PB95-963715
                                EPA/ROD/R01-95/115
                                March 1996
EPA Superfund
      Record of Decision:
       Otis Air National Guard (Containment
       of 7 Groundwater Plumes), MA
       9/25/1995

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                FINAL


        RECORD OF DECISION

                 FOR

          INTERIM ACTION


          CONTAINMENT OF

   SEVEN GROUNDWATER PLUMES


                  AT


MASSACHUSETTS MILITARY RESERVATION

      CAPE COD, MASSACHUSETTS


               September 1995

                Submitted to:

           Installation Restoration Program
          Air National Guard Readiness Center
           Andrews Air Force Base, Maryland

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               RECORD OF DECISION FOR INTERIM ACTION
            CONTAINMENT OF SEVEN GROUNDWATER PLUMES
               MASSACHUSETTS MILITARY RESERVATION
                        TABLE OF CONTENTS


 Section  	Title	Page No.

 1.0 DECLARATION FOR THE RECORD OF DECISION	1-1

 2.0 SITE NAME, LOCATION, AND DESCRIPTION	2-1

 3.0 SITE HISTORY AND ENFORCEMENT ACTIVrnES	3-1
     3.1   LF-1 PLUME  	3-1
     3.2   SD-5 AND WESTERN AQUAFARM PLUMES	3-4
     3.3   EASTERN BRIARWOOD PLUME	3-6
     3.4   FS-12 PLUME	3-8
     3.5   CS-10 PLUME	3-8
     3.6   ASHUMET VALLEY PLUME	3-9
     3.7   ENFORCEMENT HISTORY	3-9

 4.0 COMMUNITY PARTICIPATION	4-1

 5.0 SCOPE AND ROLE OF THE RESPONSE ACTION	5-1

 6.0 RESULTS OF SITE INVESTIGATIONS	6-1
     6.1   RESULTS OF GROUNDWATER CONTAMINATION
          ASSESSMENTS	6-1

 7.0 SUMMARY OF SITE RISKS	7-1

 8.0 DESCRIPTION OF ALTERNATIVES	  	8-1
     8.1   NO ACTION ALTERNATIVE	8-1
     8.2   PLUME CONTAINMENT ALTERNATIVE  	8-1

 9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES	9-1
     9.1   OVERALL PROTECTION OF HUMAN HEALTH AND THE
          ENVIRONMENT	9-1
     9.2   COMPLIANCE WITH APPLICABLE OR RELEVANT AND
          APPROPRIATE REQUIREMENTS	9-1
     9.3   LONG-TERM EFFECTIVENESS AND PERMANENCE  	9-2
     9.4   REDUCTION  OF TOXICTTY, MOBILITY, OR VOLUME
          THROUGH TREATMENT	9-2
     9.5   SHORT-TERM EFFECTIVENESS  	9-2
     9.6   IMPLEMENTABIUTY  	9-3
     9.7   COST  	9-3
     9.8   STATE ACCEPTANCE	9-3
     9.9   COMMUNITY ACCEPTANCE	9-3


06448A.B02                        .  i                        September 1995

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              RECORD OF DECISION FOR INTERIM ACTION
            CONTAINMENT OF SEVEN GROUNDWATER PLUMES
               MASSACHUSETTS MILITARY RESERVATION

                       TABLE OF CONTENTS
                            (continued)

 Section	Title	Page No.

     9.10  SUMMARY  	9-4

 10.0 THE SELECTED INTERIM REMEDIAL ACTION	10-1
     10.1  CLEANUP LEVELS	10-1
     10.2  DESCRIPTION OF THE SELECTED REMEDY  	10-2

 11.0 STATUTORY DETERMINATIONS	11-1
     11.1  THE SELECTED INTERIM REMEDY IS PROTECTIVE OF
          HUMAN HEALTH AND THE ENVIRONMENT	11-1
     11.2  THE SELECTED INTERIM REMEDY ATTAINS ARARs  	11-1
     11.3  THE SELECTED INTERIM REMEDIAL ACTION IS COST
          EFFECTIVE	11-15
     11.4  THE SELECTED INTERIM REMEDY UTILIZES PERMANENT
          SOLUTIONS AND ALTERNATIVE TREATMENT OR RESOURCE
          RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT
          PRACTICABLE	11-16
     11.5  THE SELECTED INTERIM REMEDY SATISFIES THE
          PREFERENCE FOR TREATMENT WHICH PERMANENTLY AND
          SIGNIFICANTLY REDUCES THE TOXICTTY, MOBILITY, OR
          VOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL
          ELEMENT	11-17

 12.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES 	12-1

 13.0 STATE ROLE	13-1

REFERENCES  	13-2

GLOSSARY OF ACRONYMS AND ABBREVIATIONS	13-5

GLOSSARY OF TECHNICAL TERMS	13-8

APPENDIX A    ADMINISTRATIVE RECORD INDEX	A-l
APPENDIX B    STATE CONCURRENCE LETTER	B-l
APPENDIX C    SUMMARY OF COMMENTS RECEIVED
              DURING THE PUBLIC COMMENT PERIOD
              AND NGB RESPONSES	C-l
064MA.B02                         11                        Septan** 1993

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                 RECORD OF DECISION FOR INTERIM ACTION
              CONTAINMENT OF SEVEN GROUNDWATER PLUMES
                 MASSACHUSETTS MILITARY RESERVATION
                             LIST OF FIGURES
 Figure	Title	Page No.

 2-1 Site Location Map	2-2
 3-1 Groundwater Plumes Map	3-2
 6-1 LF-1 Plume	6-2
 6-2 SD-5 Plume	6-4
 6-3 Western Aquafarm Plume	6-5
 6-4 Eastern Briarwood Plume	6-7
 6-5 FS-12 Plume	6-9
 6-6 CS-10 Plume	6-10
 6-7 Ashumet Valley Plume	6-12
06448A.B02                             ill                           September 1995

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                 RECORD OF DECISION FOR INTERIM ACTION
              CONTAINMENT OF SEVEN GROUNDWATER PLUMES
                 MASSACHUSETTS MILITARY RESERVATION
                             LIST OF TABLES
 Table	Title	Page No.

 3-1   Plume Information	3-3
 7-1   Summary of Groundwater Risks for Seven Plumes  	7-3
 10-1  Federal MCLs, Federal Non-Zero MCLGs and Massachusetts MCLs for
      Plume Contaminants of Concern	10-3
 10-2  Proposed Treatment Levels for Extracted Groundwater	10-4
 11-1  Chemical-Specific ARARs  	11-3
 11-2  Location-Specific ARARs	11-5
 11-3  Action-Specific ARARs	11-8
0644SA.B02                             lv                           SipMnbw 1995

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                                                                      SECTION 1
              1.0  DECLARATION FOR THE RECORD OF DECISION
 SITE NAME AND LOCATION

 The Massachusetts Military Reservation (MMR) on Cape Cod, Massachusetts lies within the
 boundaries of Bourne,  Mashpee, and Sandwich,  and abuts Falmouth.  Seven groundwater
 contaminant plumes have migrated beyond or are approaching the installation boundary. These
 groundwater plumes are referred to as: the Landfill-1 (LF-1) Plume, the Storm Drain-5 (SD-5)
 Plume, the Western Aquafarm Plume, the Eastern Briarwood Plume, the Fuel Spill-12 (FS-12)
 Plume, the Chemical Spill-10 (CS-10) Plume, and the Ashumet Valley Plume.

 STATEMENT OF BASIS AND PURPOSE

 This document presents the selected  interim  remedial action chosen for seven groundwater
 contaminant plumes at MMR 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
 Contingency Plan (NCP).  The decision is based on the Administrative Record for this site,
 which was developed in accordance with Section 113(k) of CERCLA and which is available for
 public  review at the information repositories located at:   (1) the Falmouth  Public Library,
 Falmouth, Massachusetts; (2) the National Guard Bureau (NGB) Installation Restoration Program
 (IRP) at Otis Air National Guard (ANG) Base, Massachusetts; (3) the U.  S. Environmental
 Protection Agency (USEPA) Regional Office at 90 Canal Street, Boston, Massachusetts;  and
 (4) the Massachusetts Department of Environmental Protection, Lakeville, Massachusetts. The
 items comprising the Administrative Record upon which the selection of a  remedial action is
 based are listed in Appendix A. The Commonwealth of Massachusetts' statement of concurrence
 with the selected remedy is presented in Appendix B.

 ASSESSMENT OF ftTTE GROUNDWATER

 Actual or threatened releases of hazardous substances associated with the seven plumes addressed
 by this document,  if not addressed by implementing the response action selected in this Record
 of Decision (ROD), may pose an imminent  and substantial endangerment  to human health,
 welfare, or the environment.

 DESCRIPTION OF TWR SKT.FCTED INTERIM KEMTDY

 In summary, the interim remedy consists of the following:

       •      extracting contaminated groundwater at the leading edge of the seven plumes and
            potentially extracting groundwater from hot spot areas identified during remedial
            design, if feasible
                          Installation Restoration Program

06448A.B02                                1-1                              September 1995

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                                                                         SECTION 1
       •     pumping and conveying the extracted groundwater to a treatment system

       •     removing Volatile Organic Compounds (VOCs) and other compounds using the
             treatment system

       •     discharging treated water back to groundwater and/or other beneficial use

       •     installing, measuring water levels in, and sampling groundwater monitoring wells
             downgradient and to the sides of the extraction wells at each plume to monitor the
             hydraulic performance of the extraction system

       •     sampling the influent between key unit processes, and the effluent of the treatment
             system(s) to monitor its performance

       •     restricting groundwater use within the areas contained through imposition  of
             institutional controls

This interim remedial action will intercept the contaminated groundwater plumes to prevent
further downgradient movement of the contaminants.  Extraction and treatment will continue
until the final remedy for the site is chosen. The interim and final remedies must be consistent
with the clean-up goals established for the entire MMR site.   The National Guard Bureau's
(NGB's) long-term clean-up goals for reducing contamination in the groundwater at MMR are
to meet federal Maximum Contaminant Levels (MCLs), non-zero federal Maximum Contaminant
Level Goals (MCLGs), Massachusetts MCLs, or risk-based guidance levels for compounds for
which drinking water standards have  not been set.

STATUTORY DETERMINATIONS

The interim action is protective of human health and the environment, complies with federal and
state Applicable or Relevant and Appropriate Requirements (ARARs) for this limited scope
action, and is cost-effective. Although this interim action is not intended to fully address the
statutory mandate for permanence and treatment to the maximum extent practicable, this interim
action uses treatment and thus is in furtherance of that statutory mandate. Because this action
does not constitute the final remedy for the seven groundwater plumes, the statutory preference
for remedies that employ treatment that reduces mobility,  toxicity, or volume as  a  principal
element, although partially addressed in this remedy, will be addressed by the final response
action.  Subsequent actions are planned to fully address the threats posed by conditions at these
plumes.  Because mis remedy will result in hazardous substances remaining on site above health-
based concentrations, a review  will be conducted after five years of operation to ensure the
remedy provides adequate protection of human health and the environment. Because this is an
interim action ROD, review of this site and this remedy will be continuing as the NGB continues
to develop final remedial alternatives  for the groundwater plumes.
                          Installation Restoration Program

0644IA.B02                                 1-2                                ScpunlMr 1995

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                                                                       SECTION 1
The foregoing represents selection of the interim remedial action by the Department of Defense
(DoD), NGB, and USEPA New  England Region, with concurrence of the Commonwealth of
Massachusetts.
Department of Defense, NGB
By:    l^ytuwdyM/ .ftJ^LMbJEA/	       Date:
       Donald W  Shepperd vW
       Major General, U.S. Air Force
       Director, Air National Guard
U. S. Environmental Protection Agency,
New England Region


By:   n^^Lfi /n>  fou^^u*s	      Date:
            M. Murphy     T  "/f
      Director, Waste Managemeiit Division
                          Installation Restoration Program

06448 A. B02                                1-3                              September 1995

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                                                                          SECTION 1
                            [This page intentionally blank]
                           Installation Restoration Program




0644IA.B02                                 1-4                               Stptmbw 1995

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                                                                        SECTION 2
                 2.0 SITE NAME, LOCATION, AND DESCRIPTION
 MMR,  which lies within the boundaries  of Bourne,  Mashpee, and  Sandwich,  and abuts
 Falmouth, Massachusetts (Figure 2-1), occupies approximately 22,000 acres and consists of
 several operating commands units:  the ANG and the Army National Guard (ARNG), which are
 both part of the NGB; the U. S. Air Force (USAF); the U. S. Coast Guard (USCG); and the
 Veterans Administration Cemetery. The USAF managed the base until the end of 1973 when
 base management was transferred to the ANG.

 MMR is located  on  two distinct  types of terrain on the Cape Cod Peninsula.   The main
 Cantonment Area lies on a broad, flat,  gently southward-sloping glacial  outwash plain.
 Elevation in the area ranges from 100 to 140 feet above sea level. To the north and west of the
 Cantonment Area, the terrain becomes hummocky with irregular hills and greater topographic
 relief, and lies in the southward extent of Wisconsin Age terminal moraines.  The elevations
 north and west of the Cantonment Area generally range from 100 to 250 feet; the highest
 elevation reportedly is 306 feet [U. S. Army Corps of Engineers (USAGE),  1985]. The entire
 site is dotted with numerous kettle  holes and depressions, some of which contain water.

 A single groundwater flow system  underlies western Cape Cod (from the Cape Cod Canal to
 Barnstable and Hyannis), including MMR. The aquifer system as described is unconfined (e.g.,
 in equilibrium with atmospheric pressure) and is recharged by infiltration from precipitation.
 Surface water runoff at MMR is virtually nonexistent. The highly permeable nature of the sands
 and gravels underlying  the  area allow for rapid infiltration of rainfall,  which essentially
 eliminates surface water runoff except on extreme slopes.  The high point of the water table, or
 the top of the groundwater mound within the western Cape Cod groundwater system, is located
 beneath the northern portion  of MMR.  Flow is generally radially outward from this mound.
 The ocean forms the lateral boundary of the aquifer on three sides, with groundwater discharging
 into Vineyard Sound and Nantucket Sound on the south, Buzzards Bay on the  west, and Cape
 Cod Bay on the north. The Bass River in Yarmouth forms the eastern lateral  boundary (ABB
 Environmental Services, Inc., May 1992).

 MMR has a year-round population of approximately 2,000 people, with an additional 800
 nonresident employees.  Year-round residents live in a housing area operated by the USCG.
 Intermittent use of the area  for Reserve and National Guard activities increases the  MMR
 population by as many as several thousand people (E. C. Jordan Co., 1986). Both year-round
 and seasonal residents live in the towns adjacent to MMR (i.e., Falmouth, Mashpee, Sandwich,
 and Bourne). The populations of these towns fluctuate significantly between winter and summer
 seasons as a result of the influx of vacationers.
                          Installation Restoration Program

06448A.B02                                 2-1                              September 1995

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     T99MTOH
                                         10    ' Kilometers
     SITE LOCATION MAP

MASSACHUSETTS MILITARY RESERVATION
      FIGURE 2-1
Stone & Webster Environmental
    Technology & Services
                               2-2

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                                                                        SECTION 3
              3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In accordance with Section 117(a) of CERCLA, the NGB is publishing this ROD to address the
public review and comment on the selected interim containment alternative known as remedial
alternative, for the  seven plumes.   The NGB, in consultation with the  USEPA  and the
Massachusetts  Department of Environmental Protection  (MADEP),  has  considered public
comments submitted during the public comment period as part of the final decision-making
process for selecting the interim remedial action for the site.  The results and conclusions of the
Plume Response Plan, developed by Operational Technologies Corporation in consultation with
the Plume Management Process Action  Team (PAT) 1994 are  summarized in this ROD.
Technical terms are defined in the Glossary of Technical Terms at the end of this document.

Past releases of hazardous materials at the MMR have resulted in groundwater contamination
in a number of areas.  Documented sources of contamination include former motor pools,
landfills, fire training areas and drainage structures such as dry wells.  Nine major plumes of
groundwater contamination (Figure 3-1  and Table 3-1) have been found to be migrating from
these source areas and have been defined during extensive groundwater investigations.  Recent
field investigations have identified the presence of a tenth plume emanating from a  fuel dump
valve test site,  designated Fuel Spill-1 (FS-1).  Further investigations are planned to determine
the significance of contamination at that site.  Seven of the nine plumes have migrated beyond
the MMR facility boundary:   LF-1  Plume, the SD-5 Plume, the PFSA Plume, the  Eastern
Briarwood Plume, the Ashumet Valley Plume, the FS-12 Plume and the CS-4 Plume.  However,
the PFSA Plume is not currently migrating and appears to be undergoing  natural biodegradation.
Interim action for the PFSA Plume is not included under this interim action.  The CS-10 Plume
and the Western Aquafarm Plume are approaching the MMR property line  and are included
under this interim action.  Extraction and treatment of groundwater has already been initiated
for the  purpose  of containing one plume, the CS-4 Plume, to manage the  migration of
contaminants and prevent further pollution of downgradient areas and an operating  municipal
well in the Town of Falmouth.  Quarterly groundwater elevation measurements and sampling
of monitoring wells located downgradient  of the CS-4 extraction wells are being performed to
evaluate the effectiveness of the CS-4 containment system.

Information on the source areas of contamination and investigation history for each of the seven
groundwater plumes being addressed under this Record  of Decision are summarized below.
Contamination  assessment  results relevant to the interim action described in this document are
summarized in Section 6.1.

3.1   LF-1 PLUME

The origin of the LF-1 groundwater contamination has been attributed to the Main Base Landfill,
and a former  motor pool located immediately to the southeast of the landfill, designated
Chemical  Spill-9  (CS-9).  CS-9 contaminated soils and underground drainage structures were
                          Installation Restoration Program

06448A.B02                                 3-1                               September 1995

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^•^sr-; v
  -s-i-
                                                  SCALE IN FEET
GROUNDWATER PLUMES MAP

MASSACHUSETTS MILITARY RESERVATION

Sown: HAZWRAP MMR Study Areas and Groundwattr PKjm.s Map (7-15-94)
      FIGURE 3-1

Stone & Webster Environmental
    Technology & Services
                                 3-2

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                                                    Table 3-1
                                                Plume Information
Plume Identification
LF-1
CS-10
PFSA*
SD-5 (NDIL)
Eastern Briarwood
Western Aquafarm
CS^t*
FS-12
FS-1*
Ashumet Valley
Contamination Source Area(s)
Main Base Landfill
Unit Equipment Training Site/Boeing
Michigan Aerospace Research Center
(UTES/BOMARC)
Petrol Fuel Storage Area (PFSA)
Storm Drain-5 [(Non-Destructive Inspection
Laboratory (NDIL)]
MMR Industrial Area
Underground Storage Tanks (USTs), Fuel
Transfer System
Motor Pool & Defense Property Disposal
Office (DPDO)
Cape Cod Canal Fuel Transfer Line
Fuel Dump Valve Test Site
Sewage Treatment Plant and Fire Training
Area 1
Major Chemical Contaminants
TCE, PCE, CCI4, Vinyl chloride, Arsenic,
Chromium
TCE, PCE, 1,1 -DCE
Benzene, Ethylbenzene
TCE, 1,2-DCEs, PCE, Methylene chloride
PCE, Benzene
Toluene, Ethylbenzene, Xylenes, TCE,
Lead
TCE, PCE
Benzene, EDB
Undetermined at this time
1,2-DCEs, PCE, TCE
        * Plumes not being addressed under this Interim Remedial Action.

Note:  Naturally-occurring Iron and Manganese mobilized due to the contamination are also present in many of the
       groundwater plumes.  Treatment for Iron and Manganese, if necessary, will be addressed during containment design.
       TCE  - Trichloroethene
       PCE  - Tetrachloroethene
       CCI4 - Carbon tetrachloride
1,1-DCE - 1,1-Dichloroethene
1,2-DCEs - 1,2-Dichloroethenes
EDB - Ethylene dibromide
s
1

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                                                                         SECTION 3
 removed during the summer of 1994 as an add-on to the LF-1 capping project.  The removed
 soils were  treated using the on-site thermal desorption unit.   The landfill encompasses
 approximately 100 acres and is bounded by Turpentine and Frank Perkins Roads to the east and
 west, and Herbert Road and Gonnery Avenue to the north and south, respectively.  LF-1 was
 used as the primary solid waste disposal facility at MMR beginning in 1944.  Disposal activities
 occurred from 1941 until 1984.  Wastes believed to have been landfilled at LF-1 include:
 general refuse, fuel tank sludge, herbicides, solvents,  transformer oils, fire extinguisher fluids,
 blank small arms ammunition, paints, paint thinners, batteries, DDT powder, hospital waste,
 municipal sewage sludge, coal fly ash,  and  possibly live ordnance.   After 1970, the NGB
 regulated  disposal in the Post-1970 cell as a  component of the MMR  Hazardous Waste
 Management Plan. Waste disposal in the Post-1970 Cell of LF-1 ceased in 1984. Since then,
 a trash transfer station on MMR has been used, with final disposal at the SEMASS incinerator
 in Rochester, Massachusetts  (CDM Federal Programs Corp., 1994).

 Closure activities at  several  landfill cells are underway in accordance with the ROD for an
 interim  remedial action (ABB Environmental Services, Inc.  1993).  These activities include
 securing the landfill with a fence along the perimeter roads that include CS-9.  Closure plans
 for the  1970 Cell, the Post-1970 Cell, and the Kettle Hole  were finalized in May 1993.
 Construction of an impermeable cap over these  areas is currently in progress.  An alternate
 closure, consisting of leaving buried wastes in place, maintaining vegetative cover, and long-
 term  groundwater monitoring, was  recommended  for the  1947, 1951, and  1957  Cells
 (collectively known as the Northwest Operable Unit).  The effectiveness of alternate closure for
 the Northwest Operable Unit has not yet been  resolved (CDM Federal Programs Corp.,  1994).
 The decision on the appropriate action for the remaining landfill cells will be documented in a
 final ROD for this operable unit.

 The initial Site Inspection (SI) for the landfill detected halogenated solvents in soils and leachate
 (R. F. Weston, Inc.,  1985).  A follow-up study initiated in 1986 detected chlorinated solvents
 in groundwater at the landfill, and in downgradient monitoring wells and the base supply Well G
 (E. C. Jordan Co., 1987). Inorganics were also detected in the subsurface. An Interim RI was
 performed from 1987 to 1989 to quantify the  extent of past landfilling,  to further quantify the
 impact on groundwater downgradient of each landfill cell, and to estimate the potential for each
 cell to be a continuing source of groundwater contamination (E.  C. Jordan Co., 1990).  An RI
 performed between 1992 and  1994  was intended to further characterize the extent of subsurface
 contamination associated with the LF-1 plume (CDM  Federal Programs Corp., 1994).

 3.2   SD-5 AND WESTERN AQUAFARM FLUMES

 The source of contamination  for the SD-5 Plume  is the SD-5 A operable unit:

      •     The SD-5 A is a point source at the former site of the Non-Destructive Inspection
             Laboratory (NDIL),  where a dry well was located.
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                                                                          SECTION 3
 Sources of contamination for the Western Aquafarm Plume include three operable units:

        •      SD-5B is  a  series  of underground storage tanks (USTs)/fuel transfer system,
              known as the Western Aquafarm.

        •      SD-5C is located 1,000 feet south-southeast of SD-5B (the Western Aquafarm).
              SD-5C is an  installation  similar to SD-SB, and  is  known  as the Eastern
              Aquafarm. SD-5C also includes two additional source areas, the Permanent Field
              Training Site (PFTS) and Fuel Spill-5 (FS-5).

        •      A fourth operable unit,  designated SD-5D, is the impacted groundwater zone
              attributable to source area  Operable Units A, B, and C.  Tank flushings from
              Operable Units B and C were directed to a permanent  drainage swale midway
              between them, creating potential for a relatively wide combined source area.

 The NDBL was used to perform structural integrity testing of aircraft parts. Waste penetrants,
 trichloroethane (TCE), other halogenated solvents, emulsifiers, and spent film developers were
 generated in the testing process at the NDIL. These wastes were discharged to a leaching well
 behind  the NDIL building from  1955 to  1970 (E.  C. Jordan Co., 1986).   During  an SI
 performed in  1987 and  1988, the NDIL leaching well was determined to be a source for
 chlorinated  solvents  in  groundwater  (E.  C.  Jordan  Co.,  1990a).    The  NGB  removed
 approximately 700 gallons of fluid from the leaching well in 1990 (ABB Environmental Services,
 Inc., 1993).

 The Western Aquafarm system, located on the western side of the Central Drainage Swale,
 consists of six 25,000-gallon USTs that were used in the 1950s and 1960s to store and transfer
 aviation gasoline (AVGAS) and JP-4 jet fuel. Use of the Western Aquafarm was discontinued
 by 1970.  The Eastern and Western Aquafarms operated on the principle of water displacement.
 Fuel  was transferred from USTs  to refueler  trucks by pumping water into  the tanks and
 displacing the fuel.   To refill, fuel was  pumped into the tanks, water was displaced and
 discharged into a one-acre basin within the Central Drainage  Swale. Based on fueling reports,
 up to 20 million gallons per year of flushed water may have been discharged to the Central
 Drainage Swale from the aquafarm USTs (E. C. Jordan Co., 1986).

 The Eastern Aquafarm was a separate fuel storage and transfer system on the eastern side of the
 Central Drainage Swale that operated similar to  the Western Aquafarm system.  As fuel storage
 was phased out at this location,-the Eastern Aquafarm tanks were reportedly used for storage
 of motor vehicle gasoline (MOGAS) and ethylene glycol deicing fluid (E. C. Jordan Co., 1986).
 The USTs located at the Eastern and Western Aquafarms were removed in 1995 and transported
 off site  by a licensed carrier.

 The PFTS was used from  1956 to  1971  to support ANG training.  Up to 1,500 gallons of
 halogenated solvents; waste petroleum, oil, and lubricants;  ethylene glycol; and fuel  were
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                                                                        SECTION 3
 discharged into the Central Drainage Swale.  From 19S8 to 19S9, an additional 1,000 gallons
 of AVGAS and JP-4 were reportedly discharged into the drainage swale area to drain refueler
 trucks prior to fuel delivery maintenance.  An adjacent hangar (Building 3140) has  been
 demolished.  A historical design drawing shows a NDIL leaching well (which was  later
 removed) located at the western end of the building (ABB Environmental Services, Inc., 1993).

 During the early 1960s, three refueling aircraft were destroyed in a fire, resulting in the FS-5
 fuel spill.  At the time of the fire, the aircraft were fueled with approximately 15,000 gallons
 of AVGAS. Some unknown portion of that total amount of fuel was washed into a storm drain
 near the Eastern Aquafarm, which also discharges into the one-acre basin within the Central
 Drainage Swale. (ABB Environmental Services, Inc., 1993).

 An initial field investigation for the SD-S area of concern was performed in 1985. Halogenated
 organics and lead were detected in soil/sediment samples collected  from the drainage swale
 (R. F. Weston, Inc., 1985).  An SI (E. C. Jordan Co., 1986) performed during  1987/1988
 identified a number of contaminants in soil and groundwater, including chlorinated solvents, and
 confirmed that the NDIL leaching well was a source of contamination. Lead and a number of
 tentatively identified compounds (TICs) were also detected in soil and groundwater downgradienf
 of the Western Aquafarm,  suggesting residual fuel contamination.  Lead and polynuclear
 aromatic hydrocarbons (PAHs) detected in the Central Drainage Swale indicated potential
 contamination from infiltration of contaminated stormwater runoff. Other inorganics were also
 detected in the subsurface and in the Central Drainage Swale.

 An RI for the SD-5 site performed  between 1989 and 1993 focused primarily on the
 investigation of sources of contamination (ABB Environmental Services, Inc., 1993).  An RI for
 the Southeast Region Groundwater Operable Unit (SERGOU) was performed in 1993/1994. The
 purpose of the SERGOU RI was to identify the nature, distribution and impact of contaminants
 in groundwater in an area encompassing the SD-5, Western Aquafarm, and PFSA plumes, all
 of which are located in the region near the southeast edge of MMR.

 3.3    EASTERN BRIARWOOD PLUME

 The Eastern Briarwood Plume is located near the southeastern comer of the MMR property.
 Specific source areas of the groundwater contamination have not been defined. Contamination
 is believed to emanate from  several locations, including the former heat plant and various
 maintenance shops and hangers. Four potential areas that may be sources of the contamination
 include the Storm Drain-4 (SD-4), Chemical Spill-14 (CS-14), Chemical Spill-15 (CS-15) and
 Fuel SpiU-25 (FS-25) Study Areas.

 Study Area SD-4 is a drainage course located on the southeast side of die Flightline Area of
MMR. Storm  water runoff from the SD-4 study area is  collected in a series of ditches, some
of which are unlined.  The drainage  ditches channeled flow to an oil/water separator, which
discharged treated water to a ditch and a small wetland area to the south. It is estimated that
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                                                                          SECTION 3
 over 1.4 million gallons of petroleum distillate solvent was flushed to the drainage system (E. C.
 Jordan  Co.,  1986).  This solvent, used to wash aircraft daily,  was reportedly dumped into
 hangar  deck drains connected to the storm drain system.

 Unknown quantities of solvents, including toluene and TCE used in the maintenance of aircraft
 at Hangar 128 between 1955 and 1970, were also flushed into the storm drain system.  From
 1978 to 1988, the hangar was used by the USCG for aircraft maintenance. Numerous spills of
 aviation gasoline (AVGAS) on the hangar deck and a portion of this fuel were also reportedly
 washed into the storm drain system.

 A former pumphouse (Building 123) contained four  25,000-gallon USTs used to store JP-4.
 Reportedly, periodic spills  had also occurred at the pumphouse and were washed into the
 drainage system.

 Study Area CS-14 is located within the Flightline Area of MMR.  From 1955 to 1969, a
 leaching pit in Building 156 reportedly received discharge from a room that housed a solvent
 vapor degreaser.    The  degreaser was  used to remove a  petroleum-based rust inhibitor
 (Cosmoline) from engines and engine parts.  Two other potential sources of contaminant release
 to the subsurface, a sand and gasoline trap, and an out-of-service oil/water separator, are in the
 process  of being evaluated.   However, these have not been documented  as sources  of
 contamination.

 Study Area CS-15 encompasses two buildings (Buildings 202 and 204) and jet engine test stands.
 The study area was used for engine testing from 1949 until 1985. Engine testing was performed
 inside Building 204  from 1949 to  1954.  During that time, wastes generated in Building 204
 were washed to a floor drain which led to a gasoline trap and then a drainage  ditch (CDM
 Federal  Programs Corp.,  1994). From 1954 to 1985, engine testing was performed outside at
 Building 202. It is estimated that 180 gallons per year of JP-4 and AVGAS and 1,000 to 15,000
 gallons per year of petroleum distillate were generated from 1949 to 1970.  During that period,
 wastes were reportedly washed off a concrete test pad and onto the ground. After 1970, the
 only waste generated (JP-4) was picked  up for disposal by a contractor  (E. C.  Jordan Co.,
 1986).

 Study Area FS-25 is an area of petroleum contamination located near Building 167. Possible
 historical sources of the contamination include heavy equipment maintenance and/or refueling
 operations, and  runoff from  the  nearby  runway.  Approximately 2,000 cubic  yards  of
 contaminated soil was excavated from this area in  1989 (E. C. Jordan Co., 1990b).

 An SI that included the above areas was performed in 1985 and 1986 (E. C. Jordan Co., 1986).
 An RI  completed in 1994  defined the nature and extent of contamination believed  to be
 associated with Study Areas  SD-4,  CS-14, and CS-15 (CDM Federal Programs Corps., 1994).
 The  characterization of  subsurface contamination associated  with Source Area FS-25 was
 completed in  1990 (E. C. Jordan Co., 1990b).
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                                                                        SECTION 3
 3.4   FS-12 PLUME

 The origin of the FS-12 groundwater contamination and free product was a reported leak of
 approximately 70,000 gallons from a section of fuel pipeline at the intersection of Greenway
 Road and the western entrance to L-range (Advanced Sciences, Inc., 1993). Both AVGAS and
 JP-4 jet fuel were carried through the pipeline. The leaking section of the pipeline was repaired
 in 1972. Contamination associated with FS-12 was first detected in 1990 when the Sandwich
 Water District detected hydrocarbon odors and volatile organic compounds (VOCs), including
 benzene, in groundwater at two exploratory wells installed on the grounds of Camp Good News
 downgradient and off-base. The exploratory wells were installed as part of an effort to identify
 suitable locations for additional water supply production wells.   The RI completed in 1993
 concluded that fuel leaking from the pipeline contaminated  soil hi the  immediate vicinity  of
 Greenway Road and groundwater (Advanced Sciences, Inc.,  1993).

 The NGB has initiated remediation of the free product as a Time-Critical Removal Action. An
 in situ vapor extraction, air sparging, vapor-phase and catalytic oxidation and carbon adsorption
 system to effect remediation of the detected free product is currently being constructed and will
 be operational in August of 1995.

 3.5    CS-10 FLUME

 The CS-10 study area is 38 acres in size and is located near the eastern edge of the MMR
 property line, west  of Snake Pond. The USAF maintained ground-to-air missiles at the Boeing
 Michigan Aerospace Research Center (BOMARC), located within the  CS-10 study area, from
 1960 until 1973 when it was abandoned. Since 1978, the ARNG has operated the Unit Training
 Equipment  Site (UTES) at this location for maintenance of armored and wheeled vehicles.

 BOMARC  operations that used hazardous materials and generated chemical and fuel-related
 waste products included maintenance of missile guidance systems, maintenance of the fuel and
 engine system, fueling and defueling, and power plant operations. Maintenance of the guidance
 systems would have required the use of significant quantities of solvents.  However, quantities
 and waste disposal  methods for the solvents and fuels are unknown. A fuel spill occurred in
 1985 during the removal of a 25,000-gallon UST. Less than 500 gallons of fuel were reportedly
 released and soils impacted by the spill  were excavated and removed  from the site (CDM
 Federal Programs Corp., 1993). No records of spills from UTES operations were found (CDM
 Federal Programs Corp., 1993).

 The U. S. Army Environmental Hygiene Agency (AEHA) initiated an evaluation of the possible
 impact of UTES/BOMARC activities on local groundwater quality  in 1985.  An SI was
 conducted from 1986 to  1988 based on the detection of  several chlorinated organics in
 groundwater during the AEHA study. The SI identified a number of use-related contamination
 sources in the BOMARC  area, including leaching wells, oil interceptors, storm drain catch
 basins, and drainage swales.   Disposal of fuel and industrial chemicals into these structures
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0644IA.M2                                 3-8

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                                                                        SECTION 3
 resulted in the release of contaminants to groundwater.  Contaminants are  reported to have
 spread throughout the source area through drainage structures (CDM Federal Programs Corp.,
 1993).

 An Interim RI was conducted in 1989 and 1990 to investigate suspected sources of groundwater
 contamination,  determine  the extent  of groundwater  contamination,  and determine the
 significance of facility storm sewers as contaminant migration pathways.  The most recent RI
 focused on completing characterization of the nature and extent of downgradient contamination
 (CDM Federal Programs Corp., 1993).  The NGB plans to perform an Interim Feasibility Study
 to address nine hot spot source areas of contamination.

 3.6    ASHIMET VALLEY PLUME

 The Ashumet Valley groundwater contamination is reported to be the result of two sources (ABB
 Environmental Services, Inc., 1992).  The sewage treatment plant (STP), which began operation
 at MMR in 1936, was the most likely source in the past. VOCs were not routinely disposed of
 in the STP since the 1970s (Operational Technologies Corp., 1994).  Fire  Training Area-1
 (FTA-1) was operated until 1985.  The inactive FTA-1, located north of the  STP, also
 contributed to the Ashumet Valley Plume. Activities at FTA-1  included pouring used fuels and
 solvents onto the ground and igniting the liquid for fire fighter training exercises.  Contaminants
 from the FTA-1 area appear to be following the same migration path as contaminants from the
 Ashumet Valley sewage treatment area but deeper in the aquifer.

 An initial investigation of the Ashumet Valley Plume performed in 1986 and 1987 confirmed the
 presence of the chlorinated solvents in groundwater reported earlier by the U. S. Geological
 Survey (USGS) and others.

 As a result of these findings, the  NGB funded two interim  remedial measures to address the
 impact of the Ashumet Valley Plume  and to protect the public health of  Ashumet Valley
 residents. The NGB reimbursed the Town of Falmouth for the cost of the Ashumet Valley water
 supply well,  and provided funds to extend the Falmouth  municipal  water  system into the
 Ashumet Valley neighborhood north of Route 151.

 A detailed assessment of the migration of the plume and the potential risks  to downgradient
 receptors was performed in the late 1980s and  during 1990 (E. C. Jordan  Co., 1991).  A
 groundwater RI report submitted in April 1995 indicated insignificant discharge of the Ashumet
 Valley Plume to Ashumet Pond (ABB Environmental Services, Inc., 1995).

 3.7    ENFORCEMENT HISTORY

 In 1982, the DoD initiated a multi-phase IRP to identify and evaluate problems associated with
 past hazardous waste disposal and spills at DoD installations, including NGB facilities. An on-
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                                                                         SECTION 3
 base IRP office was established in 1990.  The ERP parallels the Superfimd program and is
 conducted in seven stages, as follows:

       •      identification of potential hazardous waste sites

       •      confirmation of the presence of hazardous materials at the site

       •      determining  the  type  and extent  of  contamination during  the Remedial
              Investigation

       •      evaluation of alternatives for cleanup of the site in a Feasibility Study

       •      proposal of a clean-up remedy in a Proposed Plan

       •      selection of a remedy

       •      preparation of a Record of Decision

       •      implementation of the remedy for cleanup of the she

 Both private sector and federal facility sites are eligible for placement on the USEPA National
 Priorities List (NPL), which is an information management tool used to prioritize investigations
 and responses at hazardous waste sites. MMR was added to the NPL on November 21, 1989
 (USEPA,  1989).  Federal military sites such as MMR receive funding from the DoD Defense
 Environmental Restoration Account and not from the Hazardous Substances Superfund under
 CERCLA.

 The NGB, as the manager  of. the IRP, has followed  USEPA guidelines  for   the  IRP
 investigations conducted since 1986 and for all investigations conducted since 1989 when the
 facility was added to the NPL. Placement on the NPL has not necessitated substantive changes
 in the overall technical approach to remediation studies. However, upon formalization of the
 NPL status, the NGB and USCG  entered into an FFA with the USEPA to define responsibilities,
 documentation requirements, and future regulatory interaction regarding IRP activities at MMR.
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                                                                        SECTION 4
                        4.0  COMMUNITY PARTICIPATION
 Throughout MMR's history, community concern and involvement has been high. The NGB and
 USEPA have kept the community and other interested patties apprised of site activities through
 informational meetings, fact sheets, press releases, public hearings, and Technical Environmental
 Affairs Committee (TEAC) meetings.  The TEAC was organized in 1986 by the NGB to provide
 a forum for public input on MMR remedial response activities.  Membership on the TEAC
 comprises USEPA, MADEP, and representatives from local, regional, and state groups.

 During July 1991, the MMR community relations plan was released; this outlined a program to
 address community concerns and keep citizens informed and involved during remedial activities.
 Consistent with the Community Relations Plan, the NGB offered the public the opportunity to
 review the Proposed Plan and comment on the remedial alternatives described therein.

 The NGB held two public informational meetings to describe the preferred alternative and the
 no-action alternative which  were  considered by the Plume Management PAT (Operational
 Technologies Corporation, 1994). The first public meeting was held on February 7, 1995 at the
 North Falmouth Elementary School, Old Main Street, in Falmouth, Massachusetts.  The second
 public  meeting was held on February 9, 1995  at the Forestdale  School, 151 Route 130, in
 Sandwich, Massachusetts.  The public was encouraged to attend the meetings to hear the
 presentations and participate in discussions.

 The NGB conducted a 30-day formal public comment period from February 10 to March 11,
 1995 to provide an opportunity for public involvement in the containment decision.  During the
 comment period, the public was invited to review the Proposed Plan and the Plume Response
 Plan report and to offer comments on the Proposed Plan to the NGB.

 The NGB held an informal public hearing on March  1, 1995,  at 7:00 P.M., at the  Mashpee
 Middle School, Old Barnstable Road, Mashpee,  Massachusetts, to accept verbal and written
 comments on the remedial alternatives under consideration for the  seven groundwater plumes.
 This hearing provided the opportunity for people to comment on the Proposed Plan after they
 heard the presentations made at the two informational public meetings.

 The NGB, in consultation with the USEPA and MADEP,  considered comments received from
 the public as part of the process of reaching a final decision on the  most appropriate interim
 remedy for the seven plumes of groundwater contamination.  The NGB's final choice of an
 interim remedy is contained in this ROD. Public comment was an important part of the ROD
process and was considered in selecting the interim remedy. A Responsiveness Summary, that
 summarizes the public's written and verbal comments with the NGB's responses to comments
 received during the public comment period,  is included with this ROD (Appendix C).
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                                                                       SECTION 5
               5.0 SCOPE AND ROLE OF THE RESPONSE ACTION
The selected remedy was developed by comparing the no-action alternative with containment of
the seven groundwater plumes at MMR.  The selected remedy is an interim remedy. An interim
remedy is designed to take action to protect human health and the environment in the short term
while additional information is collected to evaluate and select a final remedy.   The interim
remedy will support the final remedy and will operate until a final remedial action is developed.

In summary, the interim remedy provides for:  (1) extracting contaminated groundwater at the
leading edge of the seven plumes and potentially extracting groundwater from hot spot areas
identified during remedial design,  if feasible; (2) conveying the extracted groundwater to a
treatment  system  to  remove contaminants; (3) discharging  the treated water back to the
groundwater and/or other beneficial use; (4) installing monitoring wells, measuring water levels,
and sampling groundwater to monitor the performance of the extraction system; (5) monitoring
the influent and effluent of the treatment system; (6) restricting groundwater use within the areas
contained through imposition of institutional controls; and (7) conducting a review after  five
years of operation to ensure the remedy provides  adequate protection of human health  and
environment.  This interim remedial action will intercept the groundwater plumes to prevent
further downgradient movement of contaminants. A final remedial action, when implemented,
will be consistent with this interim action and the NGB's long-term clean-up goals for reducing
contamination in the groundwater at MMR.

The interim remedial action will address the following objectives:

       •      Reduce the risks to human health associated with the potential future consumption
             and direct contact with groundwater and surface waters

       •      Protect uncontaminated  groundwater and surface waters for future use by
             minimizing the migration of contaminants

       •      Reduce potential ecological risks to surface waters and sensitive coastal waters
             through the implementation of the containment system

       •      Reduce the time required for aquifer restoration
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                                                                      SECTION 6
                    6.0  RESULTS OF SITE INVESTIGATIONS
 6.1    RESULTS OF GROUNDWATER CONTAMINATION ASSESSMENTS

 A number of organic and inorganic contaminants were detected in groundwater during MMR
 contamination assessments.  For the purposes of this ROD, groundwater contaminants are
 separated into three groups:  halogenated (chlorinated) solvents, fuel-related compounds, and
 inorganics.  Solvent contamination is defined as the summation of the five most commonly
 occurring chlorinated solvent contaminants detected in groundwater at MMR:  tetrachloroethene
 (PCE),  trichloroethane  (TCE),  1,1-dichloroethene (1,1-DCE)  and   1,2-dichloroethenes
 (1,2-DCEs), and carbon tetrachloride (CCl,).  Organic fuel contamination  is defined as the
 summation of the four most commonly occurring fuel compounds detected at MMR:  benzene,
 toluene, ethylbenzene and xylenes (BTEX), plus a common fuel antiknock compound, ethylene
 dibromide (EDB). Inorganics contamination refers to the metals iron and manganese, but may
 include other metals such as arsenic, chromium or lead.

 The following subsections briefly describe groundwater contamination from seven AOCs.  The
 plume maps shown in Figures 6-1 through 6-7 contain references to the proposed general
 locations of extraction wells and piping routes. Precise locations of extraction wells and piping
 routes will be determined during the design of the containment system.

 6.1.1 LF-1 Plume

 Groundwater contamination near the leading edge of the LF-1 Plume consists of chlorinated
 solvents, all of which are VOCs.  The site contaminants of concern include up to 64 micrograms
 per liter 0*g/l) TCE, 65 /tg/1  PCE, 60 /ig/1  CCl, and 8 /ig/1 vinyl chloride, exceeding
 maximum contaminant levels  (MCLs) (see Table 10-1). Elevated concentrations of fuel-related
 compounds and several metals were also detected in portions of the plume.  A profile of the
 LF-1  Plume was developed based on the results of the RI  (CDM Federal  Programs Corp.,
 1994).  The approximate horizontal extent of groundwater contamination is shown  on
 Figure 6-1.  The plume of solvent-related contaminants is estimated to extend approximately
 16,500 feet downgradient from the source area to the vicinity of Route 28. At the time the
 Plume Response Plan  was prepared, the LF-1 Plume was up to 6,000 feet wide, and up to 90
 feet thick.  The plume has migrated downward  from the water table with distance from the
 source area.   Contamination  has been detected to a depth of about 100 feet below the water
 table. The estimated volume of groundwater containing chlorinated solvent-related contaminants
 in the LF-1 Plume is approximately 22 billion gallons (Operational Technologies Corp., 1994).
 Groundwater in the vicinity of the leading edge of the  LF-1 Plume is estimated to be migrating
 in two lobes  to the west/southwest at an average  speed of 544 feet per year.

 According to the RI, the LF-1 Plume is moving in the direction of the Town of Bourne water
 supply Wells No. 2  and 5 (CDM Federal Programs Corp., 1994). Tetrachloroethene  was
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to
                                                                                               Appnilmiu (bound-
                                                                                               •«»f Extraction/
                                                                                               Nachargt Snum
                                                                                               LecMton*
                             LF-1 PLUME

                            Well Fence Locations
                  MASSACHUSETTS MILITARY RESERVATION
              Sources: Modified from Plume Response Plan, Operational Technologies Corp.
                    6/94; USGS Pocasset Quadrangle
    FIGURE 6-1


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                                                                        SECTION 6
 recently detected in the Town of Bourne's Water Supply Well No. 5 at concentrations ranging
 from 0.5 jjg/1 (its detection limit) to 0.8 pg/1, below the 5.0 pg/1 federal and Massachusetts
 MCLs.   Contaminants have not been detected in Water Supply Well No. 2.  The VOCs
 tetrachloroethene, toluene,  chloroform, and  1,1,1-trichloroethane have been  detected in
 monitoring wells located near Water Supply Wells No. 2 and 5, between MMR monitoring well
 fences 4 and 5.  Concentrations of these contaminants were below federal and Massachusetts
 MCLs and were approximately an order of magnitude or more below these MCLs during the
 most recent sampling round at these water supply monitoring wells.

 6.1.2 SD-5 and Western Aquafarm Plumes

 Groundwater contamination downgradient of SD-5A (NDIL sump)  consists  of chlorinated
 solvents and other VOCs. TCE has been detected at concentrations of up to 59 pg/1, and 1,2-
 DCEs have been detected at a (total) concentration of up to 110 ugll in groundwater. A number
 of inorganic contaminants have also been detected in groundwater.  A profile of the SD-5A
 Plume was developed based on the results of the RI (ABB Environmental Services, Inc.,  1993).
 The approximate horizontal extent of groundwater contamination is shown on Figure 6-2. The
 SD-5A Plume of solvent-related contaminants is approximately 10,000 feet long, 500 feet wide
 and 20 to 30 feet thick near the source areas.  The plume slowly broadens  to a  width of
 approximately 800 feet as it migrates south with groundwater flow, and to a width of 1,750 feet
 as it turns easterly toward Johns Pond.  The plume is up to 100 feet thick near Johns Pond. The
 estimated  volume of  groundwater  containing chlorinated  VOCs in  the SD-5A  Plume is
 approximately 2 billion gallons  (Operational Technologies Corp.,  1994).  Groundwater in the
 vicinity of the SD-5A Plume migrates at an estimated speed of 1,606 feet per year, discharging
 to Johns Pond. (ABB Environmental Services, Inc., 1994).  However, contaminants associated
 with the SD-5A plume have not been detected in water samples collected from Johns Pond.

 Groundwater contamination within the SD-5B (Western Aquafarm) Plume consists of fuel-related
 contaminants, including toluene, ethylbenzene and xylenes.  Ethylbenzene has been detected at
 concentrations of up  to 910 pg/1 in  groundwater, which exceeds the  MAL.  A number of
 inorganic contaminants have also been detected in groundwater. A profile of the SD-5 Plume
 was developed based on the results of the RI. The approximate horizontal extent of groundwater
 contamination is shown on Figure 6-3.  The SD-5B Plume of fuel-related contaminants is
 approximately 1,550 feet long, 825 feet wide and 40 to 60 feet thick. The estimated volume of
 groundwater  containing fuel-related  contaminants  in  the Western  Aquafarm  Plume  is
 approximately 65 million gallons.  Groundwater in the vicinity of the Western Aquafarm Plume
 moves south at an estimated speed of 913 feet per year (Operational Technologies Corp., 1994).

 Groundwater contamination downgradient of the SD-5C (Eastern Aquafarm) Plume consists of
 TCE and PCE with sporadic fuel-related compounds.  Based on their lack of documented storage
 in the Eastern Aquafarm tanks, it is believed these solvents may have originated from the NDIL
 source.  It is currently unclear if the Eastern Aquafarm has caused appreciable  contamination
which is separate from the  NDEL contamination.  The two recognizable plumes (NDIL and
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06448A.B02                                 6-3                              September 1995

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                                                        SD-5 Source ATM*
                                                             Joknt Pond
            Scale 1:25 000
         SD-5 PLUME
                                                 FIGURE 6-2
        WtllF«nct Location
MASSACHUSETTS MILITARY RESERVATION
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                                   Western Aquaf arm
                                   Source Area*
     NOTE: Mbcationaalpipalina
     and Mtraetnn/hKharg* ayattma
      a pratminan. Actual
      llbaaaubkat
        a aaubiahad during daaign.
                   Scale 1:25 000
                   LEGEND
                    O/aatarTnai'lgg/l.
                    InQroundmlar
                       rblracUan/
                    Rachatg* (yatMi
                                                                             ReiM
      WESTERN AQUAFARM PLUME

               Well Fence Location
     MASSACHUSETTS MILITARY RESERVATION
Sourcas: Pluma Rasponaa Plan, Cpandonal Tachnotogiaa Cotp., S/M; USQS Pocaaaal Quadnngto
       FIGURE 6-3

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                                            6-5

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                                                                          SECTION 6
 Western Aquafann) are migrating  below the water table during the initial  2,000 feet of
 downgradient travel. The top of the SD-5A (NDIL) Plume is approximately 40 feet below the
 water table at South Outer Road (3,500 feet downgradient), and the Western Aquafann Plume
 is approximately 15 feet below the water table (1,550 feet downgradient). Because the NDIL
 and aquafarm source areas are believed to have discharged contaminants during the 1950s and
 1960s, contaminants theoretically could have migrated with groundwater beyond Johns Pond.
 While the on-base ilowpaths of both plumes are well defined, the off-base flow paths are more
 complex due to the influence of ponds and bogs (E. C. Jordan Co., 1991).

 6.1.3  Eastern Brianrood Plume

 The Eastern Briarwood Plume originates at several undefined sources in an industrialized area
 of MMR south of the flightline.  Groundwater contaminants of concern consist of chlorinated
 VOCs and fuel-related compounds.  PCE has been detected at concentrations of up to 14 pg/1,
 and benzene has been detected at concentrations of up to 6 pg/1 in groundwater. A profile of
 the Eastern Briarwood Plume was developed based on the results of the RI (CDM Federal
 Programs Corp., 1994a).  Contaminated groundwater  is migrating south towards Johns Pond.
 Its flow path is mapped as passing through the Eastern Briarwood development, where most
 shallow domestic water  wells have been replaced  by public water  supplies because of solvent
 contamination.   The rate of natural  groundwater movement should be sufficient  to have
 transported contaminants towards Johns Pond.  The residential well contamination  in the  late
 1980s may indicate passage of the plume. At the time  the Plume Response Plan was prepared,
 the Eastern  Briarwood Plume of  solvent-related contaminants  was estimated  to  extend
 approximately 2,500 feet downgradient from the source areas, was approximately  1,200  feet
 wide and about 20 feet thick at the leading edge of the plume.  The plume was known to be at
 least  15 to  20 feet below  the water table at the furthest  downgradient  monitoring well
 intersecting the plume.   Evidence of solvents at low concentrations in groundwater at a depth
 of 55 feet below the water table has been documented. The estimated volume of groundwater
 containing fuel-related contaminants in  the Eastern Briarwood Plume was estimated to be
 approximately 160 million gallons. The results of the most recent sampling round indicates the
plume has decreased in size. The approximate horizontal extent of groundwater contamination
 based on the recent sampling results is shown on Figure 6-4. Groundwater in the vicinity of the
Eastern Briarwood Plume will continue to migrate  southward at an average speed of 1,050  feet
per year.  Johns Pond, a trout stream, and cranberry bog system are located downgradient of
the plume (Operational Technologies Corp., 1994).

6.1.4 FS-12 Plume

 Groundwater  contamination within the FS-12 Plume consists of fuel-related VOCs and Semi-
volatile Organic Compounds (SVOCs).  Benzene and  EDB, the primary site contaminants of
concern,  were  detected at  concentrations of up to  1,600 and  597/tg/l  in  groundwater,
respectively, exceeding MCLs. Free product was detected in soil above die water table over a
5-acre area north and south of Greenway Road.  A profile of the FS-12 plume was developed
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                                             Eastern Briarwood Plume }—V
                                             ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^St~ft     t
                  Eastern Briarwood
                  Source Araaa
                                          Joknt  Pond
m pratminiry. Acou! buurn
wit b. tubtaM Own rtiMi
          Scale 1:25 000
EASTERN BRIARWOOD PLUME
         Well Fence Location
MASSACHUSETTS MILITARY RESERVATION
                                                           FIGURE 6-4
                                                     Stone & Webster Environmental
                                                    Technology & Services
Sources: Modfod horn Plum* Rnpom* Plift, CtMioml Ttdrategw Cop.. Ml;
    USGS POUIMI Oualnngto
                                   6-7

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                                                                        SECTION 6
 based on the results of the RI (Advanced Sciences, Inc., 1993).  The approximate horizontal
 extent of groundwater contamination is shown on Figure 6-5.  A plume  of fuel-related
 contaminants extends approximately 4,500  feet downgradient  from the  source  area to a
 monitoring well located south of the entrance to Camp Good News.  The FS-12 Plume has a
 width of up to 2,500 feet, and is 60 to 90 feet thick.  The estimated volume of groundwater
 containing fuel-related contaminants in the FS-12 Plume is approximately 1.5 billion gallons
 (Operational Technologies Corp., 1994).  Limited data suggest that the FS-12 Plume will
 continue to migrate to the south-southeast at a speed of 90 to 320 feet per year. According to
 the RI, groundwater from the FS-12 Plume is not expected to enter Snake Pond or threaten the
 Sandwich Water District Well No. 5  (Advanced Sciences, Inc., 1993).  Additional work is
 planned as part of the containment system design process to determine the need for extraction
 wells to protect Snake Pond and Well No. 5.

 6.1.5  CS-10 Plume

 Groundwater contamination within the CS-10 Plume consists primarily of chlorinated VOCs.
 The primary site contaminants of concern include up to 3,200 pg/1 TCE, 500 pg/1 PCE and
 58 pg/1 1,2-DCEs in groundwater, exceeding MCLs.   A profile  of the CS-10 plume was
 developed based on the results of the RI (CDM Federal Programs Corp., 1993). The approxi-
 mate horizontal extent of groundwater contamination is shown on Figure 6-6.  A plume of
 solvent-related contaminants is estimated to extend approximately 12,500 feet downgradient from
 the source area to a monitoring well approximately 2,000 feet from the southern boundary of
 the base (CDM Federal Programs  Corp., 1993).  The CS-10 Plume has a width of up to 3,600
 feet, and is approximately 40 to 80 feet  thick. The plume has migrated downward from  the
 water table with distance from the source area, and the top of the plume is about 55 feet below
 the water table at Gaffney Road (Operational Technologies Corp., 1994). The CS-10 Plume,
 deeper man the adjacent LF-1 plume, may commingle with and partially underflow the landfill
 plume (CDM Federal Programs Corp., 1993). The estimated volume of groundwater containing
 fuel-related contaminants in the CS-10 Plume is approximately 13 billion gallons (Operational
 Technologies Corp., 1994). The CS-10 Plume will continue to migrate in two lobes to the south
 and southwest at an average  speed of 321 feet per year.  According to the RI (CDM Federal
 Programs Corp., 1993), the easternmost lobe of the CS-10 plume is moving in the direction of
 Ashumet Pond, and a portion of this lobe of the plume  probably could discharge to the pond.
 The westernmost lobe of the plume could eventually underflow Coonamessett Pond (i.e., may
 not discharge to the pond). Concentrations of VOCs in MMR irrigation Well B, located near
 the leading edge of the western lobe of the plume, are  expected to increase over time (CDM
 Federal Programs Corp., 1993). If not contained, the potential exists that a portion of the CS-10
 Plume could eventually impact the Falmouth water supply well at Coonamessett Pond.

 6.1.6 Ashumet Valley Plume

 Groundwater contamination within the Ashumet Valley Plume consists of chlorinated VOCs.
 The plume contaminants of concern include up to 1,200 pg/1 of 1,2-DCEs, 982 pg/1 PCE, and
                          Installation Restoration Program

06448A.B02                                 6-8                    .          S*pttn*«1995

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9s
VO
          NOTE:
          •nd wrtriclion'racrMrg* »yst»m«
          •m ptrtimlrufy. Actual tocMiom
          wil bt *itiMM»d Airing dwan
                         FS-12 PLUME

                         Well Fence Location

               MASSACHUSETTS MILITARY RESERVATION
           Source: Plume Response Plan, Operational Technologies Corporation, June 1994
     FIGURE 6-5


Stone & Webster Environmental
    Technology & Services

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       CS-10 PLUME

         Wwl Fence Locnlons
MASSACHUSETTS MILITARY RESERVATION
                  C»».. «•«; U«Q8 Htmm Ou
         FIGURE 6-6

A Stone & Webster Environmental
       Technology & Services
                             6-10

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                                                                        SECTION 6
 95 fiLgll TCE, exceeding MCLs.  Ethylene dibromide was also shown to be contributing to
 groundwater risks.   Elevated  concentrations  of numerous  other  organic and inorganic
 contaminants were also detected in portions of the plume.  A profile of the Ashumet Valley
 Plume was developed based on the results  of the  RI (E. C.  Jordan Co.,  1991a).  The
 approximate horizontal extent of groundwater contamination is shown on Figure 6-7. The plume
 of DCEs, PCE, and TCE groundwater contamination  exceeding  5 jtg/1 (total)  extends
 approximately 18,750 feet downgradient from the source areas. The Ashumet Valley Plume
 extends up to 4,000 feet wide, and is up to 80 feet thick.  The plume is migrating nearly 40 feet
 below the water table throughout most of its length. The plume migrates deeper into the aquifer
 near the base sewage treatment plant due to the infiltration of approximately 250,000 gallons per
 day of treated wastewater (E. C. Jordan Co.,  1991a).  The estimated volume of groundwater
 containing VOCs in the plume is approximately 13 billion gallons. Groundwater in the vicinity
 of the Ashumet Valley Plume is migrating to the south/southwest at an average speed of 986 feet
 per year.  The Ashumet Valley Plume has reached the Town of Falraouth municipal supply well.
 If not contained, contaminated groundwater from the Ashumet Valley Plume could eventually
 reach private water supply wells and Green Pond (Operational Technologies Corp.,  1994).
 Recent studies indicated insignificant discharge of the Ashumet Valley Plume to Ashumet Pond
 (ABB Environmental Services, Inc., 1995).
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06448A.E02                                6-11                              September 1995

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      ASHUMET VALLEY PLUME
           Well Fene* Location
   MASSACHUSETTS MILITARY RESERVATION
SOUICM: Pluin.OMpormPljn.Jfr^raliamlTtctmhfM Cap.. IIH;USOSFitnouhtnt
        FIGURES-?
Stone & Webster Environmental
    Technology & Services
                                  6-12

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                                                                           SECTION 7
                           7.0  SUMMARY OF SITE RISKS
 Characterizing risk allows decisions about the need for cleanup to be made.  The risk of harm
 to human health is evaluated by calculating cumulative cancer and non-cancer risks associated
 with the public's potential for exposure to contaminants of concern, and comparing them to risk
 limits published in the NCP.

 Potential negative health effects include those which present an increased risk of developing
 cancer  from exposure to any  amount of potential cancer causing contaminants;  and non-
 cancerous health effects (such as damage to the nervous system, liver or other organs) caused
 by intake of more than a threshold amount of a contaminant. A threshold amount is the level
 at which adverse health effects may be expected to occur.

 The cumulative cancer risk is  an estimate of how much a person's  lifetime cancer risk  is
 increased as a result of exposure to the contaminants, that is, the excess risk due  to the
 contaminants from the site.  The NCP defines the acceptable cumulative cancer risk range of
 1 x 10"4 (1  in 10,000) to 1  x  10* (1 in  1,000,000) for Superfund sites.   That means an
 individual's exposure cannot increase his or her cancer risk by more than one in 10,000 to one
 in 1,000,000.  According to the NCP, anything greater is considered to be a significant risk that
 requires an evaluation of potential cleanup options.

 Exposure to contaminants  which affect  the  same organ  system  or which share  the same
 mechanism of lexicological action is totalled and measured against safe levels of these chemicals
 to calculate what is known as the Hazard Index. The NCP specifies a Hazard  Index (HI) of less
 than one for cumulative non-cancer risks.

 The results of a human health Risk Assessment for the seven MMR groundwater plumes were
 presented in the  Plume  Response Plan  and  the Proposed Plan.   The human health Risk
 Assessment  estimated the current and future risks to human health posed by  the contaminated
 groundwater based on existing Proposed Plan conditions.  The Risk Assessment is based on the
 assumption  that contaminated groundwater would be used for  drinking  water and other
 residential purposes.  The Plume Response Plan indicated that cancer and non-cancer risks to
 public health for the LF-1, CS-10, FS-12, SD-5, Western Aquafarm, Eastern Briarwood,  and
 Ashumet Valley Plumes aU exceed the risk ranges set forth in the NCP.  Calculated risks are
 presented in Table 7-1.

 There is no evidence that the seven plumes of groundwater contamination are adversely
 impacting surface waters at the present time.  Remedial  investigations indicate  that,  if not
 contained, contaminated groundwater from six of the seven plumes will eventually discharge to
 surface  waters (ABB Environmental Services,  Inc., 1993a and 1995;  CDM Federal Programs
 Corp., 1993, 1994 and 1994a). Risk assessments performed as part of the  RIs indicate that
 adverse ecological impacts on aquatic, and in some cases, terrestrial organisms could occur
                           Installation Restoration Program

06448A.B02                                 7-1                                September 1995

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                                                                       SECTION 7
 potentially in the future at those locations (ABB Environmental Services, Inc., 1993a and 1995;
 CDM Federal Programs  Corp., 1993, 1994 and 1994a).  Contaminated groundwater from the
 seventh plume, FS-12, is not expected to impact surface waters or pose any ecological risk
 (Advanced Sciences, Inc., 1993).
                          Installation Restoration Program

0644IA.B02                                 7-2

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                                                                           SECTION 7
                                        Table 7-1
                    Summary of Groundwater Risks for Seven Plumes
                           Massachusetts Military Reservation
Plume
CS-10
LF-1
FS-12
Ashumet Valley
Western Aquafarm
SD-5
Eastern Briarwood
Estimated Cancer Risk
Child
1.99x 10-2
2.40 x 10'3
w
*
*
*
*
Adult
1.29 x 1
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                                                                          SECTION 7
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0644SA.B02                                 7-4                               Stptmbut 1995

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                                                                        SECTION 8
                      8.0 DESCRIPTION OF ALTERNATIVES
 The NCP states that it is appropriate to evaluate a limited number of alternatives for interim
 remedial actions instead of the full range of alternatives typically evaluated for final remedial
 actions (see 55 FR 8704). Accordingly, two remedial alternatives were developed and evaluated
 in the Plume Response Plan:  No Action and Plume Containment.  The Plume Response Plan
 was determined to be the equivalent of a Feasibility Study and was used as the basis for the
 Proposed Plan. The No Action and Plume Containment Alternatives are described below.

 8.1   NO ACTION ALTERNATIVE

 The no-action alternative provided a baseline against which other alternatives can be compared.
 This alternative would not involve remedial actions to treat contaminated groundwater. The no-
 action alternative included semi-annual sampling of approximately 140 groundwater monitoring
 wells. Review of the site would also be conducted every five years.  The no-action alternative
 would not reduce risk and  would not meet the response objectives described in Section 10.1.

 Preliminary  estimates of cost and  time frames developed during preparation  of the Plume
 Response Plan are summarized below (Operational Technologies, Corp.,  1994).

 Estimated Time for Design and Construction:  None
 Estimated Time of Operation: 20 years
 Estimated Capital Cost: None
 Estimated Operations and Maintenance Costs:  $482,900

 Estimated Total Cost (net present worth): $6,018,700

 8.2   PLUME CONTAINMENT ALTERNATIVE

 The containment alternative includes extracting contaminated groundwater using extraction wells
 at the leading edges of seven plumes, treatment of extracted groundwater, and discharge of the
 treated water to groundwater and/or other beneficial use. The selected alternative will intercept
 the seven plumes, preventing further migration of contaminants downgradient above the MCLs
 and non-zero MCLGs.  Extraction and treatment will continue until the final groundwater
 remedy for the site has been chosen.  For cost estimating purposes, it has been assumed this
 interim containment remedy will operate for 20 years.  During this period, the NGB will also
 implement an environmental monitoring program to evaluate the effectiveness of the containment
 systems.   Monitoring wells, which will  serve as the  points of compliance for this interim
 remedial  action, will be located  downgradient and to the sides  of the extraction wells at each
plume. The NGB will adjust the rate of groundwater extraction and the reinjection of treated
groundwater, if implemented, hi a manner which ensures that the containment systems are
                          Installation Restoration Program

06448 A.B02                                8-1                               September 1995

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                                                                        SECTION 8
 operating property.  Groundwater use within the area contained will be restricted through the
 imposition of institutional controls.

 Extraction of groundwater containing halogenated solvents, fuel-related compounds and several
 metals will be accomplished using a network of wells positioned across the width of the leading
 edge of each of the seven plumes and at the depths of contamination.  Some of the solvents-
 contaminated groundwater extracted from the Ashumet Valley Plume may also contain low
 concentrations of nutrients.   Additional extraction  wells may be added in areas of higher
 concentrations referred to as hot spots for some of the plumes (i.e., at CS-10) if determined to
 be feasible during design of the remedy.  This determination will be made by the NGB, EPA,
 and  the State upon consideration of several factors,  including technical feasibility of hot spot
 contaminant  removal, impact of  additional remediation on  the overall plume containment
 schedule, and cost.  While hot spot remediation may be desirable for a number of reasons, the
 selected  interim remedy (containment and institutional controls)  will be protective of human
 health and the environment even if hot spot remediation is not implemented as part of the interim
 remedy.  Extracted groundwater will be conveyed by underground double-wall piping to one or
 more treatment systems prior to discharge.

 Preliminary estimates developed during preparation of the Plume Response Plan indicate that
 approximately 150 (vertical) extraction wells spaced about 100 to 180 feet apart pumping almost
 11 million gallons per day of water from the aquifer will be required to contain the plumes.
 Monitoring wells downgradient and to the sides of extraction wells will be installed to evaluate
 the effectiveness of the extraction systems. The actual number of extraction wells, their location
 and pumping  rates, and the locations of monitoring wells and piping will be determined during
 the design of the interim remedial action. The type of treatment methods to be used will also
 be determined during design of the interim remedial action.

 Preliminary estimates  of cost .and time frames developed during preparation of the Plume
 Response Plan (assuming one central treatment system) are summarized below  (Operational
 Technologies  Corp., 1994):

Estimated Time for Design and Construction:  42 months
Estimated Time of Operation:  20 years
Estimated Capital Cost': $112,755,000
Estimated Operations and Maintenance  Costs (net present worth)":  $66,597,000

Estimated Total Cost (netpresent worth): $179,352,000

       *      includes equipment and installation (1997 dollars).

       **     Total operation and maintenance cost for 20 years.
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                                                                           SECTION 8
 Detailed construction and operation and maintenance costs will be developed during the design
 of the interim remedial action.
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06448A.B02                                  8-3                                September 1995

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                                                                          SECTION 8
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0644IAJ02                                 8-4                               lipumlig 1995

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                                                                      SECTION 9
     9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
 The USEPA requires that remedial actions performed at CERCLA NPL sites be evaluated using
 nine criteria.  The nine criteria are used to select a remedy that meets the national Superfund
 program goals  of protecting  human  health and the environment, maintaining long-term
 protection,  and minimizing untreated  waste.  Since this would be an interim  action, the
 alternatives are evaluated in relation to the limited role and scope of the remedy.  Definitions
 of the nine criteria and a summary of the NGB's evaluation of the remedial alternatives using
 these nine criteria are presented below.

 9.1    OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

 Overall Protection of Human Health and the  Environment addresses how a  remedial action as
 a whole eliminates, reduces, or controls risks  by implementing treatment, engineering controls,
 or institutional controls. The plume containment alternative would protect human health and the
 environment by preventing the further downgradient  migration of contaminated groundwater.
 Contaminant concentrations in groundwater within the seven plumes, particularly near the source
 areas, would not be significantly reduced.   Additional protection would be afforded by the
 imposition of institutional controls restricting the use of groundwater in the contained areas.  The
 no-action alternative would not meet this criterion because contaminated groundwater would
 continue to migrate throughout the aquifer,  further contaminating drinking  water supplies.
 Consequently, risks would be increased rather than eliminated, reduced or controlled.

 9.2    COMPLIANCE WITH APPLICABLE OR RELEVANT AND  APPROPRIATE
      REQUIREMENTS

 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) addresses
 whether a remedial action  complies with all state and federal environmental and public health
 laws and requirements that apply or are relevant and appropriate to the conditions and cleanup
 options  at  a specific site.  If an ARAR cannot be met, the analysis of the alternative must
 provide the grounds for a statutory waiver. When comparing interim remedies, it is appropriate
 to analyze compliance only with those laws and regulations that are  applicable or relevant and
 appropriate to the limited scope of the interim action.

 The plume containment alternative will not meet federal and  state chemical-specific drinking
 water standards within the area of the plume being contained. However, since this is an interim
 remedy, these ARARs are being waived under CERCLA § 121(d)(4)(A) for the contained areas
 only.  Ultimately, these ARARs will be attained when the final remedial action is implemented
 for these plumes, unless grounds for a waiver can be established at that time.  The interim
 alternative, however, will comply with ARARs for all groundwater which is extracted, treated
 and discharged, including federal and state drinking water standards, and requirements for air
 emissions and disposal of sludges and solids resulting from treatment.  Section 11.2 discusses
                          Installation Restoration Program

06448A.B02                                9-1                              September 1995

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                                                                       SECTION 9
 compliance with ARARs in more detail and monitoring would be employed to verily compliance.
 The no-action alternative would not comply with ARARs because contaminated groundwater that
 exceeds federal and state drinking water standards would remain and continue to migrate.

 9.3    LONG-TERM EFFECTIVENESS AND PERMANENCE

 Long-term Effectiveness and Permanence refers to the ability of a remedial action to maintain
 reliable protection of human health and the environment over time once cleanup goals have been
 met.  Long-term effectiveness and permanence are not  relevant to the comparison between
 interim measures. As part of the Design Analysis Plan currently being developed, long-term
 effectiveness and permanence will be considered in selecting the final remedy for each of the
 seven plumes.  The plume containment alternative will continue to operate until the final remedy
 is selected.

 9.4    REDUCTION OF   TOXICITY,  MOBILITY,  OR   VOLUME   THROUGH
       TREATMENT

 Reduction of Toxicity, Mobility,  or Volume Through Treatment are three principal measures
 of overall performance of a remedial action.  The 1986 amendments to the CERCLA statute
 emphasize that, whenever possible,  a remedy should be selected that uses a treatment process
 to permanently reduce the level of toxicity of contaminants at a site,  the migration of
 contaminants away from the source of contamination, and the volume or amount of contaminants
 at the site. The plume containment alternative would prevent the further downgradient migration
 of containments at the leading edges of the seven plumes, protecting downgradient groundwater
 quality. However, contaminant volumes and toxicities within the seven plumes would not be
 significantly reduced.  The plume containment alternative would remove contaminants from
 extracted groundwater and organic contaminants removed from the extracted water  during
 treatment would be destroyed, either by the on-site treatment process itself or by the off-site
 regeneration of activated carbon if activated carbon is used. The no-action alternative would not
 reduce the toxicity, mobility or volume of contaminants since no treatment would be involved.

 9.5    SHORT-TERM EFFECTIVENESS

 Short-term Effectiveness refers to the likelihood of adverse impacts on human health and the
 environment that may be posed during the construction and implementation of an alternative until
 cleanup goals are achieved.  Because the  no-action  alternative involves no construction and
 would not involve treatment, adverse construction or implementation impacts would not occur.
 Workers performing environmental monitoring  would require specialized  health and safety
 training.  The plume containment alternative would also require specialized health and safety
 training for workers who construct and operate the groundwater extraction,  treatment and
 discharge system(s) and conduct monitoring. Adverse effects on these workers, or construction
 workers, are not anticipated as long as safe work practices are followed. Adverse effects of the
 construction and implementation of the plume containment alternative on the community are
                          Installation Restoration Program

0644SA.B02                                9-2                .               S«pttn*«r 199S

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                                                                        SECTION 9
 expected to be minimal.  Locations for extraction/recharge wells and piping beyond the MMR
 property line would be selected to minimize impacts on residents and landowners. Mitigating
 measures would also be implemented during construction to minimize its  impact  on the
 community.

 9.6    IMPLEMENTABILITY

 Implementability refers to technical and administrative feasibility, including the availability of
 materials and services needed to implement a remedial action.  The no-action alternative would
 meet this criterion because no implementation difficulties are expected. The plume containment
 alternative is also expected to be implementable.   Specific implementability issues will  be
 considered in the selection of technologies/techniques for the treatment of extracted groundwater,
 and the methods and locations for extracting groundwater and discharging treated water.  The
 selection of treatment technologies and discharge method(s)/location(s) will be performed during
 the design of the interim action.

 9.7    COST

 Cost includes the capital (i.e., equipment and installation) of implementing a remedial  action,
 as well as the cost of its operation and maintenance. The estimated total present worth cost
 considers both the capital and operation and maintenance costs.  The net present worth cost for
 the no-action alternative is estimated to be $6,018,700, based on 20 years of operation. The net
 present worth cost for the plume containment alternative is estimated to be $179,352,000, based
 on 20 years of operation. The cost of the plume containment alternative exceeds the cost of the
 no-action alternative. Capital, operation and maintenance, and present worth costs for the no-
 action and plume containment alternatives are discussed further in Section 8.0.

 9.8    STATE ACCEPTANCE

 State acceptance addresses whether the state concurs with or opposes the selected remedy  for the
 site.  The MADEP was fully involved in the development of the Plume Response Plan which
 is the basis for this ROD. A copy of the State Concurrence Letter is presented in Appendix B.

 9.9    COMMUNITY ACCEPTANCE

 Community acceptance refers to  whether  the public concurs with or opposes  the remedy
 selected. Based on the oral and written comments received during the public comment period,
 there is general acceptance of the selected interim remedy. A summary of community comments
 and the NGB's responses are presented in Appendix C.
                          Installation Restoration Program

06448A.B02                                 9-3                              September 1995

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                                                                         SECTION 9
 9.10  SUMMARY

 Of the nine criteria, protection of human health and compliance with all ARARs are considered
 threshold requirements that must be met by all remedies.  The NGB balances its consideration
 of alternatives with respect to long-term effectiveness and permanence; reductions in toxicity,
 mobility, or volume through treatment; short-term effectiveness; implementability; and cost.
 State and community concerns are then taken into consideration as modifying criteria in making
 the remedy selection decision.
                           Installation Restoration Program

0644IA.B02                                 9-4

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                                                                      SECTION 10
               10.0 THE SELECTED INTERIM REMEDIAL ACTION
 The NGB's selection of the interim remedy for the seven groundwater plumes, as described in
 this ROD, is based on an evaluation and screening process, the results of which are documented
 in the Plume Response Plan (Operational Technologies Corp., 1994). The purpose of the Plume
 Response Plan was to identify, analyze, and develop recommendations on potential remedial
 alternatives to address groundwater contamination at the site in the short term.

 The evaluation and  screening process was performed by the ERP Plume Management PAT,
 formed by the NGB to assist it in addressing plume containment at MMR in the short term.  The
 Plume Management PAT consists of individuals representing public agencies and the citizenry
 of Upper Cape Cod, including the following organizations and groups:  Coalition for Buzzards
 Bay, Association for the Preservation of Cape Cod, Alliance for Base Cleanup, Upper Cape
 Concerned Citizens,  U.  S. Geological Survey, Cape Cod Commission, USEPA, MADEP, and
 Air National Guard Readiness Center.

 The recommendations resulting from the Plume Management PAT's effort were approved by the
 IRP Senior Management Board, and  formed the basis for the NGB's selection of the interim
 remedy described in this ROD.  The Senior Management Board consists of municipal officials
 from the towns of Bourne, Falmouth, Mashpee, and Sandwich;  and representatives of the
 USEPA, MADEP, Massachusetts National Guard, and NGB. This section of the ROD describes
 the NGB's selected remedy for the site.  The no-action alternative which was also considered
 is described in Section 8.1.

 10.1   CLEANUP LEVELS

 Using the information gathered during site investigations and from the Plume Response Plan,
 the NGB identified remedial response objectives for the seven contaminated groundwater plumes.
 The objectives are as follows:

       •      Reduce the risks to human health associated with the potential future consumption
             and direct contact with  groundwater and surface waters

       •      Protect uncontaminated groundwater  and surface waters for future  use by
             minimizing the migration of contaminants

       •      Reduce potential ecological risks to surface waters and sensitive coastal waters
             through the implementation of the containment system

       •      Reduce the time required for aquifer restoration
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06448A.B02                                10-1                             September 1995

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                                                                      SECTION 10
 As an interim step to meeting these objectives, the NGB plans to contain seven groundwater
 plumes emanating from MMR  by extracting and treating groundwater to meet  ARAR's
 requirements (possibly including  hot spots).  Groundwater will be extracted from hot spots if
 determined to be feasible during  the design of the interim remedy.  It is anticipated that this
 interim remedial action, which is intended to quickly respond to these plumes, will eventually
 become part of the overall MMR groundwater remediation strategy. Therefore, the interim
 remedial action selected must be consistent with the cleanup goals established for MMR as a
 whole and the remediation of multiple plumes of groundwater contamination. The NGB's long-
 term cleanup goals for reducing contaminant concentrations in groundwater at MMR are to meet
 federal MCLs (40 CFR 141.11 and 141.16),  federal non-zero MCLGs, Massachusetts MCLs,
 and risk-based guidance levels for compounds for which drinking water standards have not been
 set. Federal MCLs, federal non-zero MCLGs, and Massachusetts MCLs for contaminants in
 the  seven groundwater plumes  addressed in this  Record of Decision are  summarized in
 Table  10-1.  For areas within the contained plumes, these federal and state standards will not
 be attained and will be waived pursuant to  § 121(d)(4)(A) of CERCLA. Ultimately, these
 ARARs will be attained when the final remedial action is implemented for these plumes, unless
 grounds for a waiver can be established at that time.  Treatment levels for water extracted by
 the containment systems for contaminants detected in groundwater from the seven plumes are
 presented in Table 10-2.

 Monitoring wells,  which will serve as the points of compliance for this interim remedial action,
 will be located downgradient of the extraction  wells at  each plume.   MCLs and non-zero
 MCLGs will be met at the monitoring wells. The NGB will adjust the rate of groundwater
 extraction, and reinfection of treated groundwater if implemented, in a manner which ensures
 that the containment system is operating properly, and the MCLs and non-zero MCLGs are
 being  met.  Furthermore,  federal MCLs, non-zero MCLGs  and Massachusetts MCLs and
 groundwater quality standards are being used to establish cleanup goals for groundwater which
 is extracted by the containment system, treated and  reinjected.  The treatment system will be
 designed and operated to ensure that all water discharged attains these standards.

 10.2  DESCRIPTION OF THE SELECTED REMEDY

 The NGB's selected remedy includes extracting contaminated groundwater using extraction wells
 at the seven plumes, treatment of extracted groundwater, and discharge of the treated water to
 groundwater and/or other beneficial use. The selected remedy will intercept the seven plumes,
 preventing further migration of contaminants downgradient above the  MCLs and non-zero
 MCLGs. Extraction and treatment will continue until the final groundwater remedy for the site
 has been chosen.   Selection of a final ground-water remedy will depend on the results of
 comprehensive RI/FSs.  For cost estimating purposes,  it has been assumed this  interim
 containment remedy will operate for 20 years.  During this period, the NGB will also implement
 an environmental monitoring program to evaluate the effectiveness of the containment systems.
 Monitoring wells, which will serve as the points of compliance for this interim remedial action,
 will be located downgradient and to the sides of the extraction wells at each plume.  The NGB
 will adjust the rate of  groundwater extraction and the reinjection of treated groundwater, if
 implemented, in a manner which ensures that  the containment systems are operating property.
                          Installation Restoration Program

0644IA.BOZ                                10-2                              Uptmb* 1995

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                                                                      SECTION 10
                                    Table 10-1
          Federal MCLs, Federal Non-Zero MCLGs and Massachusetts MCLs
                        for Plume Contaminants of Concern
Plume -
Contaminant(s)
Arsenic
Benzene
Carbon tetrachloride (CCU)
Chromium
1,1-Dichloroethene (1,1 -DCE)
cis-l,2-Dichloroethene (cis-l,2-DCE)
trans- 1,2-Dichloroethene (trans- 1,2-
DCE)
Ethylbenzene
Ethylene dibromide (EDB)
Iron
Lead
Manganese
Tetrachloroethene (PCE)
Toluene
Trichloroethene (TCE)
Vinyl chloride
Xylenes
Federal
MCL Otg/1)
50
5
5
100
7
70
100
700
0.05
—
15
—
5
1,000
5
2
10,000
Federal Non-Zero
MCLG fog/1)
—
~
—
100
7
70
100
700
—
'
—
—
—
1,000
_
_
10,000
Massachusetts
MCL fog/1)
50
5
5
100
7
70
100
700
0.02
300
15
50
5
1,000
5
2
10,000
MCL  - Maximum Contaminant Level
MCLG - Maximum Contaminant Level Goal
jtg/1   - Micrograms per liter
Note: The maximum concentrations of contaminants of concern in the various plumes are set
      forth in the discussion relating to these plumes presented in Section 6.0 of this document.
06448A.B02
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             10-3
                                                                        September 1995

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                                                                        SECTION 10
                                      Table 10-2
                             Proposed Treatment Levels*
                              for Extracted Groundwater
CHEMICAL
Arsenic
Benzene
Carbon tetrachloride (CCLJ
Chromium
1,1-Dichloroethene (1,1-DCE)
cis-l,2-Dichloroethene (cis-l,2-DCE)
trans-l,2-Dichlorocthcne (trans- 1,2-DCE)
Ethylbenzene
Ethylene dibroraide (EDB)
Iron
Lead
Manganese
*T«ulgHUM>M
Tetrachloroethene (PCE)
Toluene
Trichloroethene (TCE)
Vinyl chloride
Xylenes
TREATMENT LEVEL (pg/1)
50
5
5
100
7
70
100
700
0.02
300
15
50
5
1,000
5
2
10,000
Mg/1 « micrograms per liter
"Treatment levels are based on federal and state MCLs appropriate for discharge of treated
 water to groundwater.
0644SA.B02
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             10-4

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                                                                         SECTION 10
 Groundwater  use within the  area  contained  will be  restricted through the imposition  of
 institutional controls.  The schedule for the final remedial action concerning these seven plumes
 will be incorporated into the Federal Facilities Agreement (FFA), an agreement for addressing
 environmental contamination at MMR entered into by the NGB, USCG, and EPA.

 Extraction of groundwater containing halogenated solvents, fuel-related compounds and several
 metals will be accomplished using a network of wells positioned across the width of the leading
 edge of each of the seven plumes and at the depths of contamination.  Additional extraction wells
 may be added in hot spot areas  for some of the plumes (i.e., at CS-10) if determined  to be
 feasible during design of the interim  remedy.  Extracted groundwater will be conveyed by
 underground double-wall piping to one or more treatment systems prior to discharge.

 Some of the solvents-contaminated groundwater extracted from the Ashumet Valley Plume may
 also contain low  concentrations of nutrients.  The nutrient contamination extends beyond the
 leading edge of the solvents portion of that plume.  Money that funds the IRP cleanup program
 [Defense Environmental Restoration  Act (DERA) funds] cannot be used solely to investigate or
 remediate nutrients since they are not "hazardous substances" under CERCLA.  The location of
 the extraction well fence, which will be determined during remedial design,  will be  located  at
 the leading edge of the solvents plume and the nutrient portion of the plume extending beyond
 that will not be addressed as part of this interim remedy. However, to the extent that nutrients
 are contained within the solvents plume, they will be contained and treated with the plume water
 to be extracted as part of the interim remedy.

 Preliminary estimates developed during preparation of the Plume Response Plan indicate that
 approximately 150 (vertical) extraction  wells spaced about 100 to 180 feet apart pumping almost
 11  million gallons per day of water from the aquifer  will be  required to contain the plumes.
 Monitoring wells downgradient and to  the sides of extraction wells will be installed to evaluate
 the effectiveness of the extraction systems.    See  Figures 6-1 through 6-7 for  proposed
 approximate locations of extraction wells and piping routes for the various plumes. The actual
 number of extraction wells, their location and pumping rates,  and the locations of monitoring
 wells and piping will be determined during the design  of the interim remedial action.

 The type(s) of treatment technologies/methods that will be utilized, and the number, capacity and
 location of treatment systems will be  determined during the early stages of design of the interim
 remedial action.  Treatment may include one or more technologies to reduce the concentration
 of inorganic compounds such  as  iron, manganese, arsenic, lead and chromium.   Iron and
 manganese, if present at high enough  concentrations,  can precipitate out in  subsequent VOC
 treatment  processes,  causing  fouling  and  reducing  treatment  efficiency.    The  treatment
 technology(s) for inorganics will  also  reduce  risk associated  with  contaminants of concern.
 Subsequent treatment  will remove VOCs prior to discharge.   Samples of influent(s)  to and
 effluent(s) from the treatment system(s) will be monitored to ensure that performance criteria
 are met and treatment efficiency is maintained.
                           Installation Restoration Program

06448A.B02                                 10-5                               September 1995

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                                                                          SECTION 10
 Treatment methods for inorganic metals and nutrients that will be evaluated during the early
 stages of design will include:  oxidation with air, peroxide, ozone, chlorine; precipitation; green
 sand filtration; flocculation; suspended solids  filtration; and clarification.   Aqueous-phase
 granular activated carbon (GAC) is a proven technology for the treatment of organics in water,
 including VOCs.  As stated in the Plume Response Plan, aqueous-phase GAC will be evaluated
 during design for the treatment of groundwater extracted from the seven plumes. Other organics
 treatment  technologies that will  be considered  during  design  will  include  ultraviolet
 light/advanced oxidation; air stripping; and aqueous-phase biotreatment (potentially applicable
 for fuel-related contaminants).   Any treatment  processes generating VOC emissions will be
 equipped with air pollution control equipment (e.g., vapor-phase activated carbon or catalytic
 oxidation).  Residual wastes generated during treatment (i.e., sludge/solids, used filter media,
 used activated carbon, regeneration liquid waste) will be shipped off site for proper management.
 Methods to minimize the volume of residual waste requiring off-site management will be utilized
 where feasible and cost effective (e.g., solids dewatering,  greens and regeneration, and vapor-
 phase carbon regeneration).

 Treated water will be discharged back to the  subsurface to minimize the impact  of water
 withdrawals on groundwater levels, possibly at locations downgradient of extraction wells.
 Recharge methods (i.e., wells, galleries, etc.) and locations will be established during design of
 the interim remedial action.  Actual locations for piping  to convey water for discharge, and
 discharge monitoring wells that will be installed in the vicinity of the  recharge systems to
 evaluate operation of the recharge system, will be determined during design.  Any beneficial use
 of the treated water will be identified during the design of the containment systems. Preliminary
 locations for groundwater extraction and recharge systems, and piping to convey water to and
 back from the treatment  systems are shown  on  the individual plume maps presented in
 Section 6.0 of this document.

 Monitoring will also be conducted to evaluate the reduction in contaminant concentrations and
 the effectiveness of the containment systems. The proposed monitoring program is described
 in more detail in  the Plume Response Plan. The monitoring program was developed for  cost
 estimating purposes as part of the Plume Response Plan effort.  The actual monitoring plan will
 be developed during the design phase and will be approved by the  appropriate regulatory
 agencies.

 To the extent required by law, the  NGB and USEPA will  review the seven plumes interim
 remedial action at least once every five years after initiation  of its operation. The review  will
 ensure that the remedial action continues to protect human health and the environment.
                           Installation Restoration Program

06448A.B02                                 10-6                               SiptMter 1995

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                                                                      SECTION 11
                      11.0 STATUTORY DETERMINATIONS
 The interim remedial action selected for the containment of seven groundwater contaminant
 plumes at MMR is consistent with CERCLA and, to the extent practicable, the NCP.  The
 selected interim remedy protects human health and the environment, attains ARARs or provides
 grounds for waiving them, and is cost-effective. The selected remedy, which is not designed
 or expected to be final, also satisfies the statutory preference for treatment that permanently and
 significantly reduces the toxicity,  mobility, or volume of hazardous substances.  Additionally,
 the selected remedy uses treatment technologies or resource recovery  technologies to the
 maximum extent practicable.

 11.1   THE SELECTED INTERIM REMEDY IS PROTECTIVE OF HUMAN HEALTH
       AND THE ENVIRONMENT

 The interim remedy for the seven groundwater contaminant plumes at MMR will reduce the
 risks posed to human health by eliminating, reducing or controlling exposures to human and
 environmental receptors through  treatment, engineering controls,  and institutional  controls.
 More specifically, this remedy will provide an increased level of protection to downgradient
 receptors by containing the groundwater plumes and treating the extracted water to the cleanup
 levels prior to discharge.  Moreover, the selected remedy will result in human exposure levels
 to downgradient receptors that are within the 10~* to 10"* incremental cancer risk range and that
 are less than the HI of 1.0 for noncarcinogens.  Moreover, the  selected interim remedy will
 provide increased protection through the imposition of institutional controls which will prohibit
 the use of groundwater within the contained areas.

 Finally, implementing the selected interim remedy will not pose unacceptable short-term risks
 or cross-media impacts. Remedial construction activities are not likely to adversely affect the
 public or MMR  personnel. Initial grading of the treatment system location and the installation
 of subsurface piping and groundwater monitoring wells are not expected to encounter or expose
 contaminants. The greatest potential concerns to the public from construction-related activities
 will be due to non-contaminated fugitive dust created during site preparation.  Ambient air
 monitoring for  respirable dust will be  conducted  during remedial  construction  activities.
 Engineering controls for dust suppression are readily available and will be implemented as
 necessary. Planning and the implementation of engineering controls will minimize impacts from
 construction on roads, traffic movement, and noise.

 11.2   THE SELECTED INTERIM REMEDY ATTAINS ARARs

 The interim remedy will attain all applicable or relevant and appropriate federal and state
 location- and action-specific requirements.  Chemical-specific ARARs will not be met within the
 contained plumes and shall be waived in accordance with CERCLA § 121(d)(4)(A). However,
 groundwater shall be monitored outside the contained areas to ensure that these standards are
                          Installation Restoration Program

06448A.B02                                11-1                              September 1995

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                                                                          SECTION 11
 met. Furthermore, all water extracted as part of the containment system, treated and reinjected
 on site, shall attain federal and state drinking water standards prior to discharge.  The ARARs
 that correspond to this interim action are presented in Tables 11-1 through 11-3.

 11 J.I        Chemical-Specific ARARs

 Chemical-specific ARARs for the interim remedy are identified in Table  11-1 and are briefly
 described below.

 Federal MCLs and non-zero MCLGs were used  to establish cleanup goals  for the interim
 remedy.  In addition, state MCLs, where more stringent than the federal  standards, and state
 groundwater quality standards were also used to set cleanup levels. These standards will not be
 attained within the areas of the plumes that will be contained.  Since this is an interim remedy,
 a waiver under CERCLA §  121(d)(4)(A) will be obtained.  Ultimately, these  ARARs will be
 attained when the final remedial action is implemented for these plumes, unless grounds for a
 waiver can be established at that time.  In addition, groundwater outside of the containment area
 will be monitored and will attain the standards.  Furthermore, all groundwater which will be
 extracted  as  part of the containment  system will be treated to meet these  levels prior to
 reinjection or other beneficial reuse.

 11.2.2        Location-Specific ARARs

 Location-specific  ARARs for the interim remedy are identified in Table 11-2  and are briefly
 described below.

 The interim remedy will comply with all  federal and state  wetlands  requirements.   These
 regulations require  that projects  undertaken in or adjacent to  wetlands be conducted so as to
 minimize  any adverse impacts.   Discharge of dredge and fill  materials is  prohibited if a
 practicable alternative exists  and any loss or damage to wetlands must be mitigated.  The well
 installation and pipe construction will be conducted so that wetlands impacts will be minimized.

 In addition, since the groundwater underlying Cape Cod has been designated as a sole source
 aquifer, the Sole Source Aquifer regulations are applicable to this interim remedy.   These
 regulations prohibit the expenditure of federal funds on any project which would contaminate
 a sole source aquifer.  The interim remedy will not result in any degradation of the aquifer and
 is expected, in fact, to result in some degree of contaminant reduction through  pump and treat
 at the leading edge of the plumes as well as possible hot spot treatment.

 11.2.3       Action-Specific ARARs

 Action-specific ARARs for the selected interim remedy  are presented in  Table 11-3 and are
 described briefly below.
                           Installation Restoration Program

0644IA.B02                                 11-2

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                                                           TABLE 11-1
                                                   CHEMICAL-SPECIFIC ARARs
                                                  Massachusetts Military Reservation
                                                  Plume Containment Interim Action
                                                    Pump and Treat Groundwater
                                                    and Inject Treated Water Back
                                                         Into Groundwater
   Media
Requirement
Requirement Synopsis
Action to be Taken to
 Attain Requirement
Basis
                        FEDERAL
Groundwater   Safe Drinking Water Act (SDWA)-
              Maximum Contaminant Levels
              (MCLs), 40CFR 141.11 -141.16
                       MCLs have been promulgated for a
                       number of common organic and
                       inorganic contaminants. These levels
                       regulate the contaminants in public
                       drinking water supplies, but may
                       also be considered relevant and
                       appropriate for groundwater aquifers
                       potentially used for drinking water.
                            The standards will not be attained within
                            the contained plumes. An interim
                            remedy waiver will be obtained in
                            accordance with CERCLA §
                            121 (d)(4)(A). Use of the containment
                            remedy will result in attainment of MCLs
                            in the groundwater at the point of
                            compliance. Pumping and treatment will
                            be performed to attain MCLs for treated
                            groundwater which is reinjected into
                            groundwater.
                              Relevant and
                              Appropriate
Groundwater   SDWA - Maximum Contaminant
              Level Goals (MCLGs), 40 CFR
              141.50-141.51
                       Non-zero MCLGs are
                       nonenforceable health goals for
                       public water systems. MCLGs are
                       set at levels that would result in no
                       known or expected adverse health
                       effects with an adequate margin of
                       safety.
                            The standards will not be attained within
                            the contained plumes. An interim
                            remedy waiver will be obtained in
                            accordance with CERCLA §
                            121(d)(4)(A). Use of the containment
                            remedy will result in attainment of non-
                            zero MCLGs in groundwater at the point
                            of compliance. Pumping and treatment
                            will be performed to attain non-zero
                            MCLGs for treated groundwater which is
                            reinjected into groundwater.
                              Relevant and
                              Appropriate
                                                                                                                                               8
                                                                                                                                               8

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                                                                     TABLE 11-1 (Coot)
                                                                CHEMICAL-SPECIFIC ARARs
                                                              MsflMK*husetts Military Reservation
                                                              Plume CoaUinmenl Interim Action
                                                                 Pump and Treat Groundwater
                                                                 and Inject Treated Water Back
                                                                      Into Groundwater
\
i
                  Media
                                  Requirement Synopsis
                                     Action to be Taken to
                                      Attain Requirement
                                       STATE
              Groundwater  MA Drinking Water Standard*,
                            310 CMR 22.00 ,
These regulations establish state
MCLs for public water systems.
If state MCLs are more stringent
than federal levels, the state
levels are used.
                                                             These standards will not be attained
                                                             within the contained plumes. An
                                                             interim remedy waiver will be
                                                             obtained in accordance with CERCLA
                                                             | 121(dX4XA).  Use of containment
                                                             remedy will result in attainment of  •
                                                             these standards in groundwater at
                                                             point of compliance. Pumping and
                                                             treatment will be performed to attain
                                                             standards for treated groundwater
                                                             which is reinjected into groundwater.
                                                                  Relevant and
                                                                  Appropriate
               Groundwater
MA Groundwater Quality
Standards. 314 CMR 6.06
These standards limit the
concentration of certain
materials allowed in classified
Massachusetts waters. The
groundwater beneath MMR has
been classified as a Class I
water or fresh groundwater
found in the saturated zone of
unconsolidated deposits and is
designated as a source of potable
water supply.
                               These standards will not be attained
                               within the contained plumes. An
                               interim remedy waiver will be
                               obtained in accordance with CERCLA
                               } 121(dX4XA).  Use of containment
                               remedy will result in attainment of
                               these standards in groundwater at
                               point of compliance. Pumping and
                               treatment will be performed to attain
                               standards for treated groundwater
                               which is reinjected into groundwater.
Applicable
                                                                                                                             8
                                                                                                                             i

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                                                                           TABLE 11-2
                                                                  LOCATION-SPECIFIC ARARs
                                                                 Massachusetts Military Reservation
                                                                 Plume Containment Interim Action
                                                                   Pump and Treat Ground water
                                                                   and Inject Treated Water Back
                                                                         Into Groundwater
                  Media
Requirement
Requirement Synopsis
Action to be Taken to
 Attain Requirement
Basis
                                       FEDERAL
                Wetlands    Wetlands Executive Order
                             (EO) 11990,
                            40 CFR Part 6, Appendix A
                         Under this order, federal agencies are
                         required to minimize the destruction,
                         loss, or degradation of wetlands, and
                         beneficial values of wetlands.
L/l
                              Appropriate federal agencies
                              identified (under this act) will be
                              contacted and allowed to review the
                              proposed work plan prior to
                              initiating the remedial activities.
                              Extraction and  monitoring wells,
                              and extraction and reinjection pipes,
                              will be placed to minimize harm to
                              wetlands to the extent possible.
                              Applicable
                Wetlands     Clean Water Act (CWA), Section
                             404 (b) (I), Guidelines for
                             Specification of Disposal Sites for
                             Dredged or Fill Material (40 CFR
                             Part 230); 33 CFR Parts 320-330
                         Contains requirements for discharge
                         of dredge or fill material, including
                         that no discharge is permitted, if there
                         is a practicable alternative to the
                         proposed discharge that would have a
                         less adverse impact on the aquatic
                         ecosystem, and that no discharge is
                         permitted unless appropriate and
                         practicable steps are taken to
                         minimize potential adverse impacts
                         on the aquatic ecosystem.
                               Remedial activities will be designed
                               to minimize potential adverse
                               effects on the aquatic ecosystem.
                              Applicable
                                                                                                                                                              C/3
                                                                                                                                                              W
                                                                                                                                                              o
                                                                                                                                                              25

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                                                       TABLE 11-2 (Coot)
                                                  LOCATION-SPECIFIC ARARs
                                                 Miittfhuaetts MilHirV Reservation
                                                 Plume Containment Interim Action
                                                   Pump and Treat Groundwater
                                                   and Inject Treated Water Back
                                                        Into Groundwater
   Media
Requirement
Requirement Synopsis
Action to be Taken to
 Attain Requirement
Basis
                           FEDERAL
Wetland!       16 USC 661 et aeq., Fish and
               Wildlife Coordination Act
                         Requires federal agencies to take
                         into consideration the effect mat
                         water-related projects will nave
                         upon fish and wildlife.  Requires
                         consultation with the U.S. Fish
                         and Wildlife Service and the state
                         to develop  measures to prevent,
                         mitigate, or compensate for
                         project-related losses to fish and
                         wildlife.
                             Actions taken will minimize
                             adverse effects.  Relevant federal
                             and state agencies will be
                             contacted to help analyze the
                             effects of remedial actions on
                             wildlife in the wetlands in and
                             around the site(s).
                             Applicable
Groundwater   SDWA Sole Source Aquifers, 40
               CFR 149
                         USEPA is authorized to designate
                         aquifers as sole source and review
                         federal financially assisted projects
                         in the area to determine the
                         project's potential to contaminate
                         the aquifer. No federal assistance
                         may be made for projects that may
                         contaminate the aquifer.
                         Conversely, federal funds may be
                         used to modify projects to ensure
                         they will not contaminate the
                         aquifer.
                             The groundwater beneath Cape
                             Cod has been designated as a sole-
                             source aquifer. TheCERCLA
                             action will not increase pre-
                             existing contamination in the
                             aquifer.
                             Applicable
                                                                                                                                             §

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                                                       TABLE ll-2(Cont)
                                                  LOCATION-SPECIFIC ARARs
                                                 Massachusetts Military Reservation
                                                 Plume Containment Interim Action
                                                   Pump and Treat Ground water
                                                   and Inject Treated Water Back
                                                         Into Groundwater
   Media
Requirement
Requirement Synopsis
Action to be Taken to
 Attain Requirement
Basis
                           STATE
Wetlands      MA Wetlands Protection
              Requirements, 310 CMR 10.00
                          These requirements control
                          regulated activities in freshwater
                          wetlands, 100-year floodplains, and
                          100-foot buffer zones beyond these
                          areas. Regulated activities include
                          virtually any construction or
                          excavation activity.  Performance
                          standards are provided for
                          evaluation of the acceptability of
                          various activities.
                              Extraction and monitoring wells will
                              be placed in, and extraction and
                              reinfection pipes will be placed
                              underground, through wetlands and
                              buffer zones. All activities will be
                              performed in compliance with the
                              performance standards of the
                              regulations. Any wetlands
                              temporarily disturbed will be
                              restored. All treatment  facilities will
                              be constructed above the 100-year
                              floodplain elevation (e.g., 48 feet
                              above sea level).
                               Applicable
                                                                                                                                               8
                                                                                                                                               i

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                                                                         TABLE 11-3
                                                                  ACTION-SPECIFIC ARARs

                                                               Plume Containment Interim Action
                                                                  Pump and Treat Groundwmter
                                                                 and Inject Treated Water Back
                                                                      Into Oroundwater
do
                   Media
         Requirement
    Requirement Synopsis
   Action to be Taken to
    Attain Requirement
   Basis
                                         FEDERAL
               Groundwater   Underground Injection Control
                              Program, 40 CFR 144, 146, 147,
                              1000
                                  These regulations outline
                                  minimum program and
                                  performance standards for
                                  underground injection
                                  programs. Technical criteria
                                  and standards for siting,
                                  operation and maintenance,
                                  closure, and reporting and
                                  recordkeeping as required for
                                  permitting are set forth in Part
                                  146.
                               Discharge of treated
                               groundwater, by well
                               injection, must be in
                               accordance with all the
                               criteria and standards in these
                               federal regulations. Treated
                               groundwater must meet all
                               SDWA standards prior to well
                               injection.
                             Applicable
                Air
Resource Conservation and
Recovery Act (RCRA), 40 CFR
264, Subpart AA
Contains air pollutant emission
standards for process vents
    ciated with distillation,
                                                                fractionation, thin-film
                                                                extraction, or air or steam
                                                                stripping operations.
                                                                Applicable to operations that
                                                                manage hazardous wastes with
                                                                organic concentrations of at
                                                                least 10 ppmv.
If air stripping is selected as a
treatment method and it
involves management of
hazardous waste with organics
of at least 10 ppm, equipment
used in remedial activities will
meet the requirements and be
monitored for compliance.
Applicable
                                                                                                                            WS
                                                                                                                            B
                                                                                                                            1

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*l
                                                         TABLE ll-3(Cont)
                                                      ACTION-SPECIFIC ARARs
                                                    Massachusetts Military Reservation
                                                    Plume Containment Interim Action
                                                      Pump and Treat Ground water
                                                      and Inject Treated Water Back
                                                          Into Ground water
Media Requirement
Requirement Synopsis
Action to be Taken to
Attain Requirement
Basis
FEDERAL
Air RCRA, 40 CFR 264, Subpart
BB
Air RCRA, 40 CFR 264, Subpart
CC
Waste RCRA, 40 CFR 264.90-
264.101 and 265.90 - 265.94,
Subpart F-Releases from Solid
Waste Management Units
Contains air pollutant emission standards
for equipment leaks at hazardous waste
TSD facilities. Contains design
specifications and requirements for
monitoring for leak detection. It is
applicable to equipment that contains or
contacts hazardous wastes with organic
concentrations of at least 10 % by weight.
Contains air pollutant emission standards
for owners and operators of TSD facilities
using tanks, surface impoundments, and
containers to manage hazardous wastes.
Specific organic emissions controls have to
be installed if the average volatile organic
concentrations are equal or greater than 100
ppmw.
General facilities requirements for
groundwater monitoring at affected facilities
and general requirements for corrective
action programs, if required, at the affected
facilities.
If groundwater treatment
involves management of
hazardous waste with organics
of at least 10 ppm, equipment
will meet the design
specifications, and will be
monitored for leaks.
These emissions control
standards will be evaluated
during remedial design and
will be installed if the average
VOC concentrations are equal
to or greater than 100 ppmw.
Groundwater monitoring will
be conducted in accordance
with these requirements.
Applicable
To Be
Considered
Relevant and
Appropriate.
                                                                                                                                wa
                                                                                                                                B
                                                                                                                                3

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                                                      TABLE ll-3(Cont)
                                                   ACTION-SPECIFIC ARARS
                                                MsfHif husetts         Reservation
                                                Plume CoaUinment Interim Action
                                                  Pump and Treat Oroundwater
                                                  and Inject Treated Water Back
                                                        Into Groundwater
 Media
Requirement
Requirement Synopsis
Action to be Taken to
 Attain Requirement
Basis
          STATE
Waste     MA Hazardous Waste
          Management Rules (HWMR),
          Management Standards for all
          Hazardous Waste Facilities, 310
          CMR 30.500
                        General facility requirements outline
                        general waste security measures,
                        inspections, and training requirements.
                                Treatment will be operated in
                                accordance with the
                                substantive portions of the
                                requirement.  All workers will
                                be properly trained.
                           Relevant and
                           Appropriate
Waste     MA HWMR, Contingency Plan,
          Emergency Procedures
          Preparedness and Prevention, 310
          CMR 30.520
                        This regulation outlines requirements for
                        safety equipment and spill control, and
                        the requirements for emergency
                        procedures to be used following
                        explosions, fires, etc.
                                One-site facilities and
                                activities will be designed and
                                operated in accordance with
                                these requirements.
                                Emergency procedures will be
                                developed and implemented in
                                accordance with these
                                requirements.  Records will
                                be maintained.
                           Relevant and
                           Appropriate
Waste     MA HWMR, Use and
          Management of Containers, 310
          CMR 30.689; Storage and
          Treatment in Tanks, 310 CMR
          30.699
                        These regulations set forth requirements
                        for use and management of containers and
                        tanks at hazardous waste facilities.
                                Packing and accumulation of    Relevant and
                                treatment sludges and other     Appropriate
                                materials will adhere to these
                                standards.
                                                                                                                                            §

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                                                       TABLE M-3(Cont)
                                                   ACTION-SPECIFIC ARARs
                                                Massachusetts Military Reservation
                                                Plume Containment Interim Action
                                                   Pump and Treat Groundwater
                                                  and Inject Treated Water Back
                                                         Into Groundwater
 Media
Requirement
Requirement Synopsis
Action to be Taken to
 Attain Requirement
Basis
          STATE
Waste     MA HWMR, Requirements for
          Generators, 310 CMR 30.300
                        These regulations contain requirements
                        for generators, including testing of wastes
                        to determine if they are hazardous wastes
                        and accumulation of hazardous waste
                        prior to off-site disposal.
                                 Waste from the treatment
                                 plant will be tested to
                                 determine if it is a hazardous
                                 waste.  When a hazardous
                                 waste or residual waste is
                                 moved, the generators
                                 requirements will be complied
                                 with.
                           Relevant and
                           Appropriate
Waste     MA HWMR - Location Standards
          for Facilities,
          310 CMR 30.700-30.707
                        Under these standards, a new hazardous
                        waste facility may not be located in an
                        area subject to flooding; within the
                        watershed of a Class A or Class SA
                        segment of the surface water body unless
                        it is determined that there is no feasible
                        alternative; on land overlying an actual,
                        planned, or potential public or private
                        drinking water source; or in the flowpath
                        of groundwater supplying water to an
                        existing well.  In addition, there shall be
                        a minimum of 300 feet from the active
                        portion of the facility to the facility
                        property line.
                                 The treatment facilities will be
                                 located in compliance with
                                 these regulations.
                           Applicable

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                                                                    TABLE 11-3 (Cool)
                                                                 ACTION-SPECIFIC ARARs
                                                              Plume Containment Interim Action
                                                                Pump and Treat Groundwafer
                                                                and Inject Treated Water Back
                                                                     Into Groundwater
                  Media
                                   Requirement Synopsis
                                         Action to be Taken to
                                          Attain Requirement
                             STATE
               Waste          MA Hazardous; Wastewater
                              Treatment Regulations, 314
                              CMR8.00
K>
                           These regulations apply to wastewater
                           treatment works (including RCRA
                           wastewater treatment units) that store,
                           treat, or dispose of hazardous wastes
                           generated at the same site and which are
                           exempted from MA HWMR. These
                           regulations require the treatment works
                           to meet specified management and
                           technical standards.
                                     The wastewater treatment        Relevant and
                                     facility will be designed and      Appropriate
                                     managed in accordance with
                                     these requirements.
               Groundwater    MA Groundwater Discharge
                              Permits, 314 CMR 5.00
                           These regulations set effluent limits for
                           the discharge of pollutants to
                           groundwater.
                                      Discharge of treated water to
                                      groundwater would comply
                                      with the substantive
                                      requirements of these
                                      regulations.
                              Applicable
               Groundwater
MA • Water Resources
Management Program •
Withdrawal Permit
Requirements,
310 CMR 36.00
These regulations require registration of
groundwater or surface water
withdrawals greater than 100,000
gallons per day in order to enable the
MADEP to document baseline water use
and begin comprehensive management
of surface and groundwater in the state.
Design activities will determine  the
extraction flow utilized.
Since the extraction of
groundwater for the purposes of
treatment is a non-consumptive
use and the groundwater will be
reinjected, it is exempt from
the requirements of this
regulation under 310 CMR
36.05.
Applicable
                                                                                                                                                       8
                                                                                                                                                       I

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00
      TABLE II-3 (Cent)
   ACTION-SPECIFIC ARARs
Massachusetts Military Reservation
Plume Containment Interim Action
   Pump and Treat Groundwater
  and Inject Treated Water Back
       Into Groundwater
Media
Requirement
Requirement Synopsis
Action to be Taken to
Attain Requirement
Basis
STATE
Groundwater
Groundwater
Groundwater
MA HWMR Groundwater
Protection,
310 CMR 30.660-30.679
MA Underground Injection
Control Regulations,
3 10 CMR 27.00
MA Standards for Analytical
Data for Remedial Response
Action, Bureau of Waste Site
Cleanup Policy 300-89
These regulations require
groundwater monitoring at specified
regulated units that treat, store or
dispose of hazardous waste.
Maximum concentration limits for the
hazardous constituents are specified
in 3 10 CMR 30.668
These regulations prohibit the
injection of hazardous wastes into
groundwater in order to protect
underground sources of drinking
water.
This policy describes the minimum
standards for analytical data
submitted to the MADEP.
Groundwater monitoring will
be conducted as a component
of the remedy.
The treated groundwater will
attain MCLs and non-zero
MCLGs and the injection into
groundwater will be a
permitted activity under
310 CMR 27.05
All sampling plans will be
designed with consideration of
the analytical methods
provided in this policy.
Relevant and
Appropriate
Applicable
To Be
Considered
                                                                                                                                                  Cfi
                                                                                                                                                  8
                                                                                                                                                  i

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      TABLE 11-3 (Cool)
  ACTION-SPECIFIC ARARs
                       vo
Plume Containment Interim Action
  Pump and Treat Groundwater
  and Inject Treated Water Back
      Into Groundwater
MCQM Rcfjuiraiidit


Action to be Taken to
Attain Requirement
Basis
STATE
Air MA Air Pollution Control
Regulations,
310CMR7.00
Establishes the standards and requirements
for air pollution control in the
Commonwealth. Section 7.02 provides
emissions limitations from specified
facilities and operations and requires
BACT. Sections 7.09 (Dust, Odor,
Construction and Demolition), 7. 10
(Noise), and 7.18 (Volatile Organic
Compounds, or VOCs) contain
requirements relevant to this action.
Dust and noise
emissions will be
managed during
construction activities.
VOC emissions will be
managed through
engineering controls
during treatment
activities.
Applicable
FEDERAL
Air USEPA Policy on Control of
Air Emissions from Superfund
Air Strippers at Superfund
Groundwater Sites, Office of
Solid Waste and Emergency
Response (OSWER) Directive
9355.0-28
Air USEPA New England Region
memorandum, 12 Jury 1989
from Louis Gitto to Merril S.
nobman
Provides guidance on the control of air
emissions from air strippers used at
Sunerfuiui mtefl flnd dictinouiilMs heftwMn
requirements for attainment and

Stales that Superfund air strippers in ozone
nonattainment areas generally merit
controls on all VOC emissions.
If air stripper is used for
groundwater treatment,
controls on air stripper
will be used as
necessary to attain state
ARARs criteria and
guidance.
Remedial actions,
including air strippers.
will include controls to
reduce VOC emissions.
To Be
Considered
To Be
Considered
                                                                                   Cfl

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                                                                         SECTION 11
 Air Regulations - Federal emissions standards have been established under RCRA to control
 emissions from pollution control equipment. The treatment facility will be monitored to ensure
 that these emission standards are met.  State emissions standards are established in the state Air
 Pollution Control Regulations.  Relevant provisions regulate the  emission of dust, noise and
 VOCs. The construction of wells, piping and the treatment facilities will be conducted to ensure
 that dust and noise emissions are  controlled.  In addition, the water treatment facility will be
 designed and monitored to ensure that VOC emissions do not exceed the standards.

 Groundwater Regulations -  Federal and state underground injection  control regulations are
 applicable to the interim  remedy since treated groundwater will be  reinjected  on site.  In
 addition, other pertinent state regulations include effluent discharge limitations, groundwater
 withdrawal limitations and monitoring requirements.  These requirements  will be adhered to
 during the design,  construction and operation of the  extraction, treatment and reinjection
 systems.

 Hazardous Waste Regulations - Since the groundwater being extracted will be treated to remove
 contaminants, the treatment process  may generate hazardous waste which must be managed in
 accordance with hazardous waste requirements. The Resource Conservation and Recovery Act
 (RCRA) Subtitle C program has been delegated to the State of Massachusetts and therefore the
 state Hazardous Waste Management Rules contain the operable requirements for this interim
 remedy.   Such  requirements include generator requirements;  management  standards;  rules
 governing use and management of containers  and  storage and treatment in tanks; emergency
 procedures; and location standards.   In addition,  Massachusetts has  specific Hazardous
 Wastewater Treatment Regulations which require wastewater treatment units to meet specified
 management and technical standards.  Finally, RCRA Subpart F, which  contains general facility
 requirements for groundwater monitoring and corrective action, is a relevant and appropriate
 requirement.  The treatment facility will be designed and  operated to comply with all hazardous
 waste requirements and monitoring will be conducted as required. It should be noted that while
 the requirements governing  transportation and  disposal of hazardous waste which may be
 generated through the treatment process are not ARARs  since they apply to off-site activities,
 the NGB will ensure that shipment and disposal of any hazardous  wastes will be conducted in
 accordance with all applicable federal and state laws and regulations.

 11.3   THE SELECTED INTERIM REMEDIAL ACTION IS COST EFFECTIVE

 In the NGB's judgment, the selected remedy is cost effective (i.e., the  remedy affords overall
 effectiveness proportional to its costs).  Once the NGB identified an alternative that would be
 protective of human health and the environment  and that would attain ARARs,  the NGB
 evaluated  the overall effectiveness  of the plume containment alternative and the no action
 alternative by assessing the three relevant criteria, in combination:
                           Installation Restoration Program

06448A.B02                                11-15                              September 1995

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                                                                      SECTION 11
       •     reduction in toxicity, mobility, and volume through treatment
       •     short-term effectiveness
       •     long-term effectiveness and permanence

 The selected remedy is ultimately  expected to be more  cost effective than  the no-action
 alternative. Containment is anticipated to be part of the final remedy for the plumes.  However,
 the groundwater extraction, treatment and reinjection system used to contain the plumes will be
 smaller and less  extensive if implemented earlier, as an interim remedy.  Implementing the
 selected remedy as an interim remedial action will also protect drinking water supplies, which
 would be degraded under the no-action alternative. The costs of this interim remedial alternative
 are presented in Section 8.2.

 11.4   THE SELECTED INTERIM REMEDY  UTILIZES PERMANENT SOLUTIONS
       AND   ALTERNATIVE   TREATMENT   OR   RESOURCE  RECOVERY
       TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

 The NGB selected the alternative which uses permanent solutions and alternative treatment
 technologies or resource recovery technologies to  the maximum extent practicable.   The
 determination was made by identifying an alternative that provides the best balance of trade-offs
 in terms of the following criteria:

             long-term effectiveness and permanence
             reduction of toxicity, mobility, or volume through treatment
             short-term effectiveness
             implementabilhy
             cost

 The balancing test emphasized  long-term effectiveness,  permanence, and the  reduction of
 toxicity, mobility, and volume through treatment.   This  interim test  also 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 between the two alternatives, given the limited scope of the interim action
 selected.  Consideration of long-term effectiveness  does not apply due to the interim nature of
 the selected remedy.  The selected  remedy will achieve reduction of toxicity, mobility, or
 volume through treatment of extracted groundwater, thereby reducing migration of contaminants.
 The selected  interim remedy would have  no  implementation difficulties.   The treatment
 technologies that  will be used are demonstrated and the equipment  is readily available. The
 selected remedy will  achieve the goals of the interim action, that is, reduction of contaminant
 migration and collection of further data to characterize the seven groundwater plumes for use
 in selecting the final remedy.
                          Installation Restoration Program

0644IA.B02                               11-16                             SfptMdMr 1995

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                                                                  SECTION 11
 11.5   THE SELECTED INTERIM REMEDY SATISFIES THE PREFERENCE  FOR
       TREATMENT WHICH PERMANENTLY AND SIGNIFICANTLY REDUCES THE
       TOXICITY, MOBILITY, OR VOLUME OF THE HAZARDOUS SUBSTANCES
       AS A PRINCIPAL ELEMENT

 A significant component of the selected remedy is the extraction and treatment of groundwater
 at the leading edge of the contaminated groundwater plumes, and the subsequent discharge of
 treated water to the groundwater.  This element addresses the primary exposure pathway for
 those plumes; contamination  of groundwater.  The selected  remedy satisfies the statutory
 preference for reduction in the mobility, toxicity, or volume to the extent possible in light of its
 limited scope by extracting and treating contaminated groundwater and preventing its further
 movement to downgradient areas.  This interim ROD will be  followed by a final ROD that will
 determine what further action, if any, will be necessary to meet the preference for treatment that
 will permanently  and significantly reduce the  mobility, toxicity, or volume  of hazardous
 substances.
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                                                                      SECTION 11
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                                                                       SECTION 12
             12.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES
 The NGB presented a Proposed Plan for remediation of the seven groundwater plumes in
 February and March, 1995 (See Section 4.0).  The preferred alternative included extraction of
 contaminated groundwater, treatment of the collected groundwater, and discharge of the treated
 water back to the groundwater or other beneficial use.  There have been no significant changes
 made to the plan  as stated  in  the Proposed Plan of February 1, 1995 (Stone &  Webster
 Environmental Technology & Services).
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                                                                       SECTION 12
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                                                                       SECTION 13
                                 13.0  STATE ROLE
 The MADEP, on behalf of the Commonwealth of Massachusetts, reviewed the alternatives and
 has indicated its support for the selected interim remedy.  The MADEP was fully involved in
 the development of the Plume Response Plan which is the basis for this proposed action.  The
 MADEP concurs with the selected proposed action for the seven groundwater plumes described
 in this ROD. A copy of the State's declaration of concurrence is presented in Appendix B.
                          Installation Restoration Program

06448A.B02                                13-1                              September 1995

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                                                                        SECTION 13
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0644JA.B02                                13-2                               S*pMmb«r 1995

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                                                                    REFERENCES
                                  REFERENCES
 ABB Environmental Services, Inc., 1992. Portland, Maine "Groundwater Remediation Strategy
 Report"; Installation Restoration Program, Massachusetts Military Reservation; prepared for
 HAZWRAP; Oak Ridge, Tennessee; October 1992.

 ABB Environmental Services, Inc.,  1993.   Portland,  Maine "Record of Decision  Interim
 Remedial Action, Main Base Landfill (AOC LF-1) Source Area Operable Unit"; Installation
 Restoration Program; Massachusetts Military Reservation; prepared for HAZWRAP; Oak Ridge,
 Tennessee; January 1993.

 ABB Environmental Services, Inc.,  1993a.  Portland, Maine "Draft Remedial Investigation,
 Stormwater Drainage Disposal Site No. 5 (SD-5) Including Fuel Spill No. 5 (FS-5), (AOC
 SD-5/FS-5); Installation Restoration Program; Massachusetts Military Reservation; prepared for
 HAZWRAP; Oak Ridge, Tennessee; January 1992; Revised November 1993.

 ABB Environmental Services, Inc.  1994.   Portland, Maine "Southeast Region  Groundwater
 Operable Unit Remedial Investigation Report (Including Region 10)"; Installation Restoration
 Program; Massachusetts Military Reservation; prepared for HAZWRAP; Oak Ridge, Tennessee;
 August 1994.

 ABB Environmental Services, Inc., 1995.  "Draft Ashumet Valley Groundwater Operable Unit
 Remedial Investigation  Report"; Installation Restoration Progress; Massachusetts Military
 Reservation; prepared for HAZRAP; Oak Ridge, Tennessee; April 1995.

 Advanced Sciences,  Inc.,  1993.    "Draft  Remedial  Investigation  Report;  Remedial
 Investigation/Feasibility Study.    FS-12  Study Area"; Installation   Restoration  Program;
 Massachusetts  Military Reservation; prepared for HAZWRAP;  Oak  Ridge, Tennessee;
 December 1993.

 CDM Federal Programs Corp.,  1993.  Boston, Massachusetts  "Draft Remedial  Investigation
 Report;  AOC CS-10/Groundwater  Operable  Unit and Hydrogeological Region U  Study";
 Installation Restoration Program; Massachusetts Military Reservation; prepared for HAZWRAP;
 Oak Ridge, Tennessee; November 1993.

 CDM Federal Programs Corp.," 1994.  Boston, Massachusetts  "Draft Remedial  Investigation
 Report, Main Base Landfill (AOC LF-1) and Hydrogeological Region I  Study"; Installation
 Restoration Program; Massachusetts Military Reservation; prepared for HAZWRAP; Oak Ridge,
 Tennessee; May 1994.
                          Installation Restoration Program

06448A.B02                                                                 September 1995

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 CDM Federal Programs Corp., 1994a.  Boston, Massachusetts "Draft Remedial Investigation
 Report, Area of Contamination SD-4"; Installation Restoration Program; Massachusetts Military
 Reservation; prepared for HAZWRAP; Oak Ridge, Tennessee; September 1994.

 E. C. Jordan Co., 1986.  Portland, Maine "U. S. Air Force Installation Restoration Program,
 Phase I: Records Search, Air National Guard, Camp Edwards, U. S. Air Force, and Veterans
 Administration Facilities at Massachusetts Military  Reservation, Task 6"; prepared  for Oak
 Ridge National Laboratory; Oak Ridge, Tennessee; December 11, 1986.

 E.  C. Jordan Co.,  1987.   Portland, Maine "Task 3-1  Water Supply  Study"; Installation
 Restoration Program; Massachusetts Military Reservation; prepared for HAZWRAP; Oak Ridge,
 Tennessee; April IS, 1987.

 E. C. Jordan Co., 1990. Portland, Maine "Task 2-3B Site Inspection, Field Investigation Work
 Conducted Spring - Summer 1988 ; Installation Restoration Program; Massachusetts Military
 Reservation; prepared for HAZWRAP; Oak Ridge, Tennessee; February 1990.

 E. C. Jordan Co., 1990a.   Portland, Maine "Site Inspection Report; Field Installation Work
 Conducted Spring - Summer 1988; Task 2-3B"; Installation Restoration Program; Massachusetts
 Military Reservation; prepared for HAZWRAP; Oak Ridge, Tennessee; February 1990.

 E. C. Jordan Co., 19906.  Portland, Maine "Technical Report, Study Area FS-25"; Installation
 Restoration Program; Massachusetts Military Reservation; prepared for HAZWRAP; Oak Ridge,
 Tennessee; August 1990.

 E. C. Jordan Co., 1991. Portland, Maine "Technical Memorandum, Johns Pond Groundwater
 Underflow Study, Interim  Report"; Installation Restoration Program; Massachusetts Military
 Reservation; prepared for HAZWRAP; Oak Ridge, Tennessee; January 1991.

 E. C. Jordan Co., 1991a.  Portland, Maine "Draft Phase I of Ashumet Valley Groundwater
 Supply"; Installation Restoration Program; Massachusetts Military Reservation; prepared for
 HAZWRAP; Oak Ridge, Tennessee; March 1991.

 HAZWRAP, 1994.  "Comprehensive Plan"; Massachusetts Military Reservation; Oak Ridge,
 Tennessee; August 1994.

 Operational Technologies Corp.,  1994.  San Antonio, Texas "Plume Response Plan (PRP);
 Installation Restoration Program; Massachusetts Military Reservation; prepared  for the Plume
 Management Process Action Team; June 1994.

 R. F. Weston, Inc., 1985.  "Installation Restoration  Program Phase n, Stage I, Confirmation
 Qualification"; Otis Air National Guard Base, Massachusetts; prepared for the U. S. Air Force
 Occupational and Environmental Health laboratory; October 1985.
                         Installation Restoration Program

0644IA.K2

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                                                                    REFERENCES
 Stone & Webster Environmental Technology and Services, 1995.  "Proposed Plan for Interim
 Action, Containment of Seven  Groundwater  Plumes;" Massachusetts  Military  Reservation;
 prepared for the Air National Guard Readiness Center, Andrews  Air Force Base, Maryland;
 February 1995.

 U. S.  Environmental  Protection Agency (USEPA), 1989.   "National  Priorities  List  of
 Uncontrolled Hazardous Waste Sites, Final Rule"; 40 CFR Part 300; Federal Register, Vol. 54,
 No. 223; p. 48187; November 21, 1989.
                          Installation Restoration Program

06448A.B02                                                                 September 1995

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                                                                   REFERENCES
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0644SA.B02                                                  '              3*pM*«r 1995

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                             GLOSSARY OF ACRONYMS AND ABBREVIATIONS
               GLOSSARY OF ACRONYMS AND ABBREVIATIONS
 AEHA
 ANG
 ARAR
 ARNG
 AVGAS
 BOMARC
 CO,
 CFR
 CERCLA

 CMR
 CS
 DCE
 DERA
 DoD
 DPDO
 EDB
 EO
 FFA
 FR
 FS
 FTA
 HWMR
 IRP
 LF
 MA
 MADEP
Anny Environmental Hygiene Agency
Air National Guard
Applicable or Relevant and Appropriate Requirements
Army National Guard
Aviation Gasoline
Boeing Michigan Aerospace Research Center
Carbon Tetrachloride
Code of Federal Regulations
Comprehensive Environmental Response Compensation and
Liability Act
Code of Massachusetts Regulations
Chemical Spill
Dichloroethene
Defense Environmental Restoration Act
Department of Defense
Defense Property Disposal Office
Ethylene Dibromide
Executive Order
Federal Facility Agreement
Federal Register
Fuel Spill
Fire Training Area
Hazardous Waste Management Rules
Installation Restoration Program
Landfill
Massachusetts
Massachusetts Department of Environmental Protection
                        Installation Restoration Program
06448A.B02
                                           September 1995

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                              GLOSSARY OF ACRONYMS AND ABBREVIATIONS
  MCL
  MCLG
  MCP
  MMR
  MOGAS
  NCP
  NDIL

  NPL
  OSWER
  PAH
  PAT
  PCE
  PFSA
  PPM
  PPMV
  RCRA
  RI
  RI/FS
  ROD
  SD
  SDWA
  SERGOU
  SI
  STP
  SVOC
 TCE
 Maximum Contaminant Level
 Maximum Contaminant Level Goal
 Massachusetts Contingency Plan
 Massachusetts Military Reservation
 Motor Vehicle Gasoline
 Micrograms Per Liter
 National Contingency Plan
 Non-Destructive Inspection Laboratory
 National Guard Bureau
 National Priorities List
 Office of Solid Waste and Emergency Response
 Polynuclear Aromatic Hydrocarbon
 Process Action Team
 Tetrachloroethene
 Petrol Fuel Storage Area
 Parts per Million
 Parts per Million by Volume
 Resource Conservation and Recovery Act
 Remedial Investigation
 Remedial Investigation/Feasibility Study
 Record of Decision
 Storm Drain
 Safe Drinking Water Act
 Southeast Regional Groundwater Operable Unit
 Site Inspection
 Sewage Treatment Plant
 Semi-volatile Organic Compound
Trichloroethene
                         Installation Restoration Program
0644SA.B02

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                             GLOSSARY OF ACRONYMS AND ABBREVIATIONS
  TIC                     Tentatively Identified Compound
  TSD                     Treatment, Storage or Disposal
  U.S.                     United States
  USAF                   U. S. Air Force
  USEPA                  U. S. Environmental Protection Agency
  UST                     Underground Storage Tank
  UTES                   Unit Training Equipment Site
  VOC                     Volatile Organic Compound
                        Installation Restoration Program
06448A.B02                                                             September 1995

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                           GLOSSARY OF ACRONYMS AND ABBREVIATIONS
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0644SA.B02                                                          fepttotar 1993

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                                               GLOSSARY OF TECHNICAL TERMS
                        GLOSSARY OF TECHNICAL TERMS
Administrative Record: A file established and maintained in compliance with Section 113(K) of
CERCLA consisting of information upon which the lead agency bases its final decisions on the
selection of clean-up method(s) for a Supeifund site.  The Administrative Record  should be
established at or near the site and made available to the public.

Administrative Record Index: A list of all documents contained in the Administrative Record.

Air Sparging:  The injection of an uncontaminated gaseous  medium (typically air) below or
within an area of contamination below the water table to enhance the transfer of volatile organic
compounds (VOCs) into their gaseous phase in soil above the water table.  A vapor extraction
system is frequently used in conjunction with air sparging to remove the VOCs from soil above
the water table.

Applicable or Relevant and Appropriate Requirements (ARAJRs):  ARARs include any state or
federal statute or regulation that pertains to protection of human health and the environment in
addressing certain site conditions or using a particular clean-up technology at a Superfund site.
A state law to  preserve wetland areas is  an example of  an  ARAR.  USEPA must consider
whether a remedial alternative meets  ARARs as part of the process for selecting a clean-up
alternative for a Superfund site.

Aquifer:  A layer of bedrock or soil that can supply usable quantities of groundwater to wells
and springs. Aquifers can be a source of drinking water and provide water for other uses.

Baseline:  Existing conditions and their relative consequences if no further action is taken.

Catalytic Oxidation: A process that thermally  destroys organic contaminants in the gaseous
phase where the reactions are accelerated using a compound that is not consumed in the chemical
reaction.

Chlorinated Solvent: A substance  containing chlorine, generally used to  dissolve another
substance to form a uniformly dispersed mixture (solution).

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):  A federal
law passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization
Act.  The act created a special tax that goes into a trust fund, commonly known as Superfund,
to investigate and  clean up abandoned or uncontrolled hazardous waste sites.  Under the
program,  USEPA  can  either  (l)pay  for  site cleanup  when  parties responsible for  the
contamination cannot be located or are unwilling or unable to perform the work; or (2) take legal
action to force parties responsible for site contamination to clean up the site or pay back the
federal government for the cost of the cleanup.
                           Installation Restoration Program

06448A.B02                                                                   September 1995

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                                                GLOSSARY OF TECHNICAL TERMS
 Contamination: The state of one or more substances introduced into air, water, soil or other
 media which has the effect of making those media toxic or otherwise harmful.

 Contamination Assessment: A general  term for the evaluation of the nature and extent of
 contamination.

 Downgradient:  The direction in which groundwater flows.

 Drainage Swale: A low area of land used to direct storm-water runoff away from a source area.

 Dry Well:  Subsurface structure, generally  located above  the  water, used  to  facilitate the
 discharge/disposal of liquid wastes.

 Effluent:  The outflow or discharge  of liquid wastewater from a treatment system.

 Feasibility Study (FS): A report that summarizes the development and  analysis of remedial
 alternatives that USEPA considers for the cleanup of Superfund  sites.

 Flightline:  A parking and servicing area for aircraft, and the air or space along which aircraft
 are intended to travel.

 Free Product:  Residual organic contamination in soil and aquifer systems which can serve as
 an on-going source of groundwater contamination.

 Groundwater:  Water found beneath the earth's surface that  fills pores between materials such
 as sand, soil, gravel, and cracks in bedrock, and  often serves as a principal source of drinking
 water.

 Halogenated Solvent: A  class  of compounds containing halogens  (i.e., chlorine, fluorine,
 bromine or iodine) generally used to dissolve another substance to form a uniformly dispersed
 mixture (solution).

 Inorganic: A chemical compound that does not contain the element carbon with the exception
 of oxides of carbon and various carbonates (e.g., calcium carbonate and carbon  disulfide).
 Metals and nutrients are inorganic compounds.

 In situ: In the original place.

 Influent:  The inflow  of a liquid wastewater to  a treatment process to  reduce contaminant
 concentrations.

 Interim Remedial  Action: An  option  evaluated to address the source or  migration  of
 contaminants at a Superrund site to  control or prevent further migration.  This action is not
                           Installation Restoration Program

0644SA.BQ2                                                        '            Stpumbw 1995

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                                               GLOSSARY OF TECHNICAL TERMS
 intended to be the final remedy for the site, but must be consistent with the ultimate remedy
 chosen.

 Landfill Cell: An area within a landfill where waste disposal occurs or occurred, physically
 segregated from other waste disposal activities.

 Maximum Contaminant Level (MCL):  The maximum permissible level of a contaminant in water
 that is consumed as drinking water. These levels are determined by USEPA and are applicable
 to all public water supplies. The Commonwealth of Massachusetts also has MCLs for drinking
 water.

 Maximum Contaminant Level Goal (MCLG): The maximum level of a contaminant in drinking
 water at which no known or anticipated adverse effect on human health would occur, and which
 allows an adequate margin of safety.

 Micrograms Per Liter (pg/L):  A unit of measurement used to describe levels of contamination
 in water.  One pg/L is equal to one millionth of a gram  of contaminant per liter of water.  The
      is also known as a part per billion.
Monitoring  Well:  A  well  installed in the area of contamination that   is  used to obtain
ground water samples.

National Oil and Hazardous Substances Pollution Contingency Plan, commonly referred to as
the National Contingency Plan (NCP): The federal regulation that guides determination of the
sites to be corrected under the Superfund program and the program to prevent or control spills
into the surface waters or other portions of the environment.

National Priorities List (NPL):  USEPA's list of the most serious uncontrolled or abandoned
hazardous waste sites identified for possible long-term remedial action under Superfund.

Net Present  Worth:  The amount of money necessary to secure the promise of future payment,
or series of payments, at an assumed interest rate.

Operable Unit: A discrete action that comprises an incremental step(s) toward  a final remedy.
Operable units may address geographic portions of a site, specific site problems, or the initial
phase of an  action.

Organic: Any substance that contains the element carbon, except oxides of carbon and various
carbonates.  Chlorinated solvents and fuels are made of one or more organic compounds.

Plume:  A three-dimensional  zone within  the groundwater  that contains contaminants and
generally moves in the direction of, and with, groundwater flow.
                           Installation Restoration Program

06448A.B02                                                                   September 1995

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                                               GLOSSARY OF TECHNICAL TERMS
 Plume Response Plan: A report presenting the results of an evaluation of remedial alternatives
 for containment of seven groundwater plumes, prepared by the Plume Management Process
 Action Team.

 Polynuclear Aromatic Hydrocarbons (PAHs):  A class  of semi-volatile organic compounds
 containing at least four closed carbon rings, derived principally from petroleum, coal tar and
 vegetable sources.

 Precipitate: To separate a substance out of a solution as particles by gravity, and resulting from
 a chemical reaction.

 Recharge: To place water withdrawn from the subsurface back into the subsurface.

 Record of Decision (ROD):  A public document that explains the cleanup alternative to be used
 at an NFL site.  The ROD is based on information gathered and technical analyses performed
 during site investigations, RI/FS  and/or other similar studies, and on consideration  of public
 comments and community concerns.

 Remedial Alternative: Option evaluated by  NGB to address the source and/or  migration of
 contaminants at a Superfund site to meet health-based cleanup goals.

 Remedial Investigation/Feasibility Study (RI/FS): The RI determines the nature, extent, and
 composition of contamination at a hazardous waste site, and directs the types of cleanup options
 which are developed and evaluated in an FS.

 Risk Assessment: Evaluation and estimation of the current and future potential for adverse
 human health or environmental effects due to exposure to contaminants.

 Semi-volatile Organic Compounds (SVOCs): A  group  of  chemical  compounds having a
 molecular weight greater than 100.  These compounds are  heavier than and generally  less
 volatile than VOCs. Some SVOCs are believed to cause cancer.

 Solvents:  Liquids capable of dissolving other liquids or solids to form  a solution. The chief
 uses of industrial solvents are as cleaners and degreasers.  Solvents also are used in paints and
 Pharmaceuticals.  Solvents used in foundries and other industrial applications are frequently
 VOCs.  Many solvents arc flammable and toxic to varying degrees.

 Source: Area at a hazardous waste site from which contamination originates.

 Sparging: The process of promoting aeration that promotes the volatization or  stripping of
 volatile organic compounds from an aquifer into the vadose zone.
                           Installation Restoration Program

0644SA.BD2                                                                   StptamlMr 1995

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                                             GLOSSARY OF TECHNICAL TERMS
 Superfund: Name given to the nation's environmental trust fund established under the authority
 of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), and
 also used to refer to CERCA or sites regulated by CERCLA.

 Tentatively-Identified Compound:  Provisional identification of a compound for which specific
 chemical analyses have not been performed.

 Time-Critical Removal Action: A CERCLA remedial action, initiated within six months of
 approval, that abates a hazard which, if not addressed,  could adversely affect human health or
 the environment.

 Vapor Extraction: The process of withdrawing soil vapor containing volatile organic compounds
 (VOCs) to prevent the subsurface migration of vapors, and/or to reduce the concentration of
 VOCs in soil above the water table.

 Volatile Organic Compounds (VOCs): A group of chemical compounds composed primarily of
 carbon and hydrogen characterized by their tendency to  evaporate (or volatize) into the air from
 water or soil.  VOCs include substances that are contained in common solvents and cleaning
 fluids. Some VOCs are known to cause cancer.
                         Installation Restoration Program

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                                           GLOSSARY OF TECHNICAL TERMS
                          [This page intentionally blank]
                        Installation Restoration Program




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                               APPENDIX A




                     ADMINISTRATIVE RECORD INDEX
                       Installation Restoration Program




06448 A.B02                                              •            September 1995

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                                                                 APPENDIX A
                 MASSACHUSETTS MILITARY RESERVATION
                      ADMINISTRATIVE RECORD INDEX
                    FOR INTERIM ACTION CONTAINMENT
                     OF SEVEN GROUNDWATER PLUMES

 SECTION 1. The Administrative Record for this action identifies all pertinent documents that
 were considered by the National Guard Bureau, the U.S. Environmental Protection Agency and
 the Massachusetts Department of Environmental Protection before deciding on a preferred
 alternative for Containment of Seven Groundwater Plumes which is outlined in the Record of
 Decision.

 SECTION 2. Minutes of Plume Management Process Action Team Meetings

      *  October 28, 1993             * April 28, 1994
      *  November 17, 1993           * May 5, 1994
      *  December 9, 1993            * May 12, 1994
      *  December 23, 1993           * June 6, 1994
      *  January 12, 1994             * June 21, 1994
      *  January 28, 1994             * August 11,  1994
      *  February 3, 1994             * August 18,  1994
      *  February 10, 1994            * September 20, 1994
      *  February 17, 1994            * October 11, 1994
      *  February 24, 1994            * October 20, 1994
      *  March 10, 1994              * November 15, 1994
      *  March 30, 1994              * November 30, 1994
      *  April 6, 1994                * December 5, 1994
      *  April 14, 1994                * January 5, 1995
      *  April 20, 1994                * February 2, 1995
      *  November 1, 1994            * March 8, 1995
      *  November 9, 1994            * April 13, 1995

 SECTION 3.  Minutes of Senior Management Board Meetings

      *  November 18, 1993           * September 8, 1994
      *  December 29, 1993  .          * October 25, 1994
      *  March 16, 1994              * January 18, 1995
      *  April 14, 1994                * March 23, 1995
      *  May 18, 1994                * May 11, 1995
      *  June 15, 1994                * July 6, 1995
      *  July 28, 1994
                        Installation Restoration Program

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                                                              APPENDIX A
 SECTION 4.  Minutes and Handout of Technical Environmental Affairs Committee
 Meetings
      *  April 7, 1993
      *  June 9, 1993
      *  September 1, 1993
      *  November 3, 1993
      *  January 19, 1994
      *  March  16, 1994
      *  May 18, 1994

 SECTIONS.  Technical Reports by Site
July 13, 1994
September 28, 1994
November 16, 1994
January 18, 1995
March 22, 1995
May 24, 1995
July 12, 1995
 1.    SITE:    AREA  OF  CONTAMINATION  MAIN  BASE  LANDFILL  (LF-1)
      GROUNDWATER OPERABLE UNIT (LF-1 GROUNDWATER PLUME)

      *     Remedial Investigation Main Base Landfill (AOC LF-1) and Hydrogeologic
            Region Study, Volumes I, n, JH, DRAFT, May 1994
      *     Remedial Investigation Main Base Landfill (AOC LF-1) and Hydrogeologic
            Regions Study, Volumes I, n, HI, IV, Revised Draft, April 1995

2.    SITE: AREAS OF CONTAMINATION STORM DRAIN 5 (SD-5), LANDFILL 2 (LF-
      2), FORMER FIRE TRAINING AREA 2  (FTA-2), AND NON-DETERMINED
      SOURCE AREAS GROUNDWATER OPERABLE UNITS (WESTERN AQUAFARM
      GROUNDWATER PLUME, SD-5 GROUNDWATER PLUME AND EASTERN.
      BRIARWOOD PLUME)

      *     DRAFT Interim Remedial Investigation Report, Fire-Training Area No. 2, (FTA-
            2) and Landfill No. 2 (LF-2), April 1992
      *     Remedial Investigation Report, Stonnwater Drainage Disposal Site No. 5 (SD-5),
            Including Fuel Spill No. 5 (FS-5), AOC SD-5/FS-5, Volumes I and n, January
            1992, Revised to Include Supplemental RI Data, November 1993
      *     Remedial Investigation Report, Fire-Training Area No. 2 (FTA-2) and Landfill
            No. 2 (LF-2), Draft April 1992, Revised to Include Supplemental RI Data,
            November 1993
      *     Southeast Region Groundwater Operable Unit Remedial Investigation Report,
            Volumes I, H, m, IV, V, DRAFT, August 1994
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                                                                APPENDIX A
 3     SITE:   AREA OF  CONTAMINATION  CHEMICAL  SPILLS  16  AND  17,
      GROUNDWATER  OPERABLE UNIT (ASHUMET VALLEY GROUNDWATER
      PLUME)

      *     Interim Remedial Investigation, Sewage Treatment Plant/Former Sewage Sludge
            Disposal Area (CS-16/17 Study Area), November 1991
      *     Interim Remedial Investigation, AOC Fire-Training Area No. 1, (FTA-1),
            Groundwater Operable Unit, Task 2-5, Draft Final, April 1994
      *     Phase  I of the Ashumet Valley Groundwater Study, DRAFT, March  1991,
            Appendix L added August 1993
      *     Preliminary Risk Assessment for the Leading Edge of the Ashumet Valley Plume,
            Volumes I and H, DRAFT, January 1994
      *     Remedial Investigation Report, Sewage Treatment Plant/Former Sewage Sludge
            Disposal Area (AOC CS-16/CS-17), Draft Final November 1991,  Revised to
            Include Supplemental RI Data and Preliminary Risk Assessment, March 1995
      *     Ashumet Valley Groundwater Operable Unit Remedial Investigation,  Volumes I,
            H, m, IV, V, VI, Draft April  1995

4.     SITE: AREA OF CONTAMINATION CHEMICAL SPILL 10 (CS-10) TO INCLUDE
      FUEL  SPILL  24  (FS-24),  GROUNDWATER  OPERABLE   UNIT  (CS-10
      GROUNDWATER PLUME)

      *     Remedial Investigation, UTES/BOMARC and BOMARC  Area Fuel Spill, AOC
            CS-10  Groundwater Operable Unit CS-10D and Hydrogeologic Region 2 Study,
            DRAFT, November 1993
      *     Remedial Investigation, UTES/BOMARC and BOMARC Area Fuel Spill, CS-10
            and FS-24, Source Operable Units: CS-10A and CS-10B,  Volumes I, D, m, IV,
            V, DRAFT, March 1994
      *     Remedial Investigation UTES/BOMARC and BOMARC Area Fuel Spill CS-10
            Groundwater Operable Unit:  CS-10D and Hydrogeologic Region n Study,
            Volumes I, JJ, m, IV, Revised Draft March 1995

5.     SITE: AREA OF CONTAMINATION FUEL SPILL 12 (FS-12) GROUNDWATER
      OPERABLE UNIT (FS-12 GROUNDWATER PLUME)

      *     Remedial Investigation/Feasibility Study, FS-12 Study Area, DRAFT, December
            1993
      *     Aquifer Test Analysis, June 1994
      *     Remedial Investigation Report,  FS-12 Study Area, Volumes I-JJI, Final, January
            1995
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                                                                   APPENDIX A
 SECTION 6.   Technical Reports applicable to all groundwater plumes proposed for
 containment and those not proposed for containment.

       *    Draft Remedial Investigation Report AVGAS Fuel Valve Test Dump Site, FS-1
            Study Area, March 1991
       *    Final Groundwater Focused Feasibility Study West Truck Road Motor Pool (AOC
            CS-4), February 1992
       *    Final Groundwater Proposed Plan, West Truck Road Motor Pool (AOC CS-4)
            February 1992
       *    Final Record of  Decision,  West  Truck Road  Motor Pool (AOC  CS-4)
            Groundwater Operable Unit, May 1992
       *    CS-4 Groundwater Operable Unit,  Extraction and Treatment System, Final
            Design Package, Volumes I, JJ, ffl, IV,  and Drawings, July 1992
            Groundwater Remediation Strategy Report, October 1992
            Interim Remedial Investigation Report, Petroleum Fuels Storage Area, AOC's FS-
            10 and FS-11, DRAFT, May 1992, Appendix K added December 1992
            Plume Response Plan, June 1994
            Comprehensive Plan, Final, August 1994
            Risk Assessment Handbook, Volumes I and n, September 1994
            Final Report for Monitoring Well Inventory, Volumes I, n, m, November 1994
            Proposed Plan for Interim Action, Containment of Seven Groundwater Plumes,
            Feb. 1, 1995

 SECTION?.  Recommended Reading

       *    Final Groundwater Focused Feasibility Study West Truck Road Motor Pool (AOC
            CS-4), February 1992
       *    Final Groundwater Proposed Plan, West Truck Road Motor Pool (AOC CS-4),
            February 1992
       *    Final Record of  Decision,  West Truck  Road  Motor Pool (AOC CS-4)
            Groundwater Operable Unit, May 1992
       *    Groundwater Remediation Strategy Report, October 1992
       *    Plume Response Plan, June 1994
       *    Comprehensive Plan, Final, August 1994
       *    Proposed Plan for Interim Action, Containment of Seven Groundwater Plumes,
            Feb. 1, 1995
       *    Revised Draft Record of Decision for Interim Action, Containment of Seven
            Groundwater Plumes, Aug. 1, 1995
       *    Community Relations Plan, Final Sep. 1995
                         Installation Restoration Program

0644SA.B02                               A-4                            SipuolMr 1995

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                                                                   APPENDIX A
 SECTIONS. Correspondence

 1.     Correspondence related to the "Plume Response Plan, June 1994"

       *      Letter dated April 25, 1994. Subject: Questions about "Hot-Spot" Remediation
             from Charlie Jacobs to the Plume Management PAT.
       *      Letter dated May 10, 1994.  Subject:  Comments on Plume Response Plan from
             Denis LeBlanc to the PAT and the IRP.
       *      Letter dated May 10, 1994. Subject:  Comments on the Plume Response Plan
             from Ernest Keating to the PAT/IRP.
       *      Comment listing date May 11, 1994.  Subject:  Comments on Plume Response
             Plan from Air National Guard Readiness Center (ANGRC) to the PAT/IRP.
       *      Letter dated May 11, 1994.  Subject:  Comments on Plume Response Plan from
             Paul Marchessault to Daniel Santos.
       *      Memorandum for Record dated May 12, 1994. Subject: Comments on Plume
             Response Plan from Ken Till to Steve Wilson (OPTECH).
       *      Hand-written comment memo  dated May  12, 1994. Subject:  Comments on
             Conceptual  Model Plan from Jim Begley to PAT.
       *      Hand-written comment memo, undated. Subject:  Comments on Plume Response
             Plan from Eileen Gunn to PAT/IRP.
       *      Letter dated May 13, 1994. Subject: Modifications on previous comments from
             Denis LeBlanc to the PAT/IRP.
       *      Untitled documents dated May  24, 1994. Subject:  ANGRC changes.
       *      Memorandum dated May 1994.  Subject:  HAZWRAP comments  on Plume
             Response Plan to IRP, preliminary.
       *      Memorandum dated May 1994.  Subject:  HAZWRAP comments  on Plume
             Response Plan to IRP.
       *      Letter undated. Subject:  Comments on Plume Response Plan from Ed Kunce to
             Senior Management Board.
       *      Letter date May 27,1994. Subject: Review of Plume Response Plan from David
             Webster to Daniel Santos.
       *      Letter dated May 31, 1994.  Subject:  Town of Falmouth comments on Plume
             Response Plan from Virginia Valiela to Ross Murray.
       *      Letter dated June 1, 1994. Subject:  AD-HOC Working Group comments on the
             Plume Response Plan.
       *      Memorandum undated.    Subject:   Responsiveness Summary  to the Plume
             Response Plan.

2.     Correspondence related to the "Proposed Plan, Interim Action for Containment of Seven
       Groundwater Plumes, February 1, 1995"

       *      Letter dated Dec. 15, 1994.  Subject:  EPA comments on Draft Proposed Plan
             from Paul Marchessault to Michael Minior.
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06448A.B02                               A-5                            September 1995

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                                                                     APPENDIX A
             Letter dated Dec. 15, 1994.  Subject:  DEP comments on Draft Proposed Plan
             from James Begley to Michael Minior.
             Letter dated Dec. 15, 1994.  Subject:  Consolidated comments from all parties
             on Draft Proposed Plan from Michael Minior to Richard Skryness, Stone &
             Webster.
             Letter dated Jan. 6,1995.  Subject: NGB responses to DEP's comments on Draft
             Proposed Plan, signed by Michael Minior to James Begley.
             Letter dated Jan. 6,  1995.  Subject:  NGB responses to Plume Management
             Process  Action Team comments on Draft  Proposed Plan, signed by Michael
             Minior to Doctor William McDermott.
             Letter dated Jan. 6,  1995.  Subject:  NGB responses to Plume Management
             Process  Action Team comments on Draft  Proposed Plan, signed by Michael
             Minior to Doctor Joel Feigenbaum.
             Letter dated Jan. 6,  1995.  Subject:  NGB responses to Plume Management
             Process  Action Team comments on Draft  Proposed Plan, signed by Michael
             Minior to Susan Nickerson.
             Letter dated Jan. 6, 1995.  Subject: NGB responses to Army National Guard
             comments on Draft Proposed Plan, signed by Michael Minior to JoAnn Watson.
             Letter dated Jan. 6, 1995. Subject:  NGB responses to Army Environmental
             Center's comments on Draft Proposed Plan,  signed by Michael Minior to Doctor
             Kathleen Buchi.
             Letter dated Jan. 6, 1995.  Subject: NGB responses to USEPA comments on
             Draft Proposed Plan,  signed by Michael Minior to Paul Marchessault.
             Letter dated Jan.  30,  1995.  Subject:   EPA comments on the Revised Draft
             Proposed Plan from Paul Marchessault to Michael Minior.
             Letter dated Jan. 31, 1995.   Subject:  Draft final  Applicable, Relevant and
             Appropriate Requirements (ARARs) from Michael Minior (NGB)  to Paul
             Marchessault USEPA).
             Letter dated Jan. 31,  1995. Subject: Comments from NGB, USEPA and DEP
             to Richard Skryness of Stone & Webster on Draft  Proposed Plan, signed by
             Michael  Minior (NGB).
             Letter dated Feb. 3, 1995.  Subject: Response to comments letter dated 1/31/95
             from Richard Skryness to Michael Minior.
             Letter dated Mar. 13, 1995.  Subject: National Guard Bureau-Army comments
             on die Proposed Plan from Scott Hilyard to Michael Minior.
             Letter dated May 2, 1995.  Subject: NGB responses to National Guard Bureau-
             Army comments on the Draft Proposed Plan, signed by Michael Minior to NGB-
             ARE-PR.
             Letter dated June 16,1995.  Subject:  Army  Environmental Center comments on
             the Draft Record  of Decision for Interim  Action, Containment of  Seven
             Groundwater Plumes to Timothy Taylor from Michael Minior.
                          Installation Restoration Program

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                                                                    APPENDIX A
       *     Letter dated June 29, 1995.   Subject:  DEP  comments on Draft Record of
             Decision for Interim Action, Containment of Seven Groundwater Plumes from
             Andrea Papadopoulos to Michael Minior.
       *     Letter dated July 13, 1995.   Subject:  EPA  comments on Draft Record of
             Decision for Interim Action, Containment of Seven Groundwater Plumes from
             Paul Marchessault to Michael Minior.
       *     Letter dated July 27,  1995.  Subject:  NGB responses to Army Environmental
             Centers  comments on  the  Draft Record  of  Decision for  Interim Action,
             Containment of Seven Groundwater Plumes to Robert  Snyder  from Michael
             Minior.
       *     Letter dated July 27, 1995.  Subject:  NGB responses to  EPA comments on the
             Draft Record of Decision for Interim Action, Containment of Seven Groundwater
             Plumes to Paul Marchessault from Michael Minior.
       *     Letter dated Aug. 23,1995.  Subject:  EPA comments on NGB responses to EPA
             comments  on  the  Revised  Draft Record  of  Decision for  Interim Action,
             Containment of Seven Groundwater Plumes from Paul Marchessault to Michael
             Minior.
       *     Letter dated September 28, 1995. Subject:  NGB responses to EPA's comments
             of Aug. 23, 1995 on the Revised Draft Record  of Decision for Interim Action,
             Containment of Seven Groundwater Plumes.
       *     Letter dated September 29, 1995. Subject:  State Concurrence on the Record of
             Decision for Interim Action, Containment of Seven Groundwater  Plumes.

SECTION 9. Community Relations

1. NEWS RELEASES

       *     News Release Nr. 93-24, Meetings Scheduled
       *     News Release Nr. 93-25, Pumping Test to be Conducted
       *     News Release Nr. 93-26, Senior Management Board to Meet
       *     News Release Nr. 94-1, Schedule of Upcoming  Meetings
       *     News Release Nr. 94-2, Schedule of Upcoming  Meetings
       *     News Release Nr. 94-3, Plume Management Team to Meet Today
       *     News Release Nr. 94-5, Change in Meeting Time
       *     News Release Nr.- 94-7, Meetings Set on Base Cleanup
       *     News Release Nr. 94-9, Meetings Set
       *     News Release Nr. 94-10, Meetings Set
       *     News Release Nr. 94-11, Plume Management Team to Meet
       *     News Release Nr. 94-13, Plume Management Team to Meet
       *     News Release Nr. 94-14, Plume Management Team to Meet
       *     News Release Nr. 94-15, Team to Discuss Draft Plume   Response Plan
       *     News Release Nr. 94-17, Plume Team to Discuss Response Plan
       *     News Release Nr. 94-18, Team to Present Plume Response Plan
                         Installation Restoration Program

06448A.B02                               A-7                              September 1995

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                                                                    APPENDIX A
             News  Release Nr. 94-20, Plume Management Team and Pond Task Force
             Meetings Scheduled
             News  Release Nr. 94-21, Pond Task Force and Senior Management Board
             Meetings Set
             News Release Nr. 94-23, Plume Management PAT Team to Meet
             News Release Nr. 94-24, Public Meetings on Base Cleanup Scheduled
             News Release Nr. 94-25, Senior Management Board Meeting Rescheduled
             News Release Nr. 94-26, Senior Management Board Meeting Scheduled
             News Release Nr. 94-27, Santos to Assume New Position
             News Release Nr. 94-28, Replacement for Santos Named
             News  Release Nr.  94-29,  Plume Management Pat to Review Short-Term
             Response Plan for LF-1 Plume
             News Release Nr. 94-31, Plume Management Process Action Team to Meet
             News Release Nr. 94-32, Schedule of Upcoming Meetings
             News Release Nr. 94-34, Team Members sought for PAT
             News Release Nr. 94-35, Plume Management PAT to Meet
             News Release Nr. 94-36, Three Public Meetings Set for October
             News Release Nr. 94-39, List of November Public Meetings Set
             News Release Nr. 94-40, List of November Public Meetings Set
             News Release Nr. 94-42, Public Meeting Schedule for December
             News Release Nr. 94-45, Public Meetings Scheduled for January

             News  Release Nr. 95-1, Contractor Being Changed for Design of Plume
             Containment Project
             News Release Nr. 95-3, Plume Management Team to Meet
             News Release Nr. 95-4, Location Changed for Plume Management Team Meeting
             News Release Nr. 95-5, Plume PAT Meeting Postponed
             News Release Nr. 95-6, Meeting Schedule Announced
             News Release Nr. 95-8, Plume Management PAT to Meet
             News Release Nr. 95-9, Plume Design Contract Successfully Negotiated
             News Release Nr. 95-10, Senior Management Board Meeting Time Changed
             News Release Nr. 95-11, Kickoff Meeting on Plume Containment Design Held
             News Release Nr. 95-12, Public Meeting Schedule Announced
             News Release Nr. 95-13, June Public Meeting Schedule Announced
             News Release Nr. 95-14, Additional June Public Meetings Set & IRP Office Has
             New Home
             News Release Nr. 95-15, Team #1 to Meet on Variety of Issues
             News Release Nr. 95-16, Important Meetings Planned on Base Cleanup
             News Release Nr. 95-17, More July Meetings Planned on Base Cleanup
             News Release Nr. 95-18, More Team Meetings Scheduled
             News Release Nr. 95-20, Team #1 to Meet
             News Release Nr. 95-21, U.S. Senator John F. Kerry to Meet With Senior
             Management Board Members
                         Installation Restoration Program

0644IA.B02                               A-8                             SqMMdbw 1995

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                                                                    APPENDIX A
       *     News Release Nr. 95-23, Team #1 and Senior Management Board Meetings to
             be Held
       *     News Release Nr. 95-24, Monitoring Well Installation to Occur in Residential
             Areas Near Johns Pond
       *     News Release Nr.  95-25, Environmental  Division Chief Invites News Media
             Representatives to Discuss Base Cleanup Issues
       *     News Release Nr. 95-26, Public Meetings  Announced for September
       *     News Release Nr. 95-27, Team 2 Meeting Rescheduled
       *     News Release Nr. 95-28, Team 2 Meeting Rescheduled
       *     News Release Nr. 95-29, Team 1 Meeting Rescheduled

2.     FACT SHEETS/FLYERS

       *     Environmental Update 93-5, Nov. 4, 1993
       *     Environmental Update 94-1, Jan. 14, 1994
       *     Environmental Update 94-2, May 10, 1994
       *     Environmental Update 94-3, Sept. 26, 1994
       *     Environmental Update 95-1, Feb. 6, 1995
       *     Environmental Update 95-2, June 2, 1995
       *     Environmental Update 95-3, Sept. 1, 1995
       *     Plume Response Plan Fact Sheet #1, Plan to Stop Groundwater Plumes Defined,
             June 1994
       *     Plume Response Plan Fact Sheet #2, Ashumet Valley Groundwater Plume, June
             1994
       *     Plume Response Plan Fact Sheet #3, Chemical Spill 10 Groundwater Plume, June
             1994
       *     Plume Response Plan Fact  Sheet #4, Main Base  Landfill (LF-1) Groundwater
             Plume, June 1994
       *     Plume Response Plan Fact Sheet #5, Fuel Spill 12 (FS-12) Groundwater Plume,
             June 1994
       *     Plume Response Plan Fact  Sheet #6, Western Aquafarm Groundwater Plume,
             June 1994
       *     Plume Response Plan Fact Sheet til, Storm  Drain 5 (SD-5) Groundwater Plume,
             June 1994
       *     Plume Response Plan Fact  Sheet #8, Eastern Briarwood Groundwater Plume,
             June 1994
       *     Plume Response Plan Fact Sheet #9, Petroleum Fuel Storage Area Groundwater
             Plume, June 1994
       *     Plume Response Plan Fact Sheet #10, Chemical Spill 4 Groundwater Plume, June
             1994
       *     Plume Response Plan Fact  Sheet #11,  Fuel Spill 1 Groundwater Plume, June
             1994
       *     Environmental Update 94-3, Sept. 26, 1994
                         Installation Restoration Program

06448A.B02                               A-9                              September 1995

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                                                                    APPENDIX A
       *     Flyer, Public Participation Activities for Plans to Stop Groundwater Plumes,
             mailed Jan. 27, 1995
       *     Plume Containment Design Fact Sheet #95-1, Mar. IS, 1995
       *     Plume Containment Design Fact Sheet #95-2, Apr. 13, 1995

 3.     QUARTERLY REPORTS

             Quarterly Progress Report No. 10, January 1994
             Quarterly Progress Report No. 11, April 1994
             Quarterly Progress Report No. 12, July 1994
             Quarterly Progress Report No. 13, October 1994
             Quarterly Progress Report No. 14, January 1995
             Quarterly Progress Report No. 15, April 1995
             Quarterly Progress Report No. 16, July 1995

 4.     NEWSPAPER ARTICLES/PAID ADVERTISEMENTS

       *     "Round Table On Base A First For TEAC," Enterprises, Mashpee and Falmouth,
             Jan. 29, 1993
       *     "A Mark Of Good Faith," Enterprises, Mashpee and Falmouth, Feb. 2, 1993
       *     "Priority  Is  Stopping The Plumes'  Rep. Turkington Tells  TEAC  Group,"
             Enterprise, Falmouth, Feb. 12, 1993
       *     "DEP Says:  'Plumes Can Be Stopped'," Enterprise, Mashpee, March 5, 1993
       *     "Map Presentation 'Sloppy Journalism'," Enterprise, Mashpee, March 5, 1993
       *     "Map of Plumes A Wake-Up Call," Enterprise, Mashpee, March 5, 1993
       *     "Too Few Voices  For Too Long," Enterprise, Mashpee, Mar, 5, 1993
       *     "Ashumet cleanup remains uncertain," Cape Cod Times, March 23, 1993
       *     "Military Tests Groundwater in Cataumet Area," Bourne Courier, April 1, 1993
       *     "Guard on trail of chemical pollution," Cape Cod Times, April 9, 1993
       *     "Toxic Plume Advancing on Cataumet Wells," Bourne Courier, April 15, 1993
       *     "Guard Offers Precise Map of Forestdale Pollution," Bourne Courier, April 15,
             1993
       *     "Plume Containment Experiments Planned This Summer, Says Selectmen Valiela,
             Urging Speed Up," Enterprises, Mashpee and Falmouth, April 20, 1993
       *     "Base Cleanup Major  Priority  For Selectmen's  Consortium,"  Enterprise,
             Mashpee, May 14, 1993
       *     "National  Guard To Sponsor An Informational Public Meeting," Cape Cod
             Times, May 17, 1993
       *     "Taking Stock On Groundwater Contamination," Enterprise, May 18, 1993
       *     "Base Says  Hatchville  Plume Much Larger Than  Previously Thought,"
             Enterprises, Falmouth and Mashpee, May 21, 1993
       *     "Plume Containment Top Priority Guard Bureau Informs TEAC," Enterprises,
             Falmouth and Mashpee, June 11, 1993
                         Installation Restoration Program

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                                                                     APPENDIX A
       *     "Lawrence-Lynch Wins Base Contract For $7.6 Million," Enterprises, Falmouth
             and Mashpee, June 11, 1993
       *     "Two Plumes Reach Edge of Johns Pond," Enterprise, Mashpee, June 15, 1993
       *     "Start the Town and Stop the Plume," Bourne Courier, June 17, 1993
       *     "Town Awakens to News of Base Pollution Heading Toward  Wells," Bourne
             Courier, June 17, 1993
       *     "Cataumet public wells in peril," Cape Cod Times, July 30, 1993
       *     "Stopping  Cataumet-bound Plume May  Be Impossible,  But National  Guard
             Pledges to Try," Bourne Courier, Aug.  5, 1993
       *     "Plume Headed for Cataumet May  Be  Unstoppable," Sandwich Broadsider,
             Aug 5, 1993
       *     "Base Officials Want More Information Before Containing Plumes In Mashpee,"
             Enterprises, Falmouth and Mashpee, Aug. 10, 1993
       *     "Guarding Water," Cape Cod Times, Aug. 10, 1993
       *     "Politics, Not Technology, Is Inhibiting Plume Cleanup," Enterprises, Falmouth
             and Mashpee, Aug. 10, 1993
       *     "State DEP Will Step In To Streamline Base Cleanup," Enterprises, Mashpee and
             Falmouth,  Aug. 20, 1993

       *     "Mashpee Officials See Big Step In New Strategy On Base Cleanup," Enterprise,
             Falmouth,  Aug. 24, 1993
       *     "League's  Valuable Role," Enterprise, Falmouth, Aug. 24, 1993
       *     "Contaminated Plume Changes Direction Toward N. Falmouth," Enterprise,
             Falmouth,  Aug. 26, 1993
       *     "TEAC Meeting To Be Held," Cape Cod  Times, Aug. 27,  1993
       *     "Cataumet Plume Crosses Route 28," Bourne Courier, Sept. 2, 1993
       *     "Selectmen Will Speak  For  Public on Base  Cleanup  Oversight Team,"
             Enterprises, Falmouth, Mashpee and Bourne, Sept. 3, 1993
       *     "Water District Shuts Down Well As Precaution," Bourne Courier, Sept. 9,1993
             and Mashpee Messenger, Sept. 9, 1993
       *     "Cataumet Group Urges Containment," Enterprise, Falmouth, Sept. 10, 1993
       *     "Nat'l. Guard Will Test Wells In Contaminated Plume's Path," Enterprise,
             Falmouth,  Sept. 10, 1993
       *     "Wells Drilled On E. Shore," Enterprise, Mashpee, Sept. 10, 1993
       *     "Action On N. Falmouth Plume," Enterprise, Mashpee, Sept. 10, 1993
       *     "Falmouth joins base pollution-study team, Cape Cod Times, Sept.  16, 1993
       *     "Bourne, Guard try to resolve plume, water woes," Cape Cod Times, Sept. 16,
             1993
       *     "Hearing Is Tonight on Briarwood Water," Mashpee Messenger, Sept. 16, 1993
       *     "Water District Vows to Put Pressure on  Guard Bureau,"  Bourne  Courier,
             Sept. 16, 1993
       *     "Residents  hope for ally in fight against pollution," Cape Cod Times, Sept. 21,
             1993
                          Installation Restoration Program

06448A.B02                   •            A-ll                              September 1995

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                                                                     APPENDIX A
       *     "Cataumet Plume Containment Plan Draws Less Than Rave Reviews," Bourne
             Courier, Sept. 23, 1993
       *     "Bureau Will Sink Wells Next Month To Define Plume," Enterprise, Bourne,
             Sept. 24, 1993
       *     "Plume Containment Is Only Alternative, Says Engineer," Enterprise, Bourne,
             Sept. 24, 1993
       *     "Attempt to Pump Contaminant  Fails; Force It Out by Air, Expert Advises,"
             Sandwich Broadsider, Sept. 30, 1993
       *     "The System That Failed; The  Hope for the  Future,"  Sandwich Broadsider,
             Sept. 30, 1993
       *     "Low Levels Of Contaminants  Found  In Perry  Road  Wells,"  Enterprise,
             Falmouth, Oct. 19, 1993
       *     "Tests show water safe in N. Falmouth,"  Cape  Cod Times
       *     "Selectmen Left Out Of Base Cleanup Team: 'We Want To Be First In Line For
             Information'," Enterprise, Falmouth, Oct  22, 1993

       *     "National Guard Bureau Says Prognosis Bleak; Studds Says Otis Will Get What
             it Needs," Bourne Courier,  Mashpee Messenger,  and Sandwich Broadsider,
             Oct. 28, 1993
       *     "National Guard  Begins  Testing Wells  In The Path Of Plume From Base
             Landfill," Enterprise, Bourne, Oct. 29, 1993
       *     "Selectmen To Join Base Cleanup Team," Enterprise, Oct.  29, 1993
       *     "Facility Opens to Contain Plume Under Wildlife Area," Enterprises, Falmouth
             and Mashpee, Nov. 2, 1993
       *     "46th meeting of the TEAC to be held on Nov 3," Cape Cod Times, Nov. 1,
             1993
       *     "Guard begins cleanup of Upper Cape ground water," Cape Cod Times, Nov. 4,
             1993
       *     "Military reservation budget looks stable," Cape Cod Times, Nov. 4, 1993
       *     "Bourne Raises Questions About Pumping, Treating," Enterprise, Mashpee,
             Nov. 5, 1993
       *     "Specific Cleanup Goals," Enterprise, Falmouth, Nov. 5, 1993
       *     "Selectmen Will Serve On Base Management Team," Enterprise, Bourne, Nov. 5,
             1993
       *     "Guard Will Have To Convince Public Cleanup  Plan Works, Says Coggeshall,"
             Enterprise, Bourne, Nov. 5, 1993
       *     "CNN story highlights Upper Cape pollution," Cape Cod Times, Nov. 6, 1993
       *     "One Pump Starts to Clean Plume; But Financial Pump's Flow Slows," Sandwich
             Broadsider, Nov. 1993
       *     "Bourne  Official Supports Suggestion To Pump Water Now From Cataumet
             Plume," Enterprises, Bourne and  Mashpee, Nov. 19, 1993
       *     "Tests Show Contamination In Perry Rd. Wells; Selectmen Want To Install Mains
             Immediately," Enterprise,  Falmouth, Nov. 23, 1993
                          Installation Restoration Program

0644SA.B02                               A-12

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                                                                     APPENDIX A
       *     "Management Team Ready To Review Base Cleanup,"  Enterprises, Bourne,
             Falmouth and Mashpee, Nov. 30, 1993
       *     "Base Questions Addressed At Meeting In Mashpee," Enterprises, Mashpee and
             Falmouth, Nov. 30, 1993
       *     "Public Meeting to be Held on Base Cleanup Work,"  Sandwich Broadsider,
             Dec. 2, 1993
       *     "New Management Structure to Speed  otis  Base  Cleanup," Bourne Courier,
             Sandwich Broadsider and Mashpee Messenger, Dec. 2, 1993
       *     "Base Cleanup Meeting Tonight," Mashpee Messenger, Dec. 2, 1993
       *     "New Base Cleanup  Teams Plan Several Meetings,"  Enterprise,  Mashpee,
             Dec. 7, 1993
       *     "Briarwood  Testing Results Ready Within Two Months," Enterprise,  Mashpee,
             Dec. 7, 1993
       *     "Mashpee Board Of Health Promises United  Effort On Cleanup Of Pollution,"
             Enterprise, Mashpee, Dec. 7, 1993

       *     "Bureau to discuss Forestdale fuel spill," Cape Cod Times, Dec. 7, 1993
       *     "Corrections," Enterprise, Falmouth,  Dec. 7, 1993
       *     "Cataumet residents move to stop plume," Cape Cod Times, Dec. 10, 1993
       *     "State DEP  Plan Gives Military 22 Months To Contain Plumes," Enterprises,
             Mashpee and Falmouth, Dec. 10, 1993
       *     "Selectmen to help manage base cleanup," Cape Cod Times, Dec. 10, 1993
       *     "Good May  Come Of It," Enterprises, Falmouth and Mashpee, Dec. 10, 1993
       *     "State moves to block plumes," Cape Cod Times, Dec. 11, 1993
       *     "An Exciting Development," Enterprise Falmouth, Dec.  14, 1993
       *     "Finally, a unified front on plumes," Cape Cod Times, Dec. 15, 1993
       *     "S100M Plume Cleanup Plan No Pipe Dream," Sandwich Broadsider, Dec. 16,
             1993
       *     "A plan to stop the plumes," Cape Cod Times, Dec. 16, 1993
       *     "Activists seek S10QM for base cleanup," Cape Cod Times, Dec. 18,  1993
       *     "Final Draft Pond Report Next Month," Enterprise, Mashpee,  Dec.  21, 1993
       *     "Consultants Are Preparing 3-Dimensional Plume Models," Enterprise, Falmouth,
             Dec.  24, 1993
       *     " Cleanup Oversight Board Will Meet At Base Next Week," Enterprise, Falmouth,
             Dec.  24, 1993
       *     "Things Are Starting To Move," Enterprise, Falmouth, Dec. 28, 1993
       *     "Guard board considers plan to stop Otis plumes,"  Cape Cod  Times,  Dec. 28,
             1993
       *     "Guard says Pentagon sank cleanup plan," Cape Cod Times, Dec. 30, 1993
       *     "Military  Cleanup  Crew Performs Pump Test  Near Forestdale Plume,"  The
             Sandwich Broadsider, Dec. 30, 1993
       *     "Government Made Him Spend $200K to Replace Gas  Storage Tanks, Does
             Nothing to Stop Plume," Bourne Courier, Dec. 30,  1993
                          Installation Restoration Program

06448A.B02                               A-13                              September 1995

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                                                                     APPENDIX A
       *     "Writing Off Bad Pollution Debts," Bourne Courier, Dec. 30, 1993
       *     "Base Management  Team  Wants Master Plan To Address Containment Of
             Plumes," Enterprises, Mashpee, Bourne and Falmouth, Dec. 31, 1993
       *     "Management Team Thanks Ron Watson For His Service," Enterprises, Falmouth
             and Mashpee, Dec. 31, 1993
       *     "Activist Joel Feigenbaum Appointed To Team," Enterprises, Mashpee and
             Falmouth, Dec.  31, 1993
       *     "Simultaneous Plume Clean-up Unlikely," The Sandwich Broadsider, Jan. 6,1994

       *     "Plume Contamination Clobbers Property Values," Bourne Courier, Jan. 6,1994
       *     "DEP Officials Says New Plume Management Structure Will Be Able To Cut
             Through Washington's Red Tape," Enterprises, Mashpee, Falmouth and Bourne,
             Jan. 7, 1994
       *     "47th Meeting of TEAC to  be Held," Cape Cod Times, Jan. 17, 1994
       *     "The Base Landfill Plume Will Not Flow Harmlessly Into The Sea," Enterprise,
             Bourne, Jan. 21, 1994
       *     "Concludes Base A Health Hazard," Enterprises, Falmouth and Mashpee, Feb. 8,
             1994
       *     "Concerns Raised  About VOC Tests On Two Roads," Enterprise, Mashpee,
             Feb. 8, 1994
       *     "Action Teams For Base Cleanup Scheduled To Meet Next Week," Enterprises,
             Falmouth and Mashpee, Feb. 8, 1994
       *     "Costs On Agenda For Management Team On Plumes," Enterprise, Mashpee,
             Feb. 22, 1994
       *     "Base cleanup plan proceeds," Cape Cod Times, Feb. 24, 1994
       *     "Proximity to Base Pollution Lowers  Local Property Values, Expert Says,"
             Mashpee Messenger, Feb. 24, 1994
       *     "Public Meetings On Base Cleanup Scheduled,"  The Sandwich Broadsider,
             March 10, 1994
       *     "Public Meetings on Base Cleanup Scheduled," Falmouth/Mashpee Enterprise,
             March 11, 1994
       *     "Containment Plan Ready In 2 Months," Enterprise, Mashpee, March 22, 1994
       *     "Guard officials  caution base cleanup activities," Cape Cod Times, March 22,
             1994
       *     "National Guard Missing Crucial Deadline," Enterprises, Mashpee and Falmouth
             (As Letter-To-The Editor), March 22, 1994
       *     "Base Cleanup - Do They Really Know What They're Doing?," The Sandwich
             Broadsider, March 24, 1994
       *     "Draft Plume Mitigation Two Months Away," Enterprise, Bourne, March 25,
             1994
       *     "An  Unnecessary  Delay," Enterprises,  Bourne, Falmouth and Mashpee,
             March 25, 1994
       *     "Activist Approach Is Welcome," The Enterprise, April 19, 1994
                          Installation Restoration Program

0644SA.B02                                A-14                             S^ttnbw 199S

-------
                                                                     APPENDIX A
       *     "Committee Musters Support For Plan To Contain Plume," Enterprise, Bourne,
             April 22, 1994
       *     "Base Cleanup  Needs Master Plan; Boston Harbor Project A  Model," The
             Enterprise,  April 22, 1994
       *     "Plume Action Team Will Meet At Base," The Enterprise, April 26, 1994
       *     "Upper Cape cleanup may cost $112M," Cape Cod Times, May 6, 1994
       *     "Base Pollution Action Could Take Four Years, Cost $112M," Bourne Courier,
             May 12, 1994

       *     "Cataumet Residents Seek Faster Pollution Cleanup," Bourne Courier, May 12,
             1994
       *     "Base Action Team Endorses Plan To Contain Plumes," Enterprise, Falmouth,
             May 20, 1994
       *     "U.S. House backs aid for Cape base cleanup," Cape Cod Times, May 25, 1994
       *     "Activists seek $100M for base cleanup," Cape Cod Times, May  1994
       *     "Plume Containment Plan Endorsed, Timing An  Issue," Enterprise, Mashpee,
             May 20, 1994
       *     "Otis Team Hails Plan to Halt Base Pollution," Bourne Courier, May 26,  1994
       *     "Pond Task Force Meeting Postponed," Enterprise, Falmouth, May 24, 1994
       *     "Otis  Team Hails $112  M Plan  To Halt  Base Pollution Plume," Mashpee
             Messenger,  June 2,  1994
       *     "A Plan To Contain Plumes On The Base Ready For Presentation By June 30,"
             Enterprise, Bourne,  June  10, 1994
       *     "Mashpee ponds study hints at pollution," Cape Cod Times, June  IS, 1994
       *     "Cleanup plan for base bound for Pentagon," Cape Cod Times, June 16, 1994
       *     "Lawmakers seek $150M to check base pollution," Cape Cod Times, June 22,
             1994
       *     "PAT, the watchdog," Cape Cod Times, June 23, 1994
       *     "Full Funding For  Cleanup Targeted By Lawmakers,"  Enterprise,  Mashpee,
             June 24, 1994
       *     "Red-letter day in Otis cleanup," Cape Cod Times, June 29, 1994
       *     "Lobbying For Cape's Best Interests," Enterprise, Mashpee, June 28, 1994
             "It Won't Sell Itself," The Enterprise, June 28, 1994
             "Mr. Coggeshall Goes to  Washington," Bourne Courier, June 30,  1994
             "Pentagon commitment on cleanup eludes group," Cape Cod Times, July 1,1994
             "Pentagon OK's $250m Cape water cleanup," The Boston Globe, July 2, 1994
             "Pentagon OKs base pollution cleanup," Cape Cod Times, July 2,  1994
             "Public Meeting to be Held on Plan to Stop Groundwater Plumes," Cape Cod
             Times, July 5, 1994
             "Public Involvement Cited As Key Factor In Pentagon Funding," The Enterprise,
             July 5, 1994
             "Plan to track Bourne wells creates ripple," Cape Cod Times, July 29, 1994
             "Bill reserves $1M for base center," Cape Cod Times, July 29, 1994
                          Installation Restoration Program

06448A.B02                                A-1S                             September 1995

-------
                                                                      APPENDIX A
       *     "Plume Management PAT to Review Response Plan," Bourne Courier, Aug. 4,
             1994
       *     "Public Involvement Urged Now That Plume Containment Has Been Decided,"
             The Enterprise, Aug. 5, 1994
       *     "Base Action Team Has Two Vacancies," The Enterprise, Sept. 13, 1994
       *     "Forestdale cleanup to start next year," Cape Cod Times, Sept.  15,  1994
       *     "Tentative Timetable Offered For Implementation of Plume Response Plan For
             Military Reservation," Enterprise, Mashpee, Sept. 16. 1994
       *     "Timetable Is  Set For Containment Of Base  Plume," Enterprise, Bourne,
             Sept. 16, 1994
       *     "Base Cleanup  Priorities Questioned," The Sandwich Broadsider, Sept. 15,1994
       *     "Pollution Cleanup in Sandwich By National Guard Questioned," The Sandwich
             Broadsider, Sept. 15, 1994
       *     "Local Man Top Pick for Cleanup," the Sandwich Broadsider, Sept. 15, 1994
       *     "Base Seeks Team Members," Cape Cod Times,  Sept. 25, 1994
       *     "Base Pollution Serves As Case Study For Book," The Enterprise, Oct. 14,1994
       *     "APCC Hopes  Book On Base Pollution, Cleanup  Will Serve As Case Study For
             Other Communities,* The Enterprise, Oct. 14, 1994
       *     "Guard Will Present Plan To Save Threatened Wells," The Enterprise, Oct. 14,
             1994
       *     "Public Meeting Set to Discuss Issues Related to the Mass. Military Reservation
             Landfill Plume," Cape Cod Times, Oct.  18,  1994
       *     "Pollution and Solution both moving fast," Cape Cod Times, Oct. 23,  1994
       *     "Cataumet's water supply to be replaced, Guard says," Cape Cod Times, Oct. 26,
             1994
       *     "Public Meeting Set to Discuss Issues Related to the Mass. Military Reservation
             FS-12 Plume,"  Cape Cod Times,  Nov. 3, 1994
       *     "Plume puts Ashumet Pond at risk." Cape Cod Times, Jan. 5, 1995
       *     "Groups complain of cleanup delay," Cape Cod Times, Jan.  14, 1995
       *     "Installation Restoration Program Sponsors Two Public Meetings," Cape Cod
             Times, Jan. 16, 1995
       *     "APCC Urges  Public Pressure To End Delay  In Design Plans For Plume
             Containment," Enterprise, Falmouth, Jan. 17, 1995
       *     "Nat'l Guard Will Change Design Firms," Enterprise, Falmouth, Jan. 17, 1995
       *     "Sense Of Urgency Missing," Enterprise, Falmouth, Jan. 17, 1995
       *     "No Sense Of Urgency," Enterprise, Mashpee, Jan. 17,  1995
       *     "Local officials bristle at Guard rules on cleanup," Cape Cod Times, Jan.  19,
             1995
       *     "Nat'l Guard May Replace Public Team," The Enterprise, Jan. 20, 1995
       *     "Testing Public Trust," The Enterprise, Jan.  24, 1995
       *     "Letter- to-Editor, 'A Question of Self-Respect',"  submitted by Richard Hugues,
             Enterprise, Falmouth,  Jan.  24, 1995
                          Installation Restoration Program

0644tA.B02                                A-16

-------
                                                                      APPENDIX A
       *      "Snake Pond to Be Tested for Pollution," The Sandwich Broadsider, Jan. 26,
              1995
       *      "Falmouth Selectmen Worried About Funds For Plume Cleanup," Enterprise,
              Falmouth, Jan. 27, 1995
       *      "Letter to Washington  Urges  Priority for  Containment Plan," Enterprise,
              Falmouth, Jan. 27, 1995
       *      "Ijetter-to-Editor,  'Support Citizen Activists',"  submitted  by  Paul  Riflrin,
              Enterprise, Falmouth, Jan. 27, 1995
       *      Support Growing For Plume Team; Meeting Thursday," Enterprise,  Mashpee,
              Jan. 31, 1995
       *      "Fearful Consequences," Enterprise, Falmouth, Jan. 31, 1995
       *      "GOP Targets Cleanup Funds," Enterprise, Falmouth, Jan. 31, 1995
       *      "Pollution team gets local backing," Cape Cod Times, Feb. 3, 1995
       *      "Officials List Threats To Bourne's Water Supply," Enterprise, Bourne, Feb. 3,
              1995
       *      "Angry Audience Vows Protest If Base Ends Public Team," Enterprise, Feb. 3,
              1995
       *      "Support For Plume Team Widespread, Solid, Vocal," Enterprise, Mashpee, 3
              Feb. 1995
       *      "Studds sees risk in GOP agenda,  'Base cleanup funds among possible cuts',"
              Cape Cod  Times, Feb. 6, 1995
       *      "Plume Action Team Wants Additional Responsibilities", Enterprise, Feb. 7,
              1995
       *      "Plume Containment Team Seeking Additional Tasks From Guard  Bureau,"
              Enterprise, Feb. 7, 1995
       *      Mashpee/Wakeby  Plume Containment  Delayed If  Combined  With  FS-12,"
              Enterprise, Mashpee, Feb. 7, 1995
       *     Balanced Budget Goals Threaten Base Cleanup Funds," Enterprise,  Feb. 7, 1995
       *      "Letter-to-Editor, 'Protect Groundwater Tonight'," Sandwich Broadsider, Feb. 9,
              1995
       *      "Quick Action Necessary to Stop Cataumet-Bound Pollution," Bourne Courier,
             Feb. 9, 1995
       *      "Cleanup plan returns, but still no action," Cape Cod Times,  Feb. 9, 1995
       *      "Base cleanup needs consensus," Cape Cod Times, Feb. 10, 1995
       *      "Plume Action Team  Leader Wants To Wrap Up  Its Duties," Enterprise,
             Falmouth,  Feb. 10, 1995
       *      "Guard's Minior Sees No More Need For Plume Team," Enterprise, Mashpee,
             Feb. 10, 1995

       *      "Though Local Officials May Comment, Final Decision Rests  With Guard
             Bureau," Enterprise, Mashpee, Feb.  10, 1995
       *      "Guard Bureau Will Decide Fate of Plume Management Process Action Team,"
             Enterprise, Bourne, Feb. 10, 1995
                          Installation Restoration Program

06448A.B02                                A-17                              September 1995

-------
                                                                     APPENDIX A
             "Plume Team Appeals to Senior Board," Enterprise, Mashpee, Feb. 17, 1995
             "General Vezina Reassures Residents," Enterprise, Mashpee, Feb. 17, 1995
             "Keep Team Intact," Enterprise, Falmouth, Feb. 21, 1995
             "Otis cleanup needs monitors," Enterprise, Falmouth, Feb. 21, 1995
             "House cuts base cleanup funds," Cape Cod Times, Feb. 23, 1995
       *     "Congress Waves Ax Over Base Pollution Budget,  " Bourne Courier, Feb. 23,
             1995
       *     "Budget Cuts Could Jeopardize Plume Cleanup," Enterprise, Mashpee, Feb. 24,
             1995
       *     "Bid To Cut Federal Budget May Have An Impact On Base Cleanup," Bourne
             Enterprise, Feb. 24, 1995
       *     "House Republicans Cut Pollution Cleanup Funds," Enterprise, Feb. 24, 1995
       *     "Hearing in plume-containment plan," Cape Cod Times, Feb. 27, 1995
       *     "Plume oversight team should be kept intact," Cape Cod Times, Feb. 28, 1995
       *     "Meeting Tomorrow On Plumes," Enterprise, Mashpee, Feb. 28, 1995
       *     "Plume Plan Aired In Meeting In Mashpee," Enterprise, Mashpee, Feb. 28,1995
       *     "Cleanup should be cooperative venture,"  Cape Cod Times, Mar. 2, 1995
       *     "Otis Schedules Open Pollution Meetings," Mashpee Messenger, Mar. 2, 1995
       *     "Texas Firm Will Design Containment Plan For Plumes," Falmouth, Enterprise,
             Mar. 3, 1995
       *     "Guard Bureau Does Not Inspire Trust When It Comes To The LF-1 Plume In
             Cataumet, Enterprise, Bourne,  Mar. 3, 1995
       *     "Base cleanup plan criticized," Cape Cod Times, Mar. 3, 1995
       *     "Guard And Op-Tech  Reach  Agreement On Design Contract,"  Enterprise,
             Mashpee, Mar. 3, 1995
       *     "Toxic  Plume  Slowly  Creeps Into Cataumet Causing  Citizen   Concern,"
             Enterprise, Bourne, Mar. 3, 1995
       *     "Selectmen  Voice Concerns  Over Pollution Cleanup  Funding,"  Sandwich
             Broadsider, Mar. 9,  1995
       *     "Water District Nearing Decision To Seek Otis Pollution Damages," Sandwich
             Broadsider, Mar. 9,  1995
       *     "Cleanup contract expected to be awarded this week," Cape Cod Times, Mar. 10,
             1995
       *     "A one-sided account of base cleanup," Cape Cod Times, Mar. 10,  1995
       *     "Base Senior Management Board Agrees  To Evening Meetings For Working
             Public," Enterprise, Mar. 10, 1995
       *     "Op-Tech, Guard Get Down  To Details On $4.1 Million Plan  to Contain
             Plumes," Enterprise, Mar. 14,  1995
       *     "Pollution Cleanup Under Attack,"  Bourne Courier/Mashpee Messenger, Mar.
             16, 1995
       *     "Air Force Officer Say Working Groups Have Merits,"  Enterprise, Mar. 17,
             1995
       *     "Support PAT Team," Enterprise, Falmouth, Mar. 17, 1995
                         Installation Restoration Program

0644SA.BQ2                               A-18

-------
                                                                    APPENDIX A
       *     "Future  of Plume  Management Team On Agenda  Thursday,"  Enterprise,
             Mashpee, Mar. 21, 1995
       *     "Plume management team needs  support," Enterprise, Mar. 21, 1995
       *     "Group begins to address practical realities of base cleanup," Cape Cod Times,
             Mar. 22,  1995
       *     "Group begins to address practical realities of base cleanup," Cape Cod Times,
             Mar. 22,  1995
       *     "Base Officials Say APCC Using Scare Tactics," Enterprise, Mar. 24, 1995
       *     "Bureaucratic Mismanagement Stalling Cleanup, APCC Charges," Mar. 24,1995
       *     "Guarding The Public Interest," Enterprise, Mashpee, Mar. 28, 1995
       *     "Plume Members Will Join Renamed Team," Enterprise, Mashpee, Mar. 30,
             1995
       *     "Selectmen, National Guard Bureau Kiss, Make Up," Mashpee Messenger,
             Mar. 30,  1995
       *     "Back on  Track," Bourne Courier, Mar. 30,  1995
       *     "Public Representation  Allowed  On New  Team For Plume Containment,"
             Enterprise, Mar. 24, 1995
       *     "Upper Cape residents win say in base cleanup," Cape Cod Times, Mar. 24,
             1995
       *     "Test Wells In Bourne Village Reveal Low Levels Of Contamination In Water,"
             Enterprise, Falmouth, Mar. 31, 1995
       *     "State Mediator Will Assist Teams In Base  Cleanup Process," Enterprise,
             Mar. 31,  1995
       *   ,  "Senate Bill Would Cut $5M From Base Cleanup Funding," Enterprise, Mar. 31,
             1995
       *     "Facilitator To Aid Meetings On Plumes," Enterprise, Mashpee, Mar. 31,  1995
       *     "Tasks For Plume Team 'Still A Little Murky'," Enterprise, Mashpee, Mar. 31,
             1995
       *     "Deal cuts Otis budget," Cape Cod Times, Apr. 6, 1995
       *     "Newcomer On Pollution Cleanup," Bourne Courier,  Apr. 6, 1995
       *     "Cleanup team should reflect community," Cape Cod Times, Apr. 7, 1995
       *     "Governor's Influence Needed," Enterprise, Mashpee, Apr. 7, 1995
             "National Guard, Public Working Toward Same Goal," Enterprise, Mashpee,
             Apr. 7, 1995
             "Petitioners  On Base  Cleanup Set Goal of 5,000 Signatures," Enterprise,
             Falmouth, Apr. 7, 1995
             "With Contract Already Signed, Plume Containment Design Won't Be Affected
             By Cuts," Enterprise, Apr.  11, 1995
             "Falmouth  Resident Starts Petition or Gov.  Weld," Enterprise,  Mashpee,
             Apr. 11, 1995
             "Cleanup Program Seeks Team Members," Sandwich Broadsider, Apr. 13, 1995
                         Installation Restoration Program

06448A.B02                               A-19                             September 1995

-------
                                                                   APPENDIX A
       *     "Team to review design schedule for military base cleanup," Cape Cod Times,
             Apr. 11, 1995
       *     "A Straggle Against Propaganda," Enterprise, Falmouth/Mashpee, Apr. 11,1995
       *     "Base Cleanup Meeting Schedule Announced," Cape Cod Times, Apr. 12, 1995
       *     "Guard Announces Public Meetings," Bourne Courier, Apr. 13, 1995
       *     "Water District Sinks  Test Well On MMR In Effort To Find New Source,"
             Enterprise, Bourne, Apr. 14, 1995
       *     "This Is Your Chance To Clean Up Cape Cod," Cape Cod Times, Apr. 16,1995
       *     Cataumet Plume Committee Organizes Petition Drive," Bourne Courier, Apr. 20,
             1995
       *     "New Plume Teams To Have 20 Members," Enterprise, Falmouth/Mashpee,
             Apr. 21, 1995
       *     "Plume Design Plan Ready For March 1996," Enterprise, Apr. 21, 1995
       *     "Design Firm Targets 1996 For Containment Plant," Enterprise, Apr. 25, 1995
       *     "LF-1 Plume and Property Values," Enterprise, Bourne, Apr. 28, 1995
       *     "Pressure On Bourne Officials," Enterprise, Bourne, Apr. 28, 1995
       *     "Book Follows Plumes, Money Trail," Enterprise, Mashpee, May 5,  1995
       *     "APCC President Praises Seth Holbein's Research," Enterprise, Mashpee, May 5,
             1995
       *     "APCC's "The  Enemy Within1 Follows  Plumes, Money  Trail," Enterprise,
             Mashpee, May 5, 1995
       *     "Community teams to oversee cleanup system construction," Cape Cod Times,
             May 11,  1995
       *     "Political Pressure Needed To Secure Containment Finds," Enterprise, Mashpee,
             May 12,  1995
       *     "Legislators' Help Needed To Save Base Funds," Enterprise, Mashpee, May 12,
             1995
       *     "Plume Teams Light On Mashpee Representation," Enterprise, May 16, 1995
       *     "Bourne, Mashpee Want More  Representation  On Plume Action Teams,"
             Enterprise, May 16, 1995

       *     "Group Anxious Over Plume Cleanup", Bourne Courier, May 18, 1995
       *     "APCC Announces Conference on Otis, Bourne Courier, May 18, 1995
       *     "Bourne Requests Priority Status," Enterprise, Bourne, May 19, 1995
       *     "Citizen Group Urges Residents To Protection Coalition's Position," Enterprise,
             Bourne, May 19, 1995
       *     "Officials Recommend A Full Court Political Press," Enterprise, Bourne,
             May 19,  1995
       *     "Window Of Opportunity," Enterprise, Bourne, May 19, 1995
       *     "Congress Hears From Cape Codders," Enterprise, May 19, 1995
       *     "More Pressure Needed On Congress," Enterprise, May 19, 1995
       *     "Johns Pond,  Containment Plan Report Given Monday," Enterprise, May 19.
             1995
                         Installation Restoration Program

0644IA.B02                               A-20

-------
                                                                     APPENDIX A
       *     "Conference to focus on Cape base clean-up, Cape Cod Times, May 22, 1995
       *     "Cleanup Report Tomorrow," Enterprise, Mashpee, May 23, 1995
       *     "Father Of Cancer Victim Makes Appeal  To Congress  For Containment
             Funding," Enterprise, Mashpee, May 23, 1995
       *     "OpTech Hires Three Interns For Containment," Enterprise, May 23, 1995
       *     "Keep An Eye On $1.6 Billion," Enterprise, Mashpee, May 26, 1995
       *     "Mashpee Residents Urged To Become More Involved With Base Cleanup,"
             Enterprise, Mashpee, May 26,  1995
       *     "Ailing boy's father appeals for base cleanup," Cape Cod Times, May 29, 1995
       *     "New book assails base cleanup," Cape Cod Times, May 30, 1995
       *     "Contaminated Plume Reaches Carriage Shop  Road,"  Enterprise, Mashpee,
             May 30, 1995
       *     " APCC Plans Conference:  'State Of The Base'", Enterprise, Mashpee, May 30,
             1995
       *     "Self-Correcting,"  Enterprise, Mashpee, May 30, 1995
       *     "A United Front," Enterprise, May 30, 1995
       *     "Get the Facts on Otis Pollution Saturday," Bourne Courier, June 1, 1995
       *     "Space Available for Otis Pollution Forum," Bourne Courier, June 1, 1995
       *     "Space Available for Otis Pollution Forum," Bourne Courier, June 1, 1995
       *     "Buzzards Bay Coalition Clarifies Plume Position," Bourne Courier, June, 1,
             1995
       *     "Selectmen move to protect money for base cleanup," Cape Cod Times, June 1,
             1995
       *     "Fire Training Plume About 10 Feet  Under Ashumet," Enterprise, Mashpee,
             June 2, 1995
       *     "No proof of malfeasance in Otis Cleanup," Enterprise, Mashpee,  June 2, 1995
       *     "Feigenbaum absence reflects division over base cleanup," Cape Cod Times,
             June 2, 1995
       *     "$200 Million Cut Proposed In Base Cleanup Funding," Enterprise, Mashpee,
             June 2, 1995
       *     "Base Clean Up Team Hosts  Meeting  For  Realtors," Enterprise, Mashpee,
             June 2, 1995
       *     "Adversaries agree on need for funds," Cape Cod Times, June 4,  1995
       *     "It's time to start the cleanup,"  Cape Cod Times, June 4, 1995
       *     "Realtors To Get Update On Plumes, Programs By MMR," Enterprise, June 6,
             1995
       *     "Plume Containment Funding Topic Of Emergency Meeting, Enterprise, June 6,
             1995
       *     "Congressional Funding For Plume Containment Is 'At A  Critical Phase'",
             Enterprise, June  6, 1995
       *     "Coalition  Needed To Secure Funds For Plume Plan," Enterprise, Mashpee,
             June 6, 1995
                          Installation Restoration Program

06448A.B02                                A-21                             September 1995

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                                                                     APPENDIX A
       *     "Governor's Help Sought For MMR Funding," Enterprise, Mashpee, June 6,
             1995
       *     "Time For United Front," Enterprise, Falmouth, June 6, 1995
       *     "Cape Delegation Will Ask Gov. Weld To Help Secure  Funds For Base,"
             Enterprise, Mashpee, June 6, 1995
       *     "Alliance Will Plan Course Of Action For Base Issues," Enterprise, Mashpee,
             June 6, 1995
       *     "Pollution versus budget," Cape Cod Times, June 7, 1995
       *     "An APCC Oversight," Bourne Courier, June 8, 1995
       *     "Public Deserves A Speedy Rectification," Mashpee Messenger, June 8, 1995
       *     "Selectmen Outline Their Goals Before  Chamber   Base Cleanup, Public
             Transportation, Jobs," Enterprise, Falmouth, June 9, 1995
       *     "Base  Activists Hope To Pressure Gov. Weld With Petition, Rally At  State
             House," Enterprise, June 9,  1995
       *     "Session on base held for realty agents," Cape Cod Tunes, June 12, 1995
       *     "Residents Urged To Write Weld, Congress About Plume Funds,* June 13,1995
       *     "State House Rally To Urge Weld To Help Get Base Cleanup Funds," Enterprise,
             Mashpee,  June 13, 1995
       *     "Falmouth Will Provide Buses To Boston For Rally To Push For Base Cleanup
             Funds,'
       *     "Pressure  On All Fronts," Enterprise, Falmouth, June 13, 1995
       *     "Group to press Weld on base cleanup funds," Cape Cod Times, June 13,  1995
       *     Cuts may  affect toxic cleanup at Cape base," Cape Cod Times, June 14, 1995
       *     "Pollution at air base cuts home values," Cape Code Times, June 14, 1995
       *     "Containment Process, Need For Wells Explained To Upper Cape Realtors,"
             Enterprise, June  16, 1995
       *     "Realtors   Learn  More Environmental Questions  Loom  Ahead," Bourne
             Enterprise, June  16, 1995
       *     "Protesters ask Weld to back base cleanup," Cape Cod Times, June 16, 1995
       *     "Mashpee Residents Join Protest To Get Weld's Help With Base," Enterprise,
             Mashpee,  June 16, 1995
       *     "Gov. Weld Out Of Town For Base Rally,"  Enterprise, Mashpee, June 16,1995
       *     "During 'Base Cleanup Week,' A Look At  One Of The Activists Who Brought
             Us This Far," Enterprise, Mashpee/Falmouth, June 16, 199
       *     "Designer of Plume Containment Plan Targets  Large Parcels Of State, Town
             Land For Wells,  Enterprise,  June 16,  1995
       *     "Water District Is Not The Bad Guy," Enterprise, Bourne, June 16, 1995
       *     "'Direct action' for the base," Cape Cod Times, June 18, 1995
       *     "50 New Test Wells Planned Near Plumes, *  Enterprise, Mashpee, June 20,1995
       *     "Otis Contractor to Play Hide and Seek With Plumes," Mashpee Messenger,
             June 22, 1995
       *     "Water District:  We Won't Back Down," Bourne Courier, June 22, 1995
       *     "Good Book, Bad Timing," Sandwich Broadsider, June 22, 1995
                         Installation Restoration Program

0644JA.B02                               A-22

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                                                                    APPENDIX A
       *     "LF-1 Committee Will Host Awareness Day On Plume From Base," Enterprise,
             Bourne, June 23, 1995
       *     "Team I Will Discuss Plume Containment," Enterprise, Bourne, June 23, 1995
       *     "Public must act on threats to community," Cape Cod Times, June 25, 1995
       *     "Bourne's Example," Enterprise, June 27, 1995
       *     "Military  Concedes  to  Portion  Of  District's  Pollution Claim,  Sandwich
             Broadsider, June 29, 1995
       *     "Bourne Water District Won't Back Down," Sandwich Broadsider, June 29,1995
       *     "Cataumet Group Announces 'Plume Day'," Bourne Courier, June 29, 1995
       *     "Otis Pollution Book an Important Read," Sandwich Broadsider, June 29, 1995
       *     "Weld says cleanup is essential for base," Cape Cod Times, June 30,  1995
       *     "Plume Activists  Applaud LF-1 Committee's  Education  Day," Enterprise,
             Bourne, June 30, 1995
       *     "A Community Problem," Enterprise, Bourne, June 30, 1995
       *     "Selectmen  Seek  Help From  Gov.  Weld  On Base  Funding," Enterprise,
             Falmouth, June 30, 1995
       *     "Abatement Talk May Do More Damage To Values Than Pollution," Enterprise,
             Bourne, June 30, 1995
       *     "Water District Will Press Guard Bureau To Pay For Replacement Wells,"
             Enterprise, Bourne, June 30, 1995
       *     "Weld Pressures Defense Dept. On Cape Cod Cleanup Funds," Enterprise,
             Mashpee, June 30,  1995
       *     "Weld seeks Clinton help  to get $ for  Cape  cleanup," Boston Herald, July 1,
             1995
       *     "Plume Awareness  Day succeeds in sharing information," Cape Cod Times,
             July 2, 1995
       *     "Gov. Weld  Agrees To Help Secure Base Funds," Enterprise, Mashpee, July 4,
             1995
             "Report On Cleanup Funding," Enterprise, Mashpee, July 4, 1995
             "Welcome Aboard,  Governor," Enterprise, July 4,  1995
             "No Cleanup, No Training," Enterprise, July  4, 1995
             "Cataumet Learns Firsthand About Otis Pollution," Bourne Courier, July 6,1995
             "Meeting to discuss base cleanup," Cape Cod Times, July 6, 1995
             "Cape Cod's Strongest Card," Enterprise,  July 7, 1995
             "APCC Appeals For Help To Secure Funds For Cleanup," Enterprise, July 7,
             1995
             "Congressional Delegation Needs  Help Getting Base Cleanup Funds, APCC
             Says,"  Enterprise, July 7, 1995
             "APCC Asking Summer Residents, Visitors To Help Rally Support For Clean Up
             Funds," Enterprise,  Bourne, July 7, 1995
             "Pollution closes well in Sandwich," Cape Cod Times, July 7, 1995
             "LF-1 Plume Awareness Day Is A Success By All Accounts," Enterprise Bourne,
             July 7, 1995
                         Installation Restoration Program

06448A.B02                               A-23                             September 1995

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                                                                      APPENDIX A
       *     "Water District Wins Accord But Cataumet Loses Battle," Enterprise, Bourne,
             July 7, 1995
       *     "Plume Containment Team Angry With Gov. Weld For His Lack Of Action,"
             Enterprise, July 7, 1995
       *     "A Successful Event," Enterprise, Bourne, July 7, 1995
       *     "Pace of base cleanup faulted," Cape Cod Times, July 7, 1995
       *     "Seeking Help On Base Funding," Enterprise, Mashpee, July 11, 1995
       *     "Potential Reuse of Treated Water Troubles Containment Advocates," Enterprise,
             Mashpee, July 11, 1995
       *     "Base Management Board Stands Firm Against Plan To Prioritize Containment,"
             Enterprise, Mashpee,  July 11, 1995
       *     "Summer Residents Can Help," Enterprise, July 11, 1995
       *     "Firm Nears Completion  of Search For More Wells," Enterprise, Mashpee,
             July 11, 1995
       *     "Base  Management  Team Holds  To   Decision  To  Contain  Plumes
             Simultaneously," Enterprise, July 11, 1995
       *     "Guard to  fund new Bourne Water District wells," Cape Cod Times, July 12,
             1995
       *     "Base Cleanup a Priority, Official Says," Sandwich Broadsider, July  13, 1995
       *     "Otis  Board Seeks  Commitment For  Pollution  Cleanup Funds,"  Mashpee
             Messenger, July 13, 1995
       *     "Federal cuts threaten cleanup of base's pollution," Cape Cod Times, July 13,
             1995
       *     "Otis Board Attempts to Seek Commitment For Promised Pollution Cleanup
             Funds," Bourne Courier, July 13, 1995
       *     "Summer Residents, Irked By Military Pollution Chose To Take Activist Roles,"
             Enterprise, Bourne, July 14, 1995
       *     "Bourne's Awareness Day About Base Pollution Praised By Residents And Base
             Officials,"  Enterprise, Bourne, July 14, 1995
       *     "Base Continues With Long Range  Water Supply  Plan,"  Enterprise, Bourne,
             July 14,  1995
       *     "Make Our Officials Aware," Enterprise, Mashpee, July 14, 1995
       *     "Public Action On Plumes Discussed In Mashpee," Enterprise, July  14, 1995
       *     "Citizen Involvement On Rise," Enterprise, Mashpee, July 18, 1995
       *     "$200 Mill Cut From Base Cleanup Funds," Enterprise, July 18, 1995
       *     "Action By Residents," Enterprise, July 18, 1995
       *     "County Weighs Law  Suit Against Base," Enterprise, Mashpee, July 28, 1995
       *     " APCC Seeking Cleanup Support At County Fair," Enterprise, Mashpee, July 28,
             1995
       *     "Use of treated base water weighted," Cape Cod Times, Aug. 1, 1995
       *     "Group say no to  proposal to rescue cleaned Otis water," Cape Cod Times,
             Aug. 7, 1995
       *     "Mr. Keating's Rosy Scenario," Enterprise, Mashpee,  Aug. 8, 1995
                          Installation Restoration Program

0644SA.BC3                                A-24                              Septan** 1995

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                                                                      APPENDIX A
       *     "Treated Plume Water Will Be Reinjected," Enterprise, Mashpee, Aug. 8, 1995
       *     "Bourne Water District  Finds Promising Source For Future Well Field On The
             Base," Enterprise, Bourne, Aug. 11, 1995
       *     "Seeks Permit For Test  Well," Enterprise, Bourne, Aug. 11, 1995
       *     "Treated Groundwater  From Base  Should  Be  Returned  To The Aquifer,
             According To Process Action Teams," Aug. 11, 1995
       *     "Board seeks plan to speed base cleanup," Cape Cod Times, Aug. 12, 1995
       *     "Senator Kerry, Base Team Discuss Plume Containment," Enterprise, Aug. 18,
             1995
       *     "Kerry: Cleanup funding probable," Cape Cod Times, Aug. 19, 1995

       *     "Sen. Kerry Optimistic  On Plume Containment Funds," Enterprise, Aug. 22,
             1995
       *     "Senator Kerry  Offers  Cape  Codders Hope About Containment  Funding,"
             Enterprise, Aug. 22, 1995
       *     Design, Cleanup Funding Remains  Top Priority For Management Board,"
             Enterprise, Aug. 25, 1995
       *     "Plume Meeting Today At 5:15," Enterprise, Aug. 29, 1995
       *     "Plume's migration rate  alarms Cataumet activists," Cape Cod Times, Aug. 30,
             1995
       *     "Mashpee test well drilling under way," Aug. 30, 1995
       *     "2,000-Foot Shocker LF-1 Plume Under Homes In Cataumet," Bourne Courier,
             Aug. 31, 1995
       *     "Public Relations Plan For Base Cleanup Has Been Revised," Enterprise, Bourne,
             Sep. 1, 1995
       *     "Plume's Advance Convinces District To Shut Off Wells," Enterprise, Bourne,
             Sep. 1, 1995
       *     "LF-1 Plume 2,000' Farther Into Cataumet Than Military Predicted," Enterprise,
             Mashpee, Sep. 1, 1995
       *     "Now Psychological Impacts," Enterprise,  Mashpee, Sep. 1, 1995
       *     "Latest Plume Findings Shut Down Two Wells In Bourne," Enterprise, Bourne,
             Sep. 5, 1995
       *     " WHOI Scientist Files FOI Request For Digital Data On Base Wells," Enterprise,
             Mashpee, Sep. 8, 1995
       *     "Opposition  To Plume  Treatment Plants In Residential Areas," Enterprise,
             Mashpee, Sep. 8; 1995
       *     "Guard Hopes To Shorten Bid Process By 40 Days," Enterprise,  Mashpee,
             Sep. 8, 1995
       *     "Defense Dept. Reaffirms Commitment For Base Funds," Enterprise,  Mashpee,
             Sep. 8, 1995
       *     "Senior Board  Stands  Firm  On Simultaneous  Containment Of  Plumes,"
             Enterprise, Mashpee, Sep. 8, 1995
       *     "National Guard Plans To Prioritize Plume Containment," Sep.  8, 1995
                          Installation Restoration Program

06448A.B02                                A-25                              September 1995

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                                                                     APPENDIX A
       *     "Residents Express Fear, Anger About Pollution, Enterprise, Mashpee, Sep. 8
             1995
       *     "Otis cleanup gets budget priority," Cape Cod Times, Sep. 9,  1995
       *     "Residents Near Base Speak of 'Unacceptable Risks',",  Enterprise, Mashpee,
             Sep. 12, 1995
       *     "Plume Containment Teams Announce Meeting Schedule," Enterprise, Sep. 12,
             1995
       *     "Civilians Merely Window Dressing?," Enterprise, Sep. 12, 1995
       *     "Naming Plume Group Team One Continues To Create Controversy," Enterprise,
             Sep. 12, 1995
       *     "Language Of MMR's Priority Status Passes," Enterprise, Sep. 12,  1995
       *     "Plume Water Use Limited," Enterprise, Sep.  12, 1995
                          Installation Restoration Program

0644SA.B02                               A-26

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                            APPENDIX B



                   STATE CONCURRENCE LETTER
                     Installation Restoration Program




06448A.B02                                                      September 1995

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             Commonwealth of Massachusetts
             Executive Office of EnvironmentahAffajrs
             Department of
             Environmental  Protection
             Southeast Regional Office
  WUItem F. W«ld
   Trudy Cox*
   Sccrauiy, EOEA
  David B. Strurw
 Mr.  John DeVillars
 Regional Administrator
 U.S.  EPA Region 1
 JFK  Federal Building
 Boston,  Massachusetts 02103

 and
September 29, 1995

RE:  BOURNE—BWSC—4-0037
     Massachusetts Military
     Reservation, Containment of
     Seven Groundwater Plumes
     Record of Decision For
     Interim Action Concurrence
 Major  General  Donald W.  Shepperd
 Director,  United States  Air National Guard
 2500 Army  Pentagon
 Washington,  D.C.   20310
Dear Mr.  DeVillars  and  General Shepperd:

     The  Department of Environmental Protection (the "Department11)
has  reviewed   the   "Record  of  Decision  for  Interim  Action,
Containment  of Seven Groundwater  Plumes" (the "Interim Action")
recommended  by the  National Guard Bureau and the U.S. EPA for an
interim   cleanup  and  containment  action  of  seven  groundwater
contaminant  plumes  at  the  Massachusetts Military  Reservation
("MMR") National Priorities List  ("NPL")  site.  These  seven areas
of groundwater contamination are referred  to as:  the Landfill-1
(LF-1) Plume, the Storm Drain-5 (SD-5) Plume,  the Western Aguafarm
Plume,  the  Eastern  Briarwood  Plume,  the Fuel  Spill-12  (FS-12)
Plume, the Chemical Spill-10 (CS-10)  Plume and the Ashumet Valley
Plume.

     The  Interim  Action is designed to  control and prevent  the
continuing   downgradient   migration  of  the  seven   groundwater
contaminant plumes until a final remedy is chosen and implemented.
The  Interim Action consists  of  a  series  of extraction  wells
positioned at the leading edge(s)  of each plume and hot spot areas
and is designed to capture an area encompassing the full  width  and
depth of  each plume.  Groundwater will be extracted and  pumped to
a treatment  system  in order to remove Volatile Organic  Compounds
(VOCs)  and other chemicals and clean water will be returned to  the
groundwater  and/or   other  beneficial   reuse.     In   addition,
groundwater  monitoring  wells will  be installed  downgradient  and
crossgradient of the extraction system and will be sampled in order
to determine the effectiveness of and monitor the performance  of
    20 RlvcrsJcte Drlv* • Uktvilto, MasMChuMtts 02347 • FAX (508) 947-6557 • TttophotM (SOS) 948-2700

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                                -2-

 the Interim Action.

      A review of this Interim Action will be conducted after five
 years of operation to ensure that it provides adequate protection
 of human health and the environment.  The  Interim Action will be
 operated for an estimated twenty years, during which time the seven
 groundwater  contaminant plumes will be  fully characterized and
 options for final remedies will be evaluated.

      The  Department  has   evaluated the  Interim   Action  for
 consistency with Massachusetts General Laws ("M.G.L.") Chapter 21E
 and the Massachusetts Contingency Plan (the  "MCP"),  310 CMR 40.0000
 and other State  laws and regulations.  The  Interim Action appears
 to meet all  identified Massachusetts Applicable or  Relevant and
 Appropriate Requirements (ARARs).  The Department concurs with the
 Interim Action and will continue to evaluate compliance with ARARs
 as the remedial design progresses and during the implementation and
 operation of this  Interim Action.

      As the Department has noted in previous correspondence,  the
 MCP requires  that remedies either achieve  site specific background
 levels  as long term cleanup goals or, if not feasible, levels of no
 significant risk.   It is  the  Department's  opinion  that it  is
 important to evaluate the  feasibility  of  achieving  background
 levels  of contaminants for  the final remedy,  and hope that  the
 information obtained  during the  implementation  of  the  Interim
 Action  will be used  for this purpose.

      The  Department  looks  forward  to  working   with you   and
 facilitating  an  expeditious cleanup of the MMR NPL site. If  you
 have any questions, please contact Leonard J.  Pinaud at (508)  946-
 2871.
                                       ,  Regional Director
                         Department of Environmental Protection
C/LJP/rr
cc:  DEP - SERO
     ATTN: Andrea Papadopoulos
           Leonard Pinaud
           Lynne Doty
           Don Nagle
           Kevin Kiernan

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                               -3-
cc:  OEP - Boston
     ATTN: Ed Kur.£e
           Madeline Snow
           Andrew Cohen

     SMB Distribution

     TEAC Distribution

     Team One Distribution

     Team Two Distribution

     Long Range Water Supply PAT Distribution

     Boards of Selectmen

     Boards of Health

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                                                                        APPENDIX B
                            [This page intentionally blank]
                           Installation Restoration Program




06448 A.B02                                                                   September 1995

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                          APPENDIX C

  SUMMARY OF COMMENTS AND NGB RESPONSES RECEIVED DURING
                 THE PUBLIC COMMENT PERIOD
                    Installation Restoration Program

06448A.B02                                                  September 1995

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                                                                     APPENDIX C
                 SUMMARY OF COMMENTS RECEIVED DURING
             THE PUBLIC COMMENT PERIOD AND NGB RESPONSES
 This Responsiveness Summary addresses comments received by the National Guard Bureau
 (NGB) and United States Environmental Protection Agency (EPA) during the public comment
 period from February 10 to March 11, 1995. Comments were submitted in two forms.  At the
 public hearing on March 1, 1995, oral testimony was given which has been transcribed verbatim
 and placed into the administrative record for this project.  The administrative record is available
 for review at the main Falmouth Public Library, 13 {Catherine Lee Bates Road, Falmouth, Mass.
 A total of 16 people gave oral testimony representing the following affiliations:  State legislative
 delegation; Sierra Club; Cataumet LF-1 Committee; Otis Conversion Project;  Association for
 the Preservation of  Cape Cod;  Falmouth Selectmen's Office; Responsible Environmental
 Protection for Sandwich (REPS); Alliance for Base Cleanup; Upper Cape Concerned Citizens;
 Coalition for Buzzards Bay; and area residents.

 A total of  14 written  comment  letters were  submitted representing  the following:   State
 legislative delegation; Cape Cod Commission, Falmouth League of Women Voters; Association
 for the Preservation  of Cape Cod; Sandwich Water District; Sierra Club; REPS; and area
 residents.

 The comments received by the NGB were categorized and  summarized into the following 13
 groups:

       (1)    Areas of higher levels of groundwater contamination, or "hot spots."
       (2)    Nitrates contained within the Ashumet Valley Groundwater Plume.
       (3)    Public  Participation during  design and  implementation of the seven plume
             containment project.
       (4)    Differences between the Plume Response Plan (June 1994); Proposed Plan for
             Interim Action, Containment of Seven Groundwater Plumes (Feb. 1, 1995); and
             other reports.
       (5)    Phosphorus from the MMR Wastewater Treatment Plant and threats to Ashumet
             Pond.
       (6)    Technical plume containment design issues. Most effective methods for selection
             of technologies, types of treatment.
       (7)    Unforeseen problems during design and construction.
       (8)    Data gaps to be filled through the field effort.
       (9)    Prioritization and simultaneous plume containment.
       (10)   Federal Facilities Agreement (FFA)  and  schedule  and  design/construction
             schedule shortening.
      (11)   Hydraulic balance of the aquifer, use of treated water.
      (12)   Interim vs. final action.
      (13)   Funding issues.
                          Installation Restoration Program

06448A.B02                                 C~l                              September 1995

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                                                                    APPENDIX C
 Quite evident in many of the letters received and in testimony given at the public hearing was
 concern about the future role of the Plume Management Process Action Team (PAT) during the
 design and construction activities.  The PAT was instrumental in compiling and finalizing the
 Plume Response Plan which was the basis for the Proposed Plan and this Record of Decision.
 The Plume Response Plan developed by the PAT received an endorsement from the DoD in July
 1994. The issue of continued tasking for the Plume Management PAT is one which will not be
 addressed as part of this  Responsiveness  Summary,  because  it  is not relevant to remedy
 selection.  The Proposed Plan for which the public comment period and public hearing  were
 held, did not cover the issue of continued tasking for the PAT. That issue is under the purview
 of the Senior Management Board which was created by the NGB to review the work of the
 Plume Management PAT and two other PATs, and to provide advice to the NGB.

 AREAS OF HIGHER LEVELS OF GROUNDWATER CONTAMINATION, OR "HOT
 SPOTS"

 Comment:  Nine (9) commenters had concerns over the following related issues.  Hot spots
 should be addressed and should be treated simultaneously along with the seven plumes.  The
 Record of Decision should reflect the agreement from last year that hot spot remediation will
 take place.

 Response:   The  NGB  and the  USEPA both  see benefits in addressing higher levels of
 contamination as it would significantly aid in the long term cleanup of the plumes.  At this time,
 however, sufficient data has not been developed to adequately define the location and extent of
 the hot spot(s).  Thus, hot spot treatment will be evaluated during the design analysis phase of
 the project by performing additional groundwater monitoring in areas where previous areas of
 high concentrations have been detected.  If feasible, hot spot treatment will be implemented as
 part of the  seven plume containment project.  This determination will be made by  the NGB,
 BPA, and the State upon consideration of several factors, including technical feasibility of hot
 spot contaminant removal, impact of additional remediation on the overall plume containment
 schedule, and costs. White hot spot remediation may be desirable for a number of reasons, the
 selected interim remedy (containment and institutional  controls) will be protective  of human
 health and the environment even if hot spot remediation is not implemented as part of the interim
 remedy.

 NITRATES CONTAINED  WITHIN THE  ASHUMET VALLEY  GROUNDWATER
 PLUME

 Conjpienfr  Five (5) commenters  had concerns over the following related issues:  The fate of
 Nitrogen in the treatment process needs  to be addressed, allowing it to be distributed to other
 areas of the aquifer if not treated is a concern.  The nutrient portion of the Ashumet Valley
 Plume should be contained downgradient from  the leading edge of the solvent portion of the
 plume.
                          Installation Restoration Program

0644IA.B02                                C-2

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                                                                     APPENDIX C
 Response:  As part of the design process,  the Ashumet Valley Plume will be evaluated to
 identify all constituents, including nitrates (or nutrients).  Money that funds the IRP cleanup
 program (DERA funds) cannot be used solely to investigate or remediate nutrients since they are
 not "hazardous substances" under CERCLA.  Therefore, no cleanup levels have been established
 for nitrates. The location of the extraction well fence, which will be determined during remedial
 design, will be located at the leading edge of the solvents plume and the nutrient portion of the
 plume extending beyond that will  not be addressed as part of this interim remedy.  However,
 to the extent that nutrients are contained within the solvents plume,  they will be contained and
 treated with the plume water to be extracted as part of the interim remedy.

 PUBLIC  PARTICIPATION DURING DESIGN AND IMPLEMENTATION  OF THE
 SEVEN PLUME CONTAINMENT PROJECT

 Comment: Eight (8) commenters  had concerns over the following related issues:

       (1)    Continue public participation activities such as public  meetings, hearings, and
             comment periods, accessibility to IRP personnel, and continued participation by
             individuals and groups that are involved in the process.
       (2)    Explore and maximize  opportunities for public involvement throughout the
             cleanup process.
       (3)    Provide local residents who will be closest to the construction activities with
             adequate notification and information.
       (4)    Inadequate public participation activities could result in unforeseen delays.
       (5)    Provide information to public representatives involved in lobbying Congress and
             urging DoD officials to make a strong  case  for  cleanup programs before
             Congress.
       (6)    Tours of the CS-4 treatment plant on-base should be given.

 Response: Public participation activities for the IRP at the MMR will continue to be performed
 through the Joint Public Involvement/Community Relations Plan.  The plan is a framework for
 encouraging  public  participation.   Activities  beyond those specified  in the plan  will be
 undertaken as necessary to accomplish the goal of informing and involving the public throughout
 the myriad of activities at the MMR. In 1994, over SO public meetings were held involving the
 seven community working groups created by the NGB to encourage public participation in the
 process.  We expect this trend to continue and increase as is necessary. The NGB is currently
 pursuing  other avenues for community involvement to include:  use of cable television for
 meeting announcements, conducting talk shows, airing important public meetings and  video
 documentaries about ongoing activities.  Also to be sought will be more frequent interaction with
 the local news media, providing education about the status of the cleanup and seeking advice
 from them on how to best report the many events being planned for the next three years as part
 of the plume containment project.  Involving stakeholders in the process is critical to the success
 of the project.   It is the intention  of the NGB to meet with local neighborhood associations,
 boards of health, public works people, etc., as many times as necessary to ensure that all issues
                          Installation Restoration Program

06448A.B02                                C-3                              September 1995

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                                                                     APPENDIX C
 are addressed in an expedited but more importantly, a safe manner. Information on the status
 of the cleanup can be obtained from a variety of sources such as the IRP Office, USEPA and
 Mass. DEP, the main libraries of Falmouth, Mashpee, Sandwich, and Bourne and the on-base
 U. S. Coast Guard Library.  A site mailing list is maintained by the NGB which presently
 contains over  1,400 people.  Paid advertisements announcing meetings and public comment
 periods is  a  standard practice.   Tours are conducted frequently of the Chemical Spill 4
 groundwater treatment facility on-base, and the extraction wells located off-base in the Crane
 Wildlife Management Area of Falmouth.  Speaking engagements at schools,  universities, and
 civic groups also are part of the extensive public affairs program for the IRP, all part of efforts
 to inform and involve the public.

 DIFFERENCES BETWEEN THE PLUME RESPONSE PLAN (JUNE 1994); PROPOSED
 PLAN FOR  INTERIM ACTION,  CONTAINMENT  OF SEVEN  GROUNDWATER
 PLUMES (FEB. 1, 1995); AND OTHER REPORTS

 Comment:  Five (5) commenters had concerns over the following related issues:  The Plume
 Response Plan should have been used as the Proposed Plan.  Descriptions of LF-1 and CS-10
 are inadequate as contained in the Proposed Plan and should be revised to reflect certain
 materials (barrels of contaminated  fuel at LF-1 and nuclear weapons and rocket fuel at CS-10),
 because they are relevant to possible health risks and cleanup.  Language used in the Proposed
 Plan demonstrates a reversal from the previous Plume Response Plan in terms of providing
 assurances for hot spot treatment,  simultaneous and rapid containment,  filling  in data gaps and
 continued public involvement.

 Response:  The intention of a Proposed Plan is to clearly summarize the alternatives evaluated,
 and state the preferred alternative.  The rationale for the preferred alternative is clearly discussed
 by using the evaluation criteria identified in the Proposed Plan. The Plume Response Plan (June
 1994) does not meet the requirements under CERCLA for a Proposed Plan which is a necessary
 document under the terms of the FFA between the NGB and USEPA.   To a great extent, the
 Plume Response Plan was used as the basis for the Proposed Plan. The main difference is that
 the Plume Response Plan, which served as the Feasibility Study, was carefully written to make
 it clear that the lead agencies (NGB AND USEPA) have not made a decision in regard to a
 preferred alternative and is open to suggestion on  how the preferred alternative or other
 alternatives might be modified to better satisfy cleanup objectives at the site.  Descriptions of
 she activities from the Task 6 1986 report were written to include all possibilities for each site
 for various  types of chemical releases.  Since then, much is known through investigation work
 at the LF-1  and CS-10 source areas. No large area of metal barrels were ever indicated at the
 LF-1  location and thus it is not believed that barrels play a major factor in the contaminants
 emanating from the source area.   Although BOMARC missiles were  maintained at CS-10,
 investigations have not indicated any radioactivity, rocket fuel or their breakdown constituents.
 In addition, in record reviews and interviews, there was no indication of concern regarding these
 issues.  As part of the CERCLA process, source areas must also be addressed.   This is
 occurring at LF-1 by virtue of a multi-layer capping project currently under construction.
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                                                                    APPENDIX C
 Limited source area cleanup has occurred at CS-10 by removing contaminants from underground
 drainage structures.  More work is planned at this site.  Placing all information about source
 areas from the Task 6 report in a proposed plan for groundwater containment is not practical and
 has no bearing on the preferred alternative outlined in the Proposed Plan.

 PHOSPHORUS  FROM THE MMR WASTEWATER TREATMENT  PLANT AND
 THREATS TO ASHUMET POND

 Comment:  Three (3) commenters had concerns over the following related issues.  Phosphate
 impact on Ashumet and Johns Ponds now and in the future.  This issue should be addressed in
 an expedited manner.

 Response:  Phosphorus has been found in groundwater emanating from the base's wastewater
 treatment plant, and it is impacting Ashumet Pond. Recent studies by the U. S. Geological
 Survey estimate that septic systems and fertilizers account for approximately SO percent of
 nutrient loading of Ashumet Pond, while the other 50 percent  is attributable to the phosphorus
 portion of the Ashumet Valley Plume.  Phosphorus can have serious effects on a pond leading
 to eutrophication.  The 102nd Fighter Wing has funded over $370,000 in studies for which the
 IRP has provided oversight management. Since phosphorus  is  not a hazardous substance under
 CERCLA, the IRP  cannot expend  funds to investigate and mitigate impacts to the pond.
 However, the IRP has  worked with the  102nd Fighter Wing over the past few years to aid in
 investigating and defining the problem.  In January 1994, the  102nd Fighter Wing announced
 that it had appropriated $166,000 in additional funding to fully identify the extent of phosphorus
 between  the treatment plant and Ashumet Pond and to evaluate alternatives   for potential
 remedial actions.  The focus of phosphorus investigations has  been on Ashumet Pond as Johns
 Pond is not threatened  by the phosphorus from the base's wastewater treatment plant.

 TECHNICAL PLUME CONTAINMENT DESIGN ISSUES

 Comment:  Eleven (11) commenters had concerns over the following related issues.   There
 needs to be flexibility  and room for growth.  The most effective evaluation and selection of
 technologies must occur.  On-site regeneration and membrane technology must be evaluated.
 Use of the most modern technologies is important.  The fate of adsorbed volatile and semi-
 volatile organic compounds that may occur in the inorganic pre-treatment process needs to be
 addressed along with how the spent material will be handled if this is a problem. EDB at the
 CS-4  plume's leading  edge needs addressing along with consideration of long-term power
 requirements for the plume containment system. The evaluation criteria for system performance
 needs to  be outlined. The issue of a central treatment unit  (CTU),  individual treatment units
 (JTUs) and multiple treatment units (MTUs) needs resolution.  The least disruptive alternative
 should be chosen. Treatment units should be placed on base or on public property, not private
property. Lack of detail in the Proposed Plan may mean that certain activities will not be looked
 at or engaged by the NGB because they are not specifically listed.  A report prepared by a
 consultant to the  Sandwich Water District  should  be  evaluated and considered.   A joint
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                                                                        APPENDIX C
 containment effort between the NGB and DEP in Sandwich should be evaluated and supported.
 The NGB's consultants have minimized potential impacts to the District's Well No.  5.  All
 remedial activities at FS-12 should look to minimize impacts on Snake Pond and Well No. 5.
  Consider the use of innovative technologies to remove non-aqueous phase liquids (NAPLs) or
 pollutants sorbed  to the sedimentary particles if proven to be a long term source of pollution.
 Based on the schedule contained in the Proposed Plan for design and construction, the plan
 cannot contain the LF-1 plume prior to  its arrival in the business district of Cataumet and thus
 it is only a six plume plan.   Quality of design versus speed of design needs to be carefully
 addressed.  Over  design of extraction well systems is a concern as well as locating them near
 the leading edge of the plume and not far downgradient as was the case at CS-4. Engineering
 for  aboveground  construction should be a simple matter.

 Response:  The response to this question will be presented in the order of the comments raised:

       (1)    flexibility  and room for  growth: the treatment system to be constructed will
              contain excess capacity, and in addition, will be constructed in a modular fashion
              that will easily allow for future expansion,  if necessary.
       (2)    effective evaluation of technologies:   during the design analysis, a  
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                                                                    APPENDIX C
             is being addressed by the MA DEP.  A further evaluation of this option was
             performed by the DEP, and it was noted that there may be a small cost savings
             if the  two groundwater plumes  are combined  into  one treatment  system.
             However, it was also noted that there would be a significant delay in the time to
             begin treating the groundwater from the DEP site, since this system is already
             well into design.  Therefore,  based on this evaluation, it was determined not
             feasible to combine the two groundwater plumes into one treatment system.
       (8)    LF-1 plume and business district:  all efforts will be made to contain all of the
             plumes as quickly as possible, and to minimize any impacts to local residents and
             business districts.
       (9)    location of extraction wells:  during the design analysis, groundwater monitoring
             will be performed to determine the most recent locations of  the groundwater
             plumes. Based on this information, the location of the extraction wells will be
             proposed as near as possible to the leading edge of the plumes.  However, one
             of the items that must be considered is the potential location of the extraction
             wells.  If it is  more feasible and less disruptive to locate extraction wells on
             public or base property as opposed to private property, all efforts will be made
             to do so.

UNFORESEEN PROBLEMS DURING DESIGN AND CONSTRUCTION

Comments:  One  (1) commenter had a concern over the following issue.  It is likely that
problems may arise during the data gap effort and the construction effort. More contamination
may be found in both of these efforts and this possibility must be addressed now by the NGB
and USEPA.

Response:  As part of the design contract, the design analysis and data gap effort includes
provisions for extensive groundwater monitoring and installation of additional wells and borings
to fully define the extent of the plumes.  Any new or additional information developed during
this effort will be evaluated and addressed in order to design and construct an extraction and
treatment system which will address all of the issues identified during the design effort.

DATA GAPS TO BE FILLED THROUGH THE FIELD EFFORT

Comment: Four (4) commenters had concerns over the following related issues. A portion of
the SD-S Plume appears to have already passed the tentative location of extraction wells at the
edge of Johns Pond.  The possibility of a portion of the plume making it past the other side of
Johns Pond needs to be evaluated. Drawing out large quantities of water and replacing it could
have serious impacts such as allowing the SD-S plume to bypass the extraction wells or change
the direction that the plume is currently moving in.  Since the plumes won't be contained for
several years it seems that the plumes'  parameters could change drastically thus affecting the
ability to stop them.  There should be a way to predict where the plumes will be when the
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                                                                     APPENDIX C
 system is to go on line to stop the plumes.  The exact locations of the plumes needs to be known
 before the design can be done.

 Response:  The exact location of extraction wells for the SD-5 Plume will be determined during
 the design analysis phase in conjunction with results from the data gap field effort. It is possible
 that the extraction wells will be located so  that a portion of the  plume will be beyond their
 influence, thus discharging to Johns Pond as computer modelling  has demonstrated.  It is not
 believed that any solvents could make it past the  other side of Johns Pond due to the intense
 hydraulic gradient present underneath the pond which pulls water in from great depths. A pump
 test will be conducted to aid in the design of an extraction system to prevent the plume from
 changing directions or bypassing the extraction wells. This will be done for many of the plumes
 as part of the data gap field effort, concurrent with  the design analysis. A pump test has already
 been conducted for the FS-12 groundwater  plume.   There will be sampling of existing
 monitoring wells, installation of new wells, and computer modelling to identify exactly where
 the plumes are now  and where they  will be when the extraction systems are ready to be
 installed.

 PRIORITIZATION AND SIMULTANEOUS PLUME CONTAINMENT

 Comment:  Six (6) commenters had concerns over the following related concerns.  Plumes
 posing the greatest public health risk should be addressed first.  Wording should be included in
 the Proposed Plan specifying "total and simultaneous containment of seven plumes," along with
 a commitment to an accelerated schedule.

 Response:  The Proposed Plan was developed on the concept of simultaneous containment of
 the seven plumes over a two year construction period.  This concept will be followed through
 the design process, and the final design analysis will determine the actual system configuration.

 Alternatives to the simultaneous approach may have to  be considered if the funding should not
 be received as planned for the first  year of construction.

 FEDERAL  FACILITIES   AGREEMENT   (FFA)   AND   SCHEDULE  AND
 DESIGN/CONSTRUCTION SCHEDULE SHORTENING

 Comment:  Sixteen (16) commenters had concerns  over the following related concerns.  Every
 effort should be made to condense  and accelerate  the design and construction schedule.  It is
 hard to comprehend why it takes so long to  design and construct  a system that, for the most
part, has already been designed. It is hard to believe that the containment won't begin until the
 year 2,000 and have to operate for 20 years to get it  under control.  The schedule for
 implementation of the Proposed Plan needs to be formally established and enforceable by the
USEPA under the FFA. Time is of the essence, particularly for the LF-1 plume. Enough data
 has been gathered to allow computer models to accurately place the extraction wells without
having to go through a lengthy design process.  This would save time, and money because the
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                                                                     APPENDIX C
 plume fronts continue to expand which means it will cost more to contain the longer they are
 allowed to move.  Compress the time schedule for plume containment to 18 months from 42
 months.  The Proposed Plan should be rewritten to reflect that the 42-month period was not
 unanimously agreed upon by the Plume PAT members.  A lack of urgency in terms of human
 health is sensed.   A detailed  commitment to reducing  design and construction schedules is
 needed.  Rigorous  enforcement is needed by the USEPA but also by the DEP. The plan does
 not say that the unit will be in operation on 42 months.

 Response:  The seven plume containment project will most likely be one of the largest public
 works construction projects on Cape Cod. Because of this, the NGB saw the need to hire a
 management consultant with experience in managing all the intricate details involved with design
 and construction. CH2MHU1, of New Jersey, is the consultant providing this support. They will
 work to have the most efficient flow of communication between all parties involved and to look
 for ways to streamline and shorten the process, while at the same time helping to ensure that the
 design that is done  is of high quality. All the specifications and drawings for this project will
 be done as part of the design.  Although much is known about the seven plumes  from  past
 investigations, additional information is needed and will be gathered through conducting pump
 tests of the aquifer, sampling  existing monitoring wells  and installing new wells.  Computer
 modelling will be used to help guide the design. Based on the schedule from the Proposed Plan,
 the project would be on-line in early 1998.  Once operational, the seven plume containment
 system will operate for a minimum of 20 years, or until a final remedy for the entire plumes is
 chosen and implemented. The schedule for design and construction in the Plume Response Plan
 (June 1994) was 42 months,  and   was  the shortest  schedule possible  based on known and
 anticipated factors  affecting the project.  The NGB  will look for and  implement actions to
 streamline the process and save time but it is also committed to having a high quality design and
 installation.  Along with this are public  health concerns.  The project must be designed  and
 implemented with the protection of the public's health being the number one priority and it will
 be. The groundwater operable units (seven plumes) for each of the sites is covered  under the
 FFA and is enforceable. Both the USEPA and the NGB work very closely with the Mass. DEP
 on all issues related to this and other projects. The Proposed Plan does state on Page 6-3  that
the time for design  and construction is 42 months  and it is estimated that the time of operation
will last a minimum of 20 years or until a final remedy is selected and implemented.

HYDRAULIC BALANCE OF THE AQUIFER, USE OF TREATED  WATER

Comment:  Two (2) commenters had concerns over the following related issues.  The Proposed
Plan must remain committed to maintaining hydraulic balance within the aquifer.  Case studies
or conceptual models need to be evaluated. Other uses of treated water should not be explored.
To stop and correct groundwater degradation is the plan's basic premise.  Striving for a policy
of maintaining a sustainable supply of high quality untreated drinking water should be a goal.
There is more to be known about  the hydrological balance on the Upper Cape and a  lot of
modelling  should be done.  Seek advice from agencies like the U. S.  Geological Survey.
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                                                                       APPENDIX C
 Response: During the design analysis, modeling will be performed to determine the effects and
 any impacts of discharging the treated groundwater at one or several locations.  Hydraulic
 balance is a top priority to ensure that there are no impacts to local water bodies as  a result of
 discharging the treated groundwater.  A careful evaluation of this important item will be
 performed.

 INTERIM VS. FINAL ACTION

 Comment:  Five (5) commenters  had concerns over the following  related issues.  Additional
 extraction wells should be installed on-base to prevent additional contaminants from migrating
 off-base.  This would ensure a definite cleanup of portions of the plumes.  The plan  only stops
 the plumes and doesn't address all the damage done to date. I'm concerned about the full extent
 of the plumes and whether the cleaned water will be re-contaminated. The containment process
 should continue until the final groundwater remedy  is installed. Long term solutions to the
 entire plumes should look at innovative technologies. The Proposed Plan should clearly  state
 the intention for the final cleanup of the plumes and an assurance from the responsible party for
 this project and for that period of time.

 Response: The design analysis portion of the design will evaluate various scenarios in order to
 achieve the goals of the selected remedy for containing these seven plumes. Although installing
 additional extraction wells in other areas of the plumes would aid in remediating more of the
 plumes, that action is consistent with the final remedy for the full bodies of each of the plumes.
 The final remedy has not been decided on  yet.  The one exception to this is that areas of higher
 groundwater contamination will be evaluated and if found to be feasible to treat, will become
 part of the seven plume containment project. The seven plume containment project is considered
 interim.   In the future, a Final Record of Decision  will  be  issued by the NGB and USEPA
 addressing the course of action for dealing with the entire bodies of the seven plumes. It is the
 goal of the NGB to minimize impacts to the aquifer and not re-contaminate clean water.  The
 design analysis will ensure that cleaned water is placed in an area that will ensure it remains
 clean.

 FUNDING ISSUES

 Comment: Seven (7) commenters had concerns  over the  following related issues.  It appears
 that with political changes in Washington, D.C., and cut-backs that this project will be tabled
 or dissolved.  The Pentagon must honor its commitment to fund the containment plan.  Funding
 must  be tnaint^itMH for this plan as well  as for  the final remedy.  Both the USEPA and the
 military must commit to the $250 million.   The prospect for funding would be improved if this
project were incorporated as a line hem in the federal budget for the DoD and to have a senior
 staff officer assigned to ensure implementation as will be outlined in the design.  Actions should
 be undertaken to ensure that the pending re-authorization of Superfund law does not remove the
Polluter Pay principal of liability, nor institute cost benefit analysis as the basis for choosing the
appropriate remedy for mitigation.
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0644IA.M2                                C-10                              S«p«MriMr 1995

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                                                                        APPENDIX C
 Response:   The NGB is proceeding expecting that the construction funding for the next two
 fiscal years will be provided as committed to by DoD in July  1994.  This project has been
 identified as the number one priority for funding in FY96 and FY97 for both the Air and Army
 National Guard.

 In  a recent  letter,  Ms. Sherri W. Goodman,  Deputy Under  Secretary of Defense  for
 Environmental Security,  in response to a question on the provision of funding for this project
 cautions "...the military services are doing the best they  can to  execute consistent, reliable
 cleanup plans; however, our funding has been reduced by Congress by more than a billion
 dollars over the last three fiscal years. Given these reductions and the current Congress* pursuit
 of further  spending cuts (including the recision of funds already appropriated), changes  in
 execution plans are inevitable, especially for the largest projects."

 The NGB  is committed  to obtaining the  most cost-effective and  effective cleanup program
 possible within the funding available; execution plans, however,  may need to change.
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                                                                        APPENDIX C
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