April 14, 2015 GeoInsight Project 6768-000 Victor D - Town of Canton

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April 14, 2015

GeoInsight Project 6768-000

Victor D. Del Vecchio, Chair Board of Selectmen Town of Canton 801 Washington Street Canton MA 02021 RE:

Environmental Remediation Summary Former Plymouth Rubber Company 104 Revere Street Canton, Massachusetts

Mr. Del Vecchio: As requested, GeoInsight, Inc. (GeoInsight) prepared this letter and attachments to list the environmental reports produced by GeoInsight and previous environmental consultants involved with the Plymouth Rubber facility (the site); provide resumes for key GeoInsight (and subcontractor) personnel involved with the most recent investigations and remedial planning for the site; summarize the on-going third-party oversight of GZA GeoEnvironmental, Inc. (GZA); and provide brief responses to a list of environmental related questions that have been posed regarding the site. Concurrent with posting of this letter to the Town’s website, a combination Phase II Comprehensive Site Assessment (CSA) and Phase III Remedial Action Plan (RAP), dated January 17, 2014, and a Phase IV Remedial Implementation Plan (RIP), dated August 1, 2014, both prepared by GeoInsight, will be made available electronically. ENVIRONMENTAL STATUS GeoInsight recently submitted to the Massachusetts Department of Environmental Protection (MADEP) a combination Phase II CSA and Phase III RAP, and a Phase IV RIP. The Phase II CSA was conducted to evaluate the magnitude and extent of impacts in six known areas of environmental concern at the property. These six areas have active MADEP Bureau of Waste Site Cleanup regulatory files and include:

GeoInsight, Inc. 185 Granite Street, 3rd Floor Suite A Manchester, NH 03101-2643

GeoInsight, Inc. One Monarch Drive, Suite 201 Littleton, MA 01460-1440

GeoInsight, Inc. 200 Court Street, 2nd Floor Middletown, CT 06657-3341

Tel (603) 314-0820 Fax (603) 314-0821

Tel (978) 679-1600 Fax (978) 679-1601

Tel (860) 894-1022 Fax (860) 894-1023

www.geoinsight.com

1) 2) 3) 4) 5) 6)

Vacant Land / Former Debris Disposal Area; Former Solvent Tanks; Building No. 29 Calender Press; Former Railroad Spur; Former Tank Farm; and Sheen/Oil Impacts to Factory Pond (including residual upland areas contributing impacts) and sediment of Factory Pond.

The Phase III RAP was completed to evaluate and rank potential alternatives and technologies to remediate the impacts present in the six release areas. The Phase III RAP is also intended to describe achieving a permanent remedial solution (“Permanent Solution”) when feasible, or otherwise achieving a temporary remedial solution (“Temporary Solution”) under the Massachusetts Contingency Plan (MCP) regulations. The Phase IV RIP provides a more detailed summary of how the selected remedial approaches will be implemented on-site. The three remedial alternatives selected include: •

excavation of impacted soil hot-spots and soil containing non-aqueous phase liquid (NAPL) petroleum and plasticizer products and off-site disposal of the impacted soil at a permitted facility to achieve a Permanent Solution (this alternative is for the Former Solvent Tanks, Building No. 29 Calender Press, Former Rail Road Spur, Former Tank Farm, and the identified upland sources of sheen/oil impacts to Factory Pond);



construction of an engineered barrier over the Vacant Land to cap in-place soil with zinc impacts and achieve a Permanent Solution; and



monitored natural attenuation of impacted sediments in Factory Pond using a long-term monitoring plan to evaluate the continued progress of anticipated degradation to achieve a Temporary Solution.

ENVIRONMENTAL REPORT BIBLIOGRAPHY Environmental Resouce Associates, Inc. (ERA), 1995. Phase I Initial Site Investigation, Plymouth Rubber Company, 104 Revere Street, Canton, Massachusetts, RTN 3-11520, August 23, 1995. ERA, 1997. Phase II Comprehensive Site Assessment, Phase III Remedial Action Plan, Plymouth Rubber Company, 104 Revere Street, Canton, Massachusetts, RTN 3-11520, August 23, 1997. ERA, 1998. Phase I Report, Initial Site Investigation, and Tier Classification, Plymouth Rubber Company, Inc. Canton, Massachusetts, RTN 3-15347, July 27, 1998. ERA, 2000. Phase II Report, Plymouth Rubber Company,104 Revere Street Canton, Massachusetts, RTNs 3-15347 and 3-19744, July 28, 2000. ERA, 2001. Phase I Report, Plymouth Rubber Company, Inc., Canton, Massachusetts, RTN 3-19407, March 28, 2001. April 14, 2015 GeoInsight Project 6768-000

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ERA, 2001. Phase IV Final Inspection Report, Plymouth Rubber Company, Inc., Canton, Massachusetts, RTN 3-115207, August 22, 2001. ERA, 2001. Phase IV Remedy Implementation Plan, Plymouth Rubber Company, Inc., Canton, Massachusetts, RTN 3-19407, September 7, 2001. ERA, 2006. Phase I Initial Site Investigation Report and Tier Classification Vacant Portion of Plat 26, Lot 94, RTN 3-24531, Plymouth Rubber Company, 104 Revere Street, Canton, Massachusetts, January 4, 2006. ERA, 2006. Phase I Initial Site Investigation Report and Tier Classification, Plat 26, Lot 94, Plymouth Rubber Company 104 Revere Street, Canton, Massachusetts, RTN 4-3024840, May 5, 2006. Sanborn Head & Associates, Inc. (SHA), 2007. Tier Classification Submittal, Former Plymouth Rubber Company Site, 104 Revere Street, Canton, Massachusetts, April 6, 2007. SHA, 2007. Immediate Response Action Plan, Former Plymouth Rubber Company Site, 104 Revere Street, Canton, Massachusetts, RTN 4-20412 linked to Primary RTN 4-3011520, May 2007. SHA, 2007. RTN 4-3025379 IRA Completion Statement and Report, RTN 4-3011520 Termination of Remedy Operation Status, Former Plymouth Rubber Company Site, 104 Revere Street, Canton, Massachusetts, August 2007. SHA, 2007. RTN 4-3019744 IRA Status Report, RTN 4-3019744 Modified IRA Plan, RTN 4-3015347, and RTN 4-3019744 Phase III/Phase IV Retraction, Former Plymouth Rubber Company Site, 104 Revere Street, Canton, Massachusetts, August 2007. SHA, 2007-2012. Immediate Response Action Status Reports, Former Plymouth Rubber Company Site, 104 Revere Street, Canton, Massachusetts, RTNs 4-3019744 and 4-20412; May 2007, November 2007, May 2008, November 2008, May 2009, November 2009, June 2010, December 2010, July 2012. GeoInsight, 2012. Tier I Permit Extension and Transfer Application, Former Plymouth Rubber Company RTN 4-3011520, August 31, 2012. GeoInsight, 2013-2015. Initial Response Action Status Reports, Former Plymouth Rubber Company RTN 4-3019744 and RTN 4-20412, January 2013, July 2013, February 2014, July 2014, and January 2015.

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GeoInsight, 2014. Phase II Comprehensive Site Assessment and Phase III Remedial Action Plan, Former Plymouth Rubber Company RTN 4-3011520, January 16, 2014. Included as supporting attachments in Phase II/III report appendices: o Sundstrom, S.A., 2013. Method 3 Risk Assessment, Former Plymouth Rubber Company [Human Health Risk Assessment], Susan A. Sundstrom, Ph.D., D.A.B.T., February 2013. o Woods Hole Group, 2013. Former Plymouth Rubber Company, Stage I/II Environmental Risk Characterization [Ecological Risk Assessment], December 2013. o GZA, 2005. Draft Phase I & II Environmental Site Assessment, Plymouth Rubber Company, June 2005. GeoInsight, 2014. Phase IV Remedial Implementation Plan, Former Plymouth Rubber Company RTN 4-3011520, August 1, 2014. GeoInsight, 2014. Tier I Classification Extension, Former Plymouth Rubber Company RTN 4-3011520, August 29, 2014. GEOINSIGHT PERSONNEL Since mid-2012 when GeoInsight became involved in initiating the site-wide Phase II CSA, Darrin L. Santos, P.G., has served as the environmental project manager responsible for investigation activities, remedial planning and implementation, and subcontractor management. Michael C. Penney, P.E., L.S.P., has served as the Licensed Site Professional-of-Record for the project since 2012 providing senior direction and oversight of the environmental investigation and remedial planning activities. GeoInsight was assisted in the development of the Phase II CSA, specifically in performing a Method 3 Human Health Risk Assessment (HHRA) and Method 3 Stage I and II Ecological Risk Characterization (Stage I/II ERC). GeoInsight contracted with Susan A. Sundstrom, Ph.D., D.A.B.T., a toxicology and HHRA expert, and the Woods Hole Group, Inc. (Jerome Cura, Ph.D., L.S.P., and Joseph Famely) to conduct the Stage I/II ERC. Resumes for Messrs. Santos, Penney, and Famely, and Doctors Sundstrom and Cura, are provided in Attachment A. GZA THIRD PARTY REVIEW The Town recently retained GZA to conduct a third-party review of the GeoInsight Phase II CSA/ Phase III RAP report and the Phase IV RIP. GZA subsequently issued a memo dated February 20, 2015 regarding its review of the GeoInsight documents. GZA’s memo indicated that it agreed with the GeoInsight remedial strategy pending the resolution of some questions regarding the HHRA. GZA’s internal risk assessor issued a memo to GeoInsight with specific questions. GeoInsight and Dr. Sundstrom have provided responses to GZA’s questions. We anticipate that GZA will issue the Town another memo following further review and completion of the HHRA analysis. April 14, 2015 GeoInsight Project 6768-000

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ENVIRONMENTAL Q & A Attachment B includes a list of questions related to environmental matters with respect to the Former Plymouth Rubber site, with brief answers provided by GeoInsight. Please note that the answers were intended to be as brief as possible for presentation to the public at large. Where appropriate, page numbers from the Phase II/III and Phase IV reports where provided so that cross-referencing with more detailed information can be easily performed. Contact us in our Manchester, New Hampshire office at (603) 314-0820 if we can provide any additional information regarding the environmental status of the site. Sincerely, GEOINSIGHT, INC.

Darrin L. Santos, P.G. Senior Geologist cc:

Michael C. Penney, P.E., L.S.P. Principal/Senior Engineer

Canton Holdings, LLC.

P:\6768 Fmr Plymouth Rubber Co., Canton, MA\Memos.updates\April 2015 Memo(drft).doc

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DARRIN L. SANTOS, P.G. Senior Geologist Mr. Santos has managed projects throughout New Hampshire, Massachusetts, and Vermont. He performs and oversees hydrogeologic and contaminant site investigations, due diligence site assessments (Phase I and II), soil and groundwater analytical data collection and analysis, underground storage tank (UST) closures, and remedial planning and implementation oversight. Mr. Santos has been directly involved with several Brownfields redevelopment projects involving assessment, remedial planning, and remedial oversight that focused on returning distressed properties back to productive use in both New Hampshire and Massachusetts. Mr. Santos also focuses on Quality Assurance Project Plan (QAPP) development and implementation and serves as a Quality Assurance Manager in that regard. Mr. Santos also designs and analyzes aquifer exploration programs for water supply, source water protection, and groundwater remediation projects; designs in-situ chemical oxidation (ISCO) remedial injections; and performs vadose and saturated zone groundwater flow and contaminant fate modeling.

Education: B.S., Honors, Env. Science (Geology Concentration), University of Vermont, 1999 Years of Experience: 15 years Areas of Expertise: Site Characterization/Investigation Remedial Planning and Implementation Brownfields Investigation and Remediation Due Diligence and All Appropriate Inquiry Phase I and II Assessments Groundwater and Vadose Zone Modeling In-Situ Chemical Oxidation Drinking Water Source Explorations Aquifer and Water Protection Studies Quality Assurance Project Plans Geographic Information Systems (GIS) Professional Registrations: Professional Geologist: NH Asbestos Disposal Site Worker: NH

CERCLA RESPONSE ACTION PLANNING AND BROWNFIELDS REDEVELOPMENT ASSISTANCE; FORMER MOHAWK TANNERY/GRANITE STATE LEATHERS (PROPOSED NPL SITE); NASHUA, NEW HAMPSHIRE; 2012-Present, Senior Geologist. Reviewed historical and more recent environmental investigation studies associated with this NPLProposed Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) site in Nashua, New Hampshire for a local developer. Built upon existing Solidification/Stabilization (S/S) bench test study and knowledge from teaming relationships with an S/S field implementation contractor and cement industry chemist to develop a revised S/S Bench-Scale Treatability Study Work Plan to evaluate adequate S/S binder mix ratios of cement, blast-furnace slag and other materials for the in-situ encapsulation of leather tannery sludges and stabilization of sludge-related metals located in two unlined lagoons adjacent to the Nashua River and a lined sludge landfill located on an abutting site. Prepared a Conceptual Remedial Action Plan (RAP) further describing how the S/S treatability data will be used to “scale-up” from the bench test to site-wide field implementation of the in-situ S/S technology. The developer-client is actively seeking teaming relationships with retail and commercial redevelopment partners and as economic conditions continue to improve and the redevelopment of the property becomes more feasible, it is expected that the S/S treatability bench test will be conducted and a formal RAP for S/S implementation will be prepared.

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BROWNFIELDS REDEVELOPMENT ASSISTANCE AND MASSACHUSETTS CONTINGENCY PLAN RESPONSE ACTIONS; FORMER PLYMOUTH RUBBER CO./REVERE COPPER WORKS; CANTON, MASSACHUSETTS; 2012-Present;Senior Geologist. Initiated a Phase II Comprehensive Site Assessment and a Phase III RAP under the Massachusetts Contingency Plan (MCP) in 2012 at this 40-acre, abandoned industrial mill complex with a history of a metal/copper works in the 1800s and rubber manufacturing in the 1900s. The MCP Phase II included the advancement and sampling of 60 soil borings and 15 test pits, installation of 20 monitoring wells (to supplement an existing network of 30+ wells), the sampling of 58 monitoring wells, to collect additional data to supplement a substantial existing database of historical soil, groundwater, surface water, and sediment sampling data from six active MCP release areas at the mill complex. Documented impacts to site media include petroleum fuels, lubricating oils, and solvents; plasticizers; and metals associated with both the former rubber manufacturing and copper works conducted on-site. Oversaw a Method 3 human health risk assessment, which used the historical and current Phase II sampling data and supported a Phase III RAP involving hot spot soil removal in five of the six release areas and construction of an engineered barrier in the fifth release area. The human health risk assessment supports unrestricted residential reuse of the property following the proposed hot spot removal and construction of the engineered barrier. Conducted several rounds of sediment sampling and testing, including eco-toxicity bio-assays, to support the Method 3 ecological risk assessment of sediment in the East Branch of the Neponset River, which passes through the site. Prepared a Phase IV Remedial Implementation Plan (RIP), which was submitted in August 2014. Active remediation and site-wide redevelopment is expected to begin in 2015. DUE DILIGENCE ASSESSMENTS, BROWNFIELDS REDEVELOPMENT ASSISTANCE, SOLID WASTE MANAGEMENT RESPONSE ACTIONS; FORMER OUR LADY OF NAZARETH ACADEMY/WINCREST RESIDENTIAL SUBDIVISION; STONEHAM/ WAKEFIELD, MASSACHUSETTS; 2010-2014, Senior Geologist. Conducted Phase I and Phase II due diligence assessment of an abandoned 20-acre girl’s preparatory school for a developer-client planning a 40-unit residential subdivision on the school property. Encountered an area of historical fill-soil and debris deposition on-site, which had been previously cited by the precursor agency of the Massachusetts Department of Environmental Protection (MADEP) in the 1980s as a solid waste “dumping ground.” Oversaw the advancement of over 25 test pits to evaluate the extent of fill-soil and debris deposition on-site. Incorporated a plan to excavate, mechanically sort soil from ash and debris materials, stockpile and segregate separated materials, conduct analytical testing, and reuse the fill-soil on-site as backfill material for the development, while disposing of the segregated ash at a permitted landfill and recycling of recovered metals debris and stumps at proper facilities. The fill-soil and debris management plan was incorporated into an Application for Beneficial Use Determination (BUD), which was submitted to the MADEP Solid Waste Division and was approved in February 2011. The BUD also outlined a management and sampling and analysis plan for the controlled on-site reuse of processed brick, asphalt, and concrete from the demolition of the historical school buildings. Oversaw the excavation, sorting, and reuse of fill-soil and related segregated debris during site-wide redevelopment in 2011-2013. As of summer 2014, the last few remaining residences were under construction at the development and most residences have been sold and occupied. Prepared a BUD Engineer’s Certification and received concurrence from the MADEP that the BUD was implemented properly and the property no longer constitutes a former “dumping ground.”

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BROWNFIELDS REDEVELOPMENT AND REMEDIAL IMPLEMENTATION ASSISTANCE; TROY MILLS, TROY, NEW HAMPSHIRE; 2007-Present; Senior Geologist. Prepared a Brownfields QAPP and RAP for the multi-phase redevelopment project at the 19-acre Former Troy Blanket Mills in Troy, New Hampshire. The approved RAP proposed remediating identified petroleum impacts in two areas using an excavation and off-site disposal/recycling alternative, installing asphalt caps and implementing Activity and Use Restrictions in five separate areas where polycyclic aromatic hydrocarbons were identified in surface soil, additional investigation of possible debris and impacts in a former disposal area, exploring the possible presence of a gasoline UST in another area, evaluating polychlorinated biphenyls (PCBs) and metals in sediments of the Ashuelot River, and monitoring of natural attenuation of residual groundwater impacts. RAP implementation activities were completed in 2007 through 2011 and included several supplemental investigation programs to collect additional data to evaluate proposed or alternative remedial actions; capping of a former disposal area for redevelopment as a parking lot and preparation and recordation of an Activity and Use Restriction; excavating petroleum-impacted soil from a former leaking hydraulic oil lift located in a loading dock area; removing and decommissioning a former gasoline UST and investigating a possible release to groundwater from the former tank; and installing and sampling monitoring wells in several other Areas of Concern (AOCs). To date, 14 of 15 AOCs addressed by the RAP have had remedial or investigative activities completed that are sufficient for achieving regulatory closure. In 2012, a Certificate of Completion was issued for the closed AOCs and a Groundwater Management Permit (GMP) was approved for the site to monitor groundwater quality in the vicinity of a former debris disposal (landfill) area. Biennial GMP monitoring was initiated in May 2014. GROUNDWATER MONITORING/REMEDIAL ACTION PLAN PREPARATION AND IMPLEMENTATION; FORMER LEIGHTON MACHINE COMPANY; MANCHESTER, NEW HAMPSHIRE; 2003-2008; Senior Geologist. Developed a groundwater monitoring program to comply with a GMP issued by the New Hampshire Department of Environmental Services (NHDES) at this renovated mill complex. Following termination of the GMP monitoring after several years of collecting sufficient groundwater quality data, evaluated alternatives and prepared RAPs for remediating two areas containing residual soil impacts from past operations at the former mill. Coordinated and oversaw the excavation, and stockpiling of 75 tons of petroleum- and cyanide-impacted soil located on the building exterior near a former loading dock and the excavation and stockpiling of 100 tons of petroleum-, PCB-, and metalsimpacted soil from a crawlspace located under a portion of the mill facility. Collected soil stockpile characterization analytical data, which was sufficient for a local soil recycling facility to accept 175 tons of soil as non-hazardous waste, at a significant cost savings to the client. Prepared a RIP Completion Report in August 2008 and the NHDES approved the site for regulatory closure in January 2009.

GROUNDWATER MONITORING, DNAPL SOURCE AREA INVESTIGATION, PILOT TESTING, AND DNAPL SOURCE REMEDIATION; CLOSED LANDFILL FACILITY; PETERBOROUGH, NEW HAMPSHIRE; 2002-2011; Project/Senior Geologist/Modeler. Coordinated and implemented revised GMP and source area groundwater monitoring programs consisting of oversight of a four member team sampling over 25 monitoring wells over 2-day periods (bi-annual). Coordinated and oversaw monitoring well installations and soil boring programs, field gas chromatograph surveys, aquifer hydraulic testing activities, and surface water/groundwater interaction studies for source area investigation and pre-remedial pilot testing activities at the site. Designed a post-remediation confirmation soil sampling and residual dense non-aqueous phase liquid analysis program, which was implemented to evaluate remedial progress following hydrogen peroxide/Fenton’s Reagent ISCO injections in 2005, 2006, 2008, and 2010. Prepared a RIP including,

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updated contaminant and fate groundwater modeling projections and statistical analysis of groundwater trends.

DUE DILIGENCE AND BROWNFIELDS ALL APPROPRIATE INQUIRY SITE ASSESSMENTS AND PHASE II SUBSURFACE INVESTIGATIONS; MULTIPLE PROPERTIES, NEW HAMPSHIRE/MASSACHUSETTS/VERMONT; 1999-Present; Project/Senior Geologist. Performed or managed over 50 due diligence assessments for a variety of clients in the manufacturing, financial, municipal, retail petroleum, real estate development, and private sectors. Phase I assessments were completed at several retail and bulk storage petroleum facilities, a 97-acre former wood preservative chemical treatment facility, manufacturing facilities (including an aluminum extrusion fabrication company, a former copper foundry, and a former rubber manufacturer), automobile dealerships, shopping centers, a camp ground, a hotel, a condominium complex, a ski resort, undeveloped land, and other commercial facilities. Phase I Assessments, coupled with subsurface investigations (Phase IIs), have been performed at a many commercial and industrial facilities, including a former paper/pulp mill, a plastic injection molding manufacturing facility, a former retail dry cleaning facility, a bulk petroleum storage facility, retail gasoline stations, a water bottling plant, and a 19-acre campus of a former preparatory school redeveloped into a residential subdivision. CERCLA/SUPERFUND REMOVAL ACTION SITE; FORMER BARREL RECLAMATION FACILITY; PLAINFIELD, NEW HAMPSHIRE; 2002-Present; Project/Senior Geologist. Responsibilities included developing a QAPP and Health and Safety Plan for field sampling, data analysis, and data validation activities performed at the site. Provided oversight of field sampling programs; analyzed and validated laboratory analytical data; and prepared a report summarizing the characterization of approximately 5,400 tons of soil previously stockpiled at the site, which was impacted with PCBs, pesticides, metals, volatile organic compounds, and petroleum hydrocarbons. Directed the loading of 5,400 tons of impacted soil for off-site transportation during the United States Environmental Protection Agency (USEPA) Superfund removal action and prepared a CERCLA removal action closure report as required by the USEPA. Performed a Method Half Risk Assessment to evaluate residual PCB and pesticide soil impacts after completion of the removal action using procedures in the NHDES Risk Characterization and Management Policy (RCMP) by analyzing a database of over 300 soil samples collected at the site. Prepared a Notice of Activity and Use Restriction to manage residual PCB impacts and obtained a Certificate of No Further Action. Managed a 200-ton excavation of petroleum-impacted soil on a second site parcel at the request of the NHDES Oil Remediation and Compliance Bureau and sought reimbursement of excavation and soil disposal costs through the Oil Discharge and Disposal Cleanup Fund. Prepared a GMP Application for monitoring groundwater impacts and currently implementing the GMP monitoring program. FORMER PETROLEUM RETAIL FACILITY; MERRIMACK, NEW HAMPSHIRE; 2000-Present; Project/Senior Geologist. Initial responsibilities included overseeing soil borings and monitoring well installations, performing a soil vapor survey, and soil and groundwater sampling for a Supplemental Site Investigation performed to evaluate the extent of petroleum-impacted soil and groundwater at the site. Developed soil excavation and disposal specifications at the request of the NHDES as the RAP for the site. Coordinated a petroleum-impacted soil remedy project, including the excavation and disposal of 1,395 tons of gasoline-impacted soil in 2002, and preparing a RIP Completion Report. Following the soil excavation project, prepared a GMP Application to monitor residual groundwater impacts and coordinated the decommissioning and removal of the remaining USTs located at the site in 2006, which also included a supplemental excavation of an additional 57 tons of impacted soil. Designed and implemented a sodium persulfate ISCO pilot-injection in 2010 targeting residual soil impacts that

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could not be accessed during the 2002 and 2006 soil excavations. Additional ISCO applications were conducted in 2013 and GMP monitoring will be used to evaluate the effectiveness of the ISCO activities. WELLHEAD PROTECTION AREA DELINEATION MODELING AND AQUIFER PUMP TEST ANALYSIS, PEMBROKE WATER WORKS AND BERLIN WATER WORKS, NEW HAMPSHIRE; 2008-2010; Senior Geologist/Modeler. Designed and implemented a multi-day pumping test of an existing municipal supply well (Pembroke Water Works “Concord Well”) to collect water level monitoring data to evaluate a cone-of-depression in the field and then model the development of the area of contribution to the well using a numerical groundwater model (MODFLOW). Selected locations and oversaw installation of a network of groundwater monitoring wells and stream staff gauges and piezometers in proximity to the proposed well site along the Soucook River. Oversaw the seven-day pre-pumping, five-day pumping, and twoday post-pumping water level monitoring program. Used the site-specific aquifer data collected to develop and calibrate a groundwater flow model to simulate background ambient groundwater flow patterns under non-pumping conditions and then ran the model to simulate the development of the area of contribution over a 180-day pumping period. Prepared a Wellhead Re-delineation Report for the Pembroke Water Works “Concord Well” using the pumping test and groundwater modeling results to support the new wellhead protection area (WHPA). Served as a groundwater modeler for the 2009-2010 analysis of the Berlin Water Works Browns Farm Well (BFW) WHPA. Imported the aquifer testing data from the pumping test and modeled ambient/background groundwater flow conditions and then simulated 180 days of pumping to evaluate a zone of contribution to assist in redefining the WHPA for the Berlin BFW.

NEW MUNICIPAL SUPPLY WELL SOURCE PERMITTING/PUMP TESTING; PEMBROKE WATER WORKS, PEMBROKE, NEW HAMPSHIRE; 2000-2002; Staff/Project Geologist. Initial responsibilities included collecting regional and site-specific hydrogeologic data and performing a potential contaminant survey of the area surrounding the proposed new well located in Bear Brook State Park along the Suncook River. Provided oversight of installation and development of 16-inch diameter overburden gravel-packed well. Designed and implemented a withdrawal testing program to permit the new well including water level and water quality monitoring programs associated with the five-day pumping test; analyzing pumping test data and determining aquifer characteristics; and preparing the final permit application report. Activities were performed under New Hampshire rules for Site Selection of Large Production Wells for Community Water Systems (Env-Ws 379) and Large Groundwater Withdrawal Permitting (Env-Ws 388). A Large Quantity Groundwater Withdrawal Permit for a 300-gallon-per-minute withdrawal was issued by the NHDES in August 2002. SPECIAL TRAINING: Method 3 Risk Assessment Seminar, Massachusetts Licensed Site Professionals Association, June 2014. Biofuels: Release Prevention, Environmental Behavior, and Remediation, Interstate Technology and Regulatory Council, Webinar, June 2012. Taking the Mystery out of Complex Glacial Sequences at Environmental and Geotechnical Sites, Midwest GeoSciences Group, Webinar, June 2012. PCBs in Building Materials, Indoor Air Quality Association of Manchester/Boston, Woburn,

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Massachusetts, April 2012. Fundamentals of Groundwater Geochemistry, National Ground Water Association, Portland, Maine, May 2010. The Design and Construction of Wells, National Ground Water Association, Boston, Massachusetts, February 2007. The New MODFLOW Course, National Ground Water Association, Princeton, New Jersey, October 2005. Hydrogeology, Physical Properties and Basic Principals, Dr. Willard Murray, Londonderry, New Hampshire, May 2004. The Management Conference, CareerTrack, Manchester, New Hampshire, March 2004. Petroleum Hydrocarbons and Petroleum Hydrocarbon Measurements, New England Testing Laboratory, Londonderry, New Hampshire, February 2004. Improving the Hydrogeologic Analysis of Fractured Bedrock Systems, Midwest Geosciences Group/University of Massachusetts-Amherst, June 2002. OSHA 40-Hour Hazardous Waste Operations Training, OSHA 8-Hour Annual Refresher Training, and OSHA 10-Hour Supervisory Training. PUBLICATIONS: Santos, D. L. 1999. The effects of two years of intense military activity on the source areas and source-basin lengths of channel heads in Camp Iron Mountain of the U.S. Army’s former Desert Training Center, Mojave Desert, California. Undergraduate Honors Thesis, University of Vermont, 80 p.

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MICHAEL C. PENNEY, P.E., L.S.P. Principal / Senior Engineer Director of Engineering

Mr. Penney is very familiar with the subsurface geologic characteristics of New England through direct involvement in hundreds of intrusive site investigations of undisturbed and disturbed (or man-made) land, performed throughout the region. These investigations were completed for the purposes of foundation and site-work design, development feasibility, environmental site characterization, and remedial investigation and design. As a result of this experience, he has executed an extensive variety of geotechnical and geoenvironmental evaluations, reports, design applications, and litigation support relative to foundations, soil conditions, ground water and surface water, and contaminated soil remediation. By performing a wide range of investigation and compliance services for his clients, Mr. Penney has become knowledgeable in construction codes and hazardous waste, solid waste, and other environmental regulations pertinent to the New England states.

Education: B.S., Civil Engineering University of New Hampshire, 1984 Years of Experience: 29 years Areas of Expertise: Site Investigation and Characterization Remedial Design and Oversight Landfill Engineering Geotechnical Engineering MCP Comprehensive Response Actions Storage Tank Management SPCC Plan Preparation Construction Management Expert Witness and Litigation Support Site Design and Permitting Storm Water Management Groundwater Management Professional Registrations: Massachusetts Licensed Site

Mr. Penney has been involved in numerous permitting Professional applications involving sitework, solid waste, ground water, Professional Engineer: NH, MA, ME, surface water, and wetlands. His site characterization VT, and CT experience was gained through: personally performing oversight of construction and remedial contractor operations; completing designs for shallow and deep foundations and inspecting foundation installations; designing and overseeing geotechnical boring and monitoring well installations; design and implementation of ground water control, collection, and treatment systems; slope stability assessment and improvements; geosynthetic design projects and installations; construction surveys; design of ground improvement programs; and expert assessment of existing foundations. His document preparation experience includes developing proposals and comprehensive work scopes, review and preparation of contracts, expert witness opinions, creation of technical specifications and bid packages, remedial investigation and feasibility study reports, construction work plans, investigation reports for foundation systems and site development feasibility evaluations, development of remedial and geotechnical design reports for site improvements, risk assessment reports, remedial and as-built construction summaries, and damage assessment reports. Mr. Penney's responsibilities also include senior management of numerous large projects, high level interaction with clients and regulatory personnel, senior peer review, staff group management, geotechnical group practice leader, corporate Director of Engineering, business development, serving on a strategic corporate steering committee, and participating on the GeoInsight Board of Directors.

Resume of Michael C. Penney, P.E., L.S.P. ®

DOVER SUPERFUND LANDFILL SOURCE CONTROL REMEDIAL ACTION DESIGN; DOVER, NEW HAMPSHIRE; 2010 to Present, Senior Engineer. Engineer-In-Charge for design of comprehensive multi-level and multi-well ground water extraction system to be installed to satisfy Record of Decision. Oversaw design team planning and package completion, and worked with client and other affected parties regarding phasing of the planned work. Prepared and reviewed design drawings and details, procured project equipment information, interfaced with subcontractors participating in the design, and prepared and reviewed technical specifications. Also peer-reviewed supporting project documents and submittals related to the SCRA implementation and assisted with remedial contractor selection. BASELINE CONDITION SURVEY, BRIDGE REHABILITATION, SPS NEW ENGLAND, BOSTON, MASSACHUSETTS; 2011, Senior Engineer. In preparation for rehabilitation of several bridges around the Boston area, including the Longfellow Bridge, a sampling plan was prepared in accordance with Massachusetts Department of Transportation specifications, approved by MassDOT, and then implemented to establish pre-existing residual metals concentrations in shallow soils in the immediate vicinity of bridge footprints. Sample collection and mapping were performed to demonstrate significantly degraded background conditions from paint deterioration existed prior to planned paint stripping activities. SITE INVESTIGATION AND PROPERTY TRANSACTION LEADING TO CONSERVATION EASEMENT, LYMAN, NEW HAMPSHIRE; 2010 to 2011, Senior Engineer. Worked with landowner, Trust for Public Land, NH Fish and Game, Amonousic Valley, and NHDES to facilitate transfer of a large tract of land from a family Trust into a conservation easement. The property was approximately 1,000 acres in size and included the side of a small mountain were numerous historical closed mines were present. As part of due diligence activities associated with the transfer, testing of soils around a mine shaft indicated the apparent presence of processing residuals with highly elevated lead concentrations. Because of the unique and remote location of the site, limited access, and proposed use, a focused remedial excavation was performed using specialty equipment, with remedial goals being determined through the use of a Method 3 Risk Assessment. Because of a very tight funding deadline, close coordination with all of the parties was required, and the overall strategy achieved a Certificate of No Further Action and Covenant Not To Sue. REMEDIAL SYSTEM DESIGN, FORMER LAKES REGION CLEANERS, LACONIA, NEW HAMPSHIRE; 2011, Senior Engineer. GeoInsight was contracted by another environmental consultant to provide remedial design engineering services. Remedial excavation was planned to target PCE-impacted soils from a release of PCE from a former dry cleaner. To take advantage of providing additional post-excavation treatment, a downgradient sparge-curtrain wall system was designed with drawings and text. The system was specified to operate in a pulsed mode to continue treating ground water prior to discharge into a nearby lake. J&J CONTRACTORS, FORT DEVENS, MASSACHUSETTS; 2010, Senior Engineer. Provided geotechnical engineering and environmental services to new Armed Forces Reserve Center, which entailed approximately 224,000 square feet of new building development. Work included preparing a comprehensive Environmental Protection Plan for the proposed work; multiple stages of geotechnical investigation and reporting; assisting with sustainability objectives by helping to maximize reuse of on-site materials, including preparation of a Beneficial Use Determination describing reuse of demolished building materials; preparing a sub-slab radon collection system; assessing and addressing historical environmental conditions; and monitoring geotechnical conditions and material conformance to technical specifications.

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Resume of Michael C. Penney, P.E., L.S.P. ®

REMEDIAL DESIGN, WE CARE CLEANERS, KITTERY, MAINE; 2009-2010, Senior Engineer. Took over site from another consultant and designed and performed remedial excavation and characterization activities to address source area impacted from PCE associated with releases from a former dry cleaner. Oversaw redevelopment of area as a paved parking lot. Performed indoor air monitoring for a neighboring restaurant and subsequently designed a vapor management system for a crawlspace below the restaurant due to elevated PCE detection. Worked with MEDEP and the Voluntary Response Action Program to develop approach to help owner maintain regulatory compliance. SPRAGUE ENERGY, INC., MULTIPLE FACILITIES; 2009; Senior Engineer. Acted as senior oversight engineer for compliance and engineering analyses conducted for large, complex bulk fuel terminals at multiple locations. Performed site reconnaissance and then reviewed and updated multiple comprehensive SPCC Plans and Integrated Contingency Plans, and modified associated site plans. Conducted detailed evaluation of secondary containment permeability assessment methods and participated in numerous meetings with the NHDES regarding clarification of definitions in their regulations pertaining to ASTs. Designed containment improvements and methods to demonstrate regulatory compliance following improvements. BROWNFIELDS -FORMER ALLEN ROGERS MILL COMPLEX, LACONIA, NEW HAMPSHIRE; Engineer-In-Charge, 2007-Present. Assisted Chinburg Builders, Inc. with Brownfields and environmental compliance activities at a former mill redeveloped into residential condominiums. Impacts included solvents (from an upgradient drycleaner source), petroleum, and surficial metals. Took over consulting responsibilities from another consultant to address NHDES requests for further investigation and assessment of fuel oil USTs that formerly occupied an area of the site, surficial impacts from metals, and assessment of indoor air. Directed investigation activities to close out of the two separate areas of petroleum impacts, designed of a lead-impacted soil cap area as a Remedial Action Plan and Activity and Use Restriction, and evaluated and monitored solventimpacted ground water from an upgradient source and retrofitted existing sub-slab depressurization system to protect indoor air quality. ADESSA/IMPACT; TAUNTON, MASSACHUSETTS; 2005-2010; Senior In Charge, LSP. Oversaw and designed investigation and response actions for methyl-tert-butyl ether release from an automobile storage facility that impacted numerous bedrock supply wells in a nearby residential neighborhood. Managed a comprehensive investigation plan and directed residential well sampling program for over 30 affected homes. Assessed remedial approaches for bedrock and overburden impacts and design oxidant injection program. Led public and regulatory meetings and assisted client with cost planning and loss prevention. Prepared response action outcome for site. ASHLAND ELECTRIC, ASHLAND, NEW HAMPSHIRE; 2003-Present; Senior In Charge. After analysis of site data, performed remedial feasibility evaluation prepared a revised Remedial Action Plan (RAP), designed a pilot test, and then prepared a design and bid specification package for the installation of an air sparge and soil vapor extraction system. Subsequently prepared a Remedial Action Implementation Plan after the installation, activation, and operation of the system, and currently oversee maintenance activities. INSURANCE AUTO AUCTIONS, INC.; SALEM, NEW HAMPSHIRE; 1994 to Present. Involved with site investigation and characterization of ground water impacts at former auto salvage yard. Prepared Release Detection Permit, Ground Water Management Permit, assessed and prepared documentation related to solid waste compliance, and continue to work with NHDES in evaluating regional ground water quality in the area. Provided engineering evaluation and design of a nine-acre parking lot drainage improvement system that included the use of porous aggregate over a reinforcing

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Resume of Michael C. Penney, P.E., L.S.P. ®

geotextile to facilitate infiltration of precipitation and minimization of rutting due to weak subgrades over a historical landfill area. Developed a design package and obtained permitting through Town Planning Board and State Wetland Bureau, negotiated with abutters, and assisted client with oversight during construction. Prepared SPCC Plan and SWPPP to address site fuel storage and operations. TOWN OF COLEBROOK; NEW HAMPSHIRE; Engineer-In-Charge, 2004-2006. Engineer of Record for a large ground water pump and treat remedial system installed at a remote landfill site where impacts threatened a unique surface water body. Performed feasibility analysis, design, and preparation of detailed bid package for 27-well extraction system (both overburden and bedrock), with complex heated water shallow tray aeration system and dual discharge routes including on-site infiltration. LITIGATION SUPPORT AND EXPERT WITNESS TESTIMONY, PELHAM, NH; Senior Engineer, 2004. Provided deposition and trial testimony in the matter of Gagnon, Bellville, Russell v. Jean-Guy Bergeron. Evaluated investigation and characterization data from defendant’s consultants and from NHDES contract consultant to formulate opinion regarding how a large junkyard contaminated a large number of private drinking water supply wells with petroleum products (MTBE). Testimony involved evaluation and description of MTBE sources; MTBE migration in surface water, unsaturated and saturated overburden, and in bedrock; identification of concentration gradients; and demonstrating connection between release areas as a source and homeowner wells. Jury awarded decision to plaintiffs (group of three adjacent homeowners). TECHNICAL ASSISTANCE; COMMUNITY ADVISORY PANEL; WILMINGTON, MASSACHUSETTS; 2003-Ongoing. Provided high-level technical assessment and presented recommendations to a Town-based public group and then to the Town directly regarding degradation of the Maple Meadow Brook Aquifer from the Maple Meadow Brook Landfill and the Olin Corporation sites. Evaluated historic and on-going technical consultant reports, provided panel members with summaries of pertinent compliance information, prepared written comments for key deliverables to the MADEP, developed a summary report with strategies for moving forward to protect the Town and the public interests, and assisted Town with identifying options for addressing risks. In conjunction with evaluation of the area, also provided technical assessment of proposed use of a railroad siding on the Olin property for a rail transfer station that was being evaluated outside of the Site Assignment process through the Surface Transportation Board and provided comments to demonstrate what the proposed transfer station should go through Site Assignment. ST. PAUL TRAVELERS INSURANCE; MULTIPLE NEW ENGLAND SITES; 2005-Ongoing. Professional Engineer in charge of overseeing building damage claims against client’s insured. Responsibilities include reviewing site conditions, interviewing claimants, assessing structural conditions and energy sources that may have impacted properties, and forming opinions as to the likelihood that damages claimed were related to insured’s activities. MULTIPLE CLIENTS; BOSTON, MASSACHUSETTS; 1999-2004. Prepared engineering work plans for numerous Central Artery/Tunnel General Contractors to address soil management, storm water quality, erosion and sediment control, and ground water management associated with large CA/T projects. Oversaw soil disposal operations including documentation. TOWN OF GOFFSTOWN; GOFFSTOWN, NEW HAMPSHIRE; 2000-2003. Engineer of Record for closure design and construction oversight for two landfills totaling approximately 18 acres, which included detailed slope stability analyses, design of innovative closure strategies for multiple cap types depending upon slope and location, evaluation of retention structures that function as dams in large storm events, designing for maximized beneficial reuse of the landfill using athletic fields and

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Resume of Michael C. Penney, P.E., L.S.P. ®

passive recreational facilities following capping, and preparation of technical specification and bid package for the project with NHDES oversight. SIMPLEX TIME RECORDER; GARDNER AND WESTMINSTER, MASSACHUSETTS; 19931998; Senior Project Engineer. Provided oversight and strategic environmental management assistance during Phase II Comprehensive Site Assessment hydrogeologic investigation activities involving evaluation of a large chlorinated solvent plume in bedrock ground water using fate and transport modeling. Conducted numerous geotechnical investigations at their Gardner and Westminster, Massachusetts manufacturing facilities, including site investigation for a proposed 14,000 square foot building, building additions, evaluation of existing slabs and subgrades for support of new heavy machine loads, evaluation for a proposed vaulted UST, and geotechnical quality assurance/ compliance inspections. TOWN OF FARMINGTON; FARMINGTON, NEW HAMPSHIRE; 1994-2006. Developed and initiated strategic approach for phased closure of the 12-acre Farmington municipal landfill. Providing overall management of activities associated with closure activities and prepared closure design documentation that considered impacts to ground water from an adjacent, off-site landfill. Provided design of storm water management and erosion and control systems associated with closure. Assisted Town with options to keep the landfill active including new cell design. CHICAGO CUTLERY; ANTRIM, NEW HAMPSHIRE; 1994-1995; Senior Engineer. Designed, implemented, and documented a complex multi-media investigation of a turn-of-thecentury mill facility for impacts due to past site operations involving metals. Conducted preliminary stability and hydrologic analyses for four small dams on Great Brook in support of designing remedial approaches for mill site. Prepared Removal Action Plan and Summary Report providing focused remediation of hazardous metal residues, including capping and restoration of adjacent steep stream banks. Prepared hydrogeological assessment sufficient to delay preparation of GMZ permit. S&R CONTRACTING, LOWELL, MASSACHUSETTS; 1996-1998. Prepared permitting information for an under 100 ton-per-day wood demolition debris processing facility including Determination of Need and Site Suitability Report, coordinated initial Environmental Impact Statement evaluation for MEPA submittal. NPL LANDFILL; BROWNING FERRIS INDUSTRIES, INC.; VERMONT; 1993. Responsible for extensive slope stability analysis and portions of the cap design as part of Superfund Accelerated Clean-up Model (SACM) for the closure of a 14-acre landfill. Conducted analyses of storm water runoff to support design of steep downchutes drains. INTERIM REMEDIAL MEASURE & CLOSURE DESIGN, PELHAM LANDFILL; BFI, INC., NEW HAMPSHIRE; 1992-1993. Investigated previously existing landfill cap, designed leachate toe-drain collection system, conducted oversight of toe-drain construction, and was lead engineer for innovative cap design using recycled materials for the cap profile. Conducted as part of the cap design surface water flow analyses of before and after conditions to evaluate and control runoff. INTERIM REMEDIAL MEASURE; SERVICE CHEMICAL CORPORATION, LAIDLAW NORTHEAST, MASSACHUSETTS; 1992. Performed design of and acted as construction manager for two deep ground water collection trench drains (with geosynthetic and soil filters) installed as a supplemental interim remedial measure to control and collect overburden ground water flow impacted by solvents. Designed multi-stage excavation safety support system to facilitate construction. Design required hydrogeological analysis of trench inflow based upon evaluation of ground water and surface water flow conditions and two-stage excavation support system.

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Resume of Michael C. Penney, P.E., L.S.P. ®

SLUDGE MONOFILL CLOSURE PRELIMINARY DESIGN, WASTEWATER TREATMENT PLANT; PRIME TANNING; MAINE; 1990. Participated in geotechnical analysis of existing wastewater sludge stockpiles to determine in-place stability with regard to their function as retention structures and evaluated consolidation characteristics for proposed capping plan. Evaluated capping designs to accommodate dewatering requirements and proper surface water runoff routing. SPECIAL TRAINING: Engineering in Extreme Environments, NH Joint Engineering Societies 2014 Horizontal Well Remediation Workshop 2013 In-Situ Chemical Oxidation, LSPA, 2012 UNH Civil Engineering Alumni Conference, 2012 Emerging Technologies, NH Joint Engineering Societies 2012 Issues Encountered in Defining Boundaries of Disposal Sites, 2012 Strategies for Tackling Brownfields Redevelopment Challenges, 2011 Managing Construction Activities at Disposal Sites, 2011 Ground Water Quality and Geochemistry, 2011 NHDOT Technology Transfer Conference, 2011 BIA/NHDES Waste Management Seminar, 2011 Hydrogeological Aplications of Environmental Geophysics, 2011 Forensic Engineering, NH Joint Engineering Societies, 2010 NHDOT Technology Transfer Conference, 2010 Maine Brownfields Conference, 2010 UNH Civil Engineering Alumni Conference, 2010 Petroleum UVF Screening, 2009 Vapor Intrusion for LSPs, 2009 Short Form Risk Assessments, 2008 MCP Representativeness Evaluation & Data Usability, 2008 NH Dept. of Transportation Technical Transfer Conference, 2008 Geosynthetic Reinforcement Seminar, USDOT/FHA, 2007 In-Situ Chemical Oxidation, LSPA, 2007 Soil Nailing and Earth Retention Seminar, DFI, 2007 MTBE and Other Fuel Oxygenates: Consideration for Assessment & Remediation, NEIWPCC, 2006 Ground Water Flow in Fractured Bedrock, LSPA, 2006 Evaluating Ground Water Flow and Transport Modeling, LSPA, 2005 Activity and Use Limitations, LSPA, 2005 Data Generation Techniques for Env. Risk Characterizations, LSPA, 2005 Update on NHDES Wetland Rules, NHDES, 2005 MCP Regulatory Interfaces, EBI, 2004 Brownfields Redevelopment, ACEC, 2004 Wetland Regulations & the MCP, 2004 MCP Audit 2003 Case Studies, 2003 LSP Professional Conduct, LSP Board, 2003 Environmental Forensics, LSPA, 2003 Analytical Data Enhancement, LSPA, 2002 MCP Audit 2002 Case Studies, 2002 Soil Structure Interaction, BSCE, 2002 Solid Waste Permitting, and Landfill Closure Post-Closure Use, EnviroExpo, 2002 Monitored Natural Attenuation, LSPA, 2002 Addressing Indoor Air Contamination, 2001

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Resume of Michael C. Penney, P.E., L.S.P. ®

NH Solid Waste Conference, NHDES Waste Management Division, 2001 Assessment and Management of MTBE-Impacted Sites, 2001 Indoor Air Contamination, MADEP, 2001 MADEP EPH, VPH, and APH Methods, 2001 LSP Board Regulations and Actions, 2000 Demonstrating Compliance with the MCP through the Conceptual Model Approach, 2000 LSP Capping and Containment, 2000 Interface Friction Evaluation, Geosynthetics >99 Conference, 1999 Professionalism and Professional Ethics for LSPs, 1999 Understanding and Using Activity and Use Limitation and Public Involvement Requirements of the MCP, 1998 Remediation Waste and Remedial Wastewater Management, Massachusetts Department of Environmental Protection, 1997 Contaminated Sites Corrective Action Seminar, NH Depart. of Environmental Services, 1997 Using and Understanding Engineering and Construction EJCDC Contract Documents, ASCE/NSPE Seminar, 1996 Title 5 Regulations Seminar, MADEP, 1995 Petroleum Remediation and Reimbursement Funds Conference, NHDES, 1994 Seminar on "Policies and Trends in Environmental Remediation," BSCE, 1994 Storm Water Management and Erosion and Sediment Control Seminar, NHDES, 1993 Project Management Seminar, Pryor Resources, Inc., Nashua, NH, 1993 Excavation Safety Seminar, sponsored by the ASCE, Cambridge, MA, 1992 Completed graduate level course "Hydrologic Monitoring," UNH, 1992 Seminar on RCRA Corrective Action and Stabilization Technologies, EPA, 1991 Specifying and Designing with Geogrids Seminar, Tensar Earth Technologies, 1991 New England Seismic Design Lecture Series, M.I.T., 1991 Hydric Soils and Wetland Species Identification Short Course, NHDIA, 1990 Design, Construction and Performance of Deep Excavations in Urban Areas, Geotechnical Seminar, MIT, 1989 PUBLICATIONS: Redding, M.J., and Penney, M.C., “A Model For Landfill Reuse; A Narrative on the Costs and Technical Issues For Redeveloping Landfills,” presented at the New England Environmental Expo, Boston, MA 2002. Gilbert, J.A. and Penney, M.C., "Multi-Media Investigation of a New Hampshire Mill Site," presented at the New England Environmental Expo, Boston, MA, May 1995. PRESENTATIONS: Civil Engineering Department Guest Lecturer on Engineering Liability at UNH Durham 2012 Monitoring and Record Keeping, NH Stormwater Management 2013, HalfMoon Seminars, 2013 Sustainable Slope Features, NH Greenslopes Conference, 2011 Understanding Geotechnical Reports in Massachusetts, Lorman Seminars, 2010 Landfill Reuse as a Sustainability Option, UNH Civil Alumni Conference, 2010 The Science Behind Landfills, Toxics Action Center, 2005. Landfill Closure and Post-Closure Uses, Enviro Expo, 2002.

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Resume of Michael C. Penney, P.E., L.S.P. ®

PROFESSIONAL AFFILIATIONS: American Society of Civil Engineers & Geo-Institute North American Geosynthetics Society American Ground Water Association International Society for Soil Mechanics and Geotechnical Engineering American Council of Engineering Companies

OTHER: American Council of Engineering Companies – Executive Board Member since 2006, served as President 2010 & 2011 Appointed by the Governor’s Office to serve as a representative of business and industry on the Commission to Study Requirements For Safe and Secure Landfills, 2007 to present. Served on a NHDES workgroup to redevelop template specifications for remedial excavation projects, 2005. Served as a technical judge for the 2004 Association of Builders and Contractors (ABC) Excellence in Construction Awards. Served on the Architects, Contractors, and Engineers committee as an ASCE representative for 1996, 1997, and 1998 (Chairman).

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SUSAN A. SUNDSTROM, Ph.D., D.A.B.T.

Expertise

Dr. Sundstrom has over twenty years of research and consulting experience specializing in toxicology and human health and ecological risk assessment. Dr. Sundstrom provides expert advice in toxic tort litigation, develops risk-based cleanup criteria, and performs human health and ecological risk assessments involving a wide variety of industrial chemicals and hazardous wastes. She also consults for industrial clients on the toxicological properties of commodity and specialty chemicals used in their manufacturing processes. She has authored numerous scientific publications and technical reports, and given presentations on diverse toxicological and risk assessment issues. Prior to consulting, while in the division of Reproductive Biology of the Obstetrics and Gynecology Department at the University of Pennsylvania, she conducted medical research at the molecular level to establish the mechanisms by which chemicals and hormones modulate cell growth and influence cancer. Dr. Sundstrom's Ph.D. thesis was in the Department of Biochemistry at Dartmouth Medical School and involved an investigation of the effects of estrogens and polycyclic aromatic hydrocarbons on the induction of cytochrome P450. Dr. Sundstrom is board certified by the American Board of Toxicology.

Office Location

9 St. James Place, Unit 904, Nashua, New Hampshire 03062

Academic Background

Post-Doctoral Fellowship, 1987-1990, University of Pennsylvania, Department of Obstetrics & Gynecology, Division of Reproductive Biology. Received a National Research Service Award. Ph.D., 1987, Toxicology/Pharmacology, Dartmouth College, Hanover, New Hampshire. Received Ryan Foundation Fellowship. Bachelor of Art with Distinction, 1977, Zoology, University of New Hampshire, Durham, New Hampshire.

Professional Experience

Independent consultant, June 1995 - present. Senior Toxicologist with Balsam Environmental Consultants, A Unit of Dames & Moore, Salem, New Hampshire. January 1992 - May 1995 Senior Scientist with Cambridge Environmental, Inc., Cambridge, Massachusetts. May 1990 - December 1991

Representative Experience Human Health and Ecological Risk Assessment Dr. Sundstrom has extensive experience in performing and criticizing human health and ecological risk assessments under the Federal processes as well as under several state processes including Massachusetts, Maine, New Hampshire, Vermont, New York, Georgia, Colorado, Connecticut, New Jersey, Texas, and Pennsylvania. Some of these projects are described herein.

S.A.Sundstrom, Ph.D., D.A.B.T. July 2012

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Technical Work Group Leader for Human Health Section for New Hampshire Comparative Risk Project. Responsibilities include managing a Technical Work Group of experts to research and rank human health risks in the State of New Hampshire, coordinating with a Public Advisory Group and Management Committee, and writing a final technical report. Expert testimony and litigation support regarding human health and ecological risk assessment performed for a site in Massachusetts impacted with polychlorinated biphenyl compounds, polycyclic aromatic hydrocarbons, metals, and volatile organic compounds in ground water, soil, surface water and sediment. Support included review of the risk assessment procedures, assumptions, and calculations, and development of alternative risk-based remedial goals. General Electric Company, Schenectady, New York. Human Health risk assessment for a facility involved in manufacture of turbines and generators. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air potentially impacted with chlorinated volatile organic compounds, polychlorinated biphenyl compounds, polycyclic aromatic hydrocarbons, and metals. Performed in accordance with the USEPA guidelines. Logan International Airport, Boston, Massachusetts. Litigation support regarding the selection of remediation goals for 29 sites impacted primarily with petroleum hydrocarbon compounds. Support included review of the analytical data collected on each site and reports submitted for each site including assumptions used to estimate the costs of remedial activities. Support also included calculation of alternate remediation goals based on current and future use of the site as an airport in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. Varian Associates, Inc., Massachusetts. Human Health risk assessment and Stage I Environmental Screening for a facility involved in research and manufacture of electronic equipment. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air potentially impacted with chlorinated volatile organic compounds and metals including cyanide. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. In addition, performed an Imminent Hazard Evaluation for a residential home impacted with VOCs in indoor air within the basement. Spoke at public hearing and prepared fact sheets for public distribution as part of Public Involvement Plan process. General Electric Company, Medford and Lenox, Massachusetts. Human Health risk assessment and Stage I Environmental Screening for two facilities involved in research and manufacture of electronic equipment. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air potentially impacted with chlorinated volatile organic compounds, polychlorinated biphenyl compounds, metals, and petroleum. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan.

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Ingersoll Rand Company, Walpole, Massachusetts. Human Health risk assessment and Stage I Environmental Screening for a former manufacturing facility. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air potentially impacted with chlorinated volatile organic compounds, polychlorinated biphenyl compounds, metals, and petroleum. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. Westover Air Force Base, Chicopee, Massachusetts. Human Health risk assessments for several Sites within the operating air force base. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air potentially impacted with chlorinated volatile organic compounds, polychlorinated biphenyl compounds, metals, and petroleum. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. Clean Harbors of Braintree, Massachusetts. Human Health risk assessment for RCRA facility. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air potentially impacted with volatile organic compounds, polychlorinated biphenyl compounds, metals, semi-volatile organic compounds, metals, and petroleum. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. 44 and 174 Post Office Square, Lowell, Massachusetts. Massachusetts Department of Environmental Protection Method 3 Human Health and Environmental Risk Assessment for a former manufacturing facility located along the Merrimac River. Human health risks were evaluated for future employees, construction workers and pedestrians who could be exposed to residual metals, polycyclic aromatic hydrocarbons and fuel oils detected in soil. A Stage I environmental screening assessment was performed to assess the potential risks to aquatic receptors that could result from the migration of chemicals in ground water to the Merrimac River. PolyOne, Newton Upper Falls, Massachusetts. Massachusetts Department of Environmental Protection Method 3 Human Health and Environmental Risk Assessment for a former plastics manufacturing facility. Human health risks were evaluated assuming that the property could be used for residential purposes in the future. Risks were evaluated for hypothetical residents who could be exposed to residual phthalate compounds and petroleum detected in soil and ground water. Clean Harbors, Inc., Massachusetts. Massachusetts Department of Environmental Protection Method 3 Human Health and Environmental Risk Assessment for a former foundry. Human health risks were evaluated for employees, construction workers and trespassers who could be exposed to residual metals detected in soil. Hampshire College, Amherst, Massachusetts. Human Health Risk Assessment for an apple orchard on which lead arsenate pesticides had been used. Human health risks were evaluated for employees, students, and construction workers who could be exposed to arsenic and lead detected in soil.

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Hercules, Inc., New Jersey. Human Health risk assessment for a large manufacturing facility including four landfills in New Jersey. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, and sediment impacted with chlorinated pesticides including DDT, polychlorinated biphenyl compounds, chlorinated volatile organic compounds, and metals. Performed in accordance with the USEPA guidance. Pierce, Atwood, Scribner, Allen, Smith & Lancaster, Portland, Maine. Expert testimony and litigation support regarding risk-based remedial goals developed for potential indoor air contamination for a residential site in Maine impacted with No. 2 Fuel Oil. Loctite Corporation, Connecticut. Human health risk assessment as part of a real estate transfer for a chemical manufacturer in Connecticut. Exposures primarily included inhalation of indoor air impacted with volatile organic compounds volatilizing from impacted ground water beneath the site. Support included recommendations regarding the types of uses appropriate for the property. McKin Superfund Site, Maine. Provided technical support to a Superfund Site Citizens Advisory Group under a Technical Assistance Grant. Support included helping the public interpret the human health and ecological risk assessments and understand the mechanisms by which chemicals can affect the health of humans and other species. Raymark Superfund Site, Stratford, Connecticut. Provided technical support to a Superfund Site Citizens Advisory Group under a Technical Assistance Grant. Support included helping the public interpret the human health and ecological risk assessments and understand the mechanisms by which asbestos, metals including lead, polychlorinated biphenyl compounds, polycyclic aromatic hydrocarbons, and chlorinated solvents can affect the health of humans. Support included review of USEPA human health and ecological risk assessments and review of proposed remedial solutions. Troy Mills, New Hampshire. Reviewed toxicity of several alkyl benzene compounds to change the Reference Doses (i.e., toxicity factors) proposed by the New Hampshire Division of Public Health/Department of Environmental Services. Negotiated with NHDPH and USEPA for alternate toxicity factors that would increase remedial goals approximately 100-fold. ConocoPhillips Company, Massachusetts. Performed MADEP Method 3 risk assessments for several former and operating gasoline station sites as part of real estate transfers. ConocoPhillips Company, Massachusetts. Performed MADEP Method 3 risk assessments for sites on former agricultural chemical manufacturing company on Weymouth Neck. Site included residential condominiums, marinas, undeveloped land, and a Webb State Park, chemicals of concern included metals, polycyclic aromatic hydrocarbons and petroleum compounds. Department of the Army, New England Division Corps of Engineers, Massachusetts. Human Health risk assessment and Stage I Environmental Screening for a former dump. Assessment included an evaluation of risks resulting S.A.Sundstrom, Ph.D., D.A.B.T. July 2012

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from exposure to soil, ground water, surface water, and sediment impacted with semi-volatile organic compounds (primarily polycyclic aromatic hydrocarbons) and metals. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. General Electric, New York. Human Health risk assessment performed for 640 acre site including three landfill areas. Assessment included an evaluation of risks resulting from exposure to volatile organic compounds, polycyclic aromatic hydrocarbons, polychorinated biphenyl compounds, and metals detected in soil, ground water, surface water, and sediment. Performed in accordance with current USEPA guidelines. Felters Mill, Massachusetts. Method 3 Human Health risk assessment and Stage I Environmental Screening for a former mill property located on the Blackstone River. Assessment included an evaluation of risks resulting from exposure to soil, ground water, surface water, and sediment impacted with compound present in No. 6 Fuel Oil. Performed in accordance with the Massachusetts Contingency Plan. American Airlines, Massachusetts. Method 3 Human Health risk assessment and Stage I Environmental Screening for a former tank farm at Logan International Airport. Assessment included an evaluation of risks resulting from exposure to soil, ground water and indoor air impacted with compound present in jet fuel. Performed in accordance with the Massachusetts Contingency Plan. Clean Harbors, Massachusetts. Developed site-specific risk-based cleanup goals for soil and ground water for a Resource Conservation and Recovery Act facility located in Massachusetts that was subject to corrective action requirements of the Hazardous and Solid Waste Amendments to RCRA. The Areas of Concern were impacted with volatile organic compounds, polycyclic aromatic hydrocarbons, metals, and polychlorinated biphenyl compounds. The cleanup goals considered direct exposure to onsite receptors as well as potential exposure to offsite receptors that could occur with migration of contaminants in ground water to nearby surface water bodies. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan and with USEPA guidance. Clean Harbors Braintree, Massachusetts. Method 3 Human Health risk assessment performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 for a Resource Conservation and Recovery Act facility. The chemicals of concern included volatile organic compounds, polycyclic aromatic hydrocarbons, metals, petroleum hydrocarbons, and polychlorinated biphenyl compounds. Risks were calculated for employees, trespassers, construction workers, and hypothetical residents who could be exposed via soil and indoor air. Former Carr Leather, Lynn, Massachusetts. Human health risk assessment performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. Chemicals of concern included chlorinated volatile organic compounds, metals and petroleum hydrocarbon compounds. Risks were calculated for employees, construction workers and trespassers.

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Former Princess House, Dighton, Massachusetts. Imminent Hazard Evaluation and Method 3 Human health risk assessment performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan for a former lead crystal manufacturing company. Chemicals of concern included chlorinated volatile organic compounds and lead. Risks were calculated for employees, trespassers and hypothetical residents who could be exposed to impacted soil, sediment and indoor air. Merrimack Valley Works, North Andover, Massachusetts. Human health risk assessment performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan for former manufacturing facility. Chemicals of concern included volatile organic compounds and petroleum hydrocarbon compounds. Risks were calculated for employees and future construction workers. Mike’s Citgo, Taunton, Massachusetts. Method 3 Human Health risk assessment and Stage I Environmental Screening for a gasoline service station and surrounding residential properties. Assessment included an evaluation of risks for soil, ground water and potential indoor air impacts. Just-A-Start Corporation, Massachusetts. Method 3 Human Health risk assessment and Stage I Environmental Screening for a former manufacturing facility located in Cambridge, Massachusetts. Assessment included an evaluation of risks for future re-development of industrial property for residential use. USEPA, Region I. Evaluation of human health risks associated with contact with arsenic, lead and polycyclic aromatic hydrocarbons detected in soil, sediment and shellfish on/near residential properties in Weymouth, Massachusetts, which were formerly used for industry. Assessment performed on behalf of USEPA using both USEPA and MADEP risk assessment guidelines.

Former Fort Devens, Devons, Massachusetts. Human Health risk assessment to evaluate potential health risks to future residents, employees, construction workers, and trespassers potentially exposed to chlorinated pesticides at a former military facility proposed for re-development. Performed in accordance with USEPA Region 1 and the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. United States Postal Service, Massachusetts, Connecticut. Human Health and ecological risk assessments for post office facilities in several cites in Massachusetts and Connecticut. Assessments included an evaluation of risks resulting from exposure to soil, ground water, surface water, sediment, and indoor air impacted with a variety of organic compounds and metals. Also, established risk-based soil concentrations to establish the maximum concentrations of VOCs in soil that could be placed beneath the future building (in lieu of off-site disposal) and still provide acceptable protection for employees working in the building. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan or the State of Connecticut Remediation Standard (Section 22a-133k-1).

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Dover Municipal Landfill Superfund Site, Dover, New Hampshire. Assessment of current human health risks associated with the use of ground water compared to the previous assessment of risks to re-evaluate remedial options and to examine the feasibility of changing the Record of Decision at a federal Superfund Site in Dover, New Hampshire. Calculations involved comparisons of risks between former and current ground water conditions, former reference doses and cancer slope factors and updated toxicity factors, and former and more recent default exposure assumptions. Results of the assessment were incorporated into a costbenefit analysis. Elizabeth Mine Superfund Site, South Strafford Vermont. Assessment of human health risks associated with mine tailings in soil, ground water, surface water, fish, and sediment. Beazer East, Inc., New Jersey. Developed site-specific risk-based cleanup goals for soils impacted with polycyclic aromatic hydrocarbons and metals for a wood treatment plant located in New Jersey. Risk-based goals were developed based on methods consistent with New Jersey Department of Environmental Protection Agency regulations and USEPA regulations and guidance. Tombatillo, Lawrence, Massachusetts. Human health risk assessment for site proposed for re-development under Brownfields program. Evaluation of soils impacted with polychlorinated biphenyl compounds and polycyclic aromatic hydrocarbons for a former manufacturing Site in accordance with USEPA Region 1 and the Commonwealth of Massachusetts Regulation 310 CMR 40.0900 of the Massachusetts Contingency Plan. United States Air Force. Human health and ecological risk assessment for an industrial site in Massachusetts used to research and develop material for use in rapid repair of bomb-damaged runways. Performed in accordance with the Commonwealth of Massachusetts Regulation 310 CMR 40.545 of the Massachusetts Contingency Plan, with special consideration of the revised MCP (July, 1993). Spoke at a public hearing regarding the findings of the risk assessment as part of the Public Involvement Plan activities mandated by the MCP. Disposal Specialists, Inc., Vermont. Ecological risk assessment under CERCLA for a municipal landfill in Vermont. Identified ecological receptors that may be exposed to chemicals associated with landfill seeps, quantified levels of exposure and developed information on toxic effects of chemicals to characterize risks to the ecosystem. Review of proposed State of Maine Guidance Manual for Human Health Risk Assessments at Hazardous Substance Sites on behalf of the Paper Industry Information Office (PIIO). Preparation of criticisms regarding Draft guidance for PIIO to be used at State of Maine Department of Environmental Protection workshops and public hearings. Critique of U.S. EPA's ecological risk assessment for a Superfund Site in New Bedford Harbor, Massachusetts. Included an evaluation of sediment clean-up standards for polychlorinated biphenyl compounds by reviewing exposure and toxicity assessments involving analysis of MATC values for various aquatic species. S.A.Sundstrom, Ph.D., D.A.B.T. July 2012

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Critique of U.S. EPA's human health risk assessment for the Sullivan's Ledge Superfund Site in New Bedford, Massachusetts. Included an evaluation of exposure pathways and toxicity profiles of polycyclic aromatic hydrocarbons and polychlorinated biphenyl compounds. Ecological study concerning the effects of polychlorinated biphenyl compounds on the population of Massachusetts Species of Special Concern (Crangonyx aberrans) at the Sullivan’s Ledge Superfund Site in New Bedford, Massachusetts. Wheelabrator Technologies, Inc., Virginia. Human health risk assessment concerning a proposed municipal solid waste-to-energy facility in Tidewater, Virginia. Spoke at a public hearing regarding potential health effects of airborne contaminants with special reference to mercury and dioxins.

Toxicology and Litigation Support Litigation support regarding potential birth defects from exposure to volatile organic compounds and adhesive mixtures in Chicago, Illonois. Included review of the scientific literature, preparation of affidavits, deposition and trial testimony. Litigation support and expert testimony regarding potential health effects from exposure to vapors during the use of cyanoacrylate and methacrylate adhesives for a client in Florida. Included review of scientific literature, analysis of deposition and reports of plaintiff's expert and review of medical records to assist with case strategies. Litigation support regarding health effects of constituents present in chemical waste generated from a former coal gas manufacturing plant in Massachusetts. Support also included critique of human health and ecological risk assessment. Litigation support regarding health effects of n-hexane for a workman’s compensation case. Support included review of scientific literature, review of medical records, review of indoor air analytical data, and review of health basedstandards and guidelines. The Timberland Company, New Hampshire. Strategic environmental compliance assessment of six manufacturing facilities located in three states and two overseas locations. Provided report to establish more focus on occupational health issues with respect to the use of industrial chemicals. Loctite Corporation, Connecticut. Review of scientific and medical literature to evaluate the toxicological effects of over 800 commodity and specialty industrial chemicals for a major chemical manufacturer in Connecticut. The information is used to identify target organ effects for the preparation of Material Safety Data Sheets. Loctite Corporation. Provide on-going scientific support for United States and worldwide offices. For example, support includes research of the scientific literature to evaluate potential toxicity of new chemicals considered for market or of old chemicals for new uses, interpretation of the scientific literature to assist S.A.Sundstrom, Ph.D., D.A.B.T. July 2012

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with compliance with appropriate regulations, and preparation of warning labels for art material under The Labeling of Hazardous Art Materials Act. Provided support to challenge American Conference of Governmental and Industrial Hygienists proposed change in Threshold Limit Values for cyanoacrylate compounds. Provided scientific support for an epidemiological study to support position. New Hampshire Port Authority, New Hampshire. Development of sections of a mitigation plan under Clean Water Act to compensate for estuarine habitat losses for a proposed port expansion project at Portsmouth Harbor, New Hampshire. Included design for enhancement and creation of eelgrass, salt marsh and mudflat habitats. Litigation support and expert testimony regarding work place exposure to crystalline silica for a client in New Jersey. Included review of epidemiological literature, expert report regarding possible adverse respiratory effects from this exposure, analysis of deposition and reports of plaintiff's expert and medical records to assist with case strategies. Litigation support and expert testimony regarding work place exposure to adhesives for a client in Illonois. Included review of epidemiological literature, expert report regarding possible adverse reproductive and developmental effects from this exposure, analysis of deposition and reports of plaintiff's expert and medical records to assist with case strategies, and deposition testimony. Toxic tort litigation support for a client in Pennsylvania. Included review of the scientific basis for the American Conference of Governmental and Industrial Hygienists recommendations and Occupational Safety and Health Association standards for asbestos fibers including the evidence for differential risks depending on fiber types and size. Toxic tort litigation support for several clients in Texas, Florida, Indiana, North Carolina, Minnesota, New Hampshire and Massachusetts. Cases involved toxicity analysis of various chemicals, risks of exposure, adverse health effects, review of medical records for toxic torts.

Invited Lectures

Invited lecturer Boston College, Department of Geology and Geophysics, Boston, MA. Lectured on the fundamentals of toxicology and human health risk assessment, 1991 Invited lecturer New England Water Environment Association. Lectured on human health and environmental risk assessment procedures applicable to the revised 1994 Massachusetts Contingency Plan, 1994. Invited lecturer Massachusetts Department of Environmental Protection — Office of Research and Standards, Boston, MA. Introductory course on the fundamentals of human health and ecological risk assessment for Massachusetts Department of Environmental Protection Agency staff, 1995.

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Invited lecturer Massachusetts Continuing Legal Education, Inc. Seminar entitled Human Health Risk Assessment Under the Massachusetts Contingency Plan for the program The Science of Hazardous Waste — A Primer for Environmental, Real Estate, Personal Injury and Probate Attorneys, 1996. Invited lecturer New Hampshire Public Health Association. Presented and participated in the panel discussions on the role of environmental health issues in New Hampshire’s State Health Plan for the 1996 Forum Public Health: Getting the Message Out, 1996. Invited lecturer Massachusetts Institute of Technology — Department of Civil and Environmental Engineering, Cambridge Massachusetts. Lectured on the role of toxicology in risk assessment to Master of Engineering degree candidates, 1996, 1998. Invited lecturer Connecticut Bar Association. Seminar entitled Risk Assessment as a Strategic Remediation Tool for the program Environmental Science — A Primer for the Technically Impaired, 1998. Invited lecturer Northeastern University — Department of Engineering, Boston Massachusetts. Lectured on the role of risk assessment in remedial strategy to Master of Engineering degree candidates, 2000.

Professional Affiliations

Boston Risk Assessment Group/New England Chapter of Society of Risk Analysis American College of Toxicology Society of Environmental Toxicology and Chemistry

Publications

Wozmak, R.J. and S.A. Sundstrom, Applying Risk Assessment and Activity and Use Limitations in Place of Remedial Actions at a Petroleum Impacted Site. 14th Annual Conference on Contaminated Soils. October 1998. DeVoto, E., L.C. Green, T.L. Lash, M.B.G. Pilkington, S.A. Sundstrom, and S.G. Zemba, "Mercury: Sources and Risks, with Special Consideration of Combustion of Municipal Solid Waste," Cambridge Environmental, Inc., November, 1990. Devoto, E., M. Pilkington, S.A. Sundstrom, and S. Zemba. (1991) Exposure to Mercury: The Importance of Waste-to-Energy Facilities. Proceedings of the 1991 USEPA/Air & Waste Management Association International Symposium, 1077. Sundstrom, S.A., B.S. Komm, H. Ponce-de-Leon, Z. Yi, C. Teuscher and C.R. Lyttle, 1989. Estrogen Regulation of Tissue Specific Expression of Complement C3. J. Biol. Chem. 264(28):16941. Sundstrom, S.A., B.S. Komm, Q. Xu, V. Boundy and C.R. Lyttle, 1990. The Stimulation of Complement Component C3 Gene Expression by Antiestrogens. Endocrinology 126(3):1449.

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Brown, E.O., S.A. Sundstrom, B.S. Komm, Z. Yi, C. Teuscher and C.R. Lyttle, 1990. Progesterone Regulation of Estradiol-Induced Rat Uterine Secretory Protein, Complement C3. Biol. Reprod. 42:713. Albert, J.A., S.A. Sundstrom and C.R. Lyttle, 1990. Estrogen Regulation of Placental Alkaline Phosphatase Gene Expression in an Endometrial Adenocarcinoma Cell Line. Cancer Res. 50:3306. Yi, Z., S.A. Sundstrom, C.R. Lyttle and C. Teuscher, 1989. Differential Expression of Estrogen-Regulated CD4 and 1a Positive Cells in the Immature Rat Uterus. J. Leukocyte Biol. 46:493. Galman, M.S., S.A. Sundstrom, and C.R. Lyttle, 1990. Antagonism of Estrogen and Antiestrogen Induced Uterine Complement Component C3 Expression by ICI 164,384. J. Steroid Biochem. 36:281-286. Sundstrom, S.A., J.F. Sinclair, E.L. Smith, and P.R. Sinclair, 1989. Immunochemical Characterization of the Cytochrome P450 induced by 3-Methylcholanthrene and Ethynylestradiol. Biochemical Pharmacology 38(13):2215. Sundstrom, S.A., J.F. Sinclair, E.L. Smith, and P.R. Sinclair, 1988. Effect of Ethynylestradiol on the Induction of Cytochrome P450 by 3-Methylcholanthrene in Cultured Hepatocytes. Biochemical Pharmacology 37(6):1003. Lyttle, C.R., S.A. Sundstrom, E. Brown, H. Ponce-de-Leon, Z. Yi, and C. Teuscher, 1989. Hormonal Regulation of Rat Uterine C3 Expression. Complement and Inflammation 6(5):364. Lyttle, C.R., S.A. Sundstrom, H. Ponce-de-Leon, and B.S. Komm, 1989. Identification of an Estradiol-Induced Rat Uterine Secretory Protein as Complement Component C3. The Endocrine Society 71st Annual Meeting. Abstract 725, p.204. Sundstrom, S.A., B.S. Komm, H. Ponce-de-Leon, and C.R. Lyttle, 1988. Estradiol Regulation of the mRNA Coding for a Rat Uterine Secretory Protein. Endocrinology Suppl., 122, Abstract #1302, p.346. Sundstrom, S.A., J.F. Sinclair, E.L. Smith, and P.R. Sinclair, 1987. Effect of Ethynylestradiol on the Induction of Cytochrome P450 by 3-Methycholanthrene in Cultured Hepatocytes. The Toxicologist 7:36. Devlin, D., S.A. Sundstrom, and P.R. Sinclair, 1986. Uroporphyrin Accumulation in the Chick Embryo Hepatocyte Culture Caused by Lindane. Fifteenth Annual Meeting of the New England Pharmacologists. Sundstrom, S.A. and B.D. Roebuck, 1984. Enzyme Histochemistry of AzaserineInduced Atypical Acinar Cell Foci in Rat Pancreas. Thirteenth Annual Meeting of the New England Pharmacologists.

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Woods Hole Group PROFESSIONAL PROFILE

JOSEPH FAMELY, M.E.M. Qualifications Summary

Environmental Scientist



Fields of Expertise



Experience developing sustainability plans and indicators, climate change vulnerability assessments, greenhouse gas inventories, and urban master plans. Experience conducting ecological risk assessment, including fieldwork, database design and management, chemical exposure calculation, and risk analysis.



Experience conducting shoreline change analyses.



Adept at spatial analysis, data visualization, and writing for both technical and general audiences.



ESRI ArcGIS; ETGeowizards; MatLab; SimaPro Life Cycle Assessment; StatSoft Statistica; SigmaPlot; Vensim; Microsoft Office; Adobe Photoshop and Illustrator.

Environmental management, systems modeling, environmental impact analyses, ecological risk assessment, geospatial analysis, land use planning, sustainable design, greenhouse gas accounting, sustainability reporting, shoreline change analysis, climate change vulnerability assessment and adaptation planning. Higher Education M.E.M. B.A.

Yale School of Forestry & Environmental Studies (2009) Bowdoin College (2000)

Employment History 2009-Present 2011-2012 2009-2012 2008 2006-2007 2000-2006

Environmental Scientist, Woods Hole Group, Inc. Associate, Except Integrated Sustainability Sustainability Consultant, Anthrocology Research Fellow, Yale Urban Design Workshop Environmental Scientist, Exponent, Inc. Associate Scientist, Menzie-Cura & Associates, Inc.

Certificates of Training OSHA 40-Hour HAZWOPER Key Projects Sesuit Harbor Use and Capacity Study. Town of Dennis. 2013present. Project Manager Presently underway, this project will provide the Town with a master plan for the harbor, including analyses of current use and capacity, land and water assets, harbor regulations and by-laws, fee structure, and marina operations and maintenance. The project will culminate in recommendations for land and water improvement design alternatives, and changes to administrative and capital processes to support the safe and efficient operation of the harbor.

Woods Hole Group JOSEPH FAMELY

Key Projects (continued) Ecological Risk Assessment of a Rubber and Vinyl Tape Manufacturing Plant. GeoInsight, Inc. 2012-2013. Project Manager/Environmental Scientist Conducted a Stage I and Stage II ecological risk characterization for a former rubber and vinyl tape facility in Massachusetts. Planned and led field investigations, managed data analysis, and authored risk characterization report. The analysis included modeling metals and polycyclic aromatic hydrocarbons in fish and plant tissue from sediment concentrations. Town of Eastham Conservation Land Inventory and Analysis. Town of Eastham. 2012. Project Manager Conducted an inventory of conservation land in Eastham, including private, municipal, and nonprofit land trust-owned parcels. Reviewed Registry of Deeds documents and relevant Massachusetts conservation law to supplement parcel data with information on the date, method and purpose of protection, the custodian of the protected land, the level of protection, and the existence of wetlands, unrestricted areas, or building envelopes. The work product included a database of conservation land which is hyperlinked to all Registry of Deeds and Town of Eastham documents relevant to the conservation restrictions and readily appended to the Town’s GIS system. The analysis included recommendations for increasing the level of protection on conservation lands. Yale Community Carbon Fund Calculator. Yale Office of Sustainability. 2010-2011. Technical Lead – Transportation and Solid Waste Developed a greenhouse gas emissions model to calculate emissions related to travel, commuting, and events associated with the Yale University community. The calculator is a web-based application which includes integrated explanatory text and a standalone report on methodology. The tool enables members of the community to determine the appropriate quantity of emissions to offset with an online donation to the Yale Community Carbon Fund, which supports carbon mitigation projects for organizations and low-income households in New Haven. Long Island Sound Dredged Materials Management Planning. U.S. Army Corps of Engineers. 2009-2012. Environmental Scientist Conducted a review of literature on dredge materials management and environmental data for Long Island Sound. Reviewed potential sites throughout the Sound for alternative placement of dredge materials – including beach nourishment via direct placement, upland beneficial use, shoreline confined disposal, and nearshore placement for beach nourishment and shoreline protection. Reviews of alternatives included site visits and desktop review (in an ArcGIS environment) based on spatial analysis of environmental/physical/cultural/infrastructure impacts of project development. Prepared a synthesizing report in support of the Dredged Materials Management Plan for Long Island Sound. Delaware Estuary Regional Sediment Budget. U.S. Army Corps of Engineers. 2010-2011. Technical Lead – Geospatial Analysis Performed an estuary-wide analysis of historical shoreline change to derive a sediment source term for the fine sediment budget. Using synoptic historical shoreline data and sediment properties data for the wetland coast, calculated the surface area of the estuarine shore lost and gained between the 1880s and 2008, as well as the mass of mineral or organic sediment produced through time. The time-averaged rate of sediment production by shore erosion was then used for the sediment budget analysis. Revised: 3/2014

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Woods Hole Group JOSEPH FAMELY

Key Projects (continued) Shoreline Change Analyses for Private Properties on Long Island. Inter-Science Research Associates. 2010-2012. Technical Lead – Geospatial Analysis Conducted numerous quantitative spatial analyses of shoreline and dune movement over time in support of Coastal Erosion Hazard Area evaluations in New York. Analyzed multiple historical aerial photographs to digitize the shoreline and calculate long-term rates of change along transects through the beach and dune. Summarized results and recommended changes in the delineation of resource areas based on review of the data with respect to the New York State Coastal Erosion Management Regulations. New Bedford Harbor Superfund Site. U.S. Army Corps of Engineers. 2010-present. Environmental Scientist Data analysis and technical reporting in support of Remedial Investigation and Feasibility Study for New Bedford Harbor Operable Unit #3. Analyzed sediment and tissue chemistry data along with toxicity tests and benthic community data to support management decisions in areas outside the harbor. Greenhouse Gas Impacts Modeling for a Real Estate Development Environmental Review. Private Client. 2009. Project Manager/Technical Lead Developed a greenhouse gas model to evaluate the impacts of multiple development alternatives for a proposed socially- and environmentally-conscious resort and residential community development’s Environmental Impact Statement under the New York State Environmental Quality Review process. Prepared summary tables and text for the EIS submittal as well as a full report documenting the methodology and results. Dwight Neighborhood Sustainability Plan. Greater Dwight Development Corporation. 2008. Project Manager/Technical Lead Developed a neighborhood sustainability framework for a New Haven community. Established goals, proposed sustainability indicators and targets, and suggested strategies for adopting sustainable community practices. Provided community development corporation with a quantitative and spatial sustainability evaluation. Materials Flow Analysis on the Island of O’ahu. Hawaii Community Foundation. 2008. Environmental Scientist Researched and prepared report on material flows in the sectors of imports, exports, and natural resource extraction on the island of O’ahu in Hawaii. Research combined aggregation of available public data with phone and field interviews. The report summarized findings and proposed strategies for the optimization of material flows on an isolated island. Moss Landing Harbor Dredged Material Disposal Risk Assessment. U.S. Army Corps of Engineers. 2001-2002. Environmental Scientist Developed a conceptual site model for Monterey Bay in support of an ecological risk characterization of disposal of dredged materials. Developed a sampling and analysis plan in coordination with the conceptual site model.

Revised: 3/2014

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Woods Hole Group JOSEPH FAMELY

Publications and Awards Yale School of Architecture Retrospecta. 2008-2009. Master Plan for Nusajaya / Zone B, Iskandar, Malaysia. Group project for ARCH 636a: Sustainable Design. 2008 Award for Outstanding Work in Restorative Environmental Design – Adapting Vernacular Architecture for Sustainable and Restorative Environmental Design Elements. Independent consulting project for Urban Villages’ sustainable community development in Hudson, Alabama. 2008 Yale President’s Public Service Fellowship. Placement at Yale Urban Design Workshop through Yale Office of New Haven & State Affairs. Continuing Education Climate Adaptation Training, NOAA Coastal Services Center. LEED for Existing Buildings – Operations & Management Technical Review, U.S. Green Building Council – Connecticut Chapter. GIS for Environmental Professionals, Society of Environmental Toxicology and Chemistry – North Atlantic Chapter. Applied Statistics for Environmental Professionals, Society of Environmental Toxicology and Chemistry – North Atlantic Chapter.

Revised: 3/2014

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Woods Hole Group PROFESSIONAL PROFILE

Qualifications Summary 

Ecological risk assessment and analysis in freshwater systems, in marine and estuarine habitats, and in terrestrial environments



Expert testimony for law firms, industry, and government organizations



Designed and conducted studies to assess the effects of industrial and civil activities upon marine and aquatic ecosystems



Risk assessment and remediation at sediment and surface water contaminated sites



Environmental business development expertise for governments and companies



Founding partner of Cura Environmental and MenzieCura & Associates, Inc.



Published over 30 peerreviewed book chapters, technical papers, journal articles, and conference proceedings in the areas of risk assessment, environmental decision making, marine ecology, and dredged material disposal evaluation methods



Taught various college and university course in the areas or environmental science, biology, and oceanography

JEROME J. CURA, PH.D., M.S., B.A., Senior Environmental Scientist Fields of Expertise Dr. Cura is an ecological risk assessor at Woods Hole Group. He is also an adjunct professor at Cape Cod Community College where he teaches a course in Oceanography. He is an expert in the area of ecological risk analysis. He has conducted ecological risk analyses in various freshwater systems, in marine and estuarine habitats, and in terrestrial environments. He has developed guidance for conducting risk assessments at dredging sites for the United States Army Corps of Engineers and he chaired the International Navigation Association’s (PIANC) workgroup that developed international guidance. Dr. Cura’s experience includes conducting assessments at CERCLA and RCRA sites (industrial and government facilities), providing technical advice on the design and execution of human health and ecological risk assessments, and providing expert testimony for law firms. Industry and Government organizations frequently invite him to lead or participate in environmental conferences or symposia. Dr. Cura works as a member of The Science Collaborative, a resource network of senior environmental scientists from the consulting industry and academia. He was a founding partner of Cura Environmental and Menzie-Cura & Associates, Inc. Dr. Cura has published over 30 peer-reviewed book chapters, technical papers, journal articles, and conference proceedings in the areas of risk assessment, environmental decision making, marine ecology, and dredged material disposal evaluation methods. He is a frequent contributor to Scientific Symposia. Dr. Cura is currently an adjunct faculty member at Cape Cod Community College where he teaches a course in Fundamentals of Oceanography. Higher Education Ph.D. Biological Oceanography, University of Maine (1981) M.S. Biology, Northeastern University (1974) B.A. Biology, College of the Holy Cross (1971) Honor Societies Sigma Xi, The Scientific Research Society, Invited to Membership, 1972 Phi Sigma, Biological Sciences Honor Society, Invited to Membership, 1972

Woods Hole Group JEROME J. CURA, PH.D., LSP

Continuing Education and Certification:    

Applied Statistics for Environmental Professionals, North Atlantic Chapter of the Society of Environmental Toxicology and Chemistry, 2002 Using Bayesian Monte Carlo Analysis in Ecological Risk Assessments, North Atlantic Chapter of the Society of Environmental Toxicology and Chemistry, 2000 Licensed Site Professional, State of Massachusetts, 1994 - 2012 (License Number 6151) Certificate, Modeling of Fate and Effects of Toxic Substances in Surface and Ground Waters, Manhattan College, New York, NY, 1986

Offices Held    

Licensed Site Professional Association, Past Member Board of Directors Licensed Site Professional Association, Past Program Committee Chair North Atlantic Chapter SETAC, Past Member, Board of Directors Town of Winchester, Massachusetts, Past Chair, Conservation Commission

Professional Affiliations:        

Licensed Site Professional Association North Atlantic Chapter SETAC New England Estuarine Research Association Estuarine Research Federation Society for Risk Analysis-New England American Society of Limnology and Oceanography U.S. Section of International Navigation Association (PIANC) Water Environment Federation

Business Experience: 2011-Present 2006-Present 1990-2006 1989-1990 1986-1988 1979-1986 1973-1975

Senior Environmental Scientist, Woods Hole Group Founder, The Science Collaborative Founding Partner and Principal, Menzie-Cura & Associates, Inc. Founder, Cura Environmental Senior Project Manager, Goldberg-Zoino & Associates, Inc. Project Manager and Senior Scientist, EG&G Environmental Consultants Full-Time Faculty, Massachusetts Bay Community College

National and International Committees, Workshops, and Distinctions: Business, national government, and non-governmental organizations have invited Dr. Cura to lead or participate in environmental workshops or conferences. He is a reviewer for several journals and serves as an officer in various professional societies.

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Woods Hole Group JEROME J. CURA, PH.D., LSP

National and International Committees, Workshops, and Distinctions (continued) 1. Member, National Academies of Science, National Research Council Committee on the Design and Evaluation of Safer Chemical Substitutions: A Framework to Inform Government and Industry, Washington DC (currently serving) 2. Member, National Academies of Science, National Research Council Committee on the Mycoherbicides for Eradicating Illicit Drug Crops,Washington, DC, (http://www8.nationalacademies.org/cp/CommitteeView.aspx?key=49204) 3. Past Chair, Ecological Risk Assessment Specialty Group, Society for Risk Analysis, SRA, McLean, Virginia, http://www.sra.org/index.php 4. Technical Facilitator, Workshop on Population Level Ecological Risk Assessment, United States Environmental Protection Agency, Risk Assessment Forum, Washington, D.C., June, 2008 5. Principal U.S. Representative (appointed by the United States Army Corps of Engineers) and Chair to the International Navigation Association (PIANC) Environmental Commission Working Group 10, “Environmental Risk Assessment in Dredging and Dredged Material Management” http://www.pianc-aipcn.org/publications/reportsarticle.php?id=4000101 6. Invited Delegate, International Navigation Association, Environmental Risk Assessment of Dredging and Disposal Operations, Report of Working Group 10 of the Environmental Commission, International Navigation Association, 31st World Congress, Estoril, Portugal, May 14 to 18, 2006. http://www.pianc-aipcn.org/congresses/31-conclusions.php 7. Guest Speaker, Applying Ecological Risk Assessment to Sediment Remediation, Manufactured Gas Plant Consortium (consortium of environmental managers from power industry nation-wide), Charleston, SC, April, 2006. 8. Invited Speaker, Role of Risk Assessment in Remedial Decision Making, Program on Manufactured Gas Plant Site Management (Bar Harbor, Maine) for Electric Power Research Institute, Palo Alto, CA, June, 2006 9. Invited Speaker, Reducing Uncertainty in Ecological Risk Assessment, Tri-Services (United States Army, Navy, and Air Force) Toxicology and Risk Assessment Conference, Dayton, OH, April 2005. 10. Invited Speaker, World Dredging Congress, Sponsored by World Organization of Dredging Association and the Shipbuilding, Machinery, and Marine Technology Trade Fair, Hamburg, Germany, September 28 to October 4, 2004. http://www.woda.org/WODCONXVII/index.html 11. Breakout Session Co-Chair Society for Risk Analysis Workshop, Comparative Risk Assessment and Multi-Criteria Decision Analysis: A Framework for Managing Contaminated Sediments, West Palm Beach, Florida June 22 to 24, 2004 http://www.sra.org/newsletter/news0804.pdf

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Woods Hole Group JEROME J. CURA, PH.D., LSP

National and International Committees, Workshops, and Distinctions (continued) 12. Workshop Organizer, United States Army Corps of Engineers and United States Environmental Protection Agency, Workshop on Applying Comparative Risk Assessment to the Management of Dredged Materials, Chicago, March, 2004 13. Invited Participant, A Review of Ecological Risk Assessment in the United States Army Corps of Engineers Dredging Program and the Potential for Comparative Risk Assessment. Presented at: Advancing the State of the Art of Analyzing Risks and Benefits of Dredged Material Management. Tilghman Island, Maryland. October 31 – November 2, 2001. http://www.rff.org/documents/RFF-DP-02-16.pdf 14. Concurrent Session Leader, United States Army Corps of Engineers, National Workshop on Environmental Risk Assessment and Dredged Material Management: Issues and Application. February 18-20, 1998 at the San Diego Mission Valley Hilton, San Diego, CA. 15. Invited Participant, Using Sentinel Species Data to Address the Potential Human Health Effects of Chemicals in the Environment, Workshop, held 23-24 September 1997 in Frederick, Maryland, Cosponsored by the U.S. Army Center for Environmental Health Research, the EPA National Center for Environmental Assessment, and the Agency for Toxic Substances and Disease Registry (ATSDR). http://www.ehponline.org/members/1999/107p309-315vanderschalie/vanderschalie-full.html 16. Breakout Session Leader, United States Environmental Protection Agency/United States Army Corps of Engineers, Interpreting the Consequences of Bioaccumulation Related to Dredged Material Assessment and Management Activities Workshop. August 29-31, 1995. Denver, CO. 17. Invited Participant, USEPA/USCOE Technical Support to Task Force on Managing Dioxin Contaminated Sediment Remediation Material Workgroup, USEPA Region 2/USACE New York Division 18. Invited Participant, National Oceanic and Atmospheric Administration, North Atlantic Estuarine Eutrophication Assessment Workshop. October 2-3, 1996. Boothbay Harbor, Maine. http://ian.umces.edu/neea/pdfs/north_atlantic_regional_report.pdf 19. Invited Panel Member, Production on George’s Bank, Panel Discussion on George’s Bank New England Estuarine Research Society, 1983 Spring Meeting, Portland, Maine 20. Visiting Lecture Series, The Relationship Between Hydrography and Phytoplankton Species Distribution on George’s Bank, Bigelow Laboratory for Ocean Sciences Visiting Lecture Series, February, 1983. Peer Reviewed Publications Vorhees, D., J. Cura, C. Butler, A. DeLernia, and D. Burmistrov, Recreational Angler Fish Consumption Survey and Its Implications for Estimating Contaminant Exposure in New York Bight (In Preparation).

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Peer Reviewed Publications (continued) Von Stackelberg, K., D. Vorhees, D. Moore, J. Cura, and T. Bridges, 2008. Evaluation of Sources of Uncertainty in Risk Assessments Conducted for the US Army Using a Case Study Approach. Integrated Environmental Assessment and Management 4(1):41-60. 2008 http://www.setacjournals.org/perlserv/?request=getabstract&doi=10.1897%2FIEAM_2007-004 Netzband, A. and J. Cura, 2007. Guide to Making Easer Decisions. Ports and Harbors, Journal of the International Association of Ports and Harbors. May: 16-18. Ryan P.B., Burke TA, Cohen Hubal EA, Cura JJ, McKone TE, 2007. Using Biomarkers to Inform Cumulative Risk Assessment, Environ Health Perspect, January 2007 http://www.ehponline.org/members/2007/9334/9334.pdf Cura, J.J, Burt, S. Challinor, T. Estes, D. Kevelam, W. Manz, A. Netzband, J. F. Sanchez, T. Suzuki, 2006. Environmental Risk Assessment of Dredging and Disposal Operations, Environmental Commission Report of Working Group 10, International Navigation Association (PIANC), Brussels, Belgium. http://www.piancaipcn.org/publications/reports-article.php?id=4000101 Bridges, T., G. Kiker, J. Cura, D. Apul, I. Linkov, 2005, Towards Using Comparative Risk Assessment To Manage Contaminated Sediments, In: Strategic Management Of Marine Ecosystems (Levner, E., Linkov, I., Proth, J.M., Eds ;(50):261-269, Springer Netherlands, NATO Science Series IV, Earth and Environmental Sciences http://www.springerlink.com/content/kh44103220808378 Cura, J.J., T.S. Bridges, and M.E. McArdle. 2004. Comparative risk assessment methods and their applicability to dredged material management decision-making. Human and Ecological Risk Assessment. 10:485-503. http://www.informaworld.com/smpp/content~content=a713609757~db=all~order=page Vorhees, D.J., S.B. Kane Driscoll, K. von Stackelberg, J.J. Cura, and T.S. Bridges. 2002. An evaluation of sources of uncertainty in a dredged material assessment. Human and Ecological Risk Assessment. 8(2):369-389. http://www.informaworld.com/smpp/content~content=a727073245~db=all~order=page Kane Driscoll, S.B., W.T. Wickwire, J.J. Cura, D.J. Vorhees, C.L. Butler, D.W. Moore, and T.S. Bridges. 2002. A comparative screening-level ecological and human health risk assessment for dredged material management alternatives in New York/New Jersey Harbor. Human and Ecological Risk Assessment. 8(3):603-626. http://www.informaworld.com/smpp/content~content=a713605476~db=all~order=page Linkov, I., D. Burmistrov, J.J. Cura, and T.S. Bridges. 2002. Risk-based management of contaminated sediments: consideration of spatial and temporal patterns in exposure modeling. Environmental Science & Technology. 36(2):238-246.

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Peer Reviewed Publications (continued) http://pubs.acs.org/cgi-bin/abstract.cgi/esthag/2002/36/i02/abs/es010721d.html von Stackelberg, K., D. Burmistrov, I. Linkov, J.J. Cura, T.S. Bridges. 2002. The use of spatial modeling in an aquatic food web to estimate exposure and risk. The Science of the Total Environment. 288(1-2):97-110. http://www.ncbi.nlm.nih.gov/sites/entrez?db=pubmed&term=12013551 C.A. Menzie, S.S. Hoeppner, J.J. Cura, J.S. Freshman, and E.N. LaFrey. 2002. Urban and suburban storm water runoff as a source of polycyclic aromatic hydrocarbons (PAHs) to Massachusetts estuarine and coastal environments. Estuaries. Vol. 25, No. 2, p. 165-176. http://estuaries.olemiss.edu/cgibin/est/printabstract_public.cgi?ESTU2002_25_2_165_176 Menzie, C.A., J.J. Cura, S.B. Kane Driscoll, R. Lacey, and M. McArdle. 2002. Assessing ecological risks of PAH-contaminated sediments. Published in: Proceedings of the International Conference on Remediation of Contaminated Sediments. Venice, Italy, October 10-12, 2001. Battelle Press, Columbus, OH. http://64.233.169.104/search?q=cache:H12FF1jrWS0J:www.battelle.org/Bookstore/Book Template.aspx%3FISBN%3D1-57477-1280+%22j+cura%22&hl=en&ct=clnk&cd=56&gl=us Cura, J.J., S.B. Kane Driscoll, R. Lacey, M. McArdle, C.A. Menzie. 2001. Assessing Ecological Risks of PAH-Contaminated Sediments. In: Sediments Guidance Compendium. Electric Power Research Institute (EPRI), Palo Alto, CA. 1005216. Peddicord, R., J. Brannon, T. Bridges, J. Cura, R. Engler, C. Lee, M. Palermo, C. Price, R. Price, R. Schroeder, J. Simmers, H. Tatem, and J. Wilson. 2000. "Evaluation of Dredged Material Proposed for Placement in Upland Sites," Proceedings, Western Dredging Association 20th Technical Conference and 32nd Annual Texas A&M Dredging Seminar, June 25-28, 2000, Warwick, Rhode Island. Cura, J, 1999. Coupling Risk Reduction with Sustainable Management and Reuse. In: Transportation Research Board Conference Proceeding, Developing Decision Making Criteria. No. 19:66, National Academy of Sciences/National Research Council, Washington, DC. http://md1.csa.com/partners/viewrecord.php?requester=gs&collection=ENV&recid=5136 285&q=%22J.+Cura%22&uid=791440731&setcookie=yes Moore, D. W., Bridges, T. S., Ruiz, C., Cura, J., Kane Driscoll, S., Vorhees, D., and Peddicord, R. C. (1999). “Environmental risk assessment and dredged material management: Issues and application. Proceedings of a workshop 18-20 February 1998 at the San Diego Mission Valley Hilton, San Diego, California,” Technical Report DOER-2, U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS. http://el.erdc.usace.army.mil/elpubs/pdf/trdoer2.pdf

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Peer Reviewed Publications (continued) Cura, J.J. 1998. Ecological Risk Assessment under the Massachusetts Contingency Plan. In: Risk, Resource, and Regulatory Issues – Remediation of Chlorinated and Recalcitrant Compounds, eds. G.B. Wickramanayake and R.E. Hinchee. The First International Conference on Remediation of Chlorinated and Recalcitrant Compounds, Monterey, CA, May 18-21, 1998. http://64.233.169.104/search?q=cache:hbAU9axUb10J:www.battelle.org/BookStore/Boo kTemplate.aspx%3FISBN%3D1-57477-056X+%22j.+j.+cura%22&hl=en&ct=clnk&cd=10&gl=us Cura, J.J., W. Heiger-Bernays, T.S. Bridges, and D.W. Moore. 1998. Ecological and Human Health Risk Assessment Guidance for Aquatic Environments. Technical Report DOER4. Prepared for U.S. Army Corps of Engineers, Engineer, Research, and Development Center, Vicksburg, MS. http://el.erdc.usace.army.mil/elpubs/pdf/trdoer4.pdf Moore, D, W., T. S. Bridges, J. Cura. 1998. Dredging/Dredged Material Management Risk Assessment, Technical Report DOER-R1. Prepared for U.S. Army Corps of Engineers, Engineer, Research, and Development Center, Vicksburg, MS. http://el.erdc.usace.army.mil/elpubs/pdf/doerr1.pdf Cura, J.J. 1998. Ecological risk assessment. Water Environment Research, Literature Review. 70(4):968-971. Cura, J.J. 1997. Ecological and health risk assessment. Water Environment Research, Literature Review. 69(4):1-5. Menzie, C.A., M. Hope Henning, J.J. Cura, K. Finkelstein, J. Gentile, J. Maughan, D. Mitchell, S. Petron, B. Potocki, S. Svirsky, and P. Tyler. 1996. Special report of the Massachusetts weight-of-evidence workgroup: A weight-of-evidence approach for evaluating ecological risks. Human and Ecological Risk Assessment: 2(2)277-304. Bridges, T. S., Moore, D. W., Landrum, P., Neff, J., and Cura, J. (1996). “Summary of a workshop on interpreting bioaccumulation data collected during regulatory evaluations of dredged material, n Miscellaneous Paper D-96-1, U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS. http://el.erdc.usace.army.mil/dots/pdfs/mpd96-1.pdf von Stackelberg, K., C.A. Menzie, and J.J. Cura. 1995. Risk Assessment: Helping to Focus Risk Management Objectives for MGP Sites. Land Contamination & Reclamation. (Special Issue). 3(4):24-29. Presented at the International Symposium and Trade Fair on the Clean up of Manufactured Gas Plants, September 19-21, Prague, Czech Republic. http://md1.csa.com/partners/viewrecord.php?requester=gs&collection=ENV&recid=3985 844&q=%22J.+Cura%22&uid=791440731&setcookie=yes Menzie, C.A., J.J. Cura, J. Freshman, and S. Svirsky. 1993. Evaluating ecological risks and developing remedial objectives at forested wetland systems in New England. In: Application of Ecological Risk Assessment to Hazardous Waste Site Remediation. Water

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Peer Reviewed Publications (continued) Environment Federation, Alexandria, VA, pp. 89-100. Rex AC, Keay KE, Smith W, Cura JJ, Menzie CA, Steinhauer M and Connor MS, 1992. The State of Boston Harbor 1991. Boston: Massachusetts Water Resources Authority. Report 1992-03. 106 pp. Cura J.J., 1991. Review of Phytoplankton Data: Massachusetts Bay. Boston: Massachusetts Water Resources Authority. Report 1991-01. 105 p. http://www.mwra.state.ma.us/harbor/enquad/pdf/1991-01.pdf Menzie CA, Cura JJ, Freshman JS and Potocki B, 1991. Boston Harbor: Estimates of Loadings. Boston: Massachusetts Water Resources Authority. Report 1991-04. 108 p. http://www.mwra.state.ma.us/harbor/enquad/pdf/1991-04.pdf Menzie, C.A. and J.J. Cura. 1991. Environmental Evaluations at Hazardous Waste Sites. In Proceedings of the HMC-Northeast '91 Conference, Boston, MA, July 10-12, by the Hazardous Materials Control Research Institute. Greenbelt, MD, pp. 77-84. Menzie, C.A., J.J. Cura, R. Gillmor, B. Magnell, G. Mariani, T. Bartholomew, W. Gardner, and W. Smith. 1989. The Optimum Mix of Pollution-Monitoring Platforms: Deepwater Dumpsite-106 Case Study. In M. Champ and P. K. Park, eds., Oceanic Processes in Marine Pollution. Vol. 3 - Marine Waste Management: Science and Policy. Kreiger Publishing Co., Malabar, FL, pp. 259-276. http://md1.csa.com/partners/viewrecord.php?requester=gs&collection=ENV&recid=5817 860&q=%22J.+Cura%22&uid=791440731&setcookie=yes Cura, J.J., R. Gillmor, G. Mariani, C. Menzie, E. Burke, W. Curtis, C. Ketchum, and B. Tucholke. 1989. Site-Selection Criteria for the Disposal of Low-Level Radioactive Wastes off the East Coast of North America. In M. Champ and P. K. Park, eds., Oceanic Processes in Marine Pollution, Volume 3 - Marine Waste Management: Science and Policy. Kreiger Publishing Co., Malabar, FL, pp. 177-185. http://md1.csa.com/partners/viewrecord.php?requester=gs&collection=ENV&recid=5817 852&q=%22J.+Cura%22&uid=791440731&setcookie=yes Cura, J.J. 1987. The Phytoplankton. In R. H. Backus, ed. George’s Bank and Its Surroundings. MIT Press, Cambridge, MA, pp. 213-218. http://mitpress.mit.edu/catalog/item/default.asp?ttype=2&tid=4289 Menzie, C.A., F. Babin, E. Burke, J.J. Cura, R. Gillmor, G. Mariani, and S. Wilson. 1983. An Assessment of Research Needs Related to Future Ocean Disposal of Wastes. In M. Champ, ed. Ocean Waste Management: Policy and Strategies, International Ocean Disposal Series Special Symposium. http://www.osti.gov/energycitations/product.biblio.jsp?osti_id=5244439

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Representative Contributed Presentations Menzie, C.A., J.J. Cura, and W.F. Skinner. 1982. Thermal Impact Evaluation for Brunner Island Steam Electric Station: Toward a More Realistic Assessment. Environ. Monitoring and Assessment 2: 301-308. http://www.springerlink.com/content/r254237434l36156/?p=8122ea7514c7403ab67aa9b 265420bbf&pi=3 Cura, J., Occhalini, J., Vorhees, D. Differential Body Burdens of Various Metals and Organic Compounds in Co-Occurring Marine Bivalves: Implications for Representative Species Selection in Risk Assessment: North Atlantic Chapter Society for Environmental Toxicology and Chemistry, Annual Meeting, June, 2009. Keating-Connolly, J. and J. Cura, 2008. Characterizing the Nature and Extent of Oil Releases to Freshwater Sediment and Assessing Ecological Risk, The 24th Annual Conference on Soils, Sediments, and Water, University of Massachusetts, Amherst, Northeast Regional Environmental and Public Health Center and School of Public Health. Bridges TS, von Stackelberg K, Vorhees D, Butler C, Cura J, Greges M, Reiss M, 2006. Managing uncertainty to make risk-informed decisions about contaminated sediments, Society for Risk Analysis, Annual Meeting Bridges, T., J.J. Cura, S.B. Kane Driscoll, M. McArdle, and M. Nelson. 2002. A Review of Comparative Risk Assessment Methods and their Applicability to Dredged Material Management Decisions. 23rd Annual Meeting of SETAC North America, Salt Lake City, Utah. K. von Stackelberg, J. J. Cura, 2002, Upland Testing Manual Risk Guidance. United States Army Corps of Engineers/Environmental Protection Agency Bioaccumulation Workshop. New Orleans, LA, February 20-22. Wilson, J., Cura, J.J., Brannon, J., Bridges, T., Engler, R.M., Lee, C.R., Palermo, M., Price,C, Price,R, 2000. Evaluation of dredged material proposed for placement in upland sites. Presented at the Society of Environmental Toxicology and Chemistry 21st Annual Meeting. November 12-16, Nashville, TN W. T. Wickwire, C. A. Menzie, J. J. Cura, and J. Freshman, 1999, Embayment Sensitivity to Eutrophication: Integrating Risk Factors on a Watershed Scale, Society for Risk Analysis, 1999 Annual Meeting, Metzger, B.H., P.M. Rury, D. Turton, B. Archibald, J. Clark, and J.J. Cura. 1996. Toward Effective Ecological Risk-Management of Refinery Corrective Action. Presented at the Society of Environmental Toxicology and Chemistry 17th Annual Meeting. November 17-21, 1996. Washington, DC. Cura, J.J., R.M. Rury, R.P. Christensen, and B.B. Archibald. 1996. Integration of Habitat Quality Ranking into Screening Level Ecological Risk Assessment. Presented at the

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Representative Contributed Presentations (continued) Society of Environmental Toxicology and Chemistry 17th Annual Meeting. November 17-21, 1996. Washington, DC. Cura, J.J. and M. Studer. 1996. Measurement of PAH Loadings to Massachusetts Bay from Various Waterborne Sources. Presented at the Water Environment Federation 69th Annual Conference & Exposition. October 5-9, Dallas, Texas. Cura, J.J. and C. Menzie. 1996. Methodologies for Ecological Risk Assessment: The Overall Process and Recent Advances. Water Environment Federation 69th Annual Conference & Exposition. Conference Workshop #12 - Ecological Risk Assessment: Why and How An Important Tool in Environmental Decision Making. October 5-9, Dallas, Texas. Cura, J.J. 1991. Ecological Risk Assessments at Hazardous Waste Sites. The Boston Bar Association's Hazardous Waste Subcommittee, May Meeting, Boston, MA. Cura J.J., C.N. Flagg, and G. Mariani. 1983. Physical Factors Controlling Plankton Production on George’s Bank. American Geophysical Union Spring Meeting, Philadelphia, PA. Cura, J.J. and B.A. Magnell. 1981. The Distribution of Primary Production and Phytoplankton on George’s Bank. Third Annual Symposium on the Oceanography of the Gulf of Maine and Adjacent Seas, University of New Hampshire, Durham, NH. Cura, J.J. 1974. The Cellulolytic Capability of Several Salt Marsh Fungi. Presented at the Phi Sigma Symposium, Northeastern University Marine Science Institute, Nahant, MA. Representative Technical Reports Cura, J.J., 2009. Zooplankton Monitoring Report for Small Pond in Support of a Voluntary RCRA Clean-Up at the Combustion Engineering Facility, Windsor CT. Prepared for ABB Environmental. Cura J.J., 2008. Baseline Ecological Risk Assessment for Aquatic and Semi-Aquatic Receptors at 11 and 70 Cascade Boulevard and 37 Robinson Boulevard, and Down Steam Areas Milford and Orange, Connecticut, Prepared for GZA Geoenvironmental, Inc. Cura J.J. and D.J. Vorhees, Environmental and Human Health Risk Characterization, 126 Mechanic Street, East Brookfield, Massachusetts Release Tracking Number 2-15641. Prepared for EarthTech Inc. Von Stackelberg, K., W.T. Wickwire, J.J. Cura, D.J. Vorhees, and S.J.S. Baird. 2001. Comparative Ecological and Human Health Risk Assessment, Big Sunflower River Maintenance Project. Prepared for U.S. Army Corps of Engineers, Waterways Experiment Station, Vicksburg, MS. Butler, C.L. and J.J. Cura. 2001. Evaluation of Ecological Health of the Lower Penobscot River. Prepared for Camp, Dresser & McKee, Inc. Cambridge, Massachusetts.

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Representative Technical Reports (continued) Cura, J.J., W.T. Wickwire, M. McArdle, T.S. Bridges, and D.W. Moore. Ecological and Human Health Risk Assessment Guidance for Terrestrial Environments. Prepared for U.S. Army Corps of Engineers, Waterways Experiment Station, Vicksburg, MS. Kane Driscoll, S.B., W.T. Wickwire, J.J. Cura, D.J. Vorhees, C.L. Butler, L.W. Williams, D.W. Moore, and T.S Bridges. 1999. A Screening-Level Environmental and Human Health Risk Assessment for Select Dredged Material Management Alternatives under the New York/New Jersey Dredged Material Management Plan. Prepared for U.S. Army Corps of Engineers, New York District. Cura, J.J. and J. Freshman. 1996. Identification of Massachusetts Bays Embayments at Risk of Eutrophication. Prepared for Massachusetts Bays Program, Office of Coastal Zone Management. Cura, J.J., C. Menzie, and J. Borchardt. 1985. An Overview of Industrial Waste Disposal in the Ocean. Prepared for the United States Congress, Office of Technology Assessment. Cura, J.J., J. Borchardt, and C. Menzie. 1984. Projected Ocean Dumping Rates in the Year 2000. Prepared for the National Oceanic and Atmospheric Administration (NOAA), National Marine Pollution Program Office. http://www.osti.gov/energycitations/product.biblio.jsp?osti_id=5977881 Cura, J.J. (with EG&G Staff). 1982. An Evaluation of the Effects of Thermal Discharge from the Brunner Island Stream Electric Station on Representative Important Fish Species 316a Demonstration. Prepared for Pennsylvania Power and Light Company. Flagg, C.N., B. Magnell, D. Frye, J.J. Cura, S. McDowell, and R. Scarlet. 1982. Interpretation of the Physical Oceanography of George’s Bank. Prepared for the United States Bureau of Land Management. National Technical Information Service (NTIS) Publication Number EG&G 82-B4569. http://md1.csa.com/partners/viewrecord.php?requester=gs&collection=TRD&recid=N83 27568AH&q=%22Cura%2C+j%22&uid=791440731&setcookie=yes Cura, J.J. (with EG&G Staff). 1982. Assessment for Future Environmental Problems - Ocean Dumping. Prepared for the United States Environmental Protection Agency, Office of Strategic Assessment and Special Studies. http://oaspub.epa.gov/eims/eimsapi.dispdetail?deid=45841 Cura, J.J. 1981. The Thermal and Physical Suitability of the Pigeon River Downstream of Canton, North Carolina as Smallmouth Bass Habitat. Prepared for Champion Paper Co. Cura, J.J. (with EG&G staff). 1981. Development of Site-selection Criteria for Disposal of Low-level Radiation Wastes off the East Coast of North America. Prepared for United States Environmental Protection Agency, Office of Radiation Programs.

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ENVIRONMENTAL Q & A FORMER PLYMOUTH RUBBER COMPANY CANTON, MASSACHUSETTS What is the nature of contamination on the Plymouth Rubber (PR) site? What caused the contamination on the PR site? Historical metal working and rubber manufacturing operations, particularly including materials and stored products used to support the operations, are believed to have contributed to identified releases on-site. In brief summary, the releases included: •

plasticizer oils including petroleum hydrocarbons and phthalate esters at the Former Tank Farm (release from leaking storage tanks);



metals (primarily, zinc and lead), petroleum hydrocarbons, and polycyclic aromatic hydrocarbons (PAHs) at the Former Railroad Spur area (releases likely from incidental deposition of these materials during transfer between buildings along the rail spur);



metals (primarily, barium, chromium, lead, and zinc) at the Vacant Land (release from deposition of historical fill soil containing debris);



petroleum-based solvents (toluene, hexane, and heptane) at the Former Solvent Tank area (release from leaking storage tanks);



petroleum hydrocarbons (hydraulic and/or lubricating oil) at the Calender Building 29 area (release from leaky machinery and/or incidental release to the subsurface through building floor from equipment operation); and



petroleum hydrocarbons, phthalate esters, and metals in sediment of Factory Pond and in the “Upland Sources” to Factory Pond (releases identified from specific historical mill operations).

How is the location of the contamination determined? The six areas of concern currently managed as active “disposal sites” on-file with the Massachusetts Department of Environmental Protection (MADEP) were identified and reported as release areas prior to GeoInsight’s involvement. Plymouth Rubber retained Environmental Resource Associates, Inc. (ERA; see report bibliography) who conducted various stages of investigation and remediation in five of the six release areas prior to 2006 (Former Tank Farm, Rail Spur, Vacant Land, Factory Pond Sediment, and Former Solvent Tank areas). The Building No. 29 Calender release area was reported to the MADEP in May 2007 (after Canton Holdings became the property owner) by Sanborn Head & Associates, Inc (SHA) after they encountered petroleum non-aqueous phase liquid inside a monitoring well installed inside the building.

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The Phase II Comprehensive Site Assessment (CSA) conducted by GeoInsight sought to consolidate historical investigation data collected by past consultants on-site and then collect additional data to fill data-gaps and further define the nature and extent of impacts in the six known release area. The GeoInsight Phase II included these activities to supplement the existing database of hundreds of soil, groundwater, surface water, and sediment sampling data points: •

advancing over 60 soil borings and 30 test pits (and associated soil sample analytical testing);



installing of 20 additional groundwater monitoring wells (and associated sampling and analysis of over 50 monitoring wells on-site); and



collecting and analyzing of sediment samples and surface water samples from Mill Pond and Factory Pond.

Additional related information is provided in the Q&A response that follows. How can we be certain that all the contamination has been discovered? Pursuant to the Massachusetts Contingency Plan (MCP) regulations, a Licensed Site Professional (LSP) cannot certify that Phase II (Comprehensive Site Assessment) is complete, until the nature and extent of impacts has been determined. GeoInsight’s Phase II was expanded in real-time while it was being conducted so as to be able to collect additional sampling data (particularly with respect to the ecological risk assessment of Mill Pond and Factory Pond). While it is impractical to consider any assessment to be fully exhaustive, the total costs for the site-wide Phase II assessment were just short of $300,000 to collect new data to supplement the significant database of historical sampling data. This was a substantial, albeit, necessary investment to further evaluate environmental conditions at the site prior to developing a remedial strategy. It is also important to note that there have were three past release areas/disposal sites on-site that were previously granted regulatory closure (beyond the six active release areas). These three release areas are further summarized in Section 3.3.2 (page 9) of the Phase II/III Report. Moreover, after Plymouth Rubber vacated the property, two potential purchasers of the property conducted due diligence assessments for their clients. This included an Environmental Site Assessment completed by GZA GeoEnvironmental, Inc. (GZA; draft report issued in June 2005) and investigation completed by Gannet-Fleming, Inc. (soil and groundwater data was available to GeoInsight, a draft or final investigation report was not). Due diligence investigations are generally performed by a prospective purchaser and designed to identify and evaluate conditions that may be indicative of a releases based upon current and past site history and field observations. Lastly, in the February 20, 2015 memo summarizing its review of GeoInsight’s report for the Town, GZA indicated: “While GeoInsight has developed a significant amount of environmental data on this site, it is not uncommon for previously unknown conditions to be revealed when former industrial buildings are demolished. Any additional environmental issues that are uncovered during site redevelopment will require appropriate response actions under the MCP.”

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Canton Holdings will address any new release areas identified during building demolition and redevelopment should they be encountered. New releases are required to be reported to the MADEP under the MCP reporting conditions. Please describe the human health risk assessment performed at the site. The Method 3 human health risk assessment (HHRA) includes calculations of potential harm to human health using the site-specific soil and groundwater sampling data and realistic exposure scenarios for human presence at the site. Sections 3.2 and 3.3 of the Method 3 HHRA report (Appendix H of the GeoInsight Phase II/III report) provides a detailed summary of the assessment of carcinogenic and noncarcinogenic risks and a listing of toxicological factors associated with constituents of concern at the Plymouth Rubber site. It is important to note that the HHRA calculations using the soil and groundwater data collected on-site (that data representing in-place conditions post-remediation), indicated “No Significant Risk 1” for future residential land uses with respect to both cancer and noncancer health risks under the remediation plan currently proposed. This means that, even though carcinogenic compounds are present at the site, they are not at high enough concentrations to be a significant threat given the relatively limited exposure scenarios even in a residential setting. The HHRA will be updated post-remediation to incorporate data collected at the limits of the “hot spots” proposed for removal to confirm that remediation successfully removed the identified hot spots. A restriction on vegetable growing in the identified release areas on-site (through the use of Best Management Practices such as raised garden beds) will be used throughout most of the site (including land to be conveyed to the Town), and an engineered barrier/cap system will be used for the Vacant Land located elsewhere on the site nearest the train tracks to maintain the condition of No Significant Risk. What state agency or Town of Canton department oversees environmental regulation? In 1993, Massachusetts created a semi-privatized program where the cleanup of hazardous waste sites is conducted under the oversight of a LSP. LSPs are authorized to work on behalf of property owners to oversee the assessment and cleanup of contaminated properties. LSPs are governed by the Massachusetts Board of Registration of Hazardous Waste Site Cleanup Professionals and must follow the regulations set forth for site cleanup in the MCP. In addition, there are provisions in the MCP (see 310 CMR 40.1110) for random and targeted audits of reports prepared by LSPs by the MADEP. LSPs are also required to provide notice of the submission of various investigation and cleanup reports to the local Health Officer who reports to the Town Board of Health and local chief municipal officer (e.g., Town Administrator). What studies and reports were required by the agencies? Other than the draft Environmental Assessment Report completed by GZA and the investigation work completed by Gannet-Fleming for voluntary due diligence studies by previous potential purchasers of the property, past environmental reports on-file with the MADEP were specifically required by the MCP regulations. Additional reports that will be required for submission to the 1

No Significant Risk is defined by the MCP (310 CMR 40.0006) as “a level of control of each identified substance of concern at a site or in the surrounding environment such that no such substance of concern shall present a significant risk of harm to health, safety, public welfare or the environment during any foreseeable period of time.”

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MADEP after remediation is initiated include: a remedial “As-Built” Construction Report and Phase IV Completion Statement (possibly combined); Phase V Remedy Operating Status Reports, as needed (applicable to on-going operation of remediation systems or if an extended period of post-remediation groundwater monitoring is needed to allow additional natural attenuation); and a Solution Statement (certifying that the remedial solution, whether Temporary or Permanent, was achieved). Were the surface water and sediment from Mill Pond and Factory Pond tested? Yes. Surface water and sediment from the Mill Pond were tested during the Phase II CSA (including biological sediment toxicity testing) and although there were some residual chemicals present, it was determined there was there was No Significant Risk to ecological populations in Mill Pond. Impacts in surface water in Factory Pond did not exceed National Recommended Water Quality Criteria and, therefore, met the requirements for a condition of No Significant Risk under the MCP for ecological populations with respect to surface water. The HHRA concluded that there was No Significant Risk to humans from impacts detected in surface water and sediment of Mill Pond and Factory Pond that may result from infrequent, incidental exposures. Sediment of Factory Pond has been impacted by releases from upland sources from past industrial operations on-site, which discharged into the box-culvert system that traverses the property and empties into Factory Pond. It is important to note that the Pond has also been affected by background impacts (such as polycyclic aromatic hydrocarbons or PAHs) from urban runoff upstream of the site. The impacts released included, primarily, No. 6 heating oil and phthalates, and also metals. The GeoInsight Phase II/III report (Section 6.2.3, page 50) summarizes the notable improvement in the natural attenuation of sediment impacts in Factory Pond from the period of 2006-2007 to 2012-2013. The remedial approach for the site involves remediating indentified upland sources of impacts to the box-culvert at the main mill complex and implementing a long-term sediment monitoring program to track the expected continued natural attenuation of sediments of Factory Pond. A Wetlands Functional Assessment (Appendix I of the Phase II/III report includes the Stage I/II Ecological Risk Characterization report and Appendix D of the Stage I/II includes the Wetlands Function Assessment) was completed at the site in 2007, prior to the noted improvement in sediment conditions, and it was concluded that the wetlands ecosystem was thriving regardless of the presence of the impacts in sediment. Active remediation of sediment from Factory Pond, such as sediment dredging, poses a significant risk to the thriving ecology of the wetlands system because of the significant disturbance and removal of the sediment and destruction of established wetlands vegetation (which may not re-establish during wetlands reconstruction/replanting to the high function level that is present today). What is the plan to eliminate the containments from PR to permit prospective residents to reside and the community at large to make use of the proposed open space in a safe fashion? The remedial approach outlined in the Phase IV Remedial Implementation Plan (RIP) involves the excavation of impacted soil and groundwater from hot spots defined within identified areas of concern. The HHRA conducted in the Phase II analyzed potential risk to future residential populations to residual soil and groundwater impacts left on-site. After removal of the hot spot

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data, the HHRA concluded No Significant Risk for future residential land uses. Residential land use is the most conservative exposure scenario used in risk assessment (most “intense” exposure activities and longest duration of exposure), therefore, cleanup goals are intended to reach this requirement. The Condition of No Significant Risk requires the restriction on vegetable growing and a cap and Activity and Use Limitation (AUL) for the Vacant Land as discussed previously. Would the level of remediation currently proposed be different if the property were instead developed for an industrial or commercial use? Yes. If residential reuse was not contemplated for the site, the HHRA conducted during the Phase II CSA would have used commercial and industrial exposure scenarios. The commercial exposure scenarios include situations with less frequent exposure and lower intensity land uses than were used in the residential exposure scenario. These scenarios would allow for remediation areas to be reduced in size, thereby increasing the relative volume on impacted soil remaining on-site as well as a higher average concentration of residual impacts than will remain under the current remediation plan. Is the cleanup proposed for the site a commonly acceptable approach to environmental remediation? Yes. Cleanup of disposal sites in Massachusetts under the MCP generally follow two primary regulatory pathways. One way is to remediate soil and groundwater impacts so that remaining impacts are below applicable soil and groundwater standards established by the MADEP (a Method 1 risk analysis). The second most common way is to remediate soil impacts such that the remaining average concentration of soil and groundwater impacts (post-remediation) indicate No Significant Risk (cancer and non-cancer risks) when subject to a site-specific HHRA (Method 3 risk assessment). Short of removing all soil and groundwater containing any level of impacts (to restore the site to true virgin, ambient/background conditions), which is infeasible for most remediation sites, cleaning the property up for residential reuse –as is proposed for the PR site– is the most protective remedial approach. What precautions, if any, are required of prospective residents and visitors to the open space given the site's industrial history and existence of contaminants? With the exception of the use of Best Management Practices to restrict vegetable/produce growing for consumption within native soil, there are no other required restrictions for the open space area. Pursuant to the MCP and associated risk assessment methodologies, there will be No Significant Risk from potential exposures to remaining impacted soil in the open space area, so long as the vegetable growing Best Management Practices are followed. Should there be concern regarding the management of future grass clippings should grass be planted in areas that will be subject to the restriction on vegetable growing for consumption? No. The purpose of the vegetable growing restriction is that there may be uptake of certain constituents (metals and PAHs) from the soil into produce grown in native soil on-site, which could then be consumed. This scenario creates a more direct exposure pathway between the

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constituents and the human receptor as produce is intended to be eaten. While the nature and significance of this uptake is not well studied, risk assessment involving evaluation of consuming vegetables grown in soils containing contaminants is designed to be conservatively safe due to these uncertainties. The HHRA used residential exposure scenarios and risk calculations based upon incidental (i.e., unintended) ingestion, dermal contact, and inhalation of soil/dust containing constituents of concern. If grass were to uptake constituents of concern, the clippings would have a lower concentration of the constituent than the soil from which it was absorbed by the plant. Moreover, grass clippings are not intended for consumption. Incidental ingestion/dermal contact/inhalation of impacted soil on-site results in a condition of No Significant Risk in the HHRA. Therefore, exposure to grass clippings from soil grown in the impacted soil would also result in a condition of No Significant Risk. It should also be noted that it is unlikely that grass will be grown directly in impacted soil on-site. This conclusion is based upon the lack of organic matter in the site’s soil. As such, loam would likely be imported to provide for the proper grass growing medium and the roots of the grass would draw most nutrients from the loam and not the underlying impacted soil. Once the remediation is complete, will any restrictions apply to use of the property? A restriction on vegetable growing in the release areas on on-site will be needed; however, vegetable growing can occur by way of Best Management Practices such as using raised garden beds with imported soil for growing. There will be no restriction on future ornamental gardening and tree growing on-site. Also, an AUL will be prepared for the Vacant Land, as discussed earlier, which will be recorded in the chain of title at the Registry of Deeds and will outline provisions for the perpetual maintenance of the engineered barrier/cap system which will cover the footprint of historical fill-soil and debris deposition in the Vacant Land (to restrict access to soil impacted with metals, including zinc and lead). How will prospective residents be made aware of any use restrictions? See previous response. A document outlining Best Management Practices for vegetable growing will be prepared and included as an attachment to the Solution Statement, which will be filed with the MADEP following completion of the remedial activities on-site. It is GeoInsight’s understanding that Canton Holdings will incorporate the Best Management Practices document into the condominium covenants and rental leases and may also commit to establishing raised garden beds in specific areas of the property. Who monitors the remediation and clean up to assure the town that it will be completed in a professional and thorough fashion? The LSP-of-Record. There are professional and ethical obligations set forth on LSPs as a condition of licensure to perform cleanup activities in accordance with the MCP regulations and in a manner that is protective of human health, public welfare and safety, and the environment. The Town of Canton has also retained GZA to provide third-party review of the PR cleanup

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activities. GZA completed a review of GeoInsight’s Phase II/III report and Phase IV RIP and a memo summarizing its review was issued on February 20, 2015. It is GeoInsight’s understanding that the Town will continue to retain GZA to provide third-party oversight of the remediation, post-remediation confirmation soil and groundwater sampling, update of the postremediation HHRA to confirm successful remediation, and to review the As-Built Construction Report/Phase IV Completion Statement and final Solution Statement. Do you anticipate any problems in implementing the proposed Best Management Practices? No. In GeoInsight’s experience, condo owners typically own the inside of the building and the condo association is responsible for and owns the building exterior and grounds. Some condo communities (including those without contamination) have restrictions on gardening to certain designated areas (or restrict it all together). As such, the existence of vegetable growing Best Management Practices for the condos should not have a significant effect on condo purchase value, resale value, or eligibility for financing. Does asbestos exist at PR, and if so how will it be attended to? Yes. Asbestos-containing material is present in many of the buildings to be demolished. Canton Holdings has retained a licensed asbestos inspector who completed a survey of building materials for the presence of asbestos (and lead-based paint). A pre-demolition asbestos survey is required in Massachusetts and the property owner must provide the survey information to the local building officer when obtaining a demolition permit. Asbestos-containing materials will be abated from the buildings prior to demolition and Canton Holdings’ asbestos consultant will provide post-abatement asbestos testing data (including air quality monitoring data during the abatement) to confirm successful abatement. The PR site still has a substantial amount of buildings and asphalt paving; what does the owner plan to do the buildings and pavement to make way for new development? Are the buildings affected by lead paint? GeoInsight has been retained by Canton Holdings to prepare an Application for Beneficial Use Determination (BUD). Massachusetts Solid Waste regulations, specifically through the BUD application process, allow for the safe, controlled re-use of building demolition rubble including asphalt, brick, and concrete (commonly referred to as ABC) at redevelopment sites. Unpainted/un-coated ABC materials that have been processed (demolition rubble which is further pulverized) can be reused at a redevelopment site as common fill after notification to the MADEP Solid Waste Management group and the local health officer. Painted/coated ABC can be reused at a redevelopment site, after the bulk material is tested for various constituents of concern (metals, typically lead, being the most common from lead-based paint coating the ABC materials). The bulk demolition ABC material testing is completed pursuant to a sampling plan outlined in the BUD application and approved in the MADEP BUD permit. If constituents are below applicable levels in the bulk painted/coated ABC rubble than the processed ABC can be reused as road base-course material in the roadways of the development that will be turned over to the Town as public right-of-ways following redevelopment. This “Beneficial Reuse” is an environmentally green practice that: avoids the necessity to dispose of a significant quantity of

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otherwise useable ABC materials in landfills; conserves the fossil fuels that would be needed to transport the material to a landfill; and saves local sand and gravel resources since the ABC material can be substituted for gravel that would otherwise by imported on-site to use as fill and road base. Under the Development Agreement, the owner is obligated, following rehabilitation, to convey the Revere Barn, Rolling Mill and surrounding 2.2 acres to the town for its exclusive use; will each of the Revere Barn, Rolling Mill and 2.2 acres be suitable and environmentally safe for occupancy and use by town? Yes. Some of the open space proposed to be conveyed to the Town (including the 2.2 acres) overlaps some or all of the Former Tank Farm, Rail Spur, and Calender Building No. 29 release areas. Past responses in this Q&A have summarized how these release areas will be remediated to a level where future residential land uses would be supported. As previously stated, risk evaluation for residential land use involves the use of significantly more conservative exposure assumptions than would apply to a commercial land use or a passive land use such as a public space, town park, or nature trail. Regarding the buildings to be conveyed, it is GeoInsight’s understanding that the Revere Barn is primarily a wood structure and the Rolling Mill is primarily a brick structure both without substantial painted surfaces, and with little asbestos that will be require abatement. Abatement of asbestos-containing material and lead paint in these structures will be monitored by Canton Holding’s building materials testing consultant. What cleanup or remediation will take place on the approximately seven acres the town may acquire from the developer for open space using CPA funds as contemplated under Warrant Article 6 of the Special Town Meeting? See previous responses. Portions of the Former Tank Farm and Calender Building No. 29 release areas overlap or are completely located within the open space that the Town may acquire. Those areas will be cleaned up prior to conveyance to the Town. The additional 2.2 acres of land that is also proposed to be conveyed to the Town (regardless of the purchase of the larger open space area) overlaps portions of the Former Tank Farm and the Rail Spur release areas. The 2.2 acres of land will be cleaned up prior to conveyance. In short, these three areas will be remediated to allow for future residential land uses (most conservative clean-up scenario).

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April 14, 2015 GeoInsight Project 6768-000 Victor D - Town of Canton

April 14, 2015 GeoInsight Project 6768-000 Victor D. Del Vecchio, Chair Board of Selectmen Town of Canton 801 Washington Street Canton MA 02021 RE: ...

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