Infrastructure Northeast Marlborough Technology Park 100 Nickerson Road, Marlborough, MA Tel Fax tetratech.

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1 November 30, 2017 Wayland Recreation Commission 41 Cochituate Road Wayland, MA Re: Athletic Field at Oxbow Meadows Licensed Site Professional Peer Review Wayland, Massachusetts Dear Wayland Recreation Commission: Tetra Tech reviewed a letter from Schofield Law Group LLC including an appended opinion letter that was prepared by Underground Energy LLC regarding potential residual contamination at the former Nike missile site at 133 Oxbow Road in Wayland, Massachusetts (the Site). In consideration of the assertions and recommendations contained within this letter, Tetra Tech reviewed applicable and available documents to research the described issues and develop an opinion relative to the planned development of a portion of the Site into a recreational field. Our understanding of the conditions at the Site and our recommendations are presented below. Historical Background As documented in the opinion letter and other source documents, the acre Site operated as a Nike missile site from 1955 through 1964 by the United States Army and then from 1964 until 1974 by the Army National Guard. During the time that the Site was operated as a missile site, surface to air missiles were stored in bunkers that were located in the area of the proposed recreation field. The National Guard reportedly used the facility as a storage facility from 1974 through Environmental assessment and remediation activities were performed by the Army National Guard at the Site in the mid-1990s to address petroleum aromatic hydrocarbon (PAH) compounds in surficial soils in accordance with the Massachusetts Contingency Plan (MCP) under the Massachusetts Department of Environmental Protection (MassDEP). Remediation was completed In accordance with the MCP. A pre-acquisition environmental assessment including the collection, sampling and analysis of soil and groundwater samples for analysis of potential contaminants of concern was performed by Bois Consulting Company, Inc. in the mid-2000s on behalf of the Town of Wayland. Hazardous building materials inspections were also performed to evaluate potential contaminant sources that would need to mitigated prior to demotion. Prior to the Town of Wayland acquisition in 2009, the former missile bunkers and other Site structures were demolished/decommissioned. Pre-demolition inspection within the bunkers identified hydraulic equipment that was used to raise the missiles from the bunkers; however, no fire extinguishing/suppression systems were noted in the bunkers or support structures. As part of MassDEP-approved decommissioning efforts of the former missile bunkers in 2009, hydraulic equipment was removed; the concrete roof and upper portions of the concrete bunker walls were demolished; the concrete bottoms of the bunkers were penetrated; and soil was imported to fill and cover the former bunker areas. Since that time, the Site use has been for passive recreation including walking trails; however, approximately 3 acres on the southeasterly portion of the Site were developed with 16 residential units. A portion of the passive recreation parcel of the Site is to be converted to a grass recreation field. Opinion Letter Summary A letter dated September 27, 2017 from Schofield Law Group LLC to the Town of Wayland Zoning Board of Appeals included an appended opinion letter that was prepared by Underground Energy LLC dated September 26, 2017 regarding the possible presence of perfluorinated compounds (PFCs) including perfluorooctanoic acid (PFOA) and perfluorooctane sufonate (PFOS) at the Site. Infrastructure Northeast Marlborough Technology Park 100 Nickerson Road, Marlborough, MA Tel Fax tetratech.com

2 As presented in the opinion letter, PFCs use included firefighting foams for flammable liquids, and it is suspected that firefighting foam may have been stored and used at the Site, although it was acknowledged that there is no documentation of PFC use at the former Nike Missile site. The opinion letter also briefly discusses the possible presence of other emerging contaminants at the Site; however, the suspected presence of these emerging contaminants is not substantiated in the letter. Recommendations within the opinion letter include a sampling program prior to redevelopment or earthwork as follows: An assessment of the location and condition of any wells at the Site and in the area; and, Sampling and analysis of groundwater from all on-site monitoring wells and any nearby municipal wells for analysis of all promulgated drinking water constituents and emerging contaminants including PFCs, hexavalent chromium, nitrosamines, perchlorates, and 1,4-dioxane. PFCs/PFAS Overview PFCs, or more accurately per- and polyfluoroalkyl substances (PFAS), were developed in the 1940s and used for decades to make products that resist heat, oils, grease, stains and water. PFAS are considered an emerging contaminant whose presence in the environment (predominantly groundwater) has only recently been considered by state and federal regulators; however, regulatory standards are being developed by some regulatory agencies (although not yet by MassDEP). The most common route of exposure to humans is ingestion (i.e. consumption of contaminated water or food), and high risk exposures can result in adverse health effects. Tetra Tech Opinion It is our opinion that the pre-acquisition and decommissioning activities that were performed at the Site in the mid to late 2000s were of the appropriate nature and scope to adequately assess suspected contaminants of concern at that time and appropriately decommission the former structures. However, further investigation of other contaminants that may have not been previously evaluated (including emerging contaminants such as PFAS) may be warranted if a suspected source exists, and the presence of this contaminant may present an exposure that presents excessive risk. Further, any project that could potentially exacerbate or mitigate future remediation of identified or suspected contaminants should also be reviewed. We agree that a review of PFAS use and storage at the Site is warranted based on the information contained within the opinion letter and the developing regulatory framework regarding PFAS. As such, Tetra Tech reviewed the assertions presented in the opinion letter relative to possible sources of PFAS, potential exposures to PFAS, and the potential impact of the planned recreational field. Following is a summary of our review: PFAS Sources: Based on our review of available records, the likelihood of a significant source of PFCs/PFAS at this Site is low. This opinion is based on the lack of documentation suggesting that PFAS firefighting foams ever existed at the Site including no observed firefighting infrastructure within the bunkers or surrounding area. Further, the Maryland Department of the Environment commissioned a study entitled Emerging Contaminants at Nike Sites Initiative (ECI). The ECI s objectives included identifying Nikes Sites in Maryland where PFCs/PFAS may have been used and assessing the potential impact of PFC/PFAS, specifically aqueous film forming foam (AFFF) that may have been used for fire suppression. In summary, According to available information, perfluorinated compounds such as PFOS and PFOA were not used in AFFF by the military until approximately By this time, liquid fuels used in Ajax and Atlas missiles were being phased out and replaced with solid fuel-propelled missiles. This timeline corroborates the ACE s (Army Corp of Engineer s) conclusion that the use of AFFF containing PFOS or FPOA on Nike bases is unlikely. The ECI study dated May 2017 is appended to this letter. Exposure Site Soils: PFAS do not effectively sorb to soils. Decades of rainwater since PFAS would have theoretically been released would have substantially flushed PFAS through the soils and into groundwater which is located over 45 feet below ground surface. Further, due to the documented importation of soil in the area of the former bunkers (reportedly several feet), the theoretical presence of any residual PFAS in soils would be beneath imported soils in the area of the former missile bunkers. Development of the recreation field is predominantly a surficial grading process with little to no excavation of subsurface soils. Further, it is believed that the surface of the field will be comprised TETRA TECH 2 Infrastructure Northeast

3 of imported topsoil to support the vegetated cover. Therefore, exposure of PFAS in Site soils resulting from a theoretical historic release, if present, is not a likely concern in the area of the proposed recreation field. Exposure Drinking Water: The nearest municipal drinking water wells are over 2,000 feet away from the Site. Based on the attached MassGIS Phase I Site Assessment map dated October 25, 2017, the Site is NOT located within the Zone II (contribution area) of any public water supply wells, which is contrary to statements within the Underground Energy LLC opinion letter. Also, according to Town of Wayland and Town of Lincoln Health Department and Board of Health records, there are two (2) private drinking water wells and six (6) private irrigation wells located within one-half mile of the Site. The drinking water wells are located at #1 Weir Meadow Path in Wayland (approximately one-half mile south-southwest of the Site) and #82 Birchwood Lane in Lincoln (approximately 1,500 feet northnorthwest of the Site. It is possible that the detection of PFAS in area drinking water wells could warrant further investigation of all potential sources of PFAS in the area; however, if the Site was considered a potential source, the presence of the recreation field at the Site would not preclude such an investigation. Lastly, Tetra Tech attempted to locate the previously-installed groundwater monitoring wells that were installed at the Site in 2004; however, the monitoring wells are believed to have been destroyed or decommissioned. Assessment for specific compounds of interest is typically driven by evidence of the use or storage of such compounds. Given the lack of evidence that past operations on the Site could have served as a source for the compounds in question, replacement of these monitoring wells is not believed to be warranted at this time. Potential Project Impacts: The development of a portion of the Site into a recreation field should be considered generally independent of any potential future investigation into residual environmental contamination at the Site. Site access in the area of the proposed recreation field for future investigation and remediation activities would not be substantially impacted by the presence of a grass field. Should additional investigation be warranted at some point in the future based on new information or changes in regulatory framework, the presence of an athletic field should not hinder such an investigation. Therefore, at this time, it is our opinion that the professional standard of care does not support further environmental investigation activities at the Site. Summary Based on available information about the Site, there is currently no suspected source of contaminants (including PFCs/PFAS and other emerging contaminants) that warrant further investigation activities prior to development of the recreational field at the Site. Although investigative tasks are typically driven by site history and potential for release of oil or hazardous materials (OHM), one may always choose to add more conservative elements to an investigation out of an abundance of caution. However, given the record and the history of the site, including past investigations, we do not believe that replacing the former monitoring wells at this time in order to collect soil and/or groundwater samples for laboratory analysis targeting emerging contaminants is supported. If new future information suggesting such an investigation is warranted, such as detection of contaminants at neighboring wellheads where hydraulic connection to the Site is demonstrated or strongly inferred, such an investigation can be carried out at that time without significant hindrance from use as an athletic field. If you have any questions or comments, please feel free to contact us at (508) Very truly yours, Ronald E. Myrick, Jr. P.E., L.S.P. Director or Remediation, Assessment and Compliance Michael E. Billa, P.G., P.E., L.S.P. Vice President Attachments: MD Emerging Contaminants at Nike Sites Initiative, Maryland Department of the Environment, May 2017 MassDEP Phase 1 Site Assessment Map, 133 Oxbow Road, Wayland TETRA TECH 3 Infrastructure Northeast

4 MD EMERGING CONTAMINANTS AT NIKE SITES INITIATIVE What You Need to Know Emerging Contaminants at Nike Sites Initiative (ECI) is a project designed to document historic use of Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA), two perfluorinated chemicals (PFCs) at Formerly Used Defense Sites (FUDS) and former Nike Sites in particular. The ECI shall also assess the potential for further pre-remedial investigations of select facilities. The ECI s objectives include: Identifing Nike Sites in MD where PFCs might have been used; Defining populations that may be at risk from potential PFC contamination; Estimating users and uses of groundwater in close proximity to the sites; and Laying the groundwork for future investigations that would target identified risks PFOS and PFOA are emerging contaminants which is defined as a chemical or material that is characterized by a perceived, potential, or real threat to human health or the environment or by a lack of published health standards. These compounds were used in the manufacture and/or treatment of many products because of their unique characteristics. The product of particular interest in this initiative is Aqueous Film Forming Foam (AFFF) which is a PFOS based substance that is used to extinguish liquid fueled fires. Nike Sites are potential locations of AFFF contamination based on historical and current uses of the properties. It is already known, that subsequent to the Army s use of the properties, some local fire and rescue departments have used the sites for general fire fighting and rescue training, which could have involved the use of AFFF. However, MDE raised the question of whether AFFF could have been used historically for fire-fighting exercises involving fires fueled by liquid fuels stored onsite for use in Ajax Missiles and other rocket engines. Eighteen Nike Sites, each consisting of two separate properties, were located in a ring configuration around the cities they were designed to defend. In the Baltimore-Washington Metro area, Nike Sites were located in a ring that encompassed both cities. Sites that were designed to defend Baltimore were designated with a BA number and sites that were designed to defend Washington were designated with a W number. Environmental Investigation and Action Sixteen of the eighteen Nike Sites in Maryland have been subject to various environmental investigations and remedial actions. The other two Nike Sites are located on active military reservations and the state has no record of investigations at those sites. The materials and practices used at these sites in the late 1950s and early 1960s often had contaminated soils and groundwater. One common practice at these sites was to dispose of used oil, solvents and other Wood/LRP/May/2017

5 MD EMERGING CONTAMINANTS AT NIKE SITES INITIATIVE What You Need to Know hazardous liquids by dumping them into a pit containing gravel which allowed the substances to soak into the soil and eventually the groundwater. Current Status As part of this investigation, an internet search was conducted to find any contacts who might have information as to the use of PFOS-based compounds such as AFFF at Nike missile sites. Several inquiries were sent out to various contacts, with very few responses. One inquiry was answered by Christopher L. Evans, Chief of Environmental Programs, U.S. Army Corps of Engineers (ACE) Headquarters in November of His response stated that, Based on review of historic documents and project-specific preliminary assessments prepared for some of the missile sites in question, there are no fire training areas nor evidence of use or acquisition of Aqueous Film Forming Foam (AFFF) for Nike or Atlas missile sites. Therefore, there is no evidence for concern for past release of Perfluorooctanoic Acid (PFOA)/ Perfluorooctane Sulfonate (PFOS) at these sites. According to available information, perfluorinated chemicals such as PFOS and PFOA were not used in AFFF by the military until approximately By this time, liquid fuels used in Ajax and Atlas missiles were being phased out and replaced with the solid fuel-propelled missiles. This timeline corroborates the ACE s conclusion that the use of AFFF containing PFOS or PFOA on Nike bases is unlikely. Consequently, the only sites likely to have AFFF, PFOS/PFOA use or disposal are Nike sites where other parties (such as county fire-fighting agencies) used the property after decommissioning of these sites, such as Phoenix Launch, and not as a result of the Nike program itself. Wood/LRP/May/2017

6 MassDEP Phase 1 Site Assessment Map Page 1 of 1 10/25/2017 Site Information: 133 OXBOW ROAD WAYLAND, MA NAD83 UTM Meters: mN, mE (Zone: 19) October 25, 2017 MassDEP - Bureau of Waste Site Cleanup Phase 1 Site Assessment Map: 500 feet & 0.5 Mile Radii The information shown is the best available at the date of printing. However, it may be incomplete. The responsible party and LSP are ultimately responsible for ascertaining the true conditions surrounding the site. Metadata for data layers shown on this map can be found at: m 1000 ft