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  INDUSTRI-PLEX


Map this site in Cleanups in My Community
 North Woburn,  Massachusetts
 Middlesex County
 Street Address: Commerce & Atlantic
 Zip Code: 01801
 Congressional
 District(s):

07
 EPA ID #: MAD076580950
 Site ID #: 0100580
 Site Aliases: Mark Phillip Trust, Woburn Site, Industri-Plex 128 Site

 Site Responsibility: Federal, Potentially Responsible Parties

 NPL LISTING HISTORY
 Proposed Date 10/23/1981
 Final Date 09/08/1983

Site Description
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The Industri-Plex Superfund Site is a former chemical and glue manufacturing facility. Industri-plex was used for manufacturing chemicals such as lead-arsenic insecticides, acetic acid, and sulfuric acid for local textile, leather, and paper manufacturing industries from 1853 to 1931. Chemicals manufactured by other industries at the site include phenol, benzene, and toluene. Industri-plex was also used to manufacture glue from raw animal hide and chrome-tanned hide wastes from 1934 to 1969. The by-products and residues from these industries caused the soils within the site to become contaminated with elevated levels of metals, such as arsenic, lead and chrome. During the 1970s, the site was developed for industrial use. Excavations uncovered and mixed industrial by-products and wastes accumulated over 130 years. During this period, residues from animal hide wastes used in the manufacture of glue were relocated on-site from buried pits to piles near swampy areas on the property. Many of the animal hide piles and lagoons on-site were leaching toxic metals into the environment. In the 1980's, the site contained streams and ponds, a warehouse and office buildings, remnant manufacturing buildings, and hide waste deposits buried on the site. Animal hide residues are found on approximately 20 acres of the site in four different piles. Portions of the animal hide piles sloughed off, causing the release of hydrogen sulfide gases to the atmosphere and toxic metals to surrounding wetlands. Residences are located within 1,000 feet of the site, and more than 34,000 people live within 3 miles of the site.

Threats and Contaminants
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The groundwater is contaminated with volatile organic compounds (VOCs) including benzene and toluene, as well as ammonia and metals such as arsenic. The soil is contaminated with heavy metals including arsenic, chromium, and lead. Also, a pervasive "rotten egg" odor has been caused by hydrogen sulfide gas generated by the decay of the buried animal hides from glue manufacturing wastes. People who accidentally ingest or come into contact with contaminants may be at risk. The potential exposure most likely is limited to trespassers and workers on the site during future construction. The contaminated groundwater has the potential to migrate towards two Woburn municipal drinking wells, which are currently inactive. Wetlands near the site are threatened by site run-off.

Cleanup Approach
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The site is being addressed in three stages: initial actions and two long-term remedial phases focusing on site stabilization and cleanup of groundwater contamination.

Response Action Status
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Initial Action In 1986, the EPA installed 10,000 feet of fence to restrict site access. Extensive damage to the main areas of the fence occurred, and drums were dumped illegally on the site. Areas of the fence requiring repairs were identified by the EPA, and work to re-secure the site was completed in 1988. Warning signs also were posted.

Site Stabilization In 1986, the EPA selected a cleanup remedy that is being implemented by the potentially responsible parties (PRPs). The remedy includes the following: 1) Design and construct permeable caps over approximately 105 acres of soils and sediments contaminated with lead, arsenic, and chromium in excessive levels of 300 parts per million (ppm), 600 ppm, and 1000 ppm, respectively. The permeable caps may consist of various designed covers containing 16 inches of clean fill and a geotextile fabric placed over the contaminated soils and sediments, as well as equivalent covers such as concrete foundations or bituminous parking lots. This portion of the remedy serves to prevent physical contact with the contaminated soils and sediments, including the West, East-Central and South Hide Piles; 2) Design and construct an impermeable cap over the approximately 5 acres of East Hide Pile, and gas collection and treatment system. This portion of the remedy serves to prevent the infiltration of water through the hide pile, and prevent the release of hydrogen sulfide gas into the atmosphere; 3) Design and construct an interim groundwater treatment system to treat a groundwater hot spot contaminated with toluene and benzene. This interim system is designed to reduce the concentration of the hot spot by eighty percent and limit contamination migration off-site; 4) Conduct a Groundwater and Surface Water Investigation Plan (GSIP) to evaluate the degree of groundwater and surface water contamination from the site; and 5) Design and implement Institutional Controls for the site which will restrict future land use. The purpose of the Institutional Controls is to preserve the effectiveness of the remedy, so that human health and the environment remains protected, and allow each property owner the fullest possible use of their property.
The PRPs began designing the cleanup remedies in 1989. Design of the site permeable and impermeable cap was finalized in 1992. Construction of the permeable and impermeable cap began in 1993. Currently, the impermeable cap, gas collection and treatment system, and the permeable cap are complete. Cover certification reports, which document the proper installation of the protective caps, remain to be completed for all the properties on the Site. The design of the interim groundwater treatment system was completed initially in the fall of 1992; however, the system was altered to reflect changes resulting from a pilot air sparging design in 1993. The pilot air sparging system was designed and operational for a short period in the summer of 1994, when it was discovered that the system failed to meet the design standards and shut down. No other groundwater treatment has occurred at the Site. In the early 1990's, the PRPs conducted two phases of the GSIP. Between 1999 and 2004, the PRPs implemented an EPA approved comprehensive third/ Final GSIP investigation (see below). In 1995, EPA established a working group for the institutional controls consisting of state, landowner, and potentially responsible party representatives, and the group established a draft outline. During the late 1990s and early 2000s, EPA and the State coordinated with the PRPs over the institutional control design's consistency with the working group's outline, as well as the new Massachusetts Contingency Plan Activity and Use Limitations (AULs) format. In August 2002, EPA and the State released the draft institutional controls design to the landowners and the PRPs, and provided a presentation in September 2002. In April 2005, EPA responded to the public comments received on the draft institutional controls design and released Draft Grant of Environmental Restrictions & Easements Design (institutional controls design) to the landowners and the PRPs. A copy of the Grant is attached below under "Other Links".

As of September 30, 2008, the PRPs documented the completion of the soil, sediment and air portions of the Industri-plex Operable Unit 1 (OU1) remedial action through the preparation of a Master Cover Certification Report, as well as 34 property-specific Cover Certification Reports within Industri-plex OU1. EPA provided a copy of the property-specific Cover Certification Reports to each property owner. Additional copies are maintained at the Woburn Public Library and EPA's Record Center located at One Congress Street, Boston, MA. Electronic copies of these Cover Certification Reports are available below under the "Links to Additional Information", "Studies and Reports" at the "Cover Certification Reports for Operable Unit 1" link, where an interactive map and address table can be used to retrieve a property-specific report. Currently, EPA, State, and the PRPs are focused on the requirements for inaugurating and recording the Grant of Environmental Restrictions and Easements on each property, especially deed drawing and clear title requirements.

In 1990, the potentially responsible parties began the GSIP investigation into the nature and extent of the site-related groundwater, surface water and sediment contamination. The potentially responsible parties completed two investigations and prepared a GSIP Phase 1 and 2 Report. In the Fall of 1998, EPA completed negotiations with the potentially responsible parties for a more comprehensive investigation. The potentially responsible parties agreed to implement a comprehensive investigation, entitled the Final GSIP, which investigates the extent of site-related metals and organics contamination in groundwater, surface water, and sediments, and evaluates any environmental and human health risks posed by the contamination from Industri-Plex Site to Route 128. Between 1999 and 2004, the potential responsible parties (PRPs) completed Final GSIP sample collection and analysis. However, in June 2003, the PRPs declined to conduct the human health and ecological risk assessments under the Final GSIP. As a result, EPA prepared the baseline risk assessment, which was documented in Appendix 6 and 7 of the March 2005 Industri-Plex OU-2 (including Wells G&H OU-3) MSGRP Remedial Investigation, as described further below.

All the above "Site Stabilization" response action is associated with Industri-plex Operable Unit 1 under the 1986 Record of Decision and 1989 Consent Decree, which are attached below under "Decision Documents" and "Settlement Documents" links.


Groundwater Contamination Under the 1986 Record of Decision (ROD), EPA is required to conduct a Multiple Source Groundwater Response Plan (MSGRP) which serves as a second operable unit (OU-2) for the Industri-plex Superfund Site. The MSGRP was required to investigate other potential contamination impacts on the area wide aquifer, and determine if additional remedies may be necessary to clean up the aquifer within the Industri-Plex Study Area. The MSGRP will incorporate the potentially responsible parties' GSIP data (described above), and serve as a comprehensive Remedial Investigation/Feasibility Study (RI/FS) supporting a future ROD for the aquifer and any residual surface water and sediment contamination within the Industri-Plex Study Area. In 1997, the EPA prepared a Preliminary MSGRP Report based upon existing analytical data. In August 1998, EPA prepared a Historical Aerial Photographical Analysis of the Industri-Plex Study Area, illustrating property use and watershed changes since 1938. In 1999, EPA also evaluated the preliminary surface water and sediment data collected along the Aberjona River from Route 128 south (downstream) to the Mystic Lakes under the Wells G&H Operable Unit 3 (OU-3), Aberjona River Study Baseline Risk Assessment. The Wells G&H Superfund Site is located to the south of Route 128, immediately downstream of the Industri-Plex Study Area. The two Superfund sites are hydraulically connected by the Aberjona River, which begins in Reading, flows south through the Industri-Plex Site, under Route 128, through Wells G&H Site, and continues south eventually discharging into the Mystic Lakes. The Aberjona River Study (downstream of Route 128) data indicates the primary contaminants of concern in the surface water and sediments are metals, similar to contaminants found north of Route 128. Based upon this information, EPA decided to merge the Wells G&H OU-3, Aberjona River Study data, with the Industri-Plex OU-2 MSGRP data, and form one comprehensive RI/FS for the entire river system from the Industri-Plex Site to the Mystic Lakes (approximately 6 miles of river). In 2002, EPA completed a Historical Aerial Photographical Analysis of the Aberjona River Study Area from Salem Street, Woburn, to the Mystic Lakes. In September 2004, EPA completed the Wells G&H OU-3 Revised Aberjona River Study Baseline Risk Assessment, which identifies potential human health and ecological risks along Wells G&H 38 acre wetland (River Reach 1) and the former Cranberry Bog (portion of River Reach 2) immediately south of the Wells G&H Site due to potential exposures to sediments contaminated with metals (e.g. arsenic). See Wells G&H Site NPL Fact Sheet for additional information.
In March 2005, EPA completed the Industri-Plex OU-2 (including Wells G&H OU-3) MSGRP RI. This comprehensive RI describes the contamination and risks along the Halls Brook Holding Area (HBHA) and Aberjona River from Industri-Plex Site to the Mystic Lakes, and how contamination is migrating along the river system. The March 2005 RI merged and refined the baseline risk assessments from Industri-plex to the Mystic Lakes along the Aberjona River. The following summarizes the baseline risks presented to the public and environment: Arsenic and benzene (as well as ammonia) plumes beneath the Industri-plex OU-1 Superfund Site boundary (groundwater) may cause future health risks to people who might come in contact with the water (future industrial/ commercial/ construction worker) within Reach 0; Arsenic and benzene (as well as ammonia) plumes from Industri-plex OU-1 contribute to significant environmental risks in the HBHA Pond sediment and deep surface water within Reach 0; High concentrations of arsenic in both surface and deep soils in the Former Mishawum Lake Bed area may cause future health risk to people who come in contact with the soils within Reach 0; High concentrations of arsenic in shoreline sediments in three distinct areas along the Wells G&H Wetland and Cranberry Bog Conservation Area present a current and/or future health risk to people recreating along the shoreline (east side of the 38 acre Wells G&H wetland within Reach 1 near former production well H, west side of the 38 acre Wells G&H wetland within Reach 1 near the railroad tracks and Olympia Source Area Property, and west-central area of the Cranberry Bog Conservation Area within upper Reach 2); and High concentrations of arsenic in deeper interior wetland sediments presents a future risk to people who might come in contact with the sediments (future dredger/ construction worker) within Reach 0 and 1.

In June 2005, EPA prepared and released the Industri-plex OU-2 (including Wells G&H OU-3) Feasibility Study, and Proposed Plan. Public comment period was held and extended from July 1, 2005 - August 31, 2005. In October, EPA prepared and released a Technical Memorandum - Evaluation of Ammonia and Supplemental Soil Data, a Fact Sheet Supplementing the June 2005 Proposed Plan, and re-opened the public comment period from October 20, 2005 to November 18, 2005. Copies of all the above documents are attached below under the "Reports and Studies" links.

On January 31, 2006, EPA prepared and released Industri-plex OU-2 Record of Decision. The major components to the Industri-plex OU-2 remedy include:

• Dredging and off-site disposal of contaminated sediments in the southern portion of the HBHA Pond; dredging and off-site disposal of contaminated near shore sediments at the Wells G&H Wetland and Cranberry Bog Conservation Area; and restoration of all disturbed areas. This component will address sediments posing unacceptable human health risks for near shore sediments and unacceptable ecological risks for the southern portion of HBHA Pond.

• Use of the northern portion of HBHA Pond as a sediment retention area (primary and secondary treatment cells) that will intercept contaminated groundwater plumes (including arsenic, benzene, ammonia, 1,2-dichloroethane, trichloroethene, naphthalene) from Industri-plex OU-1, treat/sequester contaminants of concern (including arsenic, benzene, ammonia), and minimize downstream migration of contaminants (including arsenic, benzene, ammonia). The primary treatment cell will intercept the contaminated groundwater plumes discharging in the HBHA Pond. The effluent from northern portion of the HBHA Pond (secondary treatment cell outlet) will serve as the surface water compliance boundary, and achieve National Recommended Water Quality Criteria (NRWQC). Sediments which accumulate in the northern portion of the HBHA Pond will be periodically dredged and sent off-site for disposal. Portions of storm water from Halls Brook, which may interfere with the natural treatment processes occurring within the northern portion of the HBHA Pond, will be diverted to the southern portion of HBHA Pond.

• If necessary, In-situ Enhanced Bioremediation of contaminated groundwater plumes (e.g., benzene) at the West Hide Pile (WHP).

• Construction of an impermeable cap to line stream channels (e.g. New Boston Street Drainway), and to prevent the discharge of contaminated groundwater plumes, contamination of stream sediments, downstream migration of contaminants of concern, and potential impacts to other components of the selected remedy.

• Construction of a permeable cap to prevent contaminated soil erosion (e.g. Area A6), downstream migration of contaminants of concern, and potential impacts to other components of the selected remedy.

• Establishing institutional controls to restrict contact with soils, groundwater, or deeper interior wetland sediments with concentrations above cleanup standards and protect the remedy.

• Construction of compensatory wetlands for any loss of wetland functions and values associated with the selected remedy (e.g. northern portion of HBHA Pond, Halls Brook storm water by-pass, capped stream channels) nearby in the watershed.

• Long-term monitoring of the groundwater, surface water, and sediments, and periodic Five-year Reviews of the remedy.

All the above "Groundwater" response actions are associated with Industri-plex Operable Unit 2 under the 2006 Record of Decision, which is attached below under "Decision Documents" links.


Enforcement HighlightsIn 1979, in response to illegal filling of wetlands, the EPA obtained a court order to stop further development activities. The EPA and the State entered into a Consent Order with Stauffer Chemical in 1982, whereby Stauffer was to conduct an investigation and recommend cleanup actions. In 1989, the EPA and the potentially responsible parties signed a Consent Decree in which the parties agreed to implement the remedy (Industri-plex OU-1 under the 1986 ROD) for stabilizing the site and to reimburse the EPA for past and future oversight costs. In 1998, EPA successfully negotiated with the PRPs to comply with the Consent Decree and implement the Final GSIP.
In September 2006, EPA issued special notice letters to potentially responsible parties for the cleanup of Industri-plex OU-2 (in accordance with the January 2006 ROD). On February 27, 2008, EPA and the US Department of Justice announced the Lodging of a proposed Consent Decree with Pharmacia, Inc. and Bayer CropScience, Inc. for them to design, construct, and maintain this remedy. On Novemer 24, 2008, the U.S. District Court entered the Industri-plex OU-2 Consent Decree.

Environmental Progress
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Fencing and posting warning signs around the site have restricted access to the Industri-Plex site and made it safer while final cleanup activities continue. Upon completion of the final cleanup remedies, the soil and groundwater contamination levels at the Industri-Plex site will be reduced to meet established health and ecological standards. At the same time remediation has been proceeding, significant portions of the site are being developed or redeveloped for economic reuse. The Custodial Trust (a trust created by EPA, DEP, and the potentially responsible parties in the 1989 Consent Decree to hold, manage and sell developable property on the site), EPA, and the potentially responsible parties have worked with state, local governments, prospective purchasers, and developers to establish some commercial re-development on the site. In 1996, EPA modified the permeable cap design for a 36 acre portion of the site to accommodate the construction of a 2,400 vehicle Regional Transportation Center (RTC) on the site. Implementation of the design modification will improve the protectiveness of the remedy by increasing the depth of the permeable cap's clean fill to approximately 48 inches, including an asphalt parking lot. The RTC will also facilitate compliance with the Clean Air Act by removing 2,400 vehicles from the interstate and reducing vehicle air emissions in the metropolitan Boston area. The construction of the alternative RTC design cap was completed in early 1997. EPA has entered into five Prospective Purchaser Agreements (PPA) with purchasers of five different parcels on the site, which protect those parties from Superfund liability related to the existing environmental conditions.

The first PPA was entered in 1996 with Vining Disposal, Inc. (Vining), for a property that had already been developed. Since the property sale, Vining has been operating a recycling center at the property. A second PPA was entered in December 1996, with the Massachusetts Port Authority (MPA), Massachusetts Bay Transportation Authority (MBTA), and Massachusetts Highway Department (MHD) for the RTC 36 acre property. This PPA required the parties to construct the above alternative RTC Design cap, adhere to the institutional controls for the site, and provide access for any future Superfund activities. The RTC construction is expected to be completed in Spring 2001. A third PPA was entered in 1997, with a prospective purchaser for a 29.6 acre (19.0 buildable acres) retail property on the site. On December 12, 1997, Dayton-Hudson Corporation purchased the retail property, and Target Stores will anchor the property's retail development. Construction of the Target Store paralleled the construction of MHD's new Interstate 93 (I-93) interchange and the City of Woburn's Commerce Way Extension and Improvements. In October 2000, construction was completed and Target Stores, I-93 Interchange and Commerce Way Extension were open to the public. The I-93 Interchange and Commerce Way Extension will help to alleviate traffic congestion at the intersection of I-93 and I-95, improve traffic conditions in the City of Woburn, and provide access to the RTC. A fourth PPA was entered in August 1999, with 100 Metro-North Corporation (affiliate of National Development of New England, Inc.) for approximately 50 acres on the Site. The parcel will be developed for commercial office park (anchored by Raytheon Corporation), hotel (Residence Inn - Marriott), and restaurant use. The fifth PPA was entered in March 2000, with Transcom, Inc. (Transcom), for 2 acres of property that had already been developed. Transcom is expected to use the property's building and parking lot for its business operations. Transcom began its operations in the Summer 2000.

All proposed developments within the boundaries of the Site, that could potentially effect the remedy, were required to submit construction specifications, work plans, health and safety plans, in accordance with the Consent Decree and Grant of Environmental Restrictions and Easements Design (institutional controls). EPA reviewed and approved these development documents and conducted periodic oversight of significant intrusive construction activities.

Current Site Status
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By early 1998, approximately 110 acres of the site are covered with a protective cap to prevent human exposures to soils contaminated with metals (e.g. arsenic, lead and chromium) in accordance with the 1986 ROD (Industri-plex OU-1). Portions of the site have been redeveloped for a multi-modal Regional Transportation Center, Interstate-93 Interchange, public road extension, Target Stores, and Metro-North Office Park including Raytheon and Residence Inn - Marriott. In March 2005, EPA and MassDEP completed the design of Industri-plex OU-1 Institutional Controls consistent with MassDEP's Grant of Environmental Restrictions and Easements (GERE) format (see "Other Links" below for March 2005 GERE). In September 2008, EPA approved final Industri-plex OU-1 Cover Certification Reports for 31 properties/tax maps within the boundaries of OU-1 that describe and illustrate the cleanup remedy implemented on each property. Specific OU-1 cleanup information on any individual property may be accessed through an interactive OU-1 map/address link below (see "Reports and Studies" below for OU-1 Cover Certification Reports). In addition, specific post remedy information (known as As Built Records) on OU-1 individual properties consistent with the Institutional Controls design can be accessed through a similar interactive map/address link below (see "Reports and Studies" below for OU-1 As Built Records). Collectively, the Institutional Controls design and various interactive map links should help maintain landowners, prospective purchasers, community and city officials awareness of the cleanup remedy implemented on each OU-1 property and associated restricted activities and uses.

In January 2006, EPA released the Industri-plex OU-2 ROD. In September 2006, EPA issued special notice letters to parties for the cleanup of Industri-plex OU-2. On February 27, 2008, EPA and the US Department of Justice announced the Lodging of a proposed Consent Decree with Pharmacia, Inc. and Bayer CropScience, Inc. for them to design, construct, and maintain this remedy. On November 24, 2008, the U.S. District Court entered the Industri-plex OU-2 Consent Decree. In January 2009, EPA approved the Industri-plex OU-2 Surface Water Monitoring Plan. On March 24, 2011, EPA approved the Industri-plex OU-2 Remedial Design Work Plan. Currently, the Industri-plex OU-2 Settling Defendants are implementing pre-design field investigations with EPA Oversight.

Site Photos
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SDMS 452921
Before, Industrial remnants ...

SDMS 452922
After, Regional Transportation Center.

Links to Other Site Information
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Disclaimer Instructions about PDF

Newsletters & Press Releases:
Press Releases about this project  
EPA Releases Draft Baseline Human Health Risk Assessment for the Aberjona River Study Area, Spring 2003 (887KB)  
Aberjona River Study Ecological Risk Assessment, June 2003 (2,424KB)  
EPA Releases Revised Baseline Risk Assessment for the Aberjona River Study Area, October 2004, (729KB)  
Aberjona River Study Comprehensive Multiple Source Groundwater Response Plan Remedial Investigation, April 2005 (3,797KB)  
Public Meeting Presentation on Proposed Plan for Second Public Hearing, Operable Unit 02 Including Wells G&H Operable Unit 03, November 17, 2005 (2.26 MB)  
EPA Merges Two Aberjona River Studies, Spring 2002  

Federal Register Notices:
Final NPL Listing  

Administrative Records:
Administrative Record File for the Record of Decision (ROD), Operable Unit 02 and Including Wells G & H Operable Unit 03, January 31, 2006 (index with links to 117 AR documents)  

Reports and Studies:
Technical Reports and Studies  
Baseflow Surface Water Monitoring Reports  
Stormflow Reports  
Superfund Redevelopment Success, Operable Unit 01, July 1998 (12.67 MB)  
EPA Responses to Comments on the June 2003 the Aberjona River Study, Baseline Human Health and Ecological Risk Assessment, June 28, 2004 (2,778KB)  

Decision Documents:
View Records of Decision (RODS) on-line (EPA HQ)  
Record of Decision, September 30, 1986 (1,717 KB)  
Proposed Plan, Operable Unit 2, June 2005 (2.2 MB)  
Record of Decision, Operale Unit, 2, January 31, 2006 (22.5 MB)  

Settlement Documents:
Consent Decree for Remedial Design/Remedial Action at Referral, September 22, 1988 (1,709 KB)  
Consent Decree Civil Action No. 1:08-CV-10325, November 24, 2008 (19.4 MB)  

Other Links:
NPL Site Narrative at Listing:  
Site Progress Profile  
Superfund Redevelopment Case Study  
Grant of Environmental Restriction and Easement, Draft March 12, 2005 (756 KB)  
Grant of Environmental Restriction and Easement - 112 Commerce Way, November 9, 2009 (6.67 MB)  
Grant of Environmental Restriction and Easement - 30 Atlantic Avenue, April 27, 2011 (6.52 MB)  
Institutional Controls Inauguration Plan for OU1 Grants of Environmental Restriction and Easement (GEREs), October 12, 2011(1.30 MB)   

Site Repositories
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Woburn Public Library, 45 Pleasant Street, Woburn, MA 01801
(781) 933-0148

OSRR Records and Information Center, 1st Floor, 5 Post Office Square, Suite 100 (HSC), Boston, MA 02109-3912 (617) 918-1440


Contacts
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EPA Remedial Project Manager: Joseph LeMay
Address: US Environmental Protection Agency
5 Post Office Square, Suite 100
Mail Code OSRR07-4
Boston, MA 02109-3912
Phone #: 617-918-1323
E-Mail Address: lemay.joe@epa.gov

EPA Community Involvement Coordinator: Emily Zimmerman
Address: US Environmental Protection Agency
5 Post Office Square, Suite 100
Mail Code ORA01-1
Boston, MA 02109-3912
Phone #: 617-918-1037
E-Mail Address: zimmerman.emily@epa.gov

 


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