Class A-3 Response Action Outcome Statement MBTA … · 5.6 Feasibility of Restoration to...

Submitted to: Submitted by: Massachusetts Bay Transportation AECOM Authority (MBTA) Chelmsford, MA 60133920.4 April 2013

Environment

Class A-3 Response Action Outcome Statement MBTA Readville Yard Industrial Drive, Dedham and Boston, MA Release Tracking Number 3-2856

Submitted to: Submitted by: Massachusetts Bay Transportation AECOM Authority (MBTA) Chelmsford, MA 60133920.4 April 2013

Environment

Class A-3 Response Action Outcome Statement MBTA Readville Yard Industrial Drive, Dedham and Boston, MA Release Tracking Number 3-2856

_________________________________ Prepared By Timothy Markey, Senior Toxicologist

_________________________________ Reviewed By Elissa Brown, LSP

AECOM RAO Report Environment

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J:\Concord\105627 - MBTA\PROJ\TO-1 Readville\RAO\Report\Final\MBTA Readville Yard 5 RAO-A FINAL April 2013.docx

Contents

1.0 Introduction ...................................................................................................................... 1-1

1.1 General ................................................................................................................................. 1-1

1.2 Site Location and Description .............................................................................................. 1-2

1.3 Surrounding Area ................................................................................................................. 1-3

1.4 Site History ........................................................................................................................... 1-3

1.4.1 Owner and Operator History ................................................................................ 1-3

1.4.2 Oil and Hazardous Material Use and Storage History......................................... 1-3

1.5 Description of Response Actions Conducted ..................................................................... 1-4

2.0 Site Characterization ...................................................................................................... 2-1

2.1 Site Topography and Surface Water Features ................................................................... 2-1

2.2 Geology ................................................................................................................................ 2-1

2.3 Hydrogeology ....................................................................................................................... 2-1

2.4 Sensitive Receptors ............................................................................................................. 2-2

2.5 Nature and Extent of Contamination ................................................................................... 2-2

2.6 Identification of Applicable Soil and Groundwater Categories ........................................... 2-4

2.6.1 Groundwater Categories ...................................................................................... 2-4

2.6.2 Soil Categories ...................................................................................................... 2-4

3.0 Data Usability Assessment and Representativeness Evaluation ............................. 3-1

3.1 Analytical Data Usability Assessment ................................................................................. 3-1

3.1.1 Comparability Evaluation for CAM Non-Compliant, Non-CAM and Pre-CAM ... 3-1

3.1.2 Field Quality Control Data Usability Assessment ................................................ 3-2

3.1.3 Data Quality Objectives ........................................................................................ 3-2

3.2 Representativeness Evaluation ........................................................................................... 3-3

3.2.1 Conceptual Site Model.......................................................................................... 3-3

3.2.2 Data Quality Objectives and Data Collection Approach ...................................... 3-4

3.2.3 Use of Field/Screening Data ................................................................................ 3-5

3.2.4 Selection of Sampling Locations, Depths, Distribution, and Number of Sampling Locations .............................................................................................. 3-5

3.2.5 Completeness ....................................................................................................... 3-5

3.2.6 Uncertainty and Inconsistency ............................................................................. 3-5

4.0 Method 3 Risk Characterization .................................................................................... 4-1

4.1 Previous Phase II/III Method 3 Risk Characterizations ...................................................... 4-1

4.1.1 Weston & Sampson Risk Characterization .......................................................... 4-1


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4.1.2 LFR Updated RBCs .............................................................................................. 4-2

4.1.3 AECOM Revised Risk Characterization .............................................................. 4-2

4.2 Post-Remediation Method 3 Risk Characterization – Class A RAO .................................. 4-4

5.0 Response Action Outcome Statement ......................................................................... 5-1

5.1 Class of RAO ....................................................................................................................... 5-1

5.2 Boundaries of Disposal Site ................................................................................................ 5-1

5.3 Elimination of Uncontrolled Sources ................................................................................... 5-2

5.4 Upper Concentration Limits ................................................................................................. 5-2

5.5 Post RAO Operation, Maintenance & Monitoring ............................................................... 5-2

5.6 Feasibility of Restoration to Background ............................................................................ 5-2

5.7 Activity and Use Limitation .................................................................................................. 5-4

5.8 Public Involvement Activities ............................................................................................... 5-5

5.9 Licensed Site Professional Opinion .................................................................................... 5-5

6.0 References ....................................................................................................................... 6-1


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List of Appendices

Appendix A Bureau of Waste Site Cleanup (BWSC) Transmittal Form BWSC-104 (RAO)

Appendix B Copies of Public Notification Letters

Appendix C Activity and Use Limitation

Appendix D Risk Characterization

Appendix E Data Usability

List of Figures

Figure 1 Site Locus Map

Figure 2 Site Plan

Figure 3 Pre-Excavation Sample Locations

Figure 4 Post-Excavation XRF Sample Locations

Figure 5 Post-Excavation Analytical Laboratory Sample Locations

Figure 6 GIS Data Layer Map


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List of Acronyms and Definitions

ACEC Area of Critical Environmental Concern ACM Asbestos Containing Material AUL Activity and Use Limitation bgs Below Ground Surface (depth below the ground surface) BWSC Bureau of Waste Site Cleanup CAM Compendium of Analytical Methods CMR Code of Massachusetts Regulations COC Contaminants of Concern CSA Comprehensive Site Assessment CSM Conceptual Site Model DQO Data Quality Objective ELCR Excess Lifetime Cancer Risk (human health risk assessment) EPC Exposure Point Concentration EPH Extractable Petroleum Hydrocarbons EZ Exclusion Zone ft/ft foot per foot FEMA Federal Emergency Management Administration FIR Final Inspection Report GPR Ground Penetrating Radar GW-1 Groundwater category GW-1 applies if the groundwater is located within a Current

Drinking Water Source Area or Potential Drinking Water Source Area GW-2 Groundwater category GW-2 applies within 30 feet of an existing occupied structure

where the average annual depth to groundwater is 15 feet below grade or less GW-3 Groundwater at all disposal Sites in Massachusetts is considered a potential source of

discharge to surface water and is therefore categorized GW-3 at a minimum HB/GP Sample code for soil samples collected from Historical Building (HB) locations by

Geoprobe (GP) HI Hazard Index HMM HMM Associates, Inc. HQ Hazard Quotient IH Imminent Hazard IRA Immediate Response Action ISI Initial Site Investigation IWPA Interim Wellhead Protection Area LFR Levine Fricke Consultants LSP Licensed Site Professional LT/SS Sample code for surface soil samples collected from Looping Track (LT) locations MassDEP Massachusetts Department of Environmental Protection MassGIS Massachusetts Geographic Information System MBTA Massachusetts Bay Transportation Authority MCP Massachusetts Contingency Plan MW Monitoring Well MWRA Massachusetts Water Resources Authority


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List of Acronyms and Definitions (Cont’d)

NAPL Non-Aqueous Phase Liquid NOR Notice Of Responsibility NRS Numerical Ranking System OHM Oil and/or Hazardous Materials ORS Office of Research & Standards PAH Polycyclic Aromatic Hydrocarbon PCB Polychlorinated Biphenyls PID Photo-ionization Detector PIP Public Involvement Plan PRP Potentially Responsible Party QC Quality Control RAO Response Action Outcome RAP Remedial Action Plan RAPS Response Action Performance Standard RBC Risk-Based Concentration RC Risk Characterization RCRA Resource Conservation and Recovery Act RCRA 8 Resource Conservation and Recovery Act 8 Metals RIP Remedial Implementation Plan RP Responsible Party RTN Release Tracking Number SOW Scope of Work SSCMP Soil Stockpile Characterization and Management Plan SVOC Semi-Volatile Organic Compounds TCLP Toxicity Characteristic Leachate Procedure TPH Total Petroleum Hydrocarbons TSCA Toxic Substances Control Act TVOCs Total Volatile Organic Compounds UCL Upper Concentration Limit USGS United States Geological Services VOCs Volatile Organic Compounds VPH Volatile Petroleum Compounds XRF X-Ray Fluorescence

AECOM Report Environment

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Executive Summary

AECOM Environment (AECOM), on behalf of the Massachusetts Bay Transportation Authority (MBTA), has completed this Response Action Outcome (RAO) Statement for the MBTA Readville Yard (also known as the Readville 5-Yard and Readville Yard 5), located at Industrial Drive in Dedham and Boston, Massachusetts (the Site). The Site is a rail storage and maintenance yard owned by the MBTA and used by the MBTA and associated rail operators. The location of the Site is shown in Figure 1. This RAO statement applies to the entire Site, which consists of four subareas:

Area 1 – Orphan Line: The Orphan Line was formerly the Dedham Secondary Line and consists of an approximately 90-foot wide by 3,200–foot long section of abandoned railroad tracks along the Site’s northern boundary.

Area 2 – Western Fence Line (adjacent to Ashcroft Street): Area 2 is a narrow strip of land located along the southwestern Site boundary between the Exclusion Zone (EZ, see below) and a wooded area followed by residential properties on Ashcroft Street.

Area 3 - Main Rail Yard: The Main Rail Yard comprises approximately 21 acres in the eastern portion of the Site. It contains both active and inactive tracks, and is currently used by MBTA and Massachusetts commuter rail operators for storage of railroad materials (ties, track panels, etc.).

Area 4 - Exclusion Zone (EZ): The EZ is located in the western portion of the Site. Several stockpiles containing soil from off-site MBTA operations had been located in this area.

An aerial photograph showing the four areas previously identified, the Disposal Site Boundary, and Property boundary is presented as Figure 2.

The MBTA Readville Yard became a Site under the Massachusetts Contingency Plan (MCP) in 1990 following an environmental site assessment conducted for a potential real estate transaction. The Readville Yard was assigned Site Number 3-2856 by the Massachusetts Department of Environmental Protection (MassDEP) based on the detection of petroleum and metal contaminants in soil and groundwater. The degree of contamination at the Site enabled MassDEP to grant a Waiver of Approvals in October 1990 for the site assessment and cleanup without MassDEP’s oversight. In 1999, MassDEP issued a Notice of Responsibility (NOR) and a Release Tracking Number (RTN) for this Site (3-18777), after reviewing the files and determining that elevated lead concentrations in soil could pose an Imminent Hazard (IH) condition. In October 2000, the MBTA conducted an IH Evaluation of the Site and concluded that an IH did not exist at the Site. This RTN was subsequently linked to the primary RTN.

Between 1989 and 2008, a number of environmental investigations were conducted at the Site. These investigations concluded that metals (predominantly lead and arsenic), extractable petroleum hydrocarbons (EPH), and target polycyclic aromatic hydrocarbons (PAHs) had impacted soil at the Site. Contaminant concentrations in soil were generally highest within the shallow fill identified as brown to black coarse sand, asphalt, glass, coal, brick, and wood. Contaminant concentrations decreased rapidly with depth and were generally not observed within the deeper unit identified as native material, which consisted of dense sand with varying amounts of gravel, cobbles, silt, and clay. No polychlorinated biphenyls (PCBs) or herbicides were detected in the soil (surficial, shallow, or subsurface). Soil samples were also collected from the various soil stockpiles at the Site. Materials identified in the stockpiles included soil, creosote timbers, asphalt, wood debris, railroad ties, bricks,


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ash, trash, metal, burnt material, lead-acid batteries, white "talc-like" material (lime), and other miscellaneous items. Contaminants detected in the stockpiles included metals, PAHs, PCBs (at concentrations below the Toxic Substance Control Act [TSCA] thresholds), and total petroleum hydrocarbons (TPH). The location of historic soil and soil stockpile samples are shown in Figure 3.

Contaminant concentrations in groundwater were detected at or near analytical method detection limits. No contaminant concentrations were detected above the applicable MCP Method 1 GW-3 standards.

Site-wide Risk-Based Concentration levels (RBCs) were developed during risk characterization for four potential future general use scenarios/receptors, which include: residential, recreational, commercial/ industrial (indoor/outdoor worker) and construction. Contaminants of concern (COCs) carried through the risk characterization for the four Areas included arsenic, lead, antimony, barium, chromium, cobalt, copper, nickel, zinc, EPH parameters, and select PAHs. Specific contaminants driving the remediation of the Site include arsenic and lead.

A number of limited risk reduction measures were conducted at the Site that included removal of the some of the most impacted soil, covering of soil stockpiles, and erection of fencing to limit access to the Site. In 2011 through 2012, a comprehensive response action was conducted in which over 18,500 tons of impacted soil was excavated, treated on-site, as necessary, and transported off-site for re-use as landfill daily cover and grading. In addition to the impacted soil, over 1,100 tons of railroad ties, metals, and concrete were hauled off-site for recycling and/or re-use. Site restoration activities were completed in early 2012, with confirmatory samples collected from the sidewalls and bottoms of the excavations. Post-excavation soil sample locations are shown in Figures 4 and 5.These activities are detailed in the Phase IV Final Inspection Report and Completion Statement submitted to MassDEP on May 16, 2012.

Prior to the 2011 to 2012 comprehensive response action, Method 3 Risk Characterizations performed to evaluate the potential risk to human health, safety, public welfare, and the environment concluded that a level of No Significant Risk did not exist at the Site under current or future use conditions. This RAO Statement includes an updated Method 3 Risk Assessment, with the implementation of an Activity and Use Limitation (AUL) that limits use of the Site to commercial and industrial activities and required precautions to be taken during any future construction activities. Area Exposure Point Concentrations (EPCs) calculated following soil excavation are less than the RBCs, and all calculated risks to human health, safety, public welfare and the environment, indicate that a level of No Significant Risk has been achieved at the Site.

Two AULs (one for Boston and one for Dedham), included in this RAO Report, are being implemented on the MBTA property in order to maintain a level of No Significant Risk. Therefore, it is AECOM’s opinion that no further response actions are necessary at the Site and the requirements of a Class A-3 RAO have been met for the Disposal Site identified by the MassDEP as RTN 3-2856.

This report is being submitted along with a fully executed copy of Bureau of Waste Site Cleanup (BWSC) RAO Transmittal Form BWSC-104 via eDEP. A copy of the unsigned form is presented in Appendix A. In addition, AECOM has enclosed copies of the Public Notification letters sent to the Town of Dedham Town Administrator and the Director of the Board of Health and the City of Boston Mayor and Executive Director of the Public Health Commission as Appendix B of the report. As stated above, this RAO is supported by the implementation of an AUL. A copy of the AULs is included as Appendix C.


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1.0 Introduction

1.1 General

On behalf of the Massachusetts Bay Transportation Authority (MBTA), AECOM Environment (AECOM) has completed this Response Action Outcome (RAO) Statement for the MBTA Readville Yard Site (also known as the Readville 5-Yard and Readville Yard 5 Site) located on Industrial Drive in Dedham and Boston, Massachusetts (the Site and Disposal Site). The Site is a MBTA rail storage and maintenance yard at which soil has been impacted by the release of metals (predominantly lead and arsenic), and to a much lesser extent, petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs). All detected contaminant concentrations in groundwater were at or near analytical method detection limits.

This RAO statement applies to the entire Site identified by the Massachusetts Department of Environmental Protection (MassDEP) as Release Tracking Number (RTN) 3-2856. In accordance with 310 Code of Massachusetts Regulations (CMR) 40.1036(3), a Class A-3 RAO is appropriate for the Disposal Site due to the fact that:

A Permanent Solution has been achieved;

The level of oil and/or hazardous material (OHM) in the environment has not been reduced to background;

An Activity and Use Limitation (AUL) is necessary to maintain a level of No Significant Risk; and

Average contaminants concentrations do not exceed the Upper Concentration Limits (UCLs) set forth in the Massachusetts Contingency Plan (310 CMR 40.0000 – the MCP).

An AUL has been implemented on the Readville Yard Site in both Dedham and Boston, Massachusetts to maintain a level of No Significant Risk. It is AECOM’s opinion that no further response actions are necessary at the Site and the requirements of a Class A-3 RAO have been met for the Disposal Site identified by the MassDEP as RTN 3-2856.

A Method 3 Risk Characterization (RC) was completed for RTN 3-2856 as part of Supplemental Phase II/III and revised Phase IV report submitted by AECOM in January 2010. The Method 3 RC was used to evaluate and characterize the potential risk of harm to human health, public welfare, safety, and the environment which may be posed by compounds detected at the Site and is used in support of this RAO and AUL. An updated risk characterization, with consideration to recently completed remedial actions performed at the Site, is included in this report.

This report is being submitted along with a fully executed copy of Bureau of Waste Site Cleanup (BWSC) RAO Transmittal Form BWSC-104 via eDEP. A copy of the unsigned form is presented in Appendix A.

Notice of the availability of this RAO report was submitted to the City of Boston Mayor and Executive Director of the Public Health Commission, the Town of Dedham Town Administrator and the Director of the Board of Health, and the Public Involvement Plan (PIP) mailing list on April 5, 2013. Prior to


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submission of a final document, the draft version of this document was placed in the public repositories in Dedham and Boston, and notification made to public officials and other persons on the PIP list. A public meeting was held on March 6, 2013 to inform the public and to solicit the concerns of the public during a public comment period. Meeting summaries and responses to public comments (no written public comments were received during the public comment period) are included, with copies of the letters to municipal officers in Appendix B. A copy of this final document, with the meeting summaries and response to comments, has been placed in the public repositories as well.

As stated above, this RAO is supported by the implementation of an AUL. A copy of the AULs is included as Appendix C.

1.2 Site Location and Description

The Site occupies a portion of the approximately 42-acre MBTA property located on Industrial Drive and straddles the boundary between the Town of Dedham and the City of Boston (Readville), Massachusetts. Approximately 21 acres of the Site are located in Boston and 21 acres are located in the Town of Dedham. The portion of the Site located in Dedham is zoned general residential and the portion of the Site located in Readville is zoned general and light manufacturing. The geographical location for the Site is shown on the Site Locus Plan, Figure 1, and is described as follows:

UTM Coordinates: N 4,678,253 m E 323,168 m

Latitude/Longitude: 42° 14' 19" N 71° 08’ 37" W

The Site is roughly an elongated teardrop shape and its perimeter is defined by a loop railroad track enclosed by an 8-foot tall chain link fence.

The MBTA property extends beyond the railroad track fencing and includes Industrial Drive. The Site, which excludes Industrial Drive, is owned by MBTA and is currently operated by Massachusetts commuter rail operators under contract to MBTA.

The Site is mostly unpaved, with the exception of a driveway approximately 100 feet wide and 1,700 feet long running east-west along the northern side of the Site. Materials used for railroad maintenance (ties, track panels, etc.) are currently at various locations throughout the Site. The Site has been divided as follows into four areas based on historical use and types and concentrations of contaminants:


Area 2 – Western Fence Line (adjacent to Ashcroft Street): Area 2 is a narrow strip of land located along the southwestern Site boundary between the Exclusion Zone (EZ, see below) and a wooded area followed by residential properties on Ashcroft Street.

Area 3 - Main Rail Yard: The Main Rail Yard comprises approximately 21 acres in the eastern portion of the Site. It contains both active and inactive tracks, and is currently used by MBTA and Massachusetts commuter rail operators for storage of railroad materials (ties, track panels, etc.).


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Area 4 - Exclusion Zone: The EZ (Areas 4) is located in the western portion of the Site. Several stockpiles containing soil from off-site MBTA operations had been located in this area.

An aerial photograph showing key Site features, the four areas previously identified, and property boundaries, is presented as Figure 2.

1.3 Surrounding Area

The Site is abutted by residential properties to the north, east, and west, and by industrial properties to the south. Residential and commercial properties abut the Site to the west on Ashcroft Street and to the north opposite the former Dedham Secondary rail line (a.k.a. the “Orphan Line”) on Milton/W. Milton Street. Commercial and industrial properties, including a school bus garage and storage yard and a gravel crushing operation, are located to the south, opposite Industrial Drive. The MBTA Readville commuter rail station, including commuter parking lots and the MBTA 2-Yard facility, is located to the east.

1.4 Site History

1.4.1 Owner and Operator History

The Site is located at the historic crossing of the Boston & Providence Railroad, which began operating in Readville in 1834, and the Midland Railroad, which began operating in 1853. The Midland Railroad later became the New York New England Railroad and then, in 1895, a subsidiary of the New York, New Haven and Hartford Railroad. Readville Yard operations included conversion of wooden rail cars to metal cars, repair and maintenance of locomotives and rail cars, assembly of freight cars, and storage.

The Readville Yard was acquired by MBTA from the National Railroad Passenger Corporation (Amtrak) in a quitclaim deed dated November 11, 1987. Amtrak had been deeded the property from Conrail on April 1, 1976, one day after Penn Central conveyed the property to Conrail.

1.4.2 Oil and Hazardous Material Use and Storage History

Based on the history of the Site and the conditions encountered, it is assumed that paint containing metals, as well as petroleum hydrocarbons and associated PAHs were used at the Site. This is consistent with the finding of environmental investigations conducted, in which petroleum hydrocarbons and metals were detected in soil and groundwater. Additional assessment confirmed the presence of elevated concentrations of lead, arsenic, petroleum hydrocarbons, and PAHs in Site soil and soil stockpiles. In addition, PCBs were detected in some soil stockpiles.

According to the 1989 Phase I Limited Site Investigation report (HMM, 1989), a release of 100–500 gallons of sulfuric acid occurred at the Site in February 1985. Jet Line Services, Inc., (Jet Line) reportedly neutralized the spill with lime. However, “some of the acid apparently drained into the subsurface”.

In 2001-2002, reusable materials were consolidated within the 5-acre staging area and subsequently were removed from the Site. In the course of these activities, asbestos was detected in the wreckage of an Amtrak baggage car that had been stored at the Site for accident investigation purposes. The asbestos containing material (ACM) and associated asbestos-impacted soil was subsequently removed.


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1.5 Description of Response Actions Conducted

On May 12, 1989, HMM prepared a Preliminary Site Assessment / Phase I – Limited Site Investigation for the MBTA to support the proposed redevelopment of the Site as a commuter train facility. This report summarized the results of a Site investigation conducted by HMM between March 7, 1989, and May 5, 1989, and included a detailed Site description, history, subsurface investigation, and sample analysis. Based on detected concentrations of petroleum and metal contamination in soil and groundwater samples, HMM submitted a Waiver of Approvals application to the MassDEP, which was subsequently approved on October 10, 1990 (Site Number 3-2856). Additional assessment conducted by HMM in 1990 confirmed the presence of elevated concentrations of lead and petroleum hydrocarbons in Site soil. Sample locations for this data, as well as subsequent sample location data is shown on Figure 3.

On September 29, 1999, the MassDEP issued a Notice of Responsibility (NOR) and a second RTN for this Site (3-18777), after reviewing the files and determining that elevated lead concentrations in soil could potentially pose an Imminent Hazard (IH) condition. In response to the NOR, the MBTA conducted an IH evaluation, fencing of the area of elevated lead in soil, and posting of warning signs. The IH investigation (Rizzo, 2000) included the collection of 48 surficial soil samples for the analysis of lead. Elevated concentrations of lead were detected in the soil samples collected across the Site. Based on these data, based on the results of this investigation Rizzo concluded that an IH did not exist at the Site. On September 14, 2001, Rizzo submitted a Phase I - Initial Site Investigation (Phase I) to the MassDEP. The Site was Tier Classified as Tier IC with an NRS score of 413. The MassDEP conditionally approved the Tier IC permit in a letter dated February 7, 2002.

On July 13, 2001, the MBTA received a petition requesting designation of the Site as a PIP Site. In response to the petition, the MBTA and the MassDEP designated the Site as a PIP site. A draft PIP Plan was prepared and presented at a public meeting in February 2002.

On October 12, 2001, the MBTA and the Attorney General for the Commonwealth of Massachusetts entered into a preliminary injunction agreement that identified several tasks to be expedited. These tasks included covering of the exposed stockpiles within the EZ, completion of a groundwater investigation, and preparation of a stockpile characterization plan. The MBTA (Weston & Sampson, 2001) submitted an IRA Plan to conduct these three identified tasks.

Between October and December 2001, the MassDEP conducted an IH Evaluation that included the collection of over 3,000 surficial soil samples for x-ray fluorescence (XRF) field screening for lead and arsenic. Based on the results of their IH Evaluation, the MassDEP concluded that IH conditions did not exist at the Site under current conditions; however, they identified several zones for additional investigation located immediately outside the Site fence to the north near Milton Street and to the west near Ashcroft Street.

Weston & Sampson, on behalf of the MBTA, prepared a draft IRA Plan for additional assessment of the above-mentioned zones, which was submitted to the MassDEP and presented at the PIP meeting at the Dedham High School on February 27, 2002. The final IRA Plan was submitted to the MassDEP on March 28, 2002. On April 2, 2002, Weston & Sampson commenced sampling activities. Analytical data indicated high concentrations of arsenic along the western fence and lead at two locations along the northern fence. On May 28, 2002, Weston & Sampson conducted additional sampling to evaluate the extent of contamination. Between June 1 and 19, 2002, a new fence was installed approximately 20 feet west of the original western fence.


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On June 6, 2002, Weston & Sampson held another PIP meeting at the Dedham Town Hall to present the draft Phase II Scope of Work (SOW) for public comment, and to notify the residents of IRA excavation activities outside the northern fence. On June 26, 2002, Weston & Sampson documented the IRA excavation of a total of approximately 20 cubic yards of lead-impacted soil from two locations outside the northern fence. Shortly after the close of the 21-day comment period, Weston & Sampson submitted a Final Phase II SOW to the MassDEP on July 12, 2002, and fieldwork commenced the week of July 22, 2002.

In addition, Amtrak, independent of MBTA, presented a plan to the MassDEP on December 4, 2001, for disposal of solid waste and management of reusable materials stored at the Site. In accordance with this plan, reusable materials were consolidated on-Site, and wooden rail ties and metal recycled off-Site. During these activities, Amtrak identified wreckage of an Amtrak baggage car that had been stored at the Site for accident investigation purposes. Analysis of this wreckage indicated a thin adhesive coating/lining within the steel structure containing asbestos. The ACM was subsequently scheduled to be removed under an IRA Plan prepared by Amtrak and their consultant, Harding ESE, Inc., and presented during the June 6, 2002, public meeting. According to Amtrak, the train wreckage material and soil containing asbestos was removed from the Site during August and September 2002.

A Phase II investigation was performed at the Site by Weston & Sampson on behalf of the MBTA between July and October 2002 and included advancement of Geoprobe borings, excavation of test pits, installation of monitoring wells, collection of surficial soil samples, characterization of soil and debris piles, evaluation of groundwater flow, and collection of groundwater samples in August and October.

Based on the Phase II investigation, detected contaminants in soil included metals (predominantly lead and arsenic), extractable petroleum hydrocarbons (EPH), and target PAHs. Contaminant concentrations in soil were generally highest within the shallow fill identified as brown to black coarse sand, asphalt, glass, coal, brick, and wood. Contaminant concentrations decreased rapidly with depth and were generally not observed within the deeper unit identified as native material, which consisted of dense sand with varying amounts of gravel, cobbles, silt, and clay. No PCBs or herbicides were detected in the soil samples analyzed (surficial, shallow, or subsurface). Contaminants detected in the soil and debris stockpiles included total and leachable metals (mainly lead and arsenic), PAHs, PCBs (at concentrations below the Toxic Substances Control Act (TSCA) thresholds), and total petroleum hydrocarbons (TPH).

All detected contaminant concentrations in groundwater were at or near analytical method detection limits. No contaminant concentrations were detected above the applicable MCP Method 1 GW-3 standards.

A Method 3 RC was performed to evaluate the potential risk to human health, safety, public welfare, and the environment posed by contaminants detected at the Site. The results of the RC indicated that further response actions to eliminate exposure to surface (0 to 6 inches) and subsurface (0 to 3 feet) soils were required to achieve a condition of “No Significant Risk” in all Areas under existing Site conditions for all potential Site uses except for the construction worker scenario. The Phase II CSA concluded that remedial activities were required to achieve a level of “No Significant Risk” and the Phase III to be prepared for the Site would evaluate potential remedial options.


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The Final Phase II Report was submitted to the MassDEP and the information repositories on January 31, 2003. To accommodate the MassDEP’s additional comments on the Phase III, and to avoid confusion among the public, the MBTA responded to the MassDEP’s comments concerning the Final Phase II Report in the form of a Phase II Addendum – Response to DEP Comments on the Final Phase II Report (the “Phase II Addendum”). The Phase II Addendum was attached as Appendix F to the Final Phase III Report submitted to the MassDEP on April 30, 2003.

From November 23 to December 13, 2005, Levine Fricke Recon, Inc. (LFR) on behalf of a potential developer of the property collected and analyzed samples collected across the Site using a combination of field screening supplemented with laboratory analysis of selected samples. A total of 250 test pits were excavated on the Site and were excavated using a subcontracted backhoe and operator. As with previous investigations, elevated soil lead was observed primarily in the shallow soils and urban fill layer across the Site. Elevated arsenic was observed primarily in the vicinity of the railroad tracks and chemically treated railroad ties.

AECOM prepared a Final Supplemental Phase II/III Report and Revised Phase IV Remedy Implementation Plan (RIP). During the period from June 30, 2008 to July 3, 2008, as part of the Supplemental Phase II investigations AECOM sampled the existing soil stockpiles to gather the necessary data to estimate the quantity of soil that may exceed the UCL for soil lead of 3,000 mg/kg. AECOM also collected 100 soil samples to evaluate the validity of the LFR data collected in the UCL areas in the Main Yard of the rail yard. A Method 3 RC was conducted that indicated that a condition of No Significant Risk of harm to human health, public welfare and the environment did not exist at the Site (a condition of No Significant Risk of harm to safety exists). Commercial/Industrial Worker, Residential, Construction Worker, Trespasser, and Recreational Risk-Based Concentrations (RBCs) were calculated for all chemicals of concern (COCs) in each separate exposure point at the site (Area 1, Area 2, etc.) using a cumulative risk approach.

Based on the conclusions of the original Phase III Remedial Action Plan (RAP), the Supplemental Phase II Comprehensive Site Assessment (CSA) and Method 3 RC, and the proposed continued future use of the Site as commercial/industrial, AECOM recommended Soil Excavation (0 to >8 feet) to meet Commercial/Industrial RBCs and Off-Site Disposal with Stabilization as the final remedy for the Site to achieve a condition of “No Significant Risk”. The final Supplemental Phase II/III and Revised Phase IV Report was submitted to MassDEP on January 15, 2010. MassDEP issued a letter granting Conditional Approval of the final Supplemental Phase II/III and Revised Phase IV Report on May 10, 2010.

Phase IV remediation activities were initiated in July 2011 and involved the excavation of over 18,500 tons of impacted soil. The soil was treated on-site, as necessary, and transported off-site for re-use as landfill daily cover and grading. Over 1,100 tons of railroad ties, metals, and concrete were hauled off-site for recycling and/or re-use. Site restoration activities were completed by January 18, 2012. These activities are detailed in the Phase IV Final Inspection Report (FIR) and Phase IV Completion Statement submitted to MassDEP on May 16, 2012. Post-excavation soil sample locations are shown in Figures 4 and 5.


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2.0 Site Characterization

2.1 Site Topography and Surface Water Features

The topography of the Site is generally flat. Topography in the area of the Site is characterized by small hills up to 150 feet above mean sea level in height, rising above broad level river valleys marked by wetlands and small ponds.

No surface water bodies are located on or immediately adjacent to the Site. On-Site storm water is controlled by on-Site catch basins, which discharge to an approximately 900-foot long on-Site drainage ditch that runs roughly east to west. This drainage ditch is typically dry during most of the year. The Site is not located within a designated 100- or 500-year floodplain, according to the Federal Emergency Management Administration (FEMA). The nearest surface water body is Sprague Pond, located approximately 1,000 feet south/southeast of the Site.

2.2 Geology

Three major geologic units are present at the Site. These include, in stratigraphic succession from youngest to oldest:

Sand and Gravel - consisting of alternating layers of medium-coarse sand & gravel, medium-fine sand & silt, and fine sand & silt. These can be further subdivided into the following:

Fill: Brown to black, loose, fine to coarse sand, gravel and cobbles, with asphalt, ash, glass, coal, brick and wood.

Native Material Fill: Tan to brown, loose, fine to coarse sand, some gravel, with some crushed cobbles and boulders, little silt.

Native Material: Tan to brown, dense, fine to coarse sand, with varying amounts of gravel, cobbles, some silt, and trace clay.

Glacial Till - consisting of very compact fine sand and silt, and rock fragments.

Bedrock – consisting of granite.

The fill unit is thickest, up to 12 feet below grade, in the center of the Site and thins distance to the east and west. Non-native materials observed in the fill unit included asphalt, ash, scrap metal, concrete, glass, cinders, coal, brick, and wood.

Bedrock was not encountered despite drilling to a maximum depth of 35 feet below ground surface (bgs) and no bedrock outcrops were observed at the Site.

2.3 Hydrogeology

The depth to groundwater at the Site ranges from approximately 11 to 22 feet bgs. The groundwater generally flows outward from the Site in a radial pattern, with the eastern end and northwestern corner of the Site considered downgradient.


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An average horizontal hydraulic gradient of 0.006 feet per foot (ft/ft) was calculated across the Site. The average hydraulic conductivity ranges from approximately 0.291 to 2.04 feet/day. Groundwater velocities across the Site calculated using Darcy’s Law range from approximately 0.007 to 0.049 feet per day, or 2.5 to 17.9 feet per year,

2.4 Sensitive Receptors

The Massachusetts Geographic Information System (MassGIS) Data Layer Map presented in Figure 6, indicates that a medium yield non-potential drinking water source area and designated Area of Critical Environmental Concern (ACEC) is located approximately 500 feet east-southeast of the Site. In addition, a designated open space, Iacono/Readville Playground, is located approximately 500 feet north northeast of the Site. A Zone II is located approximately ½-mile south of the Site.

There are no designated drinking water resources, including Zone As, Interim Wellhead Protection Areas (IWPAs), Sole Source Aquifers or Potential Drinking Water Source Areas, Threatened or Endangered Species Habitats, or Outstanding Resource Waters, within 500 feet of the Site. The nearest surface water body is Sprague Pond, located approximately 1,000 feet south/southeast of the Site.

The closest institution is the Eastwood Care Center nursing home and convalescent home, located approximately 1 mile west-southwest of the Site. The closest residence is located approximately 150 feet north of the Site. In addition, St. Ann’s School (currently closed) is located approximately 500 feet north of the Site.

The Town of Dedham’s municipal water supplier is the Dedham-Westwood Water District, which receives their water supply from 11 artesian wells, six of which are located in Westwood, and five of which are located in Dedham. The City of Boston receives its water supply through the Massachusetts Water Resources Authority (MWRA), from the Quabbin Reservoir located in Belchertown, Massachusetts.

2.5 Nature and Extent of Contamination

Numerous soil, soil stockpile, and groundwater samples were collected from the Site between 1989 and 2012.

In 1989, HMM advanced eight soil borings to a depth of up to 15 feet. Groundwater monitoring wells were installed in seven of the eight soil borings. Groundwater samples were collected from each monitoring well and a total of nine soil composite samples were collected. Samples were analyzed for Volatile Organic Compounds (VOCs), Semi-volatile Organic Compounds (SVOCs), Toxicity Characteristic Leaching Procedure (TCLP) Resource Conservation and Recovery Act (RCRA) 8 metals, and TPH. Petroleum hydrocarbons were detected in the one groundwater sample and several of the composite soil samples. Elevated levels of base-neutral extractable compounds detected in two composite soil samples were attributed to the presence of creosote-railroad ties present at the Site. HMM Associates concluded that a release (or releases), probably in the form of coal tar/creosote or a fuel oil spill had occurred at the Site under investigation, most likely to have occurred over a lengthy period of time.


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In a Draft Phase II Report Comprehensive Site Assessment dated May 29, 1990, HMM reported on the excavation of 42 test pits, the advancement of 57 soil borings, the installation of 9 monitoring wells, and the collection and analysis of soil and groundwater samples. A risk assessment was also completed as part of this report to evaluate the potential risks to human health and the environment. HMM reportedly determined identified PAHs, TPH, and VOCs. This report is not available for review.

On October 4, 2000, Rizzo Associates conducted an evaluation of lead concentrations in surficial soil. Forty-eight grab samples were collected throughout the Site at depths of between 0 and 6 inches bgs and submitted for laboratory analysis. Lead concentrations ranged from 46 to 20,000 mg/kg. A Site-wide 95% upper percentile limit for lead was determined to be 6,275 mg/kg. Additional soil sampling by MassDEP in 2001 confirmed the presence of elevated levels of lead in surficial soils.

In 2002 - 2003, Weston & Sampson collected groundwater samples and over 100 soil samples. The groundwater samples were submitted for laboratory analysis for total dissolved metals and EPH/volatile petroleum hydrocarbons (VPH) with target VOCs/PAHs. No impacts to groundwater were detected. In total, approximately 436 soil samples from the soil and debris piles were screened in the field for lead using the XRF analyzer. Forty of the soil samples (9%) indicated concentrations of lead near or above the UCL for lead. In addition to lead, arsenic, EPH, and PAHs were detected in Site soil. Neither PCBs nor herbicides were detected in the surficial or subsurface soil. Metals, PAHs, PCBs (at concentrations below TSCA thresholds), TPH were detected in the soil stockpiles.

In 2005, LFR oversaw the excavation of 250 test pits at depths ranging 3 feet to 15 feet bgs and the collection of additional soil samples. Over 500 soil samples were collected from the test pits for field screening. LFR concluded that lead, the primary contaminant of concern, was present mostly in the shallow soils and fill layer observed at the Site. Elevated concentrations of arsenic were primarily detected in the immediate vicinity of railroad tracks and chemically-treated railroad ties.

In 2008, AECOM collected soil samples from test pit excavations to evaluate the validity of the LFR data. Samples were screened in the field for lead using an XRF meter calibrated for lead and arsenic and approximately 10% of the samples (a total of 12 samples) were submitted for confirmatory laboratory analysis of total lead, TCLP lead, total arsenic, and EPH with target PAHs.

In 2011 to 2012, following completion of remediation, AECOM collected an additional 186 soil samples for lead field screening and 50 samples for laboratory analysis of lead, 64 samples for analysis of arsenic, 9 samples for EPH with target PAHs, and 3 samples for PCBs. Confirmatory results indicated that detectable concentrations of each these contaminants remain in surficial soil.

Historical soil data were presented in the Phase I, Phase II, Supplemental Phase II/III and Revised Phase IV, and Phase IV Final Inspection and Completion reports. Historical soil data and post-excavation confirmatory soil sample data representing soil quality remaining on the Site following the Phase IV remedial activities and are presented in the Method 3 Risk Characterization for the Site (Appendix D). The laboratory analytical data reports for the Phase IV post-excavation confirmatory soil samples were provided in the Phase IV Final Inspection Report and Completion Statement (AECOM, May 2012).


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These studies indicate that contaminants that may be associated with historical railroad and industrial activities have been detected in Site soil. The predominant OHM detected are metals (lead and arsenic). Other contaminants that were detected infrequently and/or at low concentrations (i.e., EPH, PAHs, VPH or VOCs) are not believed to significantly contribute to the overall extent of contamination at the Site. Groundwater data indicate that Site contaminants have not impacted groundwater. The estimated extent of contamination (Disposal Site Boundary) as shown on Figure 2.

2.6 Identification of Applicable Soil and Groundwater Categories

2.6.1 Groundwater Categories

Three groundwater categories (GW-1, GW-2, and GW-3) are presented in the MCP for use in characterizing risk at disposal sites. Groundwater at all disposal sites is considered a potential source of discharge to surface water and is therefore categorized GW-3 at a minimum. Additional standards may also apply: Category GW-1 applies if the groundwater is located within a Current Drinking Water Source Area or Potential Drinking Water Source Area. The GW-2 classification applies within 30 feet of an existing occupied structure where the average annual depth to groundwater is 15 feet bgs or less. GW-2 standards generally reflect the likelihood of volatile components in the groundwater to enter indoor air.

A review of MassGIS data layer map (Figure 4) indicates that Site groundwater is not within a Current Drinking Water Source Area, or within a Potential Drinking Water Source Area since it is not located within: (1) the Zone A of a Class A Surface Water Body; (2) a Zone II; (3) the IWPA for a public water supply; (4) 500 feet of a private water supply well; (5) 500 feet of a sole source aquifer, (6) 500 feet or more from a public water system; (7) an area designated by the municipality specifically for the protection of groundwater quality to ensure its availability for use as a source of potable water supply. As such, groundwater is not classified as GW-1.

The MCP further states that “groundwater shall be defined to be category GW-2 if it is located within 30 feet of an occupied building or structure and the average annual depth to groundwater in that area is 15 feet or less”. Category GW-2 groundwater is considered to be a potential source of vapors of oil and/or hazardous material to indoor air [310 CMR 40.0932(6)]. Groundwater is not considered to be GW-2 because although the groundwater is located at a depth of less than 15 feet from the ground surface (average depth of water at the Site is approximately 14.63 feet bgs), it is not located within 30 feet of an existing occupied structure and foreseeable Site uses do not include construction of occupied structures.

The MCP also states that “groundwater at all disposal sites shall be considered a potential source of discharge to surface water and shall be classified, at a minimum, as category GW-3” [310 CMR 40.0932(3)]. All groundwater at the Site is, therefore, classified as GW-3.

2.6.2 Soil Categories

Three (3) soil categories are described in the MCP. The categories are applied to soil based on the accessibility of the soil and frequency of site use and intensity of soil contact by adults and children. The MCP provides standards for concentrations of certain oil and hazardous materials in soil for each category. The S-1 standards are the most stringent, and are established in the MCP to be protective of a residential receptor. The S-2 and S-3 are generally less stringent, because the site activities and uses are assumed to result in lower levels of exposure. Because the soil standards also consider the potential for contamination to leach to groundwater, individual soil standards were developed for all potential soil and groundwater category combinations.


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Because the soil standards also consider the potential for contamination to leach to groundwater, individual soil standards were developed for all potential soil and groundwater category combinations.

Impacted soils are located at depths ranging from the ground surface to depths up to approximately 15 feet bgs and/or beneath pavement/concrete. The Site is used by MBTA and Massachusetts commuter rail operators as a storage facility for rail maintenance materials and is not typically occupied. Therefore, the frequency and intensity of use by adults are both considered low. An 8-foot tall chain link fence surrounds the Site to discourage trespassers. However, the Property is not guarded and the potential exists for nearby off-site residents to enter the Site. Due to the presence of the locked 8-foot chain link fence, the fact that the Site is currently used by the MBTA and Massachusetts commuter rail operators as a storage facility for rail maintenance materials and there is currently no evidence of child trespassers, the frequency or intensity of use by children is considered low. Soils between 0 feet and 3 feet at the mostly unpaved Site are considered accessible. Soil at depths of 3 feet to 15 feet bgs in unpaved areas, and up to 15 feet bgs and under pavement, is considered potentially accessible, while soil at depths in excess of 15 feet bgs is considered isolated. Therefore for current use, the applicable soil category for the Site is S-2 for soils between 0 feet and 3 feet and S-3 for soils at depths of 3 feet to 15 feet bgs in unpaved areas.


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3.0 Data Usability Assessment and Representativeness Evaluation

In accordance with the MCP Section 40.1056(2)(k) and MassDEP Policy #WSC-07-350 “MCP Representativeness Evaluations and Data Usability Assessment”, for all Class A, B, or C RAOs, a Data Usability Assessment must be performed to document that the data relied upon is scientifically valid and defensible, and of a sufficient level of precision, accuracy, and completeness to support the RAO, and a Representativeness Evaluation must be performed to document the adequacy of the spatial and temporal data sets used to support the RAO. AECOM’s Supplemental Phase II report included a Data Usability Assessment and Representativeness Evaluation for all data generated as part of the Supplemental Phase II investigation. A Data Usability Assessment and Representativeness Evaluation for the data obtained previously by Weston & Sampson as part of the Phase II and by LFR as part of the Phase IV were included in those respective reports. Therefore, all of these historical data were not included as part of the data usability evaluation within this RAO report.

AECOM prepared a Data Usability Assessment and Representativeness Evaluation for all post-excavation soil data collected during the 2011 and 2012 Phase IV activities used in support of this RAO. The laboratory analytical data reports were provided in the Phase IV Final Inspection Report and Phase IV Completion Statement (AECOM, May 2012). A Data Usability Assessment has an analytical and a field component. An analytical Data Usability Assessment is used to evaluate whether analytical data points are scientifically valid and defensible, and of a sufficient level of precision, accuracy, and sensitivity to be used in a Representativeness Evaluation. The analytical Data Usability Assessment evaluates whether the analysis of samples has yielded a valid result.

The field component of the Data Usability Assessment evaluates whether the sampling procedure (e.g., sampling method, sample preservation and hold times) ensures that the sample that is collected and delivered to the laboratory is representative of the sampling point.

Sections 3.1 describe elements of a Data Usability Assessment conducted in support of this RAO. Section 3.2 describes the Representativeness Evaluation.

3.1 Analytical Data Usability Assessment

3.1.1 Comparability Evaluation for CAM Non-Compliant, Non-CAM and Pre-CAM

MassDEP Compendium of Analytical Methods (CAM) Compliant data (data with “Presumptive Certainty”) are data of known accuracy, precision and sensitivity. As such, the accuracy, precision and sensitivity of CAM Compliant data do not require additional evaluation in an Analytical Data Usability Assessment. Other types of analytical data (CAM Non-Compliant, Non-CAM, and Pre-CAM), however, require evaluation to identify what information is available to assess the accuracy, precision, and sensitivity of these data points, and the comparability of these data to CAM Compliant data.


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A data usability evaluation was performed on all post-excavation soil data collected during the Phase IV activities that are being used in support of this RAO. The data usability evaluation was performed following the guidance of MassDEP document WSC-CAM-VII A, Quality Assurance and Quality Control Guidelines for the Acquisition and Reporting of Analytical Data in Support of Response Actions Conducted Under the Massachusetts Contingency Plan (MCP), Revision 1, July 1, 2010, MassDEP Bureau of Waste Site Cleanup; MassDEP MCP Representativeness Evaluations and Data Usability Assessments; Policy #WSC-07-350; September 19, 2007; and the applicable analytical methods.

The data usability evaluation packages for each laboratory analytical report are provided in Appendix E. These evaluations indicated that all data have met Presumptive Certainty requirements for all CAM parameters. Although certain quality control (QC) performance standards which affect precision and accuracy of the data were not achieved for all samples, any of these minor deviations did not affect the usability of the data.

3.1.2 Field Quality Control Data Usability Assessment

Use of appropriate sampling methods is a critical component of ensuring sample integrity. In addition, how samples are manipulated in the field (e.g., split samples, compositing, etc.), as well as the use of proper sampling containers and preservatives, are essential to minimizing any potential loss of contaminants of concern prior to laboratory analysis and ensuring that the sample delivered to the laboratory for analysis is representative of field conditions.

As part of the post-excavation confirmatory sampling program, soil samples were screened in the field to define the limits of excavation for lead impacted soil. Approximately 10% of the post-excavation confirmatory soil samples were also submitted for laboratory analysis of total lead (along with other analyses). As discussed in Section 2.3.1.2 of the Supplemental Phase II/III and Revised Phase IV RIP report, the XRF and laboratory results were in good agreement, providing a coefficient of determination (R2) of 0.87. Therefore, the XRF was also used to evaluate post-excavation soil quality following the Phase IV remedial activities. The lead XRF screening results and the laboratory analytical results from the post-excavation confirmatory soil samples are summarized in Table E-1 in Appendix E. As discussed in the Method 3 Risk Characterization supporting this RAO, the higher of the soil lead concentrations obtained by XRF and laboratory analysis was conservatively used to represent the soil lead concentration for that particular sample.

Based on AECOM’s review, all field quality controls utilized were considered adequate.

3.1.3 Data Quality Objectives

All data should be evaluated against its stated Data Quality Objectives (DQO) to determine whether it is usable for its intended purpose. Data meeting project-specific response action DQO will be considered usable for a Representativeness Evaluation. Data not meeting the project-specific response action DQO may not be used in the Representativeness Evaluation without additional supporting data.

The DQO for the samples collected during this investigation was to determine if soil and groundwater quality met the criteria used in the Method 3 Risk Characterization. All DQO were met.


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3.2 Representativeness Evaluation

The Representativeness Evaluation is an evaluation and demonstration of the adequacy of the spatial and temporal data sets used to support the particular response action decision. Spatial data includes historical use, hydrogeologic and physical characteristics in addition to analytical data. Whereas the Data Usability Assessment determines the validity of an analytical data point as representative of the specific sampling point in the field and identifies any qualifications on the use of such data, the Representativeness Evaluation determines whether the data set in total (the analytical data, in combination with the Conceptual Site Model, hydrogeologic and physical data, and field observations) sufficiently characterizes conditions at the disposal site. The Representativeness Evaluation determines whether there is enough quality information from the right locations, both spatially and temporally, to support the RAO. Documentation of the Representativeness Evaluation is required as part of this RAO submittal. This section summarizes the Representativeness Evaluation conducted in support of this RAO pursuant to 310 CMR 40.1056(2)(k).

The Representativeness Evaluation should demonstrate the acceptability of the sampling program design and execution, and the adequacy of resultant usable data to characterize the nature and extent of contamination at the Disposal Site, risk to health, safety, public welfare and the environment (i.e., the achievement of No Significant Risk or No Substantial Hazard) and the elimination/control of OHM sources.

The Representativeness Evaluation should identify inconsistent and incomplete information, and sources of uncertainty, and explain why any such inconsistent information, data gaps, or uncertainty are not sufficient to undermine the RAO Opinion (i.e., justify the use of the data to support the RAO).

3.2.1 Conceptual Site Model

A Conceptual Site Model (CSM) is a description of what and how contaminants entered the environment, how they were transported within the system, and routes of exposure to human and environmental receptors. It provides a framework for assessing risks from contaminants, controlling or eliminating sources, developing response action strategies, and determining whether those strategies have been effective in achieving the RAO requirements. The CSM is a dynamic, site-specific model that is continually modified to incorporate new information. The complexity of a CSM is directly related to the complexity of disposal site conditions.

A CSM for the Site was presented in Section 2.3.1.1 of the Supplemental Phase II/III and Revised Phase IV RIP. Historical data indicates Site soil has been impacted by lead, arsenic, and petroleum hydrocarbons. In addition, PCBs are present in some soil stockpiles. Contaminants were primarily detected in shallow soil and the soil stockpiles. Groundwater does not appear to be impacted. The Phase II and Supplemental Phase II assessed the extent of surficial contamination, potential impact to deeper subsurface soils, soil stockpiles, and deeper overburden groundwater, and evaluated Site background concentrations. The Phase II/Supplemental Phase II investigations indicated the presence of metals (predominantly lead and arsenic), EPH, and target PAHs. The concentrations of OHM in soil were generally highest within the shallow urban fill material identified as brown to black coarse sand, asphalt, glass, coal, brick, and wood. The concentrations of OHM decreased significantly with depth and were generally not observed within the deeper unit identified as native material consisting of dense sand with varying amounts of gravel, cobbles, silt, and clay. With the exception of two samples collected after removal of Stockpile 4 and Stockpile 20, no PCBs (or herbicides) were detected in the surficial or subsurface soil at the Site. The concentrations of OHM detected in groundwater were at or near analytical method detection limits and were well below the applicable MCP Method 1 GW-3 standards.


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The Site is roughly an elongated teardrop shape, defined by a loop railroad track enclosed by an 8-foot tall chain link fence. The Property extends beyond the railroad track fencing. The Site is mostly unpaved, with the exception of a driveway approximately 100 feet wide and 1,700 feet long running east-west along the northern side of the Site. Materials used for railroad maintenance (ties, track panels, etc.) are stored at various locations throughout the Site. Historical site building remnants are present. A drainage ditch, bounded to the north and south by catch basins, is located along the approximate Site centerline.

The Site is abutted by residential properties to the north, east, and west, and by industrial properties to the south. Residential and commercial properties abut the Site to the west on Ashcroft Street and to the north opposite the former Dedham Secondary rail line (a.k.a. the “Orphan Line”) on Milton/W. Milton Street. Commercial and industrial properties, including a school bus garage and storage yard and a gravel crushing operation, are located to the south, opposite Industrial Drive. The MBTA Readville commuter rail station, including commuter parking lots and the MBTA 2-Yard facility, is located to the east.

No surface water bodies are located near the Site. The nearest surface water body is Sprague Pond, located approximately 1,000 feet south/southeast of the Site.

Based on observations made during advancement of soil borings, three general geologic units comprise overburden at the Site. An urban fill unit was encountered at depths up to 12 feet below grade, and with an average thickness of approximately 6 feet on the eastern portion of the Site, approximately 7 feet in the central portion of the Site, and approximately 5 feet on the western portion of the Site. Non-native materials observed in the urban fill unit included: asphalt, ash, metal, glass, coal, brick, and wood. A native material fill unit was observed consisting of reworked loose sand, gravel, and cobbles. The native fill unit ranged in thickness from ground surface to a maximum depth of 16 feet in the north-central portion of the Site. The native fill material was observed most often in the western-most and northern areas of the Site and the centrally located Staging Area. The average thickness of this unit was approximately 5 feet on the western portion, 11 feet on the central portion, and 3 feet on the eastern portion. Native material consisting of dense sand, gravel, cobbles and some silt were observed in all soil borings, at depths ranging from ground surface to a depth of 35 feet, the maximum depth explored. Bedrock was not encountered during drilling and no bedrock outcrops were observed at the Site.

The depth to water at the Site ranges from approximately 11 to 22 feet below grade. The groundwater at the Site generally flows outward from the Site in a radial pattern, with the eastern end and northwestern corner of the Site considered downgradient. A seepage velocity ranging from approximately 0.29 feet/day (106 feet/year) to 2.04 feet/day (745 feet/year) was calculated during the Phase II investigation.

3.2.2 Data Quality Objectives and Data Collection Approach

Please refer to the Phase IV Completion Report for information regarding the post-remediation soil sampling, and Section 3.1 of this report for the DQO established for the soil remediation program at the Site. The main DQO for the site investigation and for the post-excavation soil sampling program was to obtain data that satisfies the regulatory requirements of the MCP and supports site closure.


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3.2.3 Use of Field/Screening Data

An XRF was used to assist with directing the extent of excavation required in areas with lead impacted soil. As discussed in the Supplemental Phase II/III and Revised Phase IV RIP, comparison of the XRF lead detections to the corresponding laboratory results indicates that, in general, the XRF readings were slightly higher than the laboratory results. The soil lead XRF and laboratory results were in good agreement. Over 25% of the post-excavation confirmatory soil samples were also submitted for laboratory analysis of total lead. In general, a correlation between the laboratory results and field screening results was evident.

3.2.4 Selection of Sampling Locations, Depths, Distribution, and Number of Sampling

Locations

Post-excavation soil sampling locations and depths were selected to determine remaining concentrations at the Site following remediation activities, determine exposure point concentrations, and rule out exposure pathways. Confirmatory soil sampling was conducted to ensure that an appropriate volume of soil had been removed to meet the risk-based goals of for each of these areas.

Stockpiles - After removal of stockpiles, confirmatory samples were collected from the bottom surface remaining at an interval not to exceed 50 ft. Soil confirmatory samples collected from below all stockpiles were screened using the XRF for lead content and used to determine the depth of the excavation. At least 25% of the samples were submitted for laboratory analysis of lead.

Hot Spots – After excavation of soil containing the lead hot spots to appropriate depths at SS01 and SS22, a composite soil sample was collected from the sidewalls and excavation bottom at a linear distance not to exceed 50 ft, and submitted for lead analysis. Similarly, composite soil samples were collected from the sidewalls and excavation bottom for the EPH hot spot (HB/GP-24) and submitted for EPH analysis.

Grid Cells – Grid cells that exceed the commercial/industrial RBCs for arsenic were located in Area 2. After excavation, confirmatory samples were collected from sidewalls and cell bottoms, at an interval not to exceed 50 ft, and submitted for laboratory analysis of arsenic to ensure that they met commercial/industrial RBCs.

All samples were collected in accordance with the DQO stated herein.

3.2.5 Completeness

There are no remaining data gaps at the Disposal Site. The samples collected to date have characterized the nature and extent of impacts, and define current site conditions.

3.2.6 Uncertainty and Inconsistency

There were no inconsistencies or uncertainties regarding historical use information that is inconsistent with contaminants detected or not detected in the Disposal Site. In general, a correlation between the laboratory results and field screening results and observations was evident.

Based on the above considerations, the data collected is considered representative of Site conditions.


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4.0 Method 3 Risk Characterization

4.1 Previous Phase II/III Method 3 Risk Characterizations

4.1.1 Weston & Sampson Risk Characterization

As part of the Phase II report, Weston & Sampson prepared a Method 3 RC in general accordance with 310 CMR 40.0000 of the MCP, to evaluate the potential risk to human health, safety, public welfare, and the environment posed by contaminants detected at the Site. The analytical data used in the Phase II RC included the results of the 2002 Phase II investigation and IH evaluations by the MassDEP in 2002 and Rizzo in 2000. The Phase II RC for this Site focused primarily on human health posed by contaminants in soil only. Based on the findings of the Phase II, contaminants were not considered to be present in groundwater and/or air at significant concentrations, and surface water and/or sediment are not present at the Site. Consequently, groundwater, air, surface water and sediment were not considered as potential exposure media in the Phase II risk assessment. The details of the RC were presented in Appendix J of the Phase II report (see Weston & Sampson, January 2003).

The objective of the Phase II risk assessment was two-fold: 1) to develop Site-wide RBCs for various current and potential future activities and receptors; and, 2) to evaluate whether existing Site conditions pose a condition of No Significant Risk for existing and proposed uses. The following four general categories of human-health receptors were evaluated for the Phase II RC to cover a wide range of potential Site uses and development options:

General Use Category Potential Activities and Use

Recreational Use Park, playground

Construction/Utility Worker Site development, utility repairs

Commercial/Industrial Worker Indoor and outdoor work activities

Residential Use Single-family homes with gardens

The Phase II Method 3 RC involved comparison of EPCs in Areas 1 through 4 to the RBCs developed for the four general Site uses (recreational, construction, commercial/industrial, and residential). The EPCs for each of the COCS identified within each Area were then compared to the RBCs developed for each of the four general use scenarios/receptors. EPCs less than a derived RBC signified an “acceptable use”; conversely, EPCs greater than a derived RBC signified a use that “was not acceptable”. Based on the results of this comparison, Weston & Sampson created four separate matrix tables summarizing “acceptable” Site uses by area based on combinations of various remedial/response actions. All of the remedial/response actions assume removal of the two hot spot areas (one in Area 3 and one in Area 4) under future acceptable use scenarios. The various remedial/response actions included: 1) no remediation and existing soil conditions; 2) remediation of surface soil (0 to 6 inches) only (assumes removal of the two hot spot areas in Areas 3 and 4); 3) remediation of subsurface soil (0 to 3 feet) only (assumes removal of the two hot spot areas in Areas 3 and 4); and, 4) no remediation with implementation of engineering (i.e., capping) and institutional


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controls (i.e., an AUL) on the Property (assumes removal of the two hot spot areas in Areas 3 and 4). Each of these scenarios required removal of hot spots (Area SS01 in Area 4 and SS22 in Area 3).

The results of the Phase II RC indicated that further response actions to eliminate exposure to surface (0 to 6 inches) and subsurface (0 to 3 feet) soils would be required to achieve a condition of No Significant Risk in all Areas under existing Site conditions for all potential Site uses except for the construction scenario. Acceptable use of the Site can be achieved under all receptor scenarios (recreational, commercial/industrial, construction, and residential) with hot spot removal, implementation of engineering controls (i.e., cap), and an AUL. On-site reuse of soil from the stockpiles was considered in the risk assessment. Based on the concentrations of contaminants detected and the type of contaminants detected, the Phase II RC concluded that the soil from the stockpiles may be suitable for reuse in the EZ.

As discussed previously, the MBTA responded to the MassDEP’s comments concerning the Final Phase II Report in the form of a Phase II Addendum. The Phase II Addendum was attached as Appendix F to the Final Phase III Report submitted to the MassDEP on April 30, 2003. Based on the Phase II Addendum, the Phase II risk assessment results did not change.

The MBTA also responded to the MassDEP’s comments concerning the Final Phase II Report in an October 28, 2003 report entitled “Response to DEP’s September 17, 2003 Meeting Comments”. This letter prepared by Weston & Sampson formalized the comments provided by the MassDEP in the September 17, 2003 meeting and provided additional clarification on certain items contained in the Phase II and Phase III reports. The MassDEP then responded to this October 28, 2003 letter in their Memorandum dated November 20, 2003. In general, the MassDEP indicated that, with respect to the Phase II risk assessment, the majority of issues had been resolved with the exception that additional soil sampling data from areas of the Site and the stockpiles should be included in the risk characterization or an argument should be made that the newer data does not affect the results of the risk characterization, remedial plan, or selected remedial actions.

4.1.2 LFR Updated RBCs

As part of the Phase IV RIP prepared by LFR, additional soil sampling was performed in anticipation of proposed residential use of the western portion of the Site. In addition to the soil investigation, LFR retained Gradient Corporation to review and update the RBCs for the Site using “updated exposure parameters and toxicity values”.

4.1.3 AECOM Revised Risk Characterization

As requested by the MassDEP in their letter to the MBTA dated December 4, 2007, AECOM prepared an updated risk assessment in order to incorporate additional site data collected by LFR during the Phase IV RIP and by AECOM during the Supplemental Phase II investigation, and also to evaluate the site risks based on changes in toxicity information for the COCs.

The Revised Method 3 RC was included in the Supplemental Phase II/III and Revised Phase IV Report and was completed in accordance with procedures and standards for the characterization of the risk of harm to health, safety, public welfare and the environment as presented in Subpart I, Section 310 CMR 40.0900 of the MCP, and is intended to meet the Response Action Performance Standard (RAPS) specified in Section 310 CMR 40.0191. The Revised Method 3 RC report presented an evaluation of current Site conditions. Potential risks were evaluated under current land use and reasonably foreseeable future land use conditions in the absence of further remediation. As required by the MCP, use of the Site for residential purposes with unrestricted access to impacted


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media was also considered in the Revised Method 3 RC to evaluate whether one or more AULs would be required to achieve a condition of No Significant Risk.

The risk assessment focused on the risk posed by soil since, based on the findings of the Phase II investigation, contaminants were not detected at significant concentrations in groundwater. In addition, depth to groundwater across the Site is approximately 15 feet bgs, which is deeper than typical excavation depths. Surface water and sediment are not present at the Site. As with the Phase II RC, for risk assessment purposes, the Site was divided into four areas based on historical use, types and concentrations of contaminants. The areas include: Area 1 - Orphan Line; Area 2 - Ashcroft Street Fence line; Area 3 - Main Rail Yard; and Area 4 - EZ. The stockpiles located in the EZ were evaluated separately for possible on-site re-use.

Based on the current and potential future site uses, potential human receptors and routes of exposure evaluated included:

Direct contact (incidental ingestion and dermal absorption) with soils by on-site workers and contractors (adults).

Utility workers and future construction workers conducting potential subsurface excavation activities (adults) via direct contact with soils and the inhalation of re-suspended soils.

Direct contact with soils by site trespassers, including nearby off-site residents and patrons of the nearby commercial establishments (teenagers).

Direct contact with soils by future recreational users, if the Property is developed for use as a park or playground (adults, teenagers and children).

Direct contact with soils and consumption of homegrown fruits and vegetables by future site residents, if the Property is developed for residential use (adults, teenagers and children).

Inhalation of re-suspended soil (fugitive dust generated from site soil) by nearby off-site residents.

The Revised Method 3 RC concluded the following:

None of the Site conditions meet the IH criteria as defined in 310 CMR 40.0321. Therefore, no IH exists at the Site.

The source of the release at the Site is considered to be historical use of the Site as a rail yard.

Two lead hot spots were identified in each of Area 3 and Area 4. The Exposure Point Concentrations (EPCs) in these lead hot spots resulted in noncancer risks above the MassDEP acceptable risk level for one or more of the five scenarios evaluated. As such, a condition of No Significant Risk of harm to human health does not exist in these hot spots.

Evaluation of the soil EPCs in Area 1, Area 2, Area 3, and Area 4 indicated health risks above the MassDEP acceptable risk levels for future recreational and future residential scenarios.. As such, a condition of No Significant Risk of harm to human health does not exist at the Site.

The Revised Method 3 RC indicated a condition of No Significant Risk of harm to safety exists for the Site.


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The EPC for soil lead in hot spots exceeds the UCL. Therefore, by definition of UCLs in the MCP, a level of No Significant Risk to public welfare and the environment cannot be achieved for the Site. Further comprehensive response actions will likely be required to eliminate the UCL exceedances.

AECOM developed Commercial/Industrial Worker, Residential, Trespasser, Construction Worker and Recreational RBCs for all COCs in each separate exposure point at the Site (Area 1, Area 2, etc.) using a cumulative risk approach. RBCs were developed such that the total noncancer Hazard Index (HI) and/or Excess Lifetime Cancer risk (ELCR) for an exposure point did not exceed the MassDEP risk levels of a HI of 1 and ELCR of 1 x 10-5, with consideration for all COCs. RBCs were only calculated when cumulative site risks at an exposure point presented a HI >1 and/or ELCR >1 x 10-5. In this case, an RBC was established for all COCs that had a noncancer Hazard Quotient (HQ) and/or ELCR exceeding the Target Risk Levels of 0.2 and 1 x 10-6, respectively, as defined in 310 CMR 40.0984(2) and 310 CMR 40.0984(3) for the development of Method 2 standards. This approach insured that the total cumulative risk for all COCs at each exposure point did not exceed the MassDEP’s No Significant Risk levels of a HI of 1 and an ELCR of 1 x 10-5. COCs with cumulative risks less than a HI of 0.2 and/or an ELCR less than 1 x 10-6 were assumed to contribute negligibly to total Site risk.

Comprehensive response actions were deemed necessary at the Site to achieve a level of No Significant Risk and to address remaining impacts. Therefore, a Supplemental Phase III RAP (and Revised Phase IV RIP) was also submitted to the MassDEP.

4.2 Post-Remediation Method 3 Risk Characterization – Class A RAO

As discussed above, a Supplemental Phase II Method 3 baseline RC for the Site was prepared by AECOM (AECOM, 2010) on behalf of the MBTA. Based on the results of the baseline Method 3 RC, it was concluded that the Site should be remediated to eliminate the potential risk that could result from direct contact with soils and fill containing arsenic, lead, antimony, barium, chromium, cobalt, copper, nickel, zinc, EPH parameters, and select PAHs.

AECOM performed MCP assessments of potential risks to human health, safety, public welfare, and the environment to determine whether exposure to environmental media located at the Site may pose a potential for significant risk to human health, safety, public welfare, and the environment as defined by the MCP, 310 CMR 40.0000. Potential risks were evaluated under current land use and reasonably foreseeable future land use conditions in the absence of further remediation.

The risk assessment performed by AECOM to support this RAO, provided as Appendix D of this RAO, was performed using a Method 3 approach (Site-specific risk assessment), as allowed by the MCP. It provides an update to and supersedes the 2010 Method 3 risk assessment and evaluates post-remedial Site conditions. The results of this Method 3 risk assessment were used to confirm that further remediation is not required and to support the development of a RAO statement for the Site.

For the purposes of the risk characterization and previous investigation/evaluations, the 42-acre Site was divided into four separate potential exposure areas (Areas 1 through 4) based primarily on historical use, types and concentrations of contaminants, and existing zoning and access. The four areas assessed in this Method 3 risk characterization included:


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Area 2 – Western Fence Line (adjacent to Ashcroft Street): Area 2 is a narrow strip of land located along the southwestern Site boundary between the EZ and a wooded area followed by residential properties on Ashcroft Street.

Area 3 - Main Rail Yard: The Main Rail Yard is the largest area evaluated for this Site. Comprising approximately 21 acres, the area contains both active and inactive tracks. The Main Rail Yard is currently used by MBTA and Massachusetts commuter rail operators for storage of railroad materials (ties, track panels, etc.), and has a long history of use as a former railroad maintenance and storage yard. One large building was formerly located within the Main Rail Yard, and the foundation of this structure still exists in some areas.

Area 4 - Exclusion Zone: This Area is located west of the Main Rail Yard and occupies most of the western portion of the Site. Reportedly, Area 4 has been used for railroad associated materials and a historical burn pit, and has soil piles. Soil and debris stockpiles are present in this area and evaluated as a separate exposure point in the risk assessment.

Potential human receptors evaluated in this Method 3 risk characterization included:

Current/future on-Site commercial/industrial workers (adults and teenagers) exposed via incidental ingestion and dermal exposure to contaminated soil.

Future workers conducting potential future subsurface construction activities (adults and teenagers) exposed via incidental ingestion and dermal exposure to contaminated soil, and inhalation of re-suspended soil.

Current/future Site trespassers, including nearby residents (adults and teenagers) exposed via incidental ingestion and dermal exposure to contaminated soil.

Based on the Method 3 RC evaluations, and with the incorporation of an AUL to prohibit future residential use of the Site or use of the Site as a park/playground and/or daycare, and that precludes excavation of soil without meeting certain precautions, the environmental conditions at the Site indicate that:

A condition of No Significant Risk of harm to human health exists at the Site for current and foreseeable future Site conditions.

A condition of No Significant Risk to safety exists at the Site.

A condition of No Significant Risk to public welfare exists at the Site.

A condition of No Significant Risk to the environment exists at the Site for current and foreseeable future Site conditions.

Accordingly, further comprehensive response actions are not required at the Site in accordance to 310 CMR 40.0800.


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5.0 Response Action Outcome Statement

5.1 Class of RAO

The RAO was prepared to address RTN 3-2856 located on Industrial Drive in Dedham and Readville, Massachusetts. The RAO is being submitted for the Disposal Site area identified in Figure 2. The RAO for the Site was prepared in accordance with 310 CMR 40.1003, which describes the following condition:

(5) A Class A or Class B Response Action Outcome shall not be achieved unless and until each source of oil and/or hazardous material which is resulting or is likely to result in an increase in concentrations of oil and/or hazardous material in an environmental medium, either as a consequence of a direct discharge or through intermedia transfer of oil and/or hazardous material is eliminated or controlled.

RAOs are categorized under 310 CMR 40.1030 through 40.1050 as A, B, or C. A Class A RAO is applicable to the Site because the conditions described in 310 CMR 40.1035 and presented below have been met or are applicable to the Site.

(1) Class A Response Action Outcomes shall apply to sites or disposal sites where a Permanent Solution has been achieved.

(2) A Class A response action shall apply where response actions have been conducted to: (a) achieve a level of No Significant Risk, as specified in 310 CMR 40.0900; (b) eliminate or control any source of oil and/or hazardous material, as specified in 310 CMR

40.1003(5); and (c) where feasible, reduce to the extent possible the level of oil and/or hazardous material

concentrations in the environment to background.

Class A RAOs are subdivided into Class A-1, A-2, A-3 and A-4. As provided by 310 CMR 40.1036(3), Class A-3 Response Action Outcomes shall apply to disposal sites where:

“A Permanent Solution has been achieved; the level of oil and/or hazardous material has not been reduced to background; one or more Activity and Use Limitations are required to maintain a level of No Significant Risk; and oil or hazardous material at the site do not exceed Upper Concentration Limits in soil or groundwater.”

The RAO statement detailed below was prepared to provide the content described in 310 CMR 40.1056. A MCP Method 3 Risk Characterization was utilized, which demonstrated that conditions at the Site have resulted in a level of No Significant Risk of harm to health, safety, public welfare, and the environment at the Site. An AUL is required to ensure the maintenance of a condition of No Significant Risk. As such, this finding supports a Class A-3 RAO.

5.2 Boundaries of Disposal Site

The limits of the disposal site are shown in Figure 3.


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5.3 Elimination of Uncontrolled Sources

As required under 310 CMR 40.1056(2)(b), it has been demonstrated "that all uncontrolled sources as specified in 310 CMR 40.1003(5) have been eliminated or controlled". As described in Section 1.5, all uncontrolled sources of contamination were eliminated with the excavation, on-site treatment (as necessary), and off-site disposal of approximately 18,500 tons of impacted soil.

5.4 Upper Concentration Limits

As discussed in the Method 3 Risk Characterization in Appendix D of this Class A-3 RAO Statement, EPCs do not exceed UCLs. Levels of OHM detected in soil at the Site are not considered to be a continuing source of groundwater contamination. No evidence of non-aqueous phase liquid (NAPL) or other such uncontrolled sources is currently found on the Site.

5.5 Post RAO Operation, Maintenance & Monitoring

No operation, maintenance, and/or monitoring will be required to confirm and/or maintain the conditions at the Site for which this Class A-3 RAO Statement is based. No known additional response actions are needed for any portion of the Site.

5.6 Feasibility of Restoration to Background

In accordance with 310 CMR 40.0860, an evaluation of the feasibility of reducing concentrations of OHM to levels that achieve or approach background was undertaken. The MassDEP’s final policy entitled “Conducting Feasibility Evaluations Under the MCP; Policy # WSC-04-160” dated July 16, 2004 (the Feasibility Evaluation Policy) was used to evaluate the feasibility of remediating the remaining contaminated soil to background conditions.

According to the MassDEP’s Feasibility Evaluation Policy, remedial actions are considered “categorically feasible” to achieve or approach background conditions at sites where small quantities of petroleum contaminated soil remain. Specifically, these include sites where a condition of No Significant Risk has been achieved, the remaining petroleum contaminated soil is less than or equal to 20 cubic yards and where the soil:

Is located less than three feet below the ground surface; Is not covered by pavement or a permanent structure Is not located within a sensitive environment (e.g. wetlands); and Is not located in an area where removal activities will substantially interrupt public service or

threaten public safety.

The residual petroleum contamination at the Site is greater than 20 cubic yards and is located at greater than three feet below a paved surface at the Site. As such, it can be concluded that it is not “categorically feasible” to remediate the residual petroleum contamination at the Site.

According to the MassDEP’s Feasibility Evaluation Policy, remedial actions are considered “categorically infeasible” at a site when the cost of the remedial actions outweighs the benefits. The MassDEP defines four situations where it is “categorically infeasible” to achieve or approach background conditions:

Excavations under permanent structures such as building foundations or other structures where the integrity of the structure would be compromised;


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Remedial actions that will substantially interrupt public service or threaten public safety such as interruption of utilities to large numbers of customers or public service providers, interruption of critical services (e.g., police, fire, hospitals, etc.), interruption to public roadways/rail traffic, or excavation activities in areas that would pose a likely safety risk;

Remediation of degradable (nonpersistent) contaminants (listed in Table 9-1 of the Feasibility Evaluation Policy), which are compounds known to readily degrade over time; or

Remediation of persistent contaminants (listed in Table 9-2 of the Feasibility Evaluation Policy) located in S-2 and S-3 soils, which have a low potential for exposure.

If any one of the above conditions are met, the MassDEP’s Feasibility Evaluation Policy considers this sufficient to support a conclusion that achieving or approaching background is not feasible.

As stated above, it is MassDEP’s position that achieving or approaching background can be deemed infeasible for degradable/nonpersistent contaminants regardless of media classification, except for small quantities of petroleum-contaminated soil considered accessible for remediation as described previously. The benefits of additional remedial actions to achieve or approach background for degradable/nonpersistent contaminants would be considered insufficient to justify the costs of those actions. This is discussed further below.

In addition, it is the MassDEP’s position that achieving or approaching background can be deemed infeasible for persistent contaminants in soil located in areas with lower exposure potential (i.e., S-2 and S-3 soil categories). Table 9-2 of the Feasibility Evaluation Policy indicate that metals e.g., arsenic and lead), PAHs (e.g., benzo(a)pyrene and benzo(g,h,i)perylene), PCBs, MTBE and chloroform are considered persistent contaminants.

Concentrations of metals persistent COCs exceed typical background concentrations at the Site. However, based on the Method 3 RC, the remaining concentrations pose No Significant Risk of harm to human health, safety, public welfare or the environment, subject to the AUL included as Appendix C. Furthermore, it is AECOM’s opinion that the incremental costs associated with achieving or approaching background conditions is substantial and disproportionate to the incremental benefit of risk reduction, and monetary and non-pecuniary values. Specifically, the cost to excavate and dispose of the residual impacted soil is estimated to be greater than 20% of the remediation costs incurred to achieve a level of No Significant Risk. Therefore, consistent with Section 9.3.3.4 of Conducting Feasibility Evaluations Under the MCP (July 2004), achieving background conditions for soil impacts at the disposal site would be considered infeasible.

The majority of groundwater impacts are either at or approaching background. The concentrations of C5-C8 aliphatics, lead, and zinc in groundwater at the disposal site exceed typical background concentrations. However, none of the detected concentrations exceed applicable Method 1 standards and based on the Method 3 risk characterization, the concentrations pose No Significant Risk of harm to human health, safety, public welfare or the environment. Based on these considerations, it is AECOM’s opinion that the incremental costs associated with achieving or approaching background conditions is substantial and disproportionate to the incremental benefit of risk reduction, and monetary and non-pecuniary values. Specifically, the cost to remediate the lead and zinc concentrations in groundwater is estimated to be greater than 20% of the remediation costs incurred to achieve a level of No Significant Risk. Therefore, consistent with Section 9.3.3.4 of Conducting Feasibility Evaluations Under the MCP (July 2004), achieving background conditions for groundwater impacts at the disposal site would be considered infeasible.


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5.7 Activity and Use Limitation

The Site is currently vacant and is used by the MBTA and Massachusetts commuter rail operators for the storage of railroad-related construction materials. It is likely these uses will continue in the foreseeable future, and activities similar to those currently conducted at the Property can be reasonably expected to continue. The MBTA has identified the end use of the Site as commercial/industrial, as discussed at a meeting with the MassDEP in August 2003. It is anticipated that the western portion of the Property will be used as a solar farm. The reasonably foreseeable activities and uses could include underground utility construction and repair, and construction activities that disturb subsurface soils. An AUL is required to limit Site activities and uses or the disturbance of the impacted soil to prevent exposures to potential receptors in order to maintain a condition of No Significant Risk because of a potential risk to future construction workers and future on-Site residents.

The following permitted uses will continue:

Public transit-related and/or industrial/commercial activities (including construction and operation of a solar array) and uses of the Property including, but not limited to: pedestrian and vehicular traffic, or vehicular parking, which do not cause and/or result in direct contact with disturbance of, and/or relocation of impacted soil;

Emergency repairs to underground utilities;

Subsurface activities and excavation work associated with construction which is likely to disturb soil, provided it is conducted in accordance with a Soil Management Plan and Health and Safety Plan; and

Such other activities or uses which, in the Opinion of an LSP, shall present no greater risk of harm to health, safety, public welfare or the environment than the activities and uses set forth in this Paragraph; and

Such other activities or uses not identified as being a restricted use or activity.

However, the following potential Site uses are prohibited:

Use of the Site as a residence, school (with the exception of adult education), nursery, daycare, and/or other activities or uses where a child’s frequent presence is likely;

Any activities and/or uses which are likely to cause or result in direct contact with, disturbance of, and/or relocation of, the soil without prior development and implementation of a Soil Management Plan and a Health and Safety Plan in accordance with Obligations and Conditions of the AUL Opinion;

The growing of produce for consumption;

Subdivision of the Property without a re-evaluation of risk to human health, safety, public welfare, or the environment.

No record interest holders were identified within the limits of the MBTA property. In accordance with 310 CMR 40.1403(7), copies of the AULs have been provided to municipal officials (Chief Municipal Officer, Board of Health, Zoning Official and Building Code Enforcement Official). Notification letters to municipal officials accompanying the distribution of the AUL are included in Appendix B. In addition, a copy of the legal notices of the recording of the Notice of AUL in accordance with 310 CMR 40.1403(7) is included in Appendix C.


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5.8 Public Involvement Activities

In accordance with 310 CMR 40.1403(3)(f), the Mayor of Boston, Town Manager of the Town of Dedham, Executive Director of the Boston Public Health Commission, and Health Director of the Dedham Board of Health are being notified in writing of the availability of the RAO. A copy of the written notice to these local officials is contained in Appendix B, as required in 310 CMR 40.1403(4)(b).

In accordance with Public Involvement Activities in Response Actions (310 CMR 10.1403) outlined in the MCP and described in the PIP prepared for the Site (dated April 2002), notice of the availability of this RAO Statement will be submitted to the PIP mailing list. Prior to submission of a final document, the draft version of this document was placed in the public repositories in Dedham and Boston, and notification made to public officials and other persons on the PIP list. A public meeting was held on March 6, 2013 to inform the public and to solicit the concerns of the public during a public comment period. Meeting summaries and responses to public comments (no written public comments were received during the public comment period) are included, with copies of the letters to municipal officers in Appendix B. A copy of this final document, with the meeting summaries and response to comments, has been placed in the public repositories as well.

5.9 Licensed Site Professional Opinion

The seal and signature of the Licensed Site Professional, Elissa J. Brown, LSP #5371, is provided on Form BWSC-104, which is being submitted through eDEP. A copy of the BWSC-104 is provided in Appendix A.

To the best of the LSP’s knowledge, information and belief, the attached Class A-3 RAO contains material facts, data, and other information that supports the LSP Opinion that the response actions that are the subject of this submittal (i) have been developed and implemented in accordance with the applicable provisions of M.G.L. c 21E and 310 CMR 40.0000, (ii) are appropriate and reasonable to accomplish the purposes of such response actions as set for the in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.000, and (iii) comply with the identified provisions of all orders, permits, and approval identified in this submittal.

.


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6.0 References

AECOM, 2010. Supplemental Phase II/III and Revised Phase IV Remedy Implementation Plan (RIP) Release Tracking Number 3-2856, January 2010.

AECOM, 2010. Phase IV Status Report #1, Readville Yard 5, Industrial Drive, Boston and Dedham, MA, RTN 3-2856, November 4, 2010.

AECOM, 2011. Phase IV Status Report #2, Readville Yard 5, Industrial Drive, Boston and Dedham, MA, RTN 3-2856, May 5, 2011.

AECOM, 2011. Phase IV Status Report #3, Readville Yard 5, Industrial Drive, Boston and Dedham, MA, RTN 3-2856, November 4, 2011.

AECOM, 2012. Phase IV Final Inspection Report and Completion Statement, Readville Yard 5, Industrial Drive, Boston and Dedham, MA, RTN 3-2856, May 16, 2012.

Commonwealth of Massachusetts, Settlement Agreement between the Commonwealth of Massachusetts and MBTA (Civil Action No. 01-4492E) executed February 14, 2004, including the Consent Judgment, Commonwealth of Massachusetts (Plaintiff) v. MBTA (Defendant), Civil Action No. 01-4429E, February 18, 2004.

HMM Associates, Inc., 1989. Preliminary Site Assessment Phase I – Limited Site Investigation, MBTA Readville Yard.

HMM Associates, Inc., May 29, 1990. Draft Phase III Report, Development of Remedial Alternatives, MBTA Readville Yard.

Levine Fricke Recon, Inc. (LFR), Phase IV Remedy Implementation Plan, MBTA Readville 5-Yard Facility, Industrial Drive, Boston/Dedham, Massachusetts, RTNs 3-2856 and 3-18777, June 9, 2006.

Levine Fricke Recon, Inc., Phase IV Remedy Implementation Plan Amendment, July 18, 2006.

LFR, Inc., July 18, 2006. Phase IV Remedy Implementation Plan, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Massachusetts Bay Transportation Authority (MBTA), Letter from Scott Darling, MBTA Environmental and Land Use Counsel to Iris Davis and Timothy Boyle, MassDEP, Readville 5 Yard Site, Scope of Work for Phase IV Activities Response to [Mass]DEP Comments, February 28, 2008.

Massachusetts Contingency Plan (MCP), 310 CMR 40.000, October 29, 1999.

Massachusetts Department of Environmental Protection, 1995. Guidance for Disposal Site Risk Characterization - In Support of the Massachusetts Contingency Plan, Office of Research and Standards and the Bureau of Waste Site Cleanup, July 1995.


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MassDEP. 2002a. Background Levels of Polycyclic Aromatic Hydrocarbons and Metals in Soil. Technical Update. Office of Research and Standards. May 2002.

Massachusetts Department of Environmental Protection (MassDEP), February 7, 2002. IH Evaluation.

Massachusetts Department of Environmental Protection (MassDEP), Letter from Tim Boyle and Iris Davis to Geri Scoll, MBTA, Phase II/Phase III Comments, Notice of Interim Deadline; M.G.L. c. 21E & 310 CMR 40.000, March 31, 2003.

Massachusetts Department of Environmental Protection, Letter from William Gaughan, MassDEP Regional Director to Andrew Brennan, MBTA Director of Environmental Affairs, Re: ACO #ACT-BO-00-022 EOEA #1026 and Readville RR Yard, Industrial Drive, RTNS 3-2856 & 3-1877”, July 28, 2003, with attached memorandum from Jack Miano, MassDEP to Patricia Donahue, MassDEP Section Chief, Compliance Branch, Dedham & Readville, MBTA 5-Yard Rail Yard, RTN 3-2856, Comments on the Phase II and Phase III Reports, July 28, 2003.

Massachusetts Department of Environmental Protection, Letter from Laurel Mackay, MassDEP Deputy Regional Director, Bureau of Waste Site Cleanup to Gerri Scoll, MBTA, MBTA/Readville Yard, RTN 3-2856 & 3-18777, Status of Phase II and III issues, December 18, 2003 with attached memorandum from Jack Miano, MassDEP Environmental Engineer, BWSC/Audits to Patricia Donahue, MassDEP Section Chief, Compliance Branch, “Dedham & Readville, MBTA Railyard, RTN 3-2856, Phase II & Phase III – Status of Outstanding Issue”, November 20, 2003.

Massachusetts Department of Environmental Protection, Letter from Jack Miano, MassDEP Environmental Engineer and Iris Davis, MassDEP Section Chief, Risk Reduction Branch to Ms. Geri Scoll, MBTA Assistant General Manager for Environmental Affairs, Immediate Response Action Conditional Approval; M.G.L. c.21E & 310 CMR 40.000), February 5, 2004.

Massachusetts Department of Environmental Protection, Letter to the MBTA and Readville Yard LLC that the selection of an Engineered Barrier as Permanent Solution could not be made unless there were no other feasible alternatives, August 17, 2006

Massachusetts Department of Environmental Protection, Letter from Scott Darling, MBTA Environmental and Land Use Counsel to Maureen Vallatini, MassDEP Regional Counsel, Readville Yard 5 Site, Dedham and Readville, Massachusetts, RTNs 3-2856 and 3-18777, November 9, 2007

Massachusetts Department of Environmental Protection, Letter from Timothy Boyle, MassDEP Environmental Engineer and Iris Davis, MassDEP Section Chief, Risk Reduction Branch to Scott Darling, MBTA Environmental and Land Use Counsel, MassDEP’s Comments on the Readville 5 Yard’s Revised Phase IV Remedy Implementation Plan, MassDEP Release Tracking Numbers 3-2856 and 3-18777, December 4, 2007.

Massachusetts Department of Environmental Protection, Letter from Maureen Vallatini, MassDEP Senior Regional Counsel to Scott Darling, MBTA Environmental and Land Use Counsel, Readville – RTNs 3-2856 and 3-18777, Readville 5 Yard Site, March 24, 2008.


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Massachusetts Department of Environmental Protection, Letter from Kyle MacAfee, MassDEP Environmental Engineer and Stephen Johnson, Deputy Regional Director, Bureau of Waste Site Cleanup, MassDEP Comments on the Readville 5 Yard’s Supplemental Phase II Comprehensive Assessment, Phase II Remedial Action Plan and Revised Phase IV Remedy Implementation Plan, MassDEP Release Tracking Number 3-2856 and 3-18777”, October 17, 2008.

Massachusetts Department of Environmental Protection, Letter from Kyle MacAfee, MassDEP Environmental Engineer and Stephen Johnson, Deputy Regional Director, Bureau of Waste Site Cleanup, MassDEP Comments on the Readville 5 Yard’s Supplemental Phase II Comprehensive Assessment, Phase II Remedial Action Plan and Revised Phase IV Remedy Implementation Plan, MassDEP Release Tracking Number 3-2856 and 3-18777”, March 23, 2009.

Massachusetts Office of the Attorney General, Letter from William Pardee, Office of the Attorney General, Assistant Attorney General to William Mitchell, Jr., General Counsel, MBTA, Readville Yard”, January 29, 2008.

Rizzo Associates Inc., December 31, 1996. Tier II Extension, MBTA Readville Rail Yard.



Rizzo Associates Inc., October 2000. Immediate Response Action Status Report and Imminent Hazard Evaluation, MBTA Readville Rail Yard.

Rizzo Associates, Inc. (Rizzo), Immediate Response Action Plan Status Report and Imminent Hazard Evaluation, Readville Rail Yard, Industrial Drive, Dedham, Massachusetts, RTN 3-18777, October 30, 2000.

Rizzo Associates Inc., September 14, 2001. Phase I – Initial Site Investigation and Tier Classification, MBTA Readville Rail Yard.

Weston & Sampson Engineers, Inc., November 2001. Immediate Response Action Plan, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., and EST Associates, Inc., December 2001. Soil Stockpile Management and Characterization Plan, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., March 2002. Immediate Response Action Plan, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., March 2002. Immediate Response Action Status Report, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., May 2002. Immediate Response Action Status Report, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., September 2002. Immediate Response Action Status Report, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.


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Weston & Sampson Engineers, Inc., December 2002. Immediate Response Action Status Report, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., January 2003. Phase II – Comprehensive Site Assessment, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc. (W&S), Final Phase II Comprehensive Site Assessment, January 2003.

Weston & Sampson Engineers, Inc., April 2003. Phase III – Remedial Action Plan, MBTA Readville 5-Yard Facility, Dedham and Readville, MA.

Weston & Sampson Engineers, Inc., Final Phase III Identification, Evaluation and Selection of Remedial Alternatives, including the Phase II Addendum, Response to DEP Comments on Final Phase II Report, April 2003.

Weston & Sampson Engineers, Inc., Letter from W&S, on behalf of the MBTA to MassDEP requesting a written response regarding the status of the Phase II/III and completion of the activities associated with the Phase II/III, October 28, 2003.

Weston & Sampson Engineers, Inc., Letter from Kelley Race, W&S to MassDEP, BWSC, IRA Plan Modification, MBTA – Readville 5-Yard, Industrial Drive, Dedham and Boston, Massachusetts, RTN 3-2856 and 3-18777, January 26, 2004.


April 2013 J:\Concord\105627 - MBTA\PROJ\TO-1 Readville\RAO\Report\Final\MBTA Readville Yard 5 RAO-A FINAL April 2013.docx

Figures



Appendix A Bureau of Waste Site Cleanup (BWSC) Transmittal Form BWSC-104 (RAO)

b. Provide additional Release Tracking Number(s)covered by this RAO Statement.

-

BWSC104

Release Tracking Number

Massachusetts Department of Environmental ProtectionBureau of Waste Site Cleanup

RESPONSE ACTION OUTCOME (RAO) STATEMENT

Page 1 of 7

Pursuant to 310 CMR 40.1000 (Subpart J)

A. SITE LOCATION:

1. Site Name/Location Aid:

2. Street Address:

3. City/Town: 4. ZIP Code:

B. THIS FORM IS BEING USED TO: (check all that apply)

2. Submit a Response Action Outcome (RAO) Statement

3. Submit a Revised Response Action Outcome Statement

5. Submit an optional Phase I Completion Statement supporting an RAO Statement

6. Submit a Periodic Review Opinion evaluating the status of a Temporary Solution for a Class C-1 RAO Statement, asspecified in 310 CMR 40.1051 (Section F is optional)

1. List Submittal Date of RAO Statement (if previously submitted):

a. Check here if this RAO Statement covers additional Release Tracking Numbers (RTNs). RTNs that have beenpreviously linked to a Tier Classified Primary RTN do not need to be listed here.

--

b. Provide additional Release Tracking Number(s)covered by this RAO Statement.

4. Submit a Response Action Outcome Partial (RAO-P) Statement

a. Check here if this Revised RAO Statement covers additional Release Tracking Numbers (RTNs), not listed on theRAO Statement or previously submitted Revised RAO Statements. RTNs that have been previously linked to a TierClassified Primary RTN do not need to be listed here.

7. Submit a Retraction of a previously submitted Response Action Outcome Statement (Sections E & F are not required)

Check above box, if any Response Actions remain to be taken to address conditions associated with this disposal sitehaving the Primary RTN listed in the header section of this transmittal form. This RAO Statement will record only anRAO-Partial Statement for that RTN. A final RAO Statement will need to be submitted that references all RAO-PartialStatements and, if applicable, covers any remaining conditions not covered by the RAO-Partial Statements.

--

6. If a Tier I Permit has been issued, provide Permit Number:

(All sections of this transmittal form must be filled out unless otherwise noted above)

5. Check here if a Tier Classification Submittal has been provided to DEP for this disposal site.

a. Tier IA b. Tier IB c. Tier IC d. Tier II

Revised: 02/28/2006

mm/dd/yyyy

For sites with multiple RTNs, enter the Primary RTN above.

b. Eligible Tenanta. Eligible Person

Also, specify if you are an Eligible Person or Tenant pursuant to M.G.L. c. 21E s.2, and have no further obligation toconduct response actions on the remaining portion(s) of the disposal site:

3 2856

MBTA READVILLE YARD

INDUSTRIAL DR

DEDHAM 02026

✔

✔

W021916

✔

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Page 2 of 7

3. Deployment of Absorbent or Containment Materials

a. Re-use, Recycling or Treatment

iii. Describe:

5. Structure Venting System

11. Bioremediation

(check all that apply; for volumes, list cumulative amounts)

15. Removal of Contaminated Soils

2. Temporary Covers or Caps

C. DESCRIPTION OF RESPONSE ACTIONS:

10. Soil Vapor Extraction

7. Product or NAPL Recovery

4. Treatment of Water Supplies

9. Groundwater Treatment Systems

12. Air Sparging

1. Assessment and/or Monitoring Only

6. Engineered Barrier

8. Fencing and Sign Posting

Town:

Estimated volume in cubic yardsi. On Site

ii. Off Site Estimated volume in cubic yards

iia. Facility Name: State:Town:

State:iib. Facility Name:


State:Town:Facility Name:

Estimated volume in cubic yardsii. Disposal

State:Town:Facility Name:

Estimated volume in cubic yardsi. Cover

b. Landfill

State:

State:

Town :

Town:

c. Facility Name:

b. Facility Name:

a. Describe Quantity and Amount:

16. Removal of Drums, Tanks or Containers:

Revised: 02/28/2006

13. Monitored Natural Attenuation 14. In-situ Chemical Oxidation

c. Facility Name:

a. Specify Type and Volume:

17. Removal of Other Contaminated Media:

State:Town:b. Facility Name:

State:Town:

✔

✔

✔ 12,697

WM LANDFILLS ROCHESTER, NH & TAUNTO MA

✔

VARIOUS, SEE ATTACHED

PA LANDERS HANOVER MA

JAMES G GRANT READVILLE MA

3 2856

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Page 3 of 7


(check all that apply; for volumes, list cumulative amounts)C. DESCRIPTION OF RESPONSE ACTIONS (cont.):

Describe:

18. Other Response Actions:

19. Use of Innovative Technologies:

Describe:

E. RESPONSE ACTION OUTCOME CLASS:

1. Class A-1 RAO: Specify one of the following:

a. Contamination has been reduced to background levels. b. A Threat of Release has been eliminated.

2. Class A-2 RAO: You MUST provide justification that reducing contamination to or approaching background levels isinfeasible.

3. Class A-3 RAO: You MUST provide an implemented Activity and Use Limitation (AUL) and justification that reducingcontamination to or approaching background levels is infeasible.

Specify the Class of Response Action Outcome that applies to the disposal site, or site of the Threat of Release.Select ONLY one Class.

4. Class A-4 RAO: You MUST provide an implemented AUL, justification that reducing contamination to or approachingbackground levels is infeasible, and justification that reducing contamination to less than Upper Concentration Limits(UCLs) 15 feet below ground surface or below an Engineered Barrier is infeasible. If the Permanent Solution relies upon anEngineered Barrier, you must provide or have previously provided a Phase III Remedial Action Plan that justifies the selectionof the Engineered Barrier.

Revised: 02/28/2006

D. SITE USE:

This data will be used by MassDEP for information purposes only, and does not represent or create any legal commitment,obligation or liability on the part of the party or person providing this data to MassDEP.

2. Is the property a vacant or under-utilized commercial or industrial property ("a brownfield property")?

c. Don't knowb. Noa. Yes

3. Will funds from a state or federal brownfield incentive program be used on one or more of the property(ies) within the disposal site?


4. Has a Covenant Not to Sue been obtained or sought?

If Yes, identify program(s):


5. Check all applicable categories that apply to the person making this submittal: a. Redevelopment Agency or Authority

e. Fiduciary

b. Community Development Corporation c. Economic Development and Industrial Corporation

f. Secured Lenderd. Private Developer g. Municipality

h. Potential Buyer (non-owner) describe:i. Other,

1. Are the response actions that are the subject of this submittal associated with the redevelopment, reuse or the majorexpansion of the current use of property(ies) impacted by the presence of oil and/or hazardous materials?

c. Don't knowb. Noa. Yes✔

✔

✔

✔

TRANSIT AUTHORITY✔

✔

3 2856

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Page 4 of 7


E. RESPONSE ACTION OUTCOME CLASS (cont.):

5. Class B-1 RAO: Specify one of the following:

6. Class B-2 RAO: You MUST provide an implemented AUL.

b. Active Remedial Monitoring Program

a. Contamination is consistent with background levels b. Contamination is NOT consistent with backgroundlevels.

a. Active Remedial System

7. Class B-3 RAO: You MUST provide an implemented AUL and justification that reducing contamination to less thanUpper Concentration Limits (UCLs) 15 feet below ground surface is infeasible.

8. Class C-1 RAO: You must submit a plan as specified at 310 CMR 40.0861(2)(h). Indicate type of ongoing responseactions.

1. Specify the Risk Characterization Method(s) used to achieve the RAO described above:

F. RESPONSE ACTION OUTCOME INFORMATION:

2. Specify all Soil Category(ies) applicable. More than one Soil Category may apply at a Site. Be sure to check off all APPLICABLEcategories:

5. Specify whether the analytical data used to support the Response Action Outcome was generated pursuant to the Department'sCompendium of Analytical Methods (CAM) and 310 CMR 40.1056:

a. Method 1

a. S-1/GW-1

a. GW-1

b. Method 2

d. S-2/GW-1

b. GW-2

4. Specify remediation conducted:

c. Method 3

d. Method Not Applicable-Contamination reduced to or consistent with background, or Threat of Release abated

b. S-1/GW-2

c. S-1/GW-3

e. S-2/GW-2

f. S-2/GW-3 i. S-3/GW-3

h. S-3/GW-2

g. S-3/GW-1

c. GW-3

a. Check here if soil remediation was conducted.

b. Check here if groundwater remediation was conducted.

7. Estimate the number of acres this RAO Statement applies to:

Revised: 02/28/2006

d. No Groundwater Impacted

9. Class C-2 RAO: You must hold a valid Tier I Permit or Tier II Classification to continue response actions toward aPermanent Solution.

d. Other Specify:

c. None

6. Check here to certify that the Class A, B or C Response Action Outcome includes a Data Usability Assessment and DataRepresentativeness Evaluation pursuant to 310 CMR 40.1056.

a. CAM used to support all analytical data.

3. Specify all Groundwater Category(ies) impacted. A site may impact more than one Groundwater Category. Be sure to check offall IMPACTED categories:

b. CAM used to support some of the analytical data.

c. CAM not used.

✔

✔ ✔

✔

✔

✔

42

3 2856

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Page 5 of 7

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form,including any and all documents accompanying this submittal. In my professional opinion and judgment based upon applicationof (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and 309 CMR4.03(2), and(iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief,

G. LSP SIGNATURE AND STAMP:

5. Ext.:

1. LSP #:

8. Date:

7. Signature:

6. FAX: 4. Telephone:

2. First Name:

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

3. Last Name:

9. LSP Stamp:

> if Section B indicates that either an RAO Statement, Phase I Completion Statement and/or Periodic Review Opinion is beingprovided, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented inaccordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable toaccomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR40.0000, and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal.


H. PERSON MAKING SUBMITTAL:

11. Ext.:10. Telephone:

9. ZIP Code:8. State:7. City/Town:

6. Title:5. Street:

4. Last Name:3. Contact First Name:

2. Name of Organization:

12. FAX:

Revised: 02/28/2006

c. change in the personundertaking response actions

b. change of address1. Check all that apply: a. change in contact name

mm/dd/yyyy

3 2856

5371

ELISSA J BROWN

(978) 905-2134 (978) 905-2101

MASSACHUSETTS BAY TRANSPORTATION AUTHORITY [MBTA]

DEBRA DARBY

10 PARK PLAZA ROOM 6720 SITE REMEDIATION SPECIALIST

BOSTON MA 021160000

(617) 222-3169 (617) 222-1557

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Page 6 of 7


I. RELATIONSHIP TO RELEASE OR THREAT OF RELEASE OF PERSON MAKING SUBMITTAL:

Specify Relationship:4. Any Other Person Making Submittal

3. Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s. 5(j))

2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2)

Specify:

d. Transporterc. Generatorb. Operatora. Owner1. RP or PRP

e. Other RP or PRP

3. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of aRAO Statement with instructions on how to obtain a full copy of the report.

2. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal ofan RAO Statement that relies on the public way/rail right-of-way exemption from the requirements of an AUL.

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

J. REQUIRED ATTACHMENT AND SUBMITTALS:

7. If an RAO Compliance Fee is required for any of the RTNs listed on this transmittal form, check here to certify that an RAOCompliance Fee was submitted to DEP, P. O. Box 4062, Boston, MA 02211.

6. Check here if required to submit one or more AULs. You must submit an AUL Transmittal Form (BWSC113) and acopy of each implemented AUL related to this RAO Statement. Specify the type of AUL(s) below: (required for ClassA-3, A-4, B-2, B-3 RAO Statements)

b. Number of Notices submitted:a. Notice of Activity and Use Limitation

4. Check here to certify that documentation is attached specifying the location of the Site, or the location and boundaries ofthe Disposal Site subject to this RAO Statement. If submitting an RAO Statement for a PORTION of a Disposal Site, youmust document the location and boundaries for both the portion subject to this submittal and, to the extent defined, the entireDisposal Site.

d. Number of Grants submitted:c. Grant of Environmental Restriction

Revised: 02/28/2006

8. Check here if any non-updatable information provided on this form is incorrect, e.g. Site Address/Location Aid. Sendcorrections to the DEP Regional Office.

9. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached.

5. Check here to certify that, pursuant to 310 CMR 40.1406, notice was provided to the owner(s) of each property within thedisposal site boundaries, or notice was not required because the disposal site boundaries are limited to property owned bythe party conducting response actions. (check all that apply)

d. Total number of property owners notified, if applicable:

b. Notice was provided prior to, or concurrent with the submittal of this RAO Statement to the Department.

a. Notice was provided prior to, or concurrent with the submittal of a Phase II Completion Statement to the Department.

c. Notice not required.

3 28563 2856

✔ ✔

✔

✔

✔

✔

✔0

✔

✔

✔ 2

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Page 7 of 7

Date Stamp (DEP USE ONLY:)

1. I, , attest under the pains and penalties of perjury (i) that I have personallyexamined and am familiar with the information contained in this submittal, including any and all documents accompanying thistransmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, thematerial information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii)that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person orentity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to,possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

3. Title:Signature

K. CERTIFICATION OF PERSON MAKING SUBMITTAL:

13. FAX: 12. Ext.:11. Telephone:

10. ZIP Code:9. State:8. City/Town:

7. Street:

(Name of person or entity recorded in Section H)


Revised: 02/28/2006

6. Check here if the address of the person providing certification is different from address recorded in Section H.

2. By:

mm/dd/yyyy4. For: 5. Date:

YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PERBILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANTSECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU

SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE.

3 28563 2856

SITE REMEDIATION SPECIALIS

MASSACHUSETTS BAY TRANSPORTATION AUTHORITY [MBTA

BWSC-104 Response Action Outcome Statement MBTA Readville Yard Site Dedham and Boston, MA RTN 3-2856 DESCRIPTION OF RESPONSE ACTIONS C.15. Removal of Contaminated Soils b. Landfill i. Cover 365 cy to WM Turnkey Landfill, Rochester, NH in 2004 10,780 cy to WM Turnkey Landfill, Rochester, NH in 2011-2012 1,545 ct to WM Taunton Landfill, Taunton, MA in 2011-2012 C.17. Removal of Other Contaminated Media a. Specify Type and Volume Concrete, 952 tons to PA Landers, Hanover, MA Metal, 73 tons to James G Grant, Readville, MA Solid Waste, 11 tons to United Waste Management, Roxbury, MA Railroad Ties, 93 tons to WM Disposal Services of Maine, Norridgewock, ME Tailings from Screener, 64 tons to Northgate Recycling, Revere, MA REQUIRED ATTACHMENT AND SUBMITTALS: F1. Order(s), Permit(s), and/or Approval(s) Issued by the DEP or EPA Response actions on which this opinion is based were subject to the following order(s), permit(s), and/or approvals(s) issued by the DEP or EPA for this Site:

On October 10, 1990, DEQE issued a Notice of Potential Release for the Site.

On September 29, 1999, MassDEP issued a Notice of Responsibility (NOR) and a second Release Tracking Number (RTN) for this Site (3-18777), after reviewing the files and determining that elevated lead concentrations in soil could potentially pose an Imminent Hazard (IH) condition.

In accordance with the NOR, the MBTA was required to perform an Immediate Response Action (IRA) that included an IH evaluation, fencing of the area of elevated lead in soil, and posting of warning signs. The MBTA installed a fence and warning signs in December 1999. The MassDEP installed additional fencing along the Orphan Line in January 2000.

Rizzo submitted an IRA Status Report and IH Evaluation to the MassDEP on October 30, 2000, in response to an NOR. The IRA included a Site visit to verify placement and maintenance of fence and warning signs and to collect additional

surficial soil samples for lead analyses. Rizzo concluded that an IH did not exist at the Site.

On July 13, 2001, the MBTA received a petition requesting designation of the Site as a Public Involvement Plan (PIP) Site. In response to the petition, the MBTA and the MassDEP designated the Site as a PIP Site.

On September 14, 2001, Rizzo submitted a Phase I - Initial Site Investigation (Phase I) to the MassDEP. The Site was Tier Classified as Tier IC (Number W021916) with an NRS score of 413.

On October 12, 2001, the MBTA and the Attorney General for the Commonwealth of Massachusetts entered into a preliminary injunction agreement that identified several tasks to be expedited. These tasks included covering of the exposed stockpiles within the Exclusion Zone (EX), completion of a groundwater investigation, and preparation of a stockpile characterization plan. On November 6, 2001, Weston & Sampson completed and submitted an IRA Plan to conduct these three identified tasks.

Between October and December 2001, the MassDEP conducted an IH Evaluation that included the collection of over 3,000 surficial soil samples for XRF field screening for lead and arsenic. Based on the results of their IH Evaluation, the MassDEP concluded that IH conditions did not exist at the Site under current conditions; however, they identified several zones for additional investigation located immediately outside the Site fence to the north near Milton Street and to the west near Ashcroft Street.

On December 17, 2001, Weston & Sampson and EST Associates (EST) prepared and submitted a Soil Stockpile Management and Characterization Plan (SSCMP) to the MassDEP. The MassDEP verbally approved the SSCMP in December 2001.

Between October 2001 and February 2002, the MassDEP conducted an IH Evaluation that included collection of surficial soil samples along a 100-foot to 50-foot grid throughout the Site and immediately outside the fence and an assessment of exposure risks. The MassDEP concluded that an IH condition did not exist in any of the above-listed areas of the Site under current use conditions. In addition, the MassDEP’s review of their data indicated that the XRF field screening appeared to overestimate arsenic concentrations relative to standard laboratory analysis.

The MassDEP conditionally approved the Tier IC permit in a letter dated February 7, 2002.

While the MassDEP concluded that IH conditions did not exist based on the average detected concentrations within the different areas of the Site, individual samples collected at locations outside of the Site fence north of the Site near Milton Street and west of the Site near Ashcroft Street indicated detected concentrations above IH thresholds. Therefore, the MassDEP requested that the MBTA conduct an IRA to further evaluate these sampling locations. On April 1, 2002, Weston & Sampson marked out a 25-square-foot area around each of the

MassDEP’s IH evaluation sample locations that had indicated elevated lead and/or arsenic concentrations. These levels were below the MassDEP-established IH thresholds but additional assessment was deemed warranted based on the potential for variability in the sample. In Area 2, a fence was installed approximately 20 feet from the existing fence as an IRA activity.

Weston & Sampson prepared a draft IRA Plan for additional assessment of the above-mentioned zones, which was submitted to the MassDEP and presented at a PIP meeting on February 27, 2002. The final IRA Plan was submitted to the MassDEP on March 28, 2002. On April 2, 2002, Weston & Sampson commenced sampling activities. Analytical data indicated high concentrations of arsenic along the western fence and lead at two locations along the northern fence. On May 28, 2002, Weston & Sampson conducted additional sampling to evaluate the extent of contamination. Between June 1 and 19, 2002, a new fence was installed approximately 20 feet west of the original western fence.

On June 6, 2002, Weston & Sampson held a PIP meeting to present the draft Phase II Scope of Work (SOW) for public comment, and to notify the residents of IRA excavation activities outside the northern fence.

On June 26, 2002, Weston & Sampson documented the IRA excavation of a total of approximately 20 cubic yards of lead-impacted soil from two locations outside the northern fence.

After the close of the 21-day comment period, Weston & Sampson submitted a Final Phase II SOW to the MassDEP on July 12, 2002, and fieldwork commenced the week of July 22, 2002.

Weston & Sampson prepared a draft of the Phase II Report and provided it to the MassDEP on November 26, 2002 (the “Draft Phase II Report”). In accordance with PIP, the MBTA established a public comment period for the Draft Phase II Report from December 11, 2002 to January 8, 2003. On December 9, 2002, the MassDEP provided comments on the Draft Phase II Report to Weston & Sampson and, on December 11, 2002, the report was presented at a public meeting. No additional comments from the MassDEP and no comments from the public were received during the public comment period. After the close of the public comment period on January 8, 2003, Weston & Sampson finalized the Draft Phase II Report and incorporated the MassDEP’s December 9, 2002 comments into the “Final Phase II Report”. The Final Phase II Report was submitted to the MassDEP and the information repositories on January 31, 2003. In accordance with the PIP, all persons on the Site’s PIP mailing list were notified by letter dated February 3, 2003 that the Final Phase II Report was available for review at the information repositories.

A Phase II Addendum, containing MassDEP comments on the Phase II CSA as well as MBTA’s responses, was included as an appendix to the Final Phase II Report (see Weston & Sampson, January 2003). As part of the Supplemental Phase II investigation conducted during June and July 2008, additional soil data were collected to supplement the original Weston & Sampson characterization.

To accommodate the MassDEP’s additional comments on the Phase III, and to avoid confusion among the public, the MBTA responded to the MassDEP’s comments concerning the Final Phase II Report in the form of a Phase II Addendum – Response to DEP Comments on the Final Phase II Report (the “Phase II Addendum”). The Phase II Addendum was attached as Appendix F to the Final Phase III Report submitted to the MassDEP on April 30, 2003. The Phase III report was submitted to the MassDEP on April 30, 2003.

A Modified IRA Plan for lead and TPH field screening of stockpiled soil was prepared by Weston & Sampson on September 22, 2003. On October 2, 2003, a Supplemental IRA Plan Modification was prepared by Weston & Sampson and submitted to the MassDEP for comment. Between October 9 and 16, 2003, Weston & Sampson oversaw the segregation and field screening of certain soil cells in stockpiles and surficial samples identified with lead and TPH Upper Concentration Limit (UCL) exceedances. It was reported that 1,000 tons of soil was estimated to contain lead and/or TPH

The MBTA also responded to the MassDEP’s comments concerning the Final Phase II Report in an October 28, 2003 report entitled “Response to DEP’s September 17, 2003 Meeting Comments”. This letter prepared by Weston & Sampson formalized the comments provided by the MassDEP in the September 17, 2003 meeting and provided additional clarification on certain items contained in the Phase II and Phase III reports. The MassDEP then responded to this October 28, 2003 letter in their Memorandum dated November 20, 2003. In general, the MassDEP indicated that, with respect to the Phase II risk assessment, the majority of issues had been resolved with the exception that additional soil sampling data from areas of the Site and the stockpiles should be included in the risk characterization or an argument should be made that the newer data does not affect the results of the risk characterization, remedial plan, or selected remedial actions.

In December 2003, Weston & Sampson prepared a follow-up draft IRA Plan Modification for the removal of the lead and TPH UCL classified soil. The IRA Plan Modification was presented at a public meeting on December 11, 2003. On December 23, 2003, Weston & Sampson submitted a Final Draft IRA Plan Modification to the MassDEP for review. On January 26, 2004, MassDEP's comments were incorporated and on February 5, 2004, the MassDEP approved the IRA Plan Modification for the removal of the lead and TPH UCL soils.

Consent Judgment, Commonwealth of Massachusetts v. Massachusetts Bay Transportation Authority (MBTA), Civil Action, #01-04492E, dated February 23, 2004.

In a November 8, 2007 letter to the MassDEP, the MBTA provided a Draft Scope of Work (SOW) that detailed the tasks to be performed to finalize the Revised Phase IV RIP at the Site.

The MassDEP provided comments to the MBTA on the above Draft SOW for the final Phase IV RIP in a letter dated December 4, 2007. In these comments, the MassDEP indicated that some of the work required in order to submit the Revised Phase IV RIP was more appropriately categorized as Phase II and/or

Phase III activities. As such, the MassDEP stated that the Revised Phase IV RIP should include a supplement that updates the previously submitted Phase II and Phase III reports. The MBTA responded to the MassDEP comments to the Draft SOW for Phase IV RIP in a letter dated February 28, 2008.

Preliminary Draft Supplemental Phase II Comprehensive Site Assessment, Phase III Remedial Action Plan and Revised Phase IV Remedy Implementation Plan submitted to MassDEP on September 10, 2008.

September 8, 2008, a public site status meeting was held at the Knights of Columbus Hall, Dedham, MA.

MassDEP commented to MBTA on the Preliminary Draft Supplemental Phase II Comprehensive Site Assessment, Phase III Remedial Action Plan and Revised Phase IV Remedy Implementation Plan on October 17, 2008.

Draft Supplemental Phase II/III Report and Revised Phase IV RIP submitted to MassDEP on November 5, 2008.

On November 5, 2008, a Public Involvement Plan (PIP) meeting was held at St. Ann’s School, Dedham, MA.

MassDEP Office of Research and Standards (ORS) Memorandum to MBTA dated January 14, 2009 – Readville 5-Yard – ORS Comments on Draft Supplemental Phase II/III and Revised Phase IV RIP submitted November 5, 2008.

MassDEP commented to MBTA on the Draft Supplemental Phase II/III Report and Revised Phase IV RIP submitted to MassDEP on November 5, 2008 in a letter dated March 23, 2009.

MBTA responded to MassDEP comments in a letter dated May 8, 2009.

MBTA responded to public (PIP) comments in a letter dated June 8, 2009.

On July 7, 2009, representatives from the MBTA, MassDEP, AECOM, and the Office of the Attorney General met to attempt to resolve the comments provided by the MassDEP in the March 23, 2009 letter. As a follow-up to this meeting, a conference call with representatives from the MBTA, MassDEP and AECOM was held on July 16, 2009.

The final Supplemental Phase II Comprehensive Site Assessment, Phase III Remedial Action Plan and Revised Phase IV Remedy Implementation Plan was submitted to MassDEP on January 15, 2010. A Comments Resolution Letter was included as a cover letter. MassDEP comments on the Draft Supplemental Phase II/III and Revised Phase IV were incorporated into this 2010 report.

MassDEP issued a letter granting Conditional Approval of the final Supplemental Phase II/III and Revised Phase IV Report on May 10, 2010.

The Phase IV Status Report #1 was submitted to MassDEP on November 5, 2010.

A Site status meeting was held on April 14, 2011 to introduce the community to the contractor selected prior to the start of work.

The Phase IV Status Report #2 was submitted to MassDEP on May 9, 2011.

The Phase IV Status Report #3 was submitted to MassDEP on November 4, 2011.

The Phase IV Final Inspection Report and Completion Statement was submitted to MassDEP on May 16, 2012.



Appendix B Copies of Public Notification Letters

AECOM 250 Apollo Drive 978.905.2100 tel Chelmsford, MA 01824 978.905.2101 fax

J:\Concord\105627 - MBTA\PROJ\TO-1 Readville\RAO\Report\Appendices\Appendix B - Public Notifi\Public Involvement Notifications.docx

April 5, 2013

Mayor Thomas Menino Boston City Hall One City Hall Square, Suite 500 Boston, MA 02201

RE: Notice of Availability of Response Action Outcome Statement MBTA Readville Yard Industrial Drive, Dedham and Boston, Massachusetts RTN 3-2856 Dear Mayor Menino: Pursuant to the Massachusetts Contingency Plan (310 CMR 40.1403(3)(f), AECOM is writing to notify you that a Response Action Outcome Statement has been prepared by AECOM on behalf of the Massachusetts Bay Transportation Authority (MBTA). This document addresses the presence of metals (primarily lead and arsenic), petroleum hydrocarbons, and polycyclic aromatic hydrocarbons detected in soil as a result of historic railroad activities.

The Response Action Outcome Statement has been filed with the Massachusetts Department of Environmental Protection (MassDEP), Northeast Regional Office located at 205B Lowell Street, Wilmington, Massachusetts 01887. The report is available for public review and copying at the MassDEP office in Wilmington. A copy may also be obtained by contacting Debra Darby, Site Remediation Specialist, MBTA, 10 Park Plaza, Boston, Massachusetts 02116

If you have any questions concerning this letter, or require additional information, please do not hesitate to call us.

Sincerely,

Elissa J. Brown, LSP Program Manager

cc: DEP/BWSC/NERO D. Darby, MBTA



April 5, 2013

Dr. Barbara Ferrer Executive Director Boston Public Health Commission 1010 Massachusetts Avenue Boston, MA 02118

RE: Notice of Availability of Response Action Outcome Statement MBTA Readville Yard Industrial Drive, Dedham and Boston, Massachusetts RTN 3-2856 Dear Dr. Ferrer: Pursuant to the Massachusetts Contingency Plan (310 CMR 40.1403(3)(f), AECOM is writing to notify you that a Response Action Outcome Statement has been prepared by AECOM on behalf of the Massachusetts Bay Transportation Authority (MBTA). This document addresses the presence of metals (primarily lead and arsenic), petroleum hydrocarbons, and polycyclic aromatic hydrocarbons detected in soil as a result of historic railroad activities.



Sincerely,


cc: DEP/BWSC/NERO D. Darby, MBTA DATE



April 5, 2013 Mr. William Keegan Town Administrator Town of Dedham 26 Bryant Street Dedham, MA 02026 RE: Notice of Availability of Response Action Outcome Statement MBTA Readville Yard Industrial Drive, Dedham and Boston, Massachusetts RTN 3-2856 Dear Mr. Keegan: Pursuant to the Massachusetts Contingency Plan (310 CMR 40.1403(3)(f), AECOM is writing to notify you that a Response Action Outcome Statement has been prepared by AECOM on behalf of the Massachusetts Bay Transportation Authority (MBTA). This document addresses the presence of metals (primarily lead and arsenic), petroleum hydrocarbons, and polycyclic aromatic hydrocarbons detected in soil as a result of historic railroad activities.



Sincerely,





April 5, 2013

Ms.Catherine Cardinale, Health Director Board of Health Town of Dedham 26 Bryant Street Dedham, Massachusetts 02026

RE: Notice of Availability of Response Action Outcome Statement MBTA Readville Yard Industrial Drive, Dedham and Boston, Massachusetts RTN 3-2856 Dear Ms. Cardinale: Pursuant to the Massachusetts Contingency Plan (310 CMR 40.1403(3)(f), AECOM is writing to notify you that a Response Action Outcome Statement has been prepared by AECOM on behalf of the Massachusetts Bay Transportation Authority (MBTA). This document addresses the presence of metals (primarily lead and arsenic), petroleum hydrocarbons, and polycyclic aromatic hydrocarbons detected in soil as a result of historic railroad activities.



Sincerely,



March 1, 2013 The Dedham Times Page 15

Oakdale Square Alliance Neighborhood Meeting Notes

Contributed to The Dedham Times

OAKDALE SQUARE ALLIANCE NEIGHBORHOOD MEETING - February 12 at Church of the Good Shepherd, Oakdale Square

NEXT MEETING: Our next meeting is Tuesday, March 12, 2013 at 7 p.m. at the Church of the Good Shepherd; we hope to see you there!

ATTENDANCE: Stephanie Radner, Paul Reynolds, Patty Roberts, Kathleen Kalell, Martha Zeolla, Rich Campagna, Mike d’Entremont, Paul Zeolla, Eric Sargent, Maureen Sargent, Rita Mae Cushman, Joanne O’Meara, Patty Roberts, Cara Crisafulli, Katy Schneider, Monika Wilkinson.

KIDS FEST: Bring your children to the CHURCH OF THE GOOD SHEPHERD’S ANNUAL “KIDS FEST” on Saturday, March 2. be-tween 11:00am and 2:00pm for fun activities and snacks. No fee, just bring a donation of food or money for the Dedham Food Bank if possible. Activities are planned for children ages pre-K through grade 5. OSA will again be a sponsor for the event. If you want to help set up tables, go to the church hall Friday March 1 at 6:00pm. Contact Patty Roberts with any questions ([email protected]). The church is also looking for donations of cardboard boxes, paper towel tubes, toilet paper tubes and similar items for a project. Please contact Patty for details and to arrange a time for drop-off of these materials.

BUSINESS NEWS: A Dedham couple, Maureen and Eric Sar-gent, is opening Masters Self Defense Center at 63 Cedar Street in Oakdale Square. Eric will lead classes for adults and children in Kenpo Karate. Maureen is office manager. They plan to open on March 1 and their phone number is (781) 366-0631. Like their page on facebook for updates: https://www.facebook.com/ MastersSelfDefenseDedham

LIGHT THE NIGHT RECAP & DISCUSSION: This is the first time we have met since our winter event LIGHT THE NIGHT of De-cember 8, 2012 so we reviewed it tonight: A large turnout of fami-lies from the Oakdale community came for this third annual Light the Night! Thank you to Patty Roberts for arranging our use of the Church’s Hall since it was a cold rainy night. We thank our OSA members who brought yummy baked goods and hot drinks and helped with the night. Everyone loved the music, both inside and outside the church. The rain stopped and we all enjoyed the lighting of the tree outside to end the evening.

A special thanks goes to Lloyd and Rita Mae Cushman for again putting up the tree lights with their bucket truck!

This Light the Night is more popular each year. The Church of-fered us use of their hall again next year! We did some brainstorm-ing tonight to plan ahead for next year to reduce problems:

Again hold the event indoors at the Church; Ask ahead of time for help setting up the tree lights; Buy new improved lights; Out-reach for volunteer help; School or community service; Volunteer websites; Subcommittees to manage events; Persuade the Town to put in permanent lighting; Publish a WISH LIST of items needed for possible donations.

Brainstorming for Decorating Oakdale Square for the Holidays:Find out what businesses and residents like; Again ask business-

es for donations; This year we purchased wreaths from the Oakdale School PTO, which helped the school; To eliminate the difficulties in getting volunteers so near the Holidays; One-time purchase of nice artificial wreaths; Decorate “Christmas in July” Bright red ribbons and bows save time and are more noticeable.

CHIEF D’ENTREMONT’S POLICE REPORT: The Chief’s re-port includes the three months since our last meeting in November. Overall, a relatively quiet time period. Oakdale area issues:

Dale St. - a home received a phone call from someone pretending to be a detective

Curtis Newton Lumber was vandalizedCircuit Road - someone tried to get in the house by pretending

to sell asphaltPratt Ave, Oakdale Ave - an incident of malicious damage, an-

other of domestic violenceOakdale Ave - a safe stolen from lawn while resident was moving

possessions into vehicleHouse robberies at 31 Cedar St. and at 118 Cedar St.Two windows broken at Oakdale School - youngsters later ad-

mitted doing itAn attempted home robbery on Bussey St. at Boston line**Arrests have occurred in all four recent bank robberies in town

[Dedham Savings, Citizens and two at Blue Hill Bank]. The detec-tives also have made significant progress in investigating most of the recent criminal activity. We only read about the crimes in the papers, so it is comforting to hear about the resolution of many of these events.

Q&A:Whiting Ave. speed bumps were taken in for the winterDrug use in Dedham is comparable to other towns. The Schools

with Youth Commission are leading a group looking into the issues - next meeting is February 27, 6:00pm at the Middle School. The Selectmen are leading a broad task force including varied personnel and groups. Go to a meeting or meetings to learn and to give your opinions.

National Night Out will be August 6. We have had fun and con-tributed to safety progress in the first two years.

Please fill out the Police Survey on the new Dedham Police Web-site www.dedhampolice.org; it takes less than 15 minutes and will be helpful to the Police Department.

PROPOSED CHANGES TO LOGAN AIRPORT FLIGHT PATHS: Logan Airport has announced plans to put a flight path that will go over the Oakdale section of Dedham, and also part of Milton. Se-lectman Paul Reynolds told us that the Town Administrator sent a protest letter to the FAA. Best action is for each concerned resident to write to the Selectmen at “[email protected]”. Histori-cally the FAA is more responsive when the town can show letters from its citizens. Paul’s information was seconded by others in the audience.

Legal NoticeMassachusetts Department of Transportation

Rail & Transit Division

Community Meeting Notice

The MBTA will be holding a community meeting to dis-cuss the final remedy and the Draft Response Action Outcome (RAO) document submittal for the Readville 5-Yard MCP Site. The Public will have an opportunity to ask questions and comment on the information presented.

The meeting will be held on Wednesday, March 6, 2013 at 7:00 PM Meeting locationCommunity Room @ the Hyde Park Police Station, 1249 Hyde Park Avenue, Hyde Park(617) 343-5609

The meeting venue is accessible by public transportation and public parking is available. If assistive listening devices and/or interpreters are needed, please call 711 (Massachu-setts Relay Service) and request (617) 222-1984 (MBTA’s TDD/TYY). The requester is encouraged to call at least two business days before the community meeting.

We look forward to seeing you at the upcoming meeting. For further information on this project please contact Debra Darby by phone at (617) 222-3169 or by email at [email protected].

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by Kate Martin

The Mother Brook Communi-ty Group (MBCG) had its annual meeting on Tuesday night, honor-ing people who had made a differ-ence over the past twelve months, celebrating East Dedham’s ac-complishments, and looking to its future.

The Community Group, which was founded in 2008, chose the old Avery School for the gather-ing. Emcee Joe Heisler explained they held it there because it may well be one of the last municipal events in the school as an actual school.

By the end of March or the beginning of April, it is slated to be turned over to the Mother Brook Arts and Community Cen-ter (MBACC), which can the start renting the building’s spaces.

The Center represents one of the accomplishments Heisler cited for the year. “Like most of what the Mother Brook Commu-nity Group does, this was a group effort, in which we did what we could, and worked together, sometimes with the town govern-ment, sometimes without it, to accomplish what we set out to do, for the areas in and around East Dedham.”

He then turned the micro-

phone over to MBACC Co-Exec-utive Director Bob Allen for an update. Allen said the Commu-nity Group had been immensely supportive of the Center, and that the constant offers of help, be they practical or moral, were very much appreciated. “This kind of grass roots connection is im-mensely important to us.”

He added that the three-story building will use all its levels. The top floor will mostly be slated for studios, the ground floor will con-tain both studios and classrooms, and the bottom floor will have the auditorium and the former library, which will be converted into a cafe. Silversmiths, potters, and print makers have shown some tentative interest in provid-ing classes.

“Our budget is a shoestring at best,” Allen said. “So initially getting artists in there and rent-ing studio space, to get this thing kick-started, and getting some some cash flow, will help us defray the real costs of getting going.”

His fellow Co-Director, Jean Ford Webb, said they’d had about 200 people come to look at the spaces, and about 66 of those, be they individuals or groups, had shown solid interest in renting.

She said the objective is to create both studio space and com-

munity space, encouraging class-es, events in the gym, and more.

“So far as we know, this is something that’s never been done in the country,” said Town Ad-ministrator Bill Keegan. “This is not just an arts center, it’s an arts and community center.”

Emphasis then turned to the awards portion of the night, dis-tributing one such honor to a lo-cal artist who may well use the Center, Gintz Grinsberg. Grins-berg created the Mill Pond Park fish sculpture, which the commu-nity has rallied around after it was vandalized and later restored.

“I always thought we should do something with the river and the waterfront, so thanks for get-ting this going,” he said.

Earlier in the meeting, MBCG President Dan Hart noted that Dedham Institution for Savings had donated $12,000 as a grant to help with Mill Pond Park ren-ovations. Other award winners included San Marino Landscape Construction earning the Com-munity Business Award; Bob Campanella the Community Ser-vice Award; and Conservation Commission member Jon Briggs and State Representative Paul Mc-Murtry the Public Servant Award. In addition, Charlie Krueger re-ceived the first annual Rita Mae Cushman Award for meritorious service in holiday decorating.

There was also discussion of potential future changes. Town Economic Development Direc-tor Karen O’Connell said she and her colleagues were explor-ing establishing an Arts Overlay Zoning District, to help encour-age the link between the arts and the economy. She said they would be speaking to residents about it before making additional prog-ress, but that communities such as Somerville and Pittsfield had had good success with similar en-deavors.

Attorney Peter Zahka, speak-ing on behalf of East Dedham Plaza owner Anthony DeLapa, said his client was tentatively exploring making the plaza area into a mixed use, residential/commercial location. This is more challenging than building a new development, since the present tenants have to be accommodat-ed.

About five years ago, DeLapa had proposed changes to the Pla-za. “East Dedham wasn’t ready for it then,” Zahka said, “And neither was Dedham as a whole.”

He said the Dedham Square project had proven the town can take on such changes, and it was time to explore such an alteration in East Dedham. “And this has to be by East Dedham, for East Ded-ham. We have to build a feeling of cooperation between the groups forming and formed, and Mr. De-Lapa,” Zahka said.

He added that he wasn’t going into specifics on what DeLapa was thinking about at this point, since DeLapa was somewhat uncertain about the process. “One of the major death steps for this kind of thing is to present a drawing, and then throw darts at it. In that kind of a setting, I guarantee there’ll be positive ideas, but he’ll focus on the darts.”

Heisler said the goal was to host a much larger community meeting once there were more specific ideas and plans set up.

Hart added. “Speaking philo-sophically the Mother Brook Community Group does support mixed use development. If people live there, they’re more invested in the area, and there’s less van-dalism, and other improvements are made to the area.”

Mother Brook Community Group

Old Avery School to Be Put to New Uses

Massachusetts Bay Transportation AuthorityTen Park Plaza, Suite 3910, Boston, MA 02116

www.mbta.comLeading the Nation in Transportation Excellence

Community Meeting Notice

The MBTA will be holding a community meeting to discuss the final remedy and the Draft Response Action Outcome (RAO) document submittal for the Readville 5-Yard MCP Site. The Public will have an opportunity to ask questions and comment on the information presented.

The meeting will be held on Wednesday, March 6, 2013

@ 7:00 PM

Meeting location Community Room @ the Hyde Park Police Station,

1249 Hyde Park Avenue, Hyde Park (617) 343-5609

The meeting venue is accessible by public transportation and public parking is available. If assistive listening devices and/or interpreters are needed, please call 711(Massachusetts Relay Service) and request (617) 222-1984 (MBTA’s TDD/TYY). The requester is encouraged to call at least two business days before the community meeting.

We look forward to seeing you at the upcoming meeting. For further information on this project please contact Debra Darby by phone at (617) 222-3169 or by email at [email protected].

Massachusetts Bay Transportation AuthorityTen Park Plaza, Suite 3910, Boston, MA 02116

www.mbta.comLeading the Nation in Transportation Excellence

HelloCommunityMember:

ThisemailisareminderthattheMBTAwillbeholdingacommunitymeetingtodiscusstheimplementationofthefinalremedyandtheDraftResponseActionOutcome(RAO)documentsubmittalfortheReadville5‐YardMCPSite.Asyouknow,alloftheremediationatReadville5‐YardhasbeencompletedandtheRAOisadocumentthatdescribesalloftheworkperformedandthefinalconditionoftheproperty.Nowthatthisremediationhasbeencompleted,thismeetingonMarch6thisanticipatedtobethelastmeetingregardingtheReadvilleremediationproject.Communitymeetingswillbeheldontheproposedfutureuseoftheproperty.ThePublicwillhaveanopportunitytoaskquestionsandcommentontheinformationpresented.

Themeetingwillbeheldon:

Wednesday,March6,2013

@7:00PM

Meetinglocation:

CommunityRoom@theHydeParkPoliceStation1249HydeParkAvenue,HydePark

(617)343‐5609

Themeetingvenueisaccessiblebypublictransportationandpublicparkingisavailable.Ifassistivelisteningdevicesand/orinterpretersareneeded,pleasecall711(MassachusettsRelayService)andrequest(617)222‐1984(MBTA’sTDD/TYY).Therequesterisencouragedtocallatleasttwobusinessdaysbeforethecommunitymeeting.

Additionally,IwantedtoprovideyouwithanupdateofotherplanningactivitiescurrentlyunderwayforthefutureuseoftheReadville5‐Yardproperty,mostnotablythesolararraysbeingdevelopedontheDedhamportionoftheYardandthepossibleprivatedevelopmentbeingconsideredfortheBostonportionoftheYard.

UpdateontheMBTASolarProjectforReadvilleYard:

Asdescribedinearlieremails,theMBTAhasdevelopedplanstobuilda2.4megawatt(MW)solarphotovoltaic(PV)systemfortheDedhamportionoftheReadvilleYard.Thispastfall,theMBTABoardofDirectorsauthorizedtheMBTAtoenterintoanagreementwithGuerlicherSolarInternational,andtheirpartnerEnfinityInc.todevelopthePVsystems.FinalcontractsandrealestatelicenseswerethendevelopedwithGuerlicherandthecontractwasexecutedearlierthismonth.

GuerlicherwillnowdevelopdesignplansforthePVArrayandwillthenapplytothelocalutility(NStar)forthepermittointerconnectthearrayintotheregionalelectricalsystem.WeanticipatethatGuerlicherwillbeginconstructionofthearrayinlatesummer/earlyfallofthisyear.WewillcontinuetokeepthecommunityupdatedonthePVprojectandwillholdacommunitymeetingwithGuerlicheranditsengineersinattendancetopresenttheplansanditsconstructionactivities.WeanticipatethatacommunitymeetingwilloccurinMayorJuneofthis

year.Ifyouhaveanyquestionsaboutthissolarproject,pleasecontactMikeDonaghy,MBTA’[email protected]‐222‐1684.

UpdateonDevelopmentoftheBostonPortionoftheReadvilleYard:

TheMBTAcontinuestoplantosolicitprivatedevelopmentproposalsfortheBostonportionoftheReadvilleYard.ThedevelopmentwillbeconsistentwiththerecentlyenactedzoningandplanningproposalsfortheentireareathatwereissuedbytheBostonRedevelopmentAuthority(BRA).TheMBTA,anditspropertydevelopmentagent,TransitRealtyAssociates(TRA)aredevelopinganInvitationtoBid(ITB)forprivatedevelopment.WeareworkingwithBRAonthescopeandrequirementsofthatITBandanticipatethatitwillbereleasedlaterthisspring.WewillcontinuetocoordinateouractivitieswiththeBRAandothercityagencies,aswellaslocallyelectedofficialsandcommunityandneighborhoodgroupssoastokeepthecommunityinformedofourplans.

Ilookforwardtoseeingyouattheupcomingmeeting.Forfurtherinformationonthisprojectyoucancontactmebyphoneat(617)222‐[email protected].

PIP Meeting Notes Readville Yard 5 Phase IV Completion/RAO

March 6, 2013 Hyde Park Police Station

1249 Hyde Park Avenue Hyde Park, MA 02136-2891

1. Comment: A nearby resident with property abutting Area 1 of the Readville Yard 5 Site stated that she was told not to grow vegetables in her yard due to the high arsenic levels. Wondered whether that warning was warranted? Response: AECOM explained that very high arsenic levels were initially thought to be present in Area 1. However, further investigation indicated that this was actually due to an artifact in the field screening method used to estimate soil arsenic levels. Further investigations with laboratory analysis of soil samples indicated that the arsenic levels in Area 1 did not present a significant on-site risk. In addition, investigations have indicated that there has been no off-site migration of contamination. Therefore, the information that the abutting resident should not have a vegetable garden in her yard was incorrect.

2. Comment: Asked whether the deed restriction (Activity and Use Limitation – AUL) placed on the Readville Yard 5 property will eventually “go away”? Response: AECOM explained that the deed restriction follows the deed and is, therefore, a permanent restriction that will be passed along to future property owners. In addition, the MassDEP is proposing to enact means to enhance the visibility of deed restrictions to insure that future owners are aware of their existence.

3. Comment: Asked who would be using the solar power from the solar array to be built on the Dedham portion of the Readville Yard 5 Site? Response: Mike Donaghy, MBTA’s Manager of Energy Efficiency, explained that the MBTA has entered into a 20 year lease with a company that will construct a solar array on the Dedham portion of the Readville Yard 5 Site. The electrical power generated will enter the NStar grid and will be used for the MBTA’s numerous accounts with NStar. As such, the MBTA will use the generated electricity.

4. Comment: Asked if the Readville Yard 5 Site could later be developed for non-commercial purposes such as residential? Response: AECOM explained that the deed restriction placed on the property does not allow residential use. If the property is to be used for non-commercial/industrial purposes such as residential, further remediation would need to be conducted before the deed restriction could be revised or cancelled. With current technology, the remediation will likely involve further excavation of soils until the average soil concentrations at the Site to levels that allow residential use where young children could potentially be exposed to contaminants in soil.

5. Comment: Asked why no solar on Boston side of the Readville Yard 5 Site? Who at Boston “rejected” use of this portion of the Site for a construction of a solar array like in Dedham? Response: Mark Boyle, from MBTA’s real estate development division, stated that the Boston portion of the Site is zoned commercial/industrial and that re-development of the Boston portion of the Site will be done in accordance with recent zoning/planning proposals. The City of Boston zoned this portion of the property commercial/industrial in order to generate revenue from property taxes and placement of a solar array would not generate any tax revenue (Dedham does not get tax revenue from the solar array to be placed on that portion of the Site.). Zoning the Boston portion of the Site as commercial/industrial will also allow for creation of jobs and no jobs will be generated on the Dedham side with the placement of the solar array. In addition, selling the Boston portion of the Readville Yard 5 Site is expected to provide several million dollars to the MBTA.

AECOM 978.905.2100 tel

250 Apollo Drive 978.905.2101 fax

Chelmsford, MA 01824

J:\Concord\105627 - MBTA\PROJ\TO-1 Readville\RAO\Report\Appendices\Appendix C - AUL\Public Notification\AUL Public Notices Boston and Dedham Offices.docx

March 20, 2013 Dr. Barbara Ferrer Executive Director Boston Public Health Commission 1010 Massachusetts Avenue Boston, MA 02118 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Dr. Ferrer, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of the Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Suffolk County Registry of Deeds on February 26, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment cc: Massachusetts Department of Environmental Protection

AECOM 978.905.2100 tel




March 20, 2013 Mayor Thomas Menino Boston City Hall One City Hall Square, Suite 500 Boston, MA 02201 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mayor Menino, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Suffolk County Registry of Deeds on February 26, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts Department of Environmental Protection

AECOM AECOM 978.905.2100 tel




March 20, 2013 Mr. Jeff Hampton Zoning Commission City of Boston 1010 Massachusetts Avenue, 4th Floor Boston, Massachusetts 02118 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mr. Hampton, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Suffolk County Registry of Deeds on February 26, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts DEP





March 20, 2013 Mr. Bryan Glascock, Acting Commissioner Inspectional Services Department City of Boston 1010 Massachusetts Avenue, 4th Floor Boston, Massachusetts 02118 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mr. Glascock, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Suffolk County Registry of Deeds on February 26, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts DEP

AECOM 978.905.2100 tel




March 20, 2013 Mr. William Keegan Town Administrator Town of Dedham 26 Bryant Street Dedham, MA 02026 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mr. Keegan, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Norfolk County Registry of Deeds on February 27, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts DEP





March 20, 2013 Mr. Jim Sullivan Code Enforcement Officer Town of Dedham 26 Bryant Street Dedham, MA 02026 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mr. Sullivan, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Norfolk County Registry of Deeds on February 27, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts DEP





March 20, 2013 Ms.Catherine Cardinale, Health Director Board of Health Town of Dedham 26 Bryant Street Dedham, Massachusetts 02026 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mr. McGrail, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Norfolk County Registry of Deeds on February 27, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts DEP





March 20, 2013 Mr. Richard McCarthy, Jr., Planning Director Planning and Zoning Office City of Dedham 26 Bryant Street Dedham, Massachusetts 02026 Subject: Notice of Document Availability MBTA Readville Yard Industrial Drive, Boston and Dedham, Massachusetts DEP Release Tracking No.:3-2856 Dear Mr. McCarthy, Pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40. 1403(7)(a), AECOM is providing you with a copy of a Notice of Activity and Use Limitation (AUL) for the above-referenced property. The Notice of AUL (Attachment A) was recorded at the Norfolk County Registry of Deeds on February 27, 2013. If you have any questions regarding this matter please contact Elissa Brown at 978.905.2100. Sincerely yours, Elissa Brown, LSP Program Manager Attachment Cc: Massachusetts DEP



Appendix C Activity and Use Limitation

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