA, (the "Workplan"), dated November 14, 1997 and prepared by Menzie-Cura & Associates, Inc. on behalf of Wellesley College. The Workplan was prepared following discussions between DEP and Wellesley College representatives on August 28, 1997, September 5, 1997, September 8, 1997 and September 25, 1997. The Workplan was also extensively discussed at facilitated meetings between DEP and Wellesley College on December 1, 1997 and December 5, 1997. At those meetings, it was decided and agreed that DEP would issue a letter commenting on the Workplan and containing a "checklist" of items requiring additional clarification for the final workplan.

We recognize that there are many ways to perform an environmental risk characterization which meets the performance standards of the Massachusetts Contingency Plan. We believe that the Workplan prepared by Menzie-Cura represents a valid and conscientious approach towards this goal.

0 Printed on Recycled Paper .*I

Page 2

DEP has prepared the following comments on the Workplan. These comments have been previously discussed during facilitated meetings:

1. The natural history survey proposed to measure wildlife species composition and habitat use is essentially a qualitative survey. This survey is an important component of the risk assessment in that it will support the identification of potential receptors. The survey report should include the identification of any migratory bird species that are likely to use the avai!able habitat.

Owing to the natural temporal and spatial variability in the occurrence and distribution of wildlife, the results of the survey will not necessarily provide an accurate, independent measure of effects. Therefore, DEP would not necessarily place a high weight on the survey results in the risk characterization.

2. Table 1 of the Workplan lists concentrations of metals in fish, vascular plants, sediment and surface water as independent measurement endpoints. These data will provide measures or estimates of exposure only; none by itself is a measure of effects. Environmental media and biota concentrations must be evaluated with respect to published benchmarks or toxicity data in order to assess risk.

3. The Workplan identifies several situations which will consider the use of benchmark and/or literature values in the assessment. DEP cannot provide an unconditional approval of this approach, since the proposed values have not yet been identified. It was mutually agreed, at the December 5, 1997 meeting, that summary documents of toxicity data would be submitted as interim documents for DEP review and approval.

4. The Workplan presents an example of how various combinations of results might be evaluated in a weight-of-evidence approach. DEP believes this is a very useful illustration of the process. The example presented, however, has not been evaluated by DEP for substantive comment.

5. DEP has not formally reviewed the approach described the paper attached in Appendix C entitled Two Wildlife Exposure Models to Assess Impacts at the Individual and Population Levels and the Efficiency of Remedial Actions. It was not apparent whether this approach was actually being proposed for use at the site, or was only being considered for possible future use. Given that the food chain model will be submitted at a later date for DEP's review, we suggest that the approach for development of target levels be included in that submittal.

As discussed previously during facilitated meetings, the following items require clarification. We have grouped the items by subject:

Lake Waban and Paint Shop Pond

1. The proposal specifies collecting one water and one sediment sample from each of 5 Lake Waban locations for the laboratory fish embryo toxicity tests, and placing a fish embryo exposure chamber at each of those locations for the field-based toxicity tests. Page 3

This study is designed to include locations with a range of contaminant concentrations; it does not specify replication of tests at individual locations or at multiple locations with similar contaminant concentrations. The intent is to evaluate differences in toxicity along a concentration gradient using regression analysis. DEP is concerned that the study will not be sufficiently sensitive to detect toxic effects that may occur at a specific concentration. In order to discern adverse effects, it may be necessary to conduct multiple tests at the same concentration (or at similar concentrations).

DEP recommends revising the plan for sample collection and exposure chamber placement so that replicate tests will be conducted at individual locations. Wellesley may opt to do replicate tests (and collect replicate samples) from different locations of similar contaminant concentrations, instead of from single locations. It is important to recognize, however, that this approach runs a greater risk of producing ambiguous results due to variability among sampling locations in chemical and physical factors other than the target contaminants that could affect the outcome.

The necessary sample size should be determined using available information on variability in the effects to be measured.

2. The Workplan specifies that benthic community measurements will be conducted along a gradient of contamination. DEP recommends that the plan be revised to ensure ai sufficient sample size is collected from a location (or group of locations) with high :edirnent contaminant concentrations so that an adverse eflect on thesbenthic Dmrnunity, if present, would be detected.

The sample size should be determined by the biologically relevant mean difference in abundance and biomass and the natural variability in those parameters. The relevance :o food supply adequacy of the proposed relative mean difference of 50% abundance should be documented.

3. Although not previously mentioned, the benefits of adding benthic invertebrate tissue analysis to the Workplan should be considered further. Tissue residue analysis would provide valuable data on exposures of fish, wildlife and benthic organisms.

Wetlands

4. The assessment of the wetlands is proposed as a 2 step process. The discussion of the wetlands assessment includes a number of measurement endpoints. The Workplan should clearly state that for purposes of determining whether Step 2 is necessary, the focus in Step I of the process is on tissue concentration endpoints.

5. It would be helpful if the wetlands discussion identified which measurement endpoints will be evaluated qualitatively.

6. it was agreed at the December 5, 1997 meeting that a flowchart would be included to better illustrate the 2-step process for the wetlands assessment. Page 4

7. The wetlands assessment identifies in footnote 5 that additional work may be needed as part of the Phase Ill evaluation for the site. DEP feels that this discussion should be more detailed and identify for future reference that this additional Phase Ill work may include additional field work including, but not limited to, sample collection and analysis and toxicity testing.

8. Assessment Endpoint Wetland 3 is identified as Maintenance of wetlands and wetland function. The inclusion of this assessment endpoint should be clarified and more fully discussed.

Terrestrial

9. The food chain model assessing wildlife exposures should include exposures associated with drinking water, in addition to incidental ingestion of soil and prey consumption.

Risk Characterization and Development of Target Levels

10. Figure 4 describing the development of target levels was inadvertently left out of the report; pursuant to our discussions on December 1, 1997 it will be included in a revised Workplan.

If you have any questions in regard to this letter, please contact Cynthia Weidner at the letterhead address or 781/932-7720.

Very truly yours,

Cynthia Weidner Environmental Analyst

St he M.Jhs 'n Chief, Site Mana nt Section Bureau of Waste Site Cleanup

DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: Paul Galvani, Esq. DEP/NERO, ATTN: Jeffrey Mickelson, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos Office of the Attorney General, Environmental Protection Division, 200 Portland Street, Boston, MA 02114, ATTN: Matthew Brock, Esq. Wellesley College, 106 Central Street, Wellesley, MA 02181-8258, ATTN: William Reed, Vice President of Finance and Administration Wellesley College, 106 Central Street, Wellesley, MA 02181-8258, ATTN: Rene Stewart Poku, Interim Vice President of Finance and Administration \C@MONWEALTH OF MASSACHUSET* EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS - DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston/Northeast Regional Office 10 Commerce Way, Woburn, Massachusetts 01801, (781) 932-7600

ARGEO PAUL CELLUCCI TRUDY COXE Govemor Secretary E DAVID B., STRUM-I NERO FA CSIM IL ECommissioner TRANSMITTAL FORM DATE 1i-, iS/ O. Company: Contact Name: Phone: Fax Phone #: ciso t21t1S) GsRPTX) Company Phone #: OZUGGOr lIt) FROM: DEP Division: Contact Name: Phone:

COMMENTS:

Transmittal Form plus pages To report transmission problems, call Tony at (781) 932-7602 Fax Number for NERO - (781) 932-7615 CIONWEALTH OF MASSACHUSET ,fl

EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS '2 DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston/Northeast Regional Office 10 Commerce Way, Woburn, Massachusetts 01801, (781) 932-7600

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary DAVID B. STRUHS NERO FACSIMILE Commissioner TRANSMITTAL FORM

DATE / 5/

1I: Company: Contact Name: &' Phone:

Fax Phone #: (Sj oW ~IJEXD (s jszJs)s) Company Phone #: ozooZor III) FROM: DEP Division:

Contact Name: JdMtPhone:

COMMENT$:

Transmittal Form plus pages To report transmission problems, call Tony at (781) 932-7602 Fax Number for NERO - (781) 932-7615 CV ONWEALTH OF MASSACHUSETT* EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston/Northeast Regional Office 10 Commerce Way, Woburn, Massachusetts 01801, (781) 932-7600

ARGEO PAUL CELLUCCI TRUDY COXE Govemor Secretary

DAVID B. STRUHS NERO FACSIMILE Commissioner TRANSMITTAL FORM PATE It- / t / 1 Company: vVaAA%7e -L--o0,t- Contact Name: Phone:

Fax Phone #: (s ot(-IICoT1&co Company Phone #:

FROM: DEP Division: Contact Name: Phone:

COMMENTS:

Transmittal Form plus pages To report transmission problems, call Tony at (781) 932-7602 Fax Number for NERO - (781) 932-7615 A

AMONWEALTH OF MASSACI-HUSE* 7 EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION '1 Metropolitan Boston - Northeast Regional Office 10 Commerce Way, Woburn, MA 01801 (781) 932-7600 ARGEO PAUL CELLUCCI Governor TRUDY COXE Secretary DAVID B, sTRUHS Commissioner

Assistant Vice President for Administration and Community Affairs Wellesley College 106 Central Street Wellesley, MA 02181-8258 DEC 0 9 1997 Attn: Mr. Barry F. Monahan

RE: WELLESLEY - Paintshop Pond, Route 135; DEP RTN 3-0462; Extension of Interim Deadline

Dcat- Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a letter from East Coast Engineering, Inc., dated December 5, 1997, requesting an extension of the Interim Deadline established by DEP for the submittal of an evaluation of exposures at Lake Waban as part of an Immediate Response Action. As discussed at our meeting on December 5, 1997, DEP approves an extension of this Interim Deadline to January 2, 1998.

Please direct any questions regarding this matter to Cynthia Weidner at the letterhead address or 718/932-7720.

Very truly yours,

Cynthia Weidner Stephen M. Johnson Environmental Analyst Chief, Site Management Section Bureau of Waste Site Cleanup

0 Printed an Recycled Paper cc. Wellesley BOH, ATTN: Dr. Robert Katz East Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738, ATTN: Christine LeBlanc Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Wendy Heiger-Bernays Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Charlie Menzie DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: Paul Galvani, Esq. DEP/NERO, ATTN: Jeffrey Mickelson, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos Office of the Attorney General, Environmental Protection Division, 200 Portland Street, Boston, MA 02114, ATTN: Matthew Brock, Esq. Wellesley College, 106 Central Street, Wellesley, MA 02181-8258, ATTN: William Reed, Vice President of Finance and Administration

Page 2 'East Coast Engineering, INC. SCAN V

December 5, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Ms. Cynthia Weidner

Reference: Request for Interim Deadline Extension, Former Paint Factory Site, Wellesley, Massachusetts, DEP RTN 3-0462

Dear Cynthia:

East Coast Engineering, Inc., on behalf of Wellesley College, is requesting an extension of the interim deadline for completing the Imminent Hazard Evaluation of sediment and surface water data for Lake Waban. This request is based on a new delivery data of December 10, 1997 for the surface water data from the Woods Hole Group.

This letter serves to confirm our understanding, based on our meeting of December 5, 1997, that the interim deadline is extended to January 2, 1998.

If you have any questions, please feel free to contact me at (508) 748-2460 or Barry Monahan at Wellesley College (617) 283-2386.

Sincerely,

EAST COAST ENGINEERING INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. Steve Johnson, DEP - Northeast Region Ms. Susan Santos, FOCUS Group Ms. Wendy Heiger-Bernays, Menzie-Cura & Associates

P. O. Box 745 15 6A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 East Coast EngiAing, INC. [LIU-r* ®J3QEf)wwiE

P. 0. Box 745 156A Front Street Marion, MA 02738 '7 Tel: (508) 748-2460 Fax: (508) 748-2553

TObe-

- WE ARE SENDING YOU Attached ED Under separate cover via the following items:

E Shop drawings El Prints E Plans E Samples E Specifications El Copy of letter E Change order -1

COPIES DATE NO. DESCRIPTION

/ ///? r - WtA0MShit H t&

THESE ARE TRANSMITTED as checked below.

ED For approval D Approved as submitted El Resubmit copies for approval E For your use E Approved as noted El Submit copies for distribution E As requested E Returned for corrections E Return -corrected prints El For review and comment E

E FOR BIDS DUE 19 El PRINTS RETURNED AFTER LOAN TO US

REMARKS

COPY TO C- SIGNED:- AN MPC FORM 1cp~oft~ NO. 3502 if enclosurea are not as noted, kindly notify us at once. IMMONWEALTH OF MASSACHUSETT EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston - Northeast Regional Office 10 Commerce Way, Woburn, MA 01801 (781) 932-7720 ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary

DAVID B. STRUHS Commissioner

November 25, 1997 Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan, Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462; Designation of Interim Deadline

Dear Mr. Monahan:

We have received your letter dated November 24, i997 regarding Wellesley College's intent and proposed schedule to conduct an evaluation of exposures at Lake Waban as part of an Immediate Response Action, based on the recent sediment and surface water sampling results. It is our understanding that this evaluation will be performed in accordance with 310 CMR 40.0950 and will be submitted to DEP by December 19, 1997. We also intend to discuss the specifics of the recent sampling results and scope of the evaluation at our next meeting on December 1, 1997.

The proposed due date of the evaluation, December 19, 1997, is hereby established as an Interim Deadline in accordance with 310 CMR 40.0167. Extensions to Interim Deadlines must be requested in writing prior to the running of the deadline.

Should you have any questions or concerns regarding this matter, please contact Cynthia Weidner at the letterhead address or 781/932-7720.

ours, truly Very Cyntia Weidner Stephen M. Johns Environmental Analyst Chief, Site Management Section Bureau of Waste Site Cleanup

0 Printed on Recycled Paper Wellesley - Paintshop Poa Designation of Interim Deadline Page 2

cc. Wellesley BOH, ATTN: Dr. Robert Katz East Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738, ATTN: Christine LeBlanc Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Wendy Heiger-Bernays Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Charlie Menzie DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: Paul Galvani, Esq. DEP/NERO, ATTN: Jeffrey Mickelson, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos Office of the Attorney General, Environmental Protection Division, 200 Portland Street, Boston, MA 02114, ATTN: Matthew Brock, Esq. Wellesley College, 106 Central Street, Wellesley, MA 02181-8258, ATTN: William Reed, Vice President of Finance and Administration ''4

Office of Assistant V resident for Administration and Community Aff*

| Wellesley College SCAA 106 Central Street Wellesley, Massachusetts 02181-8258 (781) 283-2386 FAX (781) 283-3681 E-mail: [email protected] November 24,'1997

Ms. Cynthia Weidner Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Dear Cynthia:

The results of the Lake Waban sediment and surface water monitoring program conducted this fall are currently being evaluated by East Coast Engineering, Inc. and Menzie-Cura & Associates, Inc. Based on discussions with our consultants, and review of the preliminary results, it is our understanding that DEP believes an Immediate Response Action is appropriate.

Menzie-Cura recommends that an evaluation be conducted to evaluate exposure to surface water sediments by young children while swimming and by students while wading and swimming. The analyses will be based on surface water (agitated and non-agitated) and sediment data from samples collected in September, October, and November, 1997. This evaluation will be similar to that approved by DEP for the public beach area. The College will take these steps to address potential concerns about recreational uses of the area along the northern shore line by the College Community. We will also initiate "permitting" to cap the shallow sediments in the area in the same way the public beach was addressed. These actions will be taken to expedite a solution but without prejudice to our position that the lake is the Commonwealth's responsibility.

It is also my understanding that the Woods Hole Group will have fully completed analyzing all the samples, sediment and surface water, and distributed the analytical data to our consultants, and to the DEP by December 5, 1997. Therefore, we anticipate being able to provide the Evaluation to you by December 19, 1997. -2-

We look forward to discussing the available results of the Lake Waban sampling program with you at our meeting on December 1, 1997, and response actions which may be necessary to ensure protection of public health of the community.

Sincerely yours,

arry F. onahan '>44 -

East Coast Engineering, INC. Oqll

November 20, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Ms. Cynthia Weidner

Reference: Former Paint Factory Site, Wellesley, Massachusetts, DEP RTN 3-0462

Dear Cynthia:

On behalf of Wellesley College, we are enclosing an Immediate Response Action (IRA) Completion Report for work performed at the former paint factory site in accordance with 310 CMR 40.0427(3). This report documents the installation of the fence and posting of signs to limit access to the northern and southern wetlands at the former paint factory. The work was conducted in accordance with the IRA Plan dated September 2, 1997 and the Department of Environmental Protection's approval dated September 5, 1997. Also appended to this document is an IRA Completion Statement Form BWSC-105.

Should you have any questions following you review of this document, please contact me at (508) 748-2460. Thank you for your assistance in this matter.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. John Maggenheimer, Wellesley Natural Resource Commission Mr. Robert Katz, Wellesley Board of Health Mr. Jack McElhinney, Esq., Ropes & Gray Dr. Wendy Heiger-Bernays, Menzie-Cura & Associates

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 IMMEDIATE RESPONSE ACTION PLAN COMPLETION REPORT FORMER HENRY WOODS SONS PAINT FACTORY WELLESLEY, MASSACHUSETTS

Prepared for:

Wellesley College 106 Central Street Wellesley, Massachusetts 02181

Prepared by:

East Coast Engineering, Inc. 156A Front Street, P.O. Box 745 Marion, Massachusetts 02738-0745

November 20, 1997 IMMEDIATE RESPONSE ACTION PLAN COMPLETION REPORT FORMER HENRY WOODS SONS PAINT FACTORY WELLESLEY, MASSACHUSETTS

INTRODUCTION

This document presents the Immediate Response Action Completion Report to address response actions conducted to restrict access to surficial contamination in the wetland soils adjacent to property formerly occupied by the Henry Woods Paint Factory in Wellesley, Massachusetts. The IRA Completion Statement Transmittal Form BWSC-105 is attached.

Based on results of a recent sampling program, concentrations of lead, arsenic, cyanide, and chromium contained in the soils and wetland muck in the northern and southern wetlands exceed designated site-specific contaminant levels in the upper six (6") inches of soil. Although these areas are not readily accessible due to thick vegetative growth, these conditions pose the potential for significant risk to trespassers, thus requiring implementation of control measures to minimize exposure. These factors, and the College's position to protect overall public health and safety at this property, are the basis by which these response actions were conducted.

Implementing these remedial control measures coincides with the overall approach for this site which is to develop remedial strategies to provide protection of human health, welfare and the environment, while simultaneously maintaining the natural beauty and habitat diversity of the area. This document presents the measures which were undertaken to minimize contact with accessible pigments/contaminated soil. The need for long-term remedial measures are continuing to be analyzed and will be presented at a later date.

DESCRIPTION OF REMEDIAL ACTIVITIES COMPLETED UNDER THE IRA

The response actions conducted included access restrictions via fencing and sign posting to warn trespassers of site hazards, and upgrading existing fencing to limit trespassers from entering onto the former Paint Factory site via Paintshop Pond. This work was conducted in accordance with the IRA Plan dated September 2, 1997 and the Department of Environmental Protection's approval of September 5, 1997. Each of these measures is described in greater detail below.

Fencing

A six foot chain link fence was installed to restrict access to trespassers. The fence was installed by Reliable Fencing of Waltham, Massachusetts beginning on October 28, 1997, in accordance with the IRA Plan dated September 2, 1997. The approximate location of the fence is show on Drawing AB-2. This fencing scheme allows the continued passage of walkers/joggers through the jogging

East CoastEngineering, Inc. November 20, 1997 IRA Completion Statement, Paint Factory Site, Wellesley, Massachusetts Page 1 path from the boat ramp area and the walking path, but restricts access to northern and southern wetlands areas where wetland soils and muck, and Brook sediments to the north, contain elevated concentrations of metals and cyanide.

Access to the northern wetland is restricted by the six (6) foot chain link fence installed along the northern portion of the walking path (beginning at the existing fence), and traverses south along the walking path to the jogging path. Once at the jogging path, the fence is installed along the northern edge of the jogging path in a westerly direction, pass the culvert, and connects to end of the existing fence. Access to the southern wetland is restricted by the same type of fence installed along the eastern berm of the former impoundment, beginning at the southern end at the wetland via the vicinity of well MW-9, and traversing northward to the jogging path. At the path, the fence is installed on the southern side and traverses eastward, up to the culvert and extend about 30 feet along the western side of Waban Brook. Several gates were installed along both the northern and southern paths to access monitoring wells and piezometers.

In addition, to provide further access restriction within the former Paint Factory area, and as a means of keeping people from going around the ends of the fence which extend into Paintshop Pond, approximately 30 feet of additional fencing was extended from the existing end posts into Paintshop Pond; this fencing was added at both northern and southern ends of the fence.

Signae

Signs were posted at approximately 100-foot interval at the new fence. It has been the College's experience that signs do not remain on the fence, therefore signs were posted on the trees behind the fence. The signs are legible from a distance and read, "Warning Lead Chromate Deposits - Keep Out."

Security

The campus police will conduct periodic (daily visits at a minimum) inspections of the former Paint Factory area to ensure that locks and fencing are secured of all fence around which surrounds the Paint Factory site and associated wetlands. A walk-through of the enclosed area will be addressed bi-monthly to ensure that trespassers are not present. A log will be maintained of security checks and problems, if identified. Should any people be found at the site, they will be removed from the property immediately.

East Coast Engineering,Inc. November 20, 1997 IRA Completion Statement, Paint Factory Site, Wellesley, Massachusetts Page 2 ATTACHMENT 1

IMMEDIATE RESPONSE ACTION (IRA) PLAN FORM BWSC-105 Massachusa Department of Environmental 4 ction BWSC-105 Bureau of WRE Site Cleanup

Release Tracking IMMEDIATE RESPONSE ACTION (IRA) Number TRANSMITTAL FORM Pursuant to 310 CMR 40.0424 - 40.0427 (Subpart TE- 462 A. RELEASE OR THREAT OF RELEASE LOCATION! Release Name: Former Henry Woods Sons Paint Factory (optional) Street: Route 135 Location Aid: City/Town: Wellesley ZIP 02181-0000 Code: 7 Check here if a Tier Classification Submittal has been provided to DEP for this Release Tracking Number. Check here if this location is Adequately Regulated, pursuant to 310 CMR 40.0110-0114. Specify Program:7 CERCLA L1 HSWA Corrective Action L Solid Waste Manage ent 7 RCRA State Program (21C Facilities) Related Release Tracking Numbers That This IRA B. THIS FORM IS BEING USED TO: (check all that apply) / 7 Submit an IRA Plan (complete Sections A, B, C, D, E, H, I, J and K). 7 Check here if this IRA Plan is an update or modification of a previously approved written IRA P ate 7 Submit an Imminent Hazard Evaluation (complete Sections A, B, C, F, H, I, J and K). P/NORT - 7 Submit an IRA Status Report (complete Sections A, B, C, E, H, I, J and K). kV"qj 7 Submit a Request to Terminate an Active Remedial System and/or Terminate a Continuing Response Action(s) Taken to Address4 an Imminent Hazard (complete Sections A, B, C, D, E, H, I, J and K). Submit an IRA Completion Statement (complete Sections A, B, C, D, E, G, H, I, J and K). You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. C. RELEASE OR THREAT OF RELEASE CONDITIONS THAT WARRANT tify Media and Receptors Affected: (check all that 7 Air E Groundwater E Surface Water 7 Sediments e SiSoil apply) 7 Wetland E Storm Drain Paved 71 Private Well 7 Public Water Supply 7 Zone 2 7 Residence 7 School LI] Unknown 7 Other Specify Wetland Soils Identify Conditions That Require IRA, Pursuant to 310 CMR 40.0412: (check all that L 2 Hour Reporting Condition(s) apply) [ 72 Hour Reporting Condition(s) F Substantial Release Migration 7 Other Condition(s) Describe

Identify Oils and Hazardous Materials Released: (check all that Chorinated Slet E] Heavy Metals apply) El Oils 7 Others Specify: D. DESCRIPTION OF RESPONSE ACTIONS: (check all that apply) Assessment and/or Monitoring Only Deployment of Absorbent or Containment 7 Materials LI Excavation of Contaminated Soils LI Temporary Covers or Caps 17 7 Re-use, Recycling or Treatment LI Bioremediation Soil Vapor ( On Site 0 Off Site Est. Vol.: cubic yards LI Extraction Describe LIF7 Structure Venting System Product or NAPL 7 Store 0 On Site Q Off Site Est. Vol.: cubic yards 7 Recovery Groundwater Treatment 7 Landfill Q Cover Q Disposal Est. Vol.: cubic yards 7 Systems 7 Removal of Drums, Tanks or Containers Air Sparging Describe E] Temporary Water Supplies SECTION D IS CONTINUED ON THE NEXT PAGE.

Revised 2/24/95 Supersedes Forms BWSC-005, 006, 010 (in pad) and 011 Page 1 or 3 Do Not Alter This Form MassachuseA Department of Environmental P ction BWSC-105 Bureau of Wd Site Cleanup

IMMEDIATE RESPONSE ACTION (IRA) *,l",eTracking TRANSMITAL FORMPursuant to 310 CMR 40.0424 - 40.0427 (Subpart46

D. DESCRIPTION OF RESPONSE ACTIONS (contited): Temprrry Evacuation or Relocation of Removal of Other TRANSMITTALContaminated Media FORM 3- 462 Spcify Type and Fencing and Sign Posting

SOther Response Actions Describe

Check here if this IRA involves the use of Innovative Technologies (DEP is interested in using this information to aid in creating an Innovative Technologies Clearinghouse). Describe T~rhnninnir - E. TRANSPORT OF REMEDIATION WASTE: (if Remediation Waste has been sent to an off-site facility, answer the following questions) Name of Facility: Town and State: Quantity of Remediation Waste Transported to Date: F. IMMINENT HAZARD EVALUATION SUMMARY: (check one of the following)

Based upon an evaluation, an Imminent Hazard exists in connection with this Release or Threat of Release. D Based upon an evaluation, an Imminent Hazard does not exist in connection with this Release or Threat of Release.

L Based upon an evaluation, it is unknown whether an Imminent Hazard exists in connection with this Release or Threat of Release, and further assessment activities will be undertaken.

Based upon an evaluation, it is unknown whether an Imminent Hazard exists in connection with this Release or Threat of Release. However, response actions will address those conditions that could pose an Imminent Hazard.

G. IRA COMPLETION STATEMENT:

H Check here if future response actions addressing this Release or Threat of Release will be conducted as part of the Response Actions planned for a Site that has already been Tier Classified under a different Release Tracking Number, or a Site that is identified on the Transition List as described in 310 CMR 40.0600 (i. e., a Transition Site, which includes Sites with approved Waivers). These additional response actions must occur according to the deadlines applicable to the earlier Release Tracking Number (i. e., Site ID Number), State Release Tracking Number (i. e., Site ID Number) of Tier Classified Site or Transition Site: If any Remediation Waste will be stored, treated, managed, recycled or reused at the site following submission of the IRA Completion Statement, you must submit either a Release Abatement Measure (RAM) Plan or a Phase IV Remedy Implementation Plan, along with the appropriate transmittal form, as an attachment to the IRA Completion Statement.

H. LSP OPINION: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge, information and belief,

> if Section B of this form indicates that an Immediate Response Action Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal;

> if Section B of this form indicates that an Imminent Hazard Evaluation is being submitted, this Imminent Hazard Evaluation was developed in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and the assessment activity(ies) undertaken to support this Imminent Hazard Evaluation complies(y) with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000;

> if Section 8 of this form indicates that an immediate Response Status Report is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L c. 21E and 310 CMR 40.0000, (ii) is (re) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal;

> if Section B of this form indicates that an immediate Response Action Completion Statement or a Request to Terminate an Active Remedial System and/or Terminate a Continuing Response A ction(s) Taken to Address an imminent Hazard is being submitted, the response action(s) that is (are) the subject of this submittal (I) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40,0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal. SECTION H IS CONTINUED ON THE NEXT PAGE.

Revised 2/24/95 Supersedes Forms BWSC-005, 006, 010 (in part) and 011 Page 2 of 3 Do Not Alter This Form MassachusflDepartment of Environmental Po ction BWSC-105 Bureau of W Site Cleanup IMMEDIATE RESPONSE ACTION (IRA) Release Tracking TRANSMITTAL FORM 3i - 462 Pursuant to 310 CMR 40.0424 - 40.0427 (Subpart D) H. LSP Opinion (continued): I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the app provisions thereof.

LSP Christine R. LeBlanc LSP#: 4669 Stamp: 49 O Name: Telephone 508-748-2460 Ext.: 8TNE

FAX: 508-748-2553 SlC99 (optional)

Signature:

Date:______41a__10

1. PERSON UNDERTAKING IRA: Nameof Wellesley College Organization: Nameof Barry F. Monahan Title:Vice President of Administration Contact: Street: 106 Central Street

City/Town: Wellesely State MA ZIP Code: 02181-0000

Telephone: 617-283-2386 Ext.: FAX: --- (optional) F Check here if there has been a change in the person undertaking the IRA. J. RELATIONSHIP TO RELEASE OR THREAT OF RELEASE OF PERSON UNDERTAKING IRA: (check one) RP or PRP Specify Ct Owner Q Operator C3 Generator ( Transporter Other RP or PRP: ( Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s.2) ( Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21 E, s. 5(j)) Any Other Person Undertaking IRA Specify 7 Relttionshilr K. CERTIFICATION OF PERSON UNDERTAKING IRA: 1, Barry F. Monahan , attest under the pains and penalties of perjury (i) that I have personally examined and anifemihar with the information contained in this sumiLtal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained inthis submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. 1/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, p ible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

By: Title: Vice President for Administration (signature) For Barry F Monahan Date: / // 7 (print name of person or entity recorded in Section I)

Enter address of the person providing certification, if different from address recorded in Section 1: Street:

City/Town: State ZIP Code:

Telephone: Ext. FAX: (optional) YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE.

Revised 2/24/95 Supersedes Forms BWSC-005, 006, 010 (in part) and 011 Page 3 of 3 Do Not Alter This Form 01tLL I I uuIt ro llicd - comrrercial PmOTOBYVIRGIPBELL 's and claims Above, Maria Ortiz of Framingham, center, winces and Ient of New Christie Celorier, left and Laurel acquired 19 Moss, right recheck their notes as ,n during the their team misses the spelling of 'bulimold' at the Framingham . ct to break Education Foundation Spelling v must con- Bee at Finally Michael's. At right, ey can build David Halbert of Framingham 'id leased for High looks clearly worried about Cwater with- his team's success as fellow teammates Maureen Haskell and paport and Sally Utubor ponder the next >ieir propos- word.

Brazilian writers triumph New roun&,b tests ordered win for Maffei site. S. By Bonnie Docherty NEWS STAFFWRITER NATICK - After a local outcry about strange-colored soil on the Matei property, a state-certified lab will test the "blue-green" dirt for lead and other toxic metals. Brazilians among the NATICK an Litera- writers liv- Marco Kaltofen, owner of Boston Chemical Data Corp., said he believes oelho won the material in question may come from en's story Wellesley College's Paint Shop Pond, vhich she contaminated decades ago with "extra- rVho finds ordinarily high levels of toxic metals, untry and cadmium and lead." Maria Helena Balbino Coelho and her son, Henrique Balbino Coelho, were "If (Paint Shop Pond soil) is present, it winners at the First Brazilian ). her son, Literature Contest for Brazilian writers living is a real public health danger and needs with the in the United States. to be removed," Kaitoren said. "The ma- ("Street terial can affect groundwater and can onorable na Baibino Coelho, a babysitter with children in her hometown of travel some distance and contaminate ory ... e four grown children of her own, ages Valadares. water supplies." a cere- 23 to 32. couldn't be happier. "f worked a lot to create the group But Paul Sommer, hired by owner Wal- "I found it fantastic that I won the of'women who started this day care," do Maflfi to clean up the East Natict: maga- first place " she said in her native CoLho said. The group is called property, said the blue-green color is Brazilian Portuguese. "I hw- e hvays liked to ELAS. she said, explaining that the natu ra 1.not the result of paint pigments. ( Acade- wite, I also enjoy wrii1ng letters to letters ;tand for the Portuguese I'd like to make it very clear that it ap- ernador friends in Brazil, but T haven't kept words meaning togetherness. lei- pears to be blue clay," said Sommer, an town much of what I write and I didn't ex- sure, updating oneself and service. owner of Sommer Environmental Tech- largest pect this to happen ... I always have "The group started 12 years ago nologies in Wakefield. "It may be unfor- .ne Metro- had this dream that some day I'd and has kept its goals of bringing in tunate that someone picked up the cate- received publish a book." speakers to educate the women. gorization blue-green. It is not pigment gories of Coclho 'vas tnfmed during the They also opened this day care, and I blue-green." dture and ceremony earlier this month of an have always wanted to contribute. Sommer said he expects to receive test offer by a Brazilian publislier - I'm glad I am finally able to do it" results in about two weeks. :orted by Editora Aliguilim in Belo Horizonte, Other winners came from Cam- The five-acre lot, owned by Waldo - both in state ofMinas Gerais, bridge, Malden, Billerica, Clinton, Maffei Inc. and located off Wellesley .tnsbrasil First-place winners in each cate- Boston, Watertown, Providence, R.I., Road Extension, has been under a clean- >f Fram- gory received S1.000. Second and Greenwich, Conn., Newark, N.J., and up order by the state Department of En- \Iidwest third places received $750 and $500. Mineola, N.Y. vironmental Protection since March Coelho immediately donated her 'The most important part of this 1995. Sommer finished the first phase of n'ra Hele- prize to a day-care center for needy BRAZILIAN WRITERS, PAGE 3B cleanup last spring and is working on the NEW TESTS, PAGE 28 Luma -- oc iui ratraui uXIti a rmgue 'veb ing., C.

West YMCA is holding a Newtests set for llaffei land -cc Lunches for Active this year. The next ses- NEWTESTS, FROM 1B in the stream bed represents poten- along property line. m Friday. The compli- the second part, retesting the area tial runoff from the Maffei property," "We were assured by the Conser- A lunch begin s at 12:30 for contamination. Maffei said. vation Commission, Natick and i by a workshop and dis- Tonight the Conservation Commis- Maureen Maffei, daughter of Wal- property owners that they never "Communicating with sion will vote on extending a three- do and manager ofWaldoMaffei Inc. dumped anything illegal in there," ian" beginning at 1 p.m. year permit to build four homes on for 33 years, said she won't comment Dana Reed said, "It turns out there x32 for more informa- the controversial land. Home con- on the allegations at this point. are high concentrations of some- 've you place. struction, planned many years ago, is "I'm not going to do anything until thing illegal and toxic." on hold until the cleanup is done. I see what comes back from the Although the lead Kaltofen found .s wreaths The commission meets at 7:30 p.m. tests," she said. "To the best of my was on an adjacent property, Reed in room 205 of Town Hall. The Maffei knowledge, there's nothing there." said he has no knowledge of dump- 'le time to order your issue is slated for8:25 p.m. Last week, Sommer took samples ingby anyone butthe Maffeis. Wreath from the Boy The Conservation Commission fromthearea where neighbors "All I know is they are the only roop 1775. Your favorite does not have jurisdiction over the claim the blue-green soil is. He also ones on record to put anything in," Ske orders through Dec. 1 cleanup, but it granted a permit in dug new test pits and three addition- he said. "They have (a 1977) order of aths will be delivered on May 1996 to allow the Maffeis to real wells. conditions (from the Conservation -c. 6 The price is $8. for move contaminated dirt in the wet- After the soil tests come back, Commission) to define whatthey can ch center double faced lands buffer zone, Conservation Sommer will follow up with more put there. But what's been found has , a red velvet bow. Almost Agent Terry Whalen said. groundwater samplings, he said. been dirty." cost of each wreath goes If or when the land is freed of con- Before the recent controversy over Sommer, by contrast, said he will scout's fund-raising ob- tamination, the Maffeis have vari- blue-green soil, Sommer was plan- be pleased if Kaltofen finds contami- ances dating back about 30 years ningto wrap up his study of the site, nation nearby. from the Zoning Board ofAppeals al- Now he doesn't know when the pro- "There is nothing my client and I lowing them to build on the small jectwill be finished. would love better than to have him lots. The zoning board issued the "The plan is at the point where we prove the abutting properties are variances before there were dead- collect all of the data to make a deci- contaminated," Sommer said. 'MUNITY lines, so they are good forever, Wha- sion how to close the site," Sommer "That's what my client maintained len said. said. all along. They should be equally re- The recent furor about blue-green "We are going back to produce a sponsible for the cleanup," soil began when Kaltofen told the Phase If study in order to ascertain So far, the Maffeis have paid to Wellesley Townsman in September whether the cleanup was completely SGIVING SERVICE clean up their land. Maureen Maffei he believes there may be material successful. If it wasn't, we will pro- wouldn't say how much they have from Paint Shop Pond on the Maffei ceed with additional remediation. If - The Wayland Clergy As- spent. property. it was, we will proceed toward clos- If the soil in question turns out to .as scheduled the annual The Maffeis responded with a let- Thanksgiving service ing the case." be from Paint Shop Pond, Kaltofen ter threatening a lawsuit if he didn't ov. 23, at 7:30 p.m. at St. About 400 tons of contaminated said pond owner Wellesley College retract his statement. Kaltofen re- soil was shipped out of state this or whoever dumped the soil could be "ch, 124 Cochituate Road fused to back down, however, and i. Representatives from year. Along with hydrocarbons and iorced to pay forcleanup. has received no notice of legal ac- Aligious communities in lead, carcinogenic PCBs, or poly- Rut environmentally, it does not .pected to participate. tion. chlorinated biphenyls, have been matter who dumped the material or Kaltofen said yesterday Sommer's found on the site. where it caie from. there will be special em- description of "blue-green" soil in a Because of the long history of con- "The issue ultimately is if' (the auth of the communities. cleanup report reminded him of tamination, neighbors are worried lead) is at dangerous levels, it will rick Kelly, pastor of St. Paint Shop Pond soil he tested in Kaltofen may be right and the col- have to be removed." Kaltofen said. Lost the evening. Rabbi 1981. ored soil may be from Paint Shop "Who pays conies right after that." 'umberg of Temple Shir At a neighbor's request in 1993, Pond. :hairman of the Wayland Kaltofen tested soil from a stream In 1990, Dana and Holly Reed. ociation will speak on the just south of the Maffei property. Al- leaders of the Protect East Natick .ng theme. William though not blue-green, this soil had group, moved into a Wellesley Street irector of music at Church 1.500 parts per million oflead. Extension home adjacent to the COMMUNITY iv Spirit, will be organist The number is high. but not as high Maffei property. 'or of the community as reported lead levels found in test Soon after, they said, they saw NEWS one wishing to sing in the pits on the Maffei land, Kaltofen trucks dump asphalt and the state 'semble at St. Alnn's at 6 said. declared the land an illegal landfill. FAMILYJOURNEY "My presumption is the material Chunks N of asphalt are still visible PROGRAM

FRAMINGHAM - Fuller Middle School of Framingham has been selected to participate in an innovative geogra- C to open children's playground phy education program sponsored by Dunkin' Donuts Franchise owners ,HAM - Framingham State campus when the college moved to teaching young children. Students These franchised owned shops i hold the grand opening Framingham from Lexington in the participated in the lab program un- have become a partner in education the new children's play- mid-1800s. der the supervision of the director. with more than 1000 schools in Mas- Ith a reception honoring Jordan worked with the architects She was also the students' instructor whums N, i H lphiire. Mlaine. SJordan. who were planning the construction in a course focusing on child devel- (nude lAand and ConnecLicut They of Hemenway Hall to ensure that the opment will provide each classroom with FRAMINGHAM classroom for the lab school includ- A graduate of Framingham State USA TODAY'S family journey pro- playgrround is for the ed an observation booth. a large and College, Jordan returned to the col- ;ram. AS part of'the program, Dunk- l ": n'mher of the hnimo nn- .n' Donuts provides teach and stu- I

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IN Aauhew Certin Those familiar with ihe site say nt sVaI Wiiwr this is a familiar tactic of Waldo NAICK - Faced with the paospect of finding contami- Maffei fnc., a demolitiontexcavation nared soil allegedly from Wellesley College's Paint conipany,.threatening anyone with is Shop Pond on the site of its proposed development, legal action in an attempt to bully Waldo Maffi Inc. has gone on holh the offensive and him into silence. Waldo Maffei Inc. defensive, threatening legal action and making allega- owner/clerk Maureen Maffei, howev- tions of its own. er, has no plans to be silent herself, i The proposed development, olf Wellesley Road and has lashed out at her neighbors, Extension in Natick, has a long history starting decades accusing one of her critics of actually Nim\t,

associated with Paint Shop Pond edgcof the allegeddumping. material. "That's an outright lie," said St. SOL At the present time, a new house Martin of Maffei's claims. FROM PAGE 18 is under construction by the present St. Martin questioned whether trucks proceeded to the lot former- owners of the site, formerly owned Maiffi had any proof to back ip For w ly owned by the late Dan Brady by Dan Brady Sr. and his family. her allegations. The answer from Sr., and dumped their [illt Maffei The new owners could not be Maffei was no. said she has no idea whether the fill reached for comment. "No, but I'll take a lie-detector busi* was contaminated or if it had the Both St. Martin and Wellesley test," she said. Hue-green coloration commonly College oflficials deny any knowl- see Soil, page 22 the di;B' College committed to cleaning Paint Shop Pond

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Weiledey Colege is cleaning up a portion of Its land where contaminants were found in the soil containing chromium and lad, two chemicals conunonly associated with the paint-making process. Lesser concentrations or cyanide and arsenic, two other potentially harmful metals, were aso found. By Matthew Cann someone was going to mun some soil include chromium and lead, TAB Staff Writer other business here." two chemicals commonly associat- S ince the early 1980s, the Unfortunately for Wellesley ed with the paint-making process. For reading all I oDepartinent of Environmental College, the land they punchased Lesser concentraiions of cyanide LProtection has been involved 4jmned out to be contaminated with and arsenic, two other potentially I I Zr'

NY )CK GRANT 'RIORITIES of the property, Sommer's January were not founded on scientific fact SOIL 1995 report detailed the discovery of would subject them to potential liti- line-to-medium sand of a green-to- gation. at the Town's Housing FROM PAGE 19 blue color in test pit No. 9. This 2- "Ibis letter is to caution you that he Town's 1998 - 1999 St. Martin began working at foot layer of soil was found 20 feet the continued false accusations, and xpended to address those below the surface, three feet above 02,000 available to Wellesley College in 1972 as a cus- finger-pointing, toward my client,' t Program. todian. Three years later, he began the groundwater level. which is damaging to its reputatidn rincipally benefit low and painting at the private college, ajob "I have some of the blue-green and its responsibility as a good be expended on a wide he still holds today. In neither capaci- material from Wellesley College. As neighbor and citizen of the town of velopment, public facili- a registered professional civil engi- ation of the Town's ty, according to St. Martin, was lie in Natick, will no longer be tolerated d this hearing, or if you any position to offer fill from the col- neer, it appears to me to be a line-to- and will, if such accusations continue f "Needs Questionaire" lege to anyone. To the best of his medium sand of a blue-to-green without credible, responsible engi- pressing your views at the knowledge, no fill was removed color," said Kaltofen. neering and scientific evidence to vernorial Building, Room from the college. According to the Somnmer report, warrant and justify the same be con- "That was not part of my job at the soil in question was tested for sidered as a malicious act on your all," said St. Martin. "She's just upset petroleum contaminants. The part and they will pursue all remedies COMUNAL that we were prowen right. I knew groundwater beneath the soil was of the law to seek redress and DES Y PRIORIDADES nothing about this." tested for petroleum and metal conta- accountability from you," wrote Legal action threatened mination. The blue-green soil was attorney Melvin Newman. not tested for metals, such as lead, This letter came on Feb. 21, 1997, St. Martin, along with Kaltofen tes respeclo aLas nlCCCSi- chromium, arsenic and copper - shorly-after the Protect East Natick and at least three other residents, who municipalidal, y coio se chemicals commonly used in the Group, consisting of Wellesley Road inicipalidad para el ano have complained about dumping on paint-making process. Extension area residents, petitioned niunicipaliiad espera Maflci property, have received the In the Sept. 25, 1997 issue of the the Department of Environmental gasar en su 1rogr'ama de letters threatening legal action from le Desurrollo Comunal Wellesley Townsman, Kaltofen is Protection to designate the Maffei L municpalidad de ingre- Maffei lawyers. Involvement Plan To those who question Maffei's refened to in an article on Paint Shop cleanup a Public tar en un alcance amplio Pond as stating that a Site. This designation forces the econonico, motives for pointing lingers at her similar blue- green soiI had been found on the cleanup environ mental consultant to s publicos. disenchanted neighbors, Malfei has 'rograrna de Desarrollo Malfei pmperty. share infomiat ion with neighbbrs and only one reply: "Just test it, let's see ir a la audencia pero le Shortly thereafter, he received a town officials. les" que Vd. Puede corn- where the stulf really is in (own," she sen la audiencia, por favor letter from Waldo Maffei Inc.'s Holly Reed, despite her status as said. lawyers. co-chairwoman of the Protect East oom1B2, Framingham, MA Bany Monahan, Wellesley College "Please take notice that the above Natick group, was reluctant assistant vice posident of to speak matters attributed to you are clearly publicly and instead, deferred to her Administmtion and Community false, inflammatory, misleading and husband. 0 COMUNITA RIO Affairs, said it would be a "giant leap adverse to the economic interests of "I'm really afraid to say anything ADES E PRIORlDADES of faith" to assume Paint Shop Pond my client. Demand is made that you that will get me into trouble," she material had been dumped in Natiek. issue a formal written retraction of said. "Nothing from the college has 0111 these comments in the next issue of Abutter Joe Sheridan absolutely eito das necessidades de been shipped to any place," said the 'Wellesley Townsman.' Noticesis refutes Maffei's allegations that the bas de 1998-1999 deveram Monahan. further given that any similar Bradys accepted fill from Paint Shop \ prefeitura espera ter According to Monahin, the extent r neste prograni de mora- remarks attributed to Pond, or anywhere else. of contaminated material removal you am at your funther peril," wrote attorney Howard "I've been living here since evora beneficial principal- Paint Shop Pond, while 1950, fron under Smith. prior to that I worked around here. I rendas haixas e inoderatas. college ownership, was limited to a Tbrough his receipt of the thrat- have never seen anything dumped in ide de atividades incluindo epatnicnt of[Environmnental publiCas,' e servicos pihli- ening letter, Kaltofen joins many of that area that didn't come from ithe Protection supervised disposal of the area residents who have publicly Maffei properlyl," said Sheridan. I SCvOCC nao puder atender blue-green soil in 199 I to a certiled criticized the systematic filling of t Dana Reed sees Mejc* rvat lucslionario de site in Canada. DEP1 environmental Mitfei pmperty over the past fir ' as a ploy to shift the focus away p tr, em vez de expressar sua analyst Cynthia Widener acknowl- lo com o Deariento de decades. The Maffeis have steadfast- from the current investigation. edged that in the college's olficial iingham, MA (Tel. 620-4852). ly maintained that in the 40 years "They're pushing the real focus of msponse to the question of soil they have owned the property, noth- the whole situation away from what removal, Wellesley College olficials ing but what they perceived to be as it really is - that they've had a dirty had indicated them was none, but not clean din was accepted on the prop- landfill there," he said. according to Malfei. ety. Kaltofen has his suspicions as While Waldo Maffei Inc. has not Those who have questioned the well. Kaltolen, however, is relerring actually followed through on any of dumping activity on the site have to a hiyer of soil found on the Maffei its recent threats of litigation, the res- E DO also been contacted by the Maffei by Sommer Environmental idents have been advised by state propeny attorneys. Tchnologies ]ic., the licensed site Rep. Doug Stoddart (R-Natick) and IN THE "Any time anybody has tried to by Waldo Matfli state Sen. Cheryl Jacques (D- proessional hired put pressure on, they have been very inc, Needham) that they could be protect- HING? aggressive legally," said Protect East ed by recent legislation designed to The Ilour acre proptly has bLen Natick Group Chairman Dana Reed. under a cleanup order by the shield individuals who speak out on Abutters press case issues that affect their community. Departmntic of Environmental "It's one thing to draft the letter to Dana and his wife Holly, along Protectionsince.March JI95'fhe site scare somebody,-it's another to actu- with former Selectman John Moran, was clasilied as a Tier i site, not ally file suit," said Stoddart. Brady property abutters Joe and qualifying for lie active DEP super- Section 59H of Chapter 231 of vision that a Tier I classitication Helen Sheridan and St. Martin, have all oeceived letters from Waldo the Massachusetts General Laws, would entail. Under a Tier It desig- more commonly known as the Anti- Malei Inc.'s lawyers. natioin, a licensed site professional is Slapp law, protects citizens from The Reeds were warned that any responsible lor the assessment and suits that am tiled against people to cleanup o' the property. false accusations that were damag- Fron its subsurface investigation ing to the Malfei reputation and see Soil, page 23

udeits as much as d. in Creative Arts rofessionals gain a MONDAY NIGHT -aie the arts into all FOOTBALL imsii yutih criten, yo1.? neighbovhood dvfealth 7ood Stoe '10t Wings 25 SI ' ASEC CORPORAT1M 1515 Hancock Street, 4t or QUINCY, MASSACHUSETTS 02169-5234

DATE 7JOB NO. (617) 479-4440 ATTENTION,?,%O577 yffvy>M© 3AW Wh/hT&/ A&~ /r TO ft O RE: A k1 W A

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WE ARE SENDING YOU ELAttached L Under separate cover via __the following items: l Shop drawings L Prints E Plans 13 Samples Ei Specifications D Copy of letter E) Change order L

COPIES DATE NO. DESCRIPTION

THESE ARE TRANSMITTED as checked below: L For approval D Approved as submitted l Resubmit copies for approval F For your use l Approved as noted El Submit - copies for distribution

" As requested EL Returned for corrections LO Return - corrected prints " For review and comment l L FOR BIDS DUE 19 F-i PRINTS RETURNED AFTER LOAN TO US REMARKS ScA F4V0, Jr Cr+2 9~( f- / (rr 7 t7?S7 rAE5 4 E Va b( & ?tup1'AP4nTi01fiA ( 6ff

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C01JIMONWEALTH OF MASSACHUSETriY EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION TEN COMMERCE WAY, WOBURN, MA 01801 781-932-7600

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary

DAVID B. STRUHS Commissioner

September 30, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paincshop Pond, Route 135, DEP RTN 3-0462; REVISED SCOPE OF WORK APPROVAL

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a document entitled MCP Phase Il Comprehensive Human Health Risk Assessment Revised Scope of Work, Former Henry Woods Paint Factory Site, Wellesley, Massachusetts (the Revised Scope of Work), dated September 8, 1997 and prepared by Menzie-Cura & Associates, Inc. on behalf of Wellesley College. The Revised Scope of Work replaces a Scope of Work dated June 9, 1997 which was previously approved by DEP on July 2, 1997. This approval letter for the Revised Scope of Work is intended to replace the prior approval.

DEP has reviewed the the Revised Scope of Work and has found it to be well prepared, organized and thorough. We have the following comments/conditions:

1. The Revised Scope of Work identifies background concentrations in surface water which will be revised when additional background surface water data is collected. It is important to note that background concentrations cannot be attributable to another release and must conform to the definition of background in the Massachusetts Contingency Plan at 310 CMR 40.0006. In this case particularly, a background cyanide concentration in surface water is identified. Cyanide is not routinely detected ' Printed on Recycled Paper

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A 106 Central Street Wellesley, Massachusetts 02181-8201 (781) 283-2305 FAX (781) 283-3696

September 18, 1997

Ms. Laurel Mackay Deputy Regional Director Bureau of Waste Site Cleanup

Dear Ms. Mackay:

I am writing in response to your August 26, 1997 letter concerning the tasks required to complete the Phase II work associated with the former Henry Wood's and Sons Paint Factory Site. Based on commitments made by the Department, Wellesley College intends to proceed with the response actions outlined in your letter, once a consensus is reached among the facilitation group as to an appropriate scope of work.

The cooperative effort of the Department and the College appear to be moving this project forward through the MCP process, and this is certainly a welcome outcome. I was concerned, however, about the statement in your letter that "the Department continues to consider the College to be a party with potential liability under M.G.L. c. 21E for up to three times all response action costs incurred by the Department, as well as for natural resource damages and any damage to real or personal property".

I understand from Barry Monahan that he raised this issue at the August 28, 1997 joint facilitation meeting, and that he was told that it was not the Department's intent to seek triple damages, although the Department as a matter of law reserved all its legal rights, and recognized that Wellesley College also reserved all of its legal rights. Mr. Monahan indicated that there was acknowledgment by various senior DEP officials of the cooperative efforts of the College, and that those officials confirmed that this was not a situation where the Department intended to seek multiple damages. Further, Mr. Monahan understood that DEP would assess the appropriateness of any cost recovery action only at the conclusion of the project, and that this assessment would take into consideration the unique circumstances presented by this project. The College has likewise agreed to reserve its legal options pending the next steps. L. Mackay (2)

We look forward to seeing further progress made on this project, and are grateful for the cooperative effort that has developed between the Department and the College.

Sincerely yours,

Ren6 Stewart Poku Interim Vice President for Finance and Administration

RSP:jm To: Cynthia *dner@BWSC SMP@DEP NERO Cc: Paul Giddings@BWSC SMP@DEP NERO Bcc: SCANNAD From: Lawrence Immerman@BWSC SMP@DEP NERO Subject: re: Wellesley Date: Monday, September 15, 1997 6:47:57 EDT Attach: Certify: N Priority: Normal Defer until: Expires: Forwarded by:

DEP-5 (screened at 45-50 ft. b.g.) DEP-6 (screened at 10-15 ft. b.g.)

DEP-5 and 6 are couplets located between the Morses Pond wells and the Wellesley College Dist. Cntr. Bldg.

D P- and P- 4 located ff o wellfiel acce road ong he form C chituats± Aquadct fo print. Both is are re ed 20-25 ft g. (a re usalV'and were dr

Steve Ross's DEP well (don't know his designation of this well) is located beween MW--5 and Morses Pond well at bank of Ice House Pond, screened :at.30- 35 ft, b.g.

That's it

Larrv b *1.'~1-uC'v'-~ / fMMONWEALTH OF MASSACHUS S 2~tz7zr/3 C CUTIVE OFFICE OF ENVIRONMAAL AFFAIRS 3 DEPARTMENT OF ENVIRONMENTAL PROTECTION Senator William X. Wall Experiment Station

ARGEO PAUL CELLUCCI TRUDY COXE Governor Sccretary

DAVID B. STRUHS Commissioner

MEMORANDUM

TO: Larry Immerman, BWSC, NERO

FROM: Kenneth Hulme, Deputy Director, DEP-WES

THROUGH: Dr. Oscar C. Pancorbo, Director, DEP-WES

SUBJECT: Analytical Results for the Wellesley samples.

DATE: September 16, 1997

Enclosed are the validated analytical results for the samples from Wellesley, Morses Pond. The sampling round consisted of 2 samples to be analyzed for arsenic, chromium and lead, EPA Method 200.7. Also included is a copy of our second-level quality assurance (QA) review, completed by Robert Serabian, Quality Assurance Officer, DEP-WES. If you have any questions about these data, please contact me at 508 682-5237, ext. 313.

Lawrence Experiment Station: 1887 - 1989 * National Historic Civil Engineering Landmark 37 Shattuck e Lawrence, * FAX (508) 688- * Telephone (508) Street Massachusetts 01843 0352 682-5237 'DEP on the World Wide Web: http://www.magnet.state.ma.us/dep' COMMONWEALTH OF MASSACHUSETTS eCUTnVE OFFICE OF ENVpImnAL AFFAiRS 'IEARTMENT OF ENVIRONAMT. PROTECTION Senator WiliamX Wall Experiment Station

WILLIAM F. WELD TRUDY CC0 Governor Secreta

ARGEO PAUL CELLUCCI DAVID B. STRUT LL. Governor Crmmission

SECOND-LEVEL QUALITY ASSURANCE (OA) REVIEW OF WES ANALYTICAL DATA

TO: LQItr( J-vfoghv~WE'I OP-Wo,ocvl FROM: Robert Serabian, Quality Assurance Officer, DEP-WES- THROUGH: Kenneth Hulme, Deputy Director, DEP-WES PROJECT: Morses PoI weiIIesj - LAB SAMPLE ID #(s): q9-soqie, 9so DATE:

* Analyte(syMethod(s): .. 9.A * Sample matrix (matrices): drinking water (tap) wastewater sludge finfish drinking water (dist system) soil shellfish surface water sediment air filter ground water liquid waste air cartridge tube wastewater influent (raw sewage) solid-waste air canister wastewater effluent landfill leachate * Sample(s) collection method: grab automated sampler (e.g., ISCO) spoon dedicated bailer other (describe) e I * Did WES provide prepared containers and dedicated sampling equipment? Yes No * Were samples collected in proper containers? / Yes No * Were samples collected under chain-of-custody? Yes No * Were samples properly pserved? i Yes No

A Preservative(s): - HCI H2SO4 NaOH / HNO Ascorbic Acid 'Z Ice (Temp. at receipt "C) ()ther (describe)_-

Lawrence Experiment Station: 1887 - 1989 * National Historic Civi Engineering Landmark s7 Shattuck Seet * Lawrence, Massachusetts 01843 * FAX (508) 688-0352 * Telephone (508) 682-5237 DIVISION OF ENVIRONMENTAL ANALYSIS LLIAM X. WALL EXPERIMEN TATION Lawrence Experiment Station: I 1989

SPECIAL ANALYSIS

City/Town Wellesley Collector. Immerman Source A Morses Pond DEP-5 Source B Morses Pond DEP-6 Source C Matrix: Approved: k,// -Conc. Units: mg/L Dissolved (Field Filtered) Date

rL 97-3098 97-3099 9/5/97 9/5/97 9/5/97 9/5/97

Arsenic < MDL- < MDL EPA 200.7 9/10/97 0.010 Chromium < MDL < MDL EPA 200.7 9/10/97 0.001 Lead < MDL < MDL EPA 200.7 9/10/97 0.007

Remarks: p-jviclsuly\speciaL312 MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF ENVIRONMENTAL ANALYSIS WILLIAM X. WALL EXPERIMENT STATION Lawrence Experiment Station 1887-1989

QUALITY CONTROL DATA

City/Town: Wellesley

Collector: Immerman

Remarks:

Matrix: Water

Conc. Units: mg/L, Dissolved

SAMPLE JANALYTE jRCSINACCURACY, MDL METHOD ID j __ _ % RECOV ERY mg/L _ _

' Sample Duplicate Range LFB QCS LFM

97-3099 As < MDL -< MDL 94 98 94 0.010 EPA 200.7 97-3099 Pb < MDL < MDL 101 100 99 0.007 EPA 200.7 97-3099 Cr < MDL < MDL 99 100 97 0.001 EPA 200.7

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E S 0=E (IC em MMONWEALTH OF MASSACHUS E ECUTIVE OFFICE OF ENVIRONME AL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Senator William X. Wall Experiment Station

ARGEO PAUL CELLUCCI TRUDY COXE Govemor Secretary

DAVID B. STRUHS Commissioner

MEMORANDUM

TO: Steven Ross, BWSC, NERO

FROM: Kenneth Hulme, Deputy Director, DEP-WES

THROUGH: Dr. Oscar C. Pancorbo, Director, DEP-WES

SUBJECT: Analytical Results for the Wellesley samples.

DATE: August 19, 1997

Enclosed are the validated analytical results for the samples from Wellesley, Morses Pond. The sampling round consisted of 4 samples to be analyzed for metals, EPA Method 200.7. Also included is a copy of our second-level quality assurance (QA) review, completed by Robert Serabian, Quality Assurance Officer, DEP-WES. If you have any questions about these data, please contact me at 508 682-5237, ext. 313.

Lawrence Experiment Station: 1887 - 1989 e National Historic Civil Engineering Landmark 37 Shattuck * Lawrence, * FAX (508) 688- * Telephone (508) Street Massachusetts 01843 0352 682-5237 'DEP on the World Wide Web: http://www.magnet.state.ma.us/dep' -. COMMONWEALTH OF MASSACHUSETTS EXECUTV OFFICE OF ENVIRO AL AFFAIRS IeaTMENT4K]PAT~NTOFENVIRO~q OF PTEintPROTECTiON on Senator William XWalExperiment Station

WILLIAM F. WELD TRUDY Cor Governor Secretar

ARGEO PAUL CELLUCCI DAVID B. sTRUH Lt. Governor Comni..ne

SECOND-LEVEL QUALITY ASSURANCE (OA) REVIEW OF WES ANALYTICAL DATA

TO: s-4- igRosgWsC_- ore- w&v6otrj FROM: Robert Serabian, Quality Assurance Officer, DEP-WES THROUGH: Kenneth Hulme, Deputy Director, DEP-WES PROJECT: Mor'eeS P04d- weI1ws/e4t 1511 T9 LAB SAMPLE ID #(s): 4usjcjg9- DATE:

* Anulyte(sy/Mthod(s): ph,:. E P e4.bDS4 roe~ 7?.-.. - - ,.. * -, * Sample matrix (matrices):'I."-1 '- %imii! drinking water (tap) wastewater sludge finfish drinking water (dist. system) soil shellfish surface water sediment air filter ground water liquid waste air cartridge tube wastewater influent (raw sewage) solid-waste air canister wastewater effluent landfill leachate * Sample(s) collection method: / grab automated sampler (e.g., ISCO) spoon dedicated bailer other (describe) * Did WES provide prepared containers and dedicated sampling equipment? ,Yes. / No

* Were samples collected in proper containers?- - - No . Were samples collected .under chain-of-custdy? No e Were samples properly preserved? . Yes No A Preservative(s): HC H2SO4 aGH

V HNO3 - _- _Ascorbic Acid it/ Ice (Temp. at receipt-y *C) Ottier (describe)______

Lawrene Experment Station:187 - 18 * tiona Histori Cid Enginemring Landawk 3r Shattuck Steet 0 LaU cs, Mawsahusett 015643 * FAX (506 666-03a * Telphen (60 687 - Were samples analyzed within EPA-prescribed holding times?. Yes No

Were samples analyzed appropriate methods? / Yes No

* Are the final results expressed in the correct concentration units? Z Yes No

e Were the final concentration values adjusted to reflect dilutions, splits, or dry weight factors? Yes VNo NA (not applicable)

a Were quality control tests performed at required frequency and were their results within acceptance criteria?

A Calibration check: Yes No NA a Lab fortified matrix (LFM): Yes No NA

£ Quality control sample (QCS) - Yes No NA a Lab fortified blank (LFB): I/ Yes No NA A Surrogate standards recoveries: Yes :No. .NA A Laboratory blanks: 4/ Yes No NA a Laboratory duplicates: Yes No NA a Matrix spike/matrix spike duplicates: Yes No . NA £ Method detection limits documented: flesNo NA A Method detection limits adjusted to reflect dilution: Yes L/ No NA A Trip blank: Yes No i/ NA

A Other-

* Are data validated at the Tier H Level using EPA Region I Guidelines and MSCA QAPP? t' Yes No

* Are Data Qualified? Yes (circle qualifier below) No J: Estimated Data N: Presumptive evidence of presence of material NJ: Presumptive evidence of the presence of material at an estimated quantity PND: Precision not determined .2 R: Sample results rejected due to deficiencies in quality control U: The mtarialiwas analyzed for, but not dected. The asioclatId nmerical value-is thiesample detection limit or adjustei sample detection limit. UJ: The material was analyzed for, but not detected. The reported detection limit is estimated because quality control criteria were not met.

ADDITIONAL COMMENTS ON THE DATA:

W:ffic*%riev - DIVISION OF ENVIRONMENTAL ANALYSIS WILLIAM X. WALL EXPERIME STATION Lawrence Experiment Station: 7-1989

SPECIAL ANALYSIS

City/Town , Wellesley Collector' S. Ross Source A Morses Pond MW 8A Source B Morses Pond MW 8B Source C Morses Pond MW 8C Matrix: Water Approved: Conc. Units: mg/L, Dissolved Date

97-2531 97-2532 97-2533 8/8/97 8/8/97 8/8/97 8/8/97 8/8/97 8/8/97

Chromium < MDL 0.002 < MDL EPA 200.7 8/8/97 0.001 Arsenic 0.018 0.024 < MDL EPA 200.7 8/8/97 0.010 Lead < MDL < MDL < MDL EPA 200.7 8/8/97 0.007

Remarks: p-jvie\suy\special275 DIVISION OF ENVIRONMENTAL ANALYSIS -S. 1~ WILLIAM X. WALL EXPERIME= STATION Lawrence Experiment Station: W7-1989

SPECIAL ANALYSIS

City/Town Wellesley Collector S. Ross Source A Morses Pond MW 8D Source B Source C Matrix: Water Approved: ______Conc. Units: mg/L, Dissolved Date P y7-,

97-2534 t, I 8/8/97 8/8/97

Chromium < MDL EPA 200.7 8/8/97 0.001 Arsenic < MDL EPA 200.7 8/8/97 0.010 L ead < MDL EPA 200.7 8/8/97 0.007

Remarks:

pjvicsully\special276 MASSACH TTS DEPARTMENT OF ENVIR hIENTAL PROTECTION DIVISION OF ENVIRONMENTAL ANALYSIS WILLIAM X. WALL EXPERIMENT STATION Lawrence Experiment Station 1887-1989

QUALITY CONTROL DATA

City/Town: Wellesley

Collector: S. Ross

Remarks:

Matrix: Water

Conc. Units: mg/L, Dissolved

Sample Duplicate Range LFB QCS LFM

97-2534 Chromium

Remarks:

\jviehqc\Z27 Approved: Ad_ Date: -- :/f c~. -

'mm lie 4 n EaSt coast EngineeTing, INC. L

September 15, 1997

Wellesley College 106 Central Street Wellesley, MA 02181

Attention: Mr. Barry Monahan

Reference: Results of Surface Water Sampling Program, Public Beach, Lake Waban, Wellesley, MA

Dear Barry:

Please find the enclosed analytical data for surface water samples collected on August 29, 1997 at the Public Beach at Lake Waban in Wellesley, Massachusetts. This monitoring program was conducted for the protection of swimmers in Lake Waban and as described in the Remedial Action Measure (RAM) Completion Report dated July 17, 1996.

The two surface samples were collected at similar locations as in May, June and July, 1997, and during the 1995/1996 monitoring programs. Sample SWS-1 was collected between the beach and the dock at a depth between 0 to 2 feet of water; this sample location represents a depth at which young children would be exposed during recreational uses. Sample SWD- 1 was collected at the end of the dock at a depth between 4 to 6 feet of water representing the area where young adults might frequent. Prior to sample collection, the water was agitated to represent swimming conditions. Samples were delivered to R.L Analytical and analyzed for total lead, total and hexavalent chromium and total cyanide. The laboratory data is attached.

As shown on Table 1, the concentrations for total and hexavalent chromium, lead and cyanide were similar for both sample locations; the total chromium concentrations were <0.03 mg/I, hexavalent chromium concentrations were <0.02 mg/I, cyanide concentrations were <0.0 1 mg/l, and the lead concentrations were <0.04 mg/l.

In comparison with earlier sampling events, the concentrations of these compounds were similar or less than the concentrations observed during prior sampling events.

P. O. Box 745 1 56A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 Mr. Barry Monahan Wellesley College September 15, 1997

Rage 2

Also, the surface water of Lake Waban was measured on August 29, 1997 and recorded as elevation 108.66 M.S.L.

This completes the 1997 surface water monitoring program for the public swim area. This program will be re-established at the beginning of and during the 1998 swimming season. Should you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal cc: Ms. Cynthia Weidner, Massachusetts DEP John E. McElhinney, Esq., Ropes & Gray Dr. Katz, Wellesley Board of Health Mr. John Magenheimer, Wellesley Natural Resource Commission TABLE 1

SURFACE WATER RESULTS FOR PUBLIC BEACH LAKE WABAN, WELLESLEY, MASSACHUSETTS' (Results are in mg/)

SWS-1' SWS-2 2

I 5/29/97 6/30/97 |- 7/29/97 8/29/97 5/29/97 6/30/97 7/29/97 8/29/97

Total Lead 0.0045 0.0127 0.0133 <0.04 0.0138 0.0070 0.0083 <0.04

Total Chromium <0.002 <0.03. 0.0083 <0.03 <0.020 <0.03 0.0076 <0.03

Hexavafent Chromium <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02

Cyanide <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.0

NOTES: 1. SWS-l collected at a depth of water 0-2 feet. 2. SWD-l collected at a depth of water 4-6 feet. 3. Closure Level developed for lead and based on an assessment of potential risks from exposure to water is 0.180 mg/l 4. Analytical results represent samples collected under simulated swimming conditions (i.e., bottom sediments were stirred prior to sampling). 5. Surface waterelevation, measured June 8, 1997, was elevation 108.63 M.S.L; June 30, 1997 was elevation 108.68 M.S.L.; July 29, 1997 was elevation 108.32 M.S.L; and August 29, 1997 was elevation 108.66 M S L. R.I. Analytical

Specialists in Env ronmental Services

CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 8/29/97 Attn: Ms. Christine LeBlanc Date Reported: 9/08/97 156A Front St. PO Box 745 P.O. #: Marion, MA 02738 Work Order #: 9708-03408

DESCRIPTION: TWO SURFACE WATER SAMPLES - WELLESLY COLLEGE 8/29/97

Subject sample(s) has/have been analyzed by our laboratory with the attached results.

Reference: All parameters were analyzed by U.S. EPA approved methodologies. The specific methodologies are listed in the methods column of the Certificate Of Analysis

If you hav any questi< regarding this work, or if we maybe of further assistance, please contact us.

enc: of Custody

R. Analytical Laboratories, Inc. 41 illinois Ave. Warwick, RI 02888. (401) 737-8500 - Fax: (40) 738-1970 c

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September 9, 1997

Natural Resource Commission 525 Washington Street Wellesley, MA 02181-5992

Attention: Mr. John Maggenheimer

Reference: Notice of Intent, Implementation of Access Control Measures at the Former Paint Factory Site, Wellesley, Massachusetts

Dear John:

East Coast Engineering, Inc. is submitting, on behalfof Wellesley College, the enclosed Notice of Intent for the above-referenced site. In accordance with requirements of the Department of Environmental Protection (DEP), access control measures must be instituted and maintained to restrict access in areas where paint pigment and elevated concentrations of metal and cyanide are present in the soil and wetland muck in the wetlands east and southeast of the former paint factory, and exceed established levels.

To minimize contact with these soils, the work proposed includes installing a six-foot chain link fence to restrict access to the northern and southern wetlands. A detailed description of the proposed activities are provided in the attached Immediate Response Action document and accompanying plan.

Essentially, the majority of the work outlined herein will be conducted iri the uplands and buffer zone to the resource area; only in select locations will the work involve activity in the resource areas namely the wetlands east and southeast of the paint factory. During the course of these activities, all precautions will be taken to minimize disruption of wetlands and resource areas. A complete description of project activities and associated locations is presented in Attachment 1.

Thank you for your immediate attention to this matter. We look forward to the Commission's review.

Sincerely, EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

Enclosure cc: Mr. Barry Monahan, Wellesley College Department of Environmental Protection, Northeast Regional Office, Division of Wetlands Cynthia Weidner, Department of Environmental Protection, Northeast Regional Office Jack McElhinney, Esq., Ropes & Gray

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 OMMONWEALTH OF MASSACHUSET# \)CL EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS ('EA-rPkt ST ( eiz DEPARTMENT OF ENVIRONMENTAL PROTECTIO Metropolitan Boston - Northeast Regional Office

ARGEO PAUL CELLUCCI Governor TRUDY COXE Secretary

DAVID B. STRUHS Commissioner

September 8, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462; $COPE OF WORK CONDITIONAL APPROVAL

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a document entitled Proposed Scope of Work to Define the Extent of Sediment Contamination in Lake Waban, Wellesley, Massachusetts (the Scope of Work), dated July 17, 1997 and prepared by East Coast Engineering, Inc. on behalf of Wellesley College. The Scope of Work was submitted subsequent to a series of facilitated meetings over the past eight months between representatives of DEP and Wellesley College, under the guidance of Ms. Susan Santos of Focus Group, to discuss the need for and scope of additional Phase 11activities at the subject site.

CONDITIONS OF APPROVAL

DEP reviewed the Scope of Work and accompanying site plan CSR-1. This site plan depicts the locations of all proposed sampling points in Lake Waban. We understand that sediment samples for chemical analysis will be collected at locations shown on site plan CSR-1 in support of the human health risk assessment, the ecological risk assessment, and the delineation of the extent of contamination in Lake Waban. Cynthia Weidner of DEP provided comments on the Scope of Work to Christine LeBlanc of East Coast Engineering, Inc. during a meeting on August 5, 1997, during subsequent phone conversations, and Q Printed on Recycled Paper Page 2 during a facilitation meeting on August 28, 1997. Ms. Weidner discussed with you and Ms. LeBlanc the following conditions of approval:

1) A detailed Bathymetric Survey will be performed at Lake Waban by a contractor hired by DEP prior to the collection of sediment samples. Based on the results of the Bathymetric Survey, specific sediment sampling locations may be modified. For example, if the Bathymetric Survey reveals that there are two "bowls" at the bottom of the lake, then a 3 foot sediment boring may be needed at the botttom of each.

2) Information was found relating to the restoration of the lake shores at Wellesley College during the 1930s and provided to DEP on August 14, 1997 and August 21, 1997. According to a letter dated January 5, 1935 to the President of the College, fill was proposed to be placed in/at the lake at three locations. Ms. LeBlanc has indicated there is no information available which states that the fill placed in these areas contained paint pigments or other debris from the former paint factory which was demolished in the early 1930s. However, to be protective, DEP believes it is necessary to characterize the filled areas in order to determine whether contamination is present which could result in ecological- or human exposures. As such, DEP is requiring the following changes to the Scope of Work (please note that the locations discussed below are shown on the site plan attached to the January 5, 1935 letter):

" Move the location of a 3 foot sediment boring to the "Beach" area where construction of a "bench" was proposed in 1935. The detailed Bathymetric Survey may aid in determining the limits of the filled area at this location.

" Move the location of a 3 foot sediment boring to the "Reception of Steps at the Shore of the Lake" to investigate a location where "substantial fill" was proposed to be placed.

* Move the location of a 3 foot sediment boring to the "Vicinity of Public Bathing Platform" where "narrow fill" was proposed to extend the waterfront path.

3) We understand that a Cooling Water System at the College presently operates (during summer months only) by extracting cool water from the deepest portion of Lake Waban and discharging the water to a cove at the outlet of the lake. We are concerned that contaminants in sediments or surface water in the lake could be transported through the system. In order to evaluate this concern, a 3 foot sediment boring must be advanced immediately adjacent to the intake structure for the Cooling Water System. A cooling water (effluent) sample must be collected at the discharge point of the Cooling Water System. An attempt should also be made to collect a sediment sample at the outfall of this structure.

4) We understand that a dam controls the water level in Lake Waban and is located at the outlet stream. The locations of dams and other potential sediment deposition areas are important to consider in the selection of sampling locations, since sediments (which may be contaminated) may settle out preferentially at certain locations. Sediment borings must be advanced to a depth of three feet and samples collected in the outlet stream immediately upstream of the dam and downstream of the dam at the next area where water moves slowly and sediments deposit. Since contamination has likely been present in the lake for over 100 Page 3 years, historical information regarding the location and usage of the current dam and any prior dams, as available, must also be provided. Our goal is to evaluate the impacts of the contamination from the former paint factory. The knowledge of how water moved through the area in the past will help in determining where to sample. These data will provide the information needed to evaluate what the impacts are.

As part of the Phase II Assessment to determine the extent of contamination, attenuation of sediment contamination must be determined. If contamination relating to the paint factory is found at the furthest downstream point in exceedence of "background" concentrations, additional sampling may be required. We believe that the Scope of Work approved by this letter appears to represent a reasonable effort towards delineating the extent of contamination in sediments. As discussed during technical facilitation, this Scope of Work may not necessarily represent all required assessment work necessary to accomplish this goal if contaminants exceeding "background" levels are found at the most downstream point.

5) The fate and transport of contaminants through the continued migration of sediments must be evaluated for long-term impacts at downstream locations in the Final Phase il Report. The following future events and/or changes in site conditions must be- evaluated: 1) future construction projects which may alter water flow, e.g., the proposed construction at the Morses Pond culvert; 2) flood events; 3) the influence of dams and surface water elevation control points on sediment migration; and 4) the potential for future erosion of upland soils into the lake/stream system.

6) DEP and Wellesley College have agreed to implement the Lake Waban sampling program starting this September. Sampling has been proposed in Lake Waban as described in a document entitled Approach to Environmental Risk Characterization for Aquatic, Wetland, and Terrestrial Environments Associated with the Paintshop Pond Site, prepared by Menzie- Cura & Associates, Inc. and dated August 15, 1997. Since this proposal may not be approved in time for the proposed Fall sampling event, the following sampling activities are approved by this letter:

0 52 sediment samples will be collected from Lake Waban as shown on site plan CSR-1 and appropriate reference areas and will be analyzed for metals, grain size and SEM/AVS.

* 15 surface water samples will be collected from Lake Waban at the locations described in the above-referenced proposal, and will be analyzed for water quality parameters, total metals and dissolved metals.

a A minimum of four surface water blank samples will be collected during sampling activities in Lake Waban.

APPROVAL

Given the above conditions, DEP approves the Scope of Work. East C0 ast Erineering, INC.s @

September 8, 1997 &uP, Ic

SWellesley College 106 Central Street Wellesley, MA 02181

Attention: Mr. Barry Monahan

Reference: Public Records Relative to the Former Henry Woods Paint Factory, Wellesley College, Wellesley, MA

Dear Barry:

As we discussed, and as requested by Mr. Marco Kaltofen, enclosed please find the following documents relative to the former Paint Factory site. These documents are to be on file and maintained by the Wellesley Library.

- Report of Phase I Sampling/Analysis, prepared by GHR Engineering, Inc., and dated April 1983; - Report of Phase II Assessment, prepared by GIHR Engineering, Inc., and dated November 1987; - Addendum to the Phase II Report, prepared by GHR Engineering, Inc., and dated March 1990; - Supplemental Report to the Phase II Assessment, prepared by SAIC Engineering, Inc., and dated August 1992; - "Status Report Additional Assessment at the Former Henry Woods Paint Factory," prepared by East Coast Engineering, Inc., and dated January 27, 1997; and - Spring 1997 Groundwater Sampling Program, prepared by East Coast Engineering, Inc., and dated September 2, 1997.

I have also enclosed a post-card for your signature informing Mr. Kaltofen as to the location of the this public information depository for this project,

If you have any questions, please contact me.

Sincerely,

EAST COAST ENGINEERING, INC.

sne R. LeBlanc Principal

ce Ms, Cynthia Weidner, Department of Environmental Protection, Northereast Region Ms. Susan Santos, FOCUS Group

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 Stephen Junson@BWSC SMP@DEP NERO Karen Stromberg@BWSC PS@DEP NERO Rodene Lamkin@BWSC SMP@DEP NERO Cc: tl§5c Bcc: From: Cynthia Weidner@BWSC SMP@DEP NERO Subject: Paintshop Pond Partial PIP Date: Wednesday, September 3, 1997 13:02:41 EDT Attach: Certify: N Priority: Normal Defer until: Expires: Forwarded by:

Marco Kaltofen requested that an information repository for the Paintshop Pond site (RTN 3-0462) be established at the Wellesley Public Library in lieu of submittal of a formal PIP petition. He doesn't want to make the site a PIP site, but he does want information about the site to be available and accessible to people in the community who are interested.

We decided on which past documents were going to be placed in the repository, rather than copying the whole site file. Future reports, as they're generated, will be placed in the repository. Marco requested that he be notified when any new information is available.

Wellesley College has agreed to this arrangement and will be handling it from now on. - CW cc. The File 0 East Coast Engineering, INC. @01

September 3, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Results of the Spring 1997 Groundwater Sampling Program at the Former Henry Wood Sons Company, Wellesley, Massachusetts

Dear Cynthia:

On behalf of Wellesley College, enclosed please find a copy of the report entitled "Interpretive Report of Results of the Groundwater Sampling Survey, Spring 1997." This document presents the results of the groundwater survey and interpretation of analytical results including the groundwater samples collected from the newly installed wells east of the former Paint Factory near the Sports Complex, and south of Paintshop Pond. The next scheduled semi-annual groundwater sampling will be conducted in October 1997.

If you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. Jack McElhinney, Esq., Ropes & Gray Dr. Wendy Heiger-Bernays, Menzie-Cura & Associates Ms. Judith Nickelson, Natural Resource Commission Dr. Robert Katz, Wellesley Board of Health

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 East Coast Engineering, INC. /A

September 2, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Implementation of Access Control Measures at the Former Paint Factory, Wellesley, MA

Dear Cynthia:

On behalf of Wellesley College, please find the enclosed document entitled, "Immediate Response Action Plan, Implementation of Access Control Measures at the Former Henry Woods Sons Paint Factory, Wellesley, Massachusetts". Based on results of sampling data which identifies elevated concentrations of metals and total cyanide in the northern and southern wetlands adjacent to the former Paint Factory, it is recommended that additional access restriction to surficial contamination in the wetland soils is warranted. These factors, and the Colleges's position to protect overall public health and safety at this property, are the basis by which this IRA plan is developed.

As we discussed at our meeting on August 28, 1997, we will be filing a Notice of Intent with the Wellesley Natural Resource Commission and meeting with NRC representatives on September 25, 1997. Following the issuance of the Order of Conditions, if any, and your approval of this Plan, the College will proceed in securing a contractor to erect the fence.

If you have any questions, please contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Ms. Susan Santos, FOCUS Group Wendy Heiger-Bernays, PhD., Menzie-Cura & Associates Jack McElhinney, Esq., Ropes & Gray

P. O. Box 745 15 6A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 IMMEDIATE RESPONSE ACTION PLAN IMPLEMENTATION OF ACCESS CONTROL MEASURE FORMER HENRY WOODS SONS PAINT FACTORY WELLESLEY, MASSACHUSETTS

Prepared for:

Wellesley College 106 Central Street Wellesley, Massachusetts 02181

Prepared by:

East Coast Engineering, Inc. 156A Front Street, P.O. Box 745 Marion, Massachusetts 02738-0745

September 2, 1997 IMMEDIATE RESPONSE ACTION PLAN IMPLEMENTATION OF ACCESS CONTROL MEASURE FORMER HENRY WOODS SONS PAINT FACTORY WELLESLEY, MASSACHUSETTS

INTRODUCTION

This document presents the Immediate Response Action Plan (IRAP) to provide additional access restriction to surficial contamination in the wetland soils adjacent to property formerly occupied by the Henry Woods Paint Factory in Wellesley, Massachusetts. The Immediate Response Transmittal Form BWSC-105 is attached.

The overall approach for this site is to develop a remedial strategy to provide protection of human health, welfare and the environmental while simultaneously maintaining the natural beauty and habitat diversity of the area. This document presents the measures to minimize contact with accessible pigments/contaminated soil. The need for long-term remedial measures is being analyzed and will be presented at a later date.

BACKGROUND

The Henry Woods Paint Factory site encompasses nearly 30 acres consisting of uplands, wetlands and surface water bodies. Paintshop Pond abuts the site on the west and Lake Waban on the southeast. Waban Brook meanders through the site interconnecting the two surface water bodies. Building foundations, rubble, and debris from the former Paint Factory remain along the western portion of the site. Although the area has developed into an attractive habitat, waste pigments and soil containing metals are randomly present throughout the property.

Over the decades since the factory ceased operations, the areas has been re-vegetated with mixed hardwood, pine and hemlock forests in the upland area and wetlands associated vegetation in the area adjacent to Paintshop Pond and Lake Waban. The area supports a wide range of local wildlife and fish species. Although the area developed into an attractive habitat, the soils in and around the factory contain paint pigments and associated metals. To limit access to this areas and thus minimize

East Coast Engineering,Inc. September 2, 1997 IRA, Implementation ofAccess ControlMeasure, PaintFactory Page 1 contact with these soils, fencing was installed around the perimeter of the former Paint Factory in December 1994. Passive recreational activities, such as walking, jogging, bicycling, fishing, and bird watching are performed around Lake Waban.

RESPONSE ACTIONS CONDUCTED TO DATE

Assessment and remedial activities have been conducted at, and in the vicinity of the former Paint Factory since the mid-1970's. A compilation of documents describing this site is provide on the attached Fact Sheet.

Characterization of the wetland sediments is contained in a report entitled "StatusReport, Additional Assessment at the Former Henry Woods PaintFactory."

PROPOSED RESPONSE ACTIONS

The proposed response actions will include access restrictions via fencing, sign posting to warn trespassers of the site hazards and upgrading existing fencing to limit trespassers from entering onto the former Paint Factory site. Each of these measures is described in greater detail below.

Fencing

Six foot chain link fencing will be installed to restrict access to trespassers. The location of the proposed fence is show on Drawing IRP-4. This proposed fencing scheme allows the continued passage of walkers/joggers through the jogging path from the Boat Ramp and the walking path, but restricts access to northern and southern wetlands areas where wetland soils and muck and Brook sediments contain elevated concentrations of metals and cyanide.

Access to the northern wetland (Area A) will be restricted by the six (6) foot chain link fence installed along the northern portion of the walking path (beginning at the existing fence), and traverse south along the walking path to the jogging path. Once at the jogging path, the fence will follow be installed along the northern edge of the jogging path in a westerly direction, pass the culverts, and connecting to end of the existing fence. Access to the southern wetland (Area B) will be restricted by the same type fence installed along the eastern berm of the former impoundment, beginning at the southern end at the wetland and traversing northward to the jogging path. At the path, the fence will be installed on the southern side and traverse eastwar ntfI . A gate will be provided to cessmonitoring wel s C4 south of the jogging path. Xo ktut CAA V-VJ L'o 6-9- od2s3o f4 o-E ro To provide further access restriction within the former Paint Factory area, an is a means of keeping C'W people from going around the ends of the fence which extend into Paintshop Pond, barbed wire

East Coast Engineering, Inc. September 2, 1997 IRA, Implementation ofAccess Control Measure, Paint Factory Page 2 strands at 12" intervals will be extended an additional thirty (30) feet into the Pond and secured to either a wooden stake or metal pole (Areas C and D).

Signage

Signs will be posted on the new fencing. The signs will be legible from a distance and read, "Warning Lead Chromate Deposits - Keep Out".

The campus police will conduct periodic (daily visits at a minimum) inspections of the former Paint Factory area to ensure that locks and fencing are secured. A walk-through the enclosed area will be addressed several times a week to ensure that trespassers are not present. A log will be maintained of security checks and problems, if identified. Should any people be found at the site, they will be removed from the property immediately.

SCHEDULE

The Immediate Response Action Plan will be implemented within four (4) weeks of receiving DEP approval of this IRAP and receipt of an Order of Conditions by the Wellesley Natural Resource Commission, if applicable.

East Coast Engineering, Inc. September 2, 1997 IRA, Implementation ofA ccess Control Measure, PaintFactory Page 3 IMMEDIATE RESPONSE ACTION PLAN FACT SHEET FORMER PAINT FACTORY SITE, WELLESLEY, MASSACHUSETTS

Name/Address of Party(ies) Wellesley College Conducting Response Action: 106 Central Street Wellesley, Massachusetts 02181 Contact: Mr. Barry Monahan (617) 283-2386

Description of Release, Site Paint pigment from the former paint manufacturing Conditions and Receptors: operations. Complete documentation for this site is provided in the following reports: - Report of Phase I Sampling/Analysis, April 1983 * Report of Phase II Assessment, November 1987 - Addendum to the Phase II Report, March 1990 - Limited Diagnostic Survey, May 1990 - Supplemental Report to the Phase II Assessment, August 1992 . "Status Report Additional Assessment at the Former Henry Woods Paint Factory," January 27, 1997

Description of Remediation Installation of fencing around the perimeter of the northern Waste Actions: and southern wetland to minimize contact with metal contaminated soil. The proposed fence locations and supporting documentation is attached.

Environmental Monitoring An on-going groundwater program is conducted at the site. Plan: Security inspections of the site will be conducted daily.

Applicable Permits: No federal or state permits are necessary; a Notice of Intent will be filed with the Wellesley Natural Resource Commission for work to be conducted within 100 feet of the wetland areas and other areas subject to the Wetlands Protection Act.

Proposed Schedule: The fencing will be installed upon approval of the attached IRAP and receipt of the Order of Conditions, if required by the Wellesley NRC. A projected schedule for completion is late November 1997.

Licensed Site Professional: Christine R. LeBlanc, License No. 4669

East Coast Engineering,Inc. September 2, 1997 IRA, Implementation ofAccess Control Measure, PaintFactory Page 4 IMMEDIATE RESPONSE ACTION (IRA) TRANSMITTAL FORM BWSC-105 Massachuse epartment of Environmental P ction BWSC-105 Bureau of W Site Cleanup

Release Tracking IMMEDIATE RESPONSE ACTION (IRA) Number TRANSMITTAL FORM Pursuant to 310 CMR 40.0424 - 40.0427 (Subpart 462

Release Name: Former Henry Woods Sons Paint Factory (optional) Street: Route 135 Location Aid:

City/Town: Wellesley, Massachusetts ZIP 02181-8294 Code Check here if a Tier Classification Submittal has been provided to DEP for this Release Tracking Number. Check here if this location is Adequately Regulated, pursuant to 310 CMR 40.0110-0114. Specify Program:[ CERCLA 7 HSWA Corrective Action 7 Solid Waste Management L RCRA State Program (21C Facilities) Related Release Tracking Numbers That This IRA B. THIS FORM IS BEING USED TO: (check all that apply)

Submit an IRA Plan (complete Sections A, B, C, D, E, H, I,J and K). 7 Check here if this IRA Plan is an update or modification of a previously approved written IRA PlaR~te 2 d9 7 Submit an imminent Hazard Evaluation (complete Sections A, B, C, F, H, I, J and K). SEP 1997 7 Submit an IRA Status Report (complete Sections A, B, C, E, H, 1,J and K). [ PIN T-EAS I EGION 7 Submit a Request to Terminate an Active Remedial System and/or Terminate a Continuing Response io keto61 d dress an Imminent Hazard (complete Sections A, B, C, D, E, H, I, J and K). L Submit an IRA Completion Statement (complete Sections A, B, C, D, E, G, H, I, J and K). You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. C. RELEASE OR THREAT OF RELEASE CONDITIONS THAT WARRANT §ktify Media and Receptors Affected: (check all that 7 Air 7 Groundwater E Surface Water Sediments Soil apply) Wetland 7 Storm Drain Svrfe L Private Well 7 Public Water Supply 7 Zone 2 7 Residence

7 School 7 Unknown 7 Other Specify Identify Conditions That Require IRA, Pursuant to 310 CMR 40.0412: (check all that 7 2 Hour Reporting Condition(s) apply) 7 72 Hour Reporting Condition(s) 7 Substantial Release Migration Other Condition(s) Describe Presence of sediments containing heavy metals and cyanide

Identify Oils and Hazardous Materials Released: (check all that 7 Oils 7 Chlorinated P Heavy Metals apply) Otes Seiy 7 Others Specify: D. DESCRIPTION OF RESPONSE ACTIONS: (check all that apply) Deployment of Absorbent or Containment L Assessment and/or Monitoring Onil L Excavation of Contaminated Soils 7Temporary Covers or Caps Q Re-use, Recycling or Treatme nt 7 ioremediation Q On Site Q Off Site Est. Vol.: cubic yards LIExtractionSoil Vapor Describe LIStructure Venting System 7 Store Q On Site Q Off Site Est. Vol.: cubic yards z or NAPL L Landfill Q Cover (Q Disposal Est. Vol.: cubic yards j rundwater Treatment 7 Removal of Drums, Tanks or Conta DinersebAirSparging Describe 7 Temporary Water Supplies SECTION D IS CONTINUED ON THE NEXT PAGE. Revised 2/24/95 Supersedes Forms BSWSO-005, 006, 010 (in part) and 0 11 Page 1 of 3 Do Not Alter This Form msachuseaDepartment of Environmental P ction BWSC-105 aau of Site Cleanup

Release Tracking IEDIATE RESPONSE ACTION (IRA) Number kNSMITTAL FORM Pursua nt to 310 CMR 40.0424 - 40.0427 (Subpart 462 D. DESCRIPTION OF R SPONSE ACTIONS (contin ed): Removal of Other Contaminated Media Temporary Evacuation or Relocati on of D Residents Specify Type and g~Fencing and Sign Posting Volume: H Other Response Actions Describe

B Check here if this IRA involves the use of Innovative Technolo gies (DEP is interested in using this information to aid in creating an Innovative Technologies Clearinghouse). Describe T h kvi er nn W E. TRANSPORT OF REMEDIATION WASTE: (if Remediation Waste has been sent to an off-site facility, answer the following questions) Name of Facility: Town and State: Quantity of Remediation Waste Transported to Date: F. IMMINENT HAZARD EVALUATION SUMMARY: (check one of the following) Q Based upon an evaluation, an Imminent Hazard exists in connection with this Release or Threat of Release. j Based upon an evaluation, an Imminent Hazard does not exist in connection with this Release or Threat of Release. J Based upon an evaluation, it is unknown whether an Imminent Hazard exists in connection with this Release or Threat of Release, and further assessment activities will be undertaken.

f Based upon an evaluation, it is unknown whether an Imminent Hazard exists in connection with this Release or Threat of Release. However, response actions will address those conditions that could pose an Imminent Hazard. G. IRA COMPLETION STATEMENT:

H Check here if future response actions addressing this Release or Threat of Release will be conducted as part of the Response Actions planned for a Site that has already bee n Tier Classified under a different Release Tracking Number, or a Site that is identified on the Transition List as described in 310 CMR 40.0600 (i. e., a Transition Site, which includes Sites with approved Waivers). These additional response actions must occur accordin g to the deadlines applicable to the earlier Release Tracking Number (i. e., Site ID Number). State Release Tracking Number (i. e., Site ID Number) of Tier Classified Site or Transition Site: If any Remediation Waste will be stored, treated, managed, recycled or reused at the site following submission of the IRA Completion Statement, you must submit either a Release Abatement Measure (RAM) Plan or a Phase IV Remedy Implementation Plan, along with the appropriate transmittal form, as an attachment to the IRA Completion Statement.

H. LSP OPINION: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. in my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge, information and belief,

> if Section B of this form indicates that an Immediate Response Action Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal;

> if Section B of this form indicates that an Imminent Hazard Evaluation is being submitted, this Imminent Hazard Evaluation was developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, and the assessment activity(ies) undertaken to support this Imminent Hazard Evaluation complies(y) with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000;

> if Section B of this form indicates that an Immediate Response Status Report is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L c. 21E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal:

> if Section B of this form indicates that an Immediate Response Action Completion Statement or a Request to Terminate an Active Remedial System and/or Terminate a Continuing Response Action(s) Taken to Address an imminent Hazard is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal. SECTION H IS CONTINUED ON THE NEXT PAGE.

Revised 2124/95 Supersedes Forms BWSC-005, 006, 010 (in part) and 011 Page 2 of 3 Do Not Alter This Form Ma sachusfl Department of Environmental P ction BWSC-105 Bu au of W Site Cleanup W

ilEDIATE RESPONSE ACTION (iRA) 40.042Release Tracking TR NSMITTAL FORM Number Pursuant to 310 CMR 40.0424 - 40.0427 (Subpart D)462 H. LSP Opinion (contin ed):

I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

r2 Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the ppi able provisions thereof. VOF LSP Christine R. LeBlanc LSP# 4669 Stamp: 4 Name:

Telephone 508-748-2460 Ext.: _ CHRISTINE R. LEBLANC FAX: 508-748-2553 No.4669 (optional) Signatur T

Date: _7

I. PERSON UNDERTAKING IRA: Name of Wellesley College Organization: Name of Barry Monahan Title: Vice President for Administration Contact: Street: 106 Central Street

City/Town: Wellesley State MA ZlPCode 02181-8294

Telephone: 617-283-2386 Ext.: FAX: (optional) - ~---- Check here if there has been a change in the person undertaking the IRA. J. RELATIONSHIP TO RELEASE OR THREAT OF RELEASE OF PERSON UNDERTAKING IRA: (check one) RP or PRP Specify @ Owner Q Operator Q Generator () Transporter Other RP or PRP. [ Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2)

[ Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s 5(j)) ] Any Other Person Undertaking IRA Specify Relationship- K. CERTIFICATION OF PERSON UNDERTAKING IRA:

1, Barry Monahan , attest under the pains and penalties of perjury (i) that I have personally examined and armfinifiliiWti thdifhidf~iiiion contain inflissulihrittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal, I/theperson or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

By: _ _ _ 400. Title:Vice President for Administration ture) For Barry Mon ban Date: (print name of person or entity recorded in Section I)

Enter address of the person providing certification, if different from address recorded in Section J: Street:

City/Town: State ZIP Code:

Revised 2124/95 Supersedes Forms BWSC-005, 006, 010 (in part) and 011 Page 3 of 3 Do Not Alter This Form ',P 0l4. 572 530 US iostal Service Receipt for Certified Mail 4; No Insurance Coverage Provided. Do not use for Intemational Mail (See reverse) Sent to

Street &Numer

Post Ofice, State, & ZIP Code

Postage $ Certified Fee

Special Delivery Fee

Restricted Delivery Fee Retum Receipt Showing to Whom & Date Delivered cRehum Receip Showingo Whom, Dam, AAddresse's Add o TOTAL Postage &Fees $ P t_ k_ r D _ t__ _ _

a, osmaMo6a 12 A*MONWEALTH OF MASSACHUSET tr., EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston - Northeast Regional Office

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary

DAVID B. STRUHS Commissioner

CERTIFIED MAIL

August 26, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan, Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462;

Dear Mr. Monahan:

As you know, the Department of Environmental Protection (the Department or DEP) and Wellesley College have participated in a series of facilitated meetings since December of 1996, under the guidance of Ms. Susan Santos of Focus Group, to discuss the need for and scope of additional Phase il activities at the Paintshop Pond disposal site. I am pleased that nearly all areas of disagreement have been resolved as part of this process and that we are now able to proceed toward the completion of field work at the site. As part of the facilitation process, DEP and Wellesley College representatives agreed that the following tasks were needed to complete the Phase 11:

" Finalization of a Soils/Property Management Plan

* Additional environmental sample collection on property owned by Wellesley College

* A Bathymetric Survey of Lake Waban

* Additional environmental sample collection in Lake Waban

10 Commerce Way Woburn, Ma. 01801 * Phone (617) 932-7600 e Fax (617) 932-7615 * TDD # (617) 932-7679 K) Printed on Recycled Paper * Laboratory analyses of samples collected from Lake Waban and property owned by Wellesley College

0 A Phase 1i Human Health Risk Characterization for the entire site, as defined by the facilitation group, including Lake Waban

* A Phase 11Environmental Risk Characterization for the entire site, as defined by the facilitation group, including Lake Waban

As a result of the discussions between the College and DEP in the facilitation process, the Department understands that the College has agreed to proceed with the following Phase I response actions:

* Finalization of a Soils/Property Management Plan

* Additional environmental sample collection on property owned by Wellesley College

Additional environmental sample collection in Lake Waban

. Laboratory analyses of samples collected from property owned by-Wellesley College

* A Phase i Human Health Risk Characterization for the entire site, ias defined by the facilitation group, including Lake Waban

o A Phase 11Environmental Risk Characterization for the entire site, as defined by the facilitation group, including Lake Waban

The Department further understands that the College has agreed' to commence these response actions in September., 1997, and complete them by December, 1998.

As you are also aware from our earlier discussions, DEP intends to conduct and/or arrange for response actions at the site, pursuant to M.G.L. c. 21E, sections 4 and 8. The Department is notifying the College by this letter that DEP intends to perform the response actions not being performed by Wellesley College that the parties agreed were necessary to complete Phase It., namely:

* Laboratory analyses of samples collected from Lake Waban

* A Bathymetric Survey of Lake Waban

DEP intends to perform the response actions described above in a coordinated effort with the College. The Department further understands that the College has agreed to collect the necessary samples in accordance with the Scope of Work documents prepared by Wellesley College and approved or conditionally approved by DEP for this purpose, and that the College will deliver the samples to a DEP representative on site. Such a coordinated effort will facilitate the completion of Phase 11activities at the site. 9 e

Notwithstanding the coordinated approach described above, the Department continues to consider the College to be a party with potential liability under M.G.L. c. 21E for up to three times all response action costs incurred by the Department, as well as for natural resource damages and any damage to real or personal property. The Department's performance of the above-mentioned response actions, or any additional response actions deemed necessary by the Department, is with full reservation of all statutory and common law rights and without any admission of liability. Notwithstanding any provision herein, this notice does not create any binding obligations on the part of DEP or enforceable rights by the College against the DEP.

If you have any questions relative to this notice, you should contact me at the letterhead address or at (617) 932-7600.

Very ruly yours,

Laurel Mackay Deputy Regional Director Bureau of Waste Site Cleanup

'/'WIJesley BOH, ATTN: Dr. Robert Katz zzast Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738. ATTN: Christine LeBlanc venzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsfdrd,-MA 01824, ATTN: Dr. Wendy Heiger-Bernays Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsfdrd, MA 01824, ATN: Charlie Menzie DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Grav, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: Paul Galvani, Esq. DEP/NERO, ATTN: Jeffrey Mickelson, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos Office of the Attorney General, Environmental Protection Division, 200 Portland Street, Boston, MA 02114, ATTN: Matthew Brock, Esq. Wellesley College, 106 Central Street, Wellesley, MA 02181-8258, Attn: William Reed, Vice President of Finance and Administration DEP/NERO, ATTN: Stephen Johnson DEP/NERO, ATTN: Cynthia Weidner Fast Coast Engneering, INC.

August 11, 1997

Wellesley College 106 Central Street Wellesley, MA 02181

Attention: Mr. Barry Monahan

Reference: Results of Surface Water Sampling Program, Public Beach, Lake Waban, Wellesley, MA

Dear Barry:

Please find the enclosed analytical data for surface water samples collected on July 29, 1997 at the Public Beach at Lake Waban in Wellesley, Massachusetts. This monitoring program was conducted for the protection of swimmers in Lake Waban and as described in the Remedial Action Measure (RAM) Completion Report dated July 17, 1996.

The two surface samples were collected at similar locations as in May and June, 1997, and during the 1995/1996 monitoring programs. Sample SWS-1 was collected between the beach and the dock at a depth between 0 to 2 feet of water; this sample location represents a depth at which young children would be exposed during recreational uses. Sample SWD-1 was collected at the end of the dock at a depth between 4 to 6 feet of water representing the area where young adults might frequent. Prior to sample collection, the water was agitated to represent swimming conditions. Samples were delivered to R.I. Analytical and analyzed for total lead, total and hexavalent chromium and total cyanide. The laboratory data is attached.

As shown on Table 1, the concentrations for total and hexavalent chromium and cyanide were similar for both sample locations; the total chromium concentrations ranged between 0.0076 mg/l (SWS-2) and 0.0083 mg/l (SWS-1) and the hexavalent chromium and cyanide concentrations were <0.02 mg/l and <0.01 mg/l, respectively. The lead concentration of 0.0133 mg/l in the shallow surface water sample (SWS-1) was slightly greater than the lead concentration of 0.0083 mg/l in the deeper water sample (SWS-2). The lead values were less than the established Closure Level for the public beach of 0.180 mg/l for lead based on an assessment of potential risks from exposure to water.

In comparison with earlier sampling events, the concentrations of hexavalent chromium and cyanide were the same as observed in May and June, 1997. The lead and total chromium concentrations,

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 Mr. Barry Monahan WelesleyCollege A'uust 11 1997

Page 2 were similar to those concentrations observed in May and June, 1997 in both the shallow and deep surface water locations.

Also, the surface water of Lake Waban was measured on July 29, 1997 and recorded as elevation 108.32 M.S.L.

The next scheduled surface water monitoring date for metals and cyanide is August 30, 1997. If you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

TABLE 1

SURFACE WATER RESULTS FOR PUBLIC BEACH LAKE WABAN, WELLESLEY, MASSACHUSETTS' (Results are in mg/I)

SWS-11 SWS-2 2

5/29/97 6/30/97 7/29/97 5/29/97 6/30/97 7/29/97

Total Lead 0.0045 0.0127 0.0133 0.0138 0.0070 0.0083

Total Chromium <0.002 <0.03 0.0083 <0.020 <0.03 0.0076

Hexavalent Chromium <0.02 <0.02 <0.02 <0.02 <0.02 <0 02

Cyanide <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

NOTES: 1. SWS-1 colleded at a depth of water 0-2 feet. 2. SWD-1 colleed at a depth of water 4-6 fed. 3. Closure Level developed for lead and based on an assessment ofpotntial risks from exposure to water is 0.180 mg/. 4. Analytical results represemt samples collected under simulated swimming conditions (i.e., bottom sedimmtits were stirred prior to sampling). 5. Surface water elevation, measured June 8, 1997, was elevation 108.63 M.S.L.; June 30, 1997 was elevation 108.68 M.S.L.; and July 29, 1997 was elevation 108.32 M.S.L. 4. - -~

I R.I. Analytical

Specialists in Environmental Services

CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 7/29/97 Attn: Ms. Christine LeBlanc Date Reported: 8/05/97 156A Front St. PO Box 745 P.O. #: Marion, MA 02738 Work Order #: 9707-02608

DESCRIPTION: TWO SURFACE WATER SAMPLES

Subject sample(s) has/have been analyzed by our laboratory with the attached results.

Reference: All parameters were analyzed by U.S. EPA approved methodologies. The specific methodologies are listed in the methods column of the Certificate Of Analysis

If you nly uektions regarding this work, or if we maybe of further assistance, please contact us.

Vice enc: of Custody

RI. Analytical Laboratories, Inc. 41 Illinois Ave., Warwick, RI 02888, (401) 737-8500 - Fax: (401) 738-1970

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East Coast Enteering, INC.

July 29; 1997

Town of Wellesley WETLANDS PROTECTION COMMITTEE Town Hall 525 Washington Street Wellesley, Massachusetts 02181

Reference: Notice of Intent for Proposed Environmental Sampling Program at Lake Waban, Wellesley, Massachusetts

Dear Commission Members:

East Coast Engineering, Inc. is submitting, on behalf of Wellesley College, the enclosed Notice of Intent for proposed environmental sampling activities in Lake Waban. The proposed project includes sample collection for sediment, surface water, aquatic plant tissue and fish. These data will be used to assess risk to public health and the environment.

The proposed activities will be conducted within a resource area, land under a waterbody/waterway, and in resource area bordering land subject to flooding. A complete description of the project activities is provided in Attachment 1.

Thank you for your attention to this filing. We look forward to the Commission's review.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. John E. McElhinney, Esq., Ropes & Gray Ms. Cynthia Weidner, DEP, NERO, Division of Waste Site Cleanup DEP, NERO, Wetlands Division

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2400 Fax: (508) 748-2553 310 CMR: DEPARTMENT OF ENVIRONMENTAL PROTECTION

Forms: continued

NOTICE OF INTENT FEE TRANSMITTAL FORM

DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF WETLANDS AND WATERWAYS

NOTICE OF INTENT (NOI) APPLICANT: PRO PERTY OWNER Ne Wellesley College Name partment of Environmental Manlagement street 106 Central Street Street 100 Cambridge Street city/Town Wellesley, MA city/T Boston, MA state MA Zip code 02181 State MA Zip code 02202 Phone Number (617) 283-2386

PROJECT LOCATION: Street/Lot Number Off Route 135 City/Town Wellesley

DEP FILE NUMBER (if available)

NOI FILING FEE DISPUTED FEE

Total NOI Filing Fee: $ 250.00 Total Diputed Fee: $

(as determined in Notice of state Share of Filing Fee: S 112.50 insufficient Fee letter from (1/2 of fee in excess of $25.00) conservation commission)

City/Town share of state share of Fee: $

Filing Fee: s 137.50 (1/2 of total disputed fee)

City/Town Share of Fee:$ (1/2 of total disputed fee)

INSTRUCTIONS:

1. Send this Fee Transmittal form and a check or money order, payable to the commonwealth of Massachusetts, to the DEP Lock Box at:

Dept. of Environmental Protection Box 4062 Boston, MA 02211

2. Attach a copy of this form to the Notice of Intent submitted to the local conservation commission.

3. Attach a copy of this form and a copy of the DEP check to each of the Notice of Intent forms submitted to the DEP regional office.

11/2U/92 310 CMR - 280.56 EAST COAST ENGINEERING, INC. 3249

COMONWEALT 00003249 07/28/97

Commonwealth of Massachu5etts,

*******$112.50

PL-YMOUTH SAVINGS BANK 340 FRONT STREET P.O. BOX 517 3249 EAST COAST ENGINEERING, INC. MARION, MA 02738 156-A FRONT STREET P.O. BOX 745 MARION, MASSACHUSETTS 02738 53-7044/2113 (508) 748-2460 00003249

PAY ONE HUNDRED TWELVE AND 50 / 100 Dollars DAT! AMCUNT

07/28/97 *******$112.50 TO THE ORDER Commonwealth of Massachusetts, OF

"00 3 2490" 1: 2 L L3?0L,48::o ES 00 3 L 3"' -) IL.U I.L-I '- . ' - i; . i 10.99: continued

DEP File No. w (To be provided by DEP) Form 3 City/Town Wellesley Applicant -Wellsley Collee

Commonwealth Department of of Massachusetts Defense United States Notice of Intent of Ameica Under the Massachusetts Wetlands Protection Act, G.L. c. 131, §40 and Application for a Department of the Army Permit

Part I: General InformaonStreet Address Off Route 1 35, Wellesley College, Wellesley, MA Lot Number . . Sample collection for Sediment, 2. Project: Type ______Description Surfacc Water, Aquatic

(See Aitahmen- 1 fnr prnjonl- roecrr-ipt-Cn)

3. Registry: County Norfolk Current Book & Page Certificate (if Registered Land) 4. Applicant Wellesley College Tel. (617) 2B3-72386 Address 106 Central Street Welleslvey MA 0p1A1 5. Property Owner Commonwealth of Mass. Tel. (617) 727-3180 Address nept- of Fnwr Manarmont, 1n rn mbr-,rleyd - Pnnstnn, MA 02202 6. Representative East Coast Enc-l'neerin .Tnc. TeL{ 5)174q--2460 Address 156A Front St., P.O. Box 745, Marion, MA 02738-0745 7. a. Have the Conservation Commission and the Deparanent's Regional Office each been sent, by certified mail or hand deliver, 2 copies of completed Notice of Intent, with supporting plans and documents? Yes) No - b. Has the fee been submitted? YesfX No r c. Total Filing Fee Submitted $250 .00 d. CityiTown Share of Filing Fee $ i / -UU State Share of Filing Fee 12.50

(Sent to Cityfown) ('A of fee in excess of S25, sent to DEP) e. Is a brief statement attached indicating how the applicant calculated the fee? YesX No M

4/l/94 310 CMR - 411 EAST COAST ENGINEERING, INC. 3248

TOWNOFWELL 00003248 07/28/97

Town of Wellesley

*******$137.50

PLYMOUTH SAVINGS BANK 340 FRONT STREET P.O. BOX 517 EAST COAST ENGINEERING, INC. MARION, MA 02738 3248 156-A FRONT STREET P.O. BOX 745 MARION, MASSACHUSETTS 02738 53-7044/2113 (508) 748-2460 00003248 PAY ONE HUNDRED THIRTY-SEVEN AND 50 / 100 DollJi AMOUNT

TO THE 07/28/97 +******$137.50 ORDER Town of Wellesley OF

AUThORIZE SINATURE

liOO 3 2L,I 1 2 L L I 70L,8 E500 3 L 31" 10.99: continued

8. Have all obta e permits, variances and approvals required f cal by-law betn obtained? Yes E No fl

obtained Applied for: Not Applied For:

9. Is any portion of the site subject to a Wetlands Restriction Order pursuant to G.L. c. 131, 40A or G.L. c. 130, §105? Yes C NoM 10. List all plans and supporting documents submitted with this Notice of Intent.

Identifying Nurnber/Letter Title, Date Figure 1 Site Locus (USGS Ouad)

Drawing CSR-1 Coiilation of Procoses Lake Waban Samoling Program, July 1997 Attachment 1 "Notice of Intent for Proposed Environmenital Sampling Program at Lake Waban" (Narrative Project Desc.)

11. Check those resource areas within which work is proposed:

(a) 0 Buffer Zone (b) Inland l Bank' Land Sabject to flooding Q Bordering Vegetated Wedand" Bordering [f Land Under Water Body & Waterway' Isolated (c) Coastal M Land Under the Ocean' C Designated Port Area O Coastal Beach' Coast Dune C Barrier Beacn' Coastal Bank C Rocky Intertidal Shore' Salt Mars C Land Under Salt Pond' E Land Containing Shellfish' Fish RunD Ca Likely to involve U.S. Army Corps of Engineers concurrent jurisdiction. See General Instructions for Completing Notice of Intent.

4/l/94 310 CMR - 412 %-) CMR: DEPLAR IMLN I Ut LrIV..%UJNMLLN li L LJI t.- * Ui1

10.99: condnued

12. Is the project within estimated habitat which is indicated on the most recent Estimated Habitat Map of State-Listed Rae Wetlands Wildlife (if any) published by the Natural Heritage and Endangered Species Program?

YES [ I NO [XX ] Date printed on the Estimated Habitat Man NO MAP AVAILABLE [ I (if any) 1997-1998 Edition

If yes, have you sent a copy of the Notice of Intent to the Natural Heritage and Endangered Species Program via the U.S. Postal Service by certified or prioriry mail (or otherwise sent it in a manner that guarantees delivery within two days) no later than the date of the filing of this Notice of Intent with the conservation commission and the DEP regional office?

YES[ I NO I I N/A

If you please attach evidence of timely mailing or other delivery to the Natural Heritage and Endangered Species Program.

part U: Site Description

Indicate which of the following informadotn has been provided (on a plan, in narrative descripdon or calculadons) to clearly and accurately describe existing site conditions.

Identifying Number/Letter' (of plan, naradve or calculations)

Natural Features Attachment 1 Soils

Attachment 1 Vegetadon

Drawing CSR-1 Topography

Attachment 1 /tWG CSR-1 Open water bodies (including ponds and lakes)

N/A Flowing water bodies (including streams and rivers)

N/A Public and private surface water and ground water supplies on or within 100 feet of site N/A Maximum annual ground water elevations with dates and location of test Attachment 1 /DWj CSR-1 Boundaries of resource areas checked under Part 1, Item 1 above Other

Man-made Features:

Drawing CSR-1 Structures (such as buildings, piers, towers and headwalls)

N/A Drainage and flood control facilities at the site and immediately off the site, including culverts and open channels (with inverts), dams and dikes N/A Subsurface sewage disposal systems

N/A Underground utilities

4n1/94 310 CMR - 413 10.99: continued

N/A Roadways and parking areas W

Drawing CSR-1 Property boundaries, easements and rights-of-way

Other

Part m: Work Description

Indicate which of the following information has been provided (on a plan, in narrative description or calculations) to clearly, completely and accurately describe work proposed within each of the resource areas checked in Part I, item II above.

Identifying Number/Letter (of plan, narrative or calculations)

Planview and Cross Section of' N/A Structures (such as buildings, piers, towers and headwalls)

N/A Drainage and flood control facilities, including culverts and open channels (with inverts), dams and dikes N/A Subsurface sewage disposal systems & underground utilities

N/A Filling, dredging and excavating, indicating volume and composition of material Compensatory storage areas, where required in accordance with Part III, 10.57(4) of the regulations. N/A Wildlife habitat restoration or replication areas

Other

Point Source Discharge N/A Description of characteristics of discharge from point source (both closed and open channel), when point of discharge falls within resource area checked under Part I, Item Il above, as supported by standard engineering calculations, data and plans, including but not limited to the following:

IL DeLinedaion of the drainage area cooribudng in the point of discharge:

2. Pre- and Post-development peak run-off frorn the drainage area, at the point of discbarge. for at least the 10-year and 100-year frequency storm:

3. Pre- and post-development rate of infiltadon cont-ibudng in the resource area checked under Part L item 11 above;

4. Estimnated water quality characteristics or pre- and post-development run-off at We point. of discharge.

4/1/94 310 CMR - 414 10.99: condnued part IV: Mitigating Mleasures 0 1. Clearly, completely and accurately describe, with reference to suppordng plans and calculadons where necessary:

(a) All measures and designs proposed to meet the performance standards set fcrth under each resource area specified in Part U or Part M of the reguladons; or

(b) why the presumptions set forth under each resource area specified in Par: 1 or Part I of the regulations do not apply.

C Coastal Resource Area Type: Idenifying number or Zl Inland letter of support Land under a Waterbody/Waterway (LUWW) documents The proposed project consists of the Drawing CSR-1 collection of sediment, surface water Attachment 1 aquatic plant tissue and fish samples from Lake Waban. The sampling will not result in any adverse impacts to the LUWW. (See Attachment 1 for project impact description.)

C Coastal Resource Area Type: Idendfying number or. EX Inland (BLSF) letter of support Bordering Land Subject to Flooding documents According to the FEMA maps for Drawing CSR-1 Wellesley dated 9/5/79, Lake Waban is Attachment 1 BLSF. The sampling of sediment, surface water, plant tissue and fish will not adversely impact the BLSF. (See Attachment 1)

4/1/94 310 CMR - 415 10.99: condnued

0 Coastal Resource Area Type: Identifying number or C Inland letter of support docume nts

2. Clearly, completely and accurately describe, with reference to supporting plans and calculations where necessary:

(a) all measures and designs to regulate work within the Buffer Zone so as to ensure that said work does not alter an area specified in Part 1, Section 10.02(1)(a) of these regulations; or

(b) ' if work in the Buffer Zone will alter such an area, all measures and designs proposed to meet the performance standards establishes for the adjacent resource area, specified in Part II or Part III of these regulations.

C Coastal Resource Area Type Bordered Identifying number or nand By 100-Fezt Discretionary Zone: letter of support documents

4/l/94 310 CMR - 416 10.99: continued

Part V: Additional Informati or a Department of the Army Permit

I. COE Application No. (to be provided by COE) (No COE Permit Required)

(Name of Waterway)

3. Names and addresses of property owners adjoining your property:

4. Document other project alternatives (i.e., other locations and/or construcdon methods, particularly those that would eliminate the discharge of dredged or fill material into waters or wetlands).

5. 8M" x 11" drawings in pianview and cross-section, showing the resource area and the proposed activity within the resource area. Drawings must be to scale and should clear enough for photocopying.

Certification is required from the Division of Water Pollution Control before the Federal Permit can be issued, Certification may be obtained by contacting the Division of Water Pollution Control, 1 Winter Street, Boston, Massachusetts, 02108.

Where the activity will take place within the area under the Massachusetts approved Coastal Zone Management Program, the applicant certifies that his proposed activity compies with and will be conducted in a manner that is consistent with the approved program.

Information provided will be used in evaluating the application for a permit and is made a matter of public record through issuance of a public notice. Disclosure of this information is voluntary; however, if necessary information is not provided, the application cannot be processed nor can a permit be issued.

I hereby certify under the pains and penalties of perjury that the foregoing Notice of Intent and accompanying plans, cuments and supportin ata are true and comple to the best of my knowledge.

Sigaire o Aplicant ?Dae

Signature of Applicant's Representative Date

Farm "Excepuon to ENG Form 43-45 approved by HOUSACE, 6 May 1982" NED 100 (Test) 1 MAY 82 . "Tbis document contains a joint Depamnen of the Army and state of Massachusetts application for a permit to obtain permission to perform activides in WseUnised States waters. The Office of Management and Budget (OMB) tias approved tose quesdons required by the US Army Corps of Engineers. OMB Number 072-0036 and expiration date of 30 September 1983 appies". This statement will be set in 6 point type.

4/1/94 310 CMR - 417 NOTICE OF INTENT FEES

CATEGORY 1 - $55.00 PER ACTIVITY CATEGORY 3 - 5251WER ACTIVITY

A. Any work on a single family residential A. Site preparation for any development lot (addition, deck, garage, pool, shed, excluding single family house (removal driveway) of vegetation, excavation, grading with no construction proposed) B. Site preparation of each single family house lot excluding construction of B. Construction of each building, any part house (removal of vegetation, of which falls in the buffer zone or excavation, grading) resource area (commercial, industrial, institutional, apartments, C. Control of nuisance vegetation on a condominiums) single family hduse lot (removal, Any activities associated with said herbicide treatment, etc.) buildings (site preparations, detention basins, septic systems, parking lots, D. Resource Improvement allowed under utilities, point source discharges, limited project status (10.53 (41]) roadways/driveways other than those reviewable as limited projects) E. Septic system (construction, repair, maintenance, upgrade) C. Construction of each roadway/driveway (not associated with a single family or F. Monitoring well (installation) limited project status)

TOTAL CATEGORY ONE ACTIVITIES D. Hazardous waste cleanup

CATEGORY 2 - $250.00 PER ACTIVITY TOTAL CATEGORY THREE ACTIVITIES

A. Construction of each single family house CATEGORY 4 - $725.00 PER ACTIVITY in the buffer zone or resource area (site preparation, detention basins, A. Each crossing for a limited project utilities, septic systems, roadways, access roadway (commercial, industrial, driveways) institutional, or residential construction other than single family B. Parking lot (any size) dwelling)

C. Beach nourishment B. Construction, modification or repair of a flood control structure (dam, D. Construction, reconstruction, sluiceway, tidegate) maintenance of public utilities in coastal resource areas (10.24 [7a-c]) C. Public or private landfill (creation, electric generating facility, operation, maintenance) underground/overhead utilities) Coastal limited projects D. Sand and gravel operations (excavation, (repair/maintenance or piers buildings, filling, stockpiling) culverts) E. Railroads (new lines or extension of E. Any limited project status filing (10.53 existing lines) [3][a-d][f-1]) F. Control of nuisance vegetation other F. New agricultural or aquacultural than on a single family lot (removal, projects herbicide)

G. Each wetland driveway crossing G. Bridges - except to access a single associated with a single family home family lot (construction, filed for under limited project status reconstruction, expansion, maintenance) (10.53(3e]) H. Raising or lowing of surface water H. Any point source discharge levels

I. Any other activity not described in I. Any alteration of a resource area to Categories 1, 3, 4, or 5 X divert water (clean up hazardous wastes or any other purpose) TOTAL CATEGORY TWO ACTIVITIES $250.00 Jfl Any activities associated with dredging conduct'ed on land under a waterbody, w4aterway or ocean (except associ ed with a new dock)

K. Sewage treatment plant (construction, discharge of effluent)

TOTAL CATEGORY FOUR ACTIVITIES

CATEGORY 5 - $2.00/LINEAR FOOT - $50.00 MINIMUM - $1,000 MAXIMUM

A. Docks, piers, revetments, or coastal/inland engineering structures (construction, reconstruction, repair, replacement and the placement of rip rap on resource areas)

TOTAL CATEGORY FIVE ACTIVITIES

ADD ALL TOTALS

CATEGORY ONE TOTAL

CATEGORY TWO TOTAL S250.00

CATEGORY THREE TOTAL

CATEGORY FOUR TOTAL

CATEGORY FIVE TOTAL

TOTAL FILING FEE $250.00

PERSON CALCULATING FEE SCHEDULE (PRINT)

Christine LeBlanc, East Coast Engineering

ADDRESS

156A Front Street, P.O. Box 745

Marion, MA 02738-0745

TELEPHONE (508) 748-2460

DATE

SIGNATURE 4 -

CONSERVATION COMMISSION VERIFICATION Not ication to Abutters Under e Mass usetts Wetlands ProtectiW ct

In accordance with the second paragraph of Massachusetts General Laws Chapter 131, Section 40, you are hereby notified of the following.

A. The name of the applicant is Wellesley College

B. The applicant has filed a Notice of Intent with the Conservation Commission for the municipality of Welleslev seeking permission to remove, fill, dredge or alter an Area Subject to Protection Under the Wetlands Protection Act (General Laws Chapter 131, Section 40).

C. The address of the lot where the activity is proposed is Work (samoling) is orocosed in Lake Waban, off Route 135, Wellesley, MA

D. Copies of the Notice of Intent may be examined at East Coast Encineerin, Inc. 156A Front Street, Marion, MA 02738-0745 between the hours of 9:00 am and 4:00 nm on the following days of the week: Monday through Friday For more information, call: ( 508 ) 748 - 2460 Check one: This is the applicant 0, representative R, or other 0 (specify):

E. Copies of the Notice of Intent may be obtained from either (check one) the applicant 0, or the applicant's representative , by calling this telephone number ( 508 ) 748 - 2460 between the hours of 9:00 am and 4:00 om on the following days of the week: Monday through Friday

F. Information regarding the date, time, and place of the public hearing may be obtained from Christine R. LeBlanc, East Coast Engineering, Inc.

by calling this telephone number ( 508 ) 748 - 2460 between the hours of 9:00 am and 4:00 um on the following days of the week: Monday throuah Friday Check one: This is the applicant 0, representative R, or other 0 (specify):

NOTE: Notice of the public hearing, including its date, time, and place, will be published at least five (5) days in advance in the Welleslev Townsman (Name of newspaper)

NOTE: Notice of the public hearing, including its date, time, and place, will be published in the City or Town Hall not less than forty-eight (48) hours in advance.

NOTE: You also may contact your local Conservation Commission or the nearest Department of Environmental Protection Regional Office for more information about this application or the Wetlands Protection Act. To contact DEP, call:

Central Region: 508-792-7650 Northeast Region: 617-935-2160

Southeast Region: 508-946-2800 Western Region: 413-784-1100 AFFIDAVIT OF SERVICE

Under the Massachusetts Wetlands Protection Act

T, Barry Monahan, VP for Administration, Wellesley College hereby certify under the pains and penalties of perjury that on_ _ July 31, 1997 I gave notification 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 filed under the Massachusetts Wetlands Protection Act by Welleslev Collece with the Welleslev Conservation Commission on July 30, 1997 for property located at off Route 135 (Welleslev College); Lake Waban

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.

Name Date 0 ABUTTER'S LIST

NOTICE OF INTENT FOR SAMPLING IN LAKE WABAN WELLESLEY COLLEGE, WELLESLEY, MASSACHUSETTS

Walter Hunnewell Willard Hunnewell 845 Washington Street 855 Washington Street Wellesley, MA 02181 Wellesley, MA 02181

Mr. & Mrs. William Stevens, Jr. Nathanael Greene 99 Pond Road 37 Pond Road Wellesley, MA 02181 Wellesley, MA 02181 ATTACHMENT 1 to the NOTICE OF INTENT PROPOSED ENVIRONMENTAL SAMPLING PROGRAM LAKE WABAN, WELLESLEY, MASSACHUSETTS

INTRODUCTION

Wellesley College has been conducting environmental assessment activities at the former Henry Woods Paint Factory property where. waste disposal practices of the 19th century caused contamination of nearby soils, sediments and surface water. Metal-laden sediments are present in Lake Waban off the northern and northeastern shorelines. These contaminated sediments are a direct result of industrial discharges by the former Paint Factory documented in correspondence as early as 1917. The Paint Factory operated on the property adjacent to and northwest of Lake Waban, between the 1850's and 1900's.

Lake Waban is a 108 acre lake located in the Town of Wellesley approximately one-half mile east of the Wellesley/Natick town line. Figure 1 provides a USGS locus of the project area. The Lake is situated approximately 1200 feet south of Route 135 and borders the southwestern portion of Wellesley College. Lake Waban (the Lake) is classified as a Great Pond and as such is owned by the Commonwealth of Massachusetts. As a designated Great Pond, access for recreational uses by residents of Wellesley and local community members is provided.

To assess the extent of metal contamination, both vertically and horizontally of the Lake sediments, and to determine the potential public health and environmental risks in Lake Waban, a comprehensive environmental sampling program is proposed. This program includes sample collection of fish, bottom sediments for chemical, physical and benthic characterization, aquatic plant tissue and surface water. This proposed program was developed, and will be undertaken, by Wellesley College in conjunction with the Department of Environmental Protection. It is expected that this work to begin in the fall of 1997 and continue through the fall of 1998.

PROJECT DESCRIPTION

Lake Waban is used as a recreational resource (i.e. swimming, boating, wading, and fishing) by College students, faulty and personnel, and members of the public. To assess the risk posed through completed exposure pathways, the following sampling program will be undertaken:

East Coast Engineering,Inc. July 29, 1997 Notice of Intent for ProposedSampling Program,Lake Waban, Wellesley, MA Attachment I Page I sampling and data collection of the sediments, and surface water at the known swimming beaches* (i.e. Green Beach, the un-official Slater, Tupelo, and Hunnewell beaches, and Sandy Bottom beaches I and 2);

*The DEP has determined that the Public Beach swim area has been adequately characterized in the previously conducted human risk assessment (December, 1995).

. additional sediment and surface water samples will be collected along the northern shoreline where boats are moored and fishing is conducted;

- additional sediment and surface water samples will be collected along the western shoreline and culvert area where fishing is conducted;

. determination of the fish population and diversity with respect to other nearby similar water bodies; fish tissue, liver and whole body samples will also be collected for analyses;

- determination of the presence of metals in aquatic vascular plants which live in Lake Waban and provide a food source to birds and mammals; aquatic plant tissue samples will also be collected for analyses; and

- determination of the abundance, number of species, and other biological characteristics of the benthic invertebrate community.

The sampling locations are identified on Drawing No. CSR- 1 entitled "Compilation of Proposed Lake Waban Sampling Program."

Sampling Methodologies

Fish To supplement fish tissue data from 1994, fish sampling will be performed using several different techniques to determine variance in species population and diversity. Large-mouth bass and yellow perch will be collected to supplement historical data. It is anticipated that sampling will occur at four near shore locations in the Lake. Fish will be caught using gill nets and poles mobilized from a boat in Lake Waban and from the shoreline. Fish will be identified, measured, and their age determined by an analysis of scales. Thereafter, the fish tissue, liver and whole body samples will be analyzed for metals.

Prior to conducting the program a permit will be obtained from the Department of Environmental Management. Sampling for the aquatic plants will be conducted during the summer.

East Coast Engineering,Inc. July 29, 1997 Notice of Intent for ProposedSampling Program,Lake Waban, Wellesley, MA Attachment ] Page 2 Sediment Surface and deep sediment borings will be advanced throughout the Lake. To develop data to assess a the horizontal extent of contamination and characterize risk, approximately 180 surficial samples (0 to 6 inches into the sediment) will be collected; the vertical extent of contamination will be assessed by advancing 18 deep borings (0 to 3 feet in depth) in the Lake. The sampling program is developed with a larger number of samples to be collected along the northern portion of the Lake since the outfall of the pigment production was situated along the northwestern corner of Lake Waban, and where higher concentrations of metals are expected. Lesser samples will be collected in the southern portion of the Lake

The surficial samples will be obtained by lowering a core barrel from a boat into the muck and sediment to a depth of about 6 inches. The core barrel will be retrieved and the sample placed into an appropriate container. For the deeper borings, a ten foot long four-inch diameter aluminum core barrel will be driven down by mechanical vibration. The core barrel will be driven into native material or a maximum depth of three feet. Again, the barrel will be retrieved and taken to the laboratory for sample selection and metal analysis.

The acid volatile sulfide/simultaneously extracted metals (SEM/AVS) relationship of sediment samples will also be determined. (SEMIAVS relationships greater than "1"are considered indicative of potential exposure to benthic invertebrates that serve as prey base for fish.)

Surface Water Surface water samples will be collected at each beach/swim location and at several locations in the center of the Lake. The shallow water samples will be collected by foot directly off-shore, and the deeper samples will be collected off the boat using a bailer, bomb or bottle sampler. The depth of water will be recorded at each sample location.

In addition to the surface water sampling at the beach areas, surface water sampling will be conducted quarterly for one year at five off shore locations. This information will provide data for comparative purposes between dissolved metals in surface water of the lake to water quality criteria.

Surface water samples will be analyzed for metals and general chemistry parameters.

Aquatic Vascular Plants Many wildlife species (birds and mammals) eat aquatic vascular plants. The presence of metals in these plants could be a route of exposure to these wildlife species. Plants used by food for wildlife will be collected from within Lake Waban and from a reference lake where metals are not believed to be elevated. Six samples will be collected along a gradient of sediment contamination. The plants will be accessed via a boat, or off shore by foot; the plant will be cut and sample placed in a plastic bag. Sampling for the aquatic plants will be conducted during the summer.

East Coast Engineering,Inc. July 29, 1997 Notice of Intentfor ProposedSampling Program, Lake Waban. Wellesley, MA Attachment 1 Page 3 1

Benthics Benthic invertebrate samples will be collected at five shallow (5' depth of water) and five deeper (10' to 20' depth of water) at locations distributed along a concentration gradient of metals in sediments. At each location, three samples will be obtained with a petite-Ponar grab with the work executed off a boat. The abundance, number of species, and other biological characteristics of the benthic invertebrate community will be determined. Sampling for benthics will be conducted during the summer.

DESCRIPTION OF RESOURCE AREAS AND POTENTIAL IMPACTS

The proposed sampling program in Lake Waban falls within the jurisdiction of the Massachusetts Wetlands Protection Act (M.G.L. Chapter 131, Section 40) and the associated regulations 310 CMR 10.00.

Under 310 CMR 10.55, 10.56 and 10.57, Lake Waban consists of three protectable resource areas: (1) bordering vegetated wetland (2) land under a waterbody/waterway, and (3) bordering land subject to flooding, respectively. A brief description of each resource area and the potential impacts from the proposed project is described below.

Land Under a Waterbody/Waterway

Description Resource area "Land Under a Waterbody/Waterway" (LUWW) is the land (ranging from organic muck or peat and fine sediment deposits to rock/bedrock or artificial impervious material (concrete, asphalt)) which is under any creek, rivers, stream, pond or lake. LUWW is likely to be significant to public and private water supply, groundwater supply, flood control, storm damage prevention, prevention of pollution, and to the protection of fisheries and wildlife habitat. As described above, the LUWW in Lake Waban is composed of gravels, sands, fine-grained silts and muck.

Vegetative growth within the LUWW, and in the water, includes floating and upright species of pondweed (Potamogeton, spp.), watermilfoil (Myriophyllum, spp.), and waterlilies (Nymphaea, spp.). Vegetation is sparse in the shallower (0 to 5 feet of water) portions of the Public Beach area due to the sandy bottom and frequent use of the swimming area by the public in the spring and summer months. Although weed harvesting is conducted in the deeper portions of the swimming area (6 to 9 feet of water), upright and floating vegetative growth is persistent.

The northeastern portion of Lake Waban is inhabited by a number of indigenous fish species. Species of fish found include large mouth bass (Micropterus salmoides), small mouth bass (Micropterus dolomieui), bluegill sunfish (Enneacanthus gloriosus), pumpkinseeds (Lepomis gibbosus), chain pickerel (Esox niger), brown bullhead (Ictalurus nebulosus), green sunfish (Lepomis

East Coast Engineering,Inc. July 29, 1997 Notice of Intent for ProposedSampling Program,Lake Waban, Wellesley, MA Attachment 1 Page 4 'a' 0 cyanellus), and golden shiner (Notropis - spp). Other vertebrate species include turtles, frogs and salamanders.

Resource Area Impacts The proposed project will involve the collection of sediment, surface water, aquatic plant tissue and fish samples from Lake Waban. Any disturbances of the water and/or sediment will be temporary, occurring only during collection of the samples.

The sampling is proposed to occur primarily during the early Fall and Summer. With the exception of the chain pickerel, spawning time for the fish found in Lake Waban is late May to early June. The chain pickerel typically spawn in March or early April, however, most species of fish will spawn in the deeper waters towards the center of the Lake, and the spawning of any of these fish will not be impacted by the project.

Bordering Land Subject to Flooding

Description Resource area "Bordering Land Subject to Flooding" (BLSF)... "is an area which floods from a rise in a bordering waterway or waterbody" (100-year flood event). The boundary of BLSF is determined by reference to the most recent flood profile data prepared by the National Flood Insurance Program (NFIP) administered by the Federal Emergency Management Agency (FEMA). According to the FEMA maps for the Town of Wellesley, dated September 5, 1979 (Panel 250255 0005B), Lake Waban is within the 100-year floodplain. The waters of the Lake are designated as Zone A6 which has a calculated 100-year flood boundary at elevation 110. BLSF is likely to be significant to flood control and storm damage prevention.

Resource Area Impacts The sampling of sediment, surface water, aquatic plant tissue and fish will not significantly impact the interests significant to resource area bordering land subject to flooding (BLSF). The sampling will not result in the loss of flood storage and will not adversely impact this resource area.

Bordering Vegetated Wetland

Resource are a Bordering Vegetated Wetlands (BVW) are... "fresh water wetlands which border on creeks, rivers, streams, ponds, and lakes..." BVW are likely to be significant to public or private water supply, to groundwater supply, to flood control, to storm damage prevention, to prevention of pollution, and to protection of fisheries. Areas of BVW exist along the perimeter of Lake Waban, extending from the waters edge to the upgradient shoreline. Plant species within the BVW associated with Lake Waban include cattails, sedges, rushes, pickerel weed in the lower areas and blueberry, azalea, speckled alder, sweet pepper bush shrubs, and red maple saplings in the higher shoreline areas.

East Coast Engineering,Inc. July 29, 1997 Notice of Intent for ProposedSampling Program, Lake Waban, Wellesley, MA Attachment I Page 5 0 0 Resource Area Impacts Vegetation samples will be collected from the BVW associated with Lake Waban. Leaf, twig, and plant tissue samples will be collected by hand and impact to the BVW will be both temporary and negligible.

SUMMARY

This proposed program falls within the jurisdiction of the Massachusetts Wetlands Protection Act and associated regulations 310 CMR 10.00. Specifically, three protectable resource areas are subject to this project including: (1) bordering vegetated wetland (2) land under a waterbody/waterway, and (3) bordering land subject to flooding.

Since the proposed sampling effort will be conducted via boat or foot in the shallower areas, and that any disturbances of the water and/or sediment will be temporary, occurring only during the time of sampling, there will be no impact to the resources areas.

East Coast Engineering,Inc. July 29, 1997 Notice of Intentfor ProposedSampling Program, Lake Waban, Wellesley, IM Attachment 1 Page 6 qM

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SCALE: 1:25 000 FIGURE 1 SITE LOCUS Programa at2 Lake! elsey ascuet 4CLIENT: WELLESLEY COLLEGE

Source: EAST COAST ENGINEERING, INC. Framingham 156A FRONT STREET, P.O. BOX 745 Quadrangle MARION, MA 02738-0745 East Coast Enftneering, INC.

July 17, 1997

Wellesley College 106 Central Street Wellesley, MA 02181

Attention: Mr. Barry Monahan

Reference: Results of Surface Water Sampling Program, Public Beach, Lake Waban, Wellesley, MA

Dear Barry:

Please find the enclosed analytical data for surface water samples collected on June 30, 1997 at the Public Beach at Lake Waban in Wellesley, Massachusetts. This monitoring program was conducted for the protection of swimmers in Lake Waban and as described in the Remedial Action Measure (RAM) Completion Report dated July 17, 1996.

Two samples were collected at similar locations as in May, 1997 and in the 1995/1996 monitoring programs. Sample SWS-l was collected between the beach and the dock at a depth between 0 to 2 feet of water; this sample location represents a depth at which young children would be exposed during recreational uses. Sample SWD- 1 was collected at the end of the dock at a depth between 4 to 6 feet of water representing the area where young adults might frequent. Prior to sample collection, the water was agitated to represent swimming conditions. Samples were delivered to R.I. Analytical and analyzed for total lead, total and hexavalent chromium and total cyanide. The laboratory data is attached.

As shown on Table 1, the concentrations for each analyte were similar for both sample locations; the total and hexavalent chromium concentrations were <0.03 mg/l and 0.02 mg/l respectively, and total cyanide concentrations were <0.01 mg/l. The concentrations of lead in the surface water sample collected in the shallow water, station SWS-1, was 0.0127 mg/l, and for the deeper water sample the concentrations was 0.0070 mg/l. The concentrations of total and hexavalent chromium and cyanide were the same as observed in May, 1997. The lead concentration in the surface water collected in the shallow water increased from the May, 1997 sampling round but decreasing concentrations were found in the sample collected in the deeper water. These values fall below the established Closure Level for the public beach of 0.180 mg/I for lead based on an assessment of potential risks from exposure to water.

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 Mr. Barry Monahan Wellesley College July 17, 1997

Page 2

,Also, the surface water of Lake Waban was measured on June 30, 1997 and recorded as elevation 180.68 M.S.L.

The next scheduled surface water monitoring date for metals and cyanide is July 30, 1997. If you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

y,7

TABLE 1

SURFACE WATER RESULTS FOR PUBLIC BEACH LAKE WABAN, WELLESLEY, MASSACHUSETTS' (Results are in mg/I)

SWS-11 SWS-2

5/29/97 6/30/97 5/29/97 6/30/97

Total Lead 0.0045 0.0127 0.0138 0.0070

Total Chromium <0.002 <0.03 <0.020 <0.03 . Hexavalent Chromium <0.02 <0.02 <0.02 <0.02

Cyanide <0.01 <0.01 <0.01 <0.01

NOTES: 1. SWS-1 collected at a depth of water 0-2 feet. 2. SWD-1 collected at a depth of water 4-6 feet. 3. Closure Level developed for lead and based on an assessment of potential risks from exposure to water is 0.180 mg/l. 4. Analytical results represent samples collected under simulated swimming conditions (i.e., bottom sediments were stirred prior to sampling). 5. Surface water elevation, measured June 8, 1997, was elevation 108.63 M.S.L.; June 30 was elevation 180.68 M.S.L. R.I. Analytical tFn7 Specialists in Environmental Services

CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 6/30/97 Attn: Ms. Christine LeBlanc Date Reported: 7/15/97 156A Front St. PO Box 745 P.O. #: Marion, MA 02738 Work Order #: 9706-01948

DESCRIPTION: FIVE GROUNDWATER SAMPLES - PROJECT: WELLSLEY COLLEGE

Subject sample(s) has/have been analyzed by our laboratory with the attached results.

Reference: All parameters were analyzed by U.S. EPA approved methodologies. The specific methodologies are listed in the methods column of the Certificate Of Analysis

y i questionfregarding this work, or if we maybe of further assistance, please contact us.

James E. ch Vice Presid t enc: Chain f Custody

RI Analvtical Laboratories, Inc. 41 Ilinois Ave, Warwick, RI 02888, (401) 737-8500 - Fax: (401) 738-1970 age 17 of 20 R.I. Analytical Laboratories, Inc. CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 6/30/97 Work Order # 9706-01948

Sample #: 7 SAMPLE DESCRIPTION: SWS-1 COLLECTED 6/30/97 (SURFACE WATER) SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

LEAD 0.0127 MG/L EPA 239.2 7/02197 18:48 KAB age 18 of 20 R.I. Analytical Laboratories, Inc.

CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 6/30/97 Work Order # 9706-01948

Sample #: 8 SAMPLE DESCRIPTION: SWD-2 COLLECTED 6/30/97 (SURFACE WATER) SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

LEAD 0.0070 MG/L EPA 239.2 7/02/97 18:48 KAB i *age 19 of 20 R.I. Analytical Laboratories, Inc.

CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 6/30/97 Work Order # 9706-01948

Sample #: 1 SAMPLE DESCRIPTION: OW-1 COLLECTED 6/30/97 SAMPLE - ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

T. PHOSPHATE (AS P) 3.02 MG/L EPA 365.2 7/08/97 9:15 JLZ TOTAL CYANIDE <0.01 MG/L EPA 335.2 7/03/97 15:30 DMD NITRATE (as N) 2.03 MG/L EPA 353.3 7/03/97 8:15 JLZ CHLORIDE 40 MG/L EPA 325.3 7/08/97 9:45 JLZ TOTAL NITROGEN (as N) 2.17 MG/L EPA 350.1-350.3 7/09/97 15:45 JLZ HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 6130/97 20:00 DMD SODIUM 23.7 MG/L EPA 200.7 7/07/97 9:46 JAH TKN (as N) <0.5 MG/L EPA 351.3 7/09/97 15:45 JLZ NITRITE (as N) 0.14 MG/L EPA 354.1 6/30/97 20:15 JLZ

Sample #: 3 SAMPLE DESCRIPTION: OW-2 COLLECTED 6/30/97 SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

T. PHOSPHATE (AS P) 1.28 MG/L EPA 365.2 7/08/97 9:15 JLZ TOTAL CYANIDE <0.01 MG/L EPA 335.2 7/03/97 15:30 DMD NITRATE (as N) 1.19 MG/L EPA 353.3 7/03/97 8:15 JLZ CHLORIDE 32 MG/L EPA 325.3 7/08/97 9:45 JLZ TOTAL NITROGEN (as N) 1.79 MG/L EPA 350.1-350.3 7/09/97 15:45 JLZ HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 6/30/97 20:00 DMD SODIUM 22.6 MG/L EPA 200.7 7/07/97 9:48 JAH TKN (as N) 0.6 MG/L EPA 351.3 7/09/97 15:45 JLZ NITRITE (as N) <0.01 MG/L EPA 354.1 6/30/97 20:15 JLZ

Sample #: 5 SAMPLE DESCRIPTION: OW-3 COLLECTED 6/30/97 SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

T. PHOSPHATE (AS P) 0.86 MG/L EPA 365.2 7/08/97 9:15 JLZ TOTAL CYANIDE <0.01 MG/L EPA 335.2 7/03/97 15:30 DMD NITRATE (as N) 1.34 MG/L EPA 353.3 7/03/97 8:15 JLZ 4. Wage 20 of 20 R.I. Analytical Laboratories, Inc. CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 6/30/97 Work Order # 9706-01948

Sample #: 5 OW-3 COLLECTED 6/30/97

SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

CHLORIDE 41 MG/L EPA 325.3 7/08/97 9:45 JLZ TOTAL NITROGEN (as N) 1.34 MG/L EPA 350.1-350.3 7/09/97 15:45 JLZ HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 6/30/97 20:00 DMD SODIUM 21.7 MG/L EPA 200.7 7/07/97 9:52 JAH TKN (as N) <0.5 MG/L EPA 351.3 7/09/97 15:45 JLZ NITRITE (as N) <0.01 MG/L EPA 354.1 6/30/97 20:15 JLZ

Sample #: 7 SAMPLE DESCRIPTION: SWS-1 COLLECTED 6/30/97 (SURFACE WATER)

SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

TOTAL CYANIDE <0.01 MG/L EPA 335.2 7/03/97 15:30 DMD HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 6/30/97 20:00 DMD CHROMIUM <0.03 MG/L EPA 200.7 7/02/97 16:12 JAH

Sample #f: 8 SAMPLE DESCRIPTION: SWD-2 COLLECTED 6/30/97 (SURFACE WATER)

SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

TOTAL CYANIDE <0.01 MG/L EPA 335.2 7/07/97 15:35 DMD HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 6/30/97 20:00 DMD CHROMIUM <0.03 MG/L EPA 200.7 7/02/97 16:12 JAH /

East Coast Engineering, INC. SC-1% July 13, 1997

b Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Water Supply Analytical Data, Wellesley College, Wellesley, MA

Dear Cynthia:

As you requested, we are enclosing a copy of the water supply analytical data for Wellesley College. The water sample was collected on May 28, 1997 by SAIC Engineering, Inc. The groundwater sample was analyzed for volatile organics, metals, cyanide and general chemistry parameters; this work was performed by Analytical Balance Corporation.

The concentrations of metals, cyanide, and general chemistry parameters met the Massachusetts Maximum Contaminant Levels and Secondary Maximum Contaminant Levels, where applicable. The concentrations of volatile organic compounds were not identified at levels greater than the detection limit of 0.5 ug/l.

If you have any questions, please feel free to contact me at (508) 74802460.

Sincerely,

EAST COAST ENGINEER G, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College

P. O. Box 745 1 56A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 I , %11" , - 1. - 1 (,.,J ,,, V ." .1 J l L 1 4j , " ' / V , Q

I-. - 4 .SSACHUSETTSDEP/DIVISION OF WATERPLY IOC INORGANICS REPORT (FORM #1 A.3) L PWS INFORMATION: 1. PWS 1Dm: - 3317001 __ 2. City/Town: Wellesley - 3. PWS Name: _Wellesley College 4. PWS Class (circle one): COM NTNC NC 5. DEP Source Code/Location ID 6. SamoIS Location 7 Date Collected 8. Collected by 3317001-00/009 Well 05128197 S. McGrail 9. Is the source treated? Y 10. Was the sample collected after treatment? I1. Manifolded? [YM If appliiabie, list the connected sources: 008/009 12. Routine [x) Special [ J (explain bdlow) Notes: I. LABORATORY ANALYTICAL INFORMATION:

LabName: Analytical Balance Corp. Lab Cert: M-MA022 Subcontracted? Yes Y No Lab Sample ID _97-05-3992 Sub. Lab. Name: _Alpha Analytical Lab Sub. Lab Cert. #,_M-MA086_ _ Lab Symbol: A (Symbols reLate cach analyte to a specific lab - if blank, analysis was pcrfirEd by Analytical Balance Corp.) Composite [ I If applicable, list the composited sources (DEP Source Code/sample locations):

Notes.

Compound Lab Sampie Resul 1MCL etection Analytical Date Analyzed Lab (reulaed) I1D g/L_ mg/L LmtMeto 'Lsymbo ]

Arsenic 3992-1 ND 0.05 0.008 S.M. 3113B- 05/29/97 Barium 3992-1 0,102 2.0 0.10 S.M. 31138- 06/05/97

Cadmium 3992-1 ND 0.005 0.001 S.M. 31138" 06/16/97

Chromium 3992-1 ND 0.1 0.005 S.M 3113B" 06/06197

Fluoride -- - 4.0 0.10 S.M. 4500FC" --

Mercury' 3992-1 ND 0.002 0,0002 EPA 245.2/3112B 06/03/97 A Selenium 3992-1 ND 0.05 0.005 S.M. 31131" 06/04/97

Sodium - -- none 0.02 S.M. 3111B -

Antimony 3992-1 ND 0.006 0.002 S.M. 3113B- 06/17/97

Beryllium 3992-1 ND 0.004 0.001 S.M. 3113B" 06/09/97

Nickel 3992-1 ND 0.1 0.004 SM. 3113B" 05/30/97

Thallium 3992-1 ND 0.002 0.001 S.M. 3113B" 06/17/97

Cyanide 3992-1 <0.02 0.2 0.02 4500-CN C-E" 06/11/97

Compound Lab Samplc Result MCL Detection Analytical Date Lab (unregulated) ID mg/L mg/L Limit Method Analyzed Symbol mp/L

Sulfate ------none 10.0 S.M. 4500-SO J" Thcre is also a snccadary MCL for fluoride which is 2.0 mg/L. Standard Methods, 18' ed. Please note that ifmethod 245.1 is used for iry yzneth will be accepted by DEP.

Laboratory Director Signature and Dare A.2 .. O 9z Aucttion; Mail TWQ copies of this report to DEPIDWS; I Winter Street; 9 Floor; Bost 02108; Attention: WQA-SAMP; within 30 days of receipt of results and no later than 10 days after the end of the reporting period. For DEPIDWS use gnly Please initialand date as completed. Accepted: Disapproved: Data tered into WQTS: comments:

ZLoc/17 Ii . - t ACHUSETTS DEP/DIVISION OF WATER . LY voc ATLE ORGANIC CONTAMiNANT RE W page 1 of 3 (FORM #7.3) 1. PWS INFORMATION: 1. PWS ID#: 3317001 2. City/Town: Wellesley - 3. PWS Name: __Wellesley College_ 4. PWS Class (circle one): =Qfr NTNC NC 5. DEP Source Code/Location ID# 6. SamniepLocation 7. Date Collected 8. Collected by 3317001-008/009 Well 05/28/97 S. McGrail 9. Is the source rated? N_ 10. Was the sample collected after treatment? _N_ 11. Manifolded [Y] If applicable, list the connected sources: 008/009

12. Routine [x] Special [ I (Explain below)

U. LABORATORY ANALYTICAL INFORMATION: Lab Name: ANALYTICAL BALANCE CORP. Lab Cen.#: M-MA022 Subcontracted? Yes ( } No (xl Lab Sample ID #: 3992 Subcontracted Lab Name: Sub. Lab Cert. # Composite (or multiple) sample? (Y,N) _ If Y, list the composited sources:

Notes: Compound Result MCL Detection Analytical Date regulated - has MCL) (4L) ( /L) Limit (Wg/L) Method Anayzed

Benzene ND 5.0 0.5 502.2 05/30/97

Carbon Tetrachloride ND 5.0 0.5 502.2 05/30/97

1,l-Dichloroethylene ND 7.0 0.5 502.2 05/30/97

1,2-Dichloroetbane ND 5.0 0.5 502.2 05/30/97

para-Dichlorobenzene ND 5.0 0.5 502.2 05/30/97

Thchloroethylene ND 5.0 0,5 502.2 05/30/97

1,1,1-Trichloroethane ND 200-0 0.5 502.2 05/30/97

Vinyl Chloride ND 2.0 0.5 502.2 05/30/97

Monochlorobenzene ND 100.0 0.5 502.2 05/30/97

o-Dichlorobenzene ND 600.0 0.5 502.2 05/30/97

trans-1,2-Dichloroethylene ND 100.0 0.5 502.2 05/30/97

cis-1,2-Dichloroethylene ND 70.0 0.5 502.2 05/30/97

1,2-Dichloropropane ND 5.0 0.5 502.2 05/30/97

Ethylbenzene ND 700.0 0.5 502.2 05/30/97

Styrene ND 100.0 0.5 502.2 05/30/97

Tetrachloroethylene ND 5.0 0.5 502.2 05/30/97

Tohene ND 1000.0 0.5 502.2 05/30/97 Xylmnes (total) ND 10000.0 0.5 502.2 05/30/97

Dichloromethane ND 5.0 0.5 502.2 05/30/97

1,2.4-Trichlorobenzene ND 70.0 0.5 502.2 05/30/97

1,,2-Trichloroethane ND 5.0 0.5 502.2 05/30/97 -PWS ED No.: 3317001 ~~~ (Form #7.3) 0 Town: Wellesley voc page 2 of 3

Compound Result MCL Detection Analytical Dae (unregulated - no MCL) (yg/L) (g/L) Limit (ug/L) Method Analyzed

Chloroform 1.9 - 0.5 502.2 05/3097

Bromodichloromethane ND - 0.5 502.2 05/30/97 Chlorodibromomethane ND 0.5 502.2 05130/97

Bromoform ND -- 0.5 502.2 05/30/97 m-Dichlorobenzene ND - 0.5 502.2 05/30/97

Dibromomethane ND 0.5 502.2 05/30/97

1,1-Dichloropropene ND - 0.5 502.2 05/30/97

1,1-Dichloroethane ND - 0.5 502.2 05/30/97

1,,2,2-Tetracbhloroethane ND -- 0.5 502.2 05/30/97

1,3-Dichloropropane ND 0.5 502.2 05/30/97

Chloromethane ND -- 0.5 502.2 05/30/97

Bromomethane ND 0.5 502.2 05/30/97 1,2,3-Trichloropropane ND 0.5 502.2 05/30/97

1,1,1,2-Tetachloroethane ND - 0.5 502.2 05/30/97 Chloroethane ND 0.5 5022 05/30/97

2,2-Dichloropropane ND - 0.5 502.2 05/30/97 o-Chlorotoluene ND -- 0.5 502.2 05/30/97 p-Chlorotoluene ND - 0.5 502.2 05/30/97

Bromobenzene ND - 0.5 502.2 05/30/97 1,3-Dichloropropene ND 0.5 502.2 05/30/97

1,2,4-Trimethylbenzene ND - 0.5 502.2 05/30/97

1,2,3-Trichlorobenzene ND -- 0.5 502.2 05/30/97 n-Propylbenzene ND - 0.5 502.2 05/30/97 n-Butylbenzene ND - 0.5 502.2 05/30/97

Naphthalene ND - 0.5 502.2 05/30/97

Hexachlorobtadiene ND -- 0.5 502.2 05/30/97 1,3,5-Trimethylbenzene ND 0.5 502.2 05/30/97 p-Lsopropyltoluene ND -- 0.5 502.2 05/30/97

Iscpropylbenene No - 0.5 502.2 05/30/97 rat-Butylbenzene ND - 0.5 502.2 05/30/97

10C\1/v -PWS MDNo,: 3317001 (Form #7.3) Town: Wellesley_ VOC page 3 of 3

Compound Result MCL Dertection Aualytical Date (Unregulated - no MCL) (g/L) (49/L Limit (up/L) Method Analyzed sec-Butylbenzene ND 0.5 5021 05/30/97

Fluorotrichloromethane ND - 0.5 502.2 05/3097

Dichlorodifluoromethane ND -- 0.5 502.2 05/30/97

Bromochloromethane ND -- 0.5 502.2 05/30/97 Methyl-tertiary-butyl ethe*

* Optional

Surgate Recoveries (As required by EPA methods 524.1 and 524.2)

Compound %Recovered QC Limits (%)

2-Bromo-1-chloropropane 107 80-120 4-Bromofluorobenzene 108 80-120

The QA/QC required matrix spike sample information is on file at our office.

Attention: Mail TWO copies of this report to your DEP Regional Office within 30 10 days after the end of the reporting period.

For DEPIDWS rae only: Please initial and dare as completed. Accepted: Disapproved: Data entered into WQTS: Comments:

Voc\1/97 9 NALYTICAL BALANCE Cot. 422 WEST GROVE STREET Environmental Chemistry MIDDLEBORO. MA 02346 Environmental Services Site Assessment 508-946-2225 Site Sampling Quality Assurance Services Fax 508-946-3335 Data Auditing

21 June 1997

SAIC 101 East Grove Street Middleboro, MA 02346

COLLECTED BY:- S. McGrail SAMPLE DATE: 05/28/97 TIME: 1020 hrs. DATE RECEIVED: 05/28/97 LOCATION: Wellesley College (Well) SAMPLE ID: 97-05-3992

RESULTS OF ANALYSIS PARAMEE ANALYTICAL j 'DATE UNITS DET RESULT METHOD ANALYZED_ LI1T .

Hexavalent Chromium Std.Meth., 3500 Cm D' 05/29/97 mg/L <0.01 <0.01

Lead EPA 200.9" 06/09/97 mg/L 0.001 ND

Standard Methods, 18* edition 1992 EPA 600/4-79-020

LabonJ Director/ Date

fbady fnfttf 4 M CHUSETTS DEP/DIVISION OF WATEIPLY SEC-CON page I of 2 SECONDARY CONTAMINANT REPORT (FORM #12.2)

I PWS INFORMATION:

1. PWS ID#: 3317001 2. City/Town: Wellesley 3. PWS Name: _Wellesley College 4. PWS Class (circle one): QM NTNC NC 5. Source To# 6. Sample Location 7. Date Collected 8.Colleted by A: 3317001-005/009 Well 05/28/97 _S. McGrail_ B: C: D:

9. Is the source treated? _Y_ 10. Was the sample collected after treatment? N 11. Manifolded [Y] if applicable, list the connected sources: 008/009

Notes:

11 LABORATORY ANALYTICAL INFORMATION: Lab Name: ANALYTICAL BALANCE CORP. Lab Cer.#: M-MA022Z_ Subcontracted? (Y, N) _N__ (usc symbols to rclate each anulyrc to a specific lab) Sub. Lab Name: Lab Cert. #: Lab SymboL Notes:

Analytical Detection Date Results (mg/L) Lab method Limit Analyzed A a -- Symbol

Lab Sample ID 3992-1 A"I S______

Turbidity (NTIU) S.M. 2130 B 0.25 05/30/97 0.42 TDS S.M. 60.1 4.2 06/04/97 218

Color (color units) S.M. 2120B - 05/30/97 0

Odor (TON) S.M. 2150B - 05/28/97 NOO

pH S.M. 4500-H*B - 05/30/97 7.7

Alkalinity - Total S.M. 2320 B 1.0 05/30/97 72.0 (CaCO3) Hardness (CaCO,) S.M. 2340 C 4.0 06/03/97 68.0

Calcium (Ca) S.M. 3500-Ca D 2.0 06103/97 20.8

Mapesium (Mg) S.M. 311 1B 0.01 05/29/97 4.68 Aluminum (Al) S.M. 3113B 0.005 06/02/97 0.007

Potassium(K) SM.31111 0.10 05/2997 40.0 Iron (Fe) SM. 311 1B 0.02 05/30/97 0.04 Manganese (Mn) S.M. 311 1B 0.01 05/30/97 ND Sulfate (SO, SM. 4500-SO.E 10.0 05/29/97 23.2

SEC-CON

SEC\i/97 - PWS ID #331 To Wellesley

page 2 of 2

Analytical Detection Date Results (mg/L) Lab method Limit Analyzed - Symbol _ _A B C D Chloride (Cl) S.M. 4500CIB 2.0 06/03/97 69.0 Silver (Ag) S.M. 3111 B 0.01 06/04197 ND

Copper (Cu) SM. 31118 0-02 05/30/97 0.06 Zinc (Zn) S.M. 311 IB 0.005 06/05/97 0.032

Laboratory Director Signature and Date / a, /9 Y

Attention: Mail IM copies of this report to your DEP Regional Office within 30 s of receipt of results and no later than 10 days after the end of the reporting period.

For DEP/DWS use only: Please initial and date as completed. Accepted: Disapproved. Data entered into WQTS:

Comments:

EI\1J97 v-i-, 'it

S MONWEALTH OF MASSACHUSE7 EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION TEN COMMERCE WAY. WOBURN. MA 01801 617-932-7600

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Govemor Commissioner

July 2, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462; SCOPE OF WORK APPROVAL

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a document entitled MCP Phase I/ Comprehensive Human Health Risk Assessment Scope of Work, Former Henry Woods Paint Factory Site, Wellesley, Massachusetts (the Scope of Work), dated June 9, 1997 and prepared by Menzie-Cura & Associates, Inc. on behalf of Wellesley College. The Scope of Work was submitted subsequent to a series of facilitated meetings over the past six months between representatives of DEP and Wellesley College, under the guidance of Ms. Susan Santos of Focus Group, to discuss the need for and scope of additional Phase 11activities at the subject site.

Following DEP's review of both the Scope of Work and a proposal by Menzie-Cura to evaluate lead exposures using an EPA lead model (Assessment of Risks Associated with Lead Exposures, dated May 12, 1997), DEP provided comments to Wellesley College's consultants and discussed the documents during a conference call on June 24, 1997. Participants in the conference call were: Cynthia Weidner of DEP, Maureen Vallatini of DEP, Christine LeBlanc of East Coast Engineering, Inc. and Dr. Wendy Heiger-Bernays of Menzie-Cura.

Prmted on Recycled Paper Page 2

AGREEMENIS

The agreements made during the conference call are summarized below:

1. The Massachusetts Contingency Plan (MCP) requires soil and groundwater at a site to be categorized in accordance with the provisions set forth in 310 CMR 40.0930. This is required even when an MCP Method 3 risk characterization is used, to ensure that the exposure scenarios developed for the site are consistent with the soil and groundwater categories at the site. Given the detailed discussions of the proposed exposure scenarios for the Paintshop Pond Site,it was agreed that it is unnecessary to address soil categorization in detail in the Scope of Work. Instead, it was decided that the Risk Assessment Report, which will document the outcome of the Scope of Work, will address soil and groundwater categorization.

2. Data requirements in support of the human health and environmental risk assessments were discussed and agreed upon in the facilitation meetings. It was acknowledged in the conference call that the data collection requirements for the human health risk assessment are included in the Scope of Work. In addition, a few data requirements described in the Scope of Work are being collected in support of the environmental risk assessment (such as sediment testing for total organic carbon, grain size and acid volatile sulfide/simultaneously extracted metals). A final scope of work for the environmental risk characterization will be prepared under separate cover and is currently under DEP review in draft form. The complete data needs in support of the environmental assessment will be described therein, or a separate scope of work for the environmental data needs will be prepared. The facilitation group will also meet on July 2, 1997 to address any additional data requirements to define the extent of contamination in Lake Waban.

3. Section 2.1.2 addresses sediment and surface water "background" concentrations. The existing background data sets for sediment and surface water each only contain two samples. Additional collection and analysis of background samples is proposed. It was agreed in the conference call that the final list of Contaminants of Concern for the human health risk assessment will be determined once the additional data has been collected and analyzed.

4. The Scope of Work refers back to a risk characterization previously conducted for the Public Beach area. It was agreed that the Risk Assessment Report will discuss in detail why the Public Beach Risk Characterization concludes that site conditions are considered protective for human exposures. In addition, it was agreed that the Soil/Property Management Plan for the Wellesley College campus will have a section addressing the conditions at the Public Beach.

5. It was agreed that utility worker exposures will be addressed in the Soil/Property Management Plan.

6. It was agreed that the risk of harm to public welfare will consider the all the factors identified at 310 CMR 40.0994. Page 3

7. In accordance with Section 7.3.1.2 of the Guidance for Disposal Site Risk Assessment, July, 1995, receptors at the site should be described in terms of their relationship to the site and the assessment should consider subpopulations based upon gender and age if those factors are indicative of a higher exposure potential or greater susceptibility to environmental contamination. In terms of evaluating exposures to lead contamination at the site, the most sensitive receptor would be a female of reproductive age, due to the potential adverse effects of lead on the developing fetus, or a small child. Therefore, it was agreed that subchronic exposures to lead will be evaluated for either a female of reproductive age or a small child. Additional tables will be prepared and added to the Scope of Work (e.g. Table 2 and Table 2A) to address the most sensitive receptors for each exposure scenario including details on how they will be evaluated.

8. It was agreed that the exposures to lead would be dealt with using the lead model and that it is not necessary to consider those results as part of the total site hazard index because the lead hazard ratio is calculated using a different methodology than hazard indices. DEP will accept the use of USEPA default values in the model, or alternatively, other values appropriate for the community (e.g. lead concentrations in drinking water).

9. It was agreed that the input/output data and graphs generated from the lead model will be submitted to DEP with the Risk Assessment Report.

10. It was agreed that the *exposure frequency" will be adjusted from the EPA default value of 1/day to 1/week (or the appropriate frequency/week) by multiplying the average daily soil intake rate by 1/7.

11.The issue of lead being found in fish bone, as opposed to fish fillets was discussed. Since we will have data on lead concentrations in fish tissue as well as lead concentrations in whole body fish, the uncertainty section in the Risk Assessment Report will discuss lead in bone and the possible impacts of lead being released during cooking.

FINALZATION OF SCOPE

The following details regarding the proposed work will be finalized through the context of informal discussions and written correspondence, where appropriate, among DEP staff and Wellesley College's consultants in the spirit of continued facilitation. All items pending resolution noted below must be finalized with DEP prior to performing the Phase 11 Comprehensive Human Health Risk Assessment for the subject site.

1. The Scope of Work proposes to use a qualitative assessment of some exposure pathways. It was agreed that some areas, such as the playing fields, could be qualitatively assessed since these areas will be maintained under the Soil/Property Management Plan. Some other exposures, such as those associated with the walking paths, will be evaluated qualitatively, however, the exact qualitative approach has not yet been decided upon. Several possible approaches were discussed, including the Page 4

approach of screening with the S-1 soil values. It was agreed that a more detailed description of the qualitative assessment will be provided to DEP.

2. The acute exposure scenarios were discussed in the conference call, and it was decided that Dr. Heiger-Bernays will provide additional information to DEP on acute exposures. In particular, a description of how acute cyanide exposures will be evaluated will be discussed. In addition, a more detailed description will be provided on acute exposures to hexavalent chromium by a sensitive receptor group (i.e. individuals who may experience allergic contact dermatitis).

3. The issue of the 'exposure duration" selected for the various scenarios was discussed. Since the lead model assumes a three month exposure period to establish equilibrium between the body compartments, some of the proposed exposure durations are too short. It was agreed that this issue needs to be resolved, but that Dr. Heiger-Bernays needs some additional time to think about the best alternative. She may propose extending the exposure period for the sensitive subpopulations to three months. This will be resolved in the near future and a more detailed description will be provided to DEP.

4. The concentration of lead in drinking water that will be used in the model is still under discussion. The Scope of Work proposes using a drinking water concentration of 20 ug/l based upon data available in Wellesley for first draw samples in high risk homes. DEP believes this number might be too high and the data set should be reviewed more closely to ensure this is not an overly conservative assumption. Additional sampling data from the Town of Wellesley and the College will be evaluated prior to determining the selected value(s). The concentration of lead in drinking water that will be used in the model will be provided to DEP.

5. The proposed ingestion rate for fish consumption by children was discussed and generally felt to be a high estimate for a small child. Dr. Heiger-Bernays will look to the literature for a better estimate of ingestion for children and provide that value to DEP.

APPROYAL

Given the above understanding of the proposed work and remaining issues to be finalized, DEP approves the Scope of Work.

If you have any questions in regard to this letter, please contact Cynthia Weidner at the letterhead address or 617/932-7720.

Very truly yours

Cynthia Weidner M. Johnson Environmental Analyst Chief, Site Management Section Bureau of Waste Site Cleanup Page 5

cc. Wellesley BOH, ATTN: Dr. Robert Katz East Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738, ATTN: Christine LeBlanc Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Wendy Heiger-Bernays DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos .j~L C-t(~

t MONWEALTH OF MASSACHUSET 9 EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION TEN COMMERCE WAY, WOBURN, MA 01801 617-932-7600 SANNED

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B, STRUHS L. Governor Commissioner

July 2, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462; SCOPE OF WORK APPROVAL

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of a document entitled MCP Phase 11Comprehensive Human Health Risk Assessment Scope of Work, Former Henry Woods Paint Factory Site, Wellesley, Massachusetts (the Scope of Work), dated June 9, 1997 and prepared by Menzie-Cura & Associates, Inc. on behalf of Wellesley College. The Scope of Work was submitted subsequent to a series of facilitated meetings over the past six months between representatives of DEP and Wellesley College, under the guidance of Ms. Susan Santos of Focus Group, to discuss the need for and scope of additional Phase || activities at the subject site.

a> Printed on Recycled Paper Page 2 .Awl

The agreements made during the conference call are summarized below:

1. The Massachusetts Contingency Plan (MCP) requires soil and groundwater at a site to be categorized in accordance with the provisions set forth in 310 CMR 40.0930. This is required even when an MCP Method 3 risk characterization is used, to ensure that the exposure scenarios developed for the site are consistent with the soil and groundwater categories at the site. Given the detailed discussions of the proposed exposure scenarios for the Paintshop Pond Site,it was agreed that it is unnecessary to address soil categorization in detail in the Scope of Work. Instead, it was decided that. the Risk Assessment Report, which will document the outcome of the Scope of Work, will address soil and groundwater categorization.

5. It was agreed that utility worker exposures will be addressed in the Soil/Property Management Plan.

6. It was agreed that the risk of harm to public welfare will consider the all the factors identified at 310 CMR 40.0994. Page 5 ip

cc. Wellesley BOH, ATTN: Dr. Robert Katz East Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738, ATTN: Christine LeBlanc Menzie-Cura & Associates, Inc., 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Dr. Wendy Heiger-Bernays DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos East Coast Engineering, INC. {35>

June 23, 1997

Wellesley College 106 Central Street Wellesley, MA 02181

Attention: Mr. Barry Monahan

Reference: Results of Surface Water Sampling Program, Public Beach, Lake Waban, Wellesley, MA

Dear Barry:

Please find the enclosed analytical data for surface water samples collected on May 29, 1997 at the Public Beach at Lake Waban in Wellesley, Massachusetts. This monitoring program was conducted for the protection of swimmers in Lake Waban and as described in the Remedial Action Measure (RAM) Completion Report dated July 17, 1996.

Two samples were collected at similar locations as the 1995/1996 monitoring programs. Sample SWS-1 was collected between the beach and the dock at a depth between 0 to 2 feet of water; this sample location represents a depth at which young children would be exposed during recreational uses. Sample SWD-1 was collected at the end of the dock at a depth between 4 to 6 feet of water representing the area where young adults might frequent. Prior to sample collection, the water was agitated to represent swimming conditions. Samples were delivered to R.I. Analytical and analyzed for total lead, total and hexavalent chromium and total cyanide. The laboratory data is attached.

As shown on Table 1, the concentrations for each analyte were similar for both sample locations; the total and hexavalent chromium concentrations were <0.020 mg/I and total cyanide concentrations were <0.01 mg/l. The concentrations of lead in the surface water sample collected in the shallow water, station SWS-1, was 0.0045 mg/l and for the deeper water sample the concentrations was 0.0138 mg/l. The concentrations of hexavalent chromium and cyanide were similar to those observed during the 1996 sampling program. The concentrations of total chromium were below those concentrations observed in 1996 and the lead concentrations were slightly greater than the 1996 values. These values fall below the established Closure Level for the public beach of 0.180 mg/I for lead based on an assessment of potential risks from exposure to water.

Also, the bottom of the Public Beach swim area was inspected on May 28, 1997. Visual observations by Mr. David Martin, a diver for Wellesley College, noted that, for the most part, the

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-.2553 Mr. Barry Monahan, Wellesley College June 23, 1997 Page 2 of 2 sand layer placed in May/June 1996 remains present. At the deeper portion of the swim area, greater than 6 feet in water depth, the sand was more sparse and tended to have pushed away in a half semi- circle shaped area. Mr. Martin's report is attached to this report. Based on this information, it is our recommendation that the raft not be located within the roped area this season. We propose that the area be re-inspected in the Spring of 1998 and re-sanded, if necessary.

The next scheduled surface water monitoring date for metals and cyanide is June 30, 1997. If you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

SURFACE WATER RESULTS FOR PUBLIC BEACH LAKE WABAN, WELLESLEY, MASSACHUSETTS' (Results are in mg/)

-. q I - - I ~.- tt..<~..:..I. - Lzr,:ToaLead .4Total Chroim j.Heavalent Chromium_*. Totl&yanide

SWS-1 2 0.0045 <0.020 <0.02 <0.01

SWD-23 0.0138 <0.020 <0.02 <0.01

Closure Level 4 0.180

NOTES: 1. Results for samples collected May 29, 1997. 2. SWS-I collected at a depth of water 0-2 feet, 3. SWD-1 collected at a depth of water 4-6 feet. 4. Closure Level developed for lead and based on an assessment of potential risks from exposure to water. 5. Analytical results represent samples collected under simulated swimming conditions (i.e., bottom sediments were stirred prior to sampling). 6. Surface water elevation, measured June 8, 1997, was elevation 108.63 MSL. ' Page 13 of 19 R.I. Analytical Laboratories, c CERTIFICATE OF ANALYSIS

East Coast Engineering, Inc. Date Received: 5/29/97 Work Order # 9705-01205

Sample #: 11 SAMPLE DESCRITION: SWS-1 COLLECTED 5/29/97 SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TrIME ANALYST

CHROMIUM <0,020 MG/L EPA 200.7 6/10/97 14:26 RGM

KOZ 1V3 IIAITVIW I H 110~~~~OOlvCL LIf TOP IH08 fl3 It:60 aaU ±6/11/90 0] -page 14 of 19 R.. Analytical Laboratories, c. CERTIFICATE OF ANALYSIS

East Coast.Engineering, Inc. Date Received: 5/29/97 Work Order # 9705-01205

SampleS#: O: SAMPLE DESCRIPTON: SWD-1 COLLECTED 5/29/97 SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

CHROMIUM <0.020 MG/L EPA 200.7 6/10/97 14:26 RGM

STO (A llv:)IIAIIVNV r H S~~~oI~~~~LS48 CLWaTfYYI 1tO XY3 9V60 (iaa £8/Ti/S - Page 19 of 19- RI. Analytical Laboratories, 6 . CERTIFICATE OF ANALYSIS

East Cdast Engineering, Inc. Date Received: 5129/97 Work Order # 9705-01205

Sample #: 9 SAMPLE DESCRIPTION: MW-14S COLLECTED 5/29/97

SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

HEXAVALENT CHROMIUM <0.02 MG/L SM35O0-Cr D 5/29/97 16:15 JLZ

Sample #: 10 SAMPLE DESCRIPTION: MW-141 COLLECTED 5/29/97 SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

HE XAVALENT CHROMIUM <0.02 MG/L SM35O-Cr D 5/29/97 16:15 JLZ

Samplet#: 1 SAMPLE DESCRIiON: SWS-1 COLLECTED 5/29/97

SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

LED 0.0045 MG/L EPA 239.2 6/03/97 21:44 JAH HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 5/29/97 16:15 JLZ TOTAL CYANIDE <0.01 MG/L EPA 335.1 6/06/97 10:45 DMD

Sample #: L2 SAMPLE DESCRIPTION: SWD-1 COLLECTED 5/29/97 SAMPLE ANALYZED PARAMETER RESULTS/UNITS METHOD DATE/TIME ANALYST

LEAD 0.0138 MG/L EPA 239.2 6/03/97 21:44 JAH HEXAVALENT CHROMIUM <0.02 MG/L SM3500-Cr D 5/29/97 16:15 JLZ TOTAL CYANIDE <0.01 MG/L EPA 335.1 6/06/97 10:45 DMD

,IV:) y~j N iJIa) 04.51 BLTt0?Y4J 9t:90 (Ia 4.5/1/90 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECrION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secreaty

ARGEO PAUL CELLUCCI DAVID B. STRUHS Li Governor Conmmissionetr Waldo Maffei, Inc. 7 Byron Road June 18, 1997 East Natick, MA 01760

Attn: Maureen Maffei RE: NATICK - Wellesley Rd. Extension DEP RTN 3 -12230, 3 -14615 Dear Ms. Maffei,

The Department of Environmental Protection (DEP) is in receipt of your May 6, 1997 letter regarding the Maffei property on Wellesley Rd. Extension. In your letter, yoiT state that approximately 20 years ago you were offered fill from the Paintshop Pond site, and after refusing to accept it, the fill went to two nearby residential lots. You requested that DEP read the newspaper article attached to your letter, and act to prevent the construction of a house on one of the lots (the "Brady lot") . I have reviewed the newspaper article that was attached to your letter as you requested. However, the article does not provide the necessary foundation for DEP to intervene as you suggested. In order for DEP to take additional actions related to the lots you reference in your letter, we will need detailed documentation and/or verifiable evidence, in addition to your letter, to support your allegations. If you are able to provide the type of documentation and/or evidence necessary for DEP to take actions, we would be willing to review it.

Any documentation you wish to forward to DEP can be mailed to the letterhead address. Please be sure to reference RTN 3-12230. Very truly yours,

J dith . Barber Service Center Director

cc: Mr. Roger Wade, Natick Board of Health, Town Hall, Natick MA Mr. Fred Conley, Natick Town Administrator, Town Hall, Natick Attorney Melvin Newman, Roberts & Newman, One Gateway Center, Newton, MA 02158-2802

10 Commerce Way * Woburn, Masachuetts 01801 * FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD D (617) 932-7679 W

MENZIE - CURA & ASSOCIATES, IC. inviwnmental Consudants 1 COURTHOUSE LANE, SUITE 2 CHELMSFORD, MASSACHUSETTS 01824-1734 (508) 453-4300 FAX (508) 453-7260

File: 120k

June 9, 1997

Ms. Cynt ia Weidner MADEP Bureau of Waste Site Clean-Up Northeast Region 10 Commerce Way Woburn, MA 01801

RE: Comprehensive Human Health Risk Assessment Scope of Work - Former Henry Woods Paint Factory Site, Wellesley, Massachusetts

Dear Ms. Weidner:

Enclosed is the scope of work for the comprehensive human health risk analysis in support of Phase II of the MCP for the former Paint Factory site.

I look forward to your comments.

Sincerely, Menzie-Cura & Associates, Inc.

Wendy eiger-Bernays, Ph.D. cc: Mr. Barry Monahan (w/enclosure) Ms. Christine LeBlanc (w/enclosure) Ms. Susan Santos (w/o enclosure) Ms. Maureen Vallatini, M.S., Esq. (w/enclosure) COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION A METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner June 3, 1997

Mimi Beck 4 Cedar Street Unit 205 Wellesley, MA 02181

Dear Ms. Beck:

Enclosed are results of recent surface water testing performed at the public beach area at Lake Waban in Wellesley and a copy of a report documenting the placement of sand at the beach area to minimize contact with contaminated sediments. Levels of lead and other metals in surface water samples are reported in units of milligrams per liter (mg/1) . The drinking water action level for lead is 0.015 mg/i. The drinking water vtandard for chromium is 0.100 mg/l. Surface water monitoring is oerformed to determine if concentrations of lead and other metals in surface water remain within acceptable levels throughout the summer months. A Closure Level for the public beach at Lake Waban has been set at 0.180 mg/l for lead based on an assessment of potential risks from exposure to water.

Please contact Cynthia Weidner at 617/932-7720 if you have any questions about the enclosed material or would like additional information.

Very tru yours,

Cynthia Weidner Environment lyst

.S phen . Jo ns Chief, Site M gement Section Bureau of Waste Site Cleanup cc. (no attachments) Wellesley BOH, Attn. Dr. Robert Katz Wellesley College, 106 Central Street, Wellesley, MA 02181- 8258, Attn: Mr. Barry F. Monahan

10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD # (617) 932-7679 Office of Assistant V' resident for Administration and Community AffW

Wellesley College .

106 Central Street Wellesley, Massachusetts 02181-8258 (617) 283-2386 FAX (617) 283-3681

May 28, 1997

Nancy Smith U. S. Environmental Protection Agency JFK Federal Building Boston, MA 02203-2211

Dear Ms. Smith:

I am writing in response to your letter of May 23, 1997 which was received yesterday, May 27, 1997. This letter grants permission to the EPA, and its authorized representatives, to access the former Henry Woods and son's paint factory site. I have spoken with Mr. Maher of PRC, and he has explained the purpose of this request and PRC role as an EPA contractor.

It is important for the EPA to know Wellesley College has been working cooperatively with the Massachusetts Department of Environmental Protection(DEP) on site assessment and remediation since 1983. To date Wellesley College has expended over 5 million dollars on site assessment and remediation work, and has just concluded a lengthy collaborative facilitation orocess with DEP to define additional assessment needs in accordance with the Massachusetts Contingency plan. I would also like to note that Wellesley College was never the operator of the paint factory. The property was purchased in the early 1930 when the paint factory has ceased operations, as a way of pursuing open space and eliminating an adjoining industrial site.

I am the appropriate point of contact (POC) for Wellesley College, and my office will be pleased to assist EPA personnel-in their site evaluations. The following telephone numbers will help you contact me:

Office (617) 283-2386 FAX (617) 283-3681 ~, .9. -i

U.S. Environmental Protection Agency -2-

Asst. V.P. for Administration and Community Affairs

BFM:jm enclosure

cc: Steve Johnson, Massachusetts Dept. of Environmental Protection John McElhinney, Esq., Ropes and Gray Christine LeBlanc, Project Engineer, East Coast Engineering -i

Request for Access Mr. Barry Monahan Page 3

CONSENT FOR ACCESS TO PROPERTY

1IUW), the Owner(s) of the Paintship Pond property located at 106 Central Street in Wellesley, MA, shall permit EPA's officers, employees, agents, contractors, subcontractors, consultants, and other authorized representatives, to enter and have access to this property for the purpose of conducting a CERCLA site evaluation.

I 4we7'realize that these actions are undertaken under EPA's response and enforcement authorities under the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended ("CERCLA"), 42 U.S.C. § 9604(e) and under Section 3007 of the Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. § 6927.

1 (We) give this written permission voluntarily with knowledge of my (our) right to refuse, and without threats or promises of any kind.

f1nature f Property Owrier/Operator Date or Authorized Representative(s)

NAME: 45ry r HvI 4/ J 2/l9 C i/--e ADDRESS: /06 a/ 10ent , 4t oa (&rI

PHONE NUMBER:(C/7) iz-J- 28

CONSENT OF ADDITIONAL OWNER(s)

Signature of Property Owner/Operator Date or Authorized Representative(s)

NAME:

ADDRESS:

PHONE NUMBER: V (0Rrer O) 0 Roy F. Weston, Inc. ILI 114_t Federal Programs Division 217 Middlesex Turnpike 30 2 h Burlington. Massachusetts 01803-3308 MANAGERS DESIGNERS/CONSULTANTS617-229-6430 * Fax 617-272-3619

SUPERFUND TECHNICAL ASSESSMENT AND RESPONSE TEAM EPA CONTRACT 68-W5-0009 16 May 1997 11098-021-001-2085-30 DC No. A-1530

Ms. Nancy Smith Site Assessment Manager U.S. EPA Region I John F. Kennedy Federal Building Boston, MA 02203-2211

Subject: Site Access Agreement Request Paintshop Pond Wellesley College Wellesley, Massachusetts CERCLIS No. MAD076572965 TDD No. 97-01-0022

Dear Ms. Smith:

The Roy F. Weston, Inc. (WESTON(), Superfund Technical Assessment and Response Team (START) would like to request the U.S. Environmental Protection Agency Region I (EPA Region I), Office of Site Remediation and Restoration to obtain site access for a Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) investigation from the following owner(s)/operator(s) of the above-mentioned property:

Wellesley College Attention: Mr. Barry Monahan, Assistant Vice President of Administration Administration and Community Affairs Wellesley, MA 02181 (617) 283-2386

S:\97010022\PAINTPND.SAA

In Association with Resource Applications. Inc., C.C. Johnson & Malhotra, P.C., and PRC Environmental Management, Inc. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I JOHN F. KENNEDY FEDERAL BUILDING PR7 BOSTON, MASSACHUSETTS 02203-0001

URGENT LEGAL MATTER - PROMPT REPLY NECESSARY

May 23, 1997 SITE:. -G~1Q Wellesley College BREAK: Attn: Mr. Barry Monahan Assistant Vice President of Administration OTHER: Administration and Community Affairs Wellesley, MA 02181

Re: REQUEST FOR ACCESS TO PROPERTY Paintshop Pond Wellesley, MA MAD076572965

Dear Mr. Monahan:

The United States Environmental Protection Agency (EPA) respectfully requests permission for EPA, its agents, contractors, and other authorized representatives to have access to the Paintshop Pond property located at 106 Central Street in Wellesley, Massachusetts.

EPA requests access to your property to conduct or oversee a CERCLA site evaluation. Entry to your property to conduct this activity is authorized by Section 104(e) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended ("CERCLA"), 42 U.S.C. § 9604(e). This authorization provided by CERCLA includes access to private property in order to determine the need for response actions, to perform response actions, and to enforce CERCLA. Ehtry by EPA is also authorized under Section 3007 of the Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. § 6927. Under that section EPA may enter property where hazardous wastes are or have been disposed of, transported from, generated, stored, or treated in order to enforce the provisions of RCRA.

CERCLA site evaluation activities may include information-gathering to determine whether hazardous substances, pollutants, and contaminants may be, or may have been released to the environment. In addition, EPA and its representatives may drive vehicles onto the site, collect samples, take photographs, and dispose of small amounts of decontamination fluid on the property. EPA or its representatives will offer the owner or company representative(s) replicates of the samples collected if requested. Prior to leaving the property, the EPA representatives will supply the owner or company representative(s) with a receipt for samples collected on the property.

Please signify your consent to access by signing this document in the space provided below, and return the signiture page to me at the following address:

Nancy Smith (Mail Code: HBS) U.S. Environmental Protection Agency JFK Federal Building Boston, MA 02203-2211

V1iw"~ u ,A..A11 p,4I. -a-----. S- - Request for Access Mr. Barry Monahan Page 3

CONSENT FOR ACCESS TO PROPERTY

I (We), the Owner(s) of the Paintship Pond property located at 106 Central Street in Wellesley, MA, shall permit EPA's officers, employees, agents, contractors, subcontractors, consultants, and other authorized representatives, to enter and have access to this property for the purpose of conducting a CERCLA site evaluation.

I (we) realize that these actions are undertaken under EPA's response and enforcement authorities under the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended ("CERCLA"), 42 U.S.C. § 9604(e) and under Section 3007 of the, Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. § 6927.

I (We) give this written permission voluntarily with knowledge of my (our) right to refuse, and without threats or promises of any kind.

Signature of Property Owner/Operator Date or Authorized Representative(s)

NAME:

ADDRESS:

PHONE NUMBER:

CONSENT OF ADDITIONAL OWNER(s)

Signature of Property Owner/Operator Date or Authorized Representative(s)

NAME:

ADDRESS:

PHONE NUMBER:

4,11 - / COMMONWEALTH OF MASSACHUSETd#! EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Conuniozr

April 18, 1997

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462; SCOPE OF WORK APPROVAL

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of two documents entitled Proposed Scope of Work, Hydrogeological Assessment, Former Henry Woods Paint Factory, Wellesley, Massachusetts:and Addendum to Scope of Work, both prepared bj East Coast Engineering, Inc. on behalf of Wellesley College. These workplans were submitted subsequent to a series of facilitated meetings between representatives of DEP and Wellesley College, under the guidance of Ms. Susan Santos of Focus Group, to discuss the need for and scope of additional Phase 11activities at the subject site.

DEP's comments on the two documents were provided to Ms. Christine LeBlanc of East Coast Engineering, Inc. on April 7, 1997 and following a telephone conversation between Ms. LeBlanc and Ms. Cynthia Weidner of DEP, details regarding the proposed work were finalized. The elevations of the proposed screened intervals at monitoring well locations MW-24, MW-25 and MW-26 were determined to be set at appropriate intervals based on the screened intervals of monitoring wells located downgradient where the highest levels of chromium are currently being detected in groundwater. The screened intervals of proposed observation wells OW-1, OW-2 and OW-3 will be set at the same screened interval as the campus water supply wells. A certain percentage of soil samples will be analyzed for all Contaminants of Concern (COCs) at the site. Currently there are 12 COCs:

10 Comnmerce Way 0 Woburn. Massachusetts 01801 * FAX (617) 932-7615 e Telephone (617) 932-7600 * TDD # (617) 932-7679 t.

s Engineering, INC.

FAX TRANSMITTAL

DATE: March 25, 1997

TO: Cynthia Weidner

FAX#9:

FROM: Christine

# OF PAGES (not including this page): 5

Following is the Addendum to the Site Tnvestigation Activities at the Former Paint Factory Site, Wellesley, MA. This document is being mailed out today via Postal Express.

Should you have any questions, please contact me at (508) 748-2460.

P. 0. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553

'ON3 JSUOD JSH3 9MBOr:2TiSUCO ISHB L6 9-tt 0

East Coast Enqineering, INC.

March 24, 1997

Natural Resource Commission 525 Washington Street Wellesley, MA 02181-5992

Attention: Mr. John Maggenheimer

Reference; Addendum to the Site hivestigation Activities at the Former Paint Factory Site, Wellesley, Massachusetts

Dear John:

As we discussed on Friday March 21, 1997, enclosed please find the addendum to conduct additional site assessment activities at the Paint Factory Site. We request that this work be performed under the Request for Determination of Applicability submitted on February 25. 1997 for the above-referenced site.

The work proposed includes advancement of four soil borings with the installation of water table wells at each boring location, and the execution of six test pits. The study area is south of Paintshop Pond extending approximately 800 feet in a south southeasterly direction and lying immediately west of the Lake Waban. A detailed description of the proposed activities is provided in the addendum Scope of Work. Essentially, as shown on the attached plan, several of the test pits and wells will be conducted in the buffer zone to the Lake Waban and Paintshop Pond and one test pit within the buffer zone of small isolated wetland.

During the course of these activities, all precautions will be taken to minimize disruption of wetlands and resource areas.

Thank you for your immediate attention to this matter. We look forward to meeting with the Commission on Thursday March 27, 1997.

Sincerely, EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

Enclosure

cc: Mr. Barry Monahan, Wellesley College Department of Environmental Protection, Northeast Regional Office, Division of Wetlands Cynthia Weidner, Department of Environmental Protection, Northeast Regional Office Jack McElhinney, Esq., Ropes & Gray

P. 0. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2400 Fax: (508) 748-2553

70 *d 'ON3 iS jOD I DjA Ot7 -2, T - GE T -S ----' " -I ADDENDUM TO SCOPE OF WORK Dated February 25, 1997 Former Henry Woods Paint Factory, Wellesley, Massachusetts

1.0 INTRODUCTION

'Ihis scope of' work is an addendum to hydrogeological assessment Scope of Work provided to the Department of Enviromnental Protection on February 25. 1997; these work plans identify further assessment activities to define the nature and extent of soil and groundwater contamination resulting from the former Henry Woods Sons Paint Factory Site. This addendum addresses furthcr study in an area south of Paintshop Pond extending approximately 800 feet in a south southeasterly direction and lying immediately west of the jogging path in response to observations of a fallen tree that appears to contain elevated concentrations of metals. Further subsurface investigation is warranted to determine whether conditions south of Paintshp Pond are consistent with the Paint Factory site. The information derived during this assessment will be integrated to support the public health and ecological risk assessments proposed at the site.

2.0 UPLANDS SOIL CHARACTERIZATION

To evaluate whether pigment and/or contaminated soils are present at depth ii this area, test pits will be excavated at locations identified as TP-53 through TP-58 on Drawing No. PSL-1A. At each location, soil samples will be evaluated for color, soil type and characteristics and the test pit logged. Soil samples will be obtained above the water table at the following increments.

- 0 to 6 inches - 6 to 12 inches S I to 3 feet - 3to 5 feet S 5 to 7 feet - 7 to 9 feet

Each of the soil samples will transported to a Massachusetts certilied laboratory and analyzed for arsenic, barium, cadmium, total and hexavalent chromium, copper, lead, nickel, zinc and total cyanide. The analytical methodology for each of these compounds is provided in Appendix B of the February 25, 1997 SOW.

Standard field methodologies and sampling protocols will be followed in. accordance with Appendix A of the February 25. 1997 Scope of Work.

East Coast Engineering. Inc. March 24. 1997 A ddendum to Scope of Work Page I

20'ci ~~~'90?SsO:D j!DI3 r~r t6-a-~ 3.0 EVALUATION OF GROUNDWATER CONDITIONS SOUTH OF PANTSHOP POND

3.1 lnstallation of Groundwater Monitoring Wells

Four groundwater monitoring wells are proposed to be installed south of Paintshop Pond. These wells are identified as MW-27 through MW-30 and shown on Drawing PL-1A. The objective of these monitoring locations is to determine the groundwater hydrology south of Paint Shop Pond and its and relationship with Lake Waban, and groundwater chemistry.

At each of these locations, soil borings will be executed to approximately 10 feet below the groundwater table. A shallow monitoring well will be installed at each location to intercept the groundwater table. The monitoring wells will be constructed according to the methodology described in Appendix A.

Continuous split spoon samples will be collected using a 24-inch long split spoon sampler. Soils will be logged and described by a qualified geologist. Any unusually discolored soil and/or pigment will be described fully. Soil samples will be submitted to a Massachusetts certified laboratory for arsenic, barium, cadmium, total and hexavalent chromium, lead, nickel, zinc, and total cyanide. (Note: metals may be present in soil as a result of groundwater contamination and not due to the presence of contaminated fill.)

3.2 Groundwater Measurements and Sampling

Following the installation of the monitoring wells, and after allowing sufficient time for the groundwater to equilibrate, water level measurements will be taken from the wells MW-27 through MW-30. (An attempt will be made to correlate these groundwater table measurements with those of the existing monitoring wells.)

Groundwater samples will be collected in accordance with Standard Protocols (Appendix A, February 25, 1997 SOW) and transferred to a Massachusetts certified laboratory. Groundwater samples collected from monitoring wells MW-27 through MW-30 will be analyzed for the following paraneters: pH! (in-situ), temperature (in-situ), and conductivity (in-situ), calcium. phosphorus, and total cyanide. and dissolved aluminum, arsenic, barium, cadmium, total and hexavalent chromium, copper, lead, iron, magnesium. nickel. mercury, selenium, silver, and zinc.

The analytical methodology for each of these compounds is provided in Appendix 3 of the February 25, 1997 SOW.

East Coast Engineering. Inc. March 24, 1997 Addendum to Scope of I'ork Page 2

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3.3 Survey of Monitoring Wells and Surface Water Points

The newly established monitoring wells will be surveyed for location and elevation. All wells and surface water monitoring points will be located to the nearest 1.0-foot horizontally and 0.01 foot vertically. The survey will be a closed traverse for horizontal control and level circuit for vertical closure. The locations and elevations of these new wells will be compiled with earlier data points and located on a plan to be used to develop groundwater contours and determine flow direction,

East Coast Engineering, Inc. arch 24, /9097 Addendwm to Scope of Work Paye 3

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East Coast Engineering, INC.

March 24, 1997

Natural Resource Commission 525 Washington Street Wellesley, MA 02181-5992

Attention: Mr. John Maggenheimer

Reference: Addendum to the Site Investigation Activities at the Former Paint Factory Site, Wellesley, Massachusetts

Dear John:

The work proposed includes advancement of four soil borings with the installation of water table wells at each boring location, and the execution of six-test pits. The study area is south of Paintshop Pond extending approximately 800 feet in a south southeasterly direction and lying immediately west of the Lake Waban. A detailed description of the proposed activities is provided in the addendum Scope of Work. Essentially, as shown on the attached plan, several of the test pits and wells will be conducted in the buffer zone to the Lake Waban and Paintshop Pond and one test pit within the buffer zone of small isolated wetland.

During the course of these activities, all precautions will be taken to minimize disruption of wetlands and resource areas.

Thank you for your immediate attention to this matter. We look forward to meeting with the Commission on Thursday March 27, 1997.

Sincerely, EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

Enclosure

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553; ADDENDUM TO SCOPE OF WORK Dated February 25, 1997 Former Henry Woods Paint Factory, Wellesley, Massachusetts

1.0 INTRODUCTION

This scope of work is an addendum to hydrogeological assessment Scope of Work provided to the Department of Environmental Protection on February 25, 1997; these work plans identify further assessment activities to define the nature and extent of soil and groundwater contamination resulting from the former Henry Woods Sons Paint Factory Site. This addendum addresses further study in an area south of Paintshop Pond extending approximately 800 feet in a south southeasterly direction and lying immediately west of the jogging path in response to observations of a fallen tree that appears to contain elevated concentrations of metals. Further subsurface investigation is warranted to determine whether conditions south of Paintshp Pond are consistent with the Paint Factory site. The information derived during this assessment will be integrated to support the public health and ecological risk assessments proposed at the site.

2.0 UPLANDS SOIL CHARACTERIZATION

To evaluate whether pigment and/or contaminated soils are present at depth in this area, test pits will be excavated at locations identified as TP-53 through TP-58 on Drawing No. PSL-IA. At each location, soil samples will be evaluated for color, soil type and characteristics and the test pit logged. Soil samples will be obtained above the water table at the following increments.

- 0 to 6 inches - 6 to 12 inches - 1 to 3 feet - 3 to 5 feet - 5 to 7 feet - 7 to 9 feet

Each of the soil samples will transported to a Massachusetts certified laboratory and analyzed for arsenic, barium, cadmium, total and hexavalent chromium, copper, lead, nickel, zinc and total cyanide. The analytical methodology for each of these compounds is provided in Appendix B of the February 25, 1997 SOW.

Standard field methodologies and sampling protocols will be followed in accordance with Appendix A of the February 25, 1997 Scope of Work.

East Coast Engineering,Inc. March 24, 1997 Addendum to Scope of Work Page 1 " A.

3.0 EVALUATION OF GROUNDWATER CONDITIONS SOUTH OF PAINTSHOP POND

3.1 Installation of Groundwater Monitoring Wells

(Foutgroundwater monitoring wells are proposed to be installed south of Paintshop Pond. These wells are identified as MW-2%through MW-39 and shown on Drawing PL-1A. The objective of these monitoring locations is to determine the groundwater hydrology south of Paint Shop Pond and its and relationship with Lake Waban, and groundwater chemistry.

3.2 Groundwater Measurements and Sampling

Groundwater samples will be collected in accordance with Standard Protocols (Appendix A, February 25, 1997 SOW) and transferred to a Massachusetts certified laboratory. Groundwater samples collected from monitoring wells MW-27 through MW-30 will be analyzed for the following parameters: pH (in-situ), temperature (in-situ), and conductivity (in-situ), calcium, phosphorus, and total cyanide, and dissolved aluminum, arsenic, barium, cadmium, total and hexavalent chromium, copper, lead, iron, magnesium, nickel, mercury, selenium, silver, and zinc.

The analytical methodology for each of these compounds is provided in Appendix B of the February 25, 1997 SOW.

East Coast Engineering,Inc. March 24, 1997 Addendum to Scope of Work Page 2 3.3 Survey of Monitoring Wells and Surface Water Points

East Coast Engineering,Inc. March 24, 1997 Addendum to Scope of Work Page 3 j

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z m ast Coast Engineering, INC.

March 24, 1997

Natural Resource Commission 525 Washington Street Wellesley, MA 02181-5992

Attention: Mr. John Maggenheimer

Reference: Addendum to the Site Investigation Activities at the Former Paint Factory Site, Wellesley, Massachusetts

Dear John:

During the course of these activities, all precautions will be taken to minimize disruption of wetlands and resource areas.

Thank you for your immediate attention to this matter. We look forward to meeting with the Commission on Thursday March 27, 1997.

Sincerely, EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

Enclosure

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 '- 1;

ADDENDUM TO SCOPE OF WORK Dated February 25, 1997 Former Henry Woods Paint Factory, Wellesley, Massachusetts

1.0 INTRODUCTION

2.0 UPLANDS SOIL CHARACTERIZATION

To evaluate whether pigment and/or contaminated soils are present at depth in this area, test pits will be excavated at locations identified as TP-53 through TP-58 on Drawing No. PSL-1A. At each location, soil samples will be evaluated for color, soil type and characteristics and the test pit logged. Soil samples will be obtained above the water table at the following increments.

- 0 to 6 inches - 6 to 12 inches e 1 to 3 feet - 3 to 5 feet - 5 to 7 feet - 7 to 9 feet

Standard field methodologies and sampling protocols will be followed in accordance with Appendix A of the February 25, 1997 Scope of Work.

East Coast Engineering, Inc. March 24, 1997 Addendum to Scope of Work Page I N11 0 0

3.0 EVALUATION OF GROUNDWATER CONDITIONS SOUTH OF PAINTSHOP POND

3.1 Installation of Groundwater Monitoring Wells

Four groundwater monitoring wells are proposed to be installed south of Paintshop Pond. These wells are identified as MW-27 through MW-30 and shown on Drawing PL-lA. The objective of these monitoring locations is to determine the groundwater hydrology south of Paint Shop Pond and its and relationship with Lake Waban, and groundwater chemistry.

At each of these locations, soil borings will be executed to approximately 10 feet below the groundwater table, A shallow monitoring well will be installed at each location to intercept the groundwater table. The monitoring wells will be constructed according to the methodology described in Appendix A.

3.2 Groundwater Measurements and Sampling

Groundwater samples will be collected in accordance with Standard Protocols (Appendix A, February 25, 1997 SOW) and transferred to a Massachusetts certified laboratory. Groundwater samples collected from monitoring wells MW-27 through MW-30 will be analyzed for the following parameters: pH (in-situ), temperature (in-situ), and conductivity (in-situ), calcium, phosphorus, and total cyanide, and dissolved aluminum, arsenic, barium, cadmium, total and hexavalent chromium, copper, lead, iron, magnesium, nickel, mercury, selenium, silver, and zinc.

The analytical methodology for each of these compounds is provided in Appendix B of the February 25, 1997 SOW.

East Coast Engineering,Inc. March 24, 1997 Addendum to Scope of Work Page 2 0 0

3.3 Survey of Monitoring Wells and Surface Water Points

East Coast Engineering, Inc. March 24, 1997 Addendum to Scope of Work Page 3 I-.

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7-z 1*~** *MMONWEALTH OF MASSACHUSE * EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAS DEPARTMENT OF ENVIRONMENTAL PRoTECnIO% METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secremray

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan MAR 2 4 1997

RE: WELLESLEY-- Paintshop Pond Route 135, DEP RTN 3-0462 REGULATORY DEADLINE EXTENSION

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of your March 4, 1997 letter requesting. an extension to the regulatory deadline established in the Massachusetts Contingency Plan (MCP) at 310 CMR 40.0550 which requires submittal of a Phase II Report, and if'applicable, a Phase III Remedial Action Plan, within two years of the Tier IA permit effective date for the subject site. The date of the Tier IA permit for this site is 9/9/94. The request for an extension is based upon the progress being made at facilitation meetings intended to develop scopes of work necessary to complete the Phase II requirements of the MCP.

As discussed with you at our March 20 meeting, DEP is willing to grant an extension to the regulatory deadline. However, it has not yet been decided exactly what additional work Wellesley College intends to conduct. Therefore, we are not able to establish a reasonable deadline until we know more precisely the scope and the activities which Wellesley College will be performing. Once we are informed in writing of the additional Phase II work that Wellesley College will be conducting, we will issue a mutually agreeable extension.

Please contact Cynthia Weidner at the letterhead address or (617) 932-7720 with any further questions or concerns regarding this matter.

yours

Cynthia Weidner Stephen M. Jo on Environmental Analyst Chief, Site Management Section Bureau of Waste Site Cleanup

10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD # (617) 932-7679 WELLESLEY - Paint hop Pond Page 2

CC: Wellesley Board of Health, ATTN: Dr. Robert Katz East Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion MA 02738 ATTN: Christine LeBlanc Menzie-Cura and Associates, 1 Court House Lane, Suite 2, Chelmsford, MA 01824 ATTN: Dr. Wendy Heiger-Bernays DEP Data Entry DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley,. MA 02181 ATTN: Judith Nicolson Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney DEP/NERO, ATTN: Jeffrey Mickelson, Esq. DEP/NERO, ATTN: Laurel Mackay, Esq. East Coast Enineering, INC.

March 12, 1997

Town of Wellesley Natural Resource Commission 525 Washington Street Wellesley, Massachusetts 02181

Reference: Request for a Certificate of Compliance - DEP 324-221, Site Assessment Activities at the Former Henry Woods paint Factory, Wellesley, MA

Dear Commission Members:

East Coast Engineering, on behalf of Wellesley College, is requesting a Certificate of Compliance for the above-referenced project. The work, which was performed in accordance with both the "Scope of Work for ConductingAdditional Activities at the Former Henry Woods Paint Factory" and the Order of Conditions dated March 28, 1996 was completed on May 22, 1996.

I look forward to discussing this with you further on March 27, 1997. If you have any further questions, please feel free to contact me at (508) 748-2460. Thank you for your attention in this matter.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College John E. McElhinney, Esq., Ropes & Gray DEP, Northeast Region, Wetlands Division Ms. Cynthia Weidner, DEP, Northeast Region, Waste Site Cleanup

P. O. Box 745 15 6A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 Office of Assistant Varesident for Administration and Community Affa . 0 Wellesley College 106 Central Street Wellesley, Massachusetts 02181-8258 (617) 283-2386 FAX (617) 283-3681 March 4, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Request for Extension to Permit for Former Paint Factory Site, Wellesley, MA

Dear Cynthia:

In accordance with the Tier 1A Permit for the former Paint Factory site (RTN 3-0462), we respectfully request and extension to complete the Phase II and Phase III work in accordance 310 CMR 40.0550 of the Massachusetts Contingency Plan. This extension request is based on the progress being made at our facilitation meetings to develop the scopes of work to complete the Phase II requirements which include the delineation of the extent of contamination, and the human and ecological risk assessments. At the completion of these facilitation meetings it is our intent to develop a schedule to complete these scopes, amenable to the DEP and ourselves, implement the work plans, and provide complete Phase II and Phase III documents.

If this request for extension is acceptable to the Department, please confirm the extension is writing to us. Thank you for your attention in this matter.

Sincerely yours,

Tarry F. M ahan Asst. V.P. for Administration and Com unity Affairs BFM:jm cc: J. McElhinney, Esq., Ropes Gray C. LeBlanc, East Coast Engineering, Inc. S. Santos, FOCUS Group East Coast Engineering, INC. \k)

February 26, 1997

Natural Resource Commission 525 Washington Street Wellesley, MA 02181-5992

Attention: Mr. John Maggenheimer

Reference: Request for Determination of Applicability, Site Investigation Activities at the Former Paint Factory Site, Wellesley, Massachusetts

Dear John:

East Coast Engineering, Inc. is submitting, on behalf of Wellesley College, the enclosed Request for Determination of Applicabilityfor the above-referenced site. In accordance with requirements of the Department of Environmental Protection (DEP), further assessment activities are required to determine the nature and extent of groundwater contamination east of the former Paint Factory.

To evaluate the groundwater conditions, the work proposed includes installing four (4) hand driven well points in the northern wetland east of the Paint Factory and one monitoring well along the walking path east of the wetlands. (Additional monitoring wells are proposed as part of this scope of work but their respective locations fall outside of the Wetlands Protection Act.) A detailed description of the proposed activities are provided in the proposed Scope of Work.

Essentially, the work outlined herein will be conducted in the buffer zone to the resource area and in wetlands. During the course of these activities, all precautions will be taken to minimize disruption of wetlands and resource areas. A complete description of project activities and associated locations is present in Attachment 1.

Thank you for your immediate attention to this matter. We look forward to the Commission's review.

Sincerely, EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

Enclosure

P 0. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 6a 0 East Coast Engineering, INC. '4

February 25, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Proposed Scope of Work, Hydrogeological Assessment, Former Henry Woods Paint Factory, Wellesley, Massachusetts

Dear Cynthia:

Enclosed please find the "ProposedScope of Work HydrogeologicalAssessment, FormerHenry Woods PaintFactory, Wellesley, MA. " This Scope depicts the proposed program to install the additional groundwater monitoring wells in the northern and northeastern portion of the study area as agreed upon during our facilitation meetings. This Scope also addresses the installation of well points in the northern wetlands, east of the Paint Factory and the monitoring wells in the area of the College wellfield.

Please review and provide any necessary comments at your earliest convenience.

Sincerely, EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Jack McElhinney, Esq., Ropes & Gray Dr. Wendy Heiger-Bernays, Menzie-Cura & Associates, Inc. Mr. Barry Monahan, Wellesley College

P. O. Box 745 15 6A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 East Coast Engineering, INC,

January 27, 1997

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Ms. Cynthia Weidner

Reference: Status Report, Additional Assessment at the Former Henry Woods Paint Factory, Wellesley, Massachusetts

Dear Cynthia:

On behalf of Wellesley College, we are pleased to submit the enclosed report entitled "StatusReport, AdditionalAssessment at the FormerHenry Woods PaintFactory, Wellesley, Massachusetts" dated January 24, 1997.

As you requested in our meetings, this document includes the following: * laboratory data sheets for groundwater samples form the new monitoring wells; and - groundwater elevations for new monitoring wells, contours, and discussion of the site- wide groundwater flow direction

If you have any further questions, please contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc, L.S.P. Principal

enclosure

cc: Mr. Barry Monahan, Wellesley College Jack McElhinney, Esq., Ropes & Gray Wendy Heiger-Bemays, PhD., Menzie-Cura & Associates Charles Menzie, PhD., Menzie-Cura & Associates Susan Santos, Focus Group

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax; (508) 748-2553 MEMORANDUM

TO: Cynthia Weidner, BWSC, NERO FROM: Maureen Vallatini, ORS DATE: January 10, 1997 RE: AWQC and Mixing Zones

In discussions with Warren Kimball he identified 3 issues which DWPC includes in determining whether a mixing zone is appropriate for a point source discharge, and if so how it will be addressed. The 3 general issues are: (A) location, (B) in-zone quality and (C) size and shape.

A) Location * The location of the mixing zone can have no critical uses within it, such as use as a drinking water source, a recreational area or a swimming beach. * There must exist a zone of passage for all migrating animals or a mixing zone will not be allowed. B) In-zone Quality * If a mixing zone were to be allowed, the-water at the delineated boundary of that zone must meet all public health criteria. " All acute criteria must be met within the zone. * All potential nuisance conditions must be avoided. C) Size and Shape * This isn't really about size & shape, but I wanted to summarize this as Warren presented it,. You'll get the idea. * This is really the first issue because DWPC takes a 2-tiered approach in considering the appropriateness of a mixing zone. First, in order to minimize the size of the mixing zone, the point source must apply all reasonable technologies to reduce contaminant concentrations in the effluent. If all reasonable technologies are applied and there is still a need for a mixing zone, it will be considered at that time. Therefore, all point sources need treatment before DWPC will even consider discussing the second tier which is water quality. * The total mixing zone should be less than 10% of the lake. (Lake Waban is 108 acres).

I also spoke with Michael Hutcheson, Nancy Bettinger and Paul Locke and none of them were aware of any situations where we divided up a surface water body based upon habitat. Michael pointed out that since the exceedances at Lake Waban are in the shallow zone we should be especially concerned because the shallow waters function as a nursery for the fish. He did note that the deeper areas of the lake would have different qualities which might effect the metals. Warren Kimball reminded us to "think like the fish" and the fish is not going to respect any arbitrary boundaries we draw.

Note: DWPC considers any exceedance (in the surface water)of an acute AWQC as a violation. Chronic criteria are compared to a 4 day average, and those values are viewed over a 3 year period. You can exceed once every 3 years and not be out of compliance.

Finally, I spoke with Sue Svirsky an Ecological Risk Assessor at EPA, Region I. Sue says that the AWQC are always considered ARARs under Superfund, either as State or Federal Standards. She did think it was possible that there might be RODs that do not cite the AWQC, but thought that those were most likely sites where the focus was not on surface water, but rather on sediments or biota. She said that could happen because you can't do anything to remediate surface water, except to remediate sediments or groundwater, so surface water may not have been the focus. Moreover, there are so many problems with surface water sampling, they may have not done it, or not done much of it. Bottom line is she felt any exceedance of the AWQC indicates you have exposure and very likely impairment to the benthic community. She felt we should focus on (dare I say it) sources and the groundwater, and that surface water should be last on the list. She thought averaging over the lake was ridiculous. East Coast Engiting, INC. P. 0. Box 745 156A Front Street Marion MA 02738 Tel: (508) 748-2460 Fax: (508) 748-2553 DATE JOS NO

ATTENTION

ahrn,f wiM/ (xtbu jyn )

WE ARE SENDING YOU Attached El Under separate cover via the following items:

E Shop drawings E Prints [I Plans El Samples E Specifications El Copy of letter E Change order El___

COPIES DATE NO OESCRIPTION

THESE ARE TRANSMITTED as checked below:

E For approval EJ Approved as submitted E Resubmit copies for approval E For your use E Approved as noted E Submit____copies for distribution E As requested El Returned for corrections El Return -corrected prints E For review and comment 7

E FOR BIDS DUE 19 E PRINTS RETURNED AFTER LOAN TO US

REMARKS

(1 t Ic j COPY TO SIGNED: AN MPC FORM L azc 3a/9QA NO 3502 f enclosures are niot as noted, kindly notify us at once. East Coast Enineering, INC. SC

December 26, 1996

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Results of the Fall 1996 Groundwater Sampling Program at the Former Henry Wood Sons Company, Wellesley, Massachusetts

Dear Cynthia:

In accordance with the "Scope of Work for ConductingAdditional Assessment at the Former Henry Woods Paint Factory" dated February 28, 1996, and approved by the Department of Environmental Protection on March 28, 1996, please find the enclosed report entitled "InterpretiveReport ofResults for the Groundwater Sampling Survey, Fall 1996". East Coast Engineering conducted the.Spring 4%9& groundwater sampling program during the week of October 14, 1996. This document presents the 4- results of the groundwater survey and interpretation of analytical results. The next scheduled semi- annual groundwater sampling will be conducted in April 1997.

If you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College Mr. Jack McElhinney, Esq., Ropes & Gray Dr. Wendy Heiger-Bernays, Menzie-Cura & Associates Dr. Richard Hughto, P.E., L.S.P., Rizzo & Associates Ms. Judith Nickelson, Natural Resource Commission Dr. Robert Katz, Wellesley Board of Health

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2.553 0 40 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

December 18, 1996

Wellesley College 106 Central Street Wellesley, MA 02181-8258

Attn: Mr. Barry F. Monahan Assistant Vice President for Administration and Community Affairs

RE: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462.

Dear Mr. Monahan:

The Department of Environmental Protection (DEP) is in receipt of two Release Notification Forms submitted in response to the discovery of contamination exceeding DEP's reportable concentrations at certain areas at the Wellesley College property.

As discussed with you during a meeting on December 12, 1996, the boundaries were identified for the Paintshop Pond Disposal Site (which DEP has assigned the Release Tracking Number 3-0462). Since the areas where reportable concentrations were exceeded are within the site boundary for Release Tracking Number 3-0462, notification is not required pursuant to 310 CMR 40.0317(16). These areas will be addressed as part of Release Tracking Number 3-0462.

The specific language of 310 CMR 40.0317(16) is intended to obviate the need for reporting additional releases at properties where assessment is ongoing and also encourages a holistic approach to assessment and remediation activities at a disposal site. Notification is still required, however, for "two-hour" reporting conditions at existing disposal sites since "two- hour" conditions require immediate action and DEP approval.

10 Commnerce Way 0 Woburn, Massachusetts 01801 1 FAX (617) 932-7615 * Telephone (617) 932-7600 0 TDD # (617) 932-7679 WELLESLEY - PaintshPond Page 2

Please contact Cynthia Weidner at the letterhead address or 617/932-7720 with any concerns or questions in this matter.

Very truly yours,

Cynthia Weidner Environmental Analyst

Stephen M. Johnso{/ Chief, Site Management Section Bureau of Waste Site Cleanup

IQ. Wellesley BOH, ATTN: Dr. Robert Katz 3ast Coast Engineering, Inc., 156A Front Street, PO Box 745, Marion, MA 02738, ATTN: Christine LeBlanc Menzie-Cura and Associates, 1 Court House Lane, Suite 2, Chelmsford, MA 01824, ATTN: Wendy Heiger-Bernays and Charlie Menzie DEP Data Entry/File DEP/ORS/Boston, ATTN: Maureen Vallatini Natural Resources Commission, Town Hall, 525 Washington Street, Wellesley, MA 02181, ATTN: Judith Nicolson, Director Ropes & Gray, One International Place, Boston, MA 02110-2624, ATTN: John McElhinney, Esq. DEP/NERO, ATTN: Jeffrey Mickelson, Esq. DEP/OGC/Boston, ATTN: Laurel MacKay, Esq. Focus Group, 29 Welgate Road, Medford, MA 02155, ATTN: Susan Santos Office of the Attorney General, 200 Portland Street, Boston, MA 02114, ATTN: Matthew Brock, Esq. V/

MEMO TO THE FILE TO: File FROM: Cynthia Weidner, DEP/BWSC/NEROL) THRU: Rodene Lamkin and Stephen Johnson, DEP/BWSC/NER DATE: November 15, 1996 SUBJ: WELLESLEY - Paintshop Pond, Route 135, DEP RTN 3-0462 RE: Meeting on August 28, 1996

A meeting was held at DEP/NERO on August 28, 1996 for the purpose of discussing various risk assessment-related topics regarding the subject site. Present at the meeting were: Cynthia Weidner of DEP/BWSC/NERO, Maureen Vallatini of DEP/ORS/Boston, Wendy Heiger- Bernays of Menzie*Cura & Associates, Inc., and Christine LeBlanc of East Coast Engineering, Inc. The Attendance Sheet for this meeting is attached.

Ms. LeBlanc requested the meeting in order to informally discuss topics described on the attached fax dated August 21, 1996. During the meeting, the following issues were discussed:

1) A sampling program was conducted at various locations on the Wellesley College campus for the purpose of identifying "background" soil concentrations for all contaminants of concern at the subject site. At two locations, elevated lead and arsenic levels were identified. In response to this discovery, Ms. LeBlanc conducted an investigation and concluded that the elevated levels are due to the widespread application of lead arsenate pesticides at the campus over many years. (See letters in the site file dated June 19, 1996 and July 17, 1996 from East Coast Engineering, Inc.) Elevated levels of lead and arsenic were only found in the upper six inches of soil, further supporting the assertion that a surficial application of pesticides was the source. Ms. LeBlanc proposed to use the data collected from the depth range greater than six inches for the "background" samples, since elevated levels were only found in the upper six inches. During a telephone conversation a few days following this meeting, Ms. Weidner advised Ms. LeBlanc that the approach seemed reasonable, but the final determination of whether the approach was acceptable would remain contingent on the actual background numbers proposed.

2) Ms. LeBlanc questioned whether an MCP risk assessment is required to demonstrate that a level of No Significant Risk exists at areas where pesticides were applied. The contamination in these areas is not subject to notification as per 310 CMR 40.0317. During a telephone conversation a few days following this meeting, Ms. Weidner advised Ms. LeBlanc that although the assessment and cleanup of contamination resulting from the proper application of pesticides are not subject to M.G.L. Chapter 21E or the MCP, exposures to pesticide contamination and potential health impacts should be evaluated. The MCP risk characterization process may be used 4 .$ 9 0

WELLESLEY - Paintshop Pond Meeting on August 28, 1996 Page 2

to evaluate those exposures, however, it is not required.

3) Elevated lead concentrations were identified at the flower gardens/greenhouses. Ms. LeBlanc determined that these levels were resultant from the historic use of lead paint at this building and, as such, are also exempted from requirements under the MCP. Ms. LeBlanc stated that, even though this contamination is related to lead paint, Wellesley College intends to remove and/or isolate soil containing lead at levels exceeding the applicable MCP Method 1 standard.

4) High lead, chromium and arsenic concentrations were identified in soil at Alumnae Hall. This is consistent with past data identifying former paint factory waste at this location. According to Ms. LeBlanc, Wellesley College intends to remove and/or pave affected areas and file an Activity and Use Limitation (AUL), if needed. The intent of these actions is to eliminate the potential for human contact with contamination at this area. Ms. Weidner advised Ms. LeBlanc and Ms. Heiger-Bernays that the contaminated area at Alumnae Hall is considered a portion of the Paintshop Pond Disposal Site and, as such, any risk assessment performed solely for that area must be performed consistent with MCP requirements for performing risk assessments at portions of disposal sites. Ms. LeBlanc and Ms. Heiger-Bernays indicated that they intended to use Method 1 soil standards for comparison purposes at this area and did not necessarily agree that Alumnae Hall is part of the Paintshop Pond site. DEP representatives explained the rationale for this decision. Contaminants and waste material identical in nature have been detected at the former paint factory and at Alumnae Hall. An argument that contamination at Alumnae Hall is discrete is also not realistic given the proximity of contaminated areas. Even though Alumnae Hall was assigned a new Release Tracking Number (RTN) , due to a "Two-Hour" reporting condition, this does not necessarily mean that Alumnae Hall should be addressed separately. The assignment of a new RTN does not necessarily mean that a new disposal site has been identified, and in fact, the area may be considered part of an existing site.

5) Contamination was also detected near the current tennis courts. Again, Wellesley College intends to remove and/or pave (isolate) contaminated soil and place an AUL on that part of the campus. Ms. LeBlanc stated that the contamination may be due to the presence of fill material which appeared to be coal ash. During a telephone conversation a few days following this meeting, Ms. Weidner advised Ms. LeBlanc that this area must also be addressed as a portion of the Paintshop WELLESLEY - Paintshop Pond Meeting on August 28, 1996 Page 3

Pond Disposal Site unless it can be demonstrated that the contamination and related constituents found at this location are consistent with coal ash constituents.

6) At the Sports Center, Ms. LeBlanc confirmed that pigment waste was left in place in this area after a removal operation in 1983. Arsenic and lead were detected in the top six inches of soil, along with chromium exceeding expected background levels. Chromium was also detected in ground water in this area.

7) At the Distribution Building, arsenic at a level of 40 mg/kg was detected in surface soil. Ms. LeBlanc indicated that additional surficial soil samples would be collected in this area.

8) At the former tennis courts, arsenic was detected in the top six inches of soil beneath the tennis courts. No elevated levels of chromium or lead were identified.

In conclusion of their discussion of the results of recent field investigations, Ms. LeBlanc and Ms. Heiger-Bernays stated that it is Wellesley College's intent to eliminate exposures to metals and file Release Action Outcome Statements (RAOs) - or RAOs for portions of the site - for all of the affected campus areas (subject to MCP requirements). DEP representatives agreed with this course of action.

Ms. Weidner stated that a Phase II - Risk Characterization Report is required and must be re-submitted before the Phase II is deemed complete. None of the prior risk assessment reports can fulfill the requirement for a Phase II total site human health and ecological risk assessment. Additional risk assessment workplans will not be required, however, DEP representatives suggested that during this process, informal meetings be held, among risk assessors from both DEP and Wellesley College's consulting firms, to ensure that the final Phase II risk characterization is acceptable to DEP and is approved in a timely manner after submittal.

A few topics related to the Phase II risk characterization were also discussed. Ms. Heiger-Bernays indicated that a trespasser scenario would be evaluated and that a fugitive dust analysis would be performed. Ms. Weidner and Ms. LeBlanc discussed the use of appropriate and effective signs at the site and problems with trespassers removing signs and encroaching on contaminated areas. Ms. Heiger-Bernays and Ms. Vallatini discussed the applicability of Method 1 when S-3 soil standards are exceeded. Other miscellaneous topics were discussed before adjourning. .... ~......

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! Engineering, INC.

MEMORANDUM

TO: Cynthia Weidner, Department of Environmental Protection

FROM: Christine LeBlanc, East Coast Engineering, Inc.

DA TE: August 21, 1996

SUBJECT: Risk Assessment Issues Relative to PaintFactory and Wellesley College, Meeting on August 28, 1996

Thank you for coordinating the meeting next week scheduled for Wednesday August 28, 1996. As requested, we would like to discuss the following issues relative to the former Paint Factory and Wellesley College campus locations.

* Pesticide/Herbicide Data Relative to "Background Soil" Data collected at Pendelton Hall and uplands east of Pond Road. * Method 1 Risk Evaluation Protocol for areas on campus where metal contamination has been identified. * Paint Factory Site: - Issue regarding Comprehensive Site Evaluation - Ecological Risk Evaluation: Review of 1988 Scope of Work and assessment activities conducted during Phase H; supplementing this SOW with new data collected during the Spring 1996.

These are the primary areas which we anticipate discussing and seek input from DEP. If you have further questions, please feel free to contact me. I look forward to meeting with you and Maureen on Wednesday August 28.

cc: Mr. Barry Monahari, Wellesley College Wendy Heiger-Bernays, PhD., Menzie-Cura & Associates

R 0. Box 745 156A Front Strect Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553

TOTAL P. 02 3

Office of the'President W . Wellesley College

106 Central Street Wellesley, Massachusetts 02181-8201 (617) 283-2243

October 11, 1996

Ms. Trudy Coxe Secretary of the Executive Office of Environmental Affairs 100 Cambridge St., Suite 200 Boston, MA 02202

Dear Secretary Coxe:

I am writing to request a meeting with you and Commissioner David Struhs at your earliest convenience. Wellesley College and the Department of Environmental Protection have been working together on an environmental site, partially owned by the College, for 21 years. The site is the former Henry Wood's Sons paint factory, which ceased operations about 1904, and which the College acquired in 1932. The College was not involved in the paint factory operation or in the creation of the pollution. Nevertheless we have spent over 4.5 million dollars on site assessment and remediation, and continue to face expensive, and we believe unnecessary, DEP mandated assessment work.

I have enclosed copies of the most recent correspondence from DEP, dated August 29, 1996 and the College's response to that letter, which will give you a sense of the issues. As you will note from the correspondence, our two staffs are at an impasse.

Our position is that the DEP and the College now have sufficient information in hand to move the site to an interim solution, and that additional study and analysis is unwarranted. Further, we have repeatedly requested a response to our legal counsel's letter of November 18, 1994. This letter requested the Commonwealth's position regarding the College's entitlement to certain legal defenses including protection of the charitable immunity statute and the innocent landowner defense. We also have had no response to our position that Lake Waban's status as a "Great Pond" makes the Commonwealth responsible for the costs associated with continued analysis and remediation. Secretary Coxe -2-

Nearly two years have passed since these critical questions were raised, and the only response we have received from the DEP is an oral acknowledgment that the questions are being studied, and that a legal intern worked on these issues this summer. The questions raised by Ropes and Gray on the College's behalf are very important, and during our two year wait for a response, Wellesley College has spent an additional $600,000 in DEP directed assessment related work. It is imperative that the DEP provide a definitive response to these legal issues soon.

I would propose to bring to our meeting two Trustees who have been involved in this issue for some time, Daniel Gregory and William Saltonstall. I would also propose to bring two members of my staff who have worked closely on the project, William Reed and Barry Monahan.

I will call your office after October 22, 1996 to set up a meeting. I would ask that we meet as soon as possible as this is a vitally important issue to the College.

Sincerely yours,

Diana Chapman Walsh

DCW:jm enclosures cc: Commissioner David Struhs John Fitzgerald, MDEP (,o/o 4 L Daniel Gregory William Saltonstall Office of the'Preskient Wellesley College

106 Central Street Wellesley, Massachusetts 02181-8201 (617) 283-2243

October 11, 1996

Ms. Trudy Coxe Secretary of the Executive Office of Environmental Affairs 100 Cambridge St., Suite 200 Boston, MA 02202

Dear Secretary Coxe:

I will call your office after October 22, 1996 to set up a meeting. I would ask that we meet as soon as possible as this is a vitally important issue to the College.

Sincerely yours,

Diana Chapman Walsh

DCW:jm enclosures

cc: Commissioner David Struhs John Fitzgerald, MDEP ( c Daniel Gregory William Saltonstall East, Coast Engineering, INC. a

October 1, 1996

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Revised NRF Forms for Oval Tennis Courts and Athletic Fields, Wellesley College, Wellesley, MA

Dear Cynthia:

Enclosed pleased find the revised Release Notification Forms, as requested, for the above-referenced projects. Should you have any questions, please feel free to contact me at (508) 748-2460.

Sincerely,

EAST COAST ENGINEERIN , INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 Office of the Vice Prt nt for Finance and Admetration Wellesley College

106 Central Street Weilesley, Massachusetts 02181-8201 (617) 283-2305 FAX (617) 283-3696

September 27, 1996 DELIVERED BY HAND

Ms. Cynthia Weidner Environmental Analyst Executive Office of Environmental Affairs Department of Environmental Protection 10 Commerce Way Woburn, MA 01801

John Fitzgerald, P.E. Deputy Regional Engineer Executive Office of Environmental Affairs Bureau of Waste Site Cleanup 10 Commerce Way Woburn, MA 01801

Re: Wellesley College

Dear Ms. Weidner and Mr. Fitzgerald:

This letter is in response to your letter to Barry Monahan dated August 29, 1996. I was pleased to read that the DEP is committed to achieving an interim closure solution for the College expeditiously. This statement of intent is, of course, consistent with the College's goal. I must say, however, that I take issue with certain other statements in your letter, and by the absence of discussion about alternative approaches to resolving this project, which Mr. Fitzgerald suggested, at our July 30, 1996 meeting.

I was particularly concerned by your assertion that Wellesley College has failed "to fully evaluate and confront the magnitude of the problems presented by this site." Even more disconcerting is the statement that the College has "repeatedly and consistently downplayed the seriousness of contaminated conditions at the site." This theme is repeated in your statement that the College "failed to adequately and seriously consider all relevant risks posed by this site..." I am frankly puzzled by your assertion given the enormous amount of time and money spent by the College on this issue. I find the DEP's characterization of our response to be insulting. I Ms. Weidner, Mr. Fitzgerald -2-

believe an objective evaluation of the College's handling of the problems at the site would demonstrate that it has taken such problems seriously, studied them carefully and completely, taken appropriate remedial measures, complied with all necessary and applicable state regulations then in force, and expended in excess of $4 million in addressing a situation that was not of its own making. DEP, by contrast, has responded with inordinate delays to the College's submissions, has continually changed the rules and attempted to apply them retroactively, and has failed to acknowledge any responsibility for the delays that you have identified.

As I explained at our meeting, the DEP must understand that the College is a charitable corporation, and must account carefully -- including to the Attorney General of the Commonwealth -- for its use of funds. It must, accordingly, analyze claims against it with great care and conserve its funds, as required by law. Consequently, over the course of the past 20 years, we have attempted to analyze the problems identified at the site thoughtfully and expeditiously. The College especially has been concerned about the possibility of any human health effects that might be caused by the contamination. That is why site access is restricted. We monitor our water supply frequently because we have a responsibility for the health of all the College's constituencies.

The suggestion in your letter that the College disregarded hazards to human health is simply wrong. Iris Davis, DEP's project manager for many years visited the site dozens of times, and was very familiar with conditions that your letter claims posed an "imminent hazard". She did not characterize the site as one that posed an "imminent hazard". Frankly no one at the DEP suggested site conditions constituted an "imminent hazard" until the regulations changed once again in 1993. The College then voluntarily agreed to fence off the area. Likewise, the contention that the College is tardy in performing an ecological risk assessment is without merit. As you acknowledge, DEP approved the College's work plan for such an assessment in 1989, and the College prepared and submitted its report in a timely fashion. Your Agency then raised a couple of minor points, which the College addressed years ago. What you now seek is a new ecological risk assessment based on new regulations, consistent with the agency's repeated attempts to force the College, at great expense, to redo studies in light of newly-adopted regulations. We believe that this approach is in violation of DEP's own regulations. Ms. Weidner, Mr. Fitzgerald -3-

Perhaps most distressing of all is the Agency's failure to respond to the serious legal issues which were raised in the November 18, 1994 letter from our counsel. Indeed, a follow-up letter was sent on August 16, 1996 at our suggestion to Attorney Laurel McKay. Like .the earlier letters, this one too remains unanswered. It is inconsistent for the DEP to insist on an ever increasing level of effort from the College, while it fails to address the important legal issues involved. Rather than addressing these serious issues, you suggest that the uncertainties regarding legal responsibility for Lake Waban can now be "deferred," except that you insist that the College analyze the risk associated with exposures to the Lake of students, workers, and visitors. In our view, as stated at the meeting of July 30, this problem is fundamentally one of the Commonwealth.

I had hoped that the spirit of resolution I heard Mr. Fitzgerald speak of at our meeting would be intensified thereafter. Instead, that spirit appears to have been cast aside. While we indicated in our letter of August 21 that the College was prepared to take additional steps as set forth therein, you will recall that I spoke to the need to weigh the costs and benefits of further ecological risk assessment work when the outcome is predictable (as defined by current DEP regulations). You say that you will review our supplemental submissions, but you insist on a response with respect to still further alleged requirements. Meanwhile, the DEP has failed to respond to the legal defenses we raised almost two years ago, and during this interval the College has incurred over $600,000 in additional project costs.

I want to make our position perfectly clear. I believe Wellesley College has a history of full cooperation with the DEP starting with an initial inquiry from DEP's predecessor agency, the Massachusetts Department of Public Health, in 1975. The former Henry Wood's and Sons paint factory located at the former paint factory area, began operations about 1848 (predating the Civil War), therefore the contamination generated from this industrial operation has been located on this area for nearly 150 years. Long after the paint factory's operations ceased in the early 1900's , Wellesley College bought this land (1932). As you acknowledge, Wellesley College did not contaminate the land or Lake Waban.

The site is fenced and posted, and there is no public access. We have analyzed the site for 21 years, and have performed countless studies and initiated significant remedial action in coordinating with the DEP, and there is still no practical economic solution to cleaning up the site, thus additional testing would add only marginally incremental information, at great cost. Ms. Weidner, Mr. Fitzgerald -4-

There appears to be no cost/benefit to DEP's proposed course of action to further study and analyze the site. We believe that both DEP and the College now have in hand the information needed to move this site to an interim solution.

The course of action you proposed in your letter is devoid of the creative solutions we heard you articulate at our July 30th meeting and continues the College down the usual regulatory road, without acknowledging the uniqueness of this site and the College's role as a charitable institution and innocent landowner. This site is being treated with a "cookie cutter" approach by the DEP, when its uniqueness demands creative, cost effective action.

What we seek, and what you originally said you sought, is to get this site to an interim solution. We recognize that it is not possible at this time to get the site to a permanent solution, but given that our proposals to extend the fencing to cover all potential areas of public exposure would eliminate any public access or risk, we believe that an interim solution can be approved now based on the information in hand, and that this will stop the unnecessary expenditure of large amounts of College funds, funds for which there are urgent needs, such as financial aid support to needy students, and teaching and learning innovations.

Before we can respond to the substantive points raised in your letter, we insist that we know the limits of our exposure before we incur additional expenses. Accordingly, you must set forth the position of the Commonwealth on several legal points. Does the Commonwealth agree that Wellesley College is entitled to the protection of the charitable immunity statute? Does the Commonwealth agree that we are entitled to the protection of the innocent landowners defense? Does the Commonwealth agree that it is responsible for the pollution and contamination in Lake Waban? Once you have answered these questions, we shall know the Department's opinion of the extent of our obligations, which the agency now refuses to disclose. We then will be able to respond to your letter.

In the meanwhile, because these issues are of such importance to Wellesley College, we request a meeting between the College and Ms. Trudy Coxe, Secretary of the Executive Office of Environmental Affairs, and Mr. David B. Struhs, Commissioner of the Department of Environmental Protection. For Wellesley such a meeting would include Diana Chapman Walsh, President of the College, and two other Trustees, Daniel Gregory and Ms. Weidner, Mr. Fitzgerald -5-

William Saltonstall. The meeting would also include me, Mr. Monahan, and counsel. Presumably, you, as well as counsel, also would be present.

Please call me as soon as possible so we can jointly arrange a meeting with Secretary Coxe and Commissioner Struhs.

Very truly yours,

William S. Reed Vice President of Finance and Administration

WSR:jm

cc: Dr. Wendy Heiger-Bernays, Menzie-Cura & Assoc. Dr. Richard Hughto, P.E.,L.S.P.,Rizzo Assoc. Dr. Robert Katz, Wellesley Board of Health Christine LeBlanc,L.S.P., East Coast Engineering, Inc. John McElhinney, Esq., Ropes & Gray Barry Monahan, Asst. V.P. for Administration, Wellesley College Judith Nicolson, Director, Natural Resources Commission Office of the Vice Pre. t for Finance and Administration Wellesley College

1.06 Central Street Wellesley, Massachusetts 02181-8201 (617) 283-2305 FAX (617) 283-3696

September 27, 1996 DELIVERED BY HAND

Ms. Cynthia Weidner Environmental Analyst Executive Office of Environmental Affairs Department of Environmental Protection 10 Commerce Way Woburn, MA 01801

John Fitzgerald, P.E. Deputy Regional Engineer Executive Office of Environmental Affairs Bureau of Waste Site Cleanup 10 Commerce Way Woburn, MA 01801

Re: Wellesley College

Dear Ms. Weidner and Mr. Fitzgerald:

This letter is in response to your letter to Barry Monahan dated August 29, 1996. 1 was pleased to read that the DEP is committed to achieving an interim closure solution for the College expeditiously. This statement of intent is, of course, consistent with the College's goal. I must say, however, that I take issue with certain other statements in your letter, and by the absence of discussion about alternative approaches to resolving this project, which Mr. Fitzgerald suggested, at our July 30, 1996 meeting.

Ms. Weidner, Mr. Fitzgerald -3-

Perhaps most distressing of all is the Agency's failure to respond to the serious legal issues which were raised in the November 18, 1994 letter from our counsel. Indeed, a follow-up letter was sent on August 16, 1996 at your suggestion to Attorney Laurel McKay. Like the earlier letters, this one too remains unanswered. It is inconsistent for the DEP to insist on an ever increasing level of effort from the College, while it fails to address the important legal issues involved. Rather than addressing these serious issues, you suggest that the uncertainties regarding legal responsibility for Lake Waban can now be "deferred," except that you insist that the College analyze the risk associated with exposures to the Lake of students, workers, and visitors. In our view, as stated at the meeting of July 30, this problem is fundamentally one of the Commonwealth.

William Saltonstall. The meeting would also include me, Mr. Monahan, and counsel. Presumably, you, as well as counsel, also would be present.

Please call me as soon as possible so we can jointly arrange a meeting with Secretary Coxe and Commissioner Struhs.

Very truly yours,

William S. Reed Vice President of Finance and Administration

WSR:jm

cc: Dr. Wendy Heiger-Bernays, Menzie-Cura & Assoc. Dr. Richard Hughto, P.E.,L.S.P.,Rizzo Assoc. Dr. Robert Katz, Wellesley Board of Health Christine LeBlanc,L.S.P., East Coast Engineering, Inc. John McElhinney, Esq., Ropes & Gray Barry Monahan, Asst. V.P. for Administration, Wellesley College Judith Nicolson, Director, Natural Resources Commission Office of Assistant V resident for Administration and Community Aff Wellesley College 106 Central Street Wellesley, Massachusetts 02181-8258 (617) 283-2386 FAX (617) 283-3681

September 27, 1996

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Compilation of Site Assessment Reports, Wellesley College, Wellesley, MA

Dear Cynthia:

Enclosed pleased find the document entitled "Compilation of Site Assessment Reports" presenting the results- of site assessment activities conducted at Wellesley College in Wellesley, MA

As addressed in the January 31, 1996 Scope of Work, the assessments conducted focused on determining the nature and extent of contamination based on three criteria. The first criterion is areas where contaminated media have been previously detected; the second are "high use" areas where contaminated media have been previously detected, and where human contact with potentially contaminated soils could occur; and lastly, areas on campus where historical data and correspondence indicated that fill material might have been placed.

This document represents a compilation of individual reports providing detailed information about the physical properties and the results of assessment activities at each separate location studied on campus. For those locations in which notification requirements were triggered, the individual documents were previously submitted to the Department of Environmental Protection, under separate cover. r - -, 4 4

C. Weidner -2-

Following your review of this document, should you have any questions or would like to meet with us to discuss project issues, please feel free to contact me at (617)283-2386.

Sincerely yours,

yF. Mo han Asst. V.P. f Administration and Comm nity Affairs

BFM:jm

cc: Wendy Heiger-Bernays, Ph.D., Menzie-Cura & Associates Dr. Katz, Town of Wellesley, Board of Health Christine LeBlanc, East Coast Engineering, Inc. Mr. John Magenheimer, Town of Wellesley, NRC John McElhinney, Esq., Ropes & Gray E at Coast Engineering, INC. scAN1 e

September 23, 1996

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Attention: Ms. Cynthia Weidner

Reference: Results of Surface Water Sampling Program, September 11, 1996, Public Beach, Lake Waban, Wellesley, MA

Dear Cynthia:

Please find the enclosed analytical data for surface water samples collected on September 11, 1996 at the Public Beach at Lake Waban in Wellesley, Massachusetts. This monitoring program was conducted for the protection of swimmers in Lake Waban and as described in the Remedial Action Measure (RAM) Completion Report dated July 17, 1996.

Two samples were collected at similar locations as the 1995 monitoring program. Sample SWS-1 was collected between the beach and the dock at a depth between 0 to 2 feet of water; this sample location represents a depth at which young children would be exposed during recreations al use. Sample SWD- I was collected at the end of the dock at a depth between 4 to 6 feet of water representing the area where young adults might frequent.

Samples collected on September 11, 1996 were analyzed for total lead, total and hexavalent chromium and total cyanide. This samples were collected mid-day during greatest activity and swimmer usage in Lake Waban. Also, prior to sample collection, the water was agitated to represent swimming conditions.

As shown on the attached laboratory report, the concentrations for each analyte were similar for both samples collected; the total chromium concentration at SWS-1 was 0.0 10 mg/l, and at SWS-2, 0.008 mg/l; the hexavalent chromium concentration at each sampling station was <0.005 mg/l; the total lead at SWS-1 was 0.008 mg/l, and at SWS-2, 0.002 mg/I; and the total cyanide concentration at both stations was <0.01 mg/l. These concentrations were similar to those observed during the August 1996'sampling program.

Since the beach has officially closed for the season, no further testing will be conducted. Following your review of the enclosed information, if you have any questions, please feel free to contact me at (508) 748- 2460.

Sincerely, EAST COAST ENGINERING, INC.

Christine R. LeBlanc Principal

cc: Mr. Barry Monahan, Wellesley College John E. McElhinney, Esq., Ropes & Gray Dr. Katz, Wellesley Board of Health Mr. R. Arnold Wakelin, Jr., Executive Director Mr. John Magenheimer, Wellesley Natural Resource Commission

P. O. Box 745 156A Front Street Marion, MA 02738-0745 Tel: (508) 748-2460 Fax: (508) 748-2553 1.

Inchcape Testing Services* 575 Panupit friye Suite B Environmental Laboratories Raynham, MA 02767-5154

r lR p r aSCL tc

Date 09/20/96 East Coast Engineering, Inc. ETR Number 35509 P.O. Box 745 Project No.: 96800 156A Front Street No. Samples: 2 Marion, MA 02738 Arrived 09/11/96 P.O. Number: Attention : Ms. Chris LeBlanc

Page 1

Project: Wellesley College Waban

Standard analyses were performed in accordance with Methods for Analysis of Water and Wastes, EPA-600/4/79-020, Test Methods for Evaluating Solid Waste, SW-846, or Standard Methods for the Examination of Water and Wastewater - AlL results are in mo/l unless otherwise noted. Lab No./ Sample Description/ Prep Analysis Method No. Parameter Result Date Date Analyst

35509-1 SWS-1 SHALLOW:09/11/96 @1150(WATER) 307B Hexavalent Chromium <0. 005 09/11/96 NAR 216.2 Chromium, Total 0.010 09/13/96 09/17/96 LCP 239.2 Lead, Total 0.DL6 09/13/96 09/16/96 LCP 4500CNE Cyanide, Total <0.01 09/18/96 09/19/96 GCC

35509-2 SWD-1 DEEP:09/11/96 @1200(WATER) 307B Hexavalent Chromium <0. DOS 09/11/96 NAR 218.2 Chromium, Total 0. 008 09/13/96 09/17/96 LCP 239.2 Lead, Total 0.002 09/13/96 09/16/96 LCP 4500CNE Cyanide, Total <0.01 09/18/96 09/19/96 GCC

< Last Page > Submitted By : / Q F7N

375 Paramount Drive, Suite B - Raynham, MA 02767-5154 . Tel: 508-822-9300 - Fax: 508-822-3288 us U

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>1 - tRI 4 4'-, wI ?k 4 Office of Assistant resident for Administration and Community Aff Wellesley College SD .106 Central Street Wellesley, Massachusetts 02181-8258 (617) 283-2386 FAX (617) 283-3681

September 17, 1996

Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01810

Attention: Mr. Kyle MacAfee

Reference: Notification of Release, Wellesley College, Wellesley, MA

Dear Mr. MacAfee:

As part of our campus wide assessment program at Wellesley College, we have identified several areas where the concentrations of metals in soils exceed the Reportable Concentrations. In accordance with the Massachusetts Contingency Plan 310 CMR 40.0315, Wellesley College is providing notification and enclosing the Release Notification Forms (RNF) for each site location and associated reports highlighting the assessment activities conducted to date. These RNF's are submitted in response to a 120-day notification requirements for the following locations:

~ Athletic Field West of Keohane Sports Center "Oval" Tennis Courts

The assessment work conducted was performed in accordance with the scope of work approved by the DEP on March 12, 1996 entitled "Scope of Work for Conducting Assessment Activities at Wellesley College, Wellesley, Massachusetts" and dated January 31, 1996. 2 9

DEP -2-

Should you have any further questions, please feel free to contact me. Thank you for your assistance in this matter.

Sincerely,

BFM:jm

cc: John McElhinney, Esq., Ropes & Gray Dr. Richard Hughto, Rizzo & Associates Dr. Wendy Heiger-Bernays, Menzie-Cura & Associates Christine LeBlanc, East Coast Engineering, Inc.