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
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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
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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.
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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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[This page intentionally blank]
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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.
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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
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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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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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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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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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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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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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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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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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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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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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06448A.B02 6-1 September 1995
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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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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/
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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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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
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Sources: Modfod horn Plum* Rnpom* Plift, CtMioml Ttdrategw Cop.. Ml;
USGS POUIMI Oualnngto
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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
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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
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CS-10 PLUME
Wwl Fence Locnlons
MASSACHUSETTS MILITARY RESERVATION
C»».. «•«; U«Q8 Htmm Ou
FIGURE 6-6
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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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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).
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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
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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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0644IA.B02 8-2
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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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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
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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
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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.
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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.
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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.
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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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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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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.
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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.
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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
-------
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
-------
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
-------
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
§
-------
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
-------
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
-------
*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
-------
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.
§
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
Installation Restoration Program
06448A.B02 11-17 Stpuatoer 1995
-------
SECTION 11
[This page intentionally blank]
Installation Restoration Program
0644SA.M2 H-lg Stptnter 1995
-------
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.
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SECTION 13
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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.
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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.
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REFERENCES
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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
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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
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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
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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.
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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
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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.
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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.
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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.
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GLOSSARY OF TECHNICAL TERMS
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APPENDIX A
ADMINISTRATIVE RECORD INDEX
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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
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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
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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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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
06448A.BQ2 A-6 ' S
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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
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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
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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
0644IA.B02 A-10 S*pt«nb«r 1995
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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
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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
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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
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-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
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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.
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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.
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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
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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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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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