PB95-963706
EPA/ROD/R01-95/106
March 1996
EPA Superfund
Record of Decision:
Fort Devens Sudbury Training Annex,
Source Control Operable Unit, MA
9/29/1995
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RECORD OF DECISION
SOURCE CONTROL OPERABLE UNIT
AOC A7, THE OLD GRAVEL PIT LANDFILL
AOC A9, THE POL BURN AREA
FORT DEVENS SUDBURY TRAINING ANNEX
MIDDLESEX COUNTY, MASSACHUSETTS
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DECISION SUMMARY FOR THE RECORD OF DECISION
AOC A7, The Old Gravel Pit Landfill
AOC A9, The POL Bum Area
Fort Devens Sudbury Training Annex
Middlesex County, Massachusetts
TABLE OF CONTENTS
Contents Page Number
DECLARATION FOR THE RECORD OF DECISION ........................ i
I. SITE NAME, LOCATION AND DESCRIPTION ............................ 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES ........................ 2
A. Land Use and Response History ....................... . ......... .... 2
B. Enforcement History ............................................ 3
in. COMMUNITY PARTICIPATION ...................................... 3
IV. SCOPE & ROLE OF OPERABLE UNIT OR RESPONSE ACTION ................ 4
V. SUMMARY OF SITE CHARACTERISTICS .......................... '. ____ 4
VI. SUMMARY OF SITE RISKS ......................................... 6
VH. DEVELOPMENT AND SCREENING OF ALTERNATIVES ................... 11
A. Statutory Requirements/Response Objectives ............................ 11
B. Technology and Alternative Development and Screening .................... 11
Vffl. DESCRIPTION OF ALTERNATIVES .................................. 12
DC. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES ......... 15
X. THE SELECTED REMEDY ......................................... 19
A. Cleanup Levels ............................................... 20
B. Description of the Remedial Components .............................. 20
XI. STATUTORY DETERMINATIONS ................................ ... 22
A. The Selected Remedy is Protective of Human Health and the Environment ........ 22
B. The Selected Remedy Attains ARARs ................................ 22
C. The Selected Remedial Action is Cost-Effective .......................... 24
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies
to the Maximum Extent Practicable ........... . ..... r ................ 25
E. The Selected Remedy Does Not Satisfy the Preference for
Treatment which Permanently and Significantly Reduces the
Toxicity, Mobility, or Volume of die Hazardous Substances as
a Principal Element .................. .............. . ........... 26
. DOCUMENTATION OF NO SIGNIFICANT CHANGES ..................... 26
. STATE ROLE .................................................. 26
XIV. REFERENCES .............. ................ ........ . .......... - 26
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DECISION SUMMARY FOR THE RECORD OF DECISION
AOC A7, The Old Gravel Pit Landfill
AOC A9, The POL Burn Area
Fort Devens Sudbury Training Annex
Middlesex County, Massachusetts
TABLE OF CONTENTS rContinued't
APPENDIX A - RISK ASSESSMENT TABLES
APPENDIX B - RESPONSIVENESS SUMMARY
APPENDIX C - ARARs TABLES
APPENDDC D - ADMINISTRATIVE RECORD INDEX
APPENDIX E - STATE LETTER OF CONCURRENCE
LIST OF FIGURES
FIGURE 1 FORT DEVENS SUDBURY TRAINING ANNEX AOCs A7 AND A9
FIGURE 2 FEATURES AND CONTAMINANTS OF CONCERN, AOCs A7 AND A9
FIGURES THE SELECTED REMEDY: EXCAVATION, OFF-SITE DISPOSAL, WASTE
CONSOLIDATION, AND CAPPING
FIGURE 4 RCRA SUBTITLE C LANDFILL CAP
LISTJ5F ACRONYMS
AOCs
ARARs
AWQC
BNAs
CERCLA
CFR
CMR
DDD
DDE
DDT
FFA
FR
FS
HHRA
HI
Areas of Contamination
Applicable or Relevant and Appropriate Requirements
Ambient Water Quality Criteria
Base/neutral/acid extractable compounds
Comprehensive Environmental Response, Compensation and Liability Act
Code of Federal Regulations
Code of MftBKH"f*"« Regulations
DicUorod^henyldichloroemane
Dichlorodiphenyletfaane
Dichlorodiphenyltrichloroethane
Federal Facility Agreement
Federal Register
Feasibility Study
Human Health Risk Assessment
Hazard Index
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LIST OF ACRONYMS
(CONTINUED)
HWR
IAG
IRP
LDRs
MADEP
MFFA
MCP
MOM
NCP
NPL
OHM
O&M
PA
PAHs
PCBs
POL
RAOs
RCRA
RI
RfD
ROD
SA
SARA
SC
SI
SI/RI
TBCs
TCLP
TOC
TRC
UBK
USAEC
USEPA
UST
VOCs
Hazardous Waste Rules
Imeragency Agreement
Installation Restoration Program
Land Disposal Restrictions
Massachusetts Department of Environmental Protection
Massachusetts Fire Fighting Academy
Massachusetts Contingency Plan
Management of Migration
National Contingency Plan
National Priority List
OHM Remediation Services Corp.
Operation and Maintenance
Preliminary Assessment
Polynuclear Aromatic Hydrocarbons
Polychlorinated Biphenyls
Petroleum, Oil and Lubricants
Remedial Action Objectives
Resource Conservation and Recovery Act
Remedial Investigations
Reference Dose
Record of Decision
Study Area
Superfund Amendments and Reauthorization Act
Source Control
Site Investigation
Site Investigation/Remedial Investigation Report
To Be Considered
Toxicity Characteristic Leaching Procedure
Total Organic Carbon
Technical Review Committee
Uptake/Biokinenc (Model)
U.S. Army Environmental Center
U.S. Environmental Protection Agency
Underground Storage Tank
Volatile Organic Compounds
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
AOC A7, the Old Gravel Pit Landfill
AOC A9, the POL Bum Area
Fort Devens Sudbury Training Annex
Middlesex County, Massachusetts
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) document presents the selected source control (SC) remedial action at areas
of contamination (AOCs) A7 and A9 at the Fort Devens Sudbury Training Annex (Annex), Middlesex
County, Massachusetts. This decision document was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan. Through this document, the U.S.
Army (Army) plans to remedy, on a permanent basis through excavation, off-site disposal, waste
consolidation, and landfill capping, the potential threat to human health, welfare, or the environment posed
by contaminated soil and solid waste at AOCs A7 and A9. This decision is based on information contained
in the Administrative Record which has been developed in accordance with CERCLA 113(k). Copies of
the Administrative Record are located at the Fort Devens Library, and at the Sudbury Town Hall, 322 Old
Concord Road, in Sudbury, Massachusetts.
The State of Massachusetts Department of Environmental Protection (MADEP) concurs with the selected
remedy. A copy of the state's declaration of concurrence letter is included in Appendix E.
Although additional investigations to fill existing data gaps are required for the ground water operable unit,
preliminary management of migration (MOM) remedial alternatives have been developed and are presented
in the Feasibility Study (FS) (OHM, 1995a). A subsequent ROD will be issued to address the final MOM
remedy for AOCs A7 and A9.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from AOCs A7 and A9, if not addressed by
implementing die SC remedy selected in this ROD, may present an imminent and substantial endangerment
to public health, welfare; or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy addresses SC at AOCs A7 and A9. After collection of additional data, a MOM
remedy for me groundwater operable units at AOCs A7 and A9 will be developed. The potential direat
of contaminated groundwater to human health is not immediate because groundwater at or downgradient
from AOCs A7 and A9 is not currently used as a drinking water source. The selected remedy addresses
remediation of die source of contamination at AOCs A7 and A9 by eliminating or reducing the risks posed
by the presence of the landfill at AOC A7 and die contaminated soils at AOC A9.
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The major components of the selected remedy for AOCs A7 and A9 include:
Excavation and off-sice treatment and disposal of laboratory waste at AOC A7
Excavation of contaminated soil from AOC A9 and consolidation at AOC A7
Consolidation of contaminated soil and solid waste at AOC A7 to within the limits of the
landfill cap
Construction of a Resource Conservation and Recovery Act (RCRA) Subtitle C landfill cap
at AOC A7
Environmental monitoring and operation and maintenance (O&M) at AOC A7
Institutional controls at AOC A7 to limit future site use and to restrict site access
Five-year reviews at AOC A7.
Excavated materials from other areas on the Annex may be used at AOC A7 for fill material to meet the
subgrade design specifications for the AOC A7 landfill cap. Before material from other sites can be used
as subgrade material at AOC A7, the Army will have to comply with CERCLA and the National
Contingency Plan (NCP) for any areas which are CERCLA sites, and determine if the material to be
consolidated is hazardous and subject to RCRA Land Disposal Restrictions (LDRs), 40 CFR Pan 268.
This remedy addresses the principal threat posed by AOCs A7 and A9 by preventing endangennent to
public health, welfare, or the environment by implementation of this final SC ROD. The potential threat
to human health is not immediate because ground water at AOCs A7 and A9 is not currently used as
drinking water.
STATUTORY DETERMINATIONS
The selected remedy meets the mandates of CERCLA §121. It protects human health and the environment,
complies with federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The selected remedy does not satisfy the statutory preference for
remedies mat employ treatment that reduces toxicity, mobility, or volume as a principal element because
treatment of the entire landfill area is impracticable. The selected remedy will reduce mobility of
contaminants at AOC A7 through its containment features. Because this remedy will result in waste
remaining on site at AOC A7, a review will be conducted by the Army, the U.S. Environmental Protection
Agency (USEPA), and the MADEP in five-year intervals after completion of the landfill cap construction
to ensure that the remedy continues to provide adequate protection of human health and the environment.
The method of disposal or treatment of the laboratory waste will be determined during the remedial design
phase. The determination win reflect the requirements of CERCLA 120(bXl) mat "remedial actions in
which treatment which permanently and significantly reduces the volume, toxicity, or mobility of hazardous
substances, pollutants or contaminants, as a principal element, are to be preferred over remedial
alternatives not involving such treatment."
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The foregoing represents the selection of a final, source control remedial action by the U.S. Department
of the Army and the U.S. Environmental Protection Agency, Region I, with concurrence of the
Massachusetts Department of Environmental Protection.
U.S. Dep
Date:
Edward R. Nurtall
Title: Colonel, U.S. Army
Commander
Fort Devens, Massachusetts
in
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The foregoing represents the selection of a final source control remedial action by the U.S. Department
of the Army and the U.S. Environmental Protection Agency, Region I, with concurrence of the
Massachusetts Department of Environmental Protection.
U.S. Environmental Protection Agency
By: .-n^ fa l Date:
M. Murphy
Title: Director
Waste Management Division
U.S. Environmental Protection Agency
Region I
rv
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DECISION SUMMARY
SEPTEMBER 1995
I. SITE NAME, LOCATION AND DESCRIPTION
The Annex is a National Priority List (NPL) or Superfund site and is located in Middlesex County.
Massachusetts. The 4.3-square-mile Annex reservation comprises sections of the towns of Sudbury,
Maynard, Hudson, and Stow. The reservation is divided into two irregularly shaped parcels by Hudson
Road. There are currently five AOCs within the Annex that are under investigation. This ROD relates
to SC for AOC A7 (the Old Gravel Pit Landfill) and AOC A9 [the Petroleum, Oil and Lubricants (POL)
Bum Area], which are located on the northern boundary of the Annex overlooking the Assabet River. The
Annex location and the location of AOCs A7 and A9 are shown on Figure 1.
AOC A7 (Figure 2) is located along the northern boundary of the installation overlooking the Assabet
River. Access is obtained by traveling north on a din track originating at Patrol Road. The track is
slightly overgrown and is approximately 200 feet in length. Demolition debris, scrap metal, spent shotgun
shells, clay targets, and other solid waste is scattered across much of the area. The central portions of the
site are cleared of vegetation, while the peripheral areas 'are heavily vegetated. The steep northward-
dipping slope on the northern boundary of the area overlooking the Assabet River is heavily vegetated and
debris is visible on. and protruding from, the slope. A small section of the northeast edge of the Army
property lies within the 100-year floodplain, but the landfill extent is at least 160 feet from the floodplain.
Prior to enclosing the area with a security fence in October 1991, unauthorized persons used the area for
recreational activities such as shooting, hunting, and din biking, and as a dumping ground. An unnamed
stream east of the area flows north towards the Assabet River.
A surface dump with discarded furniture and debris is located at the east end of AOC A7 in a wooded area
approximately 100 feet north of Patrol Road. Previously referred to as Study Area (SA) P8, this surface
dump was reported as a possible transformer disposal site. SA P8 is considered pan of AOC A7 and was
included in the AOC A7 investigation.
AOC A9 is level, nearly square, and covers approximately 7 acres. The area perimeter is enclosed by a
fence and a berm. Tall grasses, shrubs, and small pine trees cover the majority of the area. A source
removal area within AOC A9 shows signs of vegetation stress. The area is bounded on the south by Patrol
Road, and on the east, north, and west by forest. The north side of AOC A9 slopes steeply down to Track
Road and the Assabet River.
Building T401 is one of two structures remaining on the site and is located by the entrance gate installed
in the southeast comer. Building T402 is also located in the southeastern corner of the area and was
reportedly used to store mannequins used for fireproof clothing burn tests. The fireproof clothing test
facility is located near the center of the cleared portion of the area. This faculty is lined with cinder block
walls, has an asphalt base, and is bounded on the north by a large, freestanding, concrete wall with metal
doors.
A fenced-in area with a metal shed (SA P12) previously stood to the east of the cloth test pit. The shed
was placed on a concrete slab, and was surrounded on four sides and top by a chain-link fence to protect
a pump apparatus for an underground storage tank (UST). The shed and fence were removed by
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OHM Remediation Services Corp. (OHM), a wholly owned subsidiary of OHM Corporation, to assist in
the UST removal performed by A;ec Assoc., Inc., an Army contractor. SA P12 is now considered pan
ofAOCA9.
A more complete discussion of the past site histories of AOCs A7 and A9 can be found in Sections 3.1 and
4.1, respectively, of the Draft Final Addendum to the Final Site/Remedial Investigation (SI/RI) Report for
the Annex (OHM, 1995b).
0. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. LAND USE AND RESPONSE HISTORY
The Annex, which was originally known as the Maynard Ordnance Depot, was acquired by the U.S.
Government in the early 1940s. During World War n, the Annex was used for holding munitions, and
after the war it became known as die Maynard Ordnance Test Station. In 1958, control of the Annex was
transferred to the Natick Research and Development Command. At that time, the principal use of the
reservation was troop training, but testing and experiments were also conducted. During the Natick Phase
(1958-1982), the Annex was utilized by other agencies or operators for a variety of uses, including testing,
training, and waste disposal. In 1982, custody of the entire Annex was transferred to Fort Devens, located
17 miles northwest of Sudbury in the Town of Ayer. Fort Devens used the reservation primarily for
training active duty, Army Reserve, and Army and Air National Guard personnel. Currently, the Annex
remains a pan of Fon Devens but portions of the site are used for military housing, the U.S. Air Force
Geophysical Radar Station, and the Region I Office of Federal Emergency Management Agency.
AOC A7, the Old Gravel Pit Landfill, was used as a dumping and burial ground for general refuse,
demolition debris, drums, and laboratory waste from 1941 to the mid-1980s. Disposal of drums and
laboratory waste was reportedly carried out between the late 1950s and 1971. Additionally, this 10-acre
site was used by the general public for unauthorized surface dumping during the 1970s until site access was
restricted. Barriers were removed during the Dames & Moore remedial investigation (RI), and dumping
was re-initiated until the physical barriers were reconstructed.
\ )
AOC A9, the POL Burn Area, was used for product testing, and was made available to local jurisdictions
and die Massachusetts Fire Fighting Academy (MFFA) for fire prevention training. Natick Laboratory
used the area for flame-retardant clothing tests, and the Massachusetts State Police used this area for the
destruction of confiscated fireworks. The area is not currently used, but was active since the 1950s. Aerial
photographs show that prior to that time the area was used for agricultural purposes.
Fire fighting training conducted by the MFFA in AOC A9 involved the use of two fire pits. One pit was
approximately 20 feet by 20 feet by no more than 2 feet deep, with a 1- to 1 '^-foot-high berm composed
of soil and cinder blocks. The bottom of the pit was unlined, and the sides were supported with cinder
blocks. During fire fighting training, the pits were filled with approximately 6 inches of water, topped off
with fuel oil, and ignited. When fuel oil costs began to rise, JP-4 jet fuel was obtained from Jetline. Inc.
with MADEP permission and was used in place of the fuel oil. The second pit used for training consisted
of two trenches, 18 to 24 inches wide, approximately 24 inches deep, and 10 to 15 feet long in die shape
of a "T." The trenches were unlined and used for fire suppression/flashback training. Later, die "T" was
backfilled and replaced with a "Z" configuration in the same area.
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POL-contaminated soils were excavated and removed from the area of the former fire training pits between
September 1987 and January 1988 by Zecco, Inc. Approximately 1,123 cubic yards of soil were
transported to a hazardous waste disposal facility. The depth of excavation in one location was reported
to be 26 feet, approximately the top of ground water. The excavations were backfilled with soils from an
unknown location on the Annex. The material was staged in the POL area until it was used as backfill,
and was not certified as clean.
A more complete discussion of the past site histories of AOCs A7 and A9 can be found in Sections 3.1 and
4.1, respectively, of the SI/RI Report.
B. ENFORCEMENT HISTORY
In 1978, the Department of Defense established the Installation Restoration Program (ERP) to identify,
investigate, and clean up contamination resulting from the use, handling, storage, or disposal of hazardous
substances at federal facilities. Environmental investigations were started at the Annex in 1980 under the
IRP in order to address the environmental impact from past land uses.
Under the program, the Army conducted a site assessment which consisted primarily of a detailed records
search. The site assessment report indicated that certain portions of the Annex may have been
contaminated. Following the site assessment, the Army conducted an RJ/FS at the Annex. The Final RI
Report by Dames & Moore (Dames & Moore, 1986). Prior to the final publication of the RI report, the
USEPA Region I, Waste Management Division, contracted NUS Corporation of Bedford, Massachusetts,
to conduct a Site Investigation (SI) of the Annex. On May 26, 1987, NUS Corporation completed the SI
report on the Annex for USEPA Region I. In June of 1985, a Preliminary Assessment (PA) of the Annex
was also conducted for USEPA Region I by an NUS Corporation Field Investigation Team. The PA
included a review of Dames & Moore's final draft RI/FS report. As a result of these investigations, the
Annex was placed on the NPL on February 21, 1990.
Investigation and cleanup activities at the Annex are goverened by an interagency agreement (IAG) called
a Federal Facility Agreement (FFA). The FFA for the Annex is a two-party agreement between the Army
and the USEPA and was signed on November 15, 1991. Under the FFA, the Army, as the lead agency,
is responsible for carrying out all work required in accordance with the requirements of CERCLA under
USEPA oversight.
m. COMMUNITY PARTICIPATION
Under the IAG, the Army established a Technical Review Committee (TRQ to facilitate technical
management and promote public participation through quarterly public information meetings. TRC
membership consists of representatives from die U.S. Army Environmental Center (USAEQ, Fort Devens
Environmental Management Office, USEPA Region I, MADEP, and the U.S. Fish and Wildlife Service,
as well as local officials and interest groups, specifically Four Town Families Organized for the Cleanup
of Sites. This organization is also known as FOCUS.
Throughout the investigations, the community has been involved in all activities. The Army has kept the
community and other interested panics apprised of these activities through informational meetings, fact
sheets, press releases, public meetings, and site tours.
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From 1990 through 1991, the Army held several informational meetings to describe the plans for the RI/FS
process. During December 1991, the Army released a community relations plan that outlined a program
to address community concerns and keep citizens informed about and involved in activities during remedial
activities. The community has been continuously kept informed regarding the status and activities of the
RI/FS through quarterly TRC meetings.
On June 1, 1995, the Army submitted the Final Proposed Plan (OHM, 1995c) to the TRC and the public
repositories. The Army published a notice announcing a public meeting to present and discuss the
Proposed Plan in several local newspapers on June 7 and June 8, 1995. The plan was made available to
the public at the Goodnow Library in Sudbury, Randall Library in Stow, the Hudson Public Library, the
Maynard Library, and the Davis Library at Fort Devens.
On June 14, 1995, the Army and USEPA held an informational meeting to discuss the results of the RJ at
AOCs A7 and A9, the cleanup alternatives presented in the FS, and to present the Army's Proposed Plan.
Immediately following this meeting, the Army held a public hearing to accept formal comments on the
Proposed Plan. From June 5 to July 5, 1995, the Army held a 30-day public comment period to accept
written comments on the alternatives presented in the FS Report, the Proposed Plan, and on any other
documents previously released to the public. A transcript of the public meeting is included in the
Responsiveness Summary in Appendix B.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy for AOCs A7 and A9 is a source control (SC) alternative. The remedy addresses the
potential risks to human health and the environment posed by existing site conditions at the Annex, and is
intended to be the permanent SC measure for AOCs A7 and A9. The SC action will be consistent with
implementation of a future MOM remedy to address ground water contamination at AOCs A7 and A9.
The MOM remedy will be addressed in the future in a separate ROD after additional data is gathered.
In summary, the selected remedy involves capping the landfill area at AOC A7 to minimize direct exposure
to landfill materials, and to minimize infiltration of precipitation, thereby limiting production of leachate
and minimizing possible resultant impacts to ground water quality and the Assabet River. The preferred
alternative includes removal of hazardous laboratory waste at AOC A7 followed by off-site treatment and
disposal, and removal of contaminated soil within AOCs A7 and A9, and consolidation beneath a landfill
cap. Exposures to landfill materials and hotspots would be limited by isolating the waste materials using
a RCRA Subtitle C multi-layer cap, and by using institutional controls to limit future site use and restrict
site access. The cap would also direct precipitation runoff away from landfill materials and provide a
barrier to infiltration. Following construction of the landfill cap at AOC A7, the Army will conduct ground
water monitoring, O&M, and five-year reviews as part of the selected remedy.
V. SUMMARY OF SITE CHARACTERISTICS
Chapter 1.0 of the FS Report contains an overview of the RI. The significant findings of the RI are
summarized below.
Results of RI of AOCs A7 and A9
RIs were performed to assess the nature and extent of contamination at AOCs A7 and A9. OHM
conducted field activities for the RI that included the collection and analysis of soil, ground water, surface
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water, sediment, and solid waste samples. Most of the samples collected at AOCs A7 and A9 were
analyzed for Target Compound List volatile organic compounds (VOCs), base/neutral/acid extractables
(BNAs), polychlorinated biphenyls (PCBs), and pesticides; Target Analyte List metals; herbicides; and
explosives. For a detailed assessment of AOCs A7 and A9, refer to the Addendum to the SI/RI Report,
which is included in the Administrative Record and Information Repositories.
Nature and Extent of Contamination: This section summarizes the nature and extent of contamination at
AOCs A7 and A9. The contaminants identified in this section have been detected at concentrations in
excess of either maximum background values. State and Federal standards, or other criteria.
In AOC A7, 14 surface soil samples were analyzed for VOCs, BNAs, PCBs, pesticides, chlorinated
herbicides, explosives, and metals. BNAs were detected at two locations, one of which contained 12
BNAs. The pesticides, dieldrin, dichlorodiphenylethane (DDE), and dichlorodiphenyltrichloroethane
(DDT) were detected at several sample locations. The PCS, Aroclor 1260, was present in one sample.
Two herbicides, silvex and dacthal, were also found. Lead was detected at one sample location at a
concentration greater than a standard.
Subsurface soil samples were collected from 19 test pits, 27 borings, and 2 hand auger locations. Many
of the pesticides and BNAs found in surface soil samples were also detected in the subsurface. The
pesticides detected included dichlorodiphenyldichloroethane (ODD), DDE, DDT, dieldrin, lindane, endrin,
heptachlor epoxide, and chlordane.
Test pitting, soil boring, and visual observation were used to estimate the areal extent and volume of the
landfill, SA P8, and the laboratory waste disposal area. The landfill area is estimated to be 1.3 acres and
11,000 cubic yards. SA P8 (along with visually-contaminated surrounding soil) is estimated to 0.35 acres
and 2,235 cubic yards. The buried laboratory debris area is estimated to be 0.54 acres and 800 cubic
yards. A plan view of these areas is presented on Figure 2.
Thirty ground water samples were collected from ten monitoring wells in AOC A7. The VOCs
tetrachloroethylene or perchloroethylene, 1,1,2,2-tetrachloroethane or perchloroethane, trichloroethylene,
and chloroform, along with the pesticide lindane, were detected at concentrations above their drinking
water standards. These exceedances were limited to three wells, OHM-A7-8, .OHM-A7-51, and
OHM-A7-46. Lead was also detected at a concentration above its drinking water standard in one of three
samples collected from monitoring well OHM-A7-12.
Surface water and sediment samples were collected from the unnamed stream located adjacent to the
landfill to assess whether contaminants from the site had entered the stream. The analytical results show
that the site is not contaminating the stream. Arsenic concentrations in surface water were below the
freshwater chronic Ambient Water Quality Criteria (AWQC), but exceeded the human health AWQC.
Arsenic, barium, nickel, and selenium were detected in sediment samples at concentrations above screening
levels.
The behavior of the contaminants in AOC A7 depends on both the chemical compound and the local
environment. Contaminants have been in place at AOC A7 for over 20 years and their behavior will be
influenced by the environmental weathering that has occurred over that time. For example, it is unlikely
that VOCs will be present in surface soils because these compounds will either volatilize into the
atmosphere or leach downward with infiltrating water. Pesticides and metals may occur at the surface, but
may be more tightly bound man freshly applied chemicals. Overburden in the area consists of fill over
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fairly low permeability tills. Water and chemicals will move fairly'readily through the fill material, but
the characteristics of the till will serve to limit the flow of water, and consequently, the flow of associated
contaminants. However, some migration of chemicals with ground water is occurring at the site.
In AOC A9, 11 surface soil samples were analyzed for VOCs, BNAs, PCBs, pesticides, explosives, and
metals. VOCs, BNAs, and pesticides were all detected at concentrations below screening levels. Arsenic,
lead, and thallium concentrations exceeded their standards at several locations.
Forty-six subsurface soil samples were collected from AOC A9 during the RI. Arsenic was the only
inorganic contaminant present at concentrations above its standard. Elevated arsenic concentrations were
limited to an area outside of the southwest corner of AOC A9 and were confined to the upper soil layers.
However, results from preliminary field screening of SA P9 (which is located apart from and outside the
fenced area of AOC A9) indicate that arsenic is present in the soil starting from the southwest corner of
AOC A9 (outside the fence) and continuing downgradient to SA P9. This large area of arsenic
contamination is probably not related to AOC A9, and has been attributed to the basewide application of
arsenic-based herbicides along the security perimeter and former railroad beds.
Twenty-five ground water samples were collected from 15 monitoring wells in AOC A9. Ground water
data indicate that VOCs, BNAs, and lead are present at concentrations above drinking water standards.
Explosive residues were found at one sampling location. There are no drinking water standards for the
explosive residues detected.
The transformation of die chemicals present in AOC A9 depends on both the chemicals and the local
environment. Chemicals have been in place at AOC A9 for many years and their transformation will be
influenced by the environmental weathering that is likely to have occurred over that time. Although
chlorinated VOCs have been detected in the ground water, some of these compounds detected may be
degradation products of other chlorinated VOCs. The soils in the area generally consist of fairly sandy
soils (and some fill) at the surface, grading to much finer materials with depth. Water and chemicals will
move fairly readily through the surface material, but the characteristics of the finer soils will serve to limit
the flow at deeper levels and consequently the migration of associated contaminants will also be inhibited.
A complete discussion of site characteristics can be found in Chapters 3.0 and 4.0 of the Addendum to the
SI/RI Report.
VI. SUMMARY OF SITE RISKS
A Baseline Risk Assessment was performed to estimate the probability and magnitude of potential adverse
human health and environmental effects from exposure to contaminants associated with the Annex. The
public health risk assessment followed a four step process: 1) contaminant identification, which identified
those hazardous substances which, given the specific conditions of the site were of significant concern; 2)
exposure assessment, which identified actual or potential exposure pathways, characterized the potentially
exposed populations, and determined the extent of possible exposure; 3) toxicity assessment, which
considered the types and magnitude of adverse health effects associated with exposure to hazardous
substances, and 4) risk characterization, which integrated the three earlier steps to summarize the potential
and actual risks posed by hazardous substances at the site, including carcinogenic and non-carcinogenic
risks. Except for chemicals that are obviously not site-related (e.g., laboratory contaminants), all detected
chemicals were considered in the risk assessment. The results of the public health risk assessment for the
Annex are discussed below followed by the conclusions of the environmental risk assessment.
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Human Health Risk Assessment
A Human Health Risk Assessment (HHRA) was prepared in January 1994 for the Annex. Some additional
sampling and analysis was conducted in AOCs A7 and A9 following completion of the HHRA and an
addendum to the HHRA was also prepared. The purpose of the HHRA addendum was to evaluate the new
data to determine if they affected the findings of the original HHRA. Based on the review described in the
addendum, the results of the HHRA were not materially affected. The HHRA addendum is included as
Appendix C to the SI/RI Report. The primary objectives of the HHRA included the following:
Examine exposure pathways and contaminant concentrations in soil and ground water at the
Annex;
Estimate the potential for adverse effects associated with the contaminants of concern at the
Annex under current and future land use conditions;
Identify site or land use conditions that present unacceptable risks; and,
Provide a risk assessment basis on which decisions can be made and from which
recommendations for future activities which are protective of human health can be determined.
The HHRA estimated present and future potential risks to human health posed by exposure to contaminated
soil, based on conditions as described in the SI/RI Report. The HHRA addressed risks that could occur
on AOCs A7 and A9 as they currently exist, and under a scenario that assumes land use may change in the
future. Under current .conditions, the greatest potential exposure is associated with unauthorized use by
school age children who were assumed to be exposed for a 10-year period (between the ages of 8 and 18).
Exposure under current use conditions is most likely to occur via direct contact with, and subsequent
ingestion or dermal absorption of, chemicals in site soils.
If sections of the Annex are excessed (sold by the military), future use could include residential housing.
Because this scenario posed the highest future use exposure potential, residential use of the facility was
evaluated to estimate maximum risks. Under this scenario, exposure could occur for a 30-year period
(reasonable maximum estimate of the time and individual remains in the same house) through direct contact
with soils and sediment (ingestion or dermal absorption), use of on-site ground water or surface water, or
by consumption of fish.
Risks were assessed using USEPA Region I guidance (USEPA, 1991a), which considers both average and
maximum concentrations of chemicals in different environmental media at AOCs A7 and A9. The
maximum concentrations represent exposure associated with repeated contact with the most contaminated
portions of the Annex. The average concentration assumes an individual receives an exposure from a
wider distribution of sources. USEPA uses a target excess cancer risk goal of one in one million (10^) for
exposure to carcinogenic substances, and typically regulates within a range of one in 10,000 to one in
1,000,000 (10-4 to 10-*).
For noncarcinogens, USEPA assumes adverse health effects are unlikely if the estimated exposure dose
is lower than the reference toxicity criteria [called the reference dose (RiD)]. The ratio of exposure dose
to RfD is termed the Hazard Quotient, and the sum of these ratios for multiple chemical exposure is called
the Hazard Index (HI). An HI over 1.0 means that adverse non-cancer effects may occur by continuous
contact with a particular chemical of concern.
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To ensure public health is adequately protected, conservative (unlikely to underestimate risk) assumptions
were used in deriving both the exposure estimate and the toxiciry values. Because of the use of these
conservative assumptions, it is likely that actual risks are considerably lower than risks estimated in this
report.
For a complete explanation of risks posed by contamination at the Annex, please refer to the HHRA
Addendum presented in the Addendum to the SI/RI Report. The Addendum to the SI/RI Report is pan of
the Administrative Record and is also included in the Information Repositories.
Health Risks Associated With AOCA7: Risks associated with current and future use scenarios at AOC AT
are as follows:
Current Use - Soil Ingestion
Average Maximum
HI 0.09 0.9
Cancer Risk 3 x 10^ 3 x 10'5
Future Use (Residential - Includes Soil and Sediment Ingestion and Ground Water Use)
Average Maximum
HI 0.2 1
Cancer Risk 7 x lO"3 5 x
Exposure to lead at AOC A7 was evaluated separately using USEPA's Uptake/Biokinetic (UBK) Model.
Results from the model were compared with an USEPA blood action level of 10 /tg/dl. Based on the UBK
model, lead does not pose a health risk in AOC A7.
Much of the risk estimated for AOC A7 is associated with the presence of hotspots (areas of localized
contamination) and contaminated ground water. For risks of the magnitude estimated above to occur would
require frequent contact with these spots. Because frequent contact is unlikely, and the hotspots will be
excavated and removed from AOC A7, actual future risks are probably substantially lower than risk
estimates that are based on maximum exposure point concentrations.
Laboratory waste buried in the west-central portion of the site consists of glassware containing unknown
chemicals. Hazards posed by this material are undefined but potentially significant, including risks
associated with leaching of materials from the she to the river and contact with die chemicals if excavation
occurs in the area. Consequently, action to address this potential hazard is warranted. Further, due to
exceedance in cancer risk under the future use scenario, action at AOC A7 is warranted.
Health Risks Associated With AOCA9: Risks associated with current and future use scenarios at AOC A9
are as follows:
Current Use - Soil Ingestion
Average Maximum
HI 0.03 0.1
Cancer Risk 2 x 10* 7 x 1Q-*
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Future Use (Residential - Includes Soil and Sediment Ingestion and Ground Water Use)
Average Maximum
HI 1 10
Cancer Risk 6 x 10'5 2 x 10"1
Much of the risk estimated for AOC A9 is associated with the presence of soil hotspots containing elevated
levels of arsenic and thallium. For risks of the magnitude estimated above to occur would require frequent
contact with these points. Because frequent contact is unlikely and the hotspots will be excavated and
removed from AOC A9, actual future risks are probably substantially lower than risk estimates based on
maximum exposure point concentrations. However, removal of soil contaminated with arsenic and thallium
is warranted because cancer risk number and HI, respectively, exceed acceptable levels under the future
land use scenario.
Exposure to lead at AOC A9 was evaluated separately using USEPA's UBK Model. Results from the
model were compared with an USEPA blood action level of 10 ^g/dl. Based on the UBK model, lead does
not pose a health risk in AOC A9.
Supplemental Ecological Risk Assessment
A supplemental ecological risk assessment was conducted as pan of the Addendum to the SI/RI Report to
determine whether risk estimates from the January 1994 risk assessment require modification and to
specifically evaluate ecological risk in AOCs A7 and A9. For a complete explanation of these assessments.
please refer to Appendix C of the Addendum to the SI/RI Report. A summary of the ecological assessment
follows.
Results of investigation at the Annex reveal a complex area containing several interrelated ecosystems.
In AOCs A7 and A9, chemicals of concern for ecological receptors can be separated into three categories:
Chemicals present in AOCs A7 and A9 ground water that may pose a risk to aquatic organisms
in the Assabet River;
Organochlorine pesticides, metals, and polynuclear aromatic hydrocarbons (PAHs) present in
soils that may pose a risk to terrestrial wildlife (these chemicals are present in hotspots in both
AOCs, and are not widely distributed); and,
Metals present at elevated concentrations in sediments in the intermittent stream east of
AOC A7; these chemicals may pose a risk to aquatic organisms.
Ecological Risks Associated with AOC A7: Soil contaminants at AOC A7 include lead, DDT, DDE,. ODD,
and chlordane. These contaminant* exist at several hotspots, with most spots concentrated in the central
portion of the site. There is no visual evidence of ecological damage at AOC A7. For a complete
explanation of risks posed by contamination at AOC A7, please refer to the supplemental ecological risk
assessment presented in Appendix C of the Addendum to the SI/RI Report. At AOC A7, contaminants in
ground water are associated with a ground water plume originating from the laboratory waste disposal area,
and possibly migrating to the Assabet River. Elevated levels of lindane and chlorinated solvents have been
found in ground water. Results of the ecological risk assessment indicate ground water migration to the
Assabet River is unlikely to adversely affect aquatic organisms. The assessment also indicates soil hotspots
are unlikely to pose an adverse risk to terrestrial wildlife. Biological assessment of the stream on the east
side of AOC A7 showed no impairment attributable to site contaminants.
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Ecological Risks Associated with AOCA9: At AOC A9, contaminants in ground water are associated with
two plumes, one containing chlorinated VOCs and the other containing petroleum-related VOCs. The
plumes extend from the AOC toward, and possibly, to the Assabet River. At some monitoring wells,
VOCs were found at concentrations above their ground water standards. Concentrations of VOCs in wells
closer to the river were much lower. Consequently, these compounds were not considered further in the
assessment. Soil contaminants exist at two primary hotspots, with elevated arsenic found in the southeast
comer of the AOC, and lead and thallium associated with an old drum in the northwest comer of the AOC.
Results of the screening-level risk assessment indicate ground water migration to the Assabet River is
unlikely to adversely affect aquatic organisms. It also suggests the contamination hotspots are unlikely to
pose a risk to terrestrial wildlife. Vegetation in the area represents early-stage successional recovery,
which is consistent with removal of topsoil and associated nutrients. Topsoil removal occurred frequently
as a consequence of earlier site activities at AOC A9.
Ecological Risks to the Assabet River:
OHM collected and analyzed sediment samples from three depths at three points in the river; upstream near
Crow Island (FWISW/SD14); adjacent to the Annex near the mouth of the stream that flows between
AOCs A7 and A9 (FWISW/SD15); and downstream (FWISW/SD16). Chemical concentrations were
compared with screening level criteria for sediments, and many chemicals exceeded these criteria. In
particular, several metals exceeded the criteria at all depths at all locations, PAHs were detected at elevated
concentrations in upstream samples, and organochlorine pesticides were detected in samples collected at
all depths from the location adjacent to the site. In addition to chemical analyses, total organic carbon
(TOC) levels were measured in all samples. TOC concentrations tended to decrease with depth (as would
be expected), but were quite variable among the three sample points. The upstream sample had the lowest
TOC (an average of O.S percent), the downstream sample had the mid range value (7 percent), and the
sample adjacent to the site had by far the highest TOC level (35 percent).
The distribution of chemicals laterally and at depth indicates the elevated concentrations are probably the
result of past releases to the river from sources other than the Annex. For example, pesticides are
concentrated in sediments near the mouth of the small stream that separates AOCs A7 and A9, and might
appear to be site related. However, these chemicals are not widespread in AOCs A7 and A9, and are only
present in hotspots. In other words, there is no evidence that contamination from AOCs A7 and A9 has
impacted the stream or has migrated to the Assabet River. Lindane, the only pesticide which appears to
be slowly migrating in ground water, was not present in river sediment samples. Furthermore, pesticide
concentrations were found at depths up to 3 feet below the sediment surface. It seems likely mat pesticides
in deep sediments may be the result of the historical use of agricultural pesticides. Based on examination
of the chemicals found in Assabet River sediments and their relationship to site chemicals, it seems unlikely
that the Annex is adversely affecting water quality in the Assabet River.
Conclusion
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment. The objectives of the selected remedial action are to remove the
presumed hazardous laboratory waste from the site, provide containment and isolation of the landfill
contents, and control potential leachate generation due to infiltration.
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. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES
Under its legal authorities, the Army's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences, including: a requirement that USEPA's
remedial action, when complete, must comply with all federal and more stringent state environmental
standards, requirements, criteria or limitations, unless a waiver is invoked; a requirement that USEPA
select a remedial action that is cost-effective and that utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable; and a preference for
remedies in which treatment which permanently and significantly reduces the volume, toxicity or mobility
of the hazardous substances is a principal element over remedies not involving such treatment. Response
alternatives were developed to be consistent with these Congressional mandates.
Based on preliminary information relating to types of contaminants, environmental media of concern, and
potential exposure pathways, remedial action objectives (RAOs) were developed to aid in the development
and screening of alternatives. These RAOs were developed to mitigate existing and future potential threats
to public health and the environment. For AOC A7, the primary RAOs are:
Eliminate potential risk to human health and the environment associated with exposure to
contaminated wastes
Minimize off-site migration of contaminants; and,
Limit infiltration of precipitation to the underlying waste within the landfill area, thereby
minimizing leachate generation and ground water degradation.
For AOC A9, the primary RAO is:
Reduce potential risk to human health associated with exposure to contaminated soil.
* 'i
B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING
CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives were developed for the site.
The FS for AOCs A7 and A9 identified and analyzed the SC and MOM alternatives to address soil and
ground water contamination, respectively. However, during the evaluation process, it was determined that
additional ground water data were needed to be collected prior to selecting an MOM remedy for both
AOCs. Further, based on the potential risks to human health and die environment posed by existing site
conditions, and die proximity to die Assabet River, stabilization of site conditions at AOCs A7 and A9 was
determined to be of high priority. Because AOC A7 contains a landfill for which many remedial
alternatives are impracticable due to implementability and cost, a remedial action to stabilize existing
conditions and provide SC was determined to be appropriate. The MOM remedy will be addressed in a
separate ROD after additional data is gathered.
Widi respect to SC, the FS developed a range of altematives-from one mat would eliminate or minimize,
to die extent feasible, die need for long-term management (including monitoring) at die site (e.g.,
excavation and off-site disposal) to one that would employ treatment as a primary component (e.g.,
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solidification/stabilization). The range also included alternatives that involved containment of waste with
minimal or no treatment but protecting human health and the environment by preventing potential exposure
and/or reducing the mobility of contaminants, and the no-action alternative.
Vm. DESCRIPTION OF ALTERNATIVES
This section provides a narrative summary of each SC alternative evaluated for AOCs A7 and A9.
A detailed assessment of each alternative can be found in Section 4.0 of the FS Report.
AQC A7 Remedial Alternatives
The Army considered three remedial alternatives to address SC at AOC A7. Each of these alternatives is
described below. A detailed presentation and analysis of the alternatives can be found in Section 4.0 of
theFS.
Alternative 1 -No Action: This alternative was evaluated in the FS to serve as a baseline for comparison
to other alternatives under consideration. Under this alternative, no containment, engineering controls,
or land use restrictions would be used.
Alternative 2 Laboratory Waste Excavation and Off-Site Disposal, Containment with RCRA Subtitle C
Landfill Cap: Alternative 2 consists of excavation of buried laboratory wastes and associated soil within
AOC A7, with off-site treatment and disposal of this waste, and construction of an impermeable RCRA
cap to contain the remaining contaminants. During excavation and transportation of the laboratory wastes,
all federal and state requirements pertaining to identification, handling, transport, storage, and disposal of
hazardous wastes will be attained in this alternative.
Prior to construction of the cap, AOC A7 would be regraded to eliminate depressions and steep sidewalls
to the extent practicable so that precipitation will run off instead of ponding on the surface or infiltrating
into the landfill. This process would require excavating some solid waste along the steep northern slope,
and replacing the waste closer to the center of the area to be capped. During she preparation and grading,
contaminated materials within AOC A7 will be consolidated as part of die necessary subgrade for the
proposed cap. The cap would be designed to meet the requirements applicable to closure of a hazardous
waste landfill (RCRA Subtitle Q.
Following construction, the cap and associated systems will be inspected periodically and maintained to
assure integrity and proper operation. Long-term O&M will include maintenance of the cap, site fencing,
drainage, and landfill gas control systems. Ground water and storm water discharge monitoring programs
will also be implemented. Five-year reviews will also be conducted.
A summary of estimated costs, time for design, construction, and operation is presented below.
Estimated Time for Design and Construction: 2 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $1,614,350
Estimated O&M Costs (present worth): $595,360
Estimated Total Cost, Including 20% Contingency (present worth): S2.418.860.
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Alternative 3, Laboratory Waste Excavation and Off-Site Disposal. Consolidation, Containment with RCRA
Subtitle CLandfill Cap: Alternative 3 will consist of the same primary components as Alternative 2. In
addition, Alternative 3 will include importation of contaminated soil from AOC A9, subsequent
consolidation of this waste with contaminated soil from AOC A7, and final placement under the RCRA
Subtide C landfill cap. The proposed area! extent of the cap, subject to change during design, is indicated
on Figure 3. The cap will consist of multiple layers, each with a specific purpose. The proposed cap
design is consistent with state-of-the-art requirements for hazardous waste landfill caps, providing a high
degree of isolation and control. As shown on Figure 4, the cap consists of the following layers (described
from top of waste to top of finished cap):
Passive gas vent layer over existing waste, if necessary, based on site-specific conditions, to
vent and/or control landfill gases generated in the landfill;
Lower very low permeability barrier, consisting of a geosynthetic clay liner, comprised of a
layer of bentonite clay sandwiched between an upper and lower geotextile layers;
Upper impermeable barrier, consisting of a synthetic membrane, to stop infiltration of
percolating water;
Drainage layer, consisting of a geonet, to divert precipitation that infiltrates through the
surficial vegetative and protective layer off of and away from the impermeable barrier layers;
and,
Vegetative and protective layer, approximately 24 inches thick and including 6 inches of
topsoil, to protect underlying cap components and control erosion by providing a suitable
medium for vegetative growth.
Landfill gas controls, such as passive gas vents or extraction wells, will be utilized (if necessary) to manage
landfill gases generated beneath the cap, thereby preventing accumulation of gas beneath the cap and
potential disruption of cap integrity.
The cap and drainage system would be connected to a system of drainage swales around the landfill to
control run-on and run-off. Along the north side of the landfill, facing the Assabet River, additional
engineering controls would be utilized to protect landfill materials and the landfill cap from potential
damage from erosion. The slope will be regraded and, if necessary, a revetment (gabion wall) will be
installed along this north slope to provide additional protection against erosion of soil and debris. Access
to the area would be further restricted by the existing fence along the perimeter of AOC A7. Long-term
O&M, ground water monitoring, and five-year reviews will be implemented.
A summary of estimated costs, time for design, construction, and operation is presented below.
Estimated Time* for Design and Construction: 2 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: 51,614,700
Estimated O&M Costs (present worth): 5595,360
Estimated Total Cost Including 20% Contingency (present worth): 52,419,235.
AOC A9 Remedial Alternatives
Alternative 1 -No Action: This alternative was evaluated in the FS to serve as a baseline for comparison
to other alternatives under consideration. Under this alternative, no containment, engineering controls or
land use restrictions would be used.
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Alternative 2 - Limited Action: Alternative 2 is a limited action consisting of a fence, warning signs, and
deed restrictions. A fence would be installed around each of the two contaminated areas within AOC A9.
The fencing would consist of a 6-foot-high. gated, chain-link fence topped with three strands of barbed
wire. Warning signs would be mounted on the fence. Deed restrictions would be imposed, prohibiting
residential development or recreational use. Monitoring would be performed at regular intervals for
30 years.
A summary of estimated costs, time for design, construction, and operation is presented below.
Estimated Time for Design and Construction: 3 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: 515,730
Estimated O&M Costs (present worth): 5462,280
Estimated Total Cost, Including 20% Contingency (present worth): 5548,620.
Alternative 3 - Off-Site Disposal: Alternative 3 involves the excavation of 50 cubic yards of soil
contaminattd above the risk-based cleanup levels for arsenic and thallium, and transportation to an off-site
facility for final treatment and disposal. Soil from AOC A9 is not expected to exhibit a hazardous toxicity
characteristic [by Toxicity Characteristic Leaching Procedure (TCLP) Test] for either lead, arsenic,
beryllium, or thallium, based on the relatively low levels of these contaminants in soil, and their relatively
strong adsorption properties. Because the lack of toxicity has not been confirmed, this alternative presents
disposal costs for both hazardous and non-hazardous soil. If soil is non-hazardous, it is acceptable for
disposal at a non-hazardous waste (RCRA Subtitle D) facility. If soil exhibits toxicity for any of the
aforementioned contaminants, it will require treatment using solidification/stabilization technologies,
followed by disposal at a hazardous waste (RCRA Subtitle C) facility. When soil excavation is complete,
borrow material from the Annex will be placed within the excavated area. A minimum of 6 inches of soil
cover will be placed on top of the fill to support vegetation.
For soil which is hazardous:
. -i
- Estimated Time for Design and Construction: 3 months
- Estimated Time of Operation: 30 years
- Estimated Capital Cost: $61,360
- Estimated O&M Costs (present worth): $25,020
- Estimated Total Cost, Including 20% Contingency (present worth): $125,650.
For soil which is non-hazardous:
- Estimated Time for Design and Construction: 3 months
- Estimated Time of Operation: 30 years
- Estimated Capital Cost: $41,010
- Estimated O&M Costs (present worth): $25,020
- Estimated Total Cost, Including 20% Contingency (present worth): $103,680.
Alternative 4, Off-Site Disposal at AOCA7: This alternative involves excavation of 50 cubic yards of
contaminated soil at AOC A9 within the fenced area. This contaminated soil is assumed to be non-
hazardous and will be transported to AOC A7, approximately 1/4 mile away. Soil will be consolidated
beneath a 2-acre RCRA Subtitle C multi-layer cap along with contaminated soil excavated from AOC A7.
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Soil from AOC A9 is not expected to exhibit a hazardous toxicity characteristic (TCLP Test) for either
lead, arsenic, beryllium, or thallium based on the relatively low levels of these contaminants, and their
relatively strong adsorption properties. However, the lack of toxicity has not been confirmed. If, as a
result of testing, soil is found to be hazardous, it will be transported off site to a hazardous (RCRA
Subtitle C) facility for treatment and disposal. When soil excavation is complete, borrow material from
the Annex will be placed within the excavated area. A minimum of 6 inches of soil cover will be placed
on top of the fill to support vegetation.
A summary of estimated costs, time for design, construction, and operation is presented below.
Estimated Time for Design and Construction: 3 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $26,870
Estimated O&M Costs (present worth): 525,020
Estimated Total Cost, Including 20% Contingency (present worth): 556,035.
Alternative 5 - Solidification/Stabilization: Alternative 5 involves the excavation of contaminated soil,
consolidation on site, and addition of solidification/stabilization agents. An estimated 50 cubic yards of
soil will be excavated from two locations. These two small hotspots of soil containing slightly elevated
levels of arsenic, lead, beryllium, and thallium would be transported to the consolidation area prior to the
treatment process. Pozzolan/Ponland cement would be placed in the mixing area. The Pozzolan/Portland
cement and soils would then be mixed using a backhoe. After hardening, the mixture would form a
relatively impermeable monolith. Treated soil would be cured within the consolidation area, and solidified
material would remain on site. The consolidation and treatment area will be covered with 6 inches of
topsoil and seeded. Monitoring would be performed at regular intervals for 30 years.
A summary of estimated costs, time for design, construction, and operation is presented below.
Estimated Time for Design and Construction: 6 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $53,925
Estimated O&M Costs (present worth): $347,730
Estimated Total Cost, Including 20% Contingency (present wonh): $466,160.
Solidification/stabilization has been shown to be effective for immobilizing inorganic compounds.
However, a treatability study is proposed for Alternative 5 to account for variability in site-specific
conditions.
EX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(l) of CERCLA presents several factors that, at a minimum, the Army is required to consider
in its assessment of alternatives. Building upon these specific statutory mandates, die NCP articulates nine
evaluation criteria to be used in assessing the individual remedial alternatives.
A detailed analysis was performed on the alternatives using die nine evaluation criteria in order to select
a site remedy. The following is a summary of the comparison of each alternative's strength and weakness
with respect to the nine evaluation criteria. These criteria are summarized as follows:
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Threshold Criteria
The two threshold criteria described below must be met in order for the alternatives to be eligible for
selection in accordance with the NCP.
1. Overall protection of human health and the environment addresses whether or not a remedy
provides adequate protection and describes how risks posed through each pathway are eliminated,
reduced or controlled through treatment, engineering controls, or institutional controls.
2. Compliance with applicable or relevant and appropriate requirements (ARARS) addresses
whedier or not a remedy will meet all of die ARARs of other Federal and State environmental
laws and/or provide grounds for invoking a waiver.
Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate die elements of one alternative to another
that meet the threshold criteria.
3. Long-term effectiveness and permanence addresses the criteria that are utilized to assess
alternatives for the long-term effectiveness and permanence they afford, along with die degree of
certainry that they will prove successful.
4. Reduction of toricity, mobility, or volume through treatment addresses the degree to which
alternatives employ recycling or treatment that reduces toxiciry, mobility, or volume, including
how treatment is used to address the principal threats posed by die site.
5. Short-term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the construction
and implementation period, until cleanup goals are achieved.
6. Implementability addresses the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.
7. Cost includes estimated capital and O&M costs, as well as present-worm costs.
Modifying Criteria
The modifying criteria are used on the final evaluation of remedial alternatives generally after the Army
has received public comment on the RI/FS and Proposed Plan.
8. State acceptance addresses the State's position and key concerns related to the preferred
alternative and other alternatives, and the State's comments on ARARs or the proposed use of
waivers.
9. Community acceptance addresses die public's general response to the alternatives described in
die Proposed Plan and RI/FS Reports.
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A detailed assessment of each alternative according to the nine criteria can be found in Section 4.0 of the
FS Report.
Following the detailed analysis of each individual alternative, a comparative analysis, focusing on the
relative performance of each alternative against the nine criteria, was conducted. Comparative analysis
for the threshold criteria and the primary balancing criteria can be found in Tables 5-1 and 5-2 of the FS
Report for AOC A7 and AOC A9, respectively.
The section below presents the nine criteria and a brief narrative summary of the alternatives and their
strengths and weaknesses according to the detailed and comparative analysis. The comparative analysis
discussion integrates alternatives for AOCs A7 and A9 because the preferred alternative involves moving
contaminated soils from AOC A9 into AOC A7. A detailed assessment of each alternative can be found
in the FS Report.
Overall Protection of Human Health and the Environment
The preferred alternative (Alternative 3 for AOC A7 combined with Alternative 4 for AOC A9) is most
protective of human health and the environment. Protection is provided by removal of laboratory waste
which is presumed to be hazardous. It also provides protection against exposures to surficial contaminants
through the placement of a physical barrier over them. The preferred alternative utilizes a RCRA
Subtitle C multi-layer landfill cap, which stringently controls infiltration of precipitation and subsequent
leachate generation. The cap is designed to prevent surficial leachate seeps.
Off-site disposal of contaminated soils (Alternative 2 for AOC A7, and Alternative 3 for AOC A9) is
similar to the preferred alternative, except that contaminated soil from AOC A9 is disposed of off site. The
off-site disposal alternatives are equally effective as the preferred alternative on both short-term and long-
term bases, since the same technology is employed. Effective containment in both alternatives would
provide overall protection by preventing direct contact, ingestion, and inhalation of site contaminants.
The No Action alternative (Alternative 1 for both AOCs A7 and A9) would not meet this criterion in its
entirety. It is not considered protective because it provides no reduction in potential risks or control of
exposure pathways.
The limited action alternative for the AOC A9, Alternative 2, provides a degree of protection of human
health and the environment by utilizing institutional controls to limit site access and future use. However,
it would not be as effective in the long term as the excavation and removal alternatives, Alternatives 3
and 4.
Alternative 5 (AOC A9) involves encapsulation of soil contaminants in a cementitious material which would
remain on site. This process is considered equally effective to the preferred alternative in protection of
human health and the environment.
Compliance with ARARs
Compliance with State and Federal ARARs pertaining to hazardous waste and municipal solid waste landfill
closure at AOC A7 would be achieved under the preferred alternative only. Material excavated from the
laboratory waste disposal areas will comply with action-specific off-site disposal requirements. For
AOC A7, a no-action alternative would not meet landfill closure requirements.
17
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At AOC A9, Alternatives 3 and 4 (the preferred alternative), will comply with action-specific off-site
disposal requirements for the material excavated from the hotspots. Since contaminated materials will
remain on site after stabilization in Alternative 5 at AOC A9, an action-specific requirement which covers
vadose zone monitoring would have to be implemented.
Long-Term Effectiveness and Permanence
At AOC A7, the preferred alternative involves excavation and off-site disposal of hazardous laboratory
wastes, and placement of a cap over the landfill area and all contaminated soil from both AOCs A7 and
A9. The preferred alternative provides an effective method of long-term containment of contaminated soil
and debris. However, the effectiveness of containment is dependent on adequate maintenance of the
landfill cap. The preferred alternative is distinct from Alternative 2 because it consolidates contaminated
soil from AOC A9 beneath the cap. At both AOCs, the No Action alternative provides no long-term
effectiveness because of the continuous potential for contaminant migration and/or direct contact to
contaminants.
At AOC A9, Alternative 2, the Limited Action alternative, provides a moderately effective method of
preventing direct contact exposure to contaminated soils. Alternative 3, which involves off-site disposal,
is permanent for the site. Alternative 5, solidification, is a proven treatment process for inorganic
contaminants; however, a treatability study and a long-term monitoring program would be required to
determine effectiveness.
Reduction of Toxicirv. Mobility, or Volume Through Treatment
None of the alternatives at AOC A7 involve treatment or destruction. The preferred alternative provides
the greatest reduction in potential mobility of site-related contaminants through a multi-layer cap. The cap
minimizes infiltration and subsequent leaching of contaminants from wastes in the unsaturated zone to the
ground water, as well as erosion of surficial contamination and the potential formation of leachate seeps
through the side slope of die cap. Alternative 2 at AOC A7 is similar to the preferred alternative except
that soil from AOC A9 is not placed beneath the cap. There is no reduction in toxicity, mobility or volume
associated with Alternative 1, the No Action alternative, at either AOC A7 or AOC A9.
At AOC A9, Alternatives 1 and 2, the No Action and Limited Action alternatives, provide no reduction
in toxicity, mobility, or volume. Alternative 3 does reduce toxicity, mobility, and volume of soil
contaminants by removing contaminated soil from the Annex. Alternative 5, which involves solidification,
reduces both the toxicity and mobility of inorganic contaminants, but the volumes of these contaminants
remain unchanged.
Short-Term Effectiveness
At AOC A7, the SC alternatives (Alternatives 2 and 3, the preferred alternative) would be effective in the
short term. Because of the potential for release of contaminants during the excavation activities, however,
engineering precautions would be taken to lessen the potential for contaminant emissions, to ensure
short-term protection of workers and area residents.
At both AOCs A7 and A9, the No Action alternatives (Alternative 1 at both AOCs) pose no risk to
remedial workers or the community because there is no remedial action; however, it provides no short-term
effectiveness because of the continuous potential for contaminant migration. At AOC A9, alternatives that
18
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involve soil excavation and transport (Alternatives 3 and 4), or excavation and mixing (Alternative 5)
would require engineering precautions to prevent or minimize short-term exposure of site workers to soil
contaminants. Alternative 5 requires addition of alkaline materials to contaminated soil, whirh slightly
increases the likelihood of injury or dust exposure.
Implementabiliry
At both AOCs A7 and A9, the No Action alternative (Alternative 1) is easiest to implement because no
remedial action is required. At AOC A7, Alternatives 2 and 3, which involve construction of a multi-layer
cap, are equal in implementabiliry, although placement of the geomembrane liner requires some skilled
labor.
At AOC A9, Alternative 2 is easily implementable because it only involves limited actions. Alternatives 3
and 4, which involve excavation and disposal either off site or at AOC A7, respectively, are also easily
implementable. Alternative 5, soil solidification, is a proven technology which is easily implemented
technically and administratively.
Cost
The costs of an alternative include the capital cost of implementing an alternative, as well as the O&M costs
over a 30-year period. The total cost of a remedial action is expressed as the present worth of both capital
and O&M costs. The estimated costs of the alternatives increase incrementally with the increasing
sophistication of the remedial action, from the No Action alternative to the preferred alternative, which
involves construction of a multi-layer cap. The preferred alternative (Alternative 4) for AOC A9 is the
least costly among the alternatives evaluated, excluding the No Action Alternative.
State Acceptance
State acceptance addresses whether, based on its review of the Addendum to the SI/RI Report, FS Report,
and Proposed Plan, the State concurs with, opposes, or has no comment on the alternative the Army is
proposing as the remedy for AOCs A7 and A9. The State has reviewed and commented on the Proposed
Plan and the Army has taken the State's comments into account. The State concurs with the selected
remedy for AOCs A7 and A9. A copy of the State's declaration of concurrence letter is included in
Appendix E.
Community Acceptance
Community acceptance addresses whether the public concurs with the Army's Proposed Plan. Community
acceptance of the Proposed Plan has been evaluated based on comments received at the public hearing
(dated June 14, 1995) and during the public comment period. This is documented in the transcript of the
public meeting in Appendix B. Based on die public comments, the public is in agreement regarding the
preferred remedial alternative as presented in the Proposed Plan.
X. THE SELECTED REMEDY
Based on the potential risks to human health and the environment posed by existing site conditions at the
Annex, and the proximity to the Assabet River, stabilization of site conditions at AOCs A7 and A9 was
determined to be of high priority. Because AOC A7 contains a landfill for which many remedial
19
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alternatives are impracticable due to implementabiliry or cost, a remedial action to stabilize existing
conditions and provide SC was determined to be appropriate. This approach is consistent with the long-
term cleanup goals at the Annex and is supported by the expectations of the Superfund program, as listed
in the NCP. 40 CFR 300.430(a)(l). The NCP indicates that the principal threats posed by a site should
be treated wherever practicable (such as in the remediation of a hotspot) and that engineering controls, such
as containment, are appropriate for waste that poses a relatively low long-term threat or where treatment
is impracticable.
A. CLEANUP LEVELS
To meet the RAOs identified in Section Vn. the Army proposes to conduct an action intended to provide
SC and stabilize existing site conditions. For the laboratory waste at AOC A7, no specific cleanup levels
were developed since the waste will be excavated and transported off site for treatment and disposal.
For the contaminated soil at AOC A9, the Army has established a cleanup level of 30 parts per million
(ppm) for arsenic and 20 ppm for thallium. These cleanup levels are based on risk and will be protective
of public health and the environment. A letter from USEPA dated May 19, 1995, presented the
development of the risk-based cleanup level for diallium (USEPA, 1995). Cleanup levels for ground water
will be developed as appropriate within the MOM operable unit for AOCs A7 and A9.
B. DESCRIPTION OF THE REMEDIAL COMPONENTS
The Army's preferred SC alternative (Alternatives 3 and 4 for AOCs A7 and A9, respectively, as presented
in the FS) is summarized as follows. The selected alternative involves isolating the landfill area at AOC A7
to minimize direct exposure to landfill materials and infiltration of precipitation, thereby limiting production
of leachate and impacts to ground water quality and the Assabet River. The alternative also involves
eliminating any future direct contact to contaminated soils at AOC A9. Major components of the selected
alternative for AOCs A7 and A9 are described below.
PREFERRED ALTERNATIVE SUMMARY
- Site Preparation and Grading
- Excavation and Off-Site Treatment and Disposal of Laboratory Waste at AOC A7
- Excavation of Contaminated Soil from AOC A9 and Consolidation at AOC A7
- Construction of RCRA Subtitle C Landfill Cap at AOC A7
- Environmental-Monitoring and O&M at AOC A7
- Institutional Controls at AOC A7
- Five-Year Reviews at AOC A7
Estimated Cost to Implement:
Estimated Capital Cost: $ 1,641,570
Estimated O&M Costs (present worth): $620,380
Estimated Total Cost Including 20% Contingency (present worth)*: $2,475,270
*Cost for five-year reviews at AOC A7 only.
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Excavation and Off-Site Treatment and Disposal of Laboratory Waste at AQC A7
Prior to construction of the landfill cap, laboratory waste will be excavated and transported off site for
treatment and disposal at an approved facility. The laboratory waste is being removed because it is
considered to be the primary source of ground water contamination.
The method of disposal or treatment of the laboratory waste will be determined during the remedial design
phase. The determination will reflect the requirements of CERCLA 120(b)(l) that "remedial actions in
which treatment which permanently and significantly reduces the volume, toxicity, or mobility of hazardous
substances, pollutants or contaminants, as a principal element, are to be preferred over remedial
alternatives not involving such treatment."
Excavation of Contaminated Soil from AOC A9 and Consolidation at AQC A7
Prior to construction of the landfill cap, contaminated soil from AOC A9 will be excavated and
consolidated at AOC A7. Excavated materials from other areas on the Annex may be used at AOC A7
as fill material to meet the subgrade design specifications for the AOC A7 landfill cap. Before material
from other sites is used as subgrade material at AOC A7, the Army will be required to comply with
CERCLA and the NCP for any areas which are CERCLA sites, and determine if the material to be
consolidated is hazardous and subject to RCRA LDRs, 40 CFR Part 268.
Construction of RCRA Subtitle C Landfill Cap at AOC A7
A multi-layer cap will be placed over the landfill area, as indicated on Figure 3. To minimize the size of
the final cap, contaminated soil and other solid waste at AOC A7 will be consolidated to within the extent
of the cap. The cap will cover approximately two acres and be designed in accordance with USEPA
guidance (USEPA, 1991b). Site-specific factors will be evaluated in determining an effective cap design.
The cap will provide a barrier to infiltration and direct precipitation runoff away from landfill materials.
The north side of the landfill, along,the Assabet River at AOC A7, is very steep and requires stabilizing.
Options to address the steep slope are regrading, or construction of a revetment or gabion wall. The
.determination of die option for the steep slope will be made during the remedial design phase.
Environmental Monitoring and O&M
Following construction of the landfill cap, the Army will conduct ground water monitoring and O&M of
the containment system. The environmental monitoring program would be submitted for regulatory review
and approval, and will identify the sampling locations and frequencies. O&M of the landfill cap will
include inspections and, if needed, repair and/or maintenance of portions of the cap, fencing, and
monitoring wells.
Institutional Controls
The selected alternative requires institutional controls and land use restrictions to prevent future use of the
land at AOC A7. Restrictions on land use at AOC A7 will be implemented by the Army to limit future
use.
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Five-Year Reviews ai AOC A7
The Army will review the conditions at AOC A7 at least once every five years. The purpose of the
five-year review is to ensure that the remedial action continues to protect human health and the
environment, and is functioning as designed.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at AOC A7 and AOC A9 of the Annex is consistent with
CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human health and
the environment, attains ARARs and is cost effective. The selected remedy meets USEPA expectations
regarding Superfund remedial actions, including mitigation of the principal threat (i.e., removal and off-site
disposal of the laboratory waste) to human health and the environment, and the use of engineering controls
such as containment of contaminated soil that poses a relatively low long-term threat, or for which
treatment is impracticable.
A. THE SELECTED REMEDY IS PROTECTIVE OF HUMAN HEALTH AND THE
ENVIRONMENT
The remedy at AOC A7 and AOC A9 of the Annex will permanently reduce the risks posed to human
health and the environment by eliminating, reducing or controlling exposures to human and environmental
receptors through engineering and institutional controls. Removal and off-site disposal of the laboratory
waste from AOC A7, construction of a RCRA Subtitle C multilayer cap over the solid waste at AOC A7,
and removal of several hotspots from AOC A7 and AOC A9 and consolidation under the cap will aD act
to prevent exposure to die contaminants. The cap will also prevent infiltration of precipitation through
unsaturated waste materials and the resultant generation of leachate. Moreover, the selected remedy will
achieve potential human health risk levels that attain the 10~* to 10* incremental cancer risk range and a
level protective of noncarcinogenic endpoints, and will comply with To Be Considered (TBC) criteria and
guidance.
B. THE SELECTED REMEDY ATTAINS ARARS
The remedy at AOCs A7 and A9 will attain all federal and state ARARs. Where no ARARs were
available, policies, criteria, and guidance were listed with status as TBC. ARARs and TBCs for AOCs A7
and A9 were identified during both the RI and FS. Appendix C presents tabular summaries of all ARARs
and TBCs previously identified, including a regulatory citation, a requirement synopsis, and the action to
be taken to attain die requirement. The following narrative presents a summary of die key ARARs and
their applicability to die selected combined remedy for AOCs A7 and A9.
Chemical-Specific ARARs
These ARARs are numerical values or procedures that, when applied to a specific site, establish numerical
limits for individual chemicals or groups of chemicals. Chemical-specific ARARs are generally health-
or risk-based standards limiting the concentration of a chemical found in or discharged to the environment.
AOCA7: There are no chemical-specific ARARs for AOC A7 for this SC ROD since die area will be
covered with a landfill cap.
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AOCA9: At AOC A9, arsenic and thallium are the contaminants that have been detected at levels that pose
a risk. Since no federal and state chemical-specific ARARs for soils exist, the Army and the USEPA have
developed risk-based cleanup levels for arsenic and thallium using a guidance document (USEPA, 199la).
This guidance is listed as TBC in the ARARs table for AOC A9 in Appendix C.
Location-Specific ARARs
Location-specific ARARs set restrictions on the types of remedial activities that can be performed based
on site-specific characteristics and location. No location-specific ARARs were identified for AOC A9.
Action-Specific ARARs
Action-specific requirements set controls or restrictions on the design, implementation, and performance
of waste management actions. They are triggered by the particular types of treatment or remedial actions
that are selected to accomplish the cleanup. After remedial alternatives are developed, action-specific
ARARs and TBC guidance that specify performance levels, as well as specific levels for discharges or
residual chemicals, will provide a basis for assessing the feasibility and effectiveness of the remedial
actions.
Landfill Closure: The following is a list of the federal and state ARARs that pertain to the construction of
the landfill cap, to storm-water management, to environmental monitoring, to consolidation, and to other
various activities at AOC A7.
Prior to construction of the landfill cap, excavated materials from other areas on the Annex may be used
at AOC A7 for fill material to meet the subgrade design specifications for the AOC A7 landfill cap. Before.
material from other sites can be used as subgrade material at AOC A7, the Army will be required to
comply widi CERCLA and the NCP for any areas which are CERCLA sites, and determine if the material
to be consolidated is hazardous and subject to RCRA LDRs, 40 CFR Part 268. If the material is non-
hazardous, it may be used for subgrade fill at AOC A7. If it is determined to be hazardous, it may not be
used for subgrade fill at AOC A7 unless it is treated in accordance with LDR requirements prior to usage.
Although AOC A7 will be receiving contaminated soil from AOC A9, it is not necessary for AOC A7 to
obtain any Federal or State permits. AOCs A7 and A9 may be viewed as separate CERCLA facilities
which are noncontiguous, as defined in CERCLA §101(9). Therefore, AOC A7 is exempt from the permit
requirements because, under the NCP, h is appropriate to aggregate these facilities for the purpose of the
response action since they are related based on the threat posed and geography, and on the compatibility
of the selected disposal approach [55 Federal Register (FR) 8690, March 8, 1990].
Federal
RCRA, Subtitle C, Subpart B - General Facility Standards (40 CFR §264.10 - 264.18);
RCRA Subtitle C, Subpart B - Construction Quality Assurance Program (40 CFR §264.19);
RCRA Subtitle C, Subpart C - Preparedness and Prevention (40 CFR §264.30 - 264.37);
RCRA Subtitle C, Subpart D - Contingency Plan and Emergency Procedures (40 CFR §264.50
- 264.56);
RCRA Subtitle C, Subpart F - Releases from Solid Waste Management Units (40 CFR §264.90
-264.101);
RCRA Subtitle C, Subpart G - Closure and Post-Closure (40 CFR §264.117 - 264.120);
23
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RCRA - Subpart N, Landfill Closure and Post-Closure Care (40 CFR §264.310);
RCRA Land Disposal Restriction (40 CFR 268); and
Clean Water Act: Final National Pollutant Discharge Elimination System General Permits for
Storm Water Discharges from Construction Sites; Notice (57 FR 44412-44435).
State
Hazardous Waste Rules (HWR) - General Management Standards for All Facilities (310 CMR
30.510);
HWR - Contingency Plan. Emergency Procedures, Preparedness, and Prevention (310 CMR
30.520);
HWR - Landfill Closure and Post-Closure Care [310 CMR 30.633(1) & (2B)];
HWR - Post-Closure [310 CMR 30.59l(b) & 30.592(b)];
HWR - Land Disposal Restrictions (310 CMR 30.750);
Massachusetts Surface Water Quality Standards (310 CMR 4.00); and
Massachusetts Ambient Air Quality Standards (310 CMR 6.00).
The following policies, criteria, and guidance (i.e., TBCs) will also be considered during the
implementation of the landfill closure remedial action:
RCRA Proposed Amendments for Landfill Closure (52 FR 8712);
USEPA Guidance: Design and Construction of RCRA/CERCLA Final Covers (EPA/625/
4-91/025); and
USEPA Guidance: Quality Assurance and Quality Control for Waste Containment Facilities
(EPA/600/R-93/182).
Laboratory Waste: During the RI at AOC A7, buried laboratory wastes were identified during test pit
excavations. Based on interviews, these wastes were dumped by Natick Laboratory employees in the
1970s. Removal of this laboratory waste and associated contaminated soil will trigger RCRA LDRs which
require treatment of wastes prior to disposal. Since the wastes nave been classified as F002 spent
halogenated solvents, they will be transported off site for treatment and disposal in accordance with the
requirements of the LDRs.
Soils subject to off-site disposal require hazardous waste characterization per 310 CMR 30.1245, and 40
CFR 261. Under these state and federal regulations, soils that are to be disposed off-site will be subject
to TCLP testing. TCLP characterizes soils as hazardous or non-hazardous depending on the leaching
characteristics of certain chemical constituents. The test is only applicable to wastes, but it is relevant and
appropriate to soils.
A detailed list of action-specific ARARs and their status are presented in Appendix C.
C. THE SELECTED REMEDIAL ACTION IS COST-EFFECTIVE
In the Army's judgment, the selected remedy is cost effective, i.e., the remedy affords overall effectiveness
proportional to its costs. In selecting this remedy, the Army first identified alternatives that are protective
of human health and the environment and that attain, or, as appropriate, waive ARARs. The Army
evaluated the overall effectiveness of each alternative by assessing the relevant three criteria-long-term
effectiveness and permanence; reduction in toxicity, mobility, or volume through treatment; and short-term
24
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effectiveness, in combination. The relationship of the overall effectiveness of this remedial alternative was
determined to be proportional to its costs. The costs of this remedial alternative are:
AOC A7
Estimated Time for Design and Construction: 2 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: 51,614,700
Estimated O&M Costs (present worth)1: 5595,360
Estimated Total Cost Including 20% Contingency (present worth): 52,419,235.
AOC A9
Estimated Time for Design and Construction: 3 months
Estimated Capital Cost: 526,870
Estimated O&M Costs (present worth): 525,020
Estimated Total Cost, Including 20% Contingency (present worth): 556,035.
D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTTONS AND ALTERNATIVE
TREATMENT OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTTCABLE-
Once the Army identified those alternatives that attain or, as appropriate, waive ARARs and that are
protective of human health and the environment, the Army identified which alternative utilizes permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. This determination was made by deciding which one of the identified alternatives provides
the best balance of trade-offs among alternatives in terms of: 1) long-term effectiveness and permanence;
2) reduction of toxicity, mobility or volume through treatment; 3) short-term effectiveness;
4) implementability; and 5) cost. The balancing test emphasized long-term effectiveness and permanence
and the reduction of toxicity, mobility or volume through treatment; and considered the preference for
treatment as a principal element, the bias against off-site land disposal of untreated waste, and community
and state acceptance.
The selected remedy provides the best balance of trade-offs among the alternatives. Excavation and off-site
treatment and disposal of the hazardous laboratory waste will provide reduction of toxicity, mobility, or
volume of the most contaminated material at the site. Residual soils contain much lower contaminant
levels. Capping of mis material will substantially reduce the contaminant mobility within and away from
the source area. Capping coupled with institutional controls is an effective measure for eliminating long-
term hazards associated with direct contact with the contaminants in soil. The long-term effectiveness of
this alternative will be monitored by management and maintenance of the cap system. This alternative is
relatively easy to implement. A relatively short duration is required to implement this alternative, thus
short-term risk to remedial workers would be minimal.
1The net present worth cost is based on a 7 percent discount rate and 30 years O&M.
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E. THE SELECTED REMEDY DOES NOT SATISFY THE PREFF.RFNCE FOR TRFATMFMT
WTJTCH PERMANENTLY AND SIGNIFICANTLY REDUCES THE TOXICITY. VfORn TTV DP
VOLUME OF THE HA7ARDQUS SUBSTANCES AS A PRINCIPAL ELEMENT
The selected remedy does not satisfy the statutory preference for treatment as a principal element due to
the impracticability of treating the landfill area (i.e., the implementability problems and prohibitive costs
which would be associated with treatment of the entire landfill). The selected remedy involves the removal
of the laboratory waste from AOC A7 and, eventual treatment and disposal off site. This permanently and
significantly reduces the toxicity, mobility, and volume of the laboratory waste. For the remaining
contaminated soil from both AOCs A7 and A9, the selected remedy provides only containment beneath a
RCRA Subtitle C landfill cap. This will result in a significant reduction of the mobility of contaminants,
but not their toxicity and volume. However, this material did not show the characteristics of toxicity based
on the TCLP results. The use of a RCRA cap for containing such waste will be protective of human health
and the environment to the maximum extent practicable. This approach is supported by the expectations
of the Superfund program, which indicates that for waste that poses a relatively low long-term threat or
where treatment is impracticable, engineering controls, such as containment, are appropriate.
XH. DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Army released the Proposed Plan for the SC remediation of AOCs A7 and A9 on June 1, 1995. The
preferred alternative included removal and off-site disposal of buried laboratory waste from AOC A7,
containment of the solid waste landfill area at AOC A7 with a RCRA Subtitle C cap, removal of several
hotspots from AOCs A7 and A9 and consolidation of this material under the AOC A7 cap. Since the
remedial action is identical to the remedy proposed in the Proposed Plan, no significant changes need to
be addressed.
Xm. STATE ROLE
The MADEP has reviewed the various alternatives and has indicated its support for the selected remedy.
The State has also reviewed the RT, Risk Assessment and FS to determine if the selected remedy is in
compliance with applicable or relevant and appropriate State Environmental laws and regulations. The
State of Massachusetts concurs with the selected remedy for the Annex. A copy of the declaration of
concurrence is attached as Appendix E.
XTV. REFERENCES
Dames & Moore, 1986. Remedial Investigation ofSudbury Annex, Massachusetts', Report No. AMXTH-
IR-CR86094, November.
OHM, 1995a. Final Feasibility Study Report for the Fort Devens Sudbury Training Annex, Areas of
Contamination A7andA9; Pittsburgh, PA; May.
OHM, 1995b. Draft Final Addendum to the Final Report Site/Remedial Investigation; Pittsburgh, PA;
April.
OHM, 1995c. Proposed Plan, AOC A7, the Old Gravel Pit Landfill, AOC A9, the POL Burn Area;
Pittsburgh, PA; June.
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USEPA, 1991a. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual
(Part B, Development of Risk-Based Preliminary Remedial Goals) Interim; Office of Emergency and
Remedial Response, Washington, DC; Publication 9285.7-01B; October.
USEPA, 199Ib. Design and Construction of RCRA/CERCLA Final Covers; USEPA/625/4-91/025,
USEPA Office of Research and Development, Washington, DC; May.
USEPA, 1995. Letter Regarding Fon Devens Sudbury Training Annex Area of Contamination A9, Risk
Based Soil Cleanup Level for Thallium; Boston, MA; May.
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FEATURES AND CONTAMINANTS OF CONCERN
AOCs A7 AND A9
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APPENDIX A
RISK ASSESSMENT TABLES
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APPENDIX A
SUMMARIES OF SOIL SAMPLING RESULTS
FOR AOCs A7 AND A9
The seven tables contained in this appendix present summaries of the soil sampling results for
AOCs A7 and A9. These data have been used as the basis for the human health risk assessment.
The source of these tables is Appendix C of the Draft Final Addendum to the Site/Remedial
Investigation Report submitted by OHM in April, 1995. The original table numbers have been retained.
A complete discussion of both the human health and ecological risk assessments for the Annex can be
found in Appendix C. Sections 3.0 and 4.0 of the Draft Final Addendum Report present area-specific
risk assessments for AOCs A7 and A9, respectively.
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Table 4-2
Phase I Total Soil Sampling Results - Area A7
Chemical
METALS:
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Vanadium
Zinc
VOLATILE ORGANICS:
1 ,1 ,2-Trichloroethane
1 ,2-Dichloroethane
Acetone
Chlorobenzene
Chloroform
Methylene chloride
Nonana
Octane
Propylbenzene
Tetrachloroethylene (PCE)
Toluene
Trichloroethylene (TCE)
Trichlorofluoromethane
Xylenes. total combined
alpha-Pinene
BNAs:
1 ,2.3.4-Tetramethylbenzene
1 ,3.5-Trimethylbenzene
1 -Ethyt-2-methylbenzene
2-Methytnaphthalene
Anthracene . -
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[b]fluoranthene
Benzo[g.h,i]peryiene
Bis (2-ethylhexyl) phthalate
Chrysene
Di-N-butyl phthalate
Frequency
(No. Detect/Total)
56/58
58/58
56/58
4/58
44/58
50/58
58/58
43/58
58/58
58/58
58/58
58/58
58/58
16/58
58/58
58/58
2/58
58/58
58/58
1/83
1/83
8/83
2/83
2/83
21/83
1/83
1/83
1/83
2/83
3/83
1/83
1/83
2/83
2/83
1/58
1/58
1/S8
3/58
2/58
2/58
2/58
1/58
1/58
13/58
1/58
33/58
Maximum Detection
(mg/kg)
1 8000.00
27.00
353.00
0.36
27.50
5420.00
270.00
11.90
250.00
22000.00
400.00
6670.00
480.00
0.92
18.70
6720.00
19.00
63.40
840.00
20.00
1.00
0.30
0.56
20.00
0.03
0.03
6.00
0.01
20.00
0.002
0.10
0.11
0.10
0.16
3.00
3.00
2.00
10.00
2.00
3.00
2.00
1.20
0.39
8.00
0.79
10.00
-------
Table 4-2 (continued)
Phaae I Total Soil Sampling Result a Area A7
Chemical
BNAs (cont.):
Fluoranthene
Fluorine
Hexadecanoic acid
lndano[1 ,2.3-c,d]pyrene
Naphthalene
Octadecanoic acid
Phenanthrene
Pyrene
Sulfur
PCS/PESTICIDES:
DDT
ODD
DOE
Dialdrin
Endosulfan sulfate
Heptachlor
Heptachlor epoxide
Lindane
PCB 1242
PCB 1248
PCB 1254
PCB 1260
alpha-Chlordana
alpha-Endosulfan
beta-Benzenehexachloride
beta-Endosulfan
gamma-Chlordane
HERBICIDES:
Dacthal (DCPA)
Silvex
EXPLOSIVES:
Cyclonite (ROX)
ORGANIC CARBON:
Total Organic Carbon
Frequency
(No. Detect/Total)
3/58
1/58
1/58
1/58
1/58
1/58
3/58
2/58
1/58
25/54
10/54
14/54
5/54
1/54
4/54
4/54
3/54
1/54
1/54
5/54
1/54
7/54
1/54
1/54
2/54
6/54
1/56
1/56
1/56
7/7
Maximum Detection
(mg/kg)
3.00
0.91
13.00
0.54
2.00
6.50
5.00
4.00
1.60
380.00
64.00
86.00
0.26
0.08
0.06
0.06
0.52
0.17
0.04
2.00
1.63
0.91
0.01
0.02
0.19
1.70
0.08
0.01
4.72
2480.00
NOTES:
DOT - 2.2-Bte(p
-------
Table 4-5
Summary of Phaee II Boring Resulte - Area A7
(values are In mg/kg unless otherwise noted)
Phase 1
Background Soil
Chemical 05% UCL
METALS:
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Nickel
Potassium
Sodium
Vanadium
VOLATILE ORGANICS:
Methyl ethyl ketone
BNAs:
Bis (2-ethylhexyl) phthalate
PCB/PESTICIDES:
2.2-Bit (p-chlorophenyl)-l .1,1 -trlchloroethane (DDT)
2,2-Bls(p-chlorophenyl)-1 .1 -dichloroethane (ODD)
2.2-Bis(p-chlorophenyl)-1 ,1 -dlchloroethene (DDE)
Llndane
ORGANIC CARBON:
Total Organic Carbon
2538
0.30
0.77
25.99
2.98
10.98
19381.77
40.71
2391.06
11.28
471.17
NO
27.22
ND
NO
0.09
0.02
0.03
ND
NA
A7SB51B
61 3
0.517
ND
26.9
3.67
18.6
16000
7.2
3910
12.3
2960
94.7
29.9
0.004
1.6
ND
ND
ND
ND
5850
A7SB52B
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
ND
ND
ND
3470
A7SB16B
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.033
0.023
ND
0.015
NA
A7SB18B
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.4
0.228
0.064
ND
NA
A7SB17B
A7SB19B (ug/l)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.8
1.2
0.065
ND
NA
1700
ND
5
26
ND
ND
ND
1100
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
56
NA
DUPSB02C
(ug/i)
600
ND
58
7.9
ND
ND
ND
610
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
23
NA
NOTES:
A7SB17B and DUPSB02C are leaphate samples (lull TCLP extraction analysis). Therefore, concentrations are reported as ug/l.
There were no positive detections for samples A7SB13B, A7SB14B, A7SB15B, and A7SB20B, which were analyzed for PCB/pesticides and organophosphorus pesticides only.
NA - Not analyzed
ND » Compound was not detected
-------
Table 5-2
Phase I Total Soil Sampling Results - Area A9
Chemical
METALS:
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Vanadium
Zinc
VOLATILE ORGANICS:
1.1.1 -Trichtoroethane (1.1,1 -TCA)
1 .1 ,3-Trimethylcyclohexane
1 ,3-Dimethylcyclohexane
1 ,4-Oimethylcyclohexane
Acetone
Ethylbenzene
Methylene chloride
Methylethyt ketone
Xylenes. total combined
alpha-Pinene
BNAs:
2-Methylnaphth«lene
Benzo[a)pyrene
Bis (2-ethylhexyl) phthalate
Chrysene
Di-N-octyl phthalate
Oibenzofuran
Fluoranthene
Ruorene
lndeno[1 .2.3-c.d]pyrene
NaphlheJene
Phenanthrane
Pyren*
Frequency
(No. Detect/Total)
40/40
40/40
40/40
2/40
21/40
31/40
40/40
19/40
40/40
40/40
40/40
40/40
40/40
1/40
40/40
40/40
40/40
40/40
3/40
1/40
1/40
1/40
4/40
2/40
14/40
1/40
4/40
4/40
1/40
1/40
18/40
1/40
1/40
1/40
4/40
1/40
1/40
1/40
3/40
1/40
Maximum Detection
(mg/kg)
12000.00
70.00
50.60
0.34
1.64
1550.00
24.50
6.10
75.00
17000.00
450.00
4070.00
410.00
0.11
13.90
2870.00
26.70
109.00
0.20
0.03
0.04
0.01
0.03
0.01
0.02
0.01
0.50
0.32
10.00
0.29
5.00
0.31
0.50
1.40
1.40
2.40
0.23
2.30
10.00
0.39
-------
Table 5-2 (continued)
Phase I Total Soil Sampling Results - Area A9
Chemical Frequency Maximum Detection
. (No. Detect/Total) (mg/kg)
PCB/PESTICIDES:
DDT 5/40 0.06
DDD . 1/40 0.09
DDE 2/40 0.03
Heptachlor epoxide 1/40 0.02
EXPLOSIVES:
2.6-Dinitrotoluene 1/40 1.10
ORGANIC CARBON:
Total Organic Carbon 15/15 19700.00
NOTES:
DDT = 2.2-Bis(p-chlorophenyl)-1,1.1-trichloroethan«
DDD = 2.2-8is(p-chlorophenyl)-1,1-dichloroethane
DDE = 2.2-Bis(p-chlorophenyl)-1,1-dichloroethene
-------
Table 5-4
Summary of Phas* II Surface Soil RmulU Area A9 (mg/kg)
Chemical
METALS:
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
Phase 1
Background Soil
95%UCL
13204.18
8.24
25.39
0.30
633.50
25.55
2.96
10.58
15381.77
40.71
2391.06
11.26
471.17
NO
NO
NO
27.22
39.75
A9SO78
14000
20
32.8
0.547
474
16.2
3.76
7.14
12000
26
2020
NO
766
0.45
61.7
304
22.9
28
A9SO8B
11000
4.1
75.8
NO
2010
53.9
3.96
11.7
16000
31
5720
12
2990
0.33
280
NO
48.7
42.3
A9SO98
7100
6.9
38.5
NO
926
13.7
NO
6.92
9900
35
2260
NO
1020
0.35
66.6
NO
20.3
28.6
A9S010B
11000
9.3
31.5
0.547
460
15.4
3.76
5.63
9900
270
1830
NO
608
0.51
NO
NO
' 20.3
28.2
NOTES:
NO - Compound was not detected
-------
Table S-6
Summary of Phase II Hand Auger and Soil Boring Results - Area A9 (mg/kg)
Chemical
METALS:
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cobalt
Magnesium
Potassium
Selenium
Phase 1
Background Soil
95% UCL
13204.18
8.24
25.39
0.30
633.50
2.96
2391.06
471.17
NO
A9HA5B
15000
140
42.7
0.676
369
4.86
2030
547
0.54
A9HA6B
17000
14
31.5
0.692
241
4.85
2170
411
0.49
A9HA7B
5200
6.4
18.1
ND.
601
ND
2150
1110
0.27
A9MA8B
7300
7.6
20.6
ND
373
ND
2730
1250
0.23
A9SB10B
4440
3.7
19.1
ND
510
ND
1820
1100
ND
A9SB11B
4960
4.1
22.7
ND
865
ND
1810
1020
ND
NOTES:
Those samples were analyzed for metals only
NO - Compound was not detected
-------
APPENDIX B
RESPONSIVENESS SUMMARY
-------
APPENDIX B
RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION
AOC A7 - The Old Gravel Pit Landfill
AOC A9 - The POL Burn Area
Fort Devens Sudbury Training Annex
Middlesex County, Massachusetts
The purpose of the Responsiveness Summary is to review public response to the Proposed Plan for
AOCs A7 and A9 at the Fen Devens Sudbury Training Annex. This summary also reviews public
comment on other remedial alternatives considered but not recommended. In addition, it documents the
Army's consideration of such comments during the decision-making process and provides answers to any
major comments raised during the public comment period for the Proposed Plan.
The responsiveness summary for the preferred alternative is divided into the following sections:
Overview - This section briefly describes the remedial alternative recommended in the
Proposed Plan and any changes to the Proposed Plan due to public comment:
Background on Community Involvement - This section provides a summary of community
interest in the proposed remedial alternative and identifies key public issues. It also describes
community relations activities conducted widi respect to diese issues.
Summary of Major Questions and Comments - This section summarizes verbal and written
comments received during the public meeting and public comment period, respectively.
Remedial Design/Remedial Action concerns - This section describes public concerns that are
directly related to design and implementation of the selected remedial alternative.
OVERVIEW
At the time of the public comment period, the Army had selected a preferred source control remedial
alternative for AOCs A7 and A9 at the Fort Devens Sudbury Training Annex in Middlesex County,
Massachusetts. The Army's preferred alternative addressed the problem of source control widi respect to
the presence of buried laboratory waste, solid waste, and soil contaminated with metals and pesticides.
The preferred alternative involved excavating the laboratory waste and transporting the waste off site to
an approved facility, excavation of contaminated soil and solid waste followed by consolidation in the
central landfill area of AOC A7, capping the landfill area widi a RCRA Subtitle C multi-layer cap, fencing
and institutional controls, environmental monitoring, operation and maintenance, site monitoring and
inspections, and 5-year reviews. This preferred alternative was selected in coordination with the USEPA
and MADEP.
Oral comments were received at die public hearing, however, no written comments were received
during the public comment period.
-------
.APPENDIX B
(CONTINUED)
RACKGROrND ON COMMUNITY INVOLVEMENT
Throughout the planning and investigative phases, the Army, USEPA, and MADEP have been
directly involved by reviewing and commenting on all proposals, project reports, and reviews. Periodic
meerjigs have been held to maintain open lines of communication and to keep all panics abreast of current
activities.
Citizen input during this process has been predominantly through the Technical Review Committee
(TRO established by the Army. Quarterly meetings of the TRC held since June 15, 1991. have brought
together local representatives from the towns of Sudbury, Stow, Maynard, and Hudson, and elected
representatives from both the state and federal levels. Local citizens interests were presented by
representatives from the 4-Town Families Organized to Clean Up Sites (FOCUS), the Lake Boon
Association, and the Organization for the Assabet River. The TRC has also included representatives from
the Fort Devens Environmental Management Office (EMO), USEPA, MADEP, the U.S. Fish and Wildlife
Sen-ice, the U.S. Army Environmental Center (USAEC. formerly USATHAMA), and the U.S. Army
Corps of Engineers (USACE). In addition, special Public Information Meetings followed by
queshon-and-answer sessions were held to present information about such topics at the USEPA's Federal
Facilities Superfund Remedial Program, the Army's Superfund program at the Sudbury Annex, the
Massachusetts State Public Involvement Program (PIP), and the Master Environmental Plan. Site visits
and tours were also conducted to familiarize any interested citizen or citizens and local, state, or federal
representatives or agencies with the various sites and the proposed plans for investigations. Both citizen
and regulatory agency input was solicited and considered during all phases of the project.
On June 1, 1995, the Army finalized the Proposed Plan. On June 7 and June 8, 1995, notices
appeared in the Enterprise Sun. Maynard Beacon, Southborough Villager, the Beacon, the Middlesex
News, and Sudbury Town Crier. The notices announced the date, time, and place of the public hearing
for the Proposed Plan and provided a name and phone number for questions or requests for further
information.
A public meeting was held on June 14, 1995, at 7:00 pm at the Stow Town Building on Great Road
in the Town of Stow, Massachusetts. The remedial investigations and the preferred remedial alternatives
for AOCs A7 and A9 were presented and discussed. Representatives at the meeting included: Tom Strunk
of the Fort Devens EMO; Bob Lim, Remedial Project Manager, USEPA; Mark Casella and Anne
Malewicz, MADEP; Debbie Acone, USAGE; Susanne Simon, ATSDR; and Stephen McGinn, Project
Manager, OHM. The informational meeting was followed immediately by a public hearing at which
formal public comments were solicited for the record.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS
The public comment period ended on July 5, 1995. No written comments or questions were received
during the public comment period. The following is a summary of major points and comments at the
public hearing and the Army's response. A transcript of the public hearing is also included in this
appendix.
-------
APPENDIX B
(CONTINUED)
Question:
What are the components of a RCRA Subtitle C cap. and how does the cap function after installation0
Response:
A large-scale color reproduction of Figure 4 was used as a display at the public meeting to show a cross-
section through the proposed RCRA Subtitle C landfill cap. It was explained that a base layer of sand at
least one foot thick would be placed above the waste to provide a secure surface to install the capping
system on. Samples of the geosymhetic clay liner, 30-mil HOPE geomembrane, geonet drain layer, and
10-ounce geotextile supplied by a manufacturer were passed around for inspection to all interested panics.
and the function of each cap component was explained. It was then pointed out that a minimum of 2 feet
of soil cover would be placed above the capping system to protect it, and that grass would be planted on
the soil cover to stabilize the surface.
Once the RCRA Subtitle C landfill cap is installed, access to the site will be restricted by a chain-link
fence. Future use of the site will be controlled by deed restrictions. Cap integrity will be preserved
through regular inspections and maintenance of the soil cover.
Question:
Who will maintain the Sudbury Training Annex after Fort Devens closes?
Response:
The U.S. Army will maintain the Sudbury Training Annex. At the present time, it appears likely that Fort
Drum will be responsible for implementing the Army's plans to remediate and maintain AOC A7.
Personnel from Fort Drum have already toured the site and are aware that there is an active citizens group
concerned with progress at the site. Fort Drum wants to ensure a smooth transition and is preparing to
assume responsibility for .the Sudbury Training Annex.
Question:
Is the Army planning to bring in wastes from sites not on the Sudbury Training Annex, such as Fort
Devens, for disposal in AOC A7?
Response:
No. Only contaminated soils and waste from sites on the Sudbury Training Annex will be placed beneath
the landfill cap in AOC A7.
Question:
The proposed plan only deals with soil contamination. What plans are there to address the ground water
issues and is mere a schedule?
-------
APPENDIX B
Response:
Soil remediation was separated from ground water remediation when it was decided that additional off-site
ground water investigation would be required to assess the extent of the chlorinated VOC and pesticide
plume originating in AOC A7. This was done so that soil, or source control, remediation could be initiated
without being delayed by the data gap in the ground water investigation. The U.S. Army Corps of
Engineers real estate office has contacted the landowner downgradient of AOC A7 requesting permission
to install and sample monitoring wells on his property. The Army is now awaiting permission.
There is no schedule at this time regarding the ground water investigation. The investigation is considered
to be ongoing and additional off-site monitoring wells will be installed and sampled as soon as possible.
Once analytical data is received regarding ground water quality downgradient of AOC A7, a proposed plan
for ground water will be prepared if a remedial response is warranted.
Question:
How will the Sudbury Training Annex be affected by the Base Realignment and Closure (BRAC) process?
Who will be responsible for deciding what parts of the Annex can be released, and what parts will be
retained for further investigation and/or remediation?
Response:
The BRAC process will require "fence-to-fence" surveys before any decision can be made about what
sections of the Annex can be released. Although some of the surveys, such as the historical and
archaeological, have been completed, ordnance, radiological, and other surveys must be completed before
any pan of the Annex can be released.
It was also pointed out that the Army cannot and will not act unilaterally under the BRAC process. The
USEPA, the MADEP, and citizens groups will all pay an active part in the process.
-------
0001
5 PUBLIC HEARING
7
8 Sudbury Training Annex
9
10 Proposed Plan.
12
1 2
i ^
15 held at:
15
17 Stow Town Building
13 380 Great Road
13 Stow, Massachusetts
2: June 14, 1995
21 7:0'0 p.m.
22 (Robin Gross, Registered Professional Reporter)
23
24
-------
0002
1 PROCEEDINGS
2 ' COMMENT PERIOD
3 MR. DARGATY: What type of thicknesses are
4 you talking about as far as the layers cf sar.d?
5 MR. McGINN: The base layer here is a foot
6 thick. That whole material right there, the whole
7 package together is less than half an inch.
8 "MR. DARGATY: How about en top?
9 MR. McGINN: Two feet of soil on top, and
10 that will all be grassed over.
11 MR. DARGATY: How about preventing people
12 from inserting poles in there, pipes or anything
13 else?
14 MR. McGINN: Part of what goes on is the
15 whole thing will have a security fence around the
16 perimeter.
17 MR. DARGATY: For always?
18 MR. McGINN: Always. The access will be
19 limited to that' site.
20 MR. STRUNK: It's there now, if you've been
21 to the site, a chain link fence about 8 feet high
22 and locked gate all around A7, and that will always
23 stay.
24 - MR. DARGATY: So the town will never think
-------
3003
of putting anything en there.
2 MR. STRUNK: I think you could do a
3 restriction on the prcperty. Fort Devens actually
4 will do a restriction that that will never be -
5 that will prevent access to that site.
MR. McGINN: And also the plan includes 30
7 years worth of maintenance and monitoring on the
3 site, which includes regular inspections of all the
5 security arrangements, the fences, you know, the
ID soil cover and all thaz.
11 MR. RUZICH: What's the presumed life of a
12 cap like that?
13 MR. McGINN: I don't know, to tell you the
14 truth. At leas- 30 years. I honestly -don't know.
15 I've never been asked chat question before.
1- MR. STRUNK: We're into the comment period,
17 by the way. As scon as the questions started. I'll
13 just make it formal.
15 MR. DARGATY: Then what happens after 25 or
2: 30 years?
21 MS. RUZICH: That's matter transmitters.
22 Star Trek.
23 MR. McGINN: There you go. That will be up
24 to-the regulators at -he time.
-------
OCC4
1 XR. RUZICH: What does that stuff dc with
2 tree rcots?
3 MR. McGINN: You don't let trees grow or.
4 it. That's part of the maintenance on the site.
5 But all you really want up here is grass, for the
6 most part.
7 ".MS. RUZICH: Who will physically be in
8 charge of the maintenance if Fort Devens closes?
9 Has it been assigned to anybody at this point?
10 MR. STRUNK: Well, the last ripple I've
11 heard in this continuous thing, Cindy, is it would
12 be Fort Drum that would take over the responsibility
13 for Sudbury and the Annex.
14 MS. RUZICH: Do they know where Stow,
15 Massachusetts, is?
16 MR. STRUNK: Yes, they've been here.
17 They've toured the site.
18 MS. RUZICH: Really? That's great.
19 MR. STRUNK: I've made them aware. Stow is
20 very aware of concerns. And I've made it clear we
21 have a very loud local voice. And Fort Devens is
22 the voice that people depend on for accurate
23 information about the Annex, and they were aware of
24 that issue. I said, probably unlike other sites
-------
0005
1 you've deal- with, the community is very much on top
2 of what the Army is doing. And they wanted to make
3 sure -hat everything, the transition was very smooth
4 and they understood everything. So they did a tour
5 of the Annex, particularly these specs right here.
6 MS. RUZICK: Whac, will they be one party
7 to the agree-.ent, or is it just that the Army does.
8 the signing and then the Army, someone in
9 Washington, would assign this to Fort Drum?
10 MR. STRUNK: The major command, force
11 command, would assign the responsibility for the
12 Annex to Fore Drum. The rest of Fore Devens itself,
13 the enclave chat's going to remain would be the Army
14 reserve unic in the center secticn, that will be
15 controlled by Fort McCoy in Wisconsin and Fort Drum
16 is upper New York state, the installation that sent
17 the troops ccwn to Haiti, 10th Mountain Group, I
18 think. But chat's the latest I've heard. That's
19 subject to change, again, as these things go back
20 and fcrth ar.i different generals yell at different
21 generals. I hope, it's Fort Drum, I think. They
22 seem co be prepared to do it.
23 MS. RUZICH: You had mencioned when we were
24 talking befcre about moving with the excavated soil
-------
;:os
1 and.that you would be bringing things into this area
2 that's being capped. Are we bringing in things from
3 off-site? Are we taking stuff, say, from Fort
4 Devens and bringing it here?
5 MR. STRUNK:. No.
6 MS. RUZICK: Cr is it just A7 and A9?
7 MR. STRUNK: As well as A7 and A9, Cindy,
8 what I've been discussing with Bob Lim at EPA is we
9 have other removals to do, local ones, 100 yards
10 here, 120 yards there.
11 MS. MALEWICZ: On site.
12 MR. STRUNK: We had planned to do that
13 off-site, but we found they are less contaminated
14 than other soils that exist there. So to save
15 money, and for expediency,. we1re going to work cut
16 to save these small removals from other these other
17 sites under the cap also instead of going off-site.
18 The amount of money that's saved is incredible.
19 Because there was a soil treatment plan on one that
20 if we don't treat the soil at all the major cosz of
21 the whole removal disappears. It's just so simple;
22 and to coordinate iz in time so this is all done at
23 the same time and we don't get involved in spending
24 money sending stuff zhaz doesn't need to be senc off
-------
0007
base. So it's only scuff frcm the Sudbury Annex.
MS. MALEWICZ: According to the state
regulations they would not be permitted to take
off-site waste.
MR. STRUNK: That's true.
MS. RUZICH: I just wanted to make sure it
aidn't become sort of a generic landfill for
whatever.
MS. MALEWICZ: No, no.
MR. LIM: That wouldn't happen.
MR. DARGATY: What are we talking about,
50,000 square feet?
MR. STRUNK: Probably more, an acre and how
much?
MR. McGINN: The whole cap area now is
running just about two acres.
MR. STRUNK: That's, what, 43 feet, 46,000
square feet an acre, so it would be 86,000.
MS. RUZICH: Let's see, a couple of other
things. One was more administrative. What are your
requirements for posting this meeting and
advertising the meeting; and did we do that? I
couldn't find an ad in the Maynard Beacon, the last
issue. I did find one in Stow, but have you done
-------
0008
1 everything about --
2 MR. STRUNK: I have the credit card for
3 newspapers like we did, Cindy, a display ad, and we
4 have the tear sheets back from the newspaper.
5 They'll tear the ad out to prove they printed it and
6 send it in before we pay them. So it was all done
7 by credit card, it was done three weeks ago. So
8 it's been out.
9 MS. RUZICH: Okay.
10 MR. STRUNK: I sent the TRC members -- all
11 TRC members had a notice and everything. So I think
12 we pretty well covered it.
13 MS. RUZICH: One thing I wanted to say was,
14 you know, I appreciate that we're finally doing
15 this. It's been five years since we started doing
16 this. In fact, the first meeting that I attended
17 was in July of 1990. I think the only people who
18 were the same people who were here are the three of
19 us from Focus. I think everybody else has gone
20 through one or multiple revisions of individuals at
21 this point, and I appreciate that we finally got
22 here. This may be a record in terms of federal
23 Superfund, only five years to get to talking about
24 do-ing a cleanup.
-------
n o ^ s.
U J J I?
1 Let's see, the other question I had was you
2 had mentioned that the area going downstream from
3 OHM, A7-51 well, that you would be looking
4 off-site. Why wasn't that, if you suspect that
5 something is -.igrating off-site, why did the
5 investigation stop at the boundary? Because if the
7 suspected contamination is coming from A7, shouldn't
8 the off-site area that's downstream be a part of
9 that same investigation and the same treatment?
10 MR. STRUNK: When it became clear that we
11 wouldn't be able to resolve the groundwater issue
12 until we .had additional wells downgradient, I
13 requested frcr. the Department of Army -headquarters
14 permission tc put off-site wells. They granted that
15 permission; the Corps of Engineers real estate
16 office has sent a letter requesting right of way to
17 the landowner. The landowner in this case has
18 agreed, but they haven't returned the letter yet.
19 So we don't have in it in our hands. But once
20 that's --
21 MS. P.UZICH: Is that the Sand and Gravel --
22 MR. -TRUNK: Apparently the person who owns
23 that owns quite a bit of land along there.
24 MS. P.UZICH: Malone, Crow Island?
-------
0 C" "
1 MR. DARGA7Y: Malone Sand and Gravel.
2 MR. STRUNK: And apparently Che way chat
3 land is situated, it would never be considered
4 buildable property or anything like that; ar.d he
5 didn't mind. So I haven't yet received the formal
okay from the landowner for those wells, but as seer.
l as that's aboard we plan to put in two or three
3 wells between the perimeter of the Annex ar.d the
9 Assabet River. And that's information we really
1C need in order to --
11 MS. RUZICH: So we're really only dealing
12 with the soil contamination in this step. Does the
13 document itself require that the groundwater issues
14 be dealt with in a specific period of time?
15 MR. STRUNK: I would say that, let's see,
15 our original schedule on the ROD called for a Record
17 of Decision in the fall of 1996. That was the
13 original AIG schedule. And we didn't want to delay
15 the whole ROD until we had resolved the grcundwater,
2C so at EPA suggestion we kept on schedule ar.d kept
21 the source control moving by just breaking it out
22 and dealing with the source control first; let's cez
23 that done, and then as we learn more we car. get the
24 wells in. Hopefully we can develop a plan for
-------
0011
', dealing with the groundwater situation, if there is
2 one that really needs to be dealt with. And if
3 that's the situation I'd like to see that as fast as
4 I can and. hopefully, on schedule.
5 'AS. RUZICH: I guess what I'm asking is,
6 we're doing this piece, and one of the biggest
7 concerns we have had over time is the piecing up of
3 the Annex, is this' little spot is clean so we don't
9 have to wcrry about this and you're checking it off
10 bit by bit, and in the meantime the Army is shutting
11 dcv/n operations in Massachusetts. So I guess what
12 I'm asking is, is there a scheduled date at this
13 pcint for the groundwater treatment?
14 MR. STRUNK: No, we don't have one. And
15 that's a good point.
15 MS. ACONE: We couldn't get closure on this
17 site until we clean the groundwater. The site
13 wouldn't close.
19 MR. LIM: As far as the groundwater
20 contamination, as far as we're concerned, the
21 investigation is still continuing in the
22 grcundwater. And that the FS, however, evaluated
23 the remedy for the groundwater, which is a
24 groundwater collection trench. However, we
-------
0312
1 recognize that there was a missing piece of data
2 between 51 and the Assabet River -hat we needed co
3 fill that data gap. The grcundwacer investigation
4 is still considered ongoing, and the Army will be
5 installing monitoring wells as seen as we can.
6 MS. RUZICH: I'm confused on "little site,
7 big site." We've got lots of little sites within
8 one big Superfund site. The entire Superfund site
9 will not be released until that groundwater patch is
10 dealt with and all the other issues in the site as
11 well?
12 MR. LIM: All the other sites, as you're
13 talking about, the other study areas.
14 MS. RUZICH: So as a whole group it doesn't
15 get released until every last one of them is
16 finished in terms of the EPA's --
17 MR. DARGATY: You don't know that for sure,
18 do you? They could possibly release some areas
19 where groundwater is not affected.
20 MR. LIM: As far as that would --in the
21 base closure process, from what I understand, the
22 base gets divided into clean and dirty parcels, and
23 cnce Sudbury goes final on the base closure list we
24 would go through the process of I suppose parceling
-------
1 che Annex as far as what's clean and what's dirty.
2 And, you know, there's other processes
3 within the base closure process that I'm net
4 entirely aware of; cut under the current ncn-base
5 closure situation that Sudbury is still in, the
6 Annex wouldn't be released in any way until all
7 cleanup at all sites are completed.
8 MS. RUZICH: Does the base closure happen
9 in October of this year then? Is that the plan?
10 MR. STRUNX: No, I'm not certain, Cindy.
11 It's July Is- Congress will accept the bases that
12 are proposed on the list, which Sudbury Annex is,
13 and after that I'm not sure. I haven't heard really
14 what a clear outline is yet.
15 MS. RUZICH: So the Sudbury Annex isn't
16 tied to Fort Devens?
17 MR. STRUNK: No, it's separate. Fort
18 Devens was listed for base closure I think in 1991,
19 and the Annex was just placed on it this winter,
20 this January. So it's a separate entity. And
21 they've nominated rr.e to be the base closure
22 environmental coordinator for it and they have sent
23 all this early material down, but I have no
24 schedules frcm the Army yet. And I know basically
-------
1 what has to happen there, but it's going tc take a
2 while to do that.
3 MR. LIM: But in September, for our
4 September TRC, I'm sure we'll know more
5 information. We'll be able to perhaps give a brief
o outline of the process as far as the federal
7 screening process and all the other base closure
8 type processes that I'm sure you are concerned
9 about, about the property and parceling and stuff.
10 MS. RUZICK: The question, the thing I'm
11 trying to find out, is even though the base is
12 closed does EPA retain jurisdiction over the cleanup
13 issue?
14 MR. LIM: Yes, I will still be the project
15 manager.
IS MS. RUZICK: So you essentially are the
17 person who agrees whether to release the whole
18 site?
19 MR. LIM: Yes. EPA is involved in that.
20 MS. RUZICH: So the Army can't choose to
21 say, "Well, we declare this square clean so we're
22 taking that and we're going to sell it and build
23 things without your cooperation"?
24 - MR. LIM: The Army cannot do anything
-------
0015
unilaterally. The EPA and 3E? will still be
2 involved.
3 MS. MALEWICZ: I car. add tc that a little
4 bit. I'm involved in the Wacertown Arsenal cleanup,
5 which is a base closing. And they prepare, the Arr.y
6 will send cut, once it's terrr.ed a BRAG site, if it
7 should becor.e a BRAG site, base closing site, they
8 will prepare what they call a CRFA document which is
9 available for public comment as well. At that ti-e
10 they will ask DEP and EPA on their recommendations
11 of what areas may be able to be released; in.other
12 words, are deemed clean in the sense that
13 historically they weren't used for anything, there's
14 no evidence of contamination, maybe some areas that
15 there's no further action.
16 With those recommendations, they will put
17 together a package saying XYZ area may be able to be
18 released. Then their real estate division will say,
19 you know, can the town use it now or could it be
20 used, so they can get that piece back into the
21 community. Water-town was a -- is a 55 acre,
22 originally 55 acre parcel and it's now a 37.5 acre
23 parcel, and because of the spotted contamination
24 deemed it wasn't sufficient to have any parcels
-------
parceled off for use right away.
2 So they do take the DE? and EPA's
3 recommendations to heart. And there's actually, if
4 it should go ERAC closing, we can provide you mere
5 information, get you up to speed, and there's an
6 actual formal process that you would be a part cf.
7 MR. STRUNK: Cindy, the things they are
8 funding for is doing a complete ordinance survey,
9 radiological survey, things that.hadn't been under
10 the investigation, remediation fund, that's covered
11 in BRAC, so it's a lot more extensive fence-to-fence
12 survey that covers a lot of things.
13 MS. RUZICH: They were supposed to do that
14 as part of the original work plan, a lot of those.
15 I think some cf that stuff actually did occur at
15 Sudbury.
17 MR. STRUNK: They have, actually, yes, in
13 the Sudbury Annex, a lot of things that would be
19 done under base closure have already been pretty
20 well completed, like the historical and
21 archeological survey. This is true.
22 Well, any further questions?
23 . MR. CASELLA: I've got a question for
24 Steve. Will the groundwater data be in, Steve,
-------
0017
1 before we initiate the capping operation for the
2 area? Is there enough time?
3 MR. McGINN: The additional groundwater
4 data?
5 MR. CASELLA: Yes.
6 MR. McGINN: I don't know what the schedule
7 is on that right now.
3 MR. STRUNK: I would imagine that it would
3 be. Don't you think, Debbie?
10 MR. DARGATY: It's eventually going to be
11 irrelevant, if you're going to remove all the
12 contamination before you cap it.
13 'MR. McGINN: Well, we're removing the
14 primary source of the contamination.
15 MR. DARGATY: You rr.ay still have scr.e in
15 there.
17 MR. McGINN: You've still got, you know, a
13 contaminated groundwater plume which is already
13 covering this area right here, so removing the
23 primary source is going to reduce the loading --
21 MR. DARGATY: Kcw far down are you going to
22 go, to the water level?
23 . MR. McGINN: As far as the excavaticn in
24 here? I'd say probably between 8 and 10 feet in
-------
CC19
1 some places. It will be below the top of the
2 groundwater.
3 MR. DARGATY: You will be below the
4 groundwater?
5 MR. McGINN: Yes. From what we can tell
5 right new, based on what we've seen in the borings
7 and what we've seen in the test pits and what we
8 have for grcundwater levels in here, it is below top
9 of the groundwater. Could be less than that in some
10 places, maybe a little more.
11 MR. DARGATY: If you were to remove all the
12 contamination, there still may be pockets that have
13 migrated down between the primary source and the
14 well you're going to dig, right?
15 MR. McGINN: Because we're already going to
15 see the contamination here in well No. 8 which is in
17 the source area and also downgradient of well No.
18 51. So, you know, you've already got contamination
19 from this area leaching out in this area, traveling
20 in the groundwater and is already in this area. And
21 where it extends out to over here is essentially --
22 MR. DARGATY: That's a slope, right?
23 . MR. McGINN: As far as the top of the
24 groundwater there, yes.
-------
1 MR. DARGATY: From che primary source co
2 where you're going to put the well, chat's like a
3 big slope, if I remember correccly.
4 MR. McGINN: It's kind of flat in this area
5 and slopes off pretty fast heading this way and then
6 shallows off, but this is a gradual easy slope all
7 the way down to the river.
8 MR. DARGATY: Does the water flow downhill
9 at that point, do you know?
10 MR. McGINN: Yes, it dees. Essentially
11 from the sice it's flowing straight across the site
12 this way (indicating).
13 MR. DARGATY: I know it's flowing down, bur
14 is iz flcwinc at an angle?
15 MR."McGINN: Oh, sure.
16 MR. DARGATY: Do you know that for sure?
17 MR. McGINN: You can see that the gradient
18 elevations from the downgradient of the groundwater
19 -- there's a slope on top of the groundwater. The
20 . slope on top of the groundwater is nowhere near as
21 steec as the slooe you're seeinc out here.
22 " MR. DARGATY: Will thac tell you something
23 as to what the depth of migrating contamination is
24 between the primary source and where.you're going to
-------
0020
dig your well?
2 MR. McGINN: Sure.
3 MR. DARGATY: If what you say is true, that
4 wouldn't be any deeper than what it is at the
5 primary source?
o MR. McGINN: Below the top of ground
7 surface, no.
3 MR. DARGATY: You wouldn't expect to find
9 contamination 20, 30 feet below, except for the
13 water?
11 MR. McGINN: Well, the answer to that is
12 sort of yes and no. In this particular case the
13 answer would be no. Based on the geology and the
14 hydrology out here, I would say the answer would be
15 no.
15 MS. MALEWICZ: Steve, can you clarify for
17 the audience why you're leaving certain materials
13 behind, like TCLP and why you're removing others? I
13 think that clarifies why the cap is appropriate and
23 why it is appropriate to leave some things behind.
21 MR. McGINN: Sure. This area in here,
22 we've had all the test pit results from this area.
23 Along with the test pits, you can see the squares,
24 we've get -- right through here we've got a variety
-------
0021
I -of them in here located or. top of geophysical
2 anomalies. We came through in this area and did the
3 geophysical surveys, located the test pits ever the
4 anomalies, essentially dug down to see what we could
5 find, what was buried out there. We dug down to a
6 depth of 6 feet in all these pits, took sar.ples at
7 2,4, and 6 feet below ground surface, and what
8 we're seeing is a definite difference between, what
9 we're seeing in this area here and what we're seeing
10 over in this area right here.
11 Primarily this is essentially solid waste
12 as opposed to liquid chemical waste over here.
13 Along with the chemical waste we've got in here
14 there's also, by test pit R, which is this one,
15 we've get buried drums and other lab waste here. We
16 do know we have had material leaching out of those
17 things, broken drums, broken glass containers; and
18 the type of chemical contamination you see here, is
19 actually different than what you see going on here.
20 We do see low levels of pesticides and some
21 metals in this area right through here, bur at much
22 lower concentrations than you're seeing over in this
23 area. Also, from what we can tell right new from
24 the test pits, the borings and all the other
-------
0022
1 information we've got, this material here, while
2 less hazardous than this material, also is at a
3 higher level relative to the top of groundwater. So
4 that the balance of the buried material out here is
5 not in the top of groundwater; also, there's not a
6 lot of material leaching out of it, or at this point
7 there's net a lot of material leaching out of it
8 getting down into the groundwater and then being
9 transported out.
10 We're fairly confident about saying that
11 the balance of the well control we've got out in
12 front of this area right here, these five wells
13 we've got which are downgradient of this whcle area
14 right here, show a lot, essentially a lot cleaner
15 groundwater out in front of this area than we're
16 seeing out in this area right here.
17 So this material, we're seeing some
18 contaminated groundwater here with the same
19 contamination that we're seeing in the soils and
20 groundwater up in the source area.
21 This area over here, we're seeing lower
22 levels of con-aminants and different types of
23 contaminants in the soils. And also we're not
24 seeing a lot of those contaminants out in the
-------
0025
I groundwater right: new. Which is why I feel
2 confident that you could go ahead and cap this stuff
3 and leave it right here and you know you're not
4 going tc be creating a problem for yourself down the
5 road; and why we think you can take this material
5 here and place it out here. Because essentially
7 this material out here is of the same nature and
8 character as what we see right here.
9 Then what appears to be hazardous materials
10 are all slated to be dug up and taken completely off
11 the site altogether, because the type of cap and the
12 situation here is not appropriate for containing
13 this kind of material.
14 MR. DARGATY: Well, Tom, if there's no
15 other questions, let's bang it up and go home.
16 "MR. STRUNK: Ckay, George. Like I said,
17 until July 5th if you want to write up any comments,
13 send them to me, I'll pass it on and we'll include
19 that in the formal reccrd. You're welcome to do
20 that; I appreciate it if you did. Anything that
21 came to your mind. And thank you very much for
22 coming cut this evening.
23 (Whereupon, the proceedings were
24 concluded at 8:00 p.m.)
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0024
1 CERTIFICATE
2 I, Robin Gross, Registered Professional
3 Reporter, do hereby certify that the foregoing
4 transcript, Volume I, is a true and accurate
5 transcription of my stenographic notes taken or Tune
6 14, 1935.
7
3
9
10 Robir. Gross
11 Recistered Professional Reporter
12
13
14 -
15
15
17
13
13
20
21
22
23
24
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APPENDIX C
ARARs
-------
APPENDIX C
ARARs
The ARARs tables contained in this, appendix are reproductions of those contained in the Final
Feasibility Study Report for the Fort Devens Sudbury Training Annex, Middlesex Counry, Massachusetts
submitted by OHM in May, 1995. The original table numbers have been retained for ease of
comparison.
-------
TABLE 3-2
FORT DEVENS SUDBURY TRAINING ANNEX - AOC A7
ARARs FOR EXCAVATION AND OFF-SITE TREATMENT AND DISPOSAL OF
LABORATORY WASTE AND CONTAINMENT BY RCRA SUBTITLE C LANDFILL CAP
1 .:::..--.-",.;.
Requinment \ SttOa
Requirement Synopsis
Action To Be Taken To Attain AKAK
ACTION-SPECIFIC
Laboratory Waste Fideral
RCRA - Identification and Listing of
Hazardous Waste (40 CFR 261)
RCRA - Land Disposal Restrictions
(40 CFR 268)
Off-Site Rule (40 CFR $300.440)
Relevant and
Appropriate
Relevant and
Appropriate
Applicable
Laboratory Waste - Slate
HWR - Requirements for Generators
(310 CMR 30.4000-30.416)
HWR - Use and Management of
Containers (310 CMR 30.680)
Soil - Federal
RCRA Subtitle C. Subpan B -
General Facility Standards (40 CFR
264.10-264.18)
Relevant and
Appropriate
Relevant and
Appropriate
Establishes definitions for solid and hazardous wastes. Sets forth
criteria used to identify hazardous waste and to list particular wastes.
Identifies characteristics of a hazardous waste and contains a
particular list of hazardous wastes.
Identifies hazardous wastes that are restricted from land disposal and
defines exemptions. Subpan D contains treatment standards for
RCRA-listed wastes.
Requires that hazardous substances, pollutants, or contaminants
transferred off site for treatment, storage, or disposal during a
CERCLA response action be transferred to a facility operating in
compliance with $3004 and $3005 of RCRA and other federal laws
and all applicable slate requirements.
Laboratory waste includes soil and debris contaminated by liquid
containers. The waste is assumed to be classified as FOU2 spent
solvents.
Removal of laboratory waste and associated contaminated soils triggers
LDRs. Since the wastes have been classified as F002 spent halogeiuicd
solvents, the wastes will be transported oft site lor treatment and
disposal in accordance with the requirements of the LDRs
Laboratory waste material will be transported to a TSDF that is in
compliance.
Requirements for generators, including accumulation of waste prior
to off-site disposal.
Requirements for use and management of containers.
Generator requirements will be complied with during excavation and
removal of laboratory waste materials.
Packing of laboratory waste materials will adhere tu these
requirements.
Relevant and
Appropriate
General requirements regarding waste analysis, security, training,
inspections, and location for any facility that treats, stores, or
disposes of hazardous wastes (a TSDF).
Requirements regarding security, training, and nispcuions will be met.
-------
TABLE 3-2
(CONTINUED)
KtguinmtiU
RCRA Subtitle C. Subpan B -
Construction Quality Assurance
Program (40 CFR 264. 19)
RCRA Subtilk C, Subpan C -
Preparedness and Preparation (40
CFR 264.30 - 264.37)
RCRA Subtitle C. Subpan D -
Contingency Plan and Emergency
Procedures (40 CFR 264 50 264 56)
RCRA - Subpan N, Landfill Closure
and Post-Closure Care (40 CFR
264310)
RCRA Subtitle C. Subpan G -
Closure and Post-closure (40 CFR
264.117-264.120)
RCRA Subtitle C, Subpan F -
Releases from Solid Waste
Management Units (40 CFR 264 90 -
264101)
RCRA Proposed Amendments for
Landfill Closure (52 FR 8712)
C^a^^tf
Rekvattaad
Approprii*
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
To Be Considered
Ktquiremtnl Synopsis
For all surface impoundments, waste piles, and landfill units, (his
regulation requires that a construction quality assurance (CQA)
program be developed and implemented. A written CQA plan must
identify the steps dial will be used to monitor and document the
quality of materials and their installation.
Requirements applicable to the design, operation, equipment, and
communications associated with a TSDF, and to arrangements with
local response departments.
Outlines general requirements for contingency and emergency
planning procedures for TSDF operations.
Final cover at a landfill requires die cover 10 be designed and
constructed to meet certain performance standards. Cover to provide
long-term minimization of infiltration. Settling and subsidence must
be accommodated. Post-closure use of properly must be restricted as
necessary to prevent damage to cover. Runoff and ninon must be
prevented. Protect and maintain surveyed benchmarks. References
{264. 1 17 - 264. 120 for maintenance and monitoring requirements.
Details general requirements for closure and post-closure of
hazardous waste facilities, including installation of a ground water
monitoring program and beginning a period of 30 years of post
closure care. {264. 1 19 requires the placement of deed restrictions.
Specifies compliance points and ground water monitoring
requirements for TSDFs during active-care and closure-care periods.
Corrective action program must be developed if monitoring shows
exceedences in limits.
Provides an option for die application of alternative closure and post-
closure requirements based on a consideration of site-specific
conditions, including exposure pathways of concern.
Action To Be Taken To Attain AKAK
A CQA program will be developed and implemented for the
construction of the land! ill cap at Area A7
Since these regulations are primarily intended lor facilities with indoor
operations and a landfill cap is being constructed at Area A7. only
requirements regarding communications equipment will apply dining
construction activities.
During all remedial action, a contingency plan wiUi emergency
procedures will be developed.
Cap design will meet performance standards. Kunolf and ninon
prevention measures will be taken. Surveyed benchmarks will he
protected.
Because Area A7 is being closed as a landfill, pans of tins requirement
concerning long-term monitoring and maintenance ot ilic sue are
relevant and appropriate. Sets a minimum of 3O year posi closure care
period. Deed restrictions will be placed resiricuug die future uses of
the site. A post-closure plan will be prepared. The plan will identity
monitoring and maintenance activities, and their .frequency
Ground water monitoring will be conducted following die construction
of the cap. Corrective action may be taken if monitoring warrants
action.
Cap and post-closure monitoring will be designed taking mui account
exposure pathways of concern
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TABLE 3-2
(CONTINUED)
Requirement
RCRA - Land Disposal Restrictions
(LORs) (40 CFR 268)
USEPA Guidance: Design and
Consuuction of RCRA/CERCLA
Final Covers (EPA/625/4-91/025)
USEPA Guidance: Quality
Assurance and Qualify Control for
Waste Containment Facilities
(EPA/600/R-93/I82)
Clean Water Act: Final NPDES
General Permits for Storm Water
Discharges From Construction Sites;
Notice (57 FR 44412-44435)
Soil- Stale
HWR - General Management
Standards for All Facilities (310
CMR 30.510)
HWR - Contingency Plan,
Emergency Procedures,
Preparedness, and Prevention (310
CMR 30.520)
Suau
Applicable
To Be Considered
To Be Considered
Relevant and
Appropriate
Rtquirimenl Synopsis
Land disposal of a RCRA hazardous waste is restricted without
specified treatment. It must be determined that the waste meets the
definition of one of the specified restricted wastes and the remedial
action must constitute placement" for the land disposal restrictions to
be considered applicable. For each hazardous waste, the LDRs
specify that the waste must be treated either by a treatment
technology or to a concentration level prior to disposal in a RCRA
Subtitle C-permilted facility.
USEPA guidance that provides technical guidance on the design and
construction of RCRA/CERCLA final covers.
USEPA guidance that provides technical guidance on quality
assurance and quality control measures for containment facilities.
Addresses NPDES permits for construction sites. For construction
sites greater than 5 acres, develop and implement storm water
pollution prevention plans. Storm water controls include stabilization
practices, such as seeding and geotextilcs. and structural practices,
such as silt fences, swales, sediment traps, basins, etc. Identify
maintenance procedures.
Relevant and
Appropriate
Relevant and
Appropriate
Establishes requirements for operation of facilities including security.
inspection, and personnel training.
Requirements for notification, safely equipment, and spill control for
hazardous waste facilities. A facility's contingency plan shall
include: procedures to be used following emergency situations and to
prevent hazards to public health, safely, or welfare and the
environment. Copies of the plan shall be submitted to the local police
and fire departments, hospitals, and emergency response teams.
Action To Be Taken To Attain ARAR
If soil at Areas A7 and A9 tail TC1.H idling, soil must be treated
before the final disposal. Soils that tail TC'I.P testing could nut be
consolidated under the landlill cap at Area A7.
Guidance will be considered in the design and construction ut the
landfill cap at Area A7
A construction quality assurance program will be developed tor the
remedial action at Area A7 based on this guidance document.
During construction, storm water management practices will be
implemented.
Requirements regarding security, inspection, and training will be met
during and after construction of the landlill cap.
During the remedial construction, safely and communication equipment
will be kept at the site, and local authorities will be laniilian^ed with
site operations. Plans will be developed and implemented during sue
work. Copies of plans will be kept on site.
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TABLE 3-2
(CONTINUED)
Keiuireme*! Symoptit
Action To Be Taken To Attain AKAK
HWR - Landfill Closure and Post
Closure Care (310 CMR 30.633(1) &
(28))
Relevant
Sets forth performance requirements for Che closure of a landfill. For
closure, the final cover must be designed and constructed to: provide
long-term minimization of migration of liquids through the closed
landfill; function with minimum maintenance; promote drainage and
inimiff erosion or abrasion of the cover; and accommodate settling.
Post-closure, long-term maintenance, and monitoring requirements
from 310 CMR 30.592 apply. Establishes a 30-year post-closure care
period (310 CMR 30.590) and ground water monitoring (310 CMR
30.660).
Landfill cap at Area A7 will be designed to meet performance sundards
lor this requirement. Following construction, long-term monitoring . ..
maintenance requirements lor die landfill will also apply.
HWR - Post-Closure (310 CMR
30.59l(b) & 30 592(b))
Relevant and
Appropriate
Requirement that establishes 30-year period of operations and
maintenance for owners and operators of all facilities at which
hazardous waste will remain on site after closure.
Requires a minimum of 30 years lor post closure care at Area A7, and
at any other site where hazardous waste will remain in place.
HWR - Land Disposal Restrictions
(310 CMR 30.750)
Relevant and
Appropriate
Identifies and describes those hazardous wastes which are restricted
from land disposal. These regulations also define die limited
circumstances where prohibited land disposal is permissible.
If soils from Areas A7 and A9 tail TCLP lest, then this requirement.
which requires treatment prior to dis|Hisal, is applicable. Soil thai tails
TCLP testing could not be consolidated under the landfill cap as pan of-
the necessary subgrade.
Massachusetts Surface Water Quality
Standards (310 CMR 4.00) (see also
57 FR 44426-44427)
Relevant and
Appropriate
Massachusetts 401 certification for the Clean Water Act requires
additional measures for surface water discharges during construction
Set backs and best management practices (BMPs) are identified and
are dependent upon the classification of the receiving water.
During construction, any new discharge outlill pipes will be designed to
be set back from the Assabcl River. Receiving swales, infiltration
trenches or basins, filler media dikes or oilier BMPs will be prepared
with the goal to minimize erosion yet niaximi/c infiltration or otherwise
improve water quality prior to discharge.
Massachusetts Ambient Air Quality
Standards (310 CMR 6.00)
Applicable
Establishes the standards and requirements for ambient air quality
standards in the Commonwealth. Specifically, Section 6.04(1)
provides ambient air quality criteria such as paniculate matter
standards. The primary ambient air quality standards for paniculate
matter are: 50 pg/m' annual ambient air quality standard, attained
when the expected annual mean arithmetic concentration is less than
or equal to 50 jig/m1; and ISO jig/m* - maximum 24-hour
oiiicentrafion. attained .when the expected number of days per
calendar year with a 24-hour average concentration above 150 pg/m'
is less than or equal to one.
The emissions limits lor fianicuiale nutter will he managed through
engineering controls during construction activities at Area A7
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TABLE 3-3
FORT DEVENS SUDBURY TRAINING ANNEX - AOC A9
ARARs FOR CONTAMINATED SOIL EXCAVATION
AND CONSOLIDATION AT AOC A7
Requirement
Statut
Requirement Synopsis
Action To Be Taken To Attain ARAR
CHEMICAL-SPECIFIC
Federal
Human Health Evaluation Manual
(Pan B. Development of Risk-based
Preliminary Remediation
GoalsXOSWER 9285.7-OIB)
To Be Considered
USEPA guidance used to develop preliminary remediation goals for
carcinogenic and non-carcinogenic contaminants in various media.
Using the guidance, risk-based cleanup levels were developed lor
arsenic and thallium. Arsenic and thallium contaminated soils at
AOC A9 will be excavated to 30 and 20 parts per million. res|>cciively.
Confirmatory samples will be taken to ensure that all contaminated soils
above the cleanup level are removed.
LOCATION SPECIFIC - None.
ACTION-SPECIFIC
Federal
RCRA - Identification and Listing of
Hazardous Waste (40 CFR 261)
Preparation of Soil Sampling
Protocols: Sampling Techniques and
Strategies (EPA/600/R 92/128, July
1992)
Applicable
To Be
Considered
Establishes definitions for solid and hazardous waste. Sets forth
criteria used to identify hazardous waste and to list particular wastes.
Identifies the characteristics of a hazardous waste and contains a list
of particular hazardous wastes.
USEPA guidance document for use in the development of soil
sampling protocols.. A paniculate sampling theory is the basis for
proper soil sampling. Other soil sampling scenarios are discussed
including sampling from stockpiled material.
Soils at Area A9 will be TCLP tested lu determine if it is hazardous.
During remedial design, a soil sampling plan will lie dcvcloficd lor
implementation during excavation of soil. The goal of die sampling
will be to determine whether soil can be consolidated as pan of the
subgrade of the landfill cap or must be shipped oll'-sile lor
treatment/disposal.
Stale
HWR - Identification and Listing of
Hazardous Waste (310 CMR 30. 100)
Massachusetts Air Pollution Control
Regulations (310 CMR 6.00)
Applicable
Applicable
Establishes provisions for classifying waste as regulated hazardous
waste. Two methods are employed to identify wastes as hazardous.
characteristics and listing.
Establishes the standards and requirements for ambient air quality
standards in the Commonwealth. Specifically. Section 6.04(1)
provides ambient air quality criteria such as paniculate matter
standards. The primary ambient air quality standards for paniculate
matter are: 50/jg/m' annual ambient air quality standard, attained
when ihc expected annual mean arithmetic concentration is less than
or equal to SOjjg/m1; and ISO^ig/m* maximum 24-hour
concentration, attained when the expected number ol days per
calendar year with a 24-hour average concentration above 150/jg/m'
is less than or equal to one.
Soil will be TCLP tested lor arsenic to determine it n is haiuidous liy
characteristics.
If necessary, emissions limits lor paniculate matter will be managed
through engineering controls during excavation activities at all sues.
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APPENDIX D
ADMINISTRATIVE RECORD INDEX
-------
Fort Devens - Sudbury Annex
Administrative Record File
Index
for Source Control
Record of Decision for AOC A7 and A9
Prepared for
New England Division
Corps of Engineers
With Assistance from
ABB Environmental Services, Inc
Corporate Place 128, 107 Audubon Road, Wakefield, MA 01880 . (617) 245-6606
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Introduction
This document is the Index to the Administrative Record File for the Source Control Record of
Decision for AOCs A7 and A9 at the Fort Devens-Sudbury Annex. Section I of the Index cites
site-specific documents and Section II cites guidance documents used by U.S. Army in selecting
a responses action at the site. Some documents in this Administrative Record File Index have
been cited but not physically included in the Administrative Record for this Source Control
ROD. If a document has been cross-referenced to another Administrative Record File Index,
the available corresponding comments and responses have been cross-referenced as well. Efforts
were made to include all appropriate comments and responses individually. In come cases,
however, comments were only included as part of the response package.
The Administrative Record File is available for public review at EPA Region I's Records Center
in Boston, Massachusetts (index only), at the Fort Devens Environmental Management Office,
Fort Devens, Massachusetts, and at the Sudbury Town Hall, Sudbury, Massachusetts.
Supplemental/Addendum volumes may be added to this Administrative Record File. Questions
concerning the Administrative Record should be addressed to the Fort Devens Environmental
Management Office.
The Administrative Record is required by the Comprehensive Environmental Responses,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendment and
Reauthorization Act (SARA).
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ADMINISTRATIVE RECORD INDEX FILE
for
Source Control
for Record of Decision for AOC A7 and A9
Fort Devens - Sudbury Annex Sites
Complied: September 8, 1995
All of the below entries are filed in the Master Fort Devens - Sudbury Annex Administrative
Record File and are therefore cross referenced in this Index.
1.0 Pre-Remedial
1.2 Preliminary Assessment
Reports
The record cited below as entry number 1 is oversized and may be reviewed, by
appointment only, at the Fort Devens Environmental Management Office.
1. "Installation Assessment NARADCOM Research and Development Laboratory,
Massachusetts," EPA Environmental Monitoring Systems Laboratory (March
1982).
2. "Burn Pit Remediation - Study Area A9," U.S. Army (November 21, 1986).
1.3 Site Inspection
Reports
1. "Final Report - Site Investigation - Natick Lab Annex Property," GZA
Associates (March 4, 1991).
2. Phase II Site Investigations Report (Draft), Vol I-III, Fort Devens Sudbury
Training Annex, Massachusetts," Ecology and Environment, Inc. (March 1994).
3. "Phase II Site Investigations Report (Draft Final), Volume I-III, Fort Devens
Sudbury Training Annex, Massachusetts," Ecology & Environment, Inc. (July
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1994).
4. "Replacement pages for the July 1994 Draft Final Phase II Site Investigations
Report, Fort Devens Sudbury Training Annex, Massachusetts," Ecology &
Environment, Inc. (September 1994).
5. "Draft Supplemental Site Investigation Task Order Work Plan, Fort Devens,
Sudbury Annex," ABB Environmental Services, Inc. (October 1994).
6. "Draft Final Supplemental Site Investigation Task Order Work Plan, Sudbury
Annex," ABB Environmental Services, Inc. (January 1995).
7. "Final Supplemental Site Investigations Task Order Work Plan, Sudbury Annex,"
ABB Environmental Services, Inc. (April 1995).
8. "Revised Figures, Final Supplemental Site Investigation Task Order Work Plan,
Sudbury Annex," ABB Environmental Services, Inc. (May 1995).
Comments
9. Comments Dated April 29, 1994 from Lorna Bozeman, Department of Health and
Human Services, Agency for Toxic Substances and Disease Registry, Atlanta,
Georgia on the "Draft Phase II site Investigation," (Ecology and Environment,
Inc.).
10. Comments Dated Ma 16, 1994 from Robert Lira, USEPA, on the "Draft Phase
II Site Investigations Report, Volumes 1-3," Ecology and Environment, Inc.
(March 1994).
11. Comments Dated June 14, 1994 from Jay Naparstek, Commonwealth of
Massachusetts Department of Environmental Protection on the March 1994
"Phase II Site Investigations Report Vol 1-3, Sudbury Training Annex,
Massachusetts," Ecology and Environment, Inc.
12. Comments Dated June 27, 1994 from Robert Lim, USEPA, on the Draft
Groundwater Model Report (as included in the Final Phase II Site Investigation
Report.
13. Comments Dated August 22, 1994 from Jay Naparstek, Commonwealth of
Massachusetts Department of Environmental Protection on the July 1994 "Phase
II Site Investigations Report Vols 1-3, Fort Devens Sudbury Training Annex,
Massachusetts," Ecology and Environment, Inc.
14. Comments Dated August 23, 1994 from Robert Lim, USEPA, on the July 1994
"Draft Final Phase II Site Investigations Report, Vol 1-3, Fort Devens Sudbury
Training Annex," Ecology and Environment, Inc.
15. Comments Dated November 22, 1994 from Robert Lim, USEPA, on the October
1994 "Draft Task Order Work Plan, Supplemental Site Investigation," ABB
Environmental Services, Inc.
16. Comments Dated December 5, 1994 from Jay Naparstek, Commonwealth of
Massachusetts Department of Environmental Protection on the "Supplemental Site
Investigations, Fort Devens Sudbury Training Annex Sudbury, Massachusetts,"
ABB Environmental Services, Inc.
17. Comments Dated February 22, 1995 from Robert Lim, USEPA, on the January
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1995 Draft Final Supplemental Site Investigation Task Order Work Plan (ABB
Environmental Services, Inc.).
Responses to Comments
18. Responses Dated June 1994 from U.S. Army Environmental Center on the Draft
Phase II Site Investigations Report, Fort Devens Sudbury Training Annex, Fort
Devens, Massachusetts (Ecology and Environment, Inc.).
19. Responses Dated September 1994 from U.S. Army Environmental Center on the
Draft Phase II Site Investigation Report, Fort Devens Sudbury Training Annex
(Ecology and Environment, Inc.).
20. Responses Dated January 20, 1995 from U. S. Army Environmental Center on
the Draft Supplemental Site Investigation Task Order Work Plan, ABB
Environmental Services, Inc. (October 1994).
21. Responses Dated February 22, 1995 from U.S. Army Environmental Center on
the Draft Final Supplemental Site Investigation Task Order Work Plan, ABB
Environmental Services, Inc. (January 1995).
Responses to Responses to Comments
22. Comments Dated November 23, 1994 from Jay Naparstek, Commonwealth of
Massachusetts Department of Environmental Protection on the Response to
Comments on the MADEPs Comments on the Draft Phase II Site Investigation
Response Letter.
1.7 Correspondence Related to Proposal of a Site to the NPL
1. Letter from Daniel J. Hannon, Commonwealth of Massachusetts, Department of
Environmental Protection to Fort Devens Installation Commander (May 24,
1991), concerning notification that Fort Devens in considered a priority disposal
site.
2.0 Removal Response
2.1 Correspondence
1. Memorandum from Timothy Prior, U. S. Army for the Record (August 12, 1991)
concerning contaminated soil disposal.
2. Memorandum from Joseph Pierce, U. S. Army to Fort Devens Installation
Commander (August 19, 1991) concerning Air Force noncompliance issues at the
Sudbury Annex.
3. "Record of Environmental Consideration," (November 9, 1992).
4. "3 Bills of Lading," (May 6, 1993).
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2.2 Removal Response Reports
1. "Removal of Underground Storage Tanks," Environmental Application, Inc. (May
1989).
2. "Post Removal Reports - UST No. 0094-SA P12 Burning Ground-Underground
Storage Tank Closure," ATEC Environmental Consultants (June 1992).
3. "Post Removal Report - Underground Storage Tank Closure - UST No. 0095 -
Building 405," ATEC Environmental Consultants (November 4, 1992).
4. "Post Removal Report - Underground Storage Tank Closure - UST No. 0096 -
Building 106," ATEC Environmental Consultants (November 9, 1992).
3.0 Remedial Investigation (RI)
3.4 Interim Deliverables
The document cited below as entry number 1 may be reviewed by appointment only at
the Fort Devens Environmental Management Office.
1. "Installation Action Plan," (July 14, 1993).
2. "Initial Screening of Remedial Technologies and Process Options Fort Devens
Sudbury Training Annex, Middlesex County, Massachusetts," OHM Remediation
Services Corp., (September 23, 1993).
3. "Development and Screening of Remedial Alternatives Fort Devens Sudbury
Training Annex, Middlesex County, Massachusetts," OHM Remediation Services
Corp., (October 28, 1993).
Comments
4. Comments Date October 25, 1993 from D. Lynne Welsh, Commonwealth of
Massachusetts Department of Environmental Protection on the Initial Screening
of Remedial Technologies and Process Options, Fort Devens Sudbury Training
Annex, Middlesex County, Massachusetts, OHM Remediation Corp. (September
23, 1993).
5. Comments Dated October 26, 1993 from Robert Lim, USEPA, on the Initial
Screening of Remedial Technologies and Process Options, OHM Remediation
Corp. (September 23, 1993).
6. Comments Dated October 27, 1993 from Cindy Svec Ruzich, Four Town Focus
on the "Draft Initial Screening of Remedial Technologies and Process Options.
7. Comments Dated December 10, 1993 from Robert Lim, USEPA, on the October
1993 "Draft Development and Screening of Remedial action Alternatives, Fort
Devens Sudbury Training Annex," OHM Remediation Services Corp.
17. Comments Dated December 22, 1993 from Jay Naparstek, Commonwealth of
-------
Massachusetts Department of Environmental Protection on the October 1993
"Development and Screening of Remedial Alternatives: Fort Devens Sudbury
Training Annex, Sudbury Massachusetts," OHM Remediation Services Corp.
3.6 Remedial Investigation (RI) Reports
The records cited below as entries number 1 and 2 may be reviewed, by appointment
only, at the Fort Devens Environmental Management Office.
1. "Final Remedial Investigations of the Sudbury Annex," Dames & Moore
(November 1986).
2. "Draft Site/Remedial Investigation Report - Volumes I-IV," OHM Remediation
Services Corp. (February 1993).
3. "Draft/Final Site/Remedial Investigation Report - Vol I-V," OHM Remediation
Services Corp. (July 1993).
4. "Final Site/Remedial Investigation Report Fort Devens Sudbury Training Annex
Middlesex County, Massachusetts," OHM Remediation Services Corp., (December
31, 1993).
5. "Final Report Site/Remedial Investigation, Fort Devens Sudbury Training Annex,
Middlesex County, Massachusetts, Vol I-VI," OHM Remediation Services Corp.
(January 1994).
6. "Draft Addendum Report Site/Remedial Investigation, Fort Devens Sudbury
Training Annex Middlesex County, Massachusetts," OHM Remediation Services
Corp. (August 1994).
7. "Draft Final Addendum Report, Site/Remedial Investigation, Fort Devens
Sudbury Training Annex. Middlesex County, Massachusetts," OHM Remediation
Services Corp. (April 1995).
Comments
8. Comments Dated April 12, 1993 from Cindy Svec Ruzich, Four Town FOCUS
on the February 1993 "Draft Site/Remedial Investigation - Volumes I-IV," OHM
Remediation Services Corp with the attached Comments Dated March 19, 1993
from Cambridge Environmental, Inc. on the February 1993 "Draft Site/Remedial
Investigation - Volumes I-IV," OHM Remediation Services Corp.
9. Comments Dated April 12, 1993 from James P. Byrne, EPA Region I on the
February 1993 "Draft Site/Remedial Investigation - Volume I-IV," OHM
Remediation Services Corp.
10. Comments Dated April 13, 1993 from Molly J. Elder for D. Lynne Chapped.
Commonwealth of Massachusetts Department of Environmental Protection on the
February 1993 "Draft Site/Remedial Investigation - Volume I-IV,' OHM
Remediation Services Corp.
11. Comments Dated May 18, 1993 from Kenneth C. Carr for Gordon E. Beckett,
-------
U.S. Department of the Interior Fish and Wildlife Services on the February 1993
"Draft Site/Remedial Investigation - Volume I-IV," OHM Remediation Services
Corp.
12. Comments Dated August 6, 1993 from Cindy Svec Ruzich, Four Town Focus,
on the Comment Time Extension on the "Draft Final RI/SI Report" and Army
Response to FOCUS Comments on 'Draft RI/SI Investigation Report".
13. Comments Dated August 20, 1993 from James P. Byrne, USEPA, on the "Draft
Final Site/Remedial Investigation Report," OHM Remediation Services Corp.
14. Comments Dated September 2, 1993 from D. Lynne Welsh, Commonwealth of
Massachusetts Department of Environmental Protection on the July 1993 "Draft
Final Site/Remedial Investigation Report," OHM Remediation Services Corp.
15. Update of Comments Dated September 12, 1993 from Cindy Svec Ruzich of Four
Town Focus on the Draft SI/RI Investigation Report.
16. Comments Dated September 14, 1993 from Robert Lim, USEPA on the Comment
Time Extension on "Draft Final SI/RI Investigation Report and Army Response
to Comments on "Draft SI/RI Investigation Report".
17. Comments Dated October 3, 1994 from Jay Naparstek, Commonwealth of
Massachusetts Department of Environmental Protection on the August 1994
"Draft Addendum Final Site/Remedial Investigation Report, Fort Devens Sudbury
Training Annex," OHM Remediation Services Corp.
18. Comments Dated October 5, 1994 from Robert Lim, USEPA, on the Draft SI/Ri
Addendum Report, Fort Devens Sudbury Training Annex.
19. Comments Dated October 13, 1993 from Cindy Svec Ruzich of Four Town Focus
on the Draft Final RI/SI Phase I Investigation Report, Volume I.
20. Comments Dated October 17, 1994 from Robert Lim, USEPA, on the August
1994 Draft SI/Ri Addendum Report, Fort Devens Sudbury Training Annex (OHM
Remediation Services Corp.).
21. Comments Dated November 1, 1994 from Jay Naparstek, Commonwealth of
Massachusetts Department of Environmental Protection on the August 1994 Draft
Addendum Report, Fort Devens Sudbury Training Annex.
22. Letter Dated November 7, 1994 from Robert Lim, USEPA, to the Ecological
Risk Assessment Issues in the Remedial Investigation of Areas of Contamination
A4, A7, and A9.
23. Follow-up Letter Dated November 21, 1994 from Robert Lim, USEPA, to the
Ecological Risk Assessment Issues in the Remedial Investigation of Areas of
Contamination A4, A7, and A9.
24. Comments Dated May 19, 1995 from Robert Lim, USEPA, on the Draft Final
Site/Remedial Investigation Addendum Report, Fort Devens Sudbury Training
Annex (OHM Remediation).
25. Comments Dated May 19, 1995 from Robert Lim, USEPA, on the Area of
Contamination A9, Risk Based Soil Cleanup Level for Thallium.
Response to Comments
-------
26. Responses Dated July 16, 1993, July 19, 1993 and July 28, 1993 from OHM
Remediation Services Corp to the April 12, 1993 Four Town FOCUS, the April
12, 1993 EPA Region I, the April 13, 1993 Commonwealth of Massachusetts
Department of Environmental Protection and the May 18, 1993 U.S. Department
of Interior Fish and Wildlife Service Comments on the February 1993 "Draft
Site/Remedial Investigation - Volumes I-IV," OHM Remediation Services Corp.
27. Responses Dated October 14, 1993 from U.S. Army Environmental Center on the
Draft Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex
(OHM Remediation Services Corp.).
28. Responses Dated October 28, 1993 from U.S. Army Environmental Center on the
Draft Final Site/Remedial Investigation Report, Fort Devens Sudbury Training
Annex (OHM Remediation Services Corp.).
29. Responses Dated November 4, 1994 from OHM Remediation Services Corp. on
the USEPA Comments on the "Draft SI/RI Addendum Report.
30. Responses Dated June 21, 1995 from U.S. Army Environmental Center on the
Draft Final Addendum to the Final Site/Remedial Investigation Report, Fort
Devens Sudbury Training Annex.
Responses to Responses to Comments
31. Rebuttals Dated November IS, 1994 from Robert Lim, USEPA, on the Responses
to the Army's Responses to Comments on the Draft SI/RI Addendum Report.
32. Correction Letter Dated November 22, 1994 from Robert Lim, USEPA, on
November 15, 1994 letter.
3.7 Work Plans and Progress Reports
Reports
The records cited below as entries number 1 and 2 may be reviewed, by appointment
only, at the Fort Devens Environmental Management Office.
1. "Draft Work Plan, Draft Field Sampling Plan, Draft Health and Safety Plan,
Draft Quality Assurance Plan," OHM Remediation Services Corp ( June/July
1991).
2. "Draft Final Work Plan, Draft Final Field Sampling Plan, Draft Final Health and
Safety Plan, Draft Final Quality Assurance Plan," OHM Remediation Services
Corp. (December 1991).
3. "Final Work Plan," OHM Remediation Services Corp. (April 1992).
4. "Final Field Sampling Plan," OHM Remediation Services Corp. (April 1992).
5. "Final Health and Safety Plan," OHM Remediation Services Corp (April 1992).
6. "Final Quality Assurance Project Plan - Volume MI," OHM Remediation
Services Corp. (April 1992).
8
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7. "Draft Master Quality Assurance Project Plan," Ecology and Environment, Inc.
(June 1993).
8. "Draft Technical Plan Addenda, Phase II Site Inspections, Remedial
Investigations," Ecology and Environment, Inc. (June 1993).
9. "Final Technical Plan Addenda, Phase II Site Inspections, Remedial
Investigations, Fort Devens Sudbury Training Annex, Massachusetts," Ecology
& Environment, Inc. (January 1994).
Comments
10. Comments Dated August 21, 1991 from Anne D. Flood, Town of Maynard on
the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health
and Safety Plan, Draft Quality Assurance Plan," OHM Remediation Services
Corp.
11. Comments Dated August 22, 1991 from Gregory M. Ciardi, Maynard Public
Schools on the June/July 1991 "Draft Work Plan, Draft Filed Sampling Plan,
Draft Health and Safety Plan, Draft Quality Assurance Plan," OHM Remediation
Services Corp.
12. Comments Dated February 12, 1992 from Todd S. Alving, Organization for the
Assabet River on the December 1991 "Draft Final Work Plan, Draft Final Field
Sampling Plan, Draft Final Health and Safety Plan, Draft Final Quality Assurance
Plan," OHM Remediation Services Corp.
13. Comments Dated May 13, 1992 from James P. Byrne, EPA Region I on the
April 1992 "Final Work Plan, Final Field Sampling Plan, Final Health and Safety
Plan, Final Quality Assurance Project Plan," OHM Remediation Services Corp.
and the April 1992 "Final Community Relations Plan," Dames & Moore.
14. Comments Dated May 18, 1992 from Ken Raina, Lake Boon Association on the
April 1992 "Final Work Plan, Final Field Sampling Plan, Final Health and Safety
Plan, Final Quality Assurance Project Plan," OHM Remediation Services Corp.
15. Comments Dated May 19, 1992 from Deborah Schumann and Cindy Svec
Ruzich, Four Town FOCUS on the April 192 " Final Work Plan, Final Field
Sampling Plan, Final Health and Safety Plan, Final Quality Assurance Project
Plan," OHM Remediation Services Corp.
16. Comments dated July 7, 1993 from Jack McKenna, Metcalf & Eddy on the June
1993 "Draft Technical Plan Addenda, Phase II Site Inspections, Remedial
Investigations," Ecology and Environment, Inc. and the June 1993 "Draft Final
Addendum to the Final Technical Plans - Phase II Feasibility Study," OHM
Remediation Services Corp.
17. Comments Dated July 23, 1993 from Molly J. Elder for D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental Protection on the
June 1993 " Draft Master Quality Assurance Project Plans," Ecology and
Environment, Inc.
18. Preliminary Comments Dated July 25, 1993 from Cindy Svec Ruzich of Four
Town Focus on the "Technical Plan Addenda, Phase'II Site Inspections, Remedial
-------
Investigations," Ecology and Environment, Inc.
19. Comments Dated August 5, 1993 from Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the June 1993
"Technical Plans Addenda Phase II Site Inspections, Remedial Investigations, Fort
Devens Sudbury Training Annex, Massachusetts," Ecology and Environment, Inc.
20. Comments Dated August 6, 1993 from James P. Byrne, USEPA, on the "Draft
Work Plan, Field Sampling Plan, Quality Assurance Project Plan, and Health and
Safety Addenda for the Phase II Site Investigations and Remedial Investigations,"
Ecology and Environment, Inc.
Responses to Comments
21. Response Dated October 1991 from OHM Remediation Services Corp. to
Regulatory Agency Comments on the June/July 1991 "Draft Work Plan, Draft
Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance
Project Plan," OHM Remediation Services Corp.
22. Response Dated November 19, 1991 from Joseph Pierce, U.S. Army to the
August 21, 1991 Comments from Todd S. Alving, Organization for the Assabet
River on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft
Health and Safety Plan, Draft Quality Assurance Project Plan," OHM
Remediation Services Corp.
23. Response Dated November 20, 1991 from Dennis R. Dowdy, U.S. Army to the
August 22, 1991 Comments from Gregory M. Ciardi, Maynard Public Schools
on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health
and Safety Plan, Draft Quality Assurance Project Plan," OHM Remediation
Services Corp.
24. Response Dated November 25, 1991 from Ronald J. Ostrowski, U. S. Army to
the August 21, 1991 Comments from Anne D. Flood, Town of Maynard on the
June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health and
Safety Plan, Draft Quality Assurance Plan," OHM Remediation Services Corp.
25. Response Dated November 1991 from OHM Remediation Services Corp. to the
Four Town FOCUS Comments on the June/July 1991 "Draft Work Plan, Draft
Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance
Plan," OHM Remediation Services Corp.
26. Responses from OHM Remediation Services Corp. to EPA Region I, Four Town
FOCUS, and the U.S. Department of the Interior Fish and Wildlife Service
Comments on the December 1991 "Draft Final Work Plan, Draft Final Field
Sampling Plan, Draft Final Health and Safety Plan, Draft Final Quality Assurance
Plan," OHM Remediation Services Corp.
27. Draft Responses to Four Town FOCUS Comments on the April 1992 "Final
Work Plan," OHM Remediation Services Corp.
28. Responses Dated September 1993 from U.S. Army Environmental Center on the
Technical Plan Addenda Phase II Site Investigation/Remedial Investigations, Fort
Devens Sudbury Training Annex, Massachusetts '(Ecology and Environment,
10
-------
Inc.).
Responses to Responses to Comments
29. Response Dated October 21, 1991 from D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection to the Response Dated
October 1991 from OHM Remediation Services Corp. to Regulatory Agency
Comments on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan,
Draft Health and Safety Plan, Draft Quality Assurance Plan," OHM Remediation
Services Corp.
30. Response Dated October 22, 1991 from James P. Byrne, EPA Region I to the
Response Dated October 1991 from OHM Remediation Services Corp. to
Regulatory Agency Comments on the June/July 1991 "Draft Work Plan, Draft
Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance
Pan," OHM Remediation Services Corp.
31. Response Dated October 22, 1991 from Steven E. Mierzykowski, U.S.
Department of the Interior Fish and Wildlife Service to the Response Dated
October 22, 1991 from OHM Remediation Services Corp. to Regulatory Agency
Comments on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan,
Draft Health and Safety Plan, Draft Quality Assurance Plan," OHM Remediation
Services Corp.
32. Response Dated January 2, 1992 from Four Town FOCUS to the Response Dated
November 1991 from OHM Remediation Services Corp. to the FOCUS
Comments on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan,
Draft Quality Assurance Plan," OHM Remediation Services Corp.
33. Rebuttals Dated November 2, 1993 from D. Lynne Welsh, Commonwealth of
Massachusetts Department of Environmental Protection on the June 1993 "Draft
Technical Plan Addenda, Phase II Site Investigation/Remedial Investigation,
Sudbury Training Annex," Ecology and Environment, Inc.
3.9 Health Assessments
1. "Health Consultation," U.S. Department of Health and Human Services Agency
for Toxic Substances and Disease Registry (November 23, 1992).
2. "Final Site-Specific Risk Assessment for the Sudbury Training Annex Facility,
Sudbury, Massachusetts," OHM Remediation Services Corp. (January 1994).
4.0 Feasibility Study (FS)
4.4 Interim Deliverables
1. "Preliminary Draft Screening of Alternatives," OHM Remediation Services Corp.
(May 25, 1993).
11
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4.6 Feasibility Study (FS) Reports
1. "Draft Final Report Feasibility Study, Fort Devens Sudbury Training Annex
Middlesex County, Massachusetts," OHM Remediation Services Corp. (May
1994).
2. "Draft Final Feasibility Study Report, Fort Devens Sudbury Training Annex,
Middlesex County, Massachusetts," OHM Remediation Services Corp. (May
1994).
3. "Draft Final Report, Feasibility Study at Fort Devens Sudbury Training Annex
Areas A7 and A9," OHM Remediation Services Corp. (January 1995).
4. "Draft Final Feasibility Study at Fort Devens Sudbury Training Annex Areas A7
and A9," OHM Remediation Services Corp. (March 1995).
5. "Final Feasibility Study at Fort Devens Sudbury Training Annex Areas A7 and
A9," OHM Remediation Services Corp. (May 1995).
Comments
6. Letter Dated January 30, 1995 from Robert Lira, USEPA, on the Source Control
Record of Decision Proposal for Fort Devens Sudbury Annex Areas of
Contamination A7 and A9.
7. Comments Dated March 2, 1995 from Robert Lim, USEPA, on the Draft Final
Feasibility Study Report at Fort Devens Sudbury Training Annex Area A7 and
A9," (OHM Remediation Services Corp.).
8. Comments Dated April 3, 1995 from Robert Lim, USEPA, on the Fort Devens
Sudbury Training Annex Feasibility Study for Area A7, 100-Floodplan Location-
Specific ARAR," (OHM Remediation Services Corp.).
9. Cross Reference: Comment Dated May 19, 1995 from Robert Lim, USEPA, on
the Area of Contamination A9, Risk Based Soil Cleanup Level for Thallium
[Filed and Cited as entry number 29 in minor break 3.6 Remedial Investigation
Reports of this Administrative Record File Index.]
Response to Comments
10. Responses Dated September 20, 1994 from U.S. Army Environmental Center on
the Draft Final Feasibility Study (OHM Remediation Services Corp.).
11. Responses Dated May 2, 1995 from U.S. Army Environmental Center on the
Draft Final Feasibility Study Report, Sudbury Training Annex (OHM
Remediation Services Corp.).
Responses to Responses to Comments
12. Rebuttals Dated October 4, 1994 from Robert Lim, USEPA, on the Army's
Response to Comments on the Feasibility Study.
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4.7 Work Plans and Progress Reports
Reports
1. "Draft Final Addendum to the Final Technical Plans - Phase II Feasibility Study."
OHM Remediation Services Corp. (June 1993).
2. "Final Addendum to the Final Technical Plans for the Phase II Feasibility Study
at the Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts,"
OHM Remediation Services Corp. (November 10, 1993).
Comments
3. Cross Reference: Preliminary Comments Dated July 7, 1993 from Jack McKenna,
Metcalf & Eddy on the June 1993 "Draft Technical Plan Addenda, Phase II Site
Inspections, Remedial Investigations," Ecology & Environment, Inc on the June
1993 "Draft Final Addendum to the Final Technical Plans - Phase II Feasibility
Study," OHM Remediation Services Corp. Filed and cited as entry number ***
in 3.7 Work Plans and Progress Reports in this Administrative Record Index.
4. Comments Dated July 22, 1993 from D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the June 1993 "Draft
Final Addendum to the Final Technical Plans - Phase II Feasibility Study," OHM
Remediation Services. Corp.
5. Comments Dated July 23, 1993 from D. Lynne Welsh, Commonwealth of
Massachusetts Department of Environmental Protection on the "Addendum to the
Final Technical Plans Phase II Feasibility Study, Fort Devens Sudbury Training
Annex, Sudbury, Massachusetts," OHM Remediation Services Corp.
6. Comments Dated August 6, 1993 from James P. Byrne, USEPA, on the June
1993 "Addendum to the Final Technical Plans, Phase II Feasibility Study, Fort
Devens Sudbury Training Annex, " OHM Remediation Services Corp.
7. Comments Dated August 6, 1993 from Cindy Svec Ruzich of Four Town Focus
on the "Draft Addendum to the Final Technical Plans Phase II Feasibility," OHM
Remediation Services Corp.
Responses to Comments
8. Responses Dated September 7, 1993 from OHM Remediation Services Corp. on
USEPA Comments on the "Addendum to die Final Technical Plans, Phase II
Feasibility Study, Fort Devens Sudbury Training Annex.
Responses to Responses to Comments
9. Rebuttal Dated October 1, 1993 from D. Lynne Welsh, Commonwealth of
Massachusetts Department of Environmental Protection on the June 1993 Army
Responses to MADEPs Comments on the Draft Final Addendum to the Final
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Technical Plans Phase I Feasibility Study, Fort Devens Sudbury Training Annex,
Sudbury, Massachusetts (OHM Remediation Corp).
4.9 Proposed Plan for Selected Remedial Action
Reports
1. "Draft Proposed Plan, Area 7, the Old Gravel Pit Landfill, Area A9, the POL
Burn Area, Fort Devens Sudbury Training Annex, Sudbury, Massachusetts,"
OHM Remediation Services Corp. (March 1995).
2. "Draft Final Proposed Plan, Area 7, the Old Gravel Pit Landfill, Area A9, the
POL Burn Area, Fort Devens Sudbury Training Annex, Sudbury, Massachusetts,"
OHM Remediation Services Corp., (April 1995).
3. "Proposed Plan AOC A7, the Old Gravel Pit Landfill, AOC A9, the POL Burn
Area, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts,"
OHM Remediation Services Corp. (June 1995).
Comments
4. Comments Dated April 12, 1995 from Robert Lim, USEPA, on the March 1995
Draft Proposed Plan, Sudbury Training Annex (OHM Remediation Services
Corp.).
5. Comments Dated May 18, 1995 from Robert Lim, USEPA on the April 1995
Draft Final Proposed Plan, Fort Devens Sudbury Training Annex (OHM
Remediation Services Corp.).
5.0 Record of Decision (ROD)
5.2 Applicable or Relevant and Appropriate Requirements (ARARs)
1. Letter from D. Lynne Chappell, Commonwealth of Massachusetts Department of
Environmental Protection to Jeff Waugh, U.S. Army (January 6, 1993).
Concerning transmittal of the attached potential ARARs.
2. "Draft Preliminary Applicable or Relevant and Appropriate Requirements for the
Fort Devens Sudbury Training Annex," OHM Remediation Services Corp.
(January 21, 1993).
5.4 Record of Decision
Reports
1. "Record of Decision, Source Control Operable Unit, AOC A7, the Old Gravel
Pit Landfill, AOC A9, the POL Burn Area, Fort Devens Sudbury Training
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Annex, Middlesex County, Massachusetts," OHM Remediation Services Corp.
(June 1995).
2. "Draft Final Record of Decision, Source Control Operable Unit, AOC A7, the
Old Gravel Pit Landfill, AOC A9, the POL Burn Area, Fort Devens Sudbury
Training Annex Middlesex County, Massachusetts," OHM Remediation Services
Corp. (August 1995).
3. "Final Record of Decision, Source Control Operable Unit, AOC A7. the Old
Gravel Pit Landfill, AOC A9, the POL Burn Area, Fort Devens Sudbury
Training Annex Middlesex County, Massachusetts," OHM Remediation Services
Corp. (September 1995).
Comments
4. Comments Dated July 21, 1995 from Robert Lim, USEPA, on the June 1995
Draft Record of Decision, Source Control Operable Unit AOC A7, the Old
Gravel Pit Landfill, AOC 9, the POL Burn Area, Fort Devens Sudbury Training
Annex, Middlesex County, Massachusetts (OHM Remediation Services Corp.).
5. Comments Dated August 25, 1995 from Robert Lim, USEPA, on the August
1995 Draft Final Record of Decision, Source Control Operable Unit AOC A7,
the Old Gravel Pit Landfill, AOC 9, the POL Burn Area, Fort Devens Sudbury
Training Annex, Middlesex County, Massachusetts (OHM Remediation Services
Corp.).
10.0 Enforcement
10.16 Federal Facility Agreements
Reports
The document cited below as entry number 1 may be reviewed, by appointment only, at
the Fort Devens Environmental Management Office.
1. "Draft Federal Facility Agreement Under CERCLA Section 120," EPA Region
I and U.S. Department of the Army (March 1991).
2. "Final Federal Facility Agreement Under CERCLA Section 120," EPA Region
I and U.S. Department of the Army (November 15, 1991).
Comments
3. Comments Dated July 12, 1991 from Edmond G. Benoit, Commonwealth of
Massachusetts Department of Environmental Protection on the March 1991 "Draft
Federal Facility Agreement Under CERCLA Section 120," EPA Region I and
U.S. Department of the Army.
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Responses to Comments
4. Response Dated September 5, 1991 from James P. Byrne, EPA Region I to the
Comments Dated July 12, 1991 from Edmond G. Benoit, Commonwealth of
Massachusetts Department of Environmental Protection on the March 1991 "Draft
Federal Facility Agreement Under CERCLA Section 120," EPA Region I and
U.S. Department of the Army.
13.0 Community Relations
13.2 Community Relations Plans
Reports
The document cited below as entries 1 and 2 may be reviewed, by appointment only, at
the Fort Devens Environmental Management Office.
1. "Draft Community Relations Plan," Dames & Moore (August 1991).
2. "Draft Final Community Relations Plan," Dames & Moore (December 1991).
3. "Final Community Relations Plan," Dames & Moore (April 1992).
Comments
4. Comments Dated September 30, 1991 from Cindy Svec Ruzich and Deborah
Schumann, Four Town FOCUS on the August 1991 "Draft Community Relations
Plan," Dames & Moore.
5. Comments Dated February 14, 1992 from Cindy Svec Ruzich and Deborah
Schumann, Four Town FOCUS on the December 1991 "Draft Final Community
Relations Plan," Dames & Moore.
6. Comments Dated March 17, 1992 from D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the December 1991
"Draft Final Community Relations Plan," Dames & Moore.
7. Comments from James P. Byrne, EPA Region I on the December 1991 "Draft
Final Community Relations Plan," Dames & Moore.
8. Cross Reference: Comments Dated May 13, 1992 from James P. Byrne, EPA
Region I on the April 1992 "Final Work Plan, Final Field Sampling Plan, Final
Heath and Safety Plan, Final Quality Assurance Project Plan," OHM Remediation
Corp. and the April 1992 "Final Community Relations Plan," Dames & Moore.
Filed and cited as entry number 15 in 3.7 Work Plans and Progress Reports in
this Administrative Record Index.
Response to Comments
9. Response to the EPA Comments on the August 1991 "Draft Community Relations
16
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Plan," Dames & Moore.
10. Response to the Commonwealth of Massachusetts Department of Environmental
Protection Comments on the August 1991 "Draft Community Relations Plan."
Dames & Moore.
13.11 Technical Review Committee Documents
1. Technical Review Committee Meeting Summary, List of Attendees, and Handouts
(May 14, 1991).
2. Technical Review Committee Meeting Summary and List of Attendees (July 31,
1991).
3. Technical Review Committee Meeting Summary and List of Attendees (October
23, 1991).
4. Technical Review Committee Meeting Summary and List of Attendees (October
23, 1991).
5. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads,
and List of Attendees (April 28, 1992).
6. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads,
and List of Attendees (July 14, 1992).
7. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads,
and List of Attendees (October 27, 1992).
8. Agenda and Attendance List for Sudbury Annex Working Meeting (November 23,
1992).
9. Technical Review Committee Meeting Summary, List of Attendees, and Handouts
(February 2, 1993).
10. Letter from Richard D. Dotchin, U.S. Army to James P. Byrne, EPA Region I
(March 3, 1993). Concerning followup to the February 2, 1993 Technical Review
Committee Meeting.
11. Technical Review Committee Meeting Summary, List of Attendees, and Handouts
(June 9, 1993).
17.0 Site Management Records
17.6 Site Management Plans
The document cited below as entries number 1 and 2 may be reviewed, by appointment
only, at the Fort Devens Environmental Management Office.
Reports
1. "Draft Master Environmental Plan," OHM Remediation Services Corp. (May
1991).
2. "Draft Final Master Environmental Plan," OHM Remediation Services Corp.
(October 1991).
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3. "Final Master Environmental Plan," OHM Remediation Services Corp (January
1992).
4. "Draft Master Environmental Plan, Fort Devens Sudbury Training Annex,
Massachusetts," Ecology & Environment, Inc. (May 1994).
5. "Draft Project Operations Plan, Fort Devens Sudbury Training Annex, Sudbury.
Massachusetts, Volume I & II," ABB Environmental Services, Inc. (October
1994).
6. "Final Project Operations Plan, Fort Devens Sudbury Training Annex, Sudbury,
Massachusetts, Volume I & II," ABB Environmental Services, Inc. (April 1995).
Comments
7. Comments Dated July 11, 1991 from James P. Byrne, EPA Region I on the May
1991 "Draft Master Environmental Plan," OHM Remediation Services Corp.
8. Comments Dated July 15, 1991 from D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the May 1991 "Draft
Master Environmental Plan," OHM Remediation Services Corp.
9. Comments from James P. Byrne, EPA Region I on the January 1992 "Final
Master Environmental Plan," OHM Remediation Services Corp.
10. Comments Dated June 27, 1994 from Robert Lim, USEPA, on the May 1994
"Master Environmental Plan, Update, Fort Devens Sudbury Training Annex,
Massachusetts," Ecology and Environment, Inc.
Responses to Comments
11. Response Dated August 28, 1991 from OHM Remediation Services Corp. to the
Comments Dated July 11, 1991 from James P. Byrne, EPA Region I on the May
1991 "Draft Master Environmental Plan," OHM Remediation Services Corp.
12. Response Dated August 28, 1991 from OHM Remediation Services Corp. to the
Comments Dated July 15, 1991 from D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the May 1991 "Draft
Master Environmental Plan," OHM Remediation Services Corp.
Responses to Responses to Comments
13. Response Dated September 12, 1991 from James P. Byrne, EPA Region I to the
Response Dated August 28, 1991 from OHM Remediation Services Corp.
17.8 Federal and Local Technical and Historical Records
The document cited below as entry number 1 may be reviewed, by appointment only, at
the Fort Devens Environmental Management Office.
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"An Intensive Archeological Survey of the Sudbury Training Annex " The Public
Archaeology Laboratory, Inc. (April 1985).
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GUIDANCE DOCUMENTS
The following guidance documents were relied upon during the Fort Devens - Sudbury Annex
cleanup. These documents may be reviewed, by appointment only, at the Environmental
Management Office at Fort Devens, Massachusetts.
1. Occupational Safety and Health Administration (OSHA). Hazardous Waste Operation and
Emergency Response (Final Rule, 29 CRF Part 1910, Federal Register. Volume 54,
Number 42) March 6, 1989.
2. USATHAMA. Geotechnical Requirements for Drilling Monitoring Well, Data
Acquisition, and Reports, March 198.
3. USATHAMA. IRDMIS User's Manual, Version 4.2, April 1991.
4. USATHAMA. USATHAMA Quality Assurance Program: PAM-41, January 1990.
5. USATHAMA. Draft Underground Storage Tank Removal Protocol - Fort Devens,
Massachusetts, December 4, 1992.
6. U.S. Environmental Protection Agency. Guidance for Preparation of Combined
Work/Quality Assurance Project Plans for Environmental Monitoring: OWRS QA-1,
May 1984.
7. U.S. Environmental Protection Agency. Office of Research and Development. Interim
Guidelines and Specifications for Preparing Quality Assurance Project Plans: QAMS-
005/80, 1983.
8. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste: EPA
SW-846 Third Edition, September 1986.
9. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation manual
(Pan A), EPA/l-89/002), 1989,.
10. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation manual
(Pan A), EPA/1-89/002), 1989.
11. U.S. Environmental Protection Agency. Hazardous Waste Management System:
Identification and Listing of Hazardous Waste: Toxicity Characteristic Revisions, (Final
Rule, 40 CFR Part 261 et al, Federal Register Pan V), June 29, 1990.
12. U.S. Army. Environmental Quality Environmental Protection and Enhancement, (Army
Regulation 200-1), April 23, 1990.
13. U.S. Environmental Protection Agency, 1991. Design and Construction of
RCRA/CERCLA Final Covers; Office of Research and Development; Washington, DC;
EPA/625/4-9i/025; May.
14. U.S. Environmental Protection Agency, 1991. Risk Assessment Guidance for Superfund:
Volume I - Human Health Evaluation Manual (Pan B, Development of Risk-Based
Preliminary Remediation Goals) Interim; Office of Emergency and Remedial Response,
Washington, DC; Publication 9285.7-01B; October.
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APPENDIX E
STATE LETTER OF CONCURRENCE
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Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of
Environmental Protection
William F. Weld Trudy Coxa
Governor Secret^
Argeo Paul Celluccl David B. Struhs
LI. Governor Communoner
September 26, 1995
John P. DeVillars
Regional Administrator
U.S. Environmental Protection Agency
Region I, JFK Building
Boston MA., 02203-2211
RE: Fort Devens Sudbury Training Annex
AOC A7, the Old Gravel Pit Landfill
AOC A9, the POL Burn Area
Sudbury, MA
Dear Mr. DeVillars:
The Massachusetts Department of Environmental Protection (MA DEP)
has reviewed the August, 1995 Draft Final Record of Decision (ROD)
regarding sites AOC A7 and AOC A9 for the Fort Devens Sudbury
Training Annex Superfund Site located in Sudbury, Massachusetts.
Based upon that draft final report, MA DEP concurs with the
selected remedial action. This action addresses the problems
associated with AOC A7 and AOC A9 by preventing further
endangerment to health, welfare, and the environment by
implementation of this record of decision.
The preferred remedial alternative for AOC's A7 and A9 involves
excavating laboratory waste with removal to an approved treatment
facility. Additional contaminated soil and solid waste below
hazardous levels will be consolidated in the central landfill area
of AOC 7.
The landfill area will be capped with a RCRA Subtitle C multi-layer
cap. Fencing, monitoring, and maintenance provisions with
inspection over the life of the facility will be required.
Specifically, the major components for the selected alternative are
as follows:
Site Preparation and Grading
Excavation and Off-Site Treatment/Disposal of Laboratory Waste
.at AOC 7
Excavation of. Contaminated Soil from AOC A9 and Consolidation
One Winter Street 8>ston, Massachusetts 02108 FAX (617) 556-1049 Telephone (617) 292-5500
t-» Pnnied on Recycled Pioer
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at AOC A7
Construction of RCRA Subtitle C Landfill Cap at AOC A7
Environmental Monitoring and O&M at AOC A7
Institutional Controls at AOC A7
Five Year Reviews at AOC A7
The remedial action selected for the AOC A7 and AOC A9 is
consistent with the Massachusetts Contingency Plan. This remedy is
protective of human health, welfare and the environment, attains
ARAR's and is cost effective.
This concurrence is based upon the State's understanding that:
1) . The MADEP will continue in the review and approval of
operational designs and maintenance plans.
2). Ground water monitoring wells will be established on the
northerly side of the proposed landfill.
3). Site conditions shall be reviewed within five (5) years from
the conclusion of the remedial action to ensure that public
health and the environment are not impacted.
If you require any additional information regarding this matter,
please contact the Bureau of Waste Site Cleanup at any time.
Very truly yours,
Edward Kunce , Deputy
Assistant Commissioner
cc: Ms. Linda Murphy, Director, U.S. EPA
Mr. Jerry Collins, Maynard BOH
Mr. George Dargaty, Town of Stow
Mr. Robert Leupold, Sudbury BOH
Mr. Robert Steere, Hudson Board of Selectmen
Mr. Thomas Strunk, Fort Devens, EMO
Ms. Cindy Ruzich, Four Town FOCUS
Mr. Robert Lim, U.S. EPA
Mr. Richard Chalpin, MADEP, NERO
Mr. Steven Johnson, MA DEP, NERO
Mr. Ed Benoit, MADEP,CEP.O
Ms. Lynne Welsh,CERO
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