PB96-963702
                                 EPA/ROD/R01-96/119
                                 November 1996
EPA  Superfund
       Record of Decision:
       Fort Devens South Post Impact Area
       and Area of Contamination 41 Groundwater
       and Areas of Contamination 25, 26, & 27, MA
       7/5/1996

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                 DECLARATION FOR THE RECORD OF DECISION
                         SOUTH POST IMPACT AREA AND
               AREA OF CONTAMINATION 41 GROUNDWATER AND
                    AREAS OF CONTAMINATION 25, 26, AND 27
                         FORT DEVENS, MASSACHUSETTS
 STATEMENT OF PURPOSE

 In December 1989, Fort Devens was listed as a National Priorities List (NPL) site under the
 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).  The Fort
 is located in Middlesex and Worcester counties and is within the towns of Ayer, Harvard,
 Lancaster, and Shirley, Massachusetts.  Seventy-three study areas (SAs) and areas of
 contamination (AOCs) at Fort Devens have been investigated under CERCLA.

 This Record of Decision (ROD) addresses AOCs 25 (Explosive Ordnance Disposal (EOD)
 Range), 26 (Zulu Ranges), and 27 (Hotel Range) and AOC 41 groundwater and a subset of the
 groundwater within the South Post Impact Area (SPIA). This subset is located north and west of
 the groundwater divide and covers approximately 964 acres. This area is referred to in this
 document as the "SPIA monitored-area" and is shown in Figure 1 of Appendix A. The SPIA is
 approximately 1,500-acre and is located within the 4,800-acre South Post section of Fort Devens.
 This Record of Decision presents the selected remedial action for the site, chosen in accordance
 with CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA),
 and, to the extent practicable, the National Contingency Plan (NCP). This ROD does not affect
 assessment or remedial activities on areas not specifically mentioned herein.

 AOC 41 groundwater has been added to this ROD since the public meeting based on the results
 of the Final Remedial Investigation (RI) completed for AOC 41 (February 1996). The RI
 indicates that proposed actions are the same for the SPIA monitored-area and AOC 41
 groundwater, AOC 41 is adjacent to the SPIA monitored-area, and AOC 41 is small  in area (6
 acres). Adding AOC 41 to this ROD would only increase the total land area covered in this ROD
 by 0.6 percent.  Therefore, the U.S. Environmental Protection Agency-(USEPA) New England
 (Region I)  recommended including AOC 41 groundwater in this ROD.

 The Fort Devens Base Realignment and Closure (BRAC) Environmental Coordinator, the
 Commander Devens Reserve Forces Training Area (RFTA), and the USEPA-New England
 Administrator have been delegated the authority to approve this ROD.

 The Commonwealth of Massachusetts has concurred with the selected remedy. A copy of the
 declaration of concurrence is included as Appendix B of this ROD.
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 STATEMENT OF BASIS

 This decision is based on the Administrative Record for the site that was developed in accordance
 with Section 113(k) of CERCLA. The Administrative Record is available for public review at the
 Fort Devens BRAC Environmental Office, Building PI2, Fort Devens, Massachusetts, and the
 Ayer Town Hall, Main Street, Ayer, Massachusetts. The Administrative Record Index (Appendix
 C of the ROD) identifies each of the items composing the Administrative Records upon which the
 selection of the remedial action is based.

 ASSESSMENT OF THE SITE

 Risk assessment results show that human health risks were  identified to be within USEPA risk
 guidelines for the pathways that were assessed. Risk to on-site ecosystems, in some instances,
 were found to be outside of USEPA risk guidance; however, their impacts were deemed
 acceptable.

 DESCRIPTION OF SELECTED REMEDY

 "No action" is the selected remedy for SPIA monitored-area groundwater, AOC 41 groundwater,
 and the surface water, sediment, and soils at the EOD, Zulu, and Hotel Ranges.  Under this
 alternative, no forma] remedial action will be taken and the  site will be left "as is," with no
 additional institutional controls, containment, removal, treatment, or other mitigating measures.
 Long-term groundwater monitoring will be conducted at the site under this "no action" ROD.

 The Army along with USEPA-New England and Massachusetts Department of Environmental
 Protection (MADEP) will develop and implement a long-term Integrated Natural Resources
 Management Plan and a Groundwater Monitoring Plan for the South Post of Fort Devens. These
 plans will be developed within 6 months of ROD signature.

 Should the Army close or transfer or change the use of the property an Environmental Baseline
 Survey (EBS) will be conducted, and the "no action" decision of this ROD will be re-examined in
 light of the  changed risk factors resulting from this closure/transfer. The EBS will be provided to
 the USEPA-New England and MADEP for comment.

 DECLARATION STATEMENT

 No remedial action is necessary to ensure the protection of human health and the environment
 unless the land use changes. Under CERCLA, any action that results in contaminants remaining
 on-site must be reviewed at least every 5 years. During 5 year reviews, an assessment is made of
 whether the implemented remedy remains protective of human health and the environment and
 whether alternative remedial actions are needed to ensure adequate protection.
C:\0102\DELIVER\SPU\FINALROD\FRODH.WPD                                               J<«« '*•

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 The foregoing represents the selection of a remedial action by the Department of the Army and
 the USEPA-New England, with the concurrence of the Commonwealth of Massachusetts
 (MADEP). Concur and recommend for immediate implementation:

 UNITED STATES DEPARTMENT OF THE ARMY
                                                       37
 JAMES c. CHAMBERS                                  Date
 :ort Devens
 BRAC Environmental Coordinator
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 The foregoing represents the selection of a remedial action by the Department of the Army and
 the USEPA-New England, with the concurrence of the Commonwealth of Massachusetts
 MADEP. Concur and recommend for immediate implementation:

 UNITED STATES DEPARTMENT OF THE ARMY
 H. Carter Hunt, Jr.
 Commander
 Devens Reserve Forces Training Area (RFT A)
Date
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 The foregoing represents the selection of a remedial action by the Department of the Army and
 the USEPA-New England, with the concurrence of the Commonwealth of Massachusetts
 MADEP.  Concur and recommend for immediate implementation:

 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
      >;^
      M. Murphy           / /                       //Date//   /
 Director of the Office of Site Remediation and Restoration
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                     RECORD OF DECISION SUMMARY
                     SOUTH POST IMPACT AREA AND
             AREA OF CONTAMINATION 41 GROUNDWATER AND
                 AREAS OF CONTAMINATION 25, 26, AND 27
                     FORT DEVENS, MASSACHUSETTS

                          TABLE OF CONTENTS
 Section                                                          Page No.

 EXECUTIVE SUMMARY ................................................. ES-1

 I.     SITE NAME, LOCATION, AND DESCRIPTION ............................ 1

 H.    SITE HISTORY AND ENFORCEMENT ACTIVITIES ........................ 2
      A.    Land-Use and Response History ..................................... 2
      B.    Enforcement History  ............................................. 3

 m.    COMMUNITY PARTICIPATION ........................................ 4

 IV.    SCOPE AND ROLE OF THE RESPONSE ACTION .......................... 5

 V.    SUMMARY OF SITE CHARACTERISTICS ................................ 6
      A.    Groundwater [[[ 6
      B.    Surface Water  .................................................. 8
      C.    Sediments [[[ 9
      D.    Soils [[[ 10

 VI.    SUMMARY OF SITE RISKS ........................................... 11
      A.    Baseline Risk Assessment Approach and Assumptions ................... 11
           1.     Exposure Pathways for the Human Health Risk Assessment ......... 12
           2.     Exposure Pathways for the Ecological Risk Evaluation  ............ 12
      B.    Baseline Risk Assessment Results ................................... 13
      C.    Ecological Risk Assessment ....................................... 16
      ARMY RATIONAL FOR PROPOSING "NO ACTION" ...................... 17

Vm.   DESCRIPTION OF THE NO ACTION ALTERNATIVE ...................... 17

IX.    DOCUMENTATION OF SIGNIFICANT CHANGES ........................ 19
      A.    Site History [[[ 19
      B.    Summary of Site Characteristics .................................... 20

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                    RECORD OF DECISION SUMMARY
                    SOUTH POST IMPACT AREA AND
            AREA OF CONTAMINATION 41 GROUNDWATER AND
                AREAS OF CONTAMINATION 25, 26, AND 27
                    FORT DEVENS, MASSACHUSETTS

                         TABLE OF CONTENTS
                              (continued)

 Section                                                      Page No.

      C.    Summary of Groundwater Impacts	23
      D.    Summary of Risks  	23
      E.    Army's Rational for Proposing the Preferred Alternative	24

 X.    STATE ROLE	25

 APPENDIX A - FIGURES
 APPENDIX B - DECLARATION OF STATE CONCURRENCE
 APPENDIX C - ADMINISTRATIVE RECORD INDEX
 APPENDDC D - RESPONSIVENESS SUMMARY
 APPENDDC E - TABLES
 APPENDDC F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS
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                               EXECUTIVE SUMMARY
 Fort Devens is located in Middlesex and Worcester counties and is within the towns of Ayer,
 Harvard, Lancaster, and Shirley, Massachusetts. Seventy-three study areas (SAs) and areas of
 contamination (AOCs) at Fort Devens have been  investigated for potential environmental
 restoration.

 This Record of Decision (ROD) addresses AOCs 25 (the Explosives Ordnance Disposal (EOD)
 Range), 26 (Zulu Ranges), and 27 (Hotel Range) and a subset of the groundwater within the
 South Post Impact Area (SPIA). This subset is located north and west of the groundwater divide
 and covers approximately 964 acres.  This area is referred to in this document as the "SPIA
 monitored-area" and is shown in Figure 1 of Appendix A.

 AOC 41  groundwater has been added to this ROD since the public meeting.  The logic for
 including the AOC 41  groundwater in this ROD is based on the results of the Final Remedial
 Investigation (RI) completed for AOC 41 (February 1996). The  RI indicates that (1) proposed
 actions are the same for the SPIA monitored-area and AOC 41 groundwater, (2) AOC 41 is
 adjacent to the SPIA monitored-area, and (3) AOC 41  is small in area (6 acres).  Adding AOC 41
 to this ROD would only increase the total land area covered in this ROD by 0.6 percent. The
 details of AOC 41 groundwater are presented in Section IX of this ROD.  The landfill portion of
 AOC 41 will be addressed under a separate action.

 This ROD presents the selected remedial action for the site, chosen in accordance with
 Comprehensive Environmental Response Compensation and Liability Act (CERCLA), as
 amended by Superfund Amendments and Reauthorization Act (SARA), and,  to the extent
 practicable, the National Contingency Plan (NCP).  This decision is based on the Administrative
 Record for the site. The Administrative Record is a collection of all the documents used by the
 Army in determining the most appropriate action to take at the SPIA monitored-area. The
 Administrative Record is available for public review at the Fort Devens Base Realignment and
 Closure (BRAC) Environmental Office and the Ayer Town Hall, Ayer, Massachusetts.  This ROD
 does not affect assessment or remedial activities on areas not specifically mentioned herein.

 The entire SPIA is approximately 1,500 acres and is located within the 4,800-acre South Post
 section of Fort Devens. The SPIA is, and will be for the foreseeable future, an active weapons
 and ordnance discharge area used by the Army, the Massachusetts National Guard, and nearby
 law enforcement agencies for training purposes.

 Metals, organic compounds, petroleum hydrocarbons, and explosive chemicals were detected in
 soil, sediments, groundwater, and surface water during the Remedial Investigation (RI) of SPIA
 monitored-area groundwater and the EOD, Zulu, and Hotel Ranges.  Using data from the RI, the
 Army prepared a Baseline Risk Assessment to determine potential risks to human health and the
 environment under reasonable exposure assumptions.

No unacceptable risks to human health and the environment were found to be associated with the
 SPIA monitored-area groundwater, even though levels exceeded Army and USEPA action levels.
No hazardous substances were detected in the one drinking water well on the South Post, Well D-

C:\0102\DELIVER\SPIA\FINALROD\FROD18.WPD          ES-1                                June 18. 1996

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 1. Well D-l, which is located near the northeast edge of the SPIA monitored-area, is used on a
 limited basis by military personnel during training activities.  Also, no unacceptable ecological risk
 to surrounding habitats were found to be associated with the SPIA monitored-area groundwater
 due to the absence of a pathway for any known ecological receptor to access the SPIA
 monitored-area groundwater.

 Risk assessment results for the EOD, Zulu, and Hotel Ranges show that human health risks were
 identified to be within USEPA risk guidelines for assessed pathways.  Risk to on-site ecosystems,
 in some instances, were found to be outside of USEPA risk guidance; however, ecological risks
 identified on the EOD, Zulu, and Hotel Ranges were deemed to be acceptable due to the
 continued use of the Impact Area for military training activities. Risk assessment results for AOC
 41 show that there is no unacceptable risk to human health from the groundwater at the South
 Post Well D-l nor are site-related  contaminants adversely impacting ecological receptors in New
 Cranberry Pond.

 "No action" is the selected remedy for the SPIA monitored-area groundwater and AOC 41
 groundwater. Under this alternative, no formal remedial action is taken and the site is considered
 to be left "as is," with no  additional institutional controls, containment, removal, treatment, or
 other mitigating measures. "No action" is also the selected remedy for the surface water,
 sediment, and soil at the EOD, Zulu, and Hotel Ranges.  The Army has submitted a Closure
 Report under the Resource Conservation and Recovery Act (RCRA) Subpart X; formal approval
 of the closure of EOD Range will occur prior to ROD signature.

 As part of this remedy, Fort Devens will ensure the following:

        •     Groundwater monitoring for potential contaminant migration out of the SPIA
              monitored-area will continue:

                    Wells will be used to monitor the groundwater from the EOD Range, Zulu
                    Ranges, Hotel Range, and AOC 41.

                    Wells will be used to monitor the north, northeast, southeast, and east sides
                    of the SPIA monitored-area.

         •   The monitoring wells will be sampled for explosives, Target Compound List
             (TCL), and the Target Analyte List (TAL) metals.

         •   A Groundwater Monitoring Plan for the South Post will be  developed that will
             include detailed groundwater monitoring at discharge points. The plan may
             include installing sentinel wells to monitor potential off-site  groundwater flow.
             Details of the plan will be developed jointly by the Army,  USEPA-New England,
             and Massachusetts Department of Environmental Protection (MADEP) within 6
             months of ROD signature. The Army will rerun the groundwater model to
             incorporate data from new sentinel well(s) and ascertain any potential impacts to
             MCI  Shirley.
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         •    Well D-l will be sampled and analyzed for explosives and Massachusetts and
              Federal drinking water requirements (MMCLs/MCLs).

         •    The Army will not develop new drinking water sources within the SPIA
              monitored-area.

         •    An Integrated Natural Resources Management Plan will be developed and
              implemented to  monitor the impacts to ecosystems in the SPIA monitored-area.
              The details of this plan will be developed jointly by the Army, USEPA-New
              England, U.S. Fish and Wildlife Service, and MADEP within 6 months of the ROD
              signature.

 Monitoring reports will include a description of site activities and a summary of analytical results.
 The Army will review and submit these monitoring reports to MADEP and USEPA annually.  If
 there is an indication of contamination emanating from the  SPIA monitored-area, the Army will
 evaluate the need for additional assessment.

 This site, as required by CERCLA, will be subject to 5 year reviews.  During a 5 year review, an
 assessment is made as to whether the implemented remedy is protective of human health and the
 environment and whether the implementation of alternative remedial actions are needed to ensure
 adequate protection.  If on-site  hazardous substances, pollutants, or contaminants that may
 present an imminent and substantial endangerment to public health and welfare migrate off site,
 the Army will take the necessary and appropriate actions to protect human health and the
 environment as required under CERCLA. More frequent reviews will be conducted if site
 conditions change.  Should the Army close or transfer or change the use of the property an
 Environmental Baseline Survey (EBS) will be conducted, and the "no action" decision of this
 ROD will be re-examined in light of the changed risk factors resulting from this  closure/transfer.
 The EBS will be provided to the USEPA-New England and MADEP for comment.
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                         RECORD OF DECISION SUMMARY
                         SOUTH POST IMPACT AREA AND
               AREA OF CONTAMINATION 41 GROUNDWATER AND
                    AREAS OF CONTAMINATION 25, 26, AND 27
                         FORT DEVENS, MASSACHUSETTS

                                    June 18,1996
 I.     SITE NAME, LOCATION, AND DESCRIPTION

 In December 1989, Fort Devens was listed as a National Priorities List (NPL) site under the
 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The Fort
 is located in Middlesex and Worcester counties and is within the towns of Ayer, Harvard,
 Lancaster, and Shirley, Massachusetts, approximately 35 miles west of Boston. Seventy-three
 study areas (SAs) and areas of contamination (AOCs) at Fort Devens have been investigated for
 potential environmental restoration.

 This Record of Decision (ROD) addresses AOCs 25 (the Explosives Ordnance Disposal (EOD)
 Range), 26 (Zulu Ranges), and 27 (Hotel Range) and a subset of the groundwater within the
 South Post Impact Area (SPIA). This subset is located north and west of the New Cranberry
 Pond/unnamed stream groundwater divide and covers approximately 964 acres. This area is
 referred to in this document as the "SPIA monitored-area" and is shown in Figure 1 of Appendix
 A.

 AOC 41 groundwater has been added to this ROD since the public meeting. The logic for
 including the AOC 41 groundwater in this ROD is based on the results of the Final Remedial
 Investigation (RI) completed for AOC 41 (February 1996). The RI indicates that (1) proposed
 actions are the same for the SPIA monitored-area and AOC 41 groundwater, (2) AOC 41 is
 adjacent to the SPIA monitored-area, and (3) AOC 41 is small in area (6 acres). Adding AOC 41
 to this ROD would only increase the total land area covered in this ROD by 0.6 percent. The
 details of AOC 41 groundwater are presented in Section DC of this ROD. The landfill portion of
 AOC 41 will be addressed under a separate action.

 The entire SPIA covers approximately  1,500 acres and is located within the 4,800-acre South
 Post section of Fort Devens (Figure 1 of Appendix A).  The SPIA is an active weapons and
 ordnance discharge area used by the Army, the Massachusetts National Guard, and nearby law
 enforcement agencies for training purposes. The area is generally bounded by Old Turnpike
 Road, Firebreak Road, the southern portion of Harvard  Road, Trainfire Road, and Dixie Road.
 The SPIA covers AOCs 25, 26, 27, and 41 as well as several SAs, and a number of other firing
 ranges along Dixie Road and Trainfire Road that are not designated as AOCs.

 This ROD presents the selected remedial action for the site, chosen in accordance with CERCLA,
 as amended by the Superfund Amendments and Reauthorization Act (SARA) and, to the extent
 practicable, the National Contingency Plan (NCP). This decision is based on the Administrative
Record for the site.
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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page 2

 EOD Range (AOC 25) is located east of Firebreak Road, approximately 2 miles south of the
 main entrance to the South Post.  The site is rectangular and measures approximately 600 feet by
 1,500 feet.

 Zulu Ranges (AOC 26) are located 2,000 feet north of the EOD Range (AOC 25),
 approximately 1.6 miles southwest of the main entrance to the South Post. The Zulu Ranges
 cover approximately 16 acres and consist of two adjacent land tracts (Zulu 1 and Zulu 2). Zulu 1
 and 2 cover approximately 10 and 6 acres, respectively.

 Hotel Range (AOC 27) is adjacent to Cranberry Pond and is located approximately 1 mile south
 of the main entrance to the South Post. The Hotel Range covers approximately 23 acres and is
 currently used exclusively for firing small-caliber automatic weapons. The area of concern where
 open burning/open detonation (OB/OD) occurred is located exclusively south of the Old Turnpike
 Road.

 H.     SITE HISTORY AND ENFORCEMENT ACnvnTES

 A.     Land-Use and Response History

 Fort Devens was established as Camp Devens in 1917.  It was used as a temporary training camp
 for soldiers from the New England area. The camp became a permanent installation in 1931 and
 was renamed Fort Devens. Throughout its history, Fort Devens has served as a training and
 induction center for military personnel and as a unit mobilization and demobilization area.  The
 installation was used in this capacity, to varying degrees, during World Wars I and U, the Korean
 War, the Vietnam Era, and operations Desert Shield and Desert Storm.  The primary mission of
 Fort Devens is to command, train, and provide logistical support for nondivisional troop units and
 to support and execute Base Realignment and Closure (BRAC) activities.  The installation also
 supports the Army Readiness Region and the National Guard units in the New England area.

 The South Post consists mainly of undeveloped and under-developed land. In the past, some
 timbering and limited fanning have taken place. The ranges on the South Post are currently used
 for various types of artillery and small arms fire, grenade detonation, and ordnance demolition.
 Managed forest accounts for much of the remainder of the area.

 At least some portion of the SPIA has been used for military training since the inception of Fort
 Devens as Camp Devens in 1917.  At various times, demolition training and OB/OD have been
 conducted at the EOD, Zulu, and Hotel Ranges. A discussion of land-use activities at these
 ranges follows.

 EOD Range (AOC 25) — From 1979 to 1992, approximately 1,200 pounds per year of
 explosives and ammunition were disposed of in the disposal area by OB/OD. A 1-acre disposal
 area is located along the southeastern boundary of the range.  The Army has submitted a Closure
Report under the Resource Conservation and Recovery Act (RCRA) Subpart X; formal approval
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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groimdwater and AOCs 25, 26, & 27	Page 3

 of the closure of EOD Range will occur prior to ROD signature.  Currently, the range operates
 under a RCRA emergency permit and is used once or twice a year.

 Zulu Ranges (AOC 26) — Prior to 1979, the range was used for OB/OD of waste explosives
 and associated waste items. Zulu 1 is primarily used for demolition training.  The demolition
 training area is located in the center of Zulu 1. Zulu 2 is used primarily as a practice range for
 hand grenade training. The grenade training area is located  on the eastern end of Zulu 2 and
 consists of two concrete bunkers, which are used for cover and protection, and two sand pits,
 which are used for receiving grenades.

 Hotel Range (AOC 27) — Before 1979, the Hotel Range was used for OB/OD of small arms,
 smoke grenades, and pyrotechnics.  After 1979, the Hotel Range was modified and extended to
 the north side of the Old Turnpike Road and used for M-16s and small caliber weapons. Prior to
 1989, the range was used as an M-70 range, but after 1989 the range was modified to an M60-
 SAW range.

 B.     Enforcement History

 In conjunction with the Army's Installation Restoration Program (IRP), Fort Devens and the U.S.
 Army Environmental Center (USAEC; formerly the U.S. Army Toxic and Hazardous Materials
 Agency) initiated a Master Environmental Plan (MEP) in 1988.  The MEP assesses the
 environmental status of SAs, specifies necessary investigations, and provides recommendations
 for response actions with the objective of identifying priorities for environmental restoration at
 Fort Devens. The MEP recommended that a record search be conducted to better define past and
 current activities.  It also recommended that the extent of contamination be determined by
 collecting soil samples and analyzing the samples for the United States Environmental Protection
 Agency (USEPA)  hazardous substance list compounds and total petroleum hydrocarbons
 (TPHC). The MEP also suggested installing monitoring wells if hazardous substances were
 detected in deeper soils.

 On December 21,  1989, Fort Devens was placed on the NPL. Fort Devens was listed as an NPL
 site because hazardous substances were detected at two sites other than the EOD, Zulu, and
 Hotel Ranges (volatile organic compound (VOC) contamination in the groundwater at the
 Shepley's Hill Landfill and metal contamination in the groundwater at the Cold Spring Brook
 Landfill). A Federal Facilities Interagency Agreement (IAG) was developed and signed by the
 Army and USEPA-New England (Region I) on May 13, 1991 and finalized on November 15,
 1991.  The IAG provides the framework for  implementing the CERCLA/SARA process at Fort
Devens.

Under Public Law  101-510, the Defense Base Realignment and Closure Act of 1990, Fort Devens
was selected for cessation of operations and closure. However, the SPIA will be retained by the
Army for continued use as a training range.  An important aspect of BRAC  actions is to determine
environmental restoration requirements before property transfer can be considered.  As a result,
an Enhanced Preliminary Assessment (PA) was performed at Fort Devens to address areas not

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27          Page 4

 normally included in the CERCLA process, but that required review prior to base closure.
 Although the Enhanced PA covers MEP activities, its main focus is to determine if additional
 areas require detailed records review and site investigation. The Enhanced PA also provides
 information and procedures to investigate installation-wide areas requiring environmental
 evaluation.  A final version of the Enhanced PA report was completed in April 1992,

 RIs were prepared for the SPIA monitored-area groundwater and EOD, Zulu, and Hotel Ranges.
 These were submitted to the USEP A-New England and the Massachusetts Department of
 Environmental Protection (MADEP) in August 1994. A Proposed Plan and summary Fact Sheet
 have been prepared for the SPIA monitored-area groundwater and EOD, Zulu, and Hotel Ranges.
 These documents have been placed in the Administrative Record and are available for public
 review at the Fort Devens BRAC Environmental Office and the Ayer Town Hall, Ayer,
 Massachusetts.

 m.   COMMUNITY PARTICIPATION

 The Army has kept the community and other interested parties apprised of site activities through
 regular and frequent informational meetings, fact sheets, press releases, and public meetings.

 After receiving public comments on an earlier draft, the Army released a final Community
 Relations Plan in February 1992.  The plan outlines a program to address community concerns
 and inform citizens, as well as involve them in activities during remedial activities.  As a part of
 this plan, the Army established a Technical Review Committee (TRC) in March 1991. The TRC,
 as required by SARA Section 211 and Army Regulation 200-1, includes representatives from
 USEP A-New England, USAEC, Fort Devens, the MADEP, local officials, and the community.
 The committee provided review and technical comments on work products, schedules, work
 plans, and proposed activities for the S As at Fort Devens.  The RI and Feasibility Study (FS)
 Reports, Proposed Plan, and other related support documents were all submitted to the TRC for
 their review and comment.  Additionally, the SPIA monitored-area groundwater and EOD, Zulu,
 and Hotel Range activities were specifically discussed at TRC meetings held September 29, 1992;
 March  31, 1993; and January 26,  1994. A Citizen's Advisory Committee (CAC) was also
 established to address Massachusetts Environmental Policy Act (MUSEPA)/Environmental
 Assessment issues concerning the reuse of property at Fort Devens.

 The TRC typically met quarterly until January 1994, when it was replaced by the Restoration
 Advisory Board (RAB).  As part of the Army's  commitment to involving the affected
 communities, a RAB is formed when an installation closure involves transfer of property to the
 community. The RAB was formed in February  1994 to join members of the CAC with current
TRC members, the RAB consists of 28 members (15 original TRC members plus  13 new
members) who are representatives from the Army, USEP A-New England, MADEP, local
governments, and citizens of the local communities. It meets monthly.  Specific responsibilities
include addressing cleanup issues such as land use and cleanup goals, reviewing plans and
documents, identifying proposed requirements and priorities, and conducting regular meetings
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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page S

 that are open to the public. The proposed plan for the SPIA monitored-area groundwater and
 EOD, Zulu, and Hotel Ranges was presented at the February 1, 1996 RAB meeting.

 During the week of January 29, 1996 the Army published a public notice concerning the Proposed
 Plan and public hearing in the Lowell Sun, The Public Spirit (Ayer), and the Fort Devens
 Chronicle and distributed a summary Fact Sheet to 647 interested parties. The Army also made
 the Plan available to the public at Fort Devens BRAC Environmental Office and the Ayer Town
 Hall.

 From February 1 to March 1, 1996, the Army held a 30-day public comment period to accept
 public comments on the alternatives presented in the Proposed Plan, as well as other documents
 released to the public.  On February 21, 1996 the Army held a formal public meeting at Fort
 Devens to discuss the Proposed Plan and to accept any verbal comments from the public.  A
 transcript of this meeting and the comments and the Army's response to comments are included in
 the attached responsiveness summary (Appendix D).

 All supporting documentation for the decision regarding the SPIA monitored-area groundwater
 and the EOD, Zulu, and Hotel Ranges has been placed in the Administrative Record for review.
 The Administrative Record is a collection of all the documents considered by the Army in
 choosing the remedy for the SPIA monitored-area groundwater and the EOD,  Zulu, and Hotel
 Ranges.  The Administrative Record is available for public review at the Fort Devens BRAC
 Environmental Office and at the Ayer Town Hall, Ayer, Massachusetts. An index to the
 Administrative Record is available at the USEPA-New England Records Center, 90 Canal Street,
 Boston, Massachusetts and is provided as Appendix C. In addition, information repositories that
 contain information relative to ongoing Fort Devens environmental actions are located in the
 Lancaster, Shirley, Harvard, and Ayer libraries.

 IV.    SCOPE AND ROLE OF THE RESPONSE ACTION

 The remedy selected for the SPIA monitored-area groundwater and EOD, Zulu, and Hotel
 Ranges is protective of human health and the environment. Risks to human health were found to
 be within USEPA guidelines, while risks to ecological receptors were found to be minimal.  The
 risks to on-site ecosystems were deemed acceptable.  However, the Army, once the final ROD is
 approved, will develop long-term plans for an Integrated Natural Resources Management Plan to
 address identified concerns. This plan will be completed within 6 months of ROD signature.

 The Army proposes "no action" for the SPIA monitored-area groundwater and the EOD, Zulu,
 and Hotel Ranges.  The Army will maintain control of the South Post for future military training
 activities.  Public access to the site will continue to be restricted, and unauthorized personnel will
be prohibited. Currently, the South Post is enclosed by a fence and access can only be gained
through gates that are controlled by the Army Range Control. However, if the Army were to
 relinquish control and release the land for other purposes, additional assessments will be required
depending on the reuse of the property.
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 V.     SUMMARY OF SITE CHARACTERISTICS

 RIs were conducted for the EOD, Zulu, and Hotel Ranges to characterize the nature and extent of
 site-related contamination. Samples from groundwater, surface water, sediments, and soil were
 taken. Chemical analyses were performed on the samples taken from the various media, and the
 results were compared with screening values previously developed. The results of the chemical
 analyses were reviewed to determine whether hazardous substances detected were related to site
 activities or were naturally occurring.  A detailed presentation of the range characteristics is
 presented in Volumes n, HI, and IV of the RI report for the EOD, Zulu, and the Hotel Ranges,
 respectively.

 A.    Groundwater

 Groundwater at Fort Devens occurs largely in the permeable glacial-deltaic outwash deposits of
 sand, gravel, and boulders. Groundwater is found under the South Post at depths of 0 to 30 feet.
 The flow of groundwater on the South Post is determined by the bedrock and till topography. A
 number of springs can be found around the circumference of SPIA.

 The SPIA can be regarded as predominantly two hydrologic units, one of which drains to the west
 and north and the other to the south and east. These units are determined by the bedrock ridge
 which forms a groundwater divide across the northern portion of the SPIA. As a result of this
 ridge, groundwater from the Zulu and Hotel  Ranges and Cranberry Pond in the northeast corner
 of the SPIA flows north into Slate Rock Brook and Slate Rock Pond. At the same time,
 groundwater from the EOD Range and most of the remaining portions of the SPIA flows
 southeast and east to the unnamed brook and New Cranberry Pond or to the north of New
 Cranberry Pond directly to the Nashua River and its wetland.

 Groundwater in the vicinity of the ranges discharges to surface water before it leaves the South
 Post. More than 50 percent of the SPIA overlies a medium yield aquifer that is a potential source
 of drinking water. MADEP concurrence with this ROD constitutes MADEP's agreement that the
 site is adequately regulated under the provisions of 310 CMR 40,000, the Massachusetts
 Contingency Plan. Measurements of hydraulic head in the groundwater and in streams and ponds
 within the South Post show that the streams around the SPIA are gaining streams (i.e.,
 groundwater discharges into the streams).

 Fort Devens withdraws groundwater from wells on the Main Post and the North Post.  The Fort
 maintains a transient noncommuniry1 supply well, Well D-l,  on the South Post along Dixie Road
 at Echo Range (E) near the north end of Alpha Range (A) (Figure 1 of Appendix A). This well is
not used to serve the general public, but is used to  supply troops who train on the South Post.
       1 Transient noncommunity water system serve at least 25 people per day for at least 60 days
per year, but not the same 25 people each day. Examples include parks, wayside rests, small-sized
resorts and hotels, restaurants, bars, and campgrounds.

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 These troops spend no more than 2 weeks per year at the site.  Fort Devens Range Control Staff
 do not use this well and there are no plans to provide connections to the Range Control Offices.

 Groundwater quality samples collected from Well D-l  show that no chemicals or metals were
 detected at concentrations above USEPA guidelines.  Specifically, five samples have been
 collected from Well D-l (May 1991, June 1991, two samples in April 1992, and March 1993) and
 were analyzed for USEPA's Target Analyte List (TAL) metals, USEPA's Target Compound List
 (TCL), total organic carbon (TOC), and water quality parameters. A summary of results is
 presented in Table 1 in Appendix E. Only one chemical, bis(2-ethylhexyl)phthalate, exceeded a
 screening value (USEPA's Maximum Contaminant Level (MCL)). As two of the samples show
 no detectable concentration of bis(2-ethylhexyl)phthalate, the RI Report attributes the finding of
 this chemical to sampling or laboratory error.

 Groundwater quality samples for the EOD and Zulu Ranges were taken in November 1992,
 March 1993, and June 1993 (Figures 2 and 3 of Appendix E show well locations). Samples were
 collected from eight monitoring wells at the EOD Range and seven wells at the Zulu Ranges.  At
 the Hotel Range, groundwater samples from four wells were taken in September 1992 and
 January 1993, and an additional six wells were sampled as part of the RI in August and November
 1993 (Figure 4 of Appendix A shows well locations).

 The samples taken at the EOD Range were analyzed for TAL metals and explosives, as well as
 hardness.  The samples taken at the Zulu Ranges were analyzed for TCL organics, TAL metals,
 explosives, and TPHC, as well as hardness. Samples taken at the Hotel Range were analyzed for
 TAL metals, TCL pesticides, explosives, TPHC, and water quality parameters.

 EOD Range (AOC 25) — Unfiltered samples from the EOD Range showed levels of iron,
 aluminum, and other metals above the concentrations found in local background samples.
 Background samples are those collected in a similar medium (i.e., water,  soil, sediment) that are
 not believed to be contaminated. Samples that were filtered to eliminate suspended solids (i.e.,
 soil and sediments to which metals may adhere) and measure only the metal dissolved in the
 water, showed concentrations several orders of magnitude lower than in the unfiltered samples
 (Tables 2 and 3 of Appendix E).  Manganese and calcium exceeded background concentrations in
 filtered samples. None of the metals in filtered samples, however, exceeded health-based
 screening values described in the RI report. Four explosives or explosive-related organic
 compounds (cyclonite (RDX), cyclotetramethylene tetranitramine (HMX), pentaerythritol
 tetranitrate (PETN), and trinitrotoluene (TNT)) were also detected in the samples. Only RDX
 exceeded the screening value.  Organic compound results are shown on Figure 5 of Appendix A.

Zulu Ranges (AOC 26) — Metals concentrations in the Zulu Ranges groundwater samples
(unfiltered) were higher than concentrations found in local background samples. As with the
samples collected in the EOD, filtered samples showed lower concentrations than the unfiltered
samples in the Zulu Ranges  (Tables 4 and 5 of Appendix E).  The maximum concentration of
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 manganese in filtered samples (62 micrograms per liter, (ug/L)) exceeded the screening value2(50
 ug/L). Several explosives or explosive-related organic compounds (RDX,  HMX, and TNT) were
 also detected in these samples. RDX at 390 ug/L exceeded its health-based screening value3(2
 ug/L). The monitoring wells showing the most significant concentrations of explosives-related
 substances are located where grenade-throwing and demolition are practiced.  The groundwater
 from the Zulu Ranges discharges to surface water located within the South Post  Organic
 compound results are shown on Figure 6 of Appendix A.

 Hotel Range (AOC 27) — Metals concentrations in the EOD Range groundwater samples
 (unfiltered) also exceeded concentrations found in local background samples. Filtered samples
 showed lower concentrations than the unfiltered samples (Tables 6 and 7 of Appendix E).  The
 maximum concentration of manganese in filtered samples (74.1 ug/L) exceeded the screening
 value of 50 ug/L. In addition, aluminum at concentrations up to 72.3 ug/L exceeded the
 screening value4(SO ug/L) in some filtered samples.  All wells in this area indicated some level of
 explosives contamination. RDX (up to 17.9 ug/L) and 1,3-dinitrobenzene (up to 1.82 ug/L)
 exceeded their screening valuess(2 ug/L and 1  ug/L, respectively). Organic compound results are
 shown on Figure 7 of Appendix A.

 Summaries of groundwater sample results for the EOD, Zulu, and Hotel Ranges are presented in
 Tables 2 through 7 in Appendix E.  Complete analytical results are presented in the RI Report.

 B.    Surface Water

 The SPIA is drained primarily by two streams,  Slate Rock Brook north and  west of the SPIA
 monitored-area and an unnamed stream in the southeast portion of the site.

 EOD Range (AOC 25) — No surface water is known to exist within or adjacent to the EOD.
 During the RI, one surface water sample was collected from the emergence  of Slate Rock Brook
 near the EOD Range, although the RI report notes that the sample is not representative of surface
 water originating at the EOD Range.  This sample was analyzed for TAL metals, TCL organics,
 explosives, and water quality parameters.  Several metals in the sample exceeded USEPA's
 Ambient Water Quality Criteria (AWQC) for the Protection of Aquatic Organisms (Freshwater
 Chronic)6. Sample analysis results are presented in Table 8 of Appendix E.
       2 Massachusetts Secondary Maximum Contaminant Levels (MCL).
       3 USEPA Office of Water Lifetime Health Advisory level.
       4 Massachusetts Secondary MCL.
       5 USEPA Office of Water Lifetime Health Advisory level.
       6 The analytical data and other information presented in the RI report indicate that the
surface water samples were not filtered.  The concentrations of metals detected may reflect the
presence of solids in the samples.  Metals that adhere to the suspended solids may pose less risk to
aquatic organisms potentially of concern because the metals may not be "bioavailable."

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 Zulu Ranges (AOC 26) — Thirteen surface water samples were collected for the RI from
 wetlands and drainage areas potentially affected by activities at the Zulu Ranges.  Figure 8 of
 Appendix A shows surface water sampling locations in the Zulu Ranges. These 13 samples were
 analyzed for TCL organics,  TAL metals, explosives, TPHC, and water quality parameters.
 Sample analysis results are presented in Table 9 of Appendix E.

 Analysis of the Zulu Range samples collected during the RI showed two metals exceeding
 USEPA AWQC: arsenic detected at a concentration of 7.18 ug/L (AWQC of 0.018 ug/L) and
 lead at a maximum concentration of 106 ug/L (AWQC of 3.2 ug/L). Earlier samples collected as
 part of a previous investigation, the Site Inspection (SI), showed higher concentrations than those
 found in the RI samples.  The differences between the two investigations may reflect different
 sampling methods, field conditions, or laboratory procedures. Explosives (including RDX and
 HMX), as well as several organic compounds, were detected in samples from the Zulu Ranges.
 One of the thirteen samples contained a detectable concentration of ODD (0.086 ug/L) that
 exceeded the AWQC (0.00083 ug/L).

 Hotel Range (AOC 27) — Nine surface water samples were collected for the RI  within
 Cranberry Pond, adjacent to the Hotel Range.  (Three samples had been collected  earlier during
 the SI.) The six RI samples  were analyzed for TCL, VOCs, pesticides, and polycyclic aromatic
 hydrocarbons (PAHs); TAL metals; explosives; TPHC; and water quality parameters. Figure 4 of
 Appendix A shows surface water sampling locations in the Hotel Range.  Sample analysis  results
 are presented in Table 10 of Appendix E

 Several metals were detected in the surface water samples collected in the Hotel Range.  One
 metal, lead, was detected at a concentration of 18.2 ug/L, which exceeded the AWQC (3.2 ug/L).
 Trace levels of explosives or explosive-related compounds were detected in these samples.

 Complete analytical results are presented in the RI report.

 C.     Sediments

 Samples of sediments were taken in conjunction with the surface water samples discussed above.
 The samples taken at the EOD Range, Zulu Ranges, and Hotel Range were analyzed for TAL
 metals, TCL organics, explosives, TPHC, TOC, and grain size.

 EOD Range (AOC 25) — Several metals in the EOD Range sample exceeded the concentrations
 detected in a local background sediment sample.  Sample analysis results are presented in Table
 11 of Appendix E.

Zulu Ranges (AOC 26) — Most metals in the Zulu Range samples were detected above
background concentrations in at least one sample. Explosives, pesticides, VOCs, and TPHC were
also detected. Sample analysis results are presented in Table 12 of Appendix E. No screening
values were established in the RI  for organic compounds in sediments.
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 Hotel Range (AOC 27) — Most samples collected in Cranberry Pond contained some metal
 concentrations in excess of those naturally occurring in the sediment. However, the data indicate
 that only one sample is unequivocally contaminated with metals.  The explosive 4-amino-2,6-
 dinitro toluene was detected in one third of the samples. VOCs, pesticides, TPHC, and two
 PAHs: benzo(b)fluoranthene and pyrene were also detected. Sample analysis results are
 presented in Table 13 of Appendix E. Complete analytical results are presented in the RI report.

 D.     Soils

 The predominant soil in the South Post, including the areas of investigation, is the Hinkley-
 Merrimac-Windsor (HMW) association. This soil consists of loams or sandy loams, loamy fine
 sands, and other sands over sand or sand and gravel.  In the active ranges, including the EOD,
 Zulu, and Hotel Ranges, the natural soils are disturbed.  A soil mapping of the SPIA monitored-
 area found that, almost without exception, the soils are sandy and well drained. The exceptions
 are in wetland areas outside the three ranges.

 EOD Range (AOC 25) — Surface and subsurface soil samples collected during the RI at the
 EOD Range in November 1993 were analyzed for TAL metals, explosives, and TPHC.  Figure 8
 of Appendix A shows soil sampling locations in the EOD Range. Several metals were detected at
 levels above background in at least one sample. Copper and zinc exceeded the background
 concentration in three surface samples. Two explosives were also detected in EOD Range surface
 soil samples: nitrocellulose (detected  in two samples) and nitroglycerine (detected in one sample).
 Low levels of TPHC were detected (maximum concentration of 45.2 ug/g).  None of the
 substances detected exceeded the health-based soil screening criteria established for the RI7.
 Sample analysis results are presented  in Table 14 of Appendix E.

 Zulu Ranges (AOC 26) — Surface and subsurface soil samples were taken at the Zulu Ranges as
 part of the SI and RI.  Figure 9 of Appendix A shows soil sampling locations in the Zulu Ranges.
 These samples were analyzed for TCL organics, TAL metals, explosives, and TPHC.  Although
 several metals exceeded background concentrations in at least one surface and subsurface sample,
 none of the metals detected exceeded the health-based screening values. PAHs were detected in
 up to three surface and subsurface samples. One of the PAHs, benzo(b)fluoranthene (0.81 ng/g),
 exceeded the screening concentration1^.7 (ig/g). RDX and TPHC were also detected. The
 maximum concentration of RDX in subsurface soil (38 fig/g) exceeded the health-based screening
 Ievel9(26 ug/g). Sample analysis results are presented in Table 15 and 16 of Appendix E.

 Hotel Range (AOC 27) — Subsurface soil samples were collected from boreholes at the Hotel
 Range and analyzed for TPHC, TAL metals, explosives, and TCL organics  Figure 10 of
       7 Either the Massachusetts Contingency Plan Human Health Level for Soil, the USEPA
Region in Risk-Based Concentration, or, for lead, the level set in the USEPA Interim Guidance
on Soil Lead Cleanup Level.
       * Massachusetts Contingency Plan Human Health Level for Soil
       9 USEPA Region m Risk-Based Concentration

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 Appendix A shows borehole locations.  None of the metals exceeded the screening values. Low
 levels of TPHC (maximum concentration of 75.6 ug/g), below the screening level of 5,000 ug/g,
 were detected in some samples. VOCs and pesticides were also detected at concentrations just
 above the detection limit.  These levels were well below screening values.  Sample analysis results
 are-presented in Table 17 of Appendix E.

 Complete analytical results are presented in the RI report.

 VL   SUMMARY OF SITE RISKS

 A risk assessment was performed to estimate the probability and magnitude of potential human
 health and environmental effects associated with exposure to contaminated media at the site.  The
 following sections discuss the general approach and assumptions, the results of the human health
 risk evaluation, and the ecological risk evaluation.

 A.    Baseline Risk Assessment Approach and Assumptions

 The human health risk assessment  followed a four-step process: (1) contaminant identification,
 which identified those hazardous substances that, given  the specifics of the site, were of
 significant concern; (2) exposure assessment,  which identified actual or potential exposure
 pathways, characterized the potentially exposed populations, and determined the extent of
 possible exposure; (3) toxicity assessment, which considered the types and magnitude of adverse
 health effects associated with exposure to hazardous substances; and (4) risk characterization,
 which integrated the three earlier steps to summarize the potential and actual risks posed by
 hazardous substances at the site, including carcinogenic and noncarcinogenic risks. A summary
 discussion of the human health risk assessment approach is presented in Section 5 of the RI
 report, Volume I, while more detailed discussions are presented in Section 8 of Volumes II, III,
 and IV of the RI report for the EOD, Zulu, and Hotel Ranges,  respectively.

 All organic chemicals that were positively detected (detected concentrations not discounted for
 reasons explained in the RI report) were selected as contaminants of potential concern (COPCs)
 for the human health risk assessment.  Some, notably pesticides which were widely applied in the
 past at Fort Devens, are probably not directly related to  range activities.  Also, organic
 compounds that could not be quantitatively eliminated during the Quality Control (QC) review as
 being not site-related, but were considered to  be questionable, were still considered as part of the
 risk assessment. Tables 18, 19, and 20 of Appendix E present the COPCs for each sampled media
 at the EOD, Zulu, and Hotel Ranges, respectively.  A summary of the health effects of each of the
 COPC can be found in Section 5, Volume 1 of the RI report.

Potential human health effects associated with exposure  to the contaminants of concern were
estimated quantitatively or qualitatively by developing several hypothetical exposure pathways.
These hypothetical pathways were  developed to reflect the potential for exposure to hazardous
substances based on the present uses, potential future uses, and location of the site. The
following is a brief summary of the exposure pathways evaluated for the human health risk and

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 ecological risk evaluations.  A more thorough description can be found in Section 8 and 9 of
 Volumes II, HI, and IV of the RI report for the EOD, Zulu, and Hotel Ranges, respectively.

 1.     Exposure Pathways for the Human Health Risk Evaluation

 EOD Range (AOC 25)

          •    Direct contact (dermal contact and incidental ingestion) with contaminated surface
              soils

          •    Inhalation of airborne soil particles

 Zulu Ranges (AOC 26)

          •    Direct contact (dermal contact and incidental ingestion) with contaminated surface
              soils

         •    Inhalation of airborne soil particles

         •    Direct contact with sediment and surface water in the adjacent wetlands

 Hotel Range (AOC 27)

         •    Direct contact (dermal contact and incidental ingestion) with contaminated surface
              soils

         •    Inhalation of airborne soil particles

         •    Direct contact with contaminated sediment and surface water at Cranberry Pond

 Groundwater in the vicinity of these ranges is not  currently used as a water supply source, nor is it
 expected to be used for that purpose in the future; therefore, direct contact with groundwater is
 not a complete exposure pathway and was not addressed further in the risk assessment. Any
 future use of the SPIA monitored-area groundwater will require a human health risk assessment.
                                                          x
 2.     Exposure Pathways for the Ecological Risk Evaluation

 EOD Range (AOC 25) — COPCs at the EOD Range include mercury, zinc, and nitroglycerin.
 The only medium of exposure is soil. The species selected as potentially exposed were
 herbaceous vegetation, white-footed mouse, killdeer, and red fox. The following pathways were
 identified as sources of potential exposure:

         •   Root uptake from contaminated soil
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          •    Contact and absorption, incidental ingestion, and feeding on contaminated food
              and soil

          •    Bioaccumulation from vegetation or animal prey

 Zulu Ranges (AOC 26) — COPCs identified at the Zulu Ranges include metals, explosives, and
 organics. Media of exposure include soils, sediments, and surface water. Selected terrestrial
 species were herbaceous vegetation, white-footed mouse, grasshopper sparrow, killdeer, and red
 fox. Selected aquatic and semiaquatic species were aquatic invertebrates, Blanding's turtle, and
 mink.

 Terrestrial and aquatic pathways include the following:

         •    Root uptake from contaminated soil

         •    Contact and absorption, incidental ingestion, and feeding on contaminated food
              and soil

         •    Incidental ingestion and drinking of contaminated surface water

         •    Bioaccumulation from vegetation or animal prey

 Hotel Range (AOC 27) — Antimony, copper, lead, mercury, nickel, and 4-amino-2,6-dinitro
 toluene were selected as ecological COPCs in Cranberry Pond sediments, which are potentially
 affected by activities at Hotel Range. Lead was selected as a COPC in surface water of Cranberry
 Pond.  Selected species were aquatic invertebrates, raccoons,  and mallard.

 The following migration pathways were identified:

         •    Uptake from contaminated sediment

         •    Contact and absorption, incidental ingestion, and feeding on contaminated food
              and sediments

         •    Contact and absorption, incidental ingestion, and drinking of contaminated surface
              water

         •    Bioaccumulation from vegetation or animal prey

B.     Baseline Risk Assessment Results

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the
exposure level with the chemical-specific cancer factor.  Section 8 of Volumes II, III, and IV of
the RJ report present detailed descriptions of the exposure assumptions. USEPA has developed

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 cancer potency factors from epidemiological or animal studies to reflect a conservative "upper
 bound" of the risk posed by potentially carcinogenic compounds.  That is, the true risk is unlikely
 to be greater than the risk predicted. The resulting risk estimates are expressed in scientific
 notation as a probability (e.g., 1 x 10"* for 1/1,000,000) and indicate (using this example), that an
 average individual is not likely to have greater than a one in a million chance of developing cancer
 over 70 years as a result of site-related exposure to the compound at the stated concentration.
 Current USEPA practice considers carcinogenic risks to be additive when assessing exposure to a
 mixture of hazardous substances.

 The hazard quotient was also calculated for each pathway as a measure of the potential for
 noncarcinogenic health effects.  A hazard quotient is calculated by dividing the exposure level by
 the reference dose (RfD) or other suitable benchmark for noncarcinogenic health effects for an
 individual compound. USEPA has developed RfDs to protect sensitive individuals over the
 course of a lifetime.  They reflect a daily exposure level that is likely to be without an appreciable
 risk of an adverse health effect. RfDs are derived from epidemiological or animal studies  and
 incorporate uncertainty factors to help ensure that adverse health effects will not occur. The
 hazard quotient is often expressed as a single value (e.g., 0.3) indicating the ratio of the stated
 exposure as defined to the RfD value (in this example, the exposure as characterized is
 approximately one third of an acceptable exposure level for the given compound). The hazard
 quotient is only considered additive for compounds that have the same or similar toxic endpoint
 and the sum is referred to as the hazard index (HI). For example: the hazard quotient for  a
 compound known to produce liver damage would not be added to a second compound whose
 toxic endpoint is kidney damage.

 Under the current USEPA Superfund policy, acceptable exposures to carcinogens are those that
 represent  an excess upper bound lifetime cancer risk of between 10"4 to  10~*. For noncarcinogenic
 effects, acceptable exposures levels are those with a HI of 1.0 or less. Using the exposure
 assumptions described in the RI report and chemical concentration data  obtained during the RI,
 the Baseline Risk Assessment evaluated both potential carcinogenic and noncarcinogenic risks to
 potentially exposed persons.

 The human health risk assessment of the RI report identified the following potential human health
 risks:

 SPIA Monitored-Area  Groundwater - Actual use of Well D-l ground water by an individual
 occurs less than 14 days per year, far less frequently than the 350 days per year that is assumed
for residential exposure.  Actual exposure duration, which probably does not exceed 10 years,
also is significantly less than the residential assumption of 30 years (which includes childhood).
Given their limited exposures, the potential risks to the troops who currently use Well D-l are
estimated to be at least two orders of magnitude less than those estimated  for residential tap
water, lowering the excess lifetime cancer risks to current groundwater users from arsenic and
chloroform below the lower extreme of the 10"4 to 10"6 range considered acceptable by USEPA.
Therefore, groundwater at the South Post of Fort Devens does not pose any unacceptable risks to
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 human health. Table 21 of Appendix E shows the calculated risks for using Well D-l
 groundwater.

 EOD Range (AOC 25) — The estimated potential cancer risks under the case of "reasonable
 maximum exposure" (RME) to contaminants at the EOD Range ranged from 1.2 x 10"9 for a site
 worker's exposure to soil, to 1.7 x 10"8 for an adult trespasser's exposure to soil. These are all
 well below USEPA's benchmark 10"4 to  10"6 range.  Table 22 of Appendix E presents a summary
 of the excess cancer risks associated with the EOD Range. The RME and the  average exposure
 cases evaluated in the human health risk assessment were based on the maximum and average
 chemical concentrations in the exposure media, in accordance with USEPA-New England
 guidance.  The cancer risks associated with average exposures were less than 33 percent of the
 RME risks.

 The His for potential RME scenarios involving noncarcinogenic COPCs from the EOD Range
 ranged from 9.0 x 10"4 for site worker  exposures to soil to 1.1 x 10"3 for the adolescent trespasser.
 All were well below USEPA's benchmark value of 1.0.  Table 23 of Appendix  E presents a
 summary of the estimated hazard indices for noncarcinogenic effects associated with the EOD
 Range.

 Zulu Ranges (AOC 26) — The estimated potential cancer risks for RME's to  contaminants at
 the Zulu Ranges ranged from 7.6 x 10"9 for an adolescent site trespasser's exposure to sediment to
 8.9 x 10"* for an adult's consumption offish.  These numbers are all below the 10"4 to 10"6 range
 Table 24 of Appendix E presents a summary of the excess cancer risks associated with the Zulu
 Ranges. The RME case assumes that all of a receptor's exposure is to 33 maximum contaminant
 concentrations observed at site. For all of the pathways evaluated, the cancer risks associated
 with average exposures were approximately 25 percent as great as the RME risks.

 Both the soil and sediment exposure pathways could reasonably apply to the same trespassers. In
 addition, the same individuals could fish from  Slate Rock Pond.  Therefore, the estimated  risks
 from soil contact, sediment contact, and fish consumption were summed to estimate the total
 receptor risk. Combining the RME risk estimates from the three pathways results in total
 estimated cancer risks of 1.7 x 10"7 for  adults and 4.1 x 10"8 for adolescents, still below the 10"6
 level.

 The His for potential RME scenarios involving noncarcinogenic COPCs from the Zulu Ranges
 ranged from 1.0 x 10"3 for.adult trespasser exposure to soil to 3.3 x 10"3 for site worker soil
 exposures.  All were well below USEPA's benchmark value of 1.0. The total His of trespassers
 from soil contact, sediment contact, and fish consumption pathways were also well below  1.0.
Table 25 of Appendix E presents a summary of the estimated hazard indices for noncarcinogenic
effects associated with the Zulu Ranges.

Hotel Range (AOC 27) — Estimated potential cancer risks for RMEs to contaminants at the
Hotel Range ranged from 4.1 x 10"9 for an adolescent site trespasser's  exposure to soil to  1.7 x
 10"* for an adult trespasser's exposure to sediment.  These numbers are all below the  10"4 to 10"6

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 range. Table 26 of Appendix E presents a summary of the excess cancer risks associated with the
 Hotel Range. The RME case assumes that all of a receptor's exposure is to the maximum
 contaminant concentrations observed at the site. For soil exposure pathways, the cancer risks
 associated with average exposures were up to a 33 percent less than the RME risks.  Cancer risks
 associated with average exposures to sediments were less than the RME risks by an order of
 magnitude.

 Both the soil and sediment exposure pathways could reasonably apply to the same site trespassers
 Therefore, the estimated risks from soil and sediment contact were summed to estimate the total
 receptor risk. Combining the RME risk estimates from these two pathways results in total
 estimated cancer risks of 1.4 x 10'7 for adults and 3.2 x 10"' for adolescents, still well below the
 ID"6 level.

 The His for potential RMEs to carcinogenic COPCs for the Hotel Range ranged from 7.7 x 10"*
 for the adult trespasser exposures to soil to 1.9 x 10'2 for site worker soil exposures.  All were
 well below USEPA's benchmark value of 1.0. The total His of trespassers from soil and sediment
 contact pathways together were also well below 1.0. Table 27 of Appendix E presents a summary
 of the estimated His for noncarcinogenic effects associated with the Hotel Range.

 C.     Ecological Risk Assessment

 An ecological risk assessment was performed for the SPIA monitored-area.  The following
 sections present a summary of the results of the ecological risk evaluations.

 SPIA Monitored-Area Groundwater—Groundwater from within the SPIA monitored-area is
 discharging to on-site surface waters prior to leaving the South Post. No ecological risk to
 surrounding habitats are associated with groundwater in the SPIA monitored-area.  Ecological
 impacts from the surface water/sediment for each individual range are described within this ROD
 in the following sections.

 EOD Range (AOC 25) — Concentrations of mercury, zinc,  and nitroglycerin in soils exceed
 USEPA guidelines for plants or small mammals, but only for the worst case scenario. Ecological
 risks identified on the EOD Range were deemed acceptable due to the continued use of the
 Impact Area for military training activities.  Table 28 of Appendix E presents, for the average
 exposure case, a summary of the hazard quotients for endpoint species at the EOD Range.  Table
 29 of Appendix E presents a summary of hazard quotients for the RME case.

 Zulu Ranges (AOC 26) — Levels of lead, zinc, and cyclonite in soils exceed USEPA risk
 guidelines for plants, small mammals, and songbirds. Several metals were detected in the
 sediments of the nearby wetlands at levels above local background concentrations. Despite some
 exceedances, these metals were not considered to be of concern because exceedances of
background or criteria were few and the magnitude of exceedance was not great. Ecological risks
identified on the Zulu Range were deemed acceptable due to the continued use of the Impact Area
for military training activities. Tables 30 and 31 of Appendix  E present, for the average exposure

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, <& 27	Page 17

 case, a summary of the hazard quotients for aquatic and terrestrial endpoint species at the Zulu
 Ranges, respectively.  Tables 32 and 33 present, for the RME case, a summary of hazard
 quotients for aquatic and terrestrial endpoint.

 Lead and other chemicals found in the surface water do not pose significant risks to wildlife or to
 aquatic life. Levels of lead exceed water quality criteria, but water samples were not toxic when
 tested in the laboratory with aquatic invertebrates and fish.

 Hotel Range (AOC 27) — Metals, explosives, and other organic chemicals found in soils at the
 Hotel Range do not pose unacceptable risks to plants or wildlife.  Levels of lead  exceed water
 quality criteria; however comparable water samples from the Zulu Range, which  also contains
 elevated levels of lead, were not toxic when tested in the laboratory with aquatic invertebrates and
 fish.  Several metals were detected in the sediments of Cranberry Pond at levels above local
 background concentrations. Despite some exceedances, these metals were not considered to be
 of concern because exceedances of background or criteria were few and the magnitude of
 exceedance was not great. In addition, the highest detected concentrations of these metals were
 within or only slightly exceeded the range of regional background levels reported for remote New
 England and for unimpacted lakes and ponds in Massachusetts. Ecological risks  identified on the
 Hotel Range were deemed acceptable due to the continued use of the Impact Area for military
 training activities. Table 34 of Appendix E presents, for the average exposure case, a summary of
 the hazard quotients for aquatic endpoint species at the Hotel Range.  Table 35 presents a
 summary of the hazard quotients for the RME case.

 The assessment concluded that explosives and other chemicals in the soil do not pose
 unacceptable risks to plants or wildlife.  In addition, lead, zinc, and other chemicals in the surface
 water pose no unacceptable ecological risk.

 VIL    ARMY RATIONAL FOR PROPOSING "NO ACTION"

 The 1991 Defense BRAC Report to the President indicates that the Army will retain the South
 Post and continue operating its training ranges.  Therefore, the South Post will not be cleaned up
 for unrestricted use. The Army Range Control will continue to restrict public access, and
 unauthorized personnel will be prohibited. Currently, the South Post is enclosed by a fence and
 access can only be gained through gates that are controlled by the Army Range Control.

 Risk assessment results show that human health risks identified are within USEPA risk guidelines.
 Risk to on-site ecosystems were deemed acceptable.

 Vm.   DESCRIPTION OF THE NO ACTION ALTERNATIVE

"No action" is the selected remedy for the SPIA monitored-area groundwater and AOC 41
groundwater. Under this alternative, no formal remedial action is taken and the site is considered
to be left "as is," with no additional institutional controls, containment, removal, treatment, or
other mitigating measures. "No action" is also the selected remedy for the surface water,

C:\0102\DELI VER\SPI AVFIN ALROD\FROD 18. WPD          ~                                   June 18, 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwatcr and AOCs 25,26, & 27	Page 18

 sediment, and soil at the EOD, Zulu, and Hotel Ranges. The Army has submitted a Closure
 Report under the RCRA Subpart X; formal approval of the closure of EOD Range will occur
 prior to ROD signature.

 As part of this remedy, Fort Devens will ensure the following:

         •    Groundwater monitoring for potential contaminant migration out of the SPIA
              monitored-area will continue:

                     Wells will be used to monitor the groundwater from the EOD Range, Zulu
                     Ranges, Hotel Range, and AOC 41.

                     Wells will be used to monitor the north, northeast, southeast, and east sides
                     of the SPIA monitored-area.

         •    The monitoring wells will be sampled for explosives, TCL, and TAL metals.

         •    A Groundwater Monitoring Plan for the South Post will be developed that will
              include detailed groundwater monitoring at discharge points. The plan  may
              include installing sentinel wells to monitor potential off-site groundwater flow.
              Details of the plan will be developed jointly by the Army, USEPA-New England,
              and MADEP within 6 months of ROD signature.  The Army will rerun the
              groundwater model to incorporate data from new sentinel weil(s) and ascertain any
              potential impacts to MCI Shirley.

         •    Well D-l will be sampled and analyzed for explosives and Massachusetts and
              Federal drinking water requirements (MMCLs/MCLs).

         •    The Army will not develop new drinking water sources within the SPIA
              monitored-area.

         •     An Integrated Natural Resources Management Plan will be developed and
              implemented to monitor the impacts to ecosystems in the SPIA monitored-area.
              The details of this plan will be developed jointly by the Army, USEPA-New
              England, U.S. Fish and Wildlife Service, and MADEP within 6 months of the ROD
              signature.

Monitoring reports will include a description of site activities and a summary of analytical results.
The Army will review and submit these monitoring reports to MADEP and USEPA annually. If
there is an indication of contamination emanating from the SPIA monitored-area, the Army will
evaluate the need for additional assessment.

This site, as required by CERCLA, will be subject to 5 year reviews.  During a 5 year review, an
assessment is made as to whether the implemented no action alternative remains protective of
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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page 19

 human health and the environment and whether the implementation of alternative remedial actions
 are needed to ensure adequate protection. If on-site hazardous substances, pollutants, or
 contaminants that may present an imminent and substantial endangerment to public health and
 welfare migrate off site, the Army will take the necessary and appropriate actions to protect
 human health and the environment as required under CERCLA.  More frequent reviews will be
 conducted if site conditions change.  Should the Army close or transfer or change the use of this
 property, an Environmental Baseline Survey (EBS) will be conducted, and the "no action"
 decision of this ROD will be re-examined in light of the changed use and risk factors resulting
 from this closure/transfer.  The EBS will be provided to the USEPA-New England and MADEP
 for comment.

 The implementation of the "no action" alternative will cost approximately $500,000.

 IX.     DOCUMENTATION OF SIGNIFICANT CHANGES

 The Army presented a Proposed Plan identifying "no action" as the preferred alternative for the
 site.  The plan was presented at a public meeting held on February 21, 1996. Comments obtained
 from the public were incorporated into the development of this Final ROD for the SPIA
 monitored-area groundwater and AOCs 25, 26, and 27. Concurrent to the development of this
 ROD, the Army was finalizing the RJ for AOC 41. AOC 41 is approximately 6-acres in size and
 is located between Harvard Road, New Cranberry Road, and an eastern portion of the SPIA
 monitored-area (Figure 11 of Appendix A shows the location of a AOC  41).

 The results of the AOC 41 RI indicate that the most appropriate remedial action for the
 groundwater at AOC 41 would be "no action." This is the same action to be taken for the SPIA
 monitored-area groundwater.  The RI also shows that AOC 41 is adjacent to the SPIA
 monitored-area, and AOC 41 is small in area (6 acres). Adding AOC 41 to this ROD would only
 increase the total land area covered in this ROD by 0.6 percent. Therefore,  the USEPA-New
 England recommended including AOC 41 in this ROD. The landfill portion of AOC 41 will be
 addressed under a separate action.

 The overall result of including AOC 41 groundwater with the SPIA monitored-area groundwater
 is that a slightly larger land area is addressed, and the Army can more rapidly proceed in the
 development and implementation of the long-term monitoring programs  for the site.  A
 Groundwater Monitoring Plan for the South Post will be developed that  will include monitoring
 the groundwater under AOC 41.  The plan may include installing  sentinel wells to monitor
 potential  off-site groundwater flow.  Details of the plan will be  developed jointly by the Army,
 USEPA-New England, and MADEP within 6 months of ROD signature.

 A.    Site History

 AOC 41 is approximately 6 acres in size and is located between Harvard Road, New Cranberry
Pond, and an eastern portion of the impact area in the South Post (Figure 11 of Appendix A).
The landfill material occupies an area approximately 75 feet by  75 feet in the central portion of the

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27	Page 20

 site. It appears to have been associated with an old brick-making kiln that was operated in this
 area in the 1800s. The AOC is overgrown with trees and swampy vegetation, and no records are
 available detailing when the site was used or what type of material was disposed of in this area. It
 is believed that this AOC was used until the 1950s for disposal of nonexplosive military and
 household debris. Miscellaneous debris is scattered over a small hill located approximately 75  feet
 north of New Cranberry Pond.  The hill slopes down to a low area at the base of the hill. The
 ground surface elevation rises to the south, then slopes again down to New Cranberry Pond. The
 water level in New Cranberry Pond is controlled by a culvert located on the eastern shore of the
 pond that impedes the water flow,  which in turn increases the water level in the pond. Installation
 personnel attempt to keep the culvert clear in an effort to maintain a constant water level in the
 pond.

 The results of the SI and Supplemental  SI (SSI) indicated that some residual surface soil
 contamination was present on the waste material.  However, the main human health risk was
 associated with the concentration of chlorinated solvents found in the ground water.  SA 41 was
 recommended for an RI/FS after the SSI and the site designation was changed from SA 41 to
 AOC 41. The RI for AOC 41 concentrated on defining the distribution of chlorinated solvents in
 groundwater.  The findings of the RI indicate that (1) the waste material is not the source of the
 groundwater contamination, (2) the source of the  groundwater contamination appears to be
 within the area investigated, (3) groundwater contaminant distribution is well defined, and (4)
 contamination does not appear to be impacting the surface water or sediment quality in New
 Cranberry Pond.

 B.      Summary of Site Characteristics

 The following subsections address the nature and distribution of analytes detected in soil and
 groundwater during the 1992 SI, 1993 SSI, and 1994 RI.  In addition to the off-site analytical
 laboratory analysis, field analytical data is presented and discussed.  Table 36 presents a list of the
 analytical tests performed on each sample in each media during the SI, SSI, and RI. Figure 12
 and  13 of Appendix A show the soil and groundwater sampling locations for field and off-site
 laboratory analysis.

 1.     Soils

 The  soil type encountered in one boring advanced  at AOC 41 included clayer silt from 4 to 36 feet
 below ground  surface.  This material was mapped  as Ayer Stage lake deposits.

 Field Analytical Results — Samples for field analysis collected as part of the RI include: 22 soil
 gas samples from  13 locations; 30 soil samples from the 13 soil gas survey points; 12  soil samples
 from 5 test pits; and 14 soil samples from the installation of one monitoring well.

Field analytical results indicate that  2 of the 13 soil gas samples contained detectable levels of
trichloroethylene (TCE) (3.6 parts per billion (ppb) and 3.9 ppb). TCE and trans-
dichloroethylene (DCE) were detected in soil samples collected from the soil gas sampling points

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page 21

 between 30 and 37 feet below ground surface.  Values of TCE ranged from less than the
 analytical detection limit (1.0 ppb) to 180 ppb while trans-DCE concentrations ranged from below
 detection limit to 9.1 ppb. The vertical distribution of observed TCE contamination coincides
 with the depth of the water table at this area.  None of the soil samples collected from the test pits
 indicated the presence of any target analyte. Of the 14 soil samples collected during the
 installation of the monitoring well, only those collected at 30 to 32, 35 to 37, and 40 to 42 feet
 below ground surface contained TCE (4.55 ppb, 5.33 ppb, and 8.58 ppb respectively).  This data
 also suggests a correlation between the vertical distribution of contamination and the depth to
 groundwater at this site.

 The field analytical results for the soil gas samples, the soil samples collected at soil gas survey
 points, the soil samples from the test pits, and the soil samples from the installation of one
 monitoring well are presented in Tables 37, 38,  39, and 40 of Appendix E, respectively.

 Off-Site Laboratory Results — Soil samples were collected for off-site laboratory analysis from
 test pits and monitoring well boring locations completed during the SI, SSI, and RI. VOCs,
 pesticides/PCBs,  and explosives were not detected in any of the soil samples collected during the
 SI and SSI. Sodium was the only inorganic attribute detected above Fort Devens background in
 all soil samples. Other analytes detected above background include calcium, copper, and nickel.
 The results of these analysis are presented in Table 41 of Appendix E.

 Twelve of the 21  soil samples collected during the RI were analyzed for VOC, semivolatile
 organic compounds (SVOC),  inorganics, toxicity characteristic leaching procedure  (TCLP),
 TPHC, and TOC.  The remaining 9 samples were analyzed for all of the previously  listed
 parameters except TCLP.

 Off-site analytical results indicate that only 1 of the 17 samples collected from potential
 groundwater contamination test pits contained VOCs (1,1,2,2-trichloroethane (TCA) and
 toluene). A review of laboratory quality control indicates that the Freon and toluene detected in
 samples beneath the waste material and the remaining detected VOC can be attributed to
 laboratory contamination. SVOCs (acenaphthylene, benzo[b]fluoranthane, benzo[k]fluoranthane,
 chrysene, fluoranthane, phenanthrene, and pyrene) were detected at low concentrations in 3 of
 these 17 soil samples.

 Cobalt, copper, nickel, and sodium exceeded Fort Devens background in 4 samples while sodium
 exceeded background in all 12 samples analyzed using TCLP; but each sample passed the TCLP.

 The off-site analytical results for the soils analysis are presented in Table 41 of Appendix E.

2.     Groundwater

Groundwater samples were collected in six separate rounds at this site (Rounds 1 through 6).
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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 21	Page 22

 Field Analytical Results — Groundwater samples were collected for field analysis only during
 the 1994 RI field program.  Field analysis of groundwater samples consisted of collection and
 analysis of groundwater samples from screened auger borings and all pre-1994 monitoring wells.
 Each of the groundwater samples was analyzed with field gas chromatography (GC) for vinyl
 chloride; t-l,2-DCE; c-1,2-DCE; benzene; TCE; toluene; TCA; ethylbenzene; m/p xylene; o-
 xylene; 1,1,2,2-TCA; and 1,2-DCE.

 Based on field analytical data, the site-related VOC (TCE, 1,1,2,2-TCA, and c- 1,2-DCE) plume
 appears to be vertically confined to the soils at  the water table, and centered along a line trending
 northeast to southwest.  Figures 14 and  15 of Appendix A show the interpretive field analytical
 concentration contours for TCE and  1,1,2,2-TCA in groundwater, respectively.

 The results of the 1994 RI sampling analysis are presented in Table 42 of Appendix E.

 Off-Site Laboratory Results — Two rounds of off-site laboratory analytical samples were
 collected during each of the field investigations conducted at AOC 41.

 Off-site analytical results for groundwater samples collected during rounds 1 and 2 (September
 1992 and January 1993, respectively) indicate that several VOC (TCE, tetrachloroethylene (PCE),
 and 1,1,2,2-TCA) were present in the groundwater. One explosive-related compound (2,4,6-
 trinitrotoluene) was detected in round 1 but not round 2, while one pesticide (eldrin) was detected
 in round 2 but not round 1.  No other VOC, SVOCs, pesticides/PCBs, or TPHC were detected in
 either round.  The results of the rounds 1 and 2 sampling analysis are presented in Table 43 of
 Appendix E.

 Five additional monitoring wells were installed between round 2 and 3.  Off-site analytical results
 for groundwater samples collected during rounds 3 and 4 (October 1993 and January 1994,
 respectively) indicate that VOC (TCE, 1,1,2,2,-TCA, 1,2-DCE) were detected in the previously
 existing well and 2 of the new monitoring wells. Nitroglycerine was detected in 1 well during
 round 4. SVOCs detected during both rounds were identified as laboratory contaminants.
 Several inorganic analytes (antimony, arsenic, and manganese) were detected at concentrations
 slightly above Fort Devens background in unfiltered samples. The results of the rounds 3 and 4
 sampling analysis are presented in Table 43 of Appendix E.

 Eleven additional wells were installed as part of the RI field investigation.  Two rounds (5 and 6)
 of groundwater samples were collected during the RI field investigation.  Round 5 was completed
 in December 1994 and round 6 was completed in March  1995. Off-site analytical results for
 groundwater samples indicate that several VOC (TCE, PCE, 1,1,2,2-TCA, cis- and trans-1,2-
 DCE, toluene, carbon tetrachloride, and carbon  disulfide) were detected in one or more wells
 during either or both rounds. The only S VOC detected appears to be attributable to laboratory
 contamination.

Each of the PAL inorganic analytes, except for mercury, was detected above its Fort Devens
background concentrations in the unfiltered groundwater samples. However, results for filtered

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page 23

 inorganic samples indicated that only antimony, arsenic, potassium, copper, manganese,
 magnesium, sodium, and zinc were detected above Fort Devens background.

 The results of all sampling analysis are presented Table 43 of Appendix E.

 C.    Summary of Groundwater Impacts

 The groundwater results of Rounds Five and Six at AOC 41 indicate the presence of several
 VOCs (TCE; PCE;  1,1,2,2-TCA; cis- and trans- 1,2-DCE; toluene; carbon tetrachloride; and
 carbon disulfide) and several inorganic analytes above their Fort Devens background
 concentrations in unfiltered samples.  The distribution and relative concentration of the VOC
 contaminants is consistent in both field and off-site laboratory results. This observation is the
 most significant feature of the contamination assessment at this site.  The groundwater is
 contaminated with VOCs, but the distribution of that contaminant plume appears to be well
 defined. The source of this VOC contamination, particularly the chlorinated solvents, has not been
 precisely located; however, it does appear to be within the area investigated during the RI. It is
 important to note that the VOC contamination appears to have  almost no movement based upon
 the consistent contaminant values and the lack of contamination in down gradient monitoring
 wells (i.e., 41M-94-09A, 41M-94-09B, 41M-94-1IX, and 41M-94-12X).

 The hydrogeologic data collected at the site indicates that groundwater flow is slow, generally
 less than 1 foot per year, and therefore contaminant migration would be within a similar order of
 magnitude.

 D.    Summary of Risks

 The focus of the baseline human health risk assessment for AOC 41 is the groundwater operable
 unit at AOC 41.  Other media including soil, sediment, and surface water were sampled in earlier
 investigations, but were not included in the baseline risk assessment.  Based on the findings
 presented RI report and previous investigations (see Appendix C — Administrative Record), it
 appears that the groundwater contamination source is within AOC 41, but is not the waste
 material.

 Groundwater associated  with AOC 41 is not currently used for drinking water or for any other
 purpose.  Except for the  Fort Devens South Post Water Point (Well D-l), groundwater on the
 South Post (where AOC 41 is located) does not represent a current or potential future source of
 drinking water.

 Groundwater supplies at Fort Devens have consistently met Massachusetts water quality
 standards. Except for sodium, the physical and chemical qualities of on-site potable water have
 complied with State  standards. The installation has been complying with the State regulation for
 reporting sodium concentrations in excess of 20 milligrams per liter (mg/L).  The sodium
 notification requirement is designed to alert persons on a sodium-restricted diet of high sodium
 levels in their drinking water.

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page 24

 The noncarcinogenic risks (as hazard indices) and carcinogenic risks associated with the analytes
 detected in Well D-l were calculated and are reported in Table 21 of Appendix E.  The exposure
 frequency was assumed to be 14 days per year.  Cancer risks were calculated for two possible
 exposure durations: 10 years, which is probably greater than any individual exposure, and 2
 years, which is more typical.

 A USEPA Office of Solid Waste and Emergency Response (OSWER) directive, The Role of
 Baseline Risk Assessment in Superfund Remedy Selection Decisions, indicates that action is
 generally warranted at a site when carcinogenic risks are greater than 1x10"4 or noncarcinogenic
 His exceed 1 (based on RME assumptions). USEPA Superfund guidelines also state that when
 the total incremental carcinogenic risk for an individual resulting from exposure at a hazardous
 waste site is within the range of 1x10"4 to 1x10"*, a decision about whether to take action or not is
 a site-specific decision.  This range of IxlO"4 to  1x10"*  is often  referred to as the Superfund target
 risk range.

 All of the His are well below the USEPA threshold of  1, indicating that there are no unacceptable
 noncarcinogenic health risks. The carcinogenic  risks are all below 1x10"*. For one exposure
 scenario, assuming a 10-year exposure duration, the cancer risk slightly exceeds IxlO"6, at
 1.3x10"*. This cancer risk is, however, at the low end of the Superfund target risk range.
     •
 The RI concludes that there are no unacceptable risks to human health from the  groundwater at
 the South Post Well D-l and that no further action would be required under CERCLA.

 An evaluation of health risks associated with exposure to soil at AOC 41  is  not included in the
 baseline risk assessment.  Surface soil at AOC 41 will be addressed separately under the Fort
 Devens landfill consolidation study. Subsurface soil will not be addressed in the baseline risk
 assessment due to the lack of an exact location of a contaminant source area.

 Data collected from surface water and sediment  at New Cranberry Pond during previous
 investigations demonstrates that surface water from New Cranberry Pond recharges groundwater
 below  AOC 41. Therefore, it appears that site-related contaminants from AOC 41 are not
 impacting ecological receptors in New Cranberry Pond.

 E.     The Army's Rational for Proposing the Preferred Alternative

 The  1991 Defense BRAC Report to the President indicated that the Army will retain the South
 Post and continue operating its training and  detonation  ranges. Therefore, the contaminants
 detected in the South Post groundwater will not  be cleaned up for unrestricted use.

 Groundwater from AOC 41 is flowing to the north-northeast and would eventually discharge to
the Nashua River. No ecological risk to surrounding habitats in New Cranberry Pond have been
 identified.
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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page 25

 No potential threats to human health and the environment are associated with the groundwater at
 Well D-l (which is the only present and planned future exposure point closest  to AOC 41);
 therefore, the "no action" alternative is proposed. The same pathways will also exist under future
 site conditions since the land use is expected to remain unchanged. The Army will maintain the
 South Post, AOC 41 and associated ranges, continue training, maintain security, and develop
 long-term Integrated Natural Resources Management and Groundwater Monitoring Plans. These
 plans will incorporate the SPIA monitored-area groundwater, AOC 41 groundwater, and AOCs
 25, 26, and 27 and will be developed within 6 months of ROD signature.

 The Groundwater Monitoring Plan will include the installation of sentinel wells to monitor the
 groundwater. Details of the monitoring plan will be developed jointly by the Army, USEPA-New
 England, and MADEP.

 Monitoring reports will include a description of site activities and a summary of analytical  results.
 Reports will be submitted to MADEP and USEPA.  Under CERCLA, any action that results in
 contaminants remaining on-site must be reviewed at least every 5 years. During 5-year reviews,
 an assessment is  made of whether the no action alternative remains protective of human health
 and the environment and whether the implementation of additional remedial actions are
 appropriate.

 Based on current information and analysis of the SI,  SSI, and RI reports,  the Army believes that
 the preferred alternative of "no action" for control of groundwater contamination at AOC 41 is
 consistent with the requirements of the Superfund law and its amendments, specifically
 Section 121 of CERCLA, and to the extent practicable, the NCP.  No action is necessary to
 ensure protection of human health and the environment.

 X.     STATE ROLE

 The Commonwealth of Massachusetts has reviewed the various alternatives and concurred with
 the selected remedy for the SPIA monitored-area groundwater and EOD Range, Zulu Ranges,
 and Hotel Range. The State has also reviewed the RI and Risk Evaluation to determine if the
 selected remedy is in compliance with applicable  or relevant and appropriate State environmental
 laws and regulations.  A copy of the declaration of concurrence is attached as Appendix B:
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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25,26, & 27
                   RECORD OF DECISION SUMMARY
                    SOUTH POST IMPACT AREA AND
            AREA OF CONTAMINATION 41 GROUNDWATER AND
                AREAS OF CONTAMINATION 25, 26, AND 27
                    FORT DEVENS, MASSACHUSETTS
                            APPENDIX A

                             FIGURES
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 RECORD OF DECISION
 South Post Impact Area &  AOC 41 Groundwater and AOCs 25, 26, & 27	Page A -1
    11:l)C490812.CDn
                Spectacfe
                  Pond
                                                                            Oxbow National
                                                                            Wildlife Refuge
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                                       /^•^^J^J/--ixi.-W>Jif^K>>/vivVv*i>/'vD/> S*7tY*

                                      •^^^m^^^^S^f^^
                                     vMwmMWMmwM-
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                                                                      South Post Impact Area
                                                                      (approximately 1,500 acres)
                                                                   ter Divide
                                                                          Are* to be monitored
                                                                      i-^il (>pproxlmatcly 964 acres)
                                                                      • SA
                                                                               study Area
                                                                    — - — -  South Post Boundary
                                                                               Range Boundary
                                                                        O      Range Latter
N. Nashua
  Kvtr
   SOURCE Ecology wid Envifonment. Inc. 1994
                                               SCALE
                                                2000
                                               4000 Feet
    Fgure 1 South Post Impact Area AOC 25, 26, and 27.
C:\PP & ROD\DEUVER\SPIA\FINALROD\F1GURE1.WPD
                                                                            June 18, 1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Paee A - 2
       Figure 2 Location oTSanpkt at AOC 25
       ROCW)EUVER\SPIA\FINALROD\FIOURE2.WPD

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25,26, & 27
                                                                                                              Page A - 3
                                                                                                         MONITORING WCLL
                                                                                                         BOREHOU
                                                                                                         surr CAUCC
                                                                                                         WETLAND
                                                                                               A	K  GEOLOGIC  CROSS SECTION
                                                                                               —j«o— TOPOGRAPHIC CONTOUR
                                                                                               == ==== UNIMPROVED ROAD
                                                                                                       - BARBED WIRE FENCE
                                                                                               — - - — ZULU RANBt BOUNDARY
        CONTOUR INTERVAL
•cotocjr ind •niitonmtnt
        Figure 3 Location of Monitoring Wells at AOC 26
  C:\PP & ROD\DELIVER\SPIAVFINALROD\FIGURE3.WPD
                                                                                                                            May 30. 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25.26. & 27
Page A - 4
                                                            CONTMIR

                                                  ''' IKMWVCD IW*»
  Figun 4 Location of Monitoring WeUi and Surface Water/SwUmcBt Sampbi at AOC 27
C:\PP & ROD\OELIV£R\SP1A\FINALROI>FIOUR£4.WPD
M«y 30, 1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCa 25, 26, & 27
                       Page A - 5
         UCMMM
                               25*l-t2-03X
COD-2 I
ANALYTC
PETN
It/92
89.S
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-
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- .1
                                     |      //   COO-

                                     '      */  23M-93-101
                            SCALE IM FEET

                         150          300
                                                  480
                                                                                          2SW-*2-08X
                                                                                                          2SM-»2-07X
                                                                                MM-95-OSX
                                                                                                          23U-«2-oax
too-t
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                                                                                                   COMCCNTRA1IONS 1H n q/l
           •eology «n
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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
                                                         Page A - 6
        UC4MU
                                                                         28M-S2-02X
                                                              CAMOM MSUtriOE
                                                                   IPHC
                                                                 1.S-ON*
                                                              3-NITM101UCNE
       11/12
        4.9
        300
        NO
        NO
NO
NO
NO
NO
 NO
 NO
!.«»
1JIC
26U-81-03X
     JMW**
                      2SU-I2-09X
                      (NO GROUNDWATER
                      CON1MHNAHTS FOUND)
                                        -._---MX_
                               _  _*/MJ.yji.
                               2.8-DNl I  9.42 1 2.0*
                               ICYCLONlTd  270  3tO
                                 HMX  1  22.4  23^0_
                                                                                                                        4.78
                                                                                                                        1M
                                                                                                                        15.7
                                                                                                         26U-12-OSX
                                                                                                  M4ALT1C
                                                                                                  CARBON
                                                                                               TCTIWCHIOWOC
                                                                                                              MJ
                                             3/f3
                                             'HO
                                                                                                                         NO
                                                                                                  ANAtYtC
                                                                                                  I.J-ONI
                                                                                               1'MTIIOTOtUCNC
                                                                                              4-AIDNO-2.I-ONT
                                                                                                 CVClONITt
                                                                                                   HMX
                                        NO
                                        NO
                                        NO
                                        18.3
                                        S.28
                            MO
                            ND
                            NO
                            7J
                           2.17
                                     •/»*
                                     0.280
                                     2S.O
                                     O.SI3
                                     1.78
                                                                                                             2IM-l2-bv
                                                                                                              ia.0   NO
                                                                                                                         NO
                                                                                                                UCtNO
                                                                                                        NO
                                                                                                       .«. <«.  .«—
                                          MONITORING WELL
                                          NOT OETCCUD
                                          S1AFF  GAUGE
                                          WULAMO
                                          UMIMPMOVCO ROAD

                                          •AUBtD WIRC ICHCE

                                          ZUlU RANGE BOUNDARY
         Figure 6 Organic Compounds In Groundwater at AOC 26
        LROtT\DEUVER\SPIA\nNALRODyFlOURE6.WPD
                                                           M.y.

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page A - 7
  Figure 7 Organks in Groundwater at AOC 27
C:\PP & ROD\DEUVER\SP1A\FINALROI>F1GUR£7.WPD
M»y 30,1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25.26, & 27
Page A - 8
                                                    xuui mums MUMMY (tsruatto)
                                                    TOP00MMflC COMTOM
     w

   Figure 8 LocatfoB of Surface Water and SedineBt Sample, at AOC 26
C:\PP * ROD\DEUVER\SPIA\FINALRCH*nGURE8.WPD
M«y30.1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25, 26, & 27
                                                                                                  Page A - 9
                                                      ZUlUI-f •
                                                    2»-*2-
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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, A 27
Page A - 10
 Figure 16 Location of Soil Samples at AOC 27
       ROD\DEUVER\SPIA\FINALRODM10URE10.WPD
         996

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RECORD OF DECISION

South Post Impact Area & AOC 41 Groundwatcr and AOCa 25,26, & 27
Page A - 11
                                                                                                       «•«

                                                                                     ..   LOCATION Of AOC 41

                                                                  AOC 41-UNAOTHOB1ZED DUMP!HO AREA (SITE A>

                                                                            REMEDIAL INVESTIGATION REPORT

                                                                                        ,  FOUTOEVENSpMA
                                                                  »llllUlrill«»U>^l...	 1  ——— ^^.— r „.     . !•  .    ,
          Figure 11 Location of AOC 41 In South Post
  C:\PP & ROD\DEL1VER\SPIA\FINALROD\FIGURE11.WPD
   May 30, 1996

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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25, 26, & 27
                   RECORD OF DECISION SUMMARY
                   SOUTH POST IMPACT AREA AND
           AREA OF CONTAMINATION 41 GROUNDWATER AND
               AREAS OF CONTAMINATION 25, 26, AND 27
                   FORT DEVENS, MASSACHUSETTS
                           APPENDIX B

               DECLARATION OF STATE CONCURRENCE
C:\PP & ROD\DEUVER\SPIA\FINALROD\FROD30.WPD                               M«y 30,1996

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                       COMMONWEALTH OF MASSACHUSETTS
                       EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
                       DEPARTMENT OF ENVIRONMENTAL PROTECTION
                       CENTRAL REGIONAL OFFICE

WILLIAM F. WELD                                                           TRUDY
Governor                                                                   Secretary
ARGEOPAULCELLUCCI                                                    DAVID B STRUHS
Lt. Governor                                                               Commissioner


                                                        July 2, 1996
     Ms. Linda  Murphy,  Director
     Office of  Site Remediation and Restoration
     U.S. Environmental Protection Agency
     Region I-JFK Federal Building
     Boston, MA 02203
     RE: Record  of  Decision; South Post Impact Area  and Area of
         Contamination 41 Groundwater and Areas  of Contamination 25,
         26,  and 27,  Fort Devens, Massachusetts
     Dear Ms. Murphy,

          The Massachusetts Department of Environmental  Protection
     (MADEP) has  reviewed the above-referenced Record  of Decision
     (SPIA ROD) as  recommended by the United States Army and the U.S.
     Environmental  Protection Agency, Region I  (EPA) for the
     remediation  of the Fort Devens South Post Impact  Area  (SPIA)  of
     the former Fort Devens.  The MADEP has worked closely, with the
     Army and EPA in the development of the preferred  alternative and
     herein concurs with the Army's choice of remedy while .expressing
     the concerns summarized below.

          The SPIA  ROD covers a total of 964 acres and includes Area
     of Contamination (AOC)  41 groundwater as well as  AOCs  25,  26,  27.
     The chosen remedy now incorporates MADEP recommended elements and
     includes development and implementation of: a Long  Term
     Groundwater  Monitoring Plan and Ecological Management  Plan;
     refinement of  the existing groundwater model; annual sampling and
     analysis of  well D-l; a prohibition on future development  of
     drinking water sources in the SPIA monitored area;  five year site
     review provisions;  and final RCRA closure of AOC  25.
           75 Grove Street • Worcester, Massachusetts 01605 • Telephone (508) 792-7650

    Fax (508)792-7621                   ^J Pnmtd on Recycled Piper               TTD #(508)767-2788

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Concurrence
SPIA  ROD:Ft Devens
July  2,  1996
Page  2
     MADEP's concurrence with  this  remedy  is premised on  the
assumption contained  in the  remedy  that contaminants will be
contained by natural  barriers  within the SPIA.  The SPIA  ROD
anticipates development of a Long Term Groundwater Monitoring
Plan designed to demonstrate contaminant containment and  which
will enhance the Groundwater Model  upon which the remedy  relies.
Because of MADEP's concern for the  potential of continued
contaminant migration, the Army has agreed that the Plan  will
require the installation and monitoring of additional sentinel
wells or "early warning" wells to monitor off-site groundwater
flow.  In addition, due to the presence of contaminants from
prior Army training activities and  the future Army use of the
SPIA, MADEP considers the development of an ecological management
plan and an environmentally  sound plan for the control releases
from OB/OD to be of considerable importance and key to MADEP's
concurrence in this ROD.

     Exposure point concentration of explosive contaminants in
AOC 26 groundwater and non-compliance with the total petroleum
hydrocarbon MCP Method I, GW-1 standard as promulgated in 310 CMR
40.0974(2)  in four SPIA groundwater monitoring wells continues to
be a cause for concern. Therefore,  MADEP intends to be vigilant
in reviewing the future effectiveness of the remedy.  Should
future subsurface contaminant  migration be observed during the
remedial review process, MADEP will take necessary action to
ensure that the cleanup standard set forth in CERCLA §
121(d)(2)(A)  is met..

     The MADEP would  like to thank  the US Army,  particularly Jim
Chambers,  Fort Devens BRAC Environmental Coordinator,  Mark
Applebee and Darrel Deleppo  of the  US Army Corps of Engineers,
and Charles George, US Army  Environmental Center for their
efforts to ensure that the people and the environment of the
Commonwealth of Massachusetts  are protected in the selection of
the remedy for these  complex sites.

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ROD Concurrence
Fort Devens,  MA
July 2,  1996
Page 3
     We look  forward  to continuing  to work with EPA and the Army
in the implementation of the remedial alternative at the SPIA and
further clean-up activities on the  other Devens sites. If you
have any questions, please feel  free to contact John Regan at
(508) 767-2840 or Lynne Welsh at  (508) 792-7653, ext.  3851.
                                           Sincerely,
                                           E. dairl Suchman
                                           Regional Director
                                           DEP-CERO
cc: Fort Devens Mailing List  (cover letter only)
    Informational Repositories
    Jim Chambers, Fort Devens EEC
    Jim Byrne, EPA
    Charles George, AEC
    Mark Applebee, ACOE
    Ron Ostrowski, Mass Land Bank
    Jay Naparstek, MADEP
    Rebecca Cutting, MADEP

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                          EXECUTIVE SUMMARY


Fort Devens  is  located in Middlesex and Worcester counties  and is within
the towns  of Ayer,  Harvard,  Lancaster,  and Shirley,  Massachusetts.
Seventy-three study areas (SAs)  and areas of  contamination  (AOCs)  at  Fort
Devens have  been  investigated for potential environmental restoration.

This Record  of  Decision (ROD)  addresses AOCs  25  (the Explosive Ordnance
Disposal  (EOD)  Range),  26 the Zulu Ranges), and  27 (the  Hotel  Range),  and
groundwater  within  the South Post Impact Area (SPIA)  north  and west of the
New Cranberry Pond  groundwater divide.  This area is  approximately 964  acres
and is referred to  in the ROD as the  "SPIA monitored-area"  (See  Figure  l)
AOC 41 (Unauthorized Landfill)  groundwater was added to  the  ROD subsequent
to the February 21,  1996  public meeting.   Additional time for  public  review
and comment  was provided.  The logic for including the AOC 41 groundwater in
this ROD is  based on the  results of the Final Remedial Investigation  (RI)
completed  for AOC 41 (February 1996) .   The RI indicates  that proposed
.actions are  the same for  the SPIA and AOC 41  groundwater, AOC  41  adjacent
to the SPIA,  and  AOC 41 is small in area (6 acres) .   Adding AOC 41 to this
ROD would  only  increase the  total land  area covered  in this ROD by a  small
increment. Therefore,  the U.S.  Environmental  Protection  Agency-(USEPA) New
England recommended including AOC 41 groundwater into this ROD.

 S" Is ROD presents the selected remedial action for the site, chosen in
  cordance with Comprehensive Environmental Response Compensation and
  ability Act (CERCLA), as amended by Superfund  Amendments and
Reauthorization Act  (SARA) ,  and,  to the extent practicable,  the National
Contingency  Plan  (NCP) .   This decision  is based  on the Administrative
Record for the  site.   The Administrative Record  is a collection of all the
documents used  by the Army in determining the most appropriate action to
take at the  SPIA.   The Administrative Record  is  available for  public review
at the Fort  Devens  Base Realignment and Closure  (BRAC) Environmental Office
and the Ayer Town Hall, Ayer,  Massachusetts.

The entire SPIA,  including the 964 acre SPIA  monitored-area, is
approximately 1,500  acres and is located within  the  4,800-acre South Post
section of Fort Devens.   The SPIA is, and will be  for the foreseeable
future, an active weapons and ordnance  discharge area used by  the Army,  the
Massachusetts National Guard,  and nearby law  enforcement agencies for
training purposes.

Metals, organic compounds, petroleum hydrocarbons, and explosive chemicals
were detected in  soil,  sediments,  groundwater, and surface water during  the
Remedial Investigation (RI)  of SPIA groundwater  and  the  EOD, Zulu, and
Hotel Ranges.   Using data from the RI,  the  Army  prepared a Baseline Risk
Assessment to determine potential risks to  human health  and the environment
under reasonable  exposure assumptions.

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No unacceptable  risks  to human health and the environment  were  found  to  b»
associated with  the  SPIA groundwater,  even though levels exceeded  Army anl
USEPA action  levels.   No hazardous substances were detected  in  the one
public drinking,  water  well  on the South Post,  Well D-l.  Well D-l,  which is
located near  the northeast  edge of the SPIA,  is  used on a  limited  basis  by
military personnel during training activities.   Also, no unacceptable
ecological risk  to surrounding habitats were  found to be associated with
the SPIA groundwater due to the absence of a  pathway for any known
ecological receptor  to access the groundwater.

Risk assessment  results for the EOD,  Zulu,  and Hotel Ranges  show that human
health risks  were identified to be within USEPA  risk guidelines for
assessed pathways.   Risk to on-site ecosystems,  in some instances,  were
found to be outside  of USEPA risk guidance, however, ecological risks
identified on the EOD,  Zulu,  and Hotel Ranges were deemed  by USEPA-New
England to be acceptable due to their low level.

"No action" is the selected remedy for the SPIA  groundwater.  Under this
alternative,  no  formal remedial action is taken  and the site is considered
to be left "as is,"  with no additional institutional controls, containment,
removal, treatment,  or other mitigating measures.   This remedy includes  the
development and  implementation of an Ecological  Management Plan and a
Groundwater Monitoring Plan.   The Groundwater Monitoring Plan will  include
the installation of  sentinel wells to monitor the  groundwater.  Details of
the monitoring plan  will be developed jointly by the Army,  USEPA-New
England, and  Massachusetts  Department  of Environmental Protection  (MADEP)
within 6 months  of ROD signature.

As part of this  remedy,  the Army will  ensure  the  following:

          • Groundwater monitoring will continue  for potential contaminant
          migration  out of  the SPIA.   Monitoring wells will be sampled for
          explosives,  Target  Compound  List  (TCL)  ,  and the Target Analyte
          List (TAL) metals annually.   The Army will rerun the groundwater
          model  to incorporate data from new  sentinel well(s) and ascertain
          any potential impacts to MCI Shirley.

          • A Groundwater Monitoring  Plan for  the  South Post will be
          developed, that will include detailed groundwater monitoring at
          discharge  points.   The plan  will include  specific information on
          additional sentinel  wells to monitor potential off-site
          groundwater  flow.   The groundwater  monitoring plan will be
          completed  within  6  months of ROD signature.

          • Well  D-l will be  sampled  annually  and  analyzed for explosives
          and Massachusetts and Federal drinking water requirements
          (MMCLs/MCLs).  No  new drinking water  sources will be developed
          within  the SPIA.

          • An Ecological Management  Plan will be  developed and implemented
          to  monitor any impacts to ecosystems in  the SPIA.

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 Monitoring reports  will include a description of site activities and a
 summary of analytical  results.   Reports will be submitted to MADEP and
 USEPA annually.

 "No  action"  is  also the selected remedy for the surface  water,  sediment,
 and  soils  at the  EOD,  Zulu,  and Hotel Ranges.   The Army  has  submitted a
 Closure Report  under the Resource Conservation and Recovery  Act (RCRA)
 Subpart X;  formal approval of the closure of EOD Range will  occur prior  to
 ROD  signature.

 Once  the final  ROD  is  approved,  the Fort Devens environmental  staff  will
 ensure  the development and implementation of a long-term Ecological
 Management Plan.  The  details of this plan will be developed jointly by  the
 Army, USEPA-New England,  U.S.  Fish and Wildlife Service,  and MADEP within 6
 months  of  the ROD signature.

 This  site,  as required by CERCLA,  will be subject  to. 5 year  reviews.
 During  a 5 year review,  an assessment is made  as to whether  the implemented
 remedy  is  protective of human health and the environment  and whether the
 implementation  of alternative remedial actions are needed to ensure
-adequate protection.   Should on-site hazardous substances migrate  off-site,
 the Army will take  the necessary and appropriate actions  to  protect  human
 health  and the  environment as required under CERCLA.   More frequent  reviews
 may be  conducted if  site conditions change.   Should the Army close and/or
 transfer this property,  an Environmental Baseline  Survey  (BBS)  will  be
 conducted.   The BBS  will be  provided to the  USEPA-New England and  MADEP  for
 comment.

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                       COMMONWEALTH OF MASSACHUSETTS
                       EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
                       DEPARTMENT OF ENVIRONMENTAL PROTECTION
                       CENTRAL REGIONAL OFFICE
WILLIAM F. WELD
Governor

ARGEO PAUL CELLUCCI
Lt. Governor .
MEMORANDUM
   TRUDY COXE
      Secretary

DAVID B. STRUMS
   Commissioner
TO:        Gail Suchman, Regional Director,  CERO

FROM:      Lynne Welsh, Section Chief,  CERO  Federal  Facilities

DATE:      July 2,  1996

SUBJECT:   South Post Impact Area and Area of  Contamination 41 Groundwater
           and Areas of Contamination 25, 26 and 27,  Fort Devens,
           Massachusetts; Evaluation of Remedial Action Record of Decision
           under M.G.L. c. 21E and the Massachusetts Contingency Plan (MCP)
I. INTRODUCTION
 he Record of Decision (ROD) addresses AOCs  25  (Explosive Ordnance Disposal
(EOD) Range) ,  26 (Zulu Ranges) , and 27  (Hotel Range  and  AOC 41
(unauthorized dumping area) groundwater and  groundwater  within the South
Post Impact Area (SPIA) .  The site locations  are depicted in Figure 1 and
are described below.

SPIA The  approximately 1500 acre SPIA is located within  the 4800 acre South
Post section of Fort Devens  (Figure 1) . The  SPIA is  generally bounded by
Old Turnpike Road,  Firebreak Road, the southern portion  of Harvard Road,
Trainfire Road and Dixie Road. The SPIA includes AOCs  25,  26,  27 and 41 as
well as several study areas, and a number of ranges  along Dixie Road and
Trainfire Road that are not designated as AOCs. The  SPIA area covered in
the ROD encompasses the 964 acres north and  west of  New  Cranberry Pond -
unnamed stream wetland groundwater divide. This area is  referred to as the
SPIA monitored-area. The AOCs  and the SPIA are detailed  in Figure 1.

EOD Range (AOC 25)  is located  east of Firebreak Road,  approximately two
miles south of the main entrance to the South Post.  The  site is rectangular
and measures approximately 600 feet by 1,500 feet.

Zulu Ranges (AOC 26) are located 2,000 feet  north of the EOD range,
approximately 1.6 miles southwest of the main entrance to the South Post.
the Zulu  Ranges cover approximately 16 acres and consist of two adjacent
land tracts (Zulu 1 and Zulu 2).
            75 Grove Street • Worcester, Massachusetts 01605 • Telephone (508) 792-7650

     Ftu (508)792-7621                  O pnm«< °" *"**>«* P«P«               TTD #(508)767-2788

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Hotel Range  (AOC  27)  is  adjacent  to  Cranberry  Pond  and  is  located
approximately one mile south  of the  main entrance to  the South  Post.  The
Hotel Range  covers approximately  23  acres and  is currently used exclusively
for firing small  caliber weapons.  The  area of  concern where  open
burning/open detonation  of  explosive materials  is located  exclusively south
of Old Turnpike Road.

Unauthorized Landfill  (AOC  41) is  located immediately north  of  New
Cranberry Pond, approximately two  miles south east  of the  main  entrance to
South Post.

The ROD presents  the  selected remedial action for the site,  chosen in
accordance with CERCLA as amended  by the Superfund  Amendments and
Reauthorization Act  (SARA).

EPA has scheduled the signing of the ROD documenting  the selection of  the
proposed remedial action for  the South Post Impact  Area  (SPIA)  and Area of
Contamination  (AOC) 41 groundwater and AOCs 25, 26  and 27  for the end  of
June 1996, The ROD will  detail the Army's decision  to implement  a no-action
ROD that addresses the principal known threats at the site through the
design and implementation of  a long  term Groundwater  Monitoring  Plan  and a
long term Ecological Management Plan.

This memorandum briefly  describes  the site,  the reasons for  implementation
of a no-action ROD and a discussion  of its effectiveness at  controlling   .
site risks.   The alternative is then  evaluated with  respect to the statutoii
requirements of M.G.L  c. 21E and  the regulatory requirements of the MCP.
The purpose  of this memorandum is  to outline the Massachusetts Department
of Environmental  Protection's (MADEP) reasoning leading to concurrence with
the ROD.

The proposed plan was initially released by the Army  for thirty day public
comment on February 1, 1996. This  plan described a no-action remedy for the
SPIA and AOCs 25,  26 and 27. These sites are collectively known as
Functional Area (FA)  I.  Concurrent with the release of the proposed plan,
the Army published a Preliminary Draft Record of Decision for the South
Post Impact Area Groundwater and Areas of Contamination 25, 26 and 27.
Subsequent to the publication of this plan,  a decision was made by the Base
Cleanup Team (BCT) to incorporate  AOC 41 groundwater  into the plan due to
its South Post location  and similarities to the FA  I  sites. The inclusion
of AOC 41 precipitated the publication of a Draft Final Record of Decision
for the South Post Impact Area and Area of Contamination 41 Groundwater and
Areas of Contamination 25, 26 and  27. No proposed plan was published to
reflect this draft ROD.  Instead,  the final draft served as the vehicle for
a second public comment  period which was conducted during the period of May
17 through June 4, 1996.

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KI.  PREFERRED REMEDIAL ACTION ALTERNATIVE

 The  remedial alternative preferred by the Army and described in the ROD
 addresses the principal known threats to the AOCs and the SPIA through the
 implementation of a no-action ROD. The Army's preferred remedy is presented
 in Section VIII and IX of the Final Record of Decision for the South Post
 Impact Area and Area of Contamination 41 Groundwater and Area's of
 Contamination 25, 26 and 27.  No CERCLA Feasibility Study was conducted for
 the  SPIA sites. However,  it was concluded from the results of the Remedial
 Investigations (RI)  and the human health and ecological risk assessments
 that no further action was necessary for the sites.  Based on these
 conclusions and given that the Army will continue to be active within the
 SPIA,  no further action or remediation was recommended for the subject
 sites and no remedial action objectives were set.

 "No  Action" is the selected remedy for the SPIA and  AOC 41 groundwater as
 well as soils and sediments at AOCs 25,  26,  26. Under this alternative,  no
 formal remedial action is taken and the site is left "as is"  with no
 additional institutional controls, containment, removal,  treatment,  or
 other mitigating measures. However,  the remedy does  require the design and
 implementation of a Long Term Groundwater Monitoring Plan and Ecological
 Management Plan.  The ROD does not preclude further remediation of soils,
 sediments and solid waste at  AOC 41.  The Army has submitted a Closure
 Report under the RCRA Subpart X.  Formal approval of  the closure of AOC 25,
 the  EOD range, will occur prior to ROD signature.
     groundwater modeling plan will include sentinel wells  to monitor the
 groundwater.  The MADEP,  USEPA and the U.S. Army will jointly develop
 details of the monitoring plan within six months of ROD  signature.  As part
 of  this remedy,  Fort Devens  will ensure the following:

           • Groundwater  monitoring for potential contaminant migration from
           the SPIA will  be implemented. Monitoring wells will be  installed
           to monitor groundwater from AOCs 25,  26,  27 and  41. The
           installation of wells at these locations provides the capacity  to
           monitor groundwater flow emanating from the SPIA.

           • The monitoring wells will be sampled for explosives,  target
           compound list  (TCL)  and the target analyte list  (TAL) metals
           annually in the fall.

           • A Groundwater Monitoring Plan for the South  Post will be
           developed that will include detailed groundwater monitoring at
           discharge points.  The plan will include specific information on
           additional sentinel wells to monitor off site  groundwater flow.
           The plan will  be developed and implemented within six months of
           ROD signature.  Monitoring reports will include  a description of
           site activities and a summary of analytical results. Further
           assessment and/or remedial action will be implemented if  the long
           term monitoring plan indicates an increase or  transport of
           contaminants.

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           •  The  South Post groundwater  model  will be refined with the
           inclusion of the new wells. The  model will be expanded  to  refle<^|
           any  potential impacts on  MCI  Shirley.

           •  Well  D-l,  the South Post drinking water well,  will  be sampled
           annually and analyzed for explosives and Massachusetts  and
           Federal drinking water requirements (MMCLs &  MCLs). No  new
           drinking water supplies will  be  developed within the  SPIA.

           •  An Ecological Management Plan  will be developed and implemented
           within  six months of ROD  signature.

The remedy selected for the SPIA and AOC 41 Groundwater and AOCs  25, 26,
and 27 are protective of human health and  the environment.  Risks  to  human
health were  found to be within USEPA guidelines.  Risks  to  ecological
receptors  were found to be minimal. Toxicity  tests AOC  26  indicate that
metals, explosives,  and other  organic compounds found on the  sites do not
pose unacceptable risks to plants or wildlife.

The Army will  maintain control of the South Post  for future military
training activities.  Public access  to the  site will continue  to be
restricted,  and admittance by  unauthorized personnel will  be  prohibited.
Currently  the  South Post is enclosed by a  fence and legal  access  can only
be gained  through gates that are  controlled by the Army Range Control
Office. However,  if the Army were to surrender control  of  the South Post
and release  the land for other purposes, additional assessments would be
required by  the Army.  Should the  Army close or transfer the property, an
Environmental  Baseline Survey  (BBS) will be conducted.  The  BBS will be
provided to  both  the USEPA and MADEP for comment.

The SPIA and AOCs will be subject to five  year CERCLA reviews. During the
reviews, an  assessment will be made as  to  whether the implemented action
remains protective of  human health and  the environment  and  whether
additional remedial actions are necessary.

III.  SITE HISTORY AND DESCRIPTION

           A. SITE HISTORY


Fort Devens  was established as Camp Devens in  1917.   It was used as a
temporary  training camp for soldiers from  the  New England area.   The camp
became a permanent installation in 1931 and was renamed  Fort Devens.
Throughout its history,  Fort Devens has served as  a training and induction
center for military personnel  and as a  unit mobilization and demobilization
unit.   The installation was used  in this capacity,  to varying degrees,
during World Wars I and II,  the Korean  War, the Vietnam Era, and operations
Desert Shield  and Desert Storm.   The primary mission of Fort Devens is to
command, train, and provide logistical  support  for  nondivisional troop
units and  to support  and execute  Base Realignment  and Closure (BRAC)
activities.  The  installation  also supports the Army Readiness Region and
the National Guard units in the New England area.

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 The  South Post consists mainly of undeveloped land.   In  the  past,  some
 |ogging and limited farming have taken place.  The ranges  on the  South  Post
 Ire  currently used for mortar,  light anti-tank,  small  arms and  grenade
 detonation. No artillery or heavy weapons are fired at Fort  Devens.  Managed
 forest  accounts for much of the remainder of the area.

 At least some portion of the SPIA has been used for military training since
 the  inception of Fort Devens as Camp Devens in 1917.   At various  times,
 demolition training and OB/OD have been conducted at  the EOD, Zulu,  and
 Hotel Ranges.   A discussion of  land-use activities at  these  ranges'follows.

 EOD  Range (AOC 25)  - From 1979  to 1992,' approximately  1,200  pounds per year
 of explosives and ammunition were disposed of in the disposal area by
 OB/OD.   The Army has submitted  a Closure Report  under  the  Resource
 Conservation and Recovery Act (RCRA)  Subpart X;  formal approval of the
 closure of EOD Range will occur prior to ROD signature.  Currently,  the
 range operates under a RCRA emergency permit and is used once or.twice a
 year.   A 1-acre disposal area is located along the southeastern boundary of
 the  range.

 Zulu Ranges (AOC 26)  - Prior to 1979,  the range  was used for OB/OD of waste
 explosives and associated waste items.   Zulu 1 is primarily used  for
 demolition training.   The demolition training area is  located in  the center
 of Zulu 1.  Zulu 2  is used primarily as a practice range for hand  grenade
 training.   The grenade training area is located  on the eastern end of Zulu
 2 and consists of two concrete  bunkers,  which are used for cover and
protection,  and two sand pits,  which are used for receiving grenades.

 Hotel Range (AOC 27)  - Before 1979,  the Hotel Range was used for OB/OD of
 small arms,  smoke grenades,  and pyrotechnics.  After 1979,  the Hotel Range
 was  modified and extended to the north side of the Old Turnpike Road and
 used for M-16s and  small caliber weapons.   Prior to 1989, the range was
 used as an M-70 range,  but after 1989  the range  was modified to an M60-SAW
 range.
 Unauthorized Landfill (AGO 41)  - AOC 41 is approximately 6 acres in size
 and  is  located between Harvard  Road,  New Cranberry Pond,  and an eastern
 portion of the impact area in the South Post  (Figure 11 of Appendix A) .
 The  landfill material occupies  and area approximately 75 feet by 75 feet in
 the  central portion of the site.   It appears  to  have been associated with
 an old  brick-making kiln that was operated in this area in the 1800s.  The
AOC  is  overgrown with trees  and swampy vegetation and no records are
 available detailing when the site was  used or what type of material was
 disposed of in this area.   It is believed that this AOC was used until the
 1950s for disposal  of nonexplosive military and  household debris.
 Miscellaneous  debris is scattered over a small hill located approximately
 75 feet north of New Cranberry  Pond.   The hill slopes down to a low area at
 the  base of the hill.   The ground surface elevation rises to the south,
 then slopes again down to New Cranberry Pond.

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 In  conjunction with the Army's Installation Restoration Program (IRP),  Fort
 Devens  and the U.S.  Army Environmental Center (USAEC,  formerly the U.S.
 Army  Toxic and Hazardous Materials Agency)  initiated a Master Environmental
 Plan  (MEP)  in 1988.   The MEP assesses the environmental status of  Study
 Areas (SA),  specifies necessary investigations,  and provides
 recommendations for response actions with the objective of identifying
 priorities for environmental restoration at Fort Devens.   The MEP
 recommended that a record search be conducted to better define past and
 current  activities.   It also recommended that the extent  of contamination
 be  determined by collecting soil samples and analyzing the samples for  the
 United  States Environmental Protection Agency (USEPA)  hazardous substance
 list  compounds and total petroleum hydrocarbons  (TPHC).   The MEP also
 suggested  installing monitoring wells if hazardous substances were detected
 in  deeper  soils.

 On  December 21,  1989,  Fort  Devens was placed on  the NPL.   Fort Devens was
 listed  as  an NPL site because hazardous substances were detected at two
 sites other than the EOD, Zulu,  and Hotel Ranges (volatile organic compound
 (VOC) contamination  in the  groundwater at the Shepley's Hill  Landfill and
 metal contamination  in the  groundwater at the Cold Spring Brook Landfill).
 A Federal  Facilities Interagency Agreement  (IAG)  was developed and signed
 by  the Army and USEPA-New England (Region I)  on  May 13, 1991  and finalized
 on November 15,  1991.   The  IAG provides the framework  for implementing the
 CERCLA/SARA process  at Fort Devens.

 Under Public Law 101-510, the Defense Base  Realignment and Closure  Act of
 1990, Fort  Devens was selected for cessation of  operations  and closure.
 However, the SPIA will be retained by the Army for continued  use as a
 training range.   An  important aspect  of BRAC actions is to  determine
 environmental  restoration requirements before property transfer  can be
 considered.  As  a result, an Enhanced Preliminary Assessment  (PA) was
performed at Fort Devens to address  areas not normally included  in  the
 CERCLA process,  but  that required review prior to base closure.  Although
 the Enhanced PA covers MEP  activities,  its  main  focus is  to determine if
additional  areas  require detailed records review and site  investigation.
The Enhanced PA also provides information and procedures  to investigate
 installation-wide areas requiring environmental  evaluation.  A final
version of  the Enhanced PA  report  was completed  in April  1992.


RIs were prepared for the SPIA Groundwater  and EOD,  Zulu, and  Hotel Ranges.
These were  submitted to the USEPA-New England and the Massachusetts
Department  of  Environmental Protection (MADEP) in August  1994.  An RI was
completed for  AOC 41 in February 1996.  A Proposed Plan and  summary Fact
Sheet have been prepared for the SPIA and AOC 41  Groundwater and EOD, Zulu,
and Hotel Ranges.  These documents  have been placed  in the Administrative
Record and  are available for public  review  at  the  Fort Devens  BRAC
Environmental  Office and the Ayer Town Hall,  Ayer, Massachusetts.

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           B.  NATURE AND EXTENT OF CONTAMINATION

Kls were conduction for the EOD,  Zulu,  Hotel Ranges and AOC 41 to
 characterize the nature and extent of site-related contamination.  Samples
 from groundwater, surface water,  sediments,  and soil were taken.   Chemical
 analyses were performed on the samples taken from the various media,  and
 the results were compared with screening values previously developed.   The
 results -of the chemical analyses  were reviewed to determine whether
 hazardous substances detected were related to site activities or  were
 naturally occurring.

 1.   GROUNDWATER

 Groundwater at Fort Devens occurs largely in the permeable glacial-deltaic
 outwash deposits of sand,  gravel,  and boulders.   Groundwater is found  under
 the South Post at depths of 0 to  60 feet.   The flow of groundwater on  the
 South Post is determined by the bedrock and till topography.   A number of
 springs can be found around the circumference of SPIA.

.Groundwater in the vicinity of the ranges  discharges to surface water
 before it leaves the South Post.   More  than 50 percent of the SPIA overlies
 a medium yield aquifer that is a  potential source of drinking water.   MADEP
 concurrence with this ROD constitutes MADEP's agreement that  the  site  is
 adequately regulated under the provisions  of 310 CMR 40,000,  the
 Massachusetts Contingency Plan.   Measurements of hydraulic head in the
 oroundwater and in streams and ponds within the  South Post show that the
 fcreams around the SPIA are gaining streams  (i.e.,  groundwater discharges
 Kito the streams).  Groundwater flow direction is complex in  certain areas
 of  the SPIA. At the EOD Range,  overall  groundwater discharge  is to the east
 from the north end of the disposal area.   At the Zulu Ranges,  groundwater
 moves north toward a wetland and  Slate  Rock  Brook.   At the Hotel  Range,
 groundwater flow is east to Cranberry Pond and north.   AOC 41 groundwater
 generally flows east towards the  Nashua River, however,  there is  some  local
 flow,  south, to New Cranberry Pond.  Groundwater  models developed  in
 conjunction with the RI report indicate that there are several groundwater
 divides in the area and that most  groundwater discharges to surface water
 before leaving the SPIA. Inconsistencies in  the  groundwater models are
 expected to be resolved during future modeling efforts which  will
 incorporate data from the proposed new  sentinel  wells.

 Fort  Devens withdraws groundwater from  wells on  the Main Post and  the  North
 Post.   The Fort maintains a transient noncommunity supply well, Well D-l,
 on  the South Post along Dixie Road at Echo Range (E)  near the north end of
 Alpha Range (A)  (Figure 1 of Appendix A) .  This  well is not used  to serve
 the general public,  but is used to supply  troops who train on the  South
 Post.   These troops spend no more  than  2 weeks per year at the site.   Fort
 Devens Range Control Staff do not  use this well  and there are no plans to
 provide connections to the Range  Control Offices.

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Groundwater  quality samples collected from Well  D-l show that no chemicals
or metals  were  detected at concentrations above  USEPA guidelines.
Specifically,  five samples have been collected from Well D-l (May 1991,
June  1991, two  samples in April 1992,  and March  1993)  and were analyzed  for
USEPA's Target  Analyte List (TAD  metals,  USEPA's Target Compound List
 (TCL), total organic carbon (TOO,  and water quality parameters.   A summary
of results is presented in Table 1 in Appendix E of the ROD. Only one
chemical,  bis(2-ethylhexyl) phthalate,  exceeded  a screening value (USEPA's
Maximum Contaminant Level  (MCL) ) .   As two of the samples show no detectable
concentration of  bis(2-ethylhexyl)  phthalate,  the RI Report attributes the
finding of this chemical to sampling or laboratory error.

Groundwater  samples were collected from the SPIA monitoring wells  and the
data  is presented in Table 8-2 of  the final RI.

Groundwater  quality samples for the EOD and Zulu Ranges were taken in
November 1992,  March 1993,  and June 1993 (Figures 2 and 3  of Appendix E
show  well  locations).   Samples were collected from eight monitoring wells
at the EOD Range  and seven wells at the Zulu Ranges.   At the Hotel Range,
groundwater  samples from four  wells were taken in September 1992 and
January 1993, and an additional six wells  were samples as  part  of  the RI in
August and November 1993.

The samples  taken at the EOD Range  were analyzed for TAL metals and
explosives,  as  well as hardness.   The  samples  taken at the Zulu Ranges were
analyzed for TCL  organics,  TAL metals,  explosives,  and TPHC,  as well as
hardness.  Samples taken at the Hotel  Range were analyzed  for TAL  metals,
TCL pesticides, explosives, TPHC,  and  water quality parameters.

Two rounds of off-site laboratory  analytical samples were  collected during
each  of the  field investigations conducted at  AOC 41.   The focus was on the
1994  RI sampling  results (Rounds Five  and  Six) because these rounds
included all  new  and existing  monitoring wells.   The results of the  1994 RI
sampling analysis are presented in  Section 7.0 of  the  RI Report.

SPIA  - Sampling events from the SPIA monitoring  wells  indicated the
presence of  explosives (dinitrobenzene  and cyclonite)  in three  wells.
Although their  concentrations  were  low,  no obvious  source  of the
contamination was found.  Additionally,  four wells were found to have low
concentrations  (below MCP Method 3  UCL,  but exceeding  Method 1  standard for
GW-l) of total  petroleum hydrocarbons  and  one  unfiltered sample was  found
to contain lead.  The results of the SPIA monitoring are  contained  in Table
8-2,  Volume  I of  the RI.

EOD Range  (AOC  25)  -  Unfiltered samples from the  EOD Range showed  levels of
iron, aluminum, and other metals above  the concentrations  found in local
background samples.   Background samples are those collected in  a similar
medium (i.e., water,  soil,  sediment) that  are  not believed to be
contaminated.   Samples that were filtered  to eliminate suspended solids
(i.e., soil  and sediments to which  metals  may  adhere)  and  measure  only the
metal dissolved in the water,  showed concentrations several orders of

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 magnitude lower than in the unfiltered samples (Tables 2 and 3 of Appendix
 E  of  the  ROD).   Manganese and calcium exceeded background concentrations in
 Jiltered  samples.   None of the metals in filtered samples,  however,
 exceeded  health-based screening values described in the RI  report.'  Four
 explosives or explosive-related organic compounds (Cyclonite (RDX),
 cyclotetramethylene tetranitramine (HMX),  pentaerythritol tetranitrate
 (PETN), and trinitrotoluene (TNT)  were also detected in the samples.   Only
 RDX exceeded the screening value.   Organic compound results are shown on
 Figure  5  of Appendix A.

 Zulu  Ranges (AOC 26)  - Metals concentrations in the Zulu Ranges groundwater
 samples  (unfiltered)  were higher than concentrations found  in local
 background samples.  As with the samples  collected in the EOD,  filtered
 samples showed lower concentrations than  the unfiltered samples in the Zulu
 Ranges  (Tables 4 and 5 of Appendix E) .   The maximum concentration of
 manganese in filtered samples (62  micrograms per liter,  (/zg/L) )  exceeded
 the screening value (50 fj.g/L) .   Several explosives or explosive-related
 organic compounds  (RDX, HMX,  and TNT)  were also detected in these samples.
 RDX at  390 ng/L exceeded its health-based  screening value (2  fig/L) .   The
 monitoring wells showing the most  significant concentrations  of explosives-
 related substances are located where  grenade-throwing and demolition  are
 practiced.   The groundwater from the  Zulu  Ranges  discharges to  surface
 water located within the South Post.   Organic compound results  are shown on
 Figure  6  of Appendix A.

 Hotel Range (AOC 27)  - Metals concentrations in the  EOD Range groundwater
kamples  (unfiltered)  also exceeded concentrations found in  local  background
^mples.   Filtered samples showed  lower concentrations than the unfiltered
 samples  (Tables 6  and 7 of Appendix E) .  The maximum concentration of
 manganese in filtered samples (74.1 /xg/L)  exceeded the screening value of
 50 M9/L.   In addition,  aluminum at concentrations up to 72.3  ng/L exceeded
 the screening value (50 /ig/L)  in some  filtered samples.   All  wells in  this
 area  indicated some level of explosives contamination.   RDX (up to 17.9
 /zg/L)  and 1,3-dinitrobenzene (up to 1.82 /zg/L)  exceeded their screening
 values  (2 M9/L and 1  fig/L,  respectively) .   Organic compound results are
 shown on  Figure 7  of  Appendix A.

 Unauthorized Landfill (AOC 41)  - Groundwater at AOC  41 is contaminated with
 several VOCs.   However,  three VOCs (1,1,2,2-TCA,  PCE and TCE) have been
 found to  have  the  widest dispersion and concentrations.   1,1,2,2-TCA was
 detected  at a  maximum concentration of  170  p.g/L,  PCE was detected at a
 maximum concentration of 10 ng/L and TCE at a maximum concentration of 220
 ptg/L.   The  groundwater results also indicated that several  inorganics
 (aluminum,  arsenic,  beryllium,  chromium, cobalt,  iron,  lead,  manganese,  and
 nickel) were present  in unfiltered groundwater samples above  the
 established Fort Devens background and  drinking water standards.  However,
 a comparison of these results to filtered  groundwater samples and TSS
 concentrations  indicate that the unfiltered concentrations  are  a  likely
 result of suspended solids and not dissolved site-related contaminants.•

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No obvious  source  of  VOC contamination  was  precisely located,  however,  it
was  determined  that the  waste  material  located  at  AOC 41 was not the
source.


2.   SURFACE WATERS

The  SPIA  is drained primarily  by two  streams, Slate  Rock Brook north and
west of the SPIA and  an  unnamed  stream  in the southeast  portion of  the
site .

EOD  Range  (AOC  25) -  No  surface  water is known  to  exist  within or adjacent
to the EOD.  During the  RI,  one  surface water sample was collected  from  the
emergence of Slate Rock  Brook  near the  EOD  Range,  although  the RI report
notes that  the  sample is not representative of  surface water originating  at
the  EOD Range.  This  sample  was  analyzed for TAL metals,  TCL organics,
explosives, and water quality  parameters.   Several metals in the sample
exceeded USEPA's Ambient Water Quality  Criteria (AWQC) for  the Protection
of Aquatic  Organisms  (Freshwater Chronic) .  Sample analysis  results  are
presented in Table 8  of  Appendix E.

Zulu Ranges (AOC 26)  - Thirteen  surface water samples were  collected for
the RI from wetlands  and drainage areas potentially  affected by activities
at the Zulu Ranges.   Figure  8  of Appendix A shows  surface water sampling
locations in the Zulu Ranges.  These  13 samples were analyzed  for TCL
organics, TAL metals,  explosives, TPHC, and water  quality parameters.
Sample analysis results  are  presented in Table  9 of  Appendix E.

Analysis of the Zulu  Range samples collected during  the  RI showed two
metals exceeding USEPA AWQC: arsenic  detected at a concentration of  7.18
Hg/L (AWQC  of 0.018 /ig/L) and  lead at a maximum concentration  of  106 M9/L
(AWQC of 3.2 fig/D .   Earlier samples  collected as  part of a  previous
investigation,  the Site  Inspection (SI) , showed higher concentrations than
those found in  the RI  samples.   The differences between  the  two
investigations may reflect -different  sampling methods, field conditions,  or
laboratory  procedures.   Explosives (including RDX  and HMX) ,  as  well  as
several organic compounds, were  detected in samples  from the Zulu Ranges.
One of the  thirteen samples  contained a detectable concentration  of  ODD
(0.086 M9/L) that  exceeded the AWQC (0.00083
Hotel Range  (AOC 27)  - Nine surface water samples were collected for the RI
within Cranberry Pond, adjacent to the Hotel Range.   (Three samples had
been collected earlier during the SI.)  The six RI samples were analyzed
for TCL VOCs, pesticides, and polycyclic aromatic hydrocarbons  (PAHs) ; TAL
metals; explosives; TPHC; and water quality parameters.  Figure 4 of
Appendix A shows surface water sampling locations in the Hotel Range.
Sample analysis results are presented in Table 10 of Appendix E.
                                     10

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[Several  metals were detected in the surface water samples collected in the
Hotel  Range.   One metal,  lead,  was detected at a concentration of 18.2
M9/L,  which exceeded the  AWQC (3.2 ^g/L).   Trace levels of explosives or
explosive-related compounds were detected in these samples.

Unauthorized Landfill (AOC 41)  - The results of the soil sampling completed
during the three field investigations indicated that some contamination was
present  on the surface soil of  the waste  material.   The remediation of the
soil contamination will be completed under Massachusetts Solid Waste
Regulations.

3.  SEDIMENTS

Samples  of sediments were taken in conjunction with the surface water
samples  discussed above.   The samples taken at the  EOD  Range,  Zulu Ranges,
and Hotel Range were analyzed for TAL metals,  TCL organics,  explosives,
TPHC,  TOC,  and grain size.

SPIA - Three  sediment samples collected from the unnamed wetland southwest
of New Cranberry Pond exhibited exceedances of local background.  However,
the metal concentrations  in sediments appeared to be influenced by sorbed
solids on organic carbon.  There is no evidence that the metals present  in
the sediments are related to contamination,  but may be  due to  the high
levels of total organic carbon  present in  the wetlands.

EOD Range (AOC 25)  - Several metals in the EOD Range sample  exceeded the
Concentrations detected in a local background sediment  sample.   Sample
analysis  results are presented  in Table 11 of Appendix  E.

Zulu Ranges (AOC 26)  -  Most metals in the  Zulu Range samples were detected
above  background concentrations in at least one sample.   Explosives,
pesticides, VOCs,  and TPHC were also detected.   Sample  analysis  results are
presented in  Table 12 of  Appendix E.   No screening  values were established
in the RI for organic compounds in sediments.

Hotel  Range (AOC 27)  -  Most samples collected in Cranberry Pond  contained
some metal  concentrations in excess of those naturally  occurring in  the
sediment.   However,  the data indicate that only one sample is  unequivocally
contaminated  with metals.   The  explosive 4-amino-2,6-dinitro toluene was
detected  in one third of  the samples.   VOCs,  pesticides,  TPHC,  and two
PAHs: benzo (b)  fluoranthene and pyrene were also detected.  Sample
analysis  results are presented  in Table 13 of Appendix  E.  Complete
analytical  results are  presented in the RI Report.

4. SOIL

The predominant soil in the South Post, including the areas  of
investigation,  is the Hinkley-Merrimac-Windsor (HMW) Association.  This
soil consists of loams  or sandy loams,  loamy fine sands,  and other sands
over sand or  sand and gravel.   In the active ranges,  including the EOD,


                                     11

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 Zulu,  and Hotel Ranges,  the natural soils are disturbed.   A soil mapping
 the  SPIA found that,  almost without exception,  the soils  are sandy and
 drained.   The exceptions are in wetland areas outside the three ranges.

 EOD  Range (AOC 25)  -  Surface and subsurface soil samples  collected during
 the  RI  at the EOD Range  in November 1993 were analyzed for TAL metals,
 explosives,  and TPHC.   Figure 8 of Appendix A shows soil  sampling locations
 in the  EOD Range.   Several metals were detected at levels above background
 in at  least one sample.   Copper and zinc exceeded the background
 concentration in three surface samples.   Two explosives were also detected
 in EOD  Range surface  soil samples: nitrocellulose (detected in two samples)
 and  nitroglycerine  (detected in one sample).   Low levels  of TPHC were
 detected  (maximum concentration of 45.2  M9/9)•   None of the substances
 detected  exceeded the  health-based soil  screening criteria established  for
 the  RI7.   Sample analysis results are presented in Table  14 of Appendix  E.

 Zulu Ranges (AOC 26)  - Surface and subsurface soil samples were taken at
 the  Zulu  Ranges as  part  of the SI and RI.   Figure 9 of Appendix A shows
 soil sampling locations  in the Zulu Ranges.   These samples were analyzed
 for  TCL organics, TAL  metals,  explosives,  and TPHC.   Although  several
 metals  exceeded background concentrations  in  at least one surface and
 subsurface sample,  none  of the metals detected  exceeded the health-based
 screening values.   PAHs  were detected in up  to  three surface and subsurface
 samples.   One of the PAHs,  benzo (b)  fluoranthene (0.81 ^g/g),  exceeded the
 screening, concentration  (0.7 ng/g) .   RDX and  TPHC was also detected.  The
 maximum concentration  of RDX in subsurface soil (38  M9/5)  exceeded the
 health-based screening level (26 M9/§)•  Sample analysis  results are
 presented in Table  15  and 16 of Appendix E.

 Hotel Range  (AOC 27) - Subsurface soil samples  were  collected  from
 boreholes  at the Hotel Range and analyzed  for TPHC,  TAL metals,  explosives,
 and TCL organics.   Figure 10 of Appendix A shows  borehole  locations.  None
 of the  metals exceeded the screening values.  Low levels  of  TPHC (maximum
 concentration of 75.6  ng/g),  below the screening  level  of  5,000  M9/9» were
 detected  in  some samples.   VOCs and pesticides  were  also  detected at
 concentrations  just above the  detection  limit.  These levels were well
 below screening values.

Unauthorized Landfill  (AOC 41)  - A March 1995 soil gas  survey  conducted in
 the shallow  soils around monitoring wells  41M-93-03X and  41M-94-03B in an
 attempt to find the source area for the  chlorinated  solvent  contamination
 detected  in  the groundwater.  The soil gas  survey  indicated two  detectible
 concentrations  of TCE  around the two wells. Soil  samples  collected from the
 same TerraProbe points used in the soil  gas survey  indicated TCE to be
present in soils adjacent to the two wells at the  30  to 37  foot  level.

 Soil samples collected from five test pits in the area  did not  indicate the
presence of  any target analytes.  Soil samples were collected from the
monitoring well  borings  during their emplacement  in  October  1994  indicated
 the presence of  TCE below the  30'  BGS level.  The  versatile  distribution of
 the TCE contamination  coincides with the depth  of the water  in  the boring.


                                     12

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 Therefore,  it appears that the TCE contamination is due to the adsorption
||f  TCE from groundwater to soil particles within the zone of the water
Pable  fluctuation. The area around 41M-93-03X and 41m-94-03B does not
 appear to be the source of the groundwater contamination.

 IV.  REVIEW SUMMARY

 A.  DOCUMENTS REVIEWED

 Numerous  documents/reports have been produced by various parties as part  of
 the  remedial investigations on Shepley's Hill Landfill.  The reports that
 served as a basis for selection of the remedial actions and which have been
 reviewed  by the USEPA and MADEP are included in the Administrative Record
 for  this  site.

 B.  PUBLIC PARTICIPATION

 The  Army  has kept the community and other interested parties apprised  of
 site activities through regular and frequent informational meetings, fact
 sheets, press releases,  and public meetings.

 The  Army  has developed and implemented a -Community Relations Plan.  As  part
 of  this plan,  the Army established a Technical Review Committee  (TRC)  in
 March  1991.  The TRC includes representatives from the USEPA,  U.S.  Army
 Environmental Center,  MADEP,  local officials and the community.  The
 committee provided review and technical comments on work products,
  hedules,  work plans and proposed activities at the Fort Devens sites. The
  C  met quarterly until  January 1994 when it was replaced by the
 Restoration Advisory Board (RAB).  A RAB is formed when a military
 installation closure involves transfer of property to the community. The
 RAB  consists of 28 members (fifteen original TRC member  plus thirteen  new
 members who are representatives from the Army,  USEPA,  MADEP,  local
 governments and citizens of local  communities.  It meets  on a monthly
 schedule.  Specific responsibilities include addressing cleanup issues  such
 as land use and cleanup  goals,  reviewing plans and documents,  identifying
 proposed  requirements and priorities,  and conducting regular meetings  which
 are  open  to the public.

 The  proposed plan for the SPIA groundwater and AOCs 25,  26 and 27  was
 presented at the February 1,  1996  RAB meeting.  During the week of  January
 29,  1996,  the Army published notices in local newspapers concerning the
 proposed  plan and public hearing and distributed a'summary Fact  Sheet  to
 647  interested  parties.  The proposed plan was made available to  the public
 at the Fort Devens BRAC Environmental Office and the Ayer Town Hall.

 From February 1,  1996 to March 1,  1996, the Army held a  thirty day public
 comment period  to accept public comments regarding the proposed  plan and
 other  SPIA documents.  On February 21,  1996 the Army held a formal  public
 meeting at  Fort Devens to discuss  the Proposed Plan and  to accept  any
 verbal comments from the public.  A transcript of this meeting is included
 in the responsiveness summary of the ROD.


                                     13

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Subsequent  to this  meeting,  a determination  was  made  to  expand  the  ROD to
encompass groundwater within AOC 41,  an Unauthorized  Landfill.  A  final
Proposed Plan describing this change  and a final Record  of  Decision was
published on May 17,  1996.  The decision and  information  regarding AOC  41
was  included in this  version of the ROD in Section  IX, Documentation of
Significant  Changes.  Concurrent with  the publication  of  the new proposed
plan,  the Army initiated a  new public comment period. This  period,  not
required under CERCLA,  ran  for twenty days and ended  on  June 4, 1996.

All  supporting documentation for the  decision regarding  SPIA groundwater
and  AOCs 25,  26,  27 and 41  has been placed in the administrative  record for
review. The  administrative  record is  available for  public review  at  the
Fort Devens  BRAC Environmental Office and the Ayer  Town  Hall.

V. CONCLUSIONS AND  RECOMMENDATIONS

A.   SPIA

The  human health risk assessment found that  there are no risks  to human
health from  the SPIA  activities,  above the range considered acceptable  by
the  USEPA under CERCLA and  the MADEP  under the MCP.

No significant risks  to plants or wildlife were identified  in SPIA soils,
but  potential risks were noted for aquatic life from surface water and
sediments.   A moderate impact  on macroinvertebrates at one station in  Slate
Rock Brook was observed,  but toxicity testing, using water from the
contaminated wetlands north  and south of  Zulu Ranges, did not identify  any|
site related impacts.   Continued observation of wildlife on the SPIA is
recommended  to evaluate the  impacts of continuing Army activities.

No further investigation or  remedial  actions are recommended.  For this
reason no site specific remedial action objectives were selected.

B.   AOC 25  (EOD Range)

Soils  at the EOD Range ordnance detonation area significantly exceeded
background in beryllium,  cobalt,  copper,  iron, manganese, mercury, nickel,
selenium, and zinc, although only zinc and copper exceeded background three
times, and only beryllium, manganese,  and selenium exceeded background
twice.  The  remaining four metals exceeded background in only one sample
which was significantly higher in silt and clay than other samples from the
site.  Nitrocellulose,  nitroglycerine,  and TPHC were also found in surface
soils and TPHC and  a  trace of  tetrachloroethene were noted in subsurface
soils.  The  two RCRA  TCLP soil samples showed no levels exceeding soil
toxicity characteristics.  Metals in  filtered groundwater samples showed
increased concentrations and increased frequency of detection in
downgradient  wells  when compared to a  local background well, but only
manganese exceeded  its  MCL.  Manganese levels are probably natural since
they cannot  be correlated to site activities and manganese is above MCL in
many Fort Devens  wells.   Several explosives were noted in groundwater
within the AOC,  but only Cyclonite exceeded its screening value, and then
only in one  well.

                                     14

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       the  EOD will continue to be part of the SPIA under Army control,  then
    groundwater will not be available to the public for human consumption
and will not be a completed pathway of exposure.   As such,  the risk  of
groundwater consumption was not estimated.   Other pathways  of exposure
examined gave reasonable maximum exposures  resulting in the assessed rick
being  below those deemed acceptable by the  USEPA under current Superfund
policy. . This human health risk assessment  addresses the toxicological
risks  from explosives but does not address  the far more substantial
physical risks of unexploded ordnance located at  EOD and throughout  the
SPIA.

The ecological risk assessment concluded that there were potential risks  to
small  mammals and to plants in the ordnance detonation area,  under
reasonable maximum exposures,  but not under average exposures.  Based on
the marginal exceedences of toxicity reference values,  the  potential  for
adverse ecological toxicological effects are minimal.   The  ecosystems in
the general vicinity of the site have not been impacted by  the EOD range,
and the analytes detected are  not ecologically significant.   The ecological
risk assessment concluded that no further action  is necessary at the EOD
range  to further investigate or mitigate ecological risks from soil  or
other  media in which analytes  were detected.   The ecological  risk
assessment addressed toxicological risks but did  not evaluate  the much more
substantial physical risks from unexploded  ordnance which will continue at
EOD and throughout the SPIA.

From the extensive environmental investigations and ecological and human
|ealth risk assessments conducted on the EOD range,  it  is concluded  that no
further investigation or remediation is  warranted at AOC 25,  and no
remedial action objectives will be developed.

C.  AOC 26 (Zulu Range)

Soils  at AOC 26 were found to  be contaminated with a number of chemicals,
the most important of which were explosives,  primarily  Cyclonite;
pesticides,  primarily DDT;  some PAHs;  and traces  of PCBs and volatiles.
TCLP testing for surface soils showed only  barium and chloroform present,
both below RCRA toxicity characteristic  levels.   Lead,  zinc, antimony,
arsenic, beryllium,  and cadmium exceed background but only lead and  zinc
could  be related to possible site activities.   Groundwater is contaminated
with explosives,  mainly Cyclonite (exceeding a Drinking Water Health
Advisory level used as a screening value) and HMX,  and  by bis (2-ethylhexyl)
phthalate,  also at levels exceeding a screening value,  and it discharges
both to surface water and sediment in the wetland north of the ranges and
probably to Slate Rock. Brook north of the ranges.   Unfiltered groundwater
shows  several elevated metals,  but filtered groundwater shows exceedances
of drinking water standards only for manganese.   Surface water showed
explosives,  mainly Cyclonite,  and methylphenol and traces of VOC.
Contaminants of Potential Concern (COPCs) were found in the wetlands both
south  and  north of the ranges.   Sediments in the  wetlands showed
explosives,  pesticides,  and traces of volatiles.   Many  metals exceeded
background and were selected as COPCs.   Because the ranges will remain
Active as  a training facility  and under  DOD jurisdiction for the

                                     15

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foreseeable  future,  the  groundwater pathway  is  considered  incomplete  and
was not assessed.  Estimated  human health  risks of  exposure  under any
probable scenario do not exceed  the upper  boundary  of  acceptable  risks  us
by the USEPA under current  Superfund guidance.   These  are  1-  lifetime  ri
of cancer and a Hazard Index  (HI) of one.

The ecological risk  assessment found that  some  soils data  exceed  reference
values for plants, small mammals, and songbirds, but that  those levels  are
of such' limited extent and  the habitat so  disturbed at  those locations  from
ongoing military training activities as to be ecologically insignificant.
Levels of lead in surface water  exceed water quality criteria, but  toxicity
testing indicated no toxicity attributed to  lead for an aquatic
invertebrate and a fish  that  were tested.  Substantial  uncertainty  exists
in extrapolating from avian toxicity to reptilian toxicity,  but,  using
avian data,  no risks were identified for turtles.   The  ecosystems at  AOC 26
do not appear to be  impacted, as indicated by the thriving communities  of
benthic invertebrates and wildlife observed during  the  field surveys.

There are no unacceptable risks  to human health or  demonstrated impacts on
wildlife at  AOC 26,  and  no  further investigation or remedial  action is
recommended  for this site.

D.  AOC 27 (Hotel Range)

The soil and groundwater at AOC  27 are affected by  military  training
activities,  shown primarily by the presence of  explosives,  pesticides, and
TPHC in soil, groundwater,  surface water,   and sediment.  Lead levels were
also elevated in subsurface soil and in surface  water.   The pesticides,
mostly DDT and its derivatives DDD and DDE, are  below background  in soils,
and were not present in  groundwater which  only  showed low  levels  of delta-
BHC (0.045 M9/L in the one  confirmed result).   Pesticide levels are likely
due to pest control -rather  than training activities at the site.
Explosives in the groundwater are by far the most conclusive evidence of
impacts from site operations.  All wells showed  at  least some levels of
explosives related compounds, with Cyclonite, HMX,   and 1,3-dinitrobenzene
the most frequently  observed compounds.   The groundwater affected by the
site is flowing north across Old Turnpike  Road,   to  discharge to a wetland
within the northern  part  of Hotel Range,  or possibly continuing on towards
Slate Rock Pond.

The risk to human health at AOC 27 has been calculated for users,  site
workers,  and trespassers.  All estimated potential  risks for carcinogens
and non-carcinogens  are  below current EPA  Superfund policy lower  limits for
lifetime risks.  The occurrence of carcinogenic  effects is below  10' per
lifetime,  and non-carcinogenic health effects are highly unlikely.

No evidence of site  related chemical stress to plants or wildlife was
observed during'the  field surveys.  The toxicity testing done at  Zulu
Ranges (AOC 26) imply that  the level of lead in  Cranberry  Pond water does
not pose a hazard to aquatic biota.   The mean concentrations of
contaminants of potential concern are unlikely  to pose a risk to  the
selected receptors,  mallards and raccoons,  with  the possible exception of

                                     16

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 the  effect of copper on mallards.   Potential risks to benthic invertebrates
 •rqm several metals in sediments (antimony,  copper,  lead,  mercury,  and
 nickel),  and also from 4-amino-2,6-dinitrotoluene, were noted.   These risks
 have high levels of uncertainty and do not apply to average levels  but only
 to reasonable maximum exposure levels.  In general,  this risk assessment is
 more likely to overestimate risks  than to underestimate them.   The  risk
 assessments have been conducted for the toxicological risks of  analytes
 detected  at AOC 27,  but does not address the more significant physical
 risks from unexploded ordnance.

 As the Army continues to use.the site, -efforts should be made to ensure
 that no activities further contribute to contamination of  Cranberry Pond.
 Periodic  review of the risk assessment in light of increased toxicological
 information of the effects of  the  existing levels of contamination,  should
 be used to more accurately assess  the risk to the environment.   Based on
 the  results of the environmental investigations and the human health and
 ecological risk assessments,  no contamination is present in levels  which
 pose unacceptable risks to human health or the environment.   AOC 27  will
 continue  to be used as a firing range by the Army,  and no  further
 investigation or remedial action is recommended at the Hotel  Range.

 E.   AOC 41 (Unauthorized Landfill)

 The  following conclusions are  based on interpretation of data collected
 from each of the previous investigations (SI,  SSI and RI)  completed  at AOC


 Whe  geologic setting at AOC 41 includes an upper sand layer underlain by a
 discontinuous clayey silt layer, a  lower silty sand  layer,  and  finally and
 lower sand layer.   Bedrock was not  encountered in any of the  borings
 completed at AOC 41.

 The  aquifer below AOC 41 can be  classified as  an unconfined overburden
 groundwater aquifer.   The aquifer  is recharged by surface  water
 infiltration and percolation,  and  recharge from surface water from New
 Cranberry Pond.   This hydraulic  condition is caused  by a road culvert
 located at the eastern end of  the pond which artificially  raises  the
 surface water elevation in the pond,  thus causing the surface water  to
 recharge  groundwater below AOC 41.   The predominant  local  groundwater  flow
 at AOC 41 is to the north-northeast,  eventually discharging into  the Nashua
 River.

 The  results of RI groundwater  sampling and field analysis  completed  during
 the  RI, indicate that the existing  groundwater contaminant  plume  appears to
 be confined to the upper portion (water table)  of the aquifer and it is
 oriented  in a northeast-southwest  direction.  Based on the  chemical
 properties of the contaminants,  the slow rate  of groundwater  flow in the
 clayey silt,  and the existing  downgradient groundwater results  (41M-94-09A
 and  B) , it appears that the distribution of  the groundwater contamination
 has  been  determined,  and that  contaminant migration  to any exposure  point
_(Well  D-l)  is minimal.


                                     17

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Surface water and sediment  from  New  Cranberry  Pond  were  sampled during
previous investigations.  However, data  collected during the  SSI and  the
RI, demonstrate that New  Cranberry Pond  surface  water  recharges groundwater
below AOC 41.  An assessment  of  the  potential  surface  soil migration
pathways showed that no migration pathway  (i.e., overland transport of
surface soil via surface  water)  exists between the  contaminants detected in
the surface soil on the waste material and New Cranberry Pond surface water
and sediment.  Because of these  reasons, the previous  surface water and
sediment data was not evaluated  in the RI.

The base-line human health  risk  assessment was limited to an  evaluation of
the exposure potential to groundwater at AOC 41, and a summary of
quantitative risk evaluation  for groundwater from Well D-l.   The risk
assessment concluded that there  are  no unacceptable risked to human health
from the groundwater at Well  D-l for troops that consume  the  water for
approximately 14 days per year,  and  that no further action would be
required under CERCLA.

Based on the results and  interpretation of the physical and chemical data
and taking into account that  the future land and groundwater  use of this
AOC will be similar to the present use, it was recommended that the Army
complete a monitoring ROD and Proposed Plan for the groundwater at AOC 41
to include the AOC 41-related contaminants in  the analysis of the
groundwater samples from  Well D-l.
                                     18

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11  UC4K3812.COR
                                                                                Oxbow National
                                                                        South Post Impact Arc*
                                                                        (•pproitanttcly 1^00 •era)

                                                                      tcr Divide
                                                                              AM to b« •••Itand
 SOUKCC: Ccmagy and EnwrnnMt. Inc. ItX
                                                SCALE
                                                  2000
4000 F««J
  Fgure 1 South Post Impact Area ACX 25, 26. and 27.

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LEGEND
                                                                                                                                FIGURE 12
                                                                                                                  SI EXPLORATION LOCftTIONS
                                                                                                 AOC 41-UNOUTHORIZED DUMPING AREA (SITE  Al
                                                                                                            REMEDIAL INVESTIGATION REPORT
                                                                                                                           FORT  DEVENS. MA

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                               FIGURE 13
                RI EXPLORATION LOCATIONS
AOC 41-UNAUTHORIZED DUMPING AREA (SITE A)  •
           REMEDIAL INVESTIGATION REPORT
                         FORT OEVENS, MA  '•

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                                   FIGURE M
 INTERPRETIVE FIELD ANALYTICAL  CONCENTRATION
CONTOURS  FOR  TRICHLOROETHENE  IN OROUNOWATER
    AOC 4J-UNAUTHORIZED DUMPING AREA (SITE  Al
                REMEDIAL  INVESTIGATION REPORT
                             FORT DEVENS. MA

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           NB*
        OANIUIT
           Km              FICURE 15
        INTERPRETIVE FIELD ftNALYTICfll
         CONCENTRATION CONTOURS FOR
!. 2-TETRftCHLOROETH6NE  IN GROUNDWftTER
 4I-UN6UTHORIZED OOMPINC AREfl (SITE ft)
       REMEDIAL INVESTIGATION REPORT
                     FORT  OEVENS. MA

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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25,26, & 27
                   RECORD OF DECISION SUMMARY
                    SOUTH POST IMPACT AREA AND
            AREA OF CONTAMINATION 41 GROUNDWATER AND
                AREAS OF CONTAMINATION 25, 26, AND 27
                    FORT DEVENS, MASSACHUSETTS
                            APPENDIX C

                   ADMINISTRATIVE RECORD INDEX
C:\PP & ROD\DEUVER\SPU\FINALROD\FROD30.WPD                               M»y 30,1996

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              Fort Devens

          Groups 2 & 7 Sites

    Administrative Record File for

                 Index
               Prepared for
           New England Division
            Corps of Engineers
                   by
 ABB ENVIRONMENTAL SERVICES, INC.
107 Audubon Road, Wakefield, Massachusetts 01880 (617)245-6606

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                                             Section I




                                     Site-Specific Documents
C:\0102\DELIVER\SPIA\FINALROD\INDEX2&7.DOC                                                    July, 1996

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                                      Introduction
       This document is the Index to the Administrative Record File for the Fort Devens Groups
 2 & 7 Sites. Section I of the Index cites site-specific documents and Section II cites guidance
 documents used by U.S. Army staff in selecting a response action at the site. Some documents in
 this Administrative Record File Index have been cited but not physically included. If a document
 has been cross referenced to another Administrative Record File Index, the available
 corresponding comments and responses have been cross referenced as well.

       The Administrative Record File is available for public review at EPA Region I's Office in
 Boston, Massachusetts, at the Fort Devens Environmental Management Office, Fort Devens,
 Massachusetts, and at the Ayer Town Hall,  1 Main  Street, Ayer, Massachusetts.
 Supplemental/Addendum volumes may be added to this Administrative Record File. Questions
 concerning the Administrative Record should be addressed to the Fort Devens Base Realignment
 and Closure Office (BRAC).
C:\0102\DELIVER\SPIA\FINALROD\INDEX2&7.DOC                                             August, 1996

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                       ADMINISTRATIVE RECORD INDEX FILE

                                         for

                             Fort Devens Groups 2 & 7 Sites

                               Compiled: August 8, 1996
  1.0        Pre-Remedial

       1.2    Preliminary Assessment

             Cross Reference: The following Reports, Comments, and Responses to
             Comments (entries 1 through 6) are filed and cited as entries 1 through 6 in minor
             break 1.2 Preliminary Assessment of the Fort Devens Group 1A Administrative
             Record File Index.

             Reports

             1.      "Final Master Environmental Plan for Fort Devens," Argonne National
                   Laboratory (April 1992).
             2.      "Preliminary Zone II Analysis for the Production Wells at Fort Devens,
                   MA, Draft Report", ETA Inc. (January 1994).

             Comments

             3.     Comments Dated May 1, 1992 from Walter Rolf, Montachusett Regional
                   Planning Commission on the April 1992 "Final Master Environmental Plan
                   for Fort Devens," Argonne National Laboratory.
             4.     Comments Dated May 7, 1992 from James P. Byrne, EPA Region I on the
                   April  1992 "Final Master Environmental Plan for Fort Devens," Argonne
                   National Laboratory.
             5.     Comments Dated May 23, 1994 from D. Lynne Welsh, Commonwealth of
                   Massachusetts Department of Environmental Protection on the January
                    1994  "Preliminary Zone II Analysis for the Production Wells at Fort
                   Devens, MA, Draft Report", ETA Inc.

             Responses to Comments

             6.     Response Dated June 29, 1992 from Carrol J. Howard, Fort Devens to the
                   May 7, 1992 Comments from James P. Byrne, EPA Region I.
C:W102\DELIVER\SPIA\FINALROD\INDEX2&7.DOC                                             July. 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page C - 2

       1.3    Site Inspection

              Reports

              1.     "Final Task Order (Site Investigations) Work Plan," ABB Environmental
                    Services, Inc. (December 1992).
              2.     "Final Task Order (Site Investigations) Work Plan - Historic Gas Stations,"
                    ABB Environmental Services, Inc. (December 1992).
              3.     "SI Data Packages - Army Environmental Center - Volume I," ABB
                    Environmental Services, Inc. (January 1993).
              4.     "SI Data Packages - Army Environmental Center - Volume II," ABB
                    Environmental Services, Inc. (January 1993).
              5.     "SI Data Package Meeting Notes for Groups 2 & 7 and Historic Gas
                    Stations," ABB Environmental Services, Inc. (April  1993).
              6.     "Final SI Report, Groups 2 & 7 and Historic Gas Stations, Volume I,"
                    ABB Environmental Services, Inc. (May 1993).
              7.     "Final SI Report, Groups 2 & 7 and Historic Gas Stations, Volume II,"
                    ABB Environmental Services, Inc. (May 1993).
              8.     "Final SI Report, Groups 2 & 7 and Historic Gas Stations, Volume III"
                    ABB Environmental Services, Inc. (May 1993).
              9.     "Final SI Report, Groups 2 & 7 and Historic Gas Stations, Volume IV,"
                    ABB Environmental Services, Inc. (May 1993).
              10.    "Final Supplemental Site Investigation Work Plan," ABB Environmental
                    Services, Inc. (August 1993).
              11.    "Supplemental Site Investigation Data Package Groups 2 & 7 and Historic
                    Gas Stations," ABB Environmental Services, Inc. (January 1994).
              12.    "Supplemental Site Investigation Data Package Meeting Notes Groups 2 &
                    7 and Historic Gas Stations," ABB Environmental Services, Inc. (March
                    1994).
Missing       13.    "Supplemental Sampling Plan for Study Area 42, Popping Furnace," OHM
                    Remediation Corporation (October 14,1994).
              14.    "Revised Final Site Investigation Report, Groups 2 & 7 and Historic Gas
                    Stations," Volumes I, II, III and IV, ABB Environmental Services, Inc.
                    (October 1995).

             Comments

              15.    Comments Dated January 11, 1993 from D. Lynne Chappell,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the December 1992 "Final Task Order (Site Investigation) Work Plan,"
                    ABB Environmental Services, Inc.
              16.    Comments Dated January 12, 1993 from James P. Byrne, EPA Region I on
                    the December 1992 "Final Task Order (Site Investigation) Work Plan,"
                    ABB Environmental  Services, Inc. and the December 1992 "Final Task

C:\0102\DEUVER\SPIA\FINALROD\INDEX2A7.DOC                                              July. 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page C - 3

                    Order (Site Investigation) Work Plan - Historic Gas Stations," ABB
                    Environmental Services, Inc.
             17.    Comments Dated July 15, 1993 from James P. Byrne, EPA Region I on the
                    May 1993 "Final SI Report, Groups 2 & 7 and Historic Gas Stations,"
                    ABB Environmental Services, Inc.
             18.    Comments Dated July 9, 1993 and July 19, 1993 from D. Lynne Chappell,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the May 1993  "Final SI Report, Groups 2 & 7 and Historic Gas
                    Stations," ABB Environmental Services, Inc.
             19.    Comments Dated March 7, 1994 from Molly Elder, Commonwealth of
                    Massachusetts Department of Environmental Protection on the January
                    1994 "Supplemental Site Investigation Data Package, Groups 2 & 7 and
                    Historic Gas Stations," ABB Environmental Services, Inc.
             20.    Comments Dated March 23, 1994 from James P. Byrne, EPA Region I on
                    the January 1994  "Supplemental Site Investigation Data Package, Groups 2
                    & 7 and Historic Gas Stations," ABB Environmental Services, Inc.
             21.    Comments Dated November 2, 1994 from D.  Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental  Protection
                    on the October 14, 1994 "Supplement Sampling Plan for Study Area 42,
                    Popping Furnace," OHM Remediation Corporation.

             Responses to Comments

             22.    Responses Dated  September 1993 from U. S.  Army Environmental Center
                    on the following document: Final Site Investigation Report, Groups 2 & 7
                    and Historic Gas Stations, dated May 1993.
             23.    Cross Reference:  Responses Dated September 1993 from U.S. Army
                    Environmental Center on the following document: Draft Supplemental Site
                    Investigation Work Plan, (Appendix M of Final SI Report), dated May
                    1993. [These Responses are filed and cited as entry number 18 in the
                    Responses to Comments section of this minor break].
             24.    Responses Dated  September 1994 from U.S. Army Environmental Center
                    on the Supplemental Site Investigation Data Package, Fort Devens Groups
                    2 & 7 and Historic Gas Stations.

             Comments to Responses to Comments

             25.     Comments Dated  September 30, 1993 from D. Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the Responses  to Comments Package dated September 1993 from the
                    U.S. Army Environmental Center.
             26.     Comments Dated  November 27, 1994 from D. Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the Army Responses to Comments, Supplemental Site Investigation


C:\0102\DELIVER\SPIA\FINALROD\INDEX2&7.DOC                                            July. 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27	Page C - 4

                    Data Package, Groups 2, 7, and Historic Gas Stations, Fort Devens, Ma.

 2.0  Removal Response

       2.2   Removal Response Reports

             Reports

             1.      "Draft Final Closure Report Study Area 49, Fort Devens, Massachusetts,"
             OHM Remediation Services Corporation (October 28, 1994).
             2.      "Draft Final Closure Report Study Area 43D, Fort Devens,
             Massachusetts," OHM Remediation Services Corporation (November 21, 1994).
             3.      "Draft Final Closure Report Study Area 56, Fort Devens, Massachusetts,"
             OHM Remediation Services Corporation (January 24, 1995).

             Comments

             4.      Comments Dated December 29, 1994 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental Protection on the
             October 28, 1994 "Draft Final Closure Report, Study Area 49, Fort Devens,
             Massachusetts," (OHM Remediation Services Corporation).
             5.      Comments Dated January 6,1995 from D. Lynne Welsh, Commonwealth
             of Massachusetts Department of Environmental Protection on the November 21,
             1994 "Draft Final Closure Report, Study Area 43D, Fort Devens, Massachusetts,"
             (OHM Remediation Services Corporation).
             6.      Comments Dated March 17, 1995 from D. Lynne Welsh, Commonwealth
             of Massachusetts Department of Environmental Protection on the January 24,
             1995 "Draft Final Closure Report, Study Area 56, Fort Devens, Massachusetts,"
             OHM Remediation Services Corporation.

       2.9    Action Memoranda

             Reports

             1.      "Final Contract Plans and Specifications Clean Out and Closure, Lake
                    George Study Area 45 (SA 45),"  ABB Environmental Services, Inc.
                   (January 1994).
             2.      "Final Contract Design Plans and Specifications Contaminated Soil
                   Removal, Various Sites, Fort Devens, Massachusetts," ABB
                   Environmental Services, Inc. (April 1994).
             3.     "Final Action Memoranda, Various Sites, Fort Devens, Massachusetts,"
                   ABB Environmental Services, Inc. (June 1994).
             4.     "Addendum - Revision 2 for Final Contract Design Plans & Specifications
                   Contaminated Soil Removal, Various Sites, Fort Devens, Massachusetts,"


C:\0102\DEUVER\SPIA\FINALROD\INDEX2fc7.DOCJuly. 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27	Page C - 5

                    ABB Environmental Services, Inc. (September 9, 1994).
             5.     "Addendum - Revision 3 for Final Contract Design Plan & Specifications
                    Contaminated Soil Removal, Various Sites, Fort Devens, Massachusetts,"
                    ABB Environmental Services, Inc. (September 16, 1994).
             6.     "Final Addendum - Revisions 2 and 3 for Final Contract Design Plan &
                    Specifications Contaminated Soil Removal, Various Sites, Fort Devens,
                    Massachusetts," ABB Environmental Services, Inc. (October 28, 1994).
             7.     "Draft Addendum - Revision 4 for Final Contract Design Plans &
                    Specifications Contaminated Soil Removal, Various Sites, Fort Devens,
                    Massachusetts," ABB Environmental Services, Inc. (March 17, 1995).

             Comments

             8.     Comments Dated February 17, 1994 from D. Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the January 1994 "Draft Contract Design Plans and Specifications
                    Contaminated Soil Removal, Various Sites, Fort Devens, Massachusetts,"
                    ABB Environmental Services, Inc.
             9.     Comments Dated May 5, 1994 from D. Lynne Welsh, Commonwealth of
                    Massachusetts Department of Environmental Protection on the April 1994
                    "Draft Action Memoranda, Various Sites, Fort Devens, Massachusetts,"
                    ABB Environmental Services, Inc.
             10.     Comments Dated May 19, 1994 from James P. Byrne, EPA Region I on
                    the April 1994 "Draft Action Memoranda, Various Sites, Fort Devens,
                    Massachusetts," ABB Environmental Services, Inc.
            •11.     Comments Dated June 10, 1994 from D. Lynne Welsh, Commonwealth of
                    Massachusetts Department of Environmental Protection on the April 1994
                    "Final Contract Design Plans and Specifications, Contaminated Soil
                    Removal, Various Sites, Fort Devens, Massachusetts," ABB
                    Environmental Services, Inc.
             12.     Comments Dated August 11, 1994 from D. Lynne Welsh, Commonwealth
                    of Massachusetts Department of Environmental Protection on the June
                    1994 "Final Action Memoranda, Various Sites, Fort Devens,
                    Massachusetts," ABB Environmental Services.Inc.
             13.     Comments Dated August 16, 1994 from D. Lynne Welsh, Commonwealth
                    of Massachusetts Department of Environmental Protection on the June 10,
                    1994 "Addendum - Revision 1 for Final Contract Design Plans &
                    Specifications, Contaminated Soil Removal, Various Sties, Fort Devens,
                    Massachusetts (ABB Environmental Services, Inc.).
             14.     Comments Dated September 28, 1994 from D. Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the September 9, 1994 "Addendum - Revision 2 for Final Contract
                    Design Plans and Specifications Contaminated Soil Removal Various Sites,
                   Fort  Devens, Massachusetts," (ABB Environmental Services, Inc.).

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              15.    Comments Dated December 20, 1994 from D. Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the October 28, 1994 "Final Addendum - Revisions 2 and 3 for Final
                    Contract Design Plans & Specifications, Contaminated Soil Removal
                    Various Sites, Fort Devens, Massachusetts," (ABB Environmental
                    Services, Inc.)

              Responses to Comments

              16.    Responses Dated March 1994 from U.S. Army Environmental Center on
                    the following document: Draft Contract Design Plans and Specifications
                    Contaminated Soil Removal, Various Sites, Fort Devens, Massachusetts
                    dated January 1994.
              17.    Responses Dated June 1994 from U.S. Army Environmental Center on the
                    following document:  Draft Action Memoranda, Various Sites, Fort
                    Devens, Massachusetts dated April 1994.
              18.    Responses Dated January 25, 1994 from U.S. Army Environmental Center
                    on the following document: "Draft Design Specifications and Plans Lake
                    George Street Vehicle Wash Area (Study Area 45).
              19.    Responses Dated September 9, 1994 from U.S. Army Environmental
                    Center on the Addendum - Revisions 2 Final Contract Design Plans &
                    Specifications Contaminated Soil Removal Various Sites, Fort Devens,
                    Massachusetts.
             20.    Response Dated October 28, 1994 from U.S. Army Environmental Center
                    on the Final Addendum - Revisions 2 and 3 for Final Contract Design Plans
                    & Specifications, Contaminated Soil Removal, Various Sites, Fort Devens,
                    Massachusetts.

3.0    Remedial Investigation (RI)

       3.1    Correspondence

              1.      Letter Dated February 15,  1996 from D. Lynne Welsh, Commonwealth of
                    Massachusetts Department of Environmental Protection, acknowledging
                    receipt of: 1. Final Remedial Investigation (RI) Reports, AOCs 41, 43G,
                    and 43J. 2. Draft Feasibility.

       3.2    Sampling and Analysis Data

             Reports

             1.      Cross Reference: "Method for Determining Background Concentrations -
                    Inorganic Analytes in Soil and Groundwater - Fort Devens," ABB
                    Environmental Services, Inc.  (January 20, 1993) [Filed and cited as entry

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                     number 1 in minor break 3.2 Sampling and Analysis Data of the Fort
                     Devens Group 1A Sites Administrative Record Index].
              2.      "Data Comparison Report, Group 2 & 7 Sites Through Round 1
                     Sampling,"  COM Federal Programs Corporation (March 1993).
              3.      "Draft Quality Assurance Project Plan, Remedial Investigations, Groups 2
                     & 7 and South Post Impact Area, Fort Devens, Massachusetts,"  Ecology
                     and Environment, Inc. (June 1993).

       3.4    Interim Deliverables

              Reports

              1.     Cross Reference:  "Final Ground Water Flow Model at Fort Devens,"
                    Engineering Technologies Associates, Inc. (May 24, 1993) [Filed and cited
                    as entry number 1 in minor break 3.4 Interim Deliverables of the Fort
                    Devens Group 1A Sites Administrative Record Index].
              2.     "Final Projects Operations Plan - Volume I of HI," ABB Environmental
                    Services, Inc. (December 1992).
              3.     "Final Projects Operations Plan - Volume II of III - Appendix A:  Health
                    and Safety Plan," ABB Environmental Services, Inc. (December 1992).
              4.     "Final Projects Operations Plan - Volume HI of III - Appendix B:
                    Laboratory QA Plan; Appendix C: USATHAMA-Certified Analytical
                    Methods," ABB Environmental Services, Inc. (December 1992).

              Comments

              5.     Comments Dated January 12, 1993 from James P. Byrne, EPA Region I on
                    the December  1992 "Final Projects Operations Plan," ABB Environmental
                    Services, Inc.
              6.     Cross Reference:  Comments Dated February 1, 1993 from James P.
                    Byrne, USEPA Region I and D. Lynne Chappell, Commonwealth of
                    Massachusetts Department of Environmental Protection on the October 30,
                    1992 "Draft Final Ground Water Flow Model at Fort Devens,"
                    Engineering Technologies Associates, Inc.  [Filed and cited as entry number
                    2 in minor break 3.4 Interim Deliverables of the Fort Devens Group 1A
                    Sites Administrative Record File Index].
              7.     Comments Dated February 17, 1993 from D. Lynne Chappell,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the December 1992 "Final Project Operations Plan," ABB
                    Environmental Services, Inc.

       3.5     Applicable or Relevant and Appropriate Requirements (ARARs)

              Cross Reference: The following report (entries 1 and 2 are filed and cited as

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             entries 1 and 2 in minor break 3.5  Applicable or Relevant and Appropriate
             Requirements (ARARs) of the Fort Devens Groups 3, 5, & 6 Sites Administrative
             Record Index.

             Reports

             1.      "Draft Applicable or Relevant and Appropriate Requirements (ARARs) for
                    CERCLA Remedial Actions," U.S. Army Toxic and Hazardous Materials
                    Agency (June 1992).
             2.      "Draft Assessment of Location-Specific Applicable or Relevant and
                    Appropriate Requirements (ARARs) for Fort Devens, Massachusetts,"  U.
                    S. Army Toxic and Hazardous Materials Agency (September 1992).

       3.6   Remedial Investigation (RI) Reports

             Reports

             1.      "Draft Remedial Investigation Report AOC 41", Volumes I, II and HI,
                    ABB Environmental Services, Inc. (July 1995).
             2.      "Final Remedial Investigation Report AOC 41", Volumes I and II, ABB
                    Environmental Services, Inc. (February 1996).

             Comments

             3.      Comments Dated March 15,1996 from John Regan, Massachusetts
                    Department of Environmental Protection on the February 1996 "Final
                    Remedial Investigation Report AOC 41", Volumes I and II, ABB
                    Environmental Services, Inc.

             Response to Comments

             4.      Response Dated February 1,1996 from ABB Environmental Services, Inc.
                    on the following document: Draft Remedial Investigation Report, AOC 41.

       3.7    Work Plans and Progress Reports

             Reports

             1.      "Draft Task Order Work Plan Area of Contamination (AOC) 41, AOC
                    43 G and 43 J, Fort Devens, Draft Remedial Investigation/Feasibility Study
                    Work Plan, Groups 2 & 7 and Historic Gas Stations,"  ABB Environmental
                    Services, Inc. (May 1994).
             2.      "Final Task Order Work Plan Area of Contamination (AOC) 41, AOC
                    43G, and AOC 43J, Fort Devens, Final Remedial Investigations/Feasibility

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                   Study Work Plan, Groups 2, 7, and Historic Gas Stations," ABB
                   Environmental Services, Inc. (August 1994).
             3.     "Revised Final Task Order Work Plan Area of Contamination (AOC) 41,
                   AOC 43G, and AOC 43J, Fort Devens, Revised Final Remedial
                   Investigations/Feasibility Study Work Plan, Groups 2, 7, and Historic Gas
                   Stations," ABB Environmental Services, Inc. (October 1994).

             Comments

             4.     Comments Dated July 06, 1994 from D. Lynne Welsh, Commonwealth of
                   Massachusetts Department of Environmental Protection the May 1994
                   "Draft Task Order Work Plan Area of Contamination (AOC) 41, AOC
                   43G and 43J, Fort Devens, Draft Remedial Investigation/Feasibility Study
                   Work Plan, Groups 2 & 7 and Historic Gas Stations," ABB Environmental
                   Services, Inc.
             5.     Comments Dated October 19, 1994 from James P. Byrne, USEPA Region
                   I, on the Final RI/FS Work Plan for AOCs 41,43G, and 43J and the
                   Response to Comments for this Document.
             6.     Comments Dated October 21, 1994 from D. Lynne Welsh, Commonwealth
                   of Massachusetts Department of Environmental Protection on the August
                   1994 "Final Task Order Work Plan, Area of Contamination (AOC) 41,
                   43G,  and AOC 43J.
             7.     Comments Dated December 15, 1994 from D. Lynne Welsh,
                   Commonwealth of Massachusetts Department of Environmental Protection
                   on the Revised Final Remedial Investigation/Feasibility Study, Revised
                   Final Task Order Work Plans AOC 41, AOC 43 G, and AOC 43 J.

             Response to Comments

             8.     Responses Dated September 1994 from U.S.  Army Environmental Center
                   on the following Document: Draft RI/FS Work Plans for Area of
                   Contamination (AOC) 41, AOC 43G, and AOC 43J.
             9.     Response Dated February 1, 1996 from ABB Environmental Services, Inc.
                   on the following document:  Draft Alternative Screening Report, AOC 41.

             Comments to Responses to Comments

             10.    Cross Reference: Comments Dated October  19, 1994 from D. Lynne
                   Welsh, Commonwealth of Massachusetts Department of Environmental
                   Protection on the Final RI/FS Work Plan for AOCs 41, 43G and 43 J and
                   the Response to Comments for this document. [Filed and cited as entry
                   number 6 in the Comments section of this minor break].
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 4.0    Feasibility Study (FS)

       4.7    Work Plans and Progress Reports

              Reports

              1.     Cross Reference: "Draft Task Order Work Plan Areas of Contamination
                    (AOC) 41, AOC 43G and 43J, Fort Devens, Draft Remedial
                    Investigation/Feasibility Study Work Plan, Groups 2 & 7 and Historic Gas
                    Stations," ABB Environmental Services, Inc. (May 1994) [Filed and cited
                    as entry number 1  in minor break 3.7 Work Plans and Progress Reports]
              2.     "Draft Work Plan Predesign Field Work and Landfill Study, Fort Devens,
                    Massachusetts," ABB Environmental Services, Inc. (June 1994).

              Comments

              3.     Cross Reference: Comments Dated July 6, 1994 from D. Lynne Welsh,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    the May  1994 "Draft Task Order Work Plan Area of Contamination (AOC)
                    41, AOC 43G and 43J, Fort Devens, Draft Remedial
                    Investigation/Feasibility Study Work Plan, Groups 2 & 7 and Historic Gas
                    Stations," ABB Environmental Services, Inc. [Filed and cited as entry
                    number 2 in the minor break 3.7 Work Plans and Progress Reports].

       4.9   Proposed Plans for Selected Remedial Action

             Reports

              1.     "Draft Proposed Plan for Groundwater Contamination at AOC 41,
                    Unauthorized Dumping Area (Site A)," ABB Environmental Services, Inc.
                    (March 1996).

5.0    Record of Decision (ROD)

       5.1    Correspondence

              1.     Cross Reference: Letter Dated April 30, 1996 from James P. Byrne, EPA
                    Region 1 on the Inclusion of AOC 41 in the South Post Impact Area ROD,
                    [Filed and cited in minor break 5. 1 Correspondence of the Fort Devens
                    Group IB Sites Administrative Record Index.]
             2.     Cross Reference: Letter Dated July 2,  1996 from E. Gail Suchman,
                    Commonwealth of Massachusetts Department of Environmental Protection
                    on the "Record of Decision, South Post Impact Area and AOC 41
                    Groundwater, and  AOCs 25, 26, and 27, Fort Devens, Massachusetts",

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                    [Filed and cited in minor break 5.1 Correspondence of the Fort Devens
                    Group IB Sites Administrative Record Index.]

       5.4   Record of Decision

             Reports

             1.      "No Further Action Decision Document Under CERCLA, Fort Devens
                    Study Area 58, Buildings 2648 and 2650 Fuel Oil Spills," ABB
                    Environmental Services, Inc. (January 1994).
             2.      "No Further Action Decision Document Under CERCLA, Fort Devens
                    Study Area 43C,E,F,K,L,M,P,Q,R, and S," ABB Environmental Services,
                    Inc. (January 1994).
             3.      "No Further Action Decision Document Under CERCLA, Fort Devens
                    Study Area 28, Fort Devens Waste Explosives Detonation Range (Training
                    Area 14)," ABB Environmental Services, Inc. (January 1994).
             4.      "No Further Action Decision Document Under CERCLA, Decision
                   Briefing, Fort Devens Study Area 28, Fort Devens Waste Explosives
                   Detonation Range (Training Area 14)," ABB Environmental Services, Inc.
                   (January 1994).
             5.     "Draft No Further Action Decision Document Under CERCLA, Study
                   Area 13, Landfill No. 9, Groups 2 & 7 and Historic Gas Stations, Fort
                   Devens, Massachusetts," ABB Environmental Services, Inc. (May 1994).
             6.     "Draft No Further Action Decision Document Under CERCLA, Study
                   Area 12, Landfill No. 8, Groups 2 & 7 and Historic Gas Stations, Fort
                   Devens, Massachusetts," ABB Environmental Services, Inc. (May 1994).
             7.     "Draft No Further Action Decision Document Under CERCLA, Study
                   Area 14, Landfill No. 10, Groups 2 & 7 and Historic Gas  Stations, Fort
                   Devens, Massachusetts," ABB Environmental Services, Inc. (May 1994).
             8.     "Draft No Further Action Decision Document Under CERCLA, Study
                   Area 43B Historic Gas Station Sites, Groups 2 & 7 and Historic Gas
                   Stations, Fort Devens, Massachusetts," ABB Environmental Services,  Inc
                   (May 1994).
             9.     "Draft No Further Action Decision Document Under CERCLA, Study
                   Area 43N, Historic Gas Station Sites, Groups 2 & 7 and Historic Gas
                   Stations, Fort Devens, Massachusetts," ABB Environmental Services, Inc.
                   (May 1994).
             10.    "No Further Action Decision Under CERCLA, Study Area 43B,  Historic
                   Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                   Services, Inc. (January 1995).
             11.    "No Further Action Decision Under CERCLA, Study Area 43C,  Historic
                   Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                   Services, Inc. (January' 1995).
             12.    "No Further Action Decision Under CERCLA, Study Area 43E, Historic

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                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc (January 1995).
              13.    "No Further Action Decision Under CERCLA, Study Area 43F, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
              14     "No Further Action Decision Under CERCL A, Study Area 43 K, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
              15.    "No Further Action Decision Under CERCLA, Study Area 43L, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
              16.    "No Further Action Decision Under CERCLA, Study Area 43M, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
              17.    "No Further Action Decision Under CERCLA, Study Area 43N, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
              18.    "No Further Action Decision Under CERCLA, Study Area 43P, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
              19.    "No Further Action Decision Under CERCLA, Study Area 43Q, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
             20.    "No Further Action Decision Under CERCLA, Study Area 43R, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
             21.    "No Further Action Decision Under CERCLA, Study Area 43 S, Historic
                    Gas Station Sites, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc. (January 1995).
             22.     "No Further Action Decision Under CERCLA, Study Area 14, Landfill No.
                    14, Fort Devens, Massachusetts,"  ABB Environmental Services, Inc.
                    (January 1995).
             23.     "No Further Action Decision Under CERCLA, Fort Devens Study Area
                    28, Waste Explosives Detonation Range (Training Area 14)," ABB
                    Environmental Services, Inc. (January 1995).
             24.     "No Further Action Decision Under CERCLA, Study Area 48, Building
                    202 Leaking Underground Storage Tank Site, Fort Devens,
                    Massachusetts," ABB Environmental Services, Inc. (January 1995).
             25.     Cross Reference:  "Draft Final ROD for the South Post Impact Area and
                    AOC 41 Groundwater and AOCs 25, 26, and 27, Fort Devens,
                    Massachusetts," Home Engineering (April 1996), [Filed and cited in minor
                    break 5.4 Record of Decision (ROD) of the Fort Devens Group IB Sites
                    Administrative Record Index.]
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             Comments

             26.    Comments Dated September 30, 1993 from James P. Byrne, EPA Region I
                   on the August 1993 "Draft Decision Document, Fort Devens Study Area
                   58, Buildings 2648 and 2650 Fuel Oil Spills," ABB Environmental
                   Services, Inc.
             27.    Comments Dated October 1 1993 from D. Lynne Welsh, Commonwealth
                   of Massachusetts Department of Environmental Protection on the August
                   1993 "Draft Decision Document, Fort Devens Study Area 58, Buildings
                   2648 and 2650 Fuel Oil Spill," ABB Environmental Services, Inc.
             28.    Comments Dated September 30, 1994 from James P. Byrne, EPA Region I
                   on the August 1993 "Draft Decision Document, Fort Devens Study Area
                   28, Waste Explosives Detonation Range (Training Area 14)," ABB
                   Environmental Services, Inc.
             29.    Comments Dated November 3, 1993 from D. Lynne Welsh,
                   Commonwealth of Massachusetts Department of Environmental Protection
                   on the September 1993 "Draft Decision Document Fort Devens Historic
                   Gas Stations, Study Area 43C,E,F,K,L,M,P,Q,R, and S," ABB
                   Environmental Services, Inc.
             30.    Comments Dated November 17, 1993 from James P. Byrne on the
                   September 1993  "Draft Decision Document Fort Devens Historic Gas
                   Stations, Study Area 43C,E,F,K,L,M,P,Q,R, and S," ABB Environmental
                   Services, Inc.
             31.    Comments Dated June 29, 1994 from D. Lynne Welsh, Commonwealth of
                   Massachusetts Department of Environmental Protection on the May 1994
                   "Draft No Further Action Decision Document Under CERCLA, Study
                   Area 13, Landfill No. 9, Groups 2 & 7 and Historic Gas Stations, Fort
                   Devens, Massachusetts,"  ABB Environmental Services, Inc., "Draft No
                   Further Action Decision Document Under CERCLA, Study Area 12,
                   Landfill No. 8, Groups 2 & 7 and Historic Gas Stations, Fort Devens,
                   Massachusetts,"  ABB Environmental Services, Inc., "Draft No Further
                   Action Decision Document Under CERCLA, Study Area 14, Landfill No.
                   10,  Groups 2 & 7 and Historic Gas Stations, Fort Devens, Massachusetts,"
                   ABB Environmental Services, Inc., "Draft No Further Action Decision
                   Document Under CERCLA, Study Area 43B, Historic Gas Station Sites,
                   Groups 2 & 7 and Historic Gas Stations, Fort Devens, Massachusetts,"
                   ABB Environmental Services, Inc., "Draft No Further Action Decision
                   Document Under CERCLA, Study Area 43N, Historic Gas Station Sites,
                   Groups 2 & 7 and Historic Gas Stations, Fort Devens, Massachusetts,"
                   ABB Environmental Services, Inc.
             32.    Comments Dated September 30, 1994 from James P. Byrne, EPA Region I
                   on the August  1993 "Draft Decision Document, Fort Devens Study Area
                   28, Waste Explosives Detonation Range (Training Area 14)," ABB
                   Environmental Services, Inc.

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             33.     Comments Dated June 30, 1994 from James P. Byrne, USEPA Region I on
                    the No Further Action Decision Under CERCLA Documents for Study
                    Area 28 and 47.
             34.     Comments Dated March 17,  1995 from D. Lynne Welsh, Commonwealth
                    of Massachusetts Department of Environmental
             35.     Cross Reference: Comments Dated on March 22, 1996 from James P
                    Byrne, USEPA Region 1 on "Draft ROD for the South Post Impact Area
                    and AOCs 25, 26, and 27, Fort Devens, Massachusetts," Home
                    Engineering (February, 1996), [Filed and cited in minor break 5.4 Record
                    of Decision (ROD) of the Fort Devens Group  IB Sites Administrative
                    Record Index.]
             36.     Cross Reference: Comments dated on March 25, 1996 from John Regan
                    (MADEP) on the "Preliminary Draft ROD for the South Post Impact Area
                    Groundwater and AOCs 25, 26, and 27, Ft. Devens, Mass." (Home,
                    February 1996), [Filed and cited in minor break 5.4 Record of Decision
                    (ROD) of the Fort Devens Group IB Sites Administrative Record Index.]
             37.     Cross Reference: Comments dated on May 10, 19% from John Regan
                    (MADEP) on "Draft Final ROD for the South Post Impact Area and AOC
                   41 Groundwater and AOCs 25,26, and 27" (Home, April 1996), [Filed
                   and cited in minor break 5.4 Record of Decision (ROD) of the Fort Devens
                   Group  IB Sites Administrative Record Index.]
             38.    Cross Reference: Comments dated on June 14, 1996 from John Regan
                   (MADEP) on "Final ROD for the South Post Impact Area and AOC 41
                   Groundwater and AOCs 25, 26, and 27, Ft. Devens, Mass." (Home, April
                    1996), [Filed and cited in minor break 5.4 Record of Decision (ROD) of
                   the Fort Devens Group IB Sites Administrative Record Index.]

             Response to Comments

             34.    Responses Dated January 1995 from U.S. Army Environmental Center on
                   the following documents: Draft No Further Action Decision Under
                   CERCLA SA 14, SA 43B and SA 43N - Groups 2, 7, and Historic Gas
                   Stations, Fort Devens, Massachusetts.
             35.    Responses Dated January 1995 from U.S. Army Environmental Center on
                   the following documents: Draft No Further Action Decision Under
                   CERCLA SA 43C, E, F, L, M, P, Q, R, S - Groups 2, 7, and Historic Gas
                   Stations, Fort Devens, Massachusetts.
             36.    Responses Dated January 1995 from U.S. Army Environmental Center on
                   the following documents: Draft No Further Action Decision Under
                   CERCLA SA 58 - Groups 2,  7, and Historic Gas Stations, Fort Devens,
                   Massachusetts.
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 10.0   Enforcement

       10.16 Federal Facility Agreements

             1.      Cross Reference: "Final Federal Facility Agreement Under CERCLA
                    Section 120," EPA Region I and U.S. Department of the Army (November
                    15, 1991) with attached map [Filed and cited as entry number 1 in minor
                    break 10.16 Federal Facility Agreements of the Fort Devens Group 1A
                    Sites Administrative Record Index].

 13.0   Community Relations

       13.2  Community Relations Plans

             Reports

             1.      Cross Reference: "Final Community Relations Plan," Ecology and
                    Environment, Inc. (February 1992) [Filed and cited as entry number 1 in
                    minor break 13.2 Community Relations Plans of the Fort Devens Group
                    1A Sites Administrative Record Index].

             Comments

             2.      Cross Reference: Letter from James P. Byrne, EPA Region I to F.
                    Timothy Prior, Fort Devens (March 19, 1992), concerning approval of the
                    February 1992 "Final Community Relations Plan,"  Ecology and
                    Environment, Inc.

       13.11  Technical Review Committee Documents

             Cross Reference: The following documents cited below as entries number 1
             through 8 are filed and cited as entries number 1 through 8 in minor break 13.11
             Technical Review Committee Documents of the Fort Devens Group 1A Sites
             Administrative Record.

             1.     Technical Review Committee Meeting Agenda and Summary (March 21,
                    1991).
             2.     Technical Review Committee Meeting Agenda and Summary
                   (June 27,1991).
             3.     Technical Review Committee Meeting Agenda and Summary (September
                    17, 1991).
             4.     Technical Review Committee Meeting Agenda and Summary (December
                    11, 1991).
             5.     Technical Review Committee Meeting Agenda and Summary (March 24,

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                    1992).
             6.     Technical Review Committee Meeting Agenda and Summary (June 23,
                    1992).
             7.     Technical Review Committee Meeting Agenda and Summary (September
                    29, 1992).
             8.     Technical Review Committee Meeting Agenda and Summary (January 5,
                    1993).

 17.0    Site Management Records

       17.6  Site Management Plans

             Cross Reference: The following Reports, Comments, and Responses to
             Comments (entries 1 through 9) are filed and cited in minor break 17.6 Site
             Management Records of the Groups 3, 5, & 6 Administrative Record Index unless
             otherwise noted below.

             Reports

             1.     "Final Quality Assurance Project Plan," Ecology and Environment, Inc.
                    (November 1991).
             2.     "General Management Procedures, Excavated Waste Site Soils, Fort
                    Devens, Massachusetts," ABB Environmental Services, Inc. (January
                    1994).

             Comments

             3.      Cross Reference:  Comments from James P. Byrne, EPA Region I on the
                    November 1991 "Final Quality Assurance Project Plan," Ecology and
                    Environment, Inc. [These Comments are filed and cited as a part of entry
                    number 8 in the Responses to Comments section of this minor break]
             4.      Comments Dated December 16,1993 from Molly J. Elder, Commonwealth
                    of Massachusetts Department of Environmental Protection on the
                    November 1993 "Draft General Management Procedures, Excavated
                    Waste Site Soils, Fort Devens, Massachusetts," ABB Environmental
                    Services, Inc.
             5.      Comments Dated December 27, 1993 from James P. Byrne, EPA Region I
                    on the November 1993 "Draft General Management Procedures,
                    Excavated Waste Site Soils, Fort Devens, Massachusetts," ABB
                    Environmental Services, Inc. [Filed and cited as entry number 4 in minor
                    break 4.4 Interim Deliverables of the AOCs 44/52 Administrative Record
                    Index.]
             6.      Comments Dated March 11, 1994 from D. Lynne Welsh, Commonwealth
                    of Massachusetts Department of Environmental Protection on the January


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                     1994 "General Management Procedures, Excavated Waste Site Soils, Fort
                     Devens, Massachusetts," ABB Environmental Services, Inc.

              Responses to Comments

              7.      Cross Reference: U. S. Army Environmental Center Responses to
                     Comments on the following documents: Feasibility Study Report;
                     Biological Treatability Study Report; Feasibility Study Report - New
                     Alternative 9, Draft General Management Procedures Excavated  Waste
                     Site Soils; and Draft Siting Study Report, dated January 25, 1994. [These
                     Responses to Comments are filed and cited as a part of entry number 7 in
                     the Responses to Comments section of minor break 4.4 Interim
                     Deliverables of the AOCs 44/52 Administrative Record Index.]
              8.      Response from Fort Devens to Comments from James P. Byrne, EPA
                     Region I on the November 1991  "Final Quality Assurance Project Plan,"
                     Ecology and Environment, Inc.
              9.      Cross Reference: U.S. Army Environmental Center Responses to
                     Comments for the following documents: Final Feasibility Study Report;
                    Draft Proposed Plan; Revised Draft Proposed Plan; Draft Excavated Soils
                    Management Plan; Final General Management Procedures Excavated
                     Waste Site Soils; and Biological Treatability Study Report, dated  May
                     1994. [These Responses to Comments are filed and cited as entry number 8
                     in the Responses to Comments section of minor break 4.4 Interim
                    Deliverables of the AOCs 44/52 Administrative Record Index.]

       17.9   Site Safety Plans

              Cross Reference:  The following documents (entries 1 through 3) are filed and
              cited in minor break 17.9 Site Safety Plans of the Fort Devens Group 1A
              Administrative Record File Index unless otherwise noted below.

              Reports

              1.      "Final Health and Safety Plan," Ecology and Environment, Inc.  (November
                     1991).

              Comments

              2.     Cross Reference:  Comments from James P. Byrne, EPA Region I on the
                    November 1991  "Final Health  and Safety Plan,"  Ecology and Environment,
                    Inc. [These Comments are filed and cited as a part of entry number 8 in
                    minor break 17.6 Site Management Plans of the Group 1A Sites
                    Administrative Record File Index].
C:\0102\DELIVER\SPIA\FIN ALROD\INDEX2ft7.DOC                                              July, 1996

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page C -18

             Responses to Comments

             3.     Response from Fort Devens to Comments from James P. Byrne, EPA
                   Region I on the November 1991 "Final Health and Safety Plan," Ecology
                   and Environment, Inc.
C:\0102\DEUVER\SPIA\FINALROD\INDEX2&7.DOC                                           July. "96

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 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27      Page C - 20

                              GUIDANCE DOCUMENTS

    The following guidance documents were relied upon during the Fort Devens cleanup. These
    documents may be reviewed, by appointment only, at the Environmental Management Office
    at Fort Devens, Massachusetts.

    1.     Occupational Safety and Health Administration (OSHA). Hazardous Waste Operation
          and Emergency Response (Final Rule, 29 CFR Part 1910, Federal Register. Volume
          54, Number 42) March 6, 1989.
    2.     USATHAMA. Geotechnical Requirements for Drilling Monitoring Well. Data
          Acquisition, and Reports. March 1987.
    3.     USATHAMA. IRDMIS User's Manual. Version 4.2, April 1991.
    4.     USATHAMA. USATHAMA Quality Assurance Program: PAM-41. January 1990.
    5.     USATHAMA. Draft Underground Storage Tank Removal Protocol - Fort Devens.
          Massachusetts. December 4, 1992.
    6.     U.S. Environmental Protection Agency. Guidance for Preparation of Combined
          Work/Quality Assurance Project  Plans for Environmental Monitoring: OWRS OA-1.
          May 1984.
    7.     U.S. Environmental Protection Agency. Office of Research and Development Interim
          Guidelines and Specifications for Preparing Quality Assurance Project Plans:  OAMS-
          005/80. 1983.
    8.     U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
          Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies
          Under CERCLA. (OSWER Directive 9355.3-01, EPA/540/3-89/004, 1986.
    9.     U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste:
          EPA SW-846 Third Edition. September 1986.
    10.    U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
          Risk Assessment Guidance for Superfund. Volume I. Human Health Evaluation
          Manual (Part AV (EPA/540/1-89/002), 1989.
    11.    U.S. Environmental Protection Agency. Hazardous Waste Management System:
          Identification and Listing of Hazardous Waste: Toxicitv Characteristic Revisions.
          (Final Rule, 40 CFR Part 261 et al., Federal Register Part V), June 29, 1990.
C:\OI02\DEUVER\SPIA\FINALROD\INDEX2&7.DOC                                            July, 1996

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                                            Section II




                                      Guidance Documents
C:\0102\DELIVER\SPIA\FINALROD\INDEX2&7.DOC                                                   July. 1996

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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25, 26, & 27
                   RECORD OF DECISION SUMMARY
                    SOUTH POST IMPACT AREA AND
            AREA OF CONTAMINATION 41 GROUNDWATER AND
                AREAS OF CONTAMINATION 25,26, AND 27
                    FORT DEVENS, MASSACHUSETTS
                            APPENDIX D

                     RESPONSIVENESS SUMMARY
C:\PP ft ROD\DEUVER\SP1A\FINALROD\FROD30.WPD                               M«y30.1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page D- 1
1. Orielnallnc Organization of Document: U.S. Army Environmental Center : ... . : ••.-.. . : ' : •; : ...... :.•
2. Document Title: Draft Final Record of Decision for th« South Pott Impact ATM and Area of Contamination 41 Groundwater, and Areas of Contamination 25, 26, and 27 :; : ¥. .x:: ; :• :
3. Date Comment* Required: Response document ...:.,.. : : ; : .."••:;•:.... : .:;.:. :.::;.:;.:.. ..••
4. Reviewed
fcy:
5.
PaKe
6.
Line
V
Section
o. Comment • - •:.••.•• . :• .• :.'- ';..'. ' '-|' ••'/-'• :'•':'. . ; •' •' .-• :' . : " ' • --
9. Comment Response . : • . .
....;; v , ;:;-:>^7<;;:-;V:V Vy.:f ' -/- '
PROPOSED PLAN for SP1A Groundwater and AOCi 25. 26. ind 27 . January 30, 1996
Nashua River
Watershed
Association,
Feb. 21, 1996
Nashua River
Watershed
Association.
Feb. 21, 1996
Nashua River
Watershed
Association,
Feb. 21, 1996
Nashua River
Watershed
Association,
Feb. 21, 1996
7
8&
9
10
12








Oroundwater Investigations Results, p.7 - What is the Army's degree of confidence for its stated
conclusion that "...contamination found in the southern SPIA wells are not impacting the Nashua
River." Even if performed over four consecutive years, once annual sampling at one she (Well D-l) for
one set of contaminants ("explosive-related organic*") seems inadequate. Were other contaminants
sampled for during this four year period? If so, what do their results show?
Oroundwater Monitoring and Ecological Management Plans, pp. 8 & 9. The Army's decision to
develop and implement such plans b welcome re-assurance. NRWA requests that the monitoring
reports mandated by these plans be submitted as well to local Boards of Health and Conservation
Commissions. In addition, these plans should prescribe mitigation measures to be taken in the event that
EPA thresholds for any of the contaminants sampled are exceeded.
EOD Range Risk Assessment, p. 1 0 — This plan should adequately describe the wont case scenario
projected. The plan assumes that continuing habitat disturbance will keep animals and plants off the
potential receptors will not be present However, periods of inactivity will very likely bring about the re-
establishment of animals and plants long before heavy-metal concentrations fall below EPA's thresholds.
Zulu Ranges Risk Assessment, p. 1 2 — What laboratory test was performed (And what were ha results?)
that showed water sample* were not toxic to aquatic invertebrates and fish despite lead accedences?
Again, if animals and plants return to disturbed habitat during these times of disuse; excessive

Sampling was done in accordance with our approved
QA/QC plan. D-l has been sampled for the complete
list of TAL, VOCs, semivolatiles, PCBs, explosives,
and semi-volaliles.
The Army, USEPA-New England, and MADEP will
develop the details of the Integrated Natural Resources
Management Plan. This plan will be developed within
6 months of ROD signature. This issue will be
addressed in the plan.
The Army, USEPA-New England, and MADEP will
develop the details of the Integrated Natural Resources
Management Plan. This plan will be developed within
6 months of ROD signature. This issue will be
addressed in the plan
The laboratory tests performed were surface water
chronic toxictty tests with invertebrates and fathead
minnows, tests were performed according to EPA
guidance. Results are provided in Appendix K to
Volume V of the Ft Devens Functional Area I RI
Report (August 1994). Water for testing was collected
from three sites in the north Zulu wetland and one site
in the south Zulu wetland. No effects on survival and
fecundity were observed. These results suggest that
indigenous biota would not be adversely affected by the
levels of contamination in wetlands associated with the
Zulu site.
The Army, USEPA-New England, and MADEP will
develop the details of the Integrated Natural Resources
Management Plan. This plan will be developed within
6 months of ROD signature. This issue will be
addressed in the plan
 U:\PP & ROD\DELIVER\SPIA\FINALROD\COMR£S22.DOC
                                                                                                                     June 18. 1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Ground water and AOCi 25.26, A 27
Page D- 2
l. Orlfta
2. DOCWM
J D s»tr1 ra*.>J
fcf!
Nashua River
Watershed
Aavociatton,
Feb. 21, 1996
U.S DOLFish
•ml Wildlife

§7-1, «M| 14XUC




iic nni Ft.
29.1996
ttafOrti
MrtTNfci

hfC
13











•Izaitoa) <
Draft Fh
6. •'•'•
Us*












rfDaCWNC**
•1 Record*
7













t U.S.AnnyEavlrasim«nlalCesrt«r
D«fMBii«rtAtCTaM4Ai*«»fCa>l«a^h*a«laai41Cii»iiincy dtfpoaal of waate ofafaanoe) ceaae at tfit tte. Conviiloontafninant


AOC 23 (F.xptonvc Onhancc DiajMMal Range)
In MM N^iwc MM| RUMtf tfjjliai of Ifa RI /VfJ II mica 1.11 Tatil* 1.D ri«Mi*r I Vi 7 na/ll ««H U»H
(It.t payt) at AOC #23 emeedlh* acule mi dvank ftcahviatcr Ambient Water Quality Criteria,
reapertfwty. ineae elevated ooncentfattoni wve not oncvaaM in the RI aoolofical nak aaaesanient
(ERA). The ERA •uromaryia the Propoaei Plan (pg. IO)al»o«toe«iMtineiiliootheaeconUiniuaiiU

rVMa^^k^i^iMtti^i^il 1^. 1&. BM^il JT ''' '' '•'•


Six aamplea were collected ntheRland3intheSIat
Cranberry Pond. As Hated in the ecological ri*k
in nearby Zuhl surface water umptei fufgesti that the
lead i« in a chemical form which is not bioavailaMe and
doe* not po*e a threat to aquatic life.
Hie Army, USEPA-New Englaml, and MADEP will
develop the detaib of the Inletrated Natural Resource*
Manacementrlaa This plan will be developed within
6roonthiofROD»ipiaiure. This issue will be
addressed SB the plan
Tb» foilownt tent has been added to the ROD -Should

rvHiAirtMl Tti* I?M MM h* •MMiirLI*fttAlfe* ItQCOA
NewEnftandandMAOEPfbrcomment''
The Army, USEPA-New England, and MADEP will
Ania*la*M Ik* Aitmilu «t>flK<« lm**mrmi**i MatManal C ••MMaannaiai

6monU«ofROD«gna.we. Th»»uew.nbe
addreaaed iotfieptan.


west of the site across Firebreak Road, which flows into
State Rock Brook. This aprina; was very shallow and
the sample collected from it was turbid, explaining the
elevated metals. There is a groundwater divide
between the EOD disposal area and the spring so tfut
the disposal area cannot possible affect the water
quality at the spring. The ecological risks of
contaminants in Slate Rock Brook were evaluated in
the assessment of the SPIA provided in Section 9 of
Volume I of the Ft Devens Functional Area I RI
Reoort
 U:\PP * ROCADELIVER\SPIA\FrNALROOCOMRES22.DOC
  June IS. 1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25.26, & 27
                                                                                                                                                                       Page D- 3
  i.
Orleuutlne Organization of Document:  U.S. Army Environmental Center
            Document Title; Draft Final Record of Decision for the South Post Impact Are* said ATM of Contamination 41 Cronndwater. and Areas of Contamination 25.26, and 27
            Date Comments Required; Response document			..  	
  4. Reviewed
                        .
                     Paje
                  6. .••.:•.
                  Une
7.
Section
8* C-onuneitt
                                                                                                         9. Comment Reattome
  U.S. D01. Fish
  and Wildlife
  Service, Feb.
  29.19960
                                      AOC 25 (Explosive Ordnance Disposal Range)
                                      In the RI (Vol. II, pg. 9-1, Line 44), we found an inconsistency in the discussion of potential polycyclic
                                      aromatic hydrocarbon (PAH) contamination in surface toilt. The ERA stated that since PAHs were not
                                      detected in subsurface toils, the tame organic analytical results would be expected in surface toils,
                                      which were not analyzed for PAHs. This logic in the ERA for soil PAHs did not make tense. We could
                                      accept the opposite (i.e., if the surface was uncontaminated the subsurface would likely be
                                      uncontaminated), but the supposition that the surface toils are clean because the subsurface soils were
                                      uncontaminated it illogical. Wat this issue ever resolved? To us, this it an inconsistency that should
                                      have been addressed before • Proposed Plan of No Action was issued Sampling to determine potential
                                      PAH surface toil contamination appears warranted.	
                                                                                                         The presumed lack of PAH contamination in surface
                                                                                                         soils was based on the fact that TPHCs were found at
                                                                                                         approximately the same concentration in both surface
                                                                                                         toil and subsurface soil, yet PAHs (a component of
                                                                                                         petroleum hydrocarbons) were not detected in
                                                                                                         subsurface samples.
   US. DOI, Fish
   and Wildlife
   Service, Feb.
   29.1996
                                      AOC 26 (Zulu Ranges)
                                      We pointed out that elevated contaminant concentration* were omitted from the RI (Vol III, pg. 5-1,
                                      Line 12) discussion if they could not be related to the the. If an environmental contaminant wat found
                                      at concentrations likely to cause a biological effect, the RI should have mentioned the elevated level and
                                      its consequence* even if the contaminant could not be directly attributable to military training or
                                      demolition activity
                                                                                                         The concentrations of these chemicals was equivalent
                                                                                                         to the local background concentrations. However, the
                                                                                                         Army, USEPA-New England, and MADEP will
                                                                                                         develop the details of the Integrated Natural Resources
                                                                                                         Management Plan. DOI concerns of data gaps will be
                                                                                                         discussed during this plans development  This plan will
                                                                                                         be developed within 6 months of ROD signature. This
                                                                                                         issue will be addressed in the plan.
   U.S. DOI, Fish
   and Wildlife
   Service,
   Feb. 29,1996
                                      AOC 26 (Zulu Ranges)
                                      The RI ERA (Vol. Ill, pg. 9-23) recommended additional toxicity tests, chemical analysis of sediment
                                      pore water, and/or other ecological investigations in the Zulu wetlands. The Proposed Plan (pg 12),
                                      however, only mentions that water samples were not toxic to aquatic invertebrates and fish.
                                                                                                         The Army. USEPA-New England, and MADEP will
                                                                                                         develop the details of the Integrated Natural Resource*
                                                                                                         Management Plan.  This plan will be developed whhin
                                                                                                         6 months of ROD signature.  This issue will be
                                                                                                         addressed in the plan.	
   U.S. DOI, Fish
   and Wildlife
   Service,
   Feb. 29,1996
                                      AOC 26 (Zulu Ranges)
                                      The USFWS concurred with the Army that remediation was not necessary at AOC #26 if explosive and
                                      ordnance training were to continue (Vol. HI, pg 5-2, Line 32). We qualified this statement in our letter
                                      with the condition that new contamination from ongoing military activities may require a reassessment if
                                      the South Post dotes and new land-uses may be implemented. Specifically, lead and explosive
                                      contaminants should be reassessed following closure.  We also concurred with the RI findings that
                                      further investigation is warranted to evaluate risk to ecological receptors using the Zulu wetlands (Vol.
                                      Ill, pg. 9-23, Line H).	
                                                                                                         No response rcijutrcu.
   U.S. DOI, Fish
   and Wildlife
   Service,
   Feb. 29.1996
                                       AOC 27 (Hotel Range)
                                       Surface soil contamination at AOC #27 requires further evaluation. In the review of the RI (see
                                       USFWS comments for Vol. IV, pg. 5-1 and 9-8), it was unclear to us how the subsurface soil boring
                                       data related to potential turficial contamination. Although, we recommended limited surface soil
                                       sampling to resolve the issue, it apparently was never conducted.
                                                                                                         Subsurface soils were collected in the RI, and in the SI
                                                                                                         10 toil samples were collected at depths of 0 to 20 feet
                                                                                                         Both the SI and RI data were evaluated in the
                                                                                                         ecological risk assessment, and no COPCs were
                                                                                                         identified. In addition, the entire former disposal area
                                                                                                         has been deeply buried as a result of profound
                                                                                                         remodeling. All surface soils at the AOC are recently
                                                                                                         bulldozed subsoils or originate from outside the former
                                                                                                         disposal area. Therefore, additional soil sampling does
                                                                                                         not appear to be warranted.
  U:\PP & ROD\DELrVERVSPIA\FINALROD\COMRES22.DOC
                                                                                                                                                                                     June 18. 1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCi 25,26, & 27
                                                                                                                           Page D- 4
            Oiirinattat Oreaisltadosi of Document» UA Anny EnvfromiMBtal Center
            DoctisnentTHIe; Draft Fhtal Retard •fDechhm for the goat* Fee* In
                            ct ATM and AIM •t'ContaiiisjiatlBai 41 Ciu*««1wrter. and Aftm *t
                                                                                                     IS. U. and 17
            Date Comments Required; Response document
  ky:
                                     7.
                                     Seettsi
                                                                                         9.C«
                                                                                                  I* Re
  U.S. DOI, Fnh
  •nd Wildlife
  Service,
  Feb. 29.1996
AOC 27 (Hotel Range)
The ERA focused on potential risks to aquatic invertebrates in Osflberry Pond (Vol. IV, pg. 9-14, Line
17). Although lesd was detected m surface water, the ERA dkl not inchi*^
tone wffTvi w>tef ran community in flMpond,
                                                                                         As discussed in section 9 of Volume IV of die Fort
                                                                                         Devens Functioml Area IRI Report, page 9-12, line
                                                                                         15, the assessment of risks to aquatic invertebrate* was
                                                                                         done using toxicity reference value* that address all
                                                                                         form* of aquatic life, including fi*h and aquatic plants.
   U.S. DOI, Fish
   and Wildlife
   Service,
   Feb. 29.1996
AOC 27 (Hotel Ranae)
The RI (Vol. IV. pf, 9-16, Urn 5) wonted that toxkfcy teats conducted for AOC *26 may abo be
appncaMetoAOC«27.  The Proposed Pta (pf. 1 3) also attempts to make thb connection. Aivw
                                                betwwn the sites may make this an invalid hypothem. We agreed with a conchmon in the ERA (Vol.
                                                IV,ps>9-l9.Une20)lliatlliebenllikcminiuiiitymaybeatri«klhm                     To
                                                resorve Ms iame. toxicity test* for AOC #27 should be conidered fa the propoaed EavinMiMntal
                                                MariatementMoiiitormtrlan. _
                                                                                         The Army, USEPA-New England, and MADEP will
                                                                                         develop the detail* of the integrated Natural Resources
                                                                                         Management Plan.  This plan win be developed wilhm
                                                                                         6 monlhi of ROD signature. This issue win be
                                                                                         addressed in the plan.
   U.S. DOI, Fish
   •ndWildKfe
   Service,
   Feb. 29.1996
                                                                   ng to define the nature
AOC 27 (Hotel Range)
The RI ERA (Yd. IV, pg. 9-19. Une 9)
and extent of contamination in Cranberry Pond. The Proposed Plan (pg. 12) mentions thai only one
sedmtent sample showed elevated metals and dismisses the need for additional sampling. We concur
 • T-J J	_•_-.!	^ f| - p fj » ^--J	»^*- .__- -—•_•__ rt,^» •jijiSilrMl.al - - *•*	*	«?	J^
wm me iccuimicnaHnoiiBi n me cKn^ •no muic uw cpnon BHH wmniaiiu waoncni •*vn|iiin^ v
warranted in Cranbeny Pond.	
The Army. USEPA-New England, and MADEP will
develop the details of the Integrated Natural Resources
Management Plan. Tha plan will be developed within
6 month* of ROD signature. This issue will be
addressed in the plan.
   U.S. DOI. Fish
   and Wildlife
   Service,
   Feb. 29.1996
AOC 27 (Hotel Range)
In the Proposed Plan (pages 10,12. ft 13X the summaries rfEcotopcal Risk Assetments for all three
AOCs slate that the risk at these sites would not be ecotogkaJly significant due to the disturbed nature of
the habitat Tlieae statement* attempt to devshte die hsbitat provided by the SP1A to fnh and wikflife
resources. AU&o^iraKlary activities are dan^lfo and fe
of me year, Uaiiiing activities oo not occur cmtinuously. Many species win unHze the habitants
aisc«ist«dwia the AOCs in other scasom when training is sporadk. Some species are even more
tolerant ef military Gaining and may coipportwWProrx)scdr1an in iu present fbrin.  If the rccommendstian* and data gap*
identified in this letter are completely addressed wUmneEcoh>t^Man««eineMMonitora«
and it b made dear to the Amy the remedial actions may be required in the future, prior to any land
transfer, we couMjoin EPA in supporting the Army's Proposed Plan of No Action We suggest that
language be added to the ROD that require* the Army to accompliihtheERArecomrnendatiomand
investigate or resorve allRI data gaps. Without this language, we believe that a No Action ROD could
be used later in the process to refute the need for additional assessment, samplmg. or remedial action.
Additional work as recommended by DOI will be
discussed during development of the Integrated Natural
Resources Management Plan.
  U:\PP * ROT*DELIVER\SPIA\FINALROD\COMRES2ZDOC
                                                                                                                                                                             June IK. 1996

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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, &  27
                                                                                                                                                                   Page D-S
            Orlelnatlne Organization of Document: U.S. Army Environmental Center
            Document Title:  Draft Final Record of Decision for the South Post Impact Area and Area of Contamination 41 Croimdwater, and Areas of Contamination 25.16, and 27
  3.
Date Comments Required: Response document
  4. Reviewed
  fcy:
         5.
         Page
6.
Line
7.  •:
Section
                                                 8* CJofiifncnt
                                                                                                                                            9*
  MADEP
  Feb. 29.1996
                                      Par. I
                                     The proposed plan should note that the ROD does not affect assessment or remedial activities on the
                                     other South Post sites. These sites include AOC 41 (Beer Can Landfill), SA 6 (household Landfill), SA
                                     12 (Range Control Landfill), SA (Popping Furnace), and RCRA closure of SA 28.
                                                                                                                The following text was added to the ROD Declaration
                                                                                                                statement and Executive Summaries "This ROD does
                                                                                                                not affect assessment or remedial activities on areas not
                                                                                                                specifically mentioned herein."	
   MADEP
   Feb. 29,1996
                                      Par. 5
                                     The MADEP re
                                       aids that the proposed plan note the location of the groundwater divide.
                                     Additionally, the plan should note that an explosive related organic, dinitrobenzene is found in
                                     monitoring wells SPM-93-8X, SPM-93-IOX and SPM-93-I6X which are north of the New Cranberry
                                     Pond Groundwater divide.
                                                                                                       The purpose of the fact sheet and proposed plan is to
                                                                                                       summarize the information on each AOC.  For detailed
                                                                                                       information, the RI Report should be consulted  Even
                                                                                                       though explosives and other contaminants were found
                                                                                                       in the referenced wells, no exposure exists at these
                                                                                                       points based on the current and future use (Army
                                                                                                       training activities). The ecological concerns will be
                                                                                                       addressed in the Integrated Natural Resources
                                                                                                       Management Plan which will be developed post-ROD.
   MADEP
   Feb. 29,1996
                                      Par. 5
                                     Please note that explosives were analyzed in groundwater samples collected from EOD-1 and metals
                                     were present in groundwater samples collected from EOD-4.
                                                                                                                The purpose of the fact sheet and proposed plan is to
                                                                                                                summarize the information on each AOC. For detailed
                                                                                                                information, the Rl Report should be consulted. Even
                                                                                                                though explosives and other contaminants were found
                                                                                                                in the referenced wells, no exposure exists at these
                                                                                                                points based on the current and future use (Army
                                                                                                                training activities). The ecological concerns will be
                                                                                                                addressed in the Integrated Natural Resources
                                                                                                                . Management Plan which will be developed post-ROD.
   MADEP
   Feb. 29,1996
                     10
                                      Par. 7
                                     The MADEP rec
                                     groundwater.
                                       rnb that the plan note the presence of explosives and metals in AOC 26
                                                                                                        The purpose of the fact sheet and proposed plan is to
                                                                                                        summarize the information on each AOC. For detailed
                                                                                                        information, the Rl Report should be consulted. Even
                                                                                                        though explosives and other contaminants were found
                                                                                                        in the referenced wells, no exposure exists at these
                                                                                                        points based on the current and future use (Army
                                                                                                        training activities). The ecological concerns will be
                                                                                                        addressed in the Integrated Natural Resources
                                                                                                        Management Plan which will be developed post-ROD.
   MADEP
   Feb. 29,1996
                      12
                                      Par. 4
                                      Although the proposed plan notes the presence of metal contamination in one Cranberry Pond sediment
                                      sample, the analytical data indicates numerous accedences of background and sediment criteria in other
                                      Cranberry Pond sediment samples.  The MADEP recommends that the Army review the available
                                      sediment data and include language in the proposed plan noting the accedences. Additionally the
                                      proposed plan should note the presence of explosives in groundwater on the the.
                                                                                                                The purpose of the fact sheet and proposed plan is to
                                                                                                                summarize the information on each AOC.  For detailed
                                                                                                                information, the RI Report should be consulted  Even
                                                                                                                though explosives and other contaminants were found
                                                                                                                in the referenced wells, no exposure exists at these
                                                                                                                points based on the current and future use (Army
                                                                                                                training activities). The ecological concerns will be
                                                                                                                addressed in the Integrated Natural  Resources
                                                                                                                Management Plan which will be developed post-ROD.
  U:\PP & ROD\DELFVER\SPIA\FINALROD\COMRES22.DOC
                                                                                                                                                                      June 18, 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOO 25,26. & 27
Page D- 6
1. OritinatlntOriatgfatlonofDatasatatt UA Ann* iHvtrmmmtm** Center '
2. DiiMMiiHTMtet Dr»»rT»^iUc«^ofP«cMaeilorlli«go«^r«« that then it no Areat to human health aM>ciated with SP1A
pouu>n»«ter bated oafkfc am aaiiri^ and qaBent«i«,<^recotnweiid that t^
fM^ •^•B^BM^Mata ifilliMVl •WftaMa^W aWIMMMllaTB^BV aM A aWatMlaMlaMtf mVJBafllMttV
The Amy ondenttandi Mid agree* with MADEP that
any fbture actions will need to be omaed to' determine
tflffSaT BUatMeallait MatHliirt aUul tK« •MMhfl ftar auMiftumail
nvestiflMioM.
The tbllowinf text wat added to the ROD Declaration
net affect Mccament or remedial activities on areas not


funvMrizetheinferniationoneachAOC. For detailed
kdonn^Km, the Rl Report ahould be consulted Even
M the referenced wclh. no ejB^oaure cxuta ai these
pointt baaed on the curmit and lutufe uee (Army
tnm.iitactiv.ties). The ecological concern will be
aaltWeMTril in thai fraf-antjuf Maittuml DdkaMM.MM.1


The Aimyapees that the rntui are within USEPA
ilandards baaed on current and Aiture use. The Army
has included statement to ttiat eflect in the ROD.

pathway in tfwRI.
DIWfTRODDELIVERVSPIA\FINALROiyCOMRES22 DOC
                                                                                                                   June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page D- 7
1. Originating Organization of Document: U.S. Army Environmental Center
2. :: '•? : DocujiKnt Title: Draft Final Record of Decision for the South Post Impact Am and Are* of Contamination 41 Groundwater, and Area* of Contamination 25, 26, and 27
3. Date Comment* Required: Response document
4. Reviewed
**• ••:••:: ';—'.v;
EPA-New
England
(no date)
EPA-New
England
(no dale)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England .
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
5. •':..:;
P.fe
Oen.
ES-I
ES-1
ES-2
ES-2
ES-2
ES-2
ES-2
ES-2
3
4
5
14
«.:/:.
Line

20
23
4
18
20
24
36
38

9
20
18
7.
Section









Par. 3



8, .Comment
Please delete "deemed acceptable by USEPA-New England" and change to read "deemed acceptable" in
all lection of the ROD that have this statement
Please change this line; the sentence is-duplicative.
Pleas* add that this will be the use for the foreseeable future also.
Please add at the end of the sentence: "within 6 months of ROD signature."
Please add the additional parameters that Otis will be sampled for (i.e.. MCLs/MMCLs).
Please make the development of this plan a separate paragraph. Please add "the details of this plan will
be developed jointly by the Army. EPA New England. US Fish and Wildlife Service, and MADEP
within 6 months of ROD signature."
Please add to the end of the sentence: "annually.'*
Please add a sentence describing the Army's responsibilities if the land use changes as a result of closure
and/or transfer.
Please add to the end of this sentence: "as required under CERCLA."
Please reference the fact that the SPIA was retained and will continue to be used as a training range.
The TRC was established in March, 1991.
Please specify what the "future activities" are (i.e., military training).
IE-6 is 1/1,000,000 not 1/100,000. Please change.
9. Comment Response
Global search done to remove "deemed acceptable by
USEPA-New England" and replace with "deemed
acceptable."
Changed sentence to read "The SPIA is
approximately.."
Changes text to read "SPIA is and will be for the
foreseeable future an active.."
Text was added.
The following text was added to the end of this bullet
"Massachusetts and Federal drinking water
requirements (MMCLs/MCLs)."
Bullet was not changed. Text was separated from a
subsequent paragraph and made a stand alone
paiapapti that focuses on this plan.
Text was added.
The following text has been added to the ROD "Should
the Army close and/or transfer this property, an
Environmental Baseline Survey (EBS) will be
conducted. The EBS will be provided to the USEPA-
New England and MADEP for comment"
Text was added.
The following text was added " However, the SPIA will
be retained by the Army for continued use as a training
range."
The text was modified to read correctly.
The text was modified to read "..future military training
activities.."
The text was modified to read correctly.
 U:\PP * ROD\DELrVER\SPIA\FINALROD\COMRES22.DOC
                                                                                                                   June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOO 25,26, & 27
Page D- 8
1, OHftM
2. • DOCUHM
3. Dated
t HJT.L M.J 1
•y
EPA-New
England
(no fete)
EPA-New
England
(no date)
EPA-New
England
(no date)

ErA-rleW
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
(no date)
EPA-New
England
CiMdatel
IWUMEJ
EPA-New
England
(no date)
MADEP
Vf« ^€ IQQJC

MADEP
Mar. 25. 1996
MADEP
U*r M IQQfC

tine Ore*
mt Title:
MHIKNtol
«
Pne
16
17
IS


IS
IS
IS
19


A-E


Dl
D2

mb«Hon<
Draft Fta
teajatrtd:
< •
Lfcte
12
35
II


29
37
41
3





45
6

rf Document
•IRtcwrd*!

7
Sectfo*


vin





Par. 1








t U A Ariay Environmental Center
Dtehtoai hr Hie South Port Impact Arm and Area) «f Cunlamaaatloii 41 Cioaudinter.aad Ar*a»of

ft aPilla^ia^gtfia^

I.2E-I « not within or below the EPA't risk range. U this • typo? Pleace clariry.
How doe» the Army Range Control restrict acccn? Are there McuritypHroh, etc.? Pfcate expand this
tection.
Pka*ea4datllwendorihe*ef«cnM:'\vMin6!m
I *-- * — tttSc t«Mn«tf 1 iHMtLI n»mm**l nfafl liaafina* MMTiifir iiMHai flluai nlam •«•!! aMMMaV fn h* n+mf*»mtmA lMaliiM«n
Army. EPA, and MADEP.
Pleaae add that the Plan will be developed within 6 month* of the ROD.
Pleate make Dm • icpante paragraph and exptein that thb plan win Iw jointly developed by the Army.
EPA. US Rah and WildUfe Service, and MADEP withan aix morthi of ROD wgnature.
Please add at the end of the sentence: "annually."
Who will implement the fang term groundwater monitoring plan? Thai needs to be mentioned abo.


Pleaae add the rick table* to the appendix
Recommends Anther review of South Post groundwater flow directions, hydraulic conductivity, well

Add at the end of the sentence "for the pathways that were assessed"
Please note that the no-action ROD does involve long term monitoring of groundwater.


Contamination 25, 26, and 27



Number was entered incorrectly, the appropriate value
"1.7 x ID*1 has been entered.
Text adequately describes restrictions.
The desind text has been added.

tSpccuic rCici dice HsU Dccn rwnovoo.
The following text was added to this paragraph "The
plan will be developed within 6 months of ROD
The desired text was added
The desired text was added
The details of the ghround water monitoring plan
(snduding number and location of monitor m( points)
will Iw 
England, US. Fish and Wildlife Aisociation, and
MADEP.
The appropriate tablea have been added to Appendix E.
The details of the ghround water monitoring plan
win be developed jointly by the Army. USEPA-New
England, U.S. Fish and Wildlife Association, and
MADEP.
The desired text has been added
The following sentence was added to the end of the
win be conducted at the site under du* "no action"
ROD."
 U:\PP A ROD\DELIVER\SPIA\FINALROI>«COMRES22 DOC
                                                                                                                  June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page D- 9
1. . Orlematlhe Organization of Document: U.S. Army Environmental Center .: ; . .:
2. Document Title: Draft Final Record of Decbfcm for the South Post Impact Am and Area of Contamination 41 Groundwater. and Area* of Contamination 25, 26, and 27
3. Date Commenti Required: Response document :
4. Reviewed
by: :;.'V
MADEP
Mir. 25, 1996
MADEP
Mar. 25, 1996
MADEP
Mar. 23. 1996
MADEP
Mar. 23, 1996
MADEP
Mar. 23, 1996
MADEP
Mar. 23, 1996
MADEP
Mar. 23, 1996
MADEP
Mar. 23, 1996
MADEP
Mar. 25, 1996
MADEP
Mar. 23, 1996
MADEP
Mar. 25. 1996
MADEP
Mar. 25, 1996
5.
P-fe
D2
ES-I
ES-I
ES-1
ES-2
ES-2
ES-2
ES-2

1
4
5
6.
Line
16
32
35
38
11
13
20
33
24
28
43
17
7.
Section












ft. Comment
Add at the end of (he sentence "unless the land use changes."
Add at the end of the sentence "even though levels exceeded Army and EPA action levels."
Add to end of sentence "due to the absence of a pathway for any known ecological receptor to access
SPIAgroundwater."
Add at the end of sentence "for assessed pathways."
Add to end of sentence "to incorporate data from new sentinel well (s) and ascertain any potential
impacts to MCI Shirley."
Please note that the Groundwater Monitoring Plan will be completed within six months of ROD
signature.
Please note that the Ecologies! Monitoring Plan will be completed whhm six months of ROD
signature.
Please change the text to note that reviews may be needed on a more frequent basts than five years
should the conditions change. An example of this would be evidence of transport of a contaminant off-
post or a sharp rise in a contaminant concentration in a sampled monitoring well.
Please check the acreage figure stated in this sentence. A review of the area indicates that the acreage
for the SPIA could be 50% higher than stated.
Please note that the SPIA also encompasses several study areas
Please note that there are information repositories in the Lancaster, Shirley, Harvard and Ayer libraries
that contain information relative to ongoing Fort Devens environmental actions.
Please note that the Ecological Monitoring Plan will be completed within six months of ROD signature.
9. Comment Response
The desired text was added.
The desired text was added
The desired text was added.
The desired text was added.
The desired text was added.
The following text was added to the end of the
paragraph "The groundwater monitoring plan will be
completed within 6 months of ROD signature'*
This information is incorporated in a paragraph
dedicated to the Integrated Natural Resources
Management Plan, following the specified bullet
The following sentence was added to the end of the
paragraph "More frequent reviews may be conducted
should she conditions change."
Total SPIA acreage is 1450 to 1 500 acres, however, in
this ROD we are only addressing the area of the SPIA
north and west of the groundwater divide. This area is
about 964 acres. Language has been added to the text
to clarify this statement
The text has been modified to read "..as well as several
study areas (SA's), and a number of other.."
The following text was added to the end of this section
"In addition, there are information repositories in the
Lancaster. Shirley, Harvard, and Ayer libraries that
contain information relative to ongoing Fort Devens
environmental actions. "
The following sentence was added to the end of this
paragraph "This plan will be completed within 6
months of ROD signature."
 U:\PP A ROD\DELIVER\SP1A\FINALROD\COMRES22.DOC
                                                                                                                    June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCi 25,26, & 27
Page D - 10
1. OrifbM
1. DMMM
J Pajiji mi al
. *** • '••• '
MADEP
Mar. 23. 1996


MADEP
\Arnr H IMA


MADEP
Mar. 25. 1996
MADEP
tJimr 1« IQQJC

MADEP


MADFP
Mir. 25. 1996


MADEP
Mar. 25. 1996

MADEP
Mar. 25. 1996

tine Om
MtTMe:
j^ ..
P»fe
6


9


12
16

IS






IS



mhatlMM
Draft Fh
•V ••
LhM
r


40


38
30

16






IS



rfDoewNcnt
•1 Record •<

StrthMi




















< U A Army EatvtraswicMsi Center
r DtcMen far tin Saath P»st imMct ATM and Art* «f Csntauilrtatla* 41 CrsuadwaJtr. «n4 AFM» of
--__— *— j) ' •


Pleaae note m this paragraph that more than 30H of the SP1 A overiia^
potential source of drinking water. Therefore, MADEP concurrence with the ROD constitutes




•amity WflMr ihM *OM analyzed in Znte RM>» •edmwm.
Pkate note tfiat any Murt Me of SMA (nMadwatcr win nquin • human heahh ritk aaactamcnt
1*e MADEP Mtet that akhoufh the Mdrai contaim a dbcuaMoaorSPIAfroinidwaUr.lhefecliaa
•colof^nccptanftemcortaminttotfiadlDMato. The MADEP racommendi that Ike Mction fadiide
dl§GllaVIOIV OH MNI Mid MtdHMUlBi
The MADEP n*Mim*B**»m*M**M of fee fellowaif additional monitonifwelb to facilitate
U«n LWtaMWn ^PU MJIafV UlH th« fatMai-HM nrttt«r 1«*n H_ 1 TlM nMtAlUtlMI nfttlM fawH Wafl
recommended on Deoortbcr 7. 1994 bylhc AfeiKylcrTo)dcSub.rtMKet.^DtteaMRefij.^
The MAPEF ruf onwnnnii thf inrtaittrttfln of ttic faflffWiiM xJditifliMil liMMtoriM ¥¥ctit to t>ctltUitc
SPIA ajmmdwater monitorinf and enhance Ike South Pott Oroundwtter Model: Add wetb lotith of
Mpijf PffBiJa* IIV Platall tft laWtaVi lanlMailaU tTMaMafalt flf C*»«tamilMtat« nffW«fMt_ Tilt MAflFF • *UJMIalHauU


The MADEP cononwi* the inctem of EPD-1 mtiwLTMP. However, we Kcoroneud lhat 26M-
9243XdW to the proxin^
-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page D- 11
1. Orlelntlne Organization of Document : U.S. Army Environmental Center :: : .; : .-.;: ..; ;-.,.>• .:,';.,,:* -::<: .o«;;::-. .-;:- ;; -.•••.:.: .<••'. •••. .••'. ••'•-.
I. Document Title: Draft Final Record of Decision for the South Port Impact Area and Area of Contamination 41 Groundwater, and Anas of Contamination IS, 26, and 27
3. Date CommenU Required: Response docmnent : : •. . :: :; :. :r . :. .: ; :
4. Reviewed
by!
MADEP
Mar. 25, 1996
MADEP
M«r. 25, 1996
MADEP
Mu. 25, 1996
CHPPM for
OSO
(no date)
CHPPM for
OSO
(no date)
CHPPM for
OSO
(no date)
CHPPM for
OSO
(no date)
CHPPM for
OSO
(no date)
CHPPM for
OSO
(nodite)
5.-- •
Pate
18
18
18
13
14
15
16
17
18
6.
Line
22
29
37






7.
Section



2
B
2
4
C.2
VII
Bt (ffOVIWMIB
The MADEP recommends the inclusion of SPM-93-12X in the LTMP. This well provides better
screening of the southern portion of the SPIA and intercepts groundwater flow from AOC 25.
Please note that the Groundwater Monitoring Plan will be completed within six months of ROD
signature.
Please note that the Ecological Management Plan will be developed within six months of ROD
signature.


Comment: In this paragraph, an example of scientific notation is given in the parentheses. To
correspond to the 1x10-6, the 1/100,000 should be 1/1,000,000.
Recommendation: Please make correction.
Comment: The RME is defined here as exposure to the "maximum contaminant conceiitiations" at a
when the 95 percent UCL exceeds the maximum.
Recommendation: If a decision was made to use the maximum concentration as the RME (not the 95
percent UCL) in the risk assessment, this should be stated clearly in the ROD.
Comment: The cancer risk for an adult exposed to sediment is reported to be 1.2x10-1. Thismustbea
typo considering the combine risk to an aduh is 1.4x10-7.

Comment: In both of these sections, the statement is made that some COCs exceeded USEPA
guidelines, but the ecological risks were deemed acceptable by USEPA-New England. This appears that
the USEPA-New England ignores USEPA guidelines.
to these two sections explaining why continued use of the Impact Areas for military training would
support USEPA-New England conclusion that the ecological risk is acceptable.
Comment: According to this section, the Oroundwater Monitoring Plan will be further developed but is
stated that Well D-l will be sampled annually. Well D-l is currently • potable water source to transient
personnel while training for two week periods.
Recommendation: As part of the Oroundwater Monitoring Plan, in accordance with the suggestion of
the Agency for Toxic Substances and Disease Registry, a sentinel well should be installed between
SPM-93-08X and Well D-l to detect contaminant migration. This will allow for actions such as
prohibiting the use of D-l as needed if significant concentrations of contaminants should be migrating in
that direction.
.9. Comnteat Response •'.;,... ..•.',• ; : . . .
The details of the ghround water monitoring plan
(including number and location of monitoring points)
will be developed jointly by the Army, USEPA-New
England, U.S. Fish and Wildlife Association, and
MADEP.
Text was added.
This information is incorporated in a paragraph
dedicated to the Integrated Natural Resources
Management Plan, following the specified bullet
The desired changes has been made.
The text was modified to read correctly.
The text in this lection was modified to read "and the
average exposure cases evaluated in the human health
risk assessment were based on the maximum and
average chemical concentrations in the exposure media.
in accordance with USEPA-New England (USEPA
1989) guidance."
Number was entered incorrectly, the appropriate value
"1.7 x 10*" has been entered.
Subject text was removed.
The details of the ghround water monitoring plan
(including number and location of monitoring points)
will be developed jointly by the Army, USEPA-New
England, U.S. Fish and Wildlife Association, and
MADEP.
 U:\PP & ROD\DELIVER\SPIA\FrNALROD\COMRES22.DOC
                                                                                                                     June 18, 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCt 25.26, & 27
Page D -12
1. OilihmhuOrtMtort^nafDir ••»»«« V JS. Anaqr Environmental Cmter
2. De*tMM*4Titfct ITran Final ITiiiiJ if Ftifhlin fir ttii Itnatti Till haaarl lUia and i\ln if rinlaa>*nalli« II friia>tnrt». an< ftiiai if rinHiiilniTlnn TTTf an< TT
4. Rc%kfvc4
*v
CHPPM for
OSO
(no date)
CHPPM for
OSO
(no date)
GENERAL
Mi Early
Feb. 39. 1996
&.
P»fe
Gen.
Gen.
«. :-.
UM





DRAFT PROPOSED PLAN Unauthori
MADEP
Mar. 27. 1996
MADEP
Mar. 27, 1996
MADEP
Mar. 27. 1996
MADEP
Mar. 27. 1996
MADEP
Mar. 27. 1996
1
5
I
12
20





7.
SccdM




BOB DWnpMi
2
1
3
4
5
•.CMMMrt
TtaMt^ovl It* Uxl, the term "Contaminants of ftM^^ However. Tables 18-20 in
Appendix E arc entitled "Chemicals of Potential Concern". Shoe the me of "chemicals" i« much ten
mm^mfSmmf 	 » «r^it*r-a«iaa •*TJLLi*'JL»ijlJrtaLj»ra** aajaeTsV **-*- 	 •--•-•a ^ .t_ D/\f\
•••••nWy MiBEm iBjimiiig conunMimn wnn cncniKM n BIB K\^LF.
Overall, concur that *e "No Action" alternative it fuflicientry piotoctmefhimianlieahli wider current
and rcaaonaMc anticipated Aiture uae acenarioa.

variable 4t|Mhi. and Mat for all poatMe poHutaali ndudng enplofrvet.
ANa,AOC41.Febniaryl996 , , •• ••., .:<.;.•. :^-*:t*K-.+. .:•.:.-...: v--:-v. ••::.. -.• , , :..
r^eaatdiriryiheioy ofeBK)tMaltr flow d>U for the area and provide
mvcatftctfi^ te MADEP t^ecs tte
moaitotiBf wcfli indk^Uf rt ItMt MBit Joed &****& fa *mi^ Me* C*v*Hrry*0nd. A
itview 01 FifMra 3. fcMivncM M tntt ponyifNi. HMOBIM me DKMAOC of oontoun on vw nforc. Plnse
Tbe M ADEP concon wMi the inchmon 4 1 M-94-09A,4IM.94-09B,«ftd4IM-94-llXmtheloof Urm
moMlonH| pun. However, we raoonmcnd Ac pravwon of rartnef nteoMic lor DM inclusion of 4 1 M-
J^tkai aMtai fnar iMniiHUkrarfiitM Ha«n lllai Alia* FSffkaw atl ftff 4J AJY Jta> 41 ft J OJ- 1 afY MMttMlifl ta* aimi_i _i 	 ia<_ RM

y.CMMMtRcarMiae
COPC ftandi for "Contaminanta of Potential Concern".
therefore the titlet Tables 1 8-20 in Appendix E will be
corrected.
No response required
•-. :' :• : -.-. :•: ::--::-. ,.-:-.:.-.; :
The detailt of the ajwound water monitoring plan
will be developed jointly by the Army. USEPA-New
En(landL U.S. Hah and WiUKfe Anociation. and
MADEP.

The details of the ahramd water menitarinc plan
(Mdudinf nunivcr MM toniioii 01 RMMlofvt£ pouwi)
wM be developed jointly by the Amy. USEPA-New
England. U.S. Fiah and WildKTe AaMctation. and
MADEP.
•Mot cppliCaibw. SUDJC^ text WM omitted or rewritten.
Not applicable. Subject text was omitted or rewritten.
The detaih of the ghround water monitoring plan
(including number and location of monitoring points)
will be developed jointly by the Army, USEPA-New
England. U.S. F«h and Wildlife Aandatkm. and
MADEP.
The details of the ghround water monitoring plan
will be developed jointly by the Army, USEPA-New
England. U.S. Fish and Wildlife Association, and
MADEP.
 U:\PP * ROT*DELIVER\SPIA\FrNALROIXX>MRES22.DOC
                                                                                                                June It. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page D - 13
1. Originating Organization of Document: U.S. Army Environmental Center . : :..-.•'• '- ••-. . J • ; ;
2. Document Title: Draft Final Record of Decision Tor the South Post Impact Area and Area of Contamination 41 Crouiidwater, and Area* of Contamination 2S, 26. and 27
3. Date Comments Required: Reipome document
4. Reviewed
k*: -'::: ;':.:
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
AEC
(unspecified)
5.
*••£
1
i
i
2
3
4
8
8
8
10
10
12
13
18
*. .:
Une














7.

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 2S, 26. & 27
Page D-14
r»fc 	 •-—+ fltf!*. llaMft PaWa! n*rmmA mt HarklnM ' — tfu. ••••ft Pa^ iMB.rt Araal *•£ in* ''^''•••'•••••••'•'•tt ft flf-Minfe im\mtmr a*Mal Irmmm ~* T*nmt^^tnmttnm H ?£ aMmJ fT
3. D«teC«MMMert«Re««if«d. RMUMI ••tamuit
4« HcvBcwcv
ky.
MADEP
May 10, 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
MADEP
May 10. 1996
&
*fe
6
17
IS
IS
18
IS
IS
IS
20
21
21
f.
LbM











?'•
2
3
1
3
3
3
7
9
3
3
4
tCtmMca*
PleaMdi»cu» South Pott Impact Area (SNA) groundwater dtacharge in flu paragraph. Although it i*
0wnowMer von the SPIA MOD wowd bo •ppfopvwto.
AMKmghMbniulionf«0vdintAOC4l^
tfw continuity of tfwnpoit
PleMo note thftt wolfe ww be HMO to nomlor the Mwditni portion of uw Sn A M wril M In* other side*
^U^*£«MM| aW AA A^^A^BT^a^ ^*— fcj Ann nnaiaiiJaiaa te brfic^M tl»t New Onrtbeny fond mrfacc *r*er it not
cannot impact New Cranbtfry Pond ecolofical reccplon may be flawed MADEP reeommendi that thk
IMM be reaorvtd bdbrc this atatement M indoded in «ie ROD.
9.CuL^-Ultcifinjt
A paragraph from the Rl which dncunc* this brae will
be incorporated into the ROD in its entirety.
All information regarding AOC 41 it included in the
Documentation of Significant Change* in accordance
with EP A-New England fuidanoa
Mention of anrrifir yminoVraUi mnnilof ing w
-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page D - 15
1. - ... OrleuuttnE Organization of Document: U.S. Army Environment*! Center . .-. . : .... : ...
. 2. ..•••'..• Document Title: Draft Final Record of Decision for the South Post Impact Area and Area of Contamination 41 CrouiMfwater, *nd Areas of Cbntiunmatloh 25, 26, and 27
3. : D»te CommenU Required: Response document
4. Reviewed
by: ;.. • ^f
MADEP
May 10. 1996
USEPA-New
England
May 14. 1996
USEPA-New
England
May 14. 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14. 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14, 1996
USEPA-New
England
May 14, 1996
&:-:-; :;.::
tmft
D-5
DS
ES-I
ES-2
ES-2
ES-2
5
17
18
19
20
21-
22
6.
Line












7.
ScCHOB


2
1
lit
bullet
3rd
bullet
'

Island
3rd
bullets
'


• f n 11 1 • i mi
B» ^.UIIUIICIU
The MADEP disagrees with the Army's statement that • number of MADEP comments regarding the
Proposed Plan were received subsequent to the Proposed Plan's finalizalion. The MADEP forwarded its
comments on the Proposed Plan within 30 days of our January 3 1, receipt of the plan. The MADEP

The fust sentence should read "...SPIA groundwater, AOC 41 groundwater, and the three AOCs..."
Please mention that the landfill portion of AOC 4 1 will be handles separately (under State solid waste
program?).
In the fourth sentence, please delete "by EPA New England".
At the end of the third sentence, delete the word "annually", we have not decided on the sampling
frequency as of yet
Delete the word "annually", we have not decided on the sampling frequency as of yet
Please add the public meeting summary and responsiveness summary to appendix D.
In the fust sentence please add "...SPIA groundwater, AOC 41 groundwater. and the three AOCs..."
Please delete the word "annually", we have not decided on the sampling frequency as of yet
Please mention that the landfill portion of AOC 41 will be handles separately (under State solid waste
program?).
Please briefly discuss the sampling results in the same level of detail you do for other AOCs.
Please briefly discuss the sampling results in the same level of detail you do for other AOCs.
9» Comment Response
The MADEP comments received by the Army that
were not addressed pertained to the content and
wording of the Proposed Plan or Fact Sheet When
these were published in January 1996 they were final.
All comments received following their publication were
incorporated, as appropriate, into the ROD.
The desired change was made.
The following text was added to the end of this
paragraph "The landfill portion of AOC 41 will be
addressed under a separate action."
The indicated text was deleted
The indicated text was deleted.
The indicated text was deleted
They will be included in the Final ROD.
The desired changes was made.
The indicated text was deleted
The following text was added to the end of this
paragraph "The landfill portion of AOC 41 will be
addressed under a separate action."
This will be included in the Final ROD.
This will be included in the Final ROD.
 U:\PP A ROD\DELrVER\SPIA\FINALROD\COMRES22.DOC
                                                                                                                      June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groundwatcr and AOCi 25.26, & 27
Paeep-16
1. OridM
2. ' : DOCIUBI
3.' IhHcCi
4« HCVMWCv
** :
USEPA-New
England
M«y H. 1996
USEPA-New
England
May 14. 1996
USEPA-Ncw
England
May U. 1996
r\HM#WatlTMl
LmcMlcr.MA
May 29. 1996
Conaervatkm
Comioion;
Lancaster, MA
May 29. 1996
Conservation
CMnUftinn
Lmcaricr.MA
M«/M IOO*


ConacrvatioR
Coniiuinn,
1 fttffrtfr MA
Mav29 1996


Comervatkm
Comiitton,
I MtnaialtM- MA
tJ*v ^O IQQf*

(tafOrti
NrtTNIe:
iaa*e»tll
& . :, •
P^
A
D
E
den

OCT.
Gen.



Geu




Ocn.


MtaaMMK
DnAFta
t^rfrrfi
«. ,:
UM



















•IRM«t4«<

7.



















rP«cUleBli»rth«a^.M^Are«»«f
•CMMIlt
aCMMCHt
OnP*fcl,lhisiiwprfiouUbehr|erMdcleMcrindeua. H it difficuh to read M presented There
rfrauM abo be • imps of AOC 4 1 itmite to the ones you have for Ae other AOCi (uncling and
nMmtorin(locatiom,R*uHs,etc.) On P«fe 1. Ihii map itiouM be Itfger md dever in deUil. Ifi
dUUCUM to fCAfl M pKMnWQ.
neMeaddthepaMkmeet»xtr»mcri|Mandre»pomvene0iii^^
IVrcafe a lumber of AOC 41 UMenniawitm the Appendix. Pleaae inert the appropriate AOC 41
remit* tablet (groiMdwatcr. aoib, COPCt. riak. etc.).

and will «• octoctad wnl ocrofB it cmM (ravd on poo** fcfvoiaBi ov new wcU ocwlopfnanl M
WewouldtacetoluvmatwhalixnnlacleinHipwaaMrwifihuled.
We alio requect that • report offindingi be provided on an arnual batbandthatilbefubfntttedtolhe
at the Town Library. Tfonp
-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page D- 17
1. ; Originating Organization of Document t U.S. Army Environmental Center . . . .
2. :;«:DoeumentTKle: Draft FlnmlRecort of DeetolonfortheSouth Port ^
3. ; . Dale Comment* Required: Response document .....'.... '••.,•': • • . .. •• . •. -.-.
4« Reviewed , ' •' •
by • . . -,: •
Conservation
Comission,
Lancaster, MA
May 29. 1996
• 5. .. .••;
P«fe
Gen.
«.-:: ,•
Line

7.
SectkNi

8, dMnineiii'
We respectfully request that the Town be kept informed of proposed actions for the cleanup of dumps
and landfills, as welt at groundwater monitoring.
9«.Comnient Reaponc . • ; - . • •-• ^ - .
The Army agrees the Conservation Commission as
well as the Board of Health, Planning Board, Board of
Selectmen, and Town Library will be added to the
distribution list if not already listed.
FINAL ROD SPIA and AOC 41 Groundwater and AOCi 2Sjj J6. and 27 • May 30, 1996
USEPA-New
England
June II. 1996
USEPA-New
England
June 11, 1996
USEPA-New
England
June 1 1. 1996
USEPA-New
England
June 11. 1096
USEPA-New
England
June 11, 1996
USEPA-New
England
June 11, 1996
USEPA-New
England
June II, 1996
USEPA-New
England
June 11, 1996
USEPA-New
England
June 11, 1996
USEPA-New
England
June 11, 1996
USEPA-New
England
June 11, 1996
Decl.
PfrJ
ES-2
ES-3
ES-3
1
4
3
17
18
18
18











Lad
Pan.



2
Commu
nity
Particip
ation
Sect IV,
last toll
line
Sect
VIII,
lit tent
Last
•ra..
2nd line
Last
para.,
4th line
Last
para.,
7th line
Suggested change: "Should the Army close of transfer or change the use of this property an EBS will be
conducted, and the "no action" decision in this ROD will be re-examined in light of the changed use and
risk factors resulting from this closure/transfer.
Suggested change: Risk assessment refers only to EOD, Zulu, and Hotel Ranges. Please discuss the
AOC 41 risk assessment briefly.
Suggestd change: If on-cite hazardous substances, pollutants or contaminants that may present an
imminent and substantial endangerment to the public health and welfare..". This statement should also
appear in the body of the ROD, in "Descriprtion of the No action Alternatives" Section.
Suggested change: If the Army closes or transfers or changes the use of the property, an EBS will be
conducted, and the "no action" decision of this ROD will be re-examined
Please add that the landfill portion of AOC 41 will be handled under s separate action as you have done
in the Executive Summary.
Correction: A typo - public meetings
Change: "additional assessments may be required" to additional assessments will be required"
Please add "...and AOC 41 groundwater"
Please add: "...an assessment is made as to whether the implemented no action alternative remains
protective"
Please change to: "If on-site hazardous substances, pollutants or contaminants that may present an
immenent and substantial endangerment to public health and welfare..".
Please change to:"If the Army closes or transfers or changes the use of the property, an EBS will be
conducted, and the "no action" decision of this ROD will be re-examined."
Suggested change was made.
Additional text was added.
Suggested change was made.
Suggested change was made.
Suggested text was added.
Correction was made.
Suggested text was added.
Suggested text was added.
Suggested text was added.
Suggested change was made.
Suggested change was made.
 U:\PP & ROD\DELrVER\SPlA\FtNALROD\COMRES22.DOC
                                                                                                                     June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCi 25,26. & 27
Page D -18
1 aTh^^aWAAaWd f\mi • •••!• ail n • .^AT TaW.*^^^a^^a4> * II fi Aaj^aatw FaMfgVwtaBMftAa^^J ^"*— — •*-- — •
i. uncimiiitK UTPHDZBHOII 01 uvcvncw* i u*ot A*V^ cjTvwvnniciirai i^cmr . - ,••••:.• •••..-,.. -...•.-. -
2. Datamini Title; Draft Final Record «f Dedalasi for the South Poet Impart Ann tut AIM of ContaanmartMl 41 Crwdwater. and Areas of Casrtamfaiatton 15. 16. and 27

4* Reviewed
^^ .,;-
USEPA-New
England
Jwiell.1996
USEPArNew
England
June 11, 1996
USEPA-New
EnflaVM
June 11, 1996
MADEP
JUM 14. 1996
MADEP
June 14. 1996
MADEP
June 14, 1996
MADEP
June 14. 1996
MADEP
June 14. 1996
MADEP
June 14. 1996
MADEP
June 14, 1996
MADEP
June 14. 1996
MADEP
June 14. 1996
S.
p*fe
24
25
App.
A
ES-2
ES
ES
ES
1
5
5
16
16
6.
Lfcte
4











7.

Irt
P«-.
last
•eat

4



4
1
3

5
•* CejMMeiH • . . : . *
P1*Mc add: "...an iiMwmnl '» made whether the no action tHcniativc icmaim protective of human...'*
It it not ayyimiiiaU to apeak of a "no action" dedtion «« "uring puiuanu* eolutiona to the maximum
extent practicable." Pleaae delete thbatntence, and etate that "no action if neccatary to enaure
protection of human hfaHn and me envvonment.
PkMe add mtpa of AOC 41 eimlartolhe one* yon have for the other AOCa (lamplint A monitorinc
location, rewht. etc.) On page A-l 1 - pletM improve the quality of do* map, ft i* difficult to interpret
The MADEP ncommendi mat the description of the remedy mdude the fellowMC: A preclusion of
Add AOC 41 to the mt ofriMi where tromdwater moMtorinf wM be conducted The fe* paragraph of
the remedial deacription notes that monitornf wiH be conducted at EOD. Zufa and Hold Rango. AOC
j« J|jM|l|| IM •fvliHfaHl In lhi4 ^artjdnt Cf IViiaiiiMiitBiuifi (if SiMiiftii A f^tiMiflCi amiiijljj nn iwnviiijHM

The M ADEP requertt mat me remedial aeMription note tint the rite* wffl be Mbjected annual reviewi

Any change of me will require turner aaMament action. AlthM^i this it mertMned in Section IV of
lh»doc«ment.katoii)dbelidHMacoiqMiMrtofdieren)edy.
Pleaw refine the dMcriptmi of the ami to bt covered by the ROD. Tlie detcriptian currently preacnted
define* the entire SPIA and not the ROD coverage MM noted in the executrv* ammary. Additionally.
PkaM deldc ntereoce* to any Feasibility Study (FS) havnf been conducted for the ROD Mte& The
conducted for the sHes. An Initial Screoung of Aheroativei for Functional Area* 1 and II wu published
• June 1994. but preacnted no akenMtmt wen praentod lor the South PoU
Co»linu«dtiie of lh» area dec« not appear to A>any*inc to am«lioraleecolcCOMRES22.DOC
                                                                                                               June 18. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page D - 19
1. Orif bnttnc Organization of Document : U.S. Army Environmental Center . . :?;.-.. ;:- : : :.;,;••;• .:•,.:•:..,.;..-. •••:•. • ••• . .•:
2. Document Title: Draft Final Record of DccfakMi for the South Post Impact Area and Area of Contamination 41 Groundwater, and Areas of Contamination 25, 26, and 27 •..••• : ••..•:•
3. • Date Comment! Required: Response document •••• : : : .
4. Reviewed .: .
**. '•.'•••-'&:
MADEP
June 14, 1996
MADEP
June 14. 1996
MADEP
June 14. 1996
MADEP
June 14. 1996
MADEP
June 14. 1996
5. •.-.•;
P«t*
17
17
18
25
25
6. .
Une





7.
SectkMi
1
5
1
1
'
8. CTofnfneni
Please correct the paragraph describing conduct of toxicology testa on AOC 27 surface water. A review
of the RI indicates that the toxicology tests were conducted on AOC 26.
Please describe the Army's plan for future explosive ordnance disposal.
See Comment 01.
Please describe how the remedial alternative would 'use permanent solutions to the maximum extent
possible". The MADEP is of the opinion that the lack of source identification and control inherent in the
no-action alternative is a temporary solution.
See Comment 03.
9. Comment Response :
The toxicity testing did take place at AOC 26. This
paragrapgh referes to the results of that testing for
comparison purposes.
No UXO disposal activities are occuring at this time.
The text was modified.
The text was modified.
The text was modified.
 U:\PP & ROD\DEL1VER\SPIA\FINALROD\COMRES22.DOC
                                                                                                                   June 18. 1996

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                 DORIS O. WONG ASSOCIATES, INC.
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                    CASE TRANSCRIPT MANAGER

                        UNITED STATES ARMY
                    BRAG ENVIROMENTAL OFFICE
                    In Coordination  With  The
      UNITED  STATES  ENVIRONMENTAL PROTECTION AGENCY
BEFORE:    James  C. Chambers, BRAC Environmental  Coordinator,  U.S.
Army

PRESENT:   Hussein Aldis,  Ecology  and Environmental,  Inc.;  James P.
Byrne,  U.S. Environmental  Proctection Agency
                                                                 To Be.
Deponent/Witness                 Taken      Delv'd   Prig to    Signed
                                                                 Y or N

Public Hearing                   2/21/96    3/05/96  Devo       N/A
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  (N
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                                  P.

  2    SPEAKERS:                       Page

  3    James  C.  Chambers                 3

  4  '  Hussein Aldis                      4

  5    James  P.  Byrne                    44

  6    Lynne  Welsh                       47

  7    Sheila McCartney                 65

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                   DORIS 0. WONG  ASSOCIATES

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                     PROCEEDINGS



         CHAIRMAN  CHAMBERS:  We're  going  to  get



started.  Welcome  everybody.  This  is  a Public



Hearing on the Proposed  Plan for  the South Post



Impact Area.  My name  is James C. Chambers;  I'm  the



BRAC Environmental Coordinator here for the  U.S.



Army at Fort Devens.   This evening we're meeting



here; my offices are upstairs.  This is now  space



operated by the Massachusetts Government Land Bank,



so we thank them for providing us the  space  for this



evening's meeting.



         Tonight we're going to have Mr. Hussein



Aldis from Ecology and Environment who is a



consultant with the Army Environmental Center out of



Aberdeen,  Maryland.  He's going to discuss the



studies that were done at South Post and what our



proposed plan is for the actions necessary for the



environment down there.  There was a study done, a



remedial investigation done of the South Post Impact



Area and how it affects the groundwater, and that's



what he'll be discussing tonight.



         Now,  he's going to give his presentation.



You've welcome to ask questions at any time,  but I



must remind you that this is a public hearing.  I
                   DORIS 0. WONG ASSOCIATES

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would ask everybody  who's  in  attendance  to  sign  the



attendance sheet,  because  this  is  a matter  of public



record, so we want to  know who  is  at  the meeting



this evening.   If  you  choose  to  speak, please



announce your name and what town or organization you



are from.



         So I'll start by  asking if there are any



questions right now  before we start the



presentation.



         I would also  like to thank you all for



coming out tonight.  I know the weather is quite



horrible out there,  we've  had a number of public



meetings, and I must say that this is one of the



more attended ones that we've had.  So I do thank



you all for coming out this evening.



         MR.  CHRISTOPH:  Actually, we came to check



the water contamination; that's why we're all here.



Never mind.



         CHAIRMAN  CHAMBERS:  Mr. Hussein Aldis from



Ecology and Environment.



         MR.  ALDIS:  First of all, I would like to



explain that  all of  this material which I am



presenting is taken  directly from the remedial



investigation reports  that are available in the
                   DORIS O. WONG ASSOCIATES

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 l   public  repositories  in  various  towns  or  in  the  area,



 2   so you  can  check  the  details  in.those  remedial



 3   investigation  reports.  All of  the material  that  I'm



 4   presenting  tonight is also displayed  on  the  boards



 5   at the  back of  the room.  These  will  remain  here  and



 6   will be available from  the BRAC  office.



 7            If you find  that I am  going  too fast,  by



 8   all means,  stop me.   But of course in  trying to



 9   explain the results of, say,  three years of work at



10   essentially five different • sites, I am going to be



11   touching on a  large amount of work very lightly,



12   just trying to hit the  highlights and give you  a



13   feeling for the conclusions and  the results and, as



14   a result of the investigation, what it is that  the



15   Army is likely to do  with the South Post area.



16            First of all,  I would like to start off by



17   defining - -



18            MRS. vom EIGEN:  Excuse me,  I have a



19   question.  You said the information was on file in



20   the town library,  and I understand there is no  file



21   at the Lancaster Library, so  that we could check it



22   with regard to the reports that  were done.



23            CHAIRMAN CHAMBERS:   Could you state your



24   name,  please.









                   DORIS 0.  WONG ASSOCIATES

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         MRS. vom EIGEN:   Florence  vom  Eigen  of



Lancaster.



         CHAIRMAN CHAMBERS:  Well,  we do maintain



repositories of information at public libraries, and



Lancaster is one of them.  If this  particular



information is not there,  I'm not aware of that.



         MRS. vom EIGEN:   Well, I was told by



someone that it was not in the Lancaster Library,



and I'll have to check that out.



         MR. LIDSTONE:  Is there some way that



people should refer to this body of documentation



when they talk to the library?  Maybe the librarian



didn't understand what they're looking.   I'm Bob



Lidstone,  Lancaster Conversation Commission.



         CHAIRMAN CHAMBERS:  Some of you know, but



because this is a public hearing,  it's part of the



process that you must announce your name.



         Again,  we make regular distributions to the



four towns:   Ayer,  Harvard, Shirley and Lancaster,



as well as the Davis Library here on Post.   And



there's an administrative  record maintained in the



Town Hall  in Ayer.   So what they should do is ask



for --we  refer to it as the "information



repository."  And we make  a periodic notification in
                   DORIS 0. WONG ASSOCIATES

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the newspapers  of what: documents  are  available  at



the repositories, as well as we do  a  mass  mailing  to



a certain mailing list to announce  that  these



documents are available.



         So I will make a note and  then  check to see



if these documents are there.  But  I  can assure you,



there are volumes of documents relating  to the



environmental restoration at Fort Devens maintained



at the Lancaster Library.



         MRS. vom EIGEN:  It was Mr.  Lidstone who



told me that there weren't any.



         MR. LIDSTONE:  Oh,  yeah?



         MRS. vom EIGEN:  This afternoon.  Sorry, I



didn't recognize you.



         MR. ALDIS:   I would like to  explain the



limitations of what I'm going to talk about tonight,



because we didn't investigate the entire South



Post.   What we did was, we investigated those sites



that had been identified, as a result of their



history and use, as being areas of potential



concern;  and they were primarily within what is



known as the South Post Impact Area.



         This diagram shows  part of the South Post.



The boundary of the South Post goes close to or
                   DORIS 0. WONG ASSOCIATES

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                                                    8
along the Nashua River,  as you probably are aware,



and across to the North  Nashua to  the west.  But



this area outlined with  the  red dashed line is



what's known as the South Post Impact Area, and it's



the impact area for weapons  firing  in the South



Post.  They have fired antitank weapons; they have



fired shells from the Main Post across Route 2 into



this area; they have fired bazookas and mortars and



small arms of all kinds.  This has been the area



which has received the impacts of  those weapons.



         The four ranges that we specifically



investigated were, from  the  south  to the north,  the



Explosives Ordnance Disposal, the  EOD range, AOC 25



as it's known, which is  the  area of contamination or



area of concern..  Then the Zulu Ranges on the west



side of the impact area; one of them is a grenade



range,  and one is a demolitions practice area.   The



Hotel Range is now a small arms firing range,  but it



was formerly used for the disposal of explosives and



munitions.  And Cranberry Pond, right next to Hotel



Range,  it was discovered during the course of the RI



had been used to dispose of  explosives by detonating



them on the surface of the pond when it was frozen



in winter.  So that area was expanded to include
                   DORIS 0. WONG ASSOCIATES

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19




20




21




22




23




24
Cranberry  Pond  as  well  as Hotel Range.



         Other  sites  around  the impact area have



included a  small landfill at SA 12, a burn pit up



here at SA  15,  a small  what  was known as the beer



can landfill at SA 41.  Those have been the subject



of other previous  investigations or even subsequent



investigations  and are  reported separately.



         We looked at the overall impact not only of



the individual  ranges within the South Post Impact



Area but the whole impact area itself.  And I'd like



to explain  that it's  really divided physically into



two portions.   On  the north and west side is Slate



Rock Brook  which receives the groundwater discharge



from the west side of the range -- of the impact



area.  On the other side there is this unnamed



stream, Heron Pond, another unnamed stream leading



to New Cranberry Pond,  that runs through the middle



of the impact area.



         So that,   basically, .the area is divided



into three  sections:  that which drains to Slate



Rock Brook; that which  drains to the unnamed streams



here; and that which drains to the unnamed streams



from the southeast side.  Almost no groundwater



which is generated by rainfall or snow melt on the
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                                                     10
South Post Impact Area  leaves  the  South  Post  without
first discharging to surface water.   The  only
possible  impact area are  a  few  acres  along  the very
southeast side, and this  is not  the impact  area  of
the ranges here but the firing  point  of  the ranges
down here.
         Now, what I'd  like to  do  is  run  briefly
through this slide show,  and I  really will make  it
brief.
          (Whereupon, there was  a slide presentation)
         MR. ALDIS:  I  think most  people  who  are
members of the public around here  have not probably
been on South Post.  It is open  for fishing and for
hunting under certain conditions with certain
permissions and certain times, but most people
probably aren't aware of  what the  South Post  Impact
Area looks like.  Let me  see if  I  can show you
something.
         This is what most people  see, the public, I
mean.   That's the entrance, and  if you're going in
there to hunt or fish with specific permission at
specific times, you're not going to see anything
much else of the South Post Impact Area except by
looking through the fencing that otherwise surrounds
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                                                     11
the site.  It is controlled access.  This  is  the



range control at the main gate.



         I've already discussed the fact that the



area was the target of a large variety of  weapons



over a long period of time.  One of the points that



needs to be made is that its future use will



continue to be military training,  and as far as we



know, the Army is going to retain it for the



foreseeable future.



         The scope of our study was to look at the



overall impact of the SPIA on the groundwater, the



sediments and surface water around it,  as well as



the specific ranges within it.



         This is the same map that I was discussing



at the introduction showing the topography and



drainage.  The blue arrows are the direction of the



groundwater flows,  as far as we can deduce them,



from the wells that we install.



         Some parts of the South Post Impact Area



are quite open;  they are burned off fairly regularly-



to help explode any munitions which didn't explode



on impact.   This is one of the ranges used for



antitank weapons.  The dark shadows in the middle



ground are  some target vehicles that you use for
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                                                     12
mortar and antitank  fire.
         This is  another  area which  is  kept  in  a
mowed and controlled  state;  it's used as a sniper
range
         Other areas are wetlands.  As you saw,
there are streams on either side and  in the middle
of the South Post Impact Area.
         And some parts of it are quite forested.
         This is a beaver pond on Slate Rock Brook.
         One of the things that's rather obvious to
people who visit the South Post is it's really a
nice, natural area, and it's become almost a
wildlife refuge.  The scope of our investigation is
outlined in these slides where we have the writing,
but I don't want to go into it in great detail.  You
can read up on that yourself.
         What we found as a result of the studies
that we had done on the groundwater was that the
major control for groundwater flow is not the
surface topography, which consists of glacial sands
and gravels, but the underlying bedrock.  You may
not be able to see this very well,  but the bedrock
contours show a ridge of phyllite or slate that runs
underneath here, underneath the area colored green,
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                                                     13
which is  the  impact area, and  the groundwater flows



off that  ridge  to  either side  to discharge to the



surface water.



          None of the groundwater that's generated by



the South Post  Impact Area leaves the South Post



without first entering surface water, either this



unnamed stream  or  Slate Rock Brook directly to the



Nashua River, with the sole exception of a very



small area down here on the southeast corner,  as I



mentioned before.



         MR. LIDSTONE:  Question.  Bob Lidstone.



Does that mean  that the significant aquifer that



runs under the Main Post does not get any recharge



from the South  Post or at least from the impact
area - -
         MR. ALDIS:  That's correct.



         MR. LIDSTONE:  -- without going off the



South Post first?



         MR. ALDIS:  That's correct.  The



groundwater that's generated within the South Post



Impact Area enters surface water before it can ever



reach the Main Post.



         MR. LIDSTONE:  But from the surface water,



it doesn't then go down into an aquifer recharge
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                                                     14
without going off  the Post?



         MR. ALDIS:  The Nashua River is a gaining



stream, which means groundwater is discharging  to



the river, not the river to the groundwater, at any



point along its course.  Fortunately, the only  place



that can possibly  happen is where there is a pump



well, and the only instance I know of that is the



McPherson well in  North Post, which is near the



river.  If the McPherson well is pumped at high



volume for a long  period of time,  it did induce some



flow from the Nashua River into the well.



         MR. LIDSTONE:  But the only way for this



water to get into  the aquifer of the Main Post would



be through the river?
         MR. ALDIS:  Through the river,  that is
correct.
         MR. LIDSTONE:  Good.



         MR. ALDIS:  Going backwards again.  The



nature and extent of contamination that we found on



investigation was in the wells that were placed



around the SPIA and within the SPIA; that is, not



specifically at an individual range.  It was very



low levels of explosives, low levels of pesticides,



like DDT and its derivatives primarily, which are
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                                                     15
almost certainly  the result of spraying  from

mosquito control,  et cetera.

         There are two places - - let me  show

you -- on the east side.  This well is slightly

contaminated with  explosives.  This well directly

downgradient from  it is completely clean.  This well

is slightly contaminated with explosives, and so is

this well.  This  is three out of the 13 wells which

are placed around  the SPIA.  And this well, which is

the only water supply well'on the South Post, has

also been tested and found to be clean.  So these

wells between impacted areas of the South Post where

there are slight levels of explosives in the

groundwater are in fact between them and the

discharge points in the river,  and they're found to

be clean.

         We have found some slight traces of

explosives getting into surface water and sediment,

and I'll cover that later.
                     %
         DR.  CRAMER:   Dr.  Cramer,  David Cramer.   I

have a question.  Contaminated with explosives?

         MR.  ALDIS:  Yes.

         DR.  CRAMER:   Excuse my ignorance.   What's

an "explosive"?
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                                                     16
 1            MR. ALDIS:   They're usually oxygen  and



 2   nitrogen organic  compounds.  They contain  their  own



 3   oxygen, and, consequently, when they react



 4   violently, the explosive basically decomposes very



 5   rapidly burning the oxygen within the molecule of



 6   the explosive.  It's  the rapidity of reaction which



 7   distinguishes them from other compounds.



 8            DR. CRAMER:  So what's left over?



 9            MR. ALDIS:   Nitrous oxide,  carbon dioxide,



10   oxygen; just simple molecules usually.   What we have



11   found is actual molecules of the explosive,  HRX,



12   RDX, these are fairly complex molecules, with



13   nitrate groups attached, which provide the oxygen



14   result which causes them to be reactive.  They're



15   relatively unstable;  that's their distinguishing



16   mark.   They could be  set off by other explosives or



17   by simple heat or friction or impact.



18            DR. CRAMER:  Okay.  Now,  when you say that



19   one well is contaminated -- two wells are



20   contaminated with the explosives,  so these are



21   unspent chemical compounds that are  in there?  Let's



22   say, for example,  stuff that's leached out of shells



23   or compounds that have not exploded,  not reacted; is



24   that what I hear you saying?
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         MR. ALDIS:  That's  the  assumption,  that



these were explosives that were  in  part  of  the



munitions, and they just didn't  react  at  the  time



that they were fired.  Either  they  never  exploded at



all, or they were not completely destroyed  in the



explosion.  We are talking about micrograms per



liter; that's parts per billion, low-level  parts per



billion.  Nothing more than  6  parts per billion of



any explosive was found in any groundwater  well.



         DR. CRAMER:  Okay.  So you could drink that



water, and you wouldn't get  sick?



         MR. ALDIS:  Oh,  yes.  The  fact is  that not



a great deal is known about  the long-term medical or



health impacts of drinking water contaminated with



explosives,  because there's very little data on it.



But as far as risks are concerned,   they're  extremely



low, even if they were being drawn.



         DR. CRAMER:  The next question for my own



education.   You have wells in  that  area, and certain



wells are contaminated with  low volumes --  low



concentrations of the pollutants, or whatever you



want to call it.   Now,  how come the other wells in



the same area are not contaminated?  My concept is



that there's like an underground aquifer and the
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                                                     18
wells all  tap  into  the  same  aquifer.   This  is  where



my education leaves  me.  And if one well  is



contaminated,  aren't they  drawing  from the  same



underground lake  or  river  or aquifer?



         MR. ALOIS:   What  I  would  say  about



groundwater is that  it's all generated by rainfall



and snow melt, that  it  sinks into  the  ground.  It



initiates  from the point where the rainfall and the



snow melts start.  And  it  depends  entirely on



whether the soils, which have rain and  snow melt,



passing through have been  contaminated.



         Now,  the impact area has  been  subject to a



large number of explosions,  but very erratically



distributed.  And clearly, it's a matter of chance



or happenstance if one well  happens to  be directly



downgradient from an explosion that left some



unexploded material  there.



         DR. CRAMER:  So those areas,   those



underground pockets  of water don't necessarily



communicate with each other?



         MR. ALDIS:   They're all interconnected;  but



groundwater flow is  so slow  that it's not turbulent,



so it doesn't mix.   And if you followed the path of



a single drop of rain that fell on the  surface, it
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                                                     19
would go down  to  the  water  table,  and  it would



travel  in a  single-flow  path  that  would not cross



any other until it  reached  surface  water and



discharge.



         So  each  individual area of  the aquifer can



be considered  to  be unmixed,  except  for those parts



of the  aquifer directly  upgradient  of  it.  It's like



a series of  streams that run  side by side but don't



mix.  It's only if you disturb them  in some way.  If



you place a  well  in them and  you pump  the water,



then it will draw water  from  around  it.



         DR. CRAMER:  So would you at  some time



later give me a reading  list?  I'm  interested about



the aquifers and which way  the -- what you just



explained to me --



         MR. CHRISTOPH:  The  flow.



         DR. CRAMER:  The flow, I'd  like to read



about that,   for somebody that's a beginner like me.



         MR. ALOIS:   I think  the best  thing you



could do is  probably  look at  the references in the.



back of the  remedial  investigation reports for the



South Post Impact Area --



         DR. CRAMER:  Okay, thank you.



         MR. ALOIS:   -- as a  start.
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                                                     20
          DR.  CRAMER:   Thank you.



          MR.  ALDIS:   This  is repeating what I just



 said about  the  three  wells being  slightly



 contaminated  with explosives,  and yet there don't



 appear  to be  any explosives leaving the South Post



 in the  groundwater, because at least two wells



 between those that are contaminated and the rivers



 are in  fact themselves uncontaminated.



          There  is one water supply well on South



 Post that's used by troops who exercise there,  and



 it was  analyzed several times,  and it does not



'contain anything above drinking water standards.



          There  are no risks to human health from  the



 groundwater as  a result of existing use,  and because



 the Army is going to  retain the area and no new



 wells will be installed, there cannot be any new



 wells which will have risks.   The existing water



 supply  well will continue  to be evaluated and



 analyzed on a regular basis to make sure that no



 change  occurs which will not be detected.



          MRS. BIRTWELL:  Anne  Birtwell,  Lancaster.



 How deep are  the wells you're  using to  test?



          MR.  ALDIS:   The D-l well is 65 feet;  it's



 quite shallow.
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                                                     21
 1            MRS. BIRTWELL:  That's a drinking  water



 2   well?



 3            MR. ALDIS:  Yes.



 4            MRS. BIRTWELL:  And that's quite shallow.



 5            MR. ALDIS:  This was quite shallow.  There



 6   was no need for them to go deeper to get the volume



 7   of flow that they needed.



 8            MRS. BIRTWELL:  To get water.



 9            MR. ALDIS:  Incidentally, it's almost the



10   same depth as the well which is contaminated



11   directly offgradient of -- no,  I take that back.




12   It's almost the same depth as the contaminated well



13   on the South Post near it, so it's clear that the



14   explosives can reach that depth.



15            MRS. BIRTWELL:  You don't know how far down



16   they go.



17            MR. ALDIS:  They travel in the groundwater,



18   they're dissolving in the groundwater, and it



19   depends on the flow patterns of the groundwater.



20   They're not going to go to any great depth before



21   they resurface at the river, because they discharge



22   to the river.



23            MRS. vom EIGEN:  I have a question about



24   how long has the contaminated well been in use over










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and above the uncontaminated  ones,  so  that  is  there



a pattern of migration  of  the contamination?



         MR. ALDIS:  The drinking water  well I am



not sure of the age of.  I  think it was  1939 or



something similar.  Can anyone  tell me that?   It's



been there a fairly long time.  The monitoring well,



which was found to be contaminated, was  I believe



installed in '93; and you  can tell by looking at the



name of the well.  It's not marked, but  I believe it



was '93, and certainly  it's about that time.  So



this was installed considerably after the drinking



water well.



         MR. CHRISTOPH:  This  is not what you would



really consider a contaminated well, except as it



showed up in the test.



         CHAIRMAN CHAMBERS:   Again, sir,  this is a



public hearing.



         MR. CHRISTOPH:  Eugene Christoph,



Lancaster.



         MR. ALDIS:  What we  call "contaminated" is



a well which has a detectable level of a foreign



substance which is clearly not naturally derived.



And,  as I said, these wells have less than six parts



per billion of detectable explosive in them.  So
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                                                     23
 1   it's at an extremely  low  level.



 2            One of  the factors  that we also  looked  at



 3   on the South Post was,  since the groundwater



 4   discharges to surface water, is the surface water



 5   and the sediment associated  with it also  impacted?



 6   So we did look at the ecological impact,  and some



 7   potential risks  were  identified.  The odd thing  is



 8   that they were not from things which you  would



 9   expect to be from the ranges, lead and zinc,



10   possibly lead, could  come from the ranges.  Lead,



11   zinc and DDT were identified as being potential



12   risks to some aquatic invertebrates; but  these were



13   regarded as being very marginal.  They might have



14   detectable effects, but they were definitely



15   marginal.   In fact, the wildlife was found to be



16   flourishing generally in South Post.



17            MR.  LIDSTONE:  Are aquatic invertebrates



18   more sensitive to lead, zinc and DDT than humans; is



19   that why it's an ecological and not human health



20   risk?



21            MR.  ALOIS:  No.  The reason they're



22   selected is because they are the most widespread and



23   common biological organisms that are used to assess



24   the health of an aquatic system.









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         MR. LIDSTONE:   So  the  lead,  zinc  and  DDT



could be a hazard to human  health  if  someone were  to



drink the water, but nobody is  planning on drinking



the water?



         MR. ALDIS:  No.  This  was an effect in  the



sediments, and as far as humans were  concerned,



there was no significant impact at all from exposure



to sediments.



         MR. LIDSTONE:   Because nobody plans to  eat



the sediment.



         MR. ALDIS:  Well,  not  so much that,  but



even trespassers who splash  through the mud and  in



marshy areas might get some  on  the skin and could



presumably absorb a tiny amount.  This was



considered,  and there was no health effect from
that.
         MR. LIDSTONE:  That's sediment not in the
water itself.



         MR. ALDIS:  That's right.



         In fact, one of the interesting things, was



to see some of the rarer animals you find on South



Post.  This is a beaver lodge along Slate Rock
Brook.
         And this was a Blanding's turtle which was
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found at Zulu Ranges.



         Now, the individual explosives that were



looked at in the Explosive Ordnance Disposal Range,



EOD Range, this is a picture of it taken from the



air looking southeast.  The actual disposal area was



this closed depression which you can see here.  You



may be able to detect faintly a track which runs



around it.  This was the area that explosives were



disposed of by open burning or other detonation.



Three sides have banks of sand around it that



contain the force of any explosion.



         And if you look across the rest of the



South Post Impact Area across to here,  this is the



stream and wetland which divides the SPIA into two.



These are the ranges on the other side,  and the



trees beyond the wetland along the Nashua River.  So



this is looking southeast across the range, just to



give you a feel for it.



         There are no boundaries on the  South Post



Impact Area,  very few fences; this is just an



arbitrary line today drawn around the area where



they disposed of explosives.   We put several wells



in here;  one,  two,  three,  four,  five,  six,  seven,



eight,  nine and ten wells were dotted around the
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area.  Quite a number  of  soil samples were  taken,
bore holes were placed  to  sample the soils, and  in
effect what we found was  almost nothing.
         The groundwater  discharges through the
disposal area and turns to  the east and discharges
to the unnamed stream and  New Cranberry Pond.  The
only well which showed  any  contamination at all  at
the end of the RI was this  one, which had minuscule
amounts -- again talking parts per billion here  --
it had the nearly 7 parts per billion of RDX and
just 1 part per billion of  HRX, which are two
explosives that were disposed of on the site.
         MR.  CHRISTOPH:  The area that you just
described there,  is that perhaps an old course of
the Nashua River?
         MR.  ALDIS:  No.  This is an area of a
glacial delta into a glacial lake,  and the reason
there is this depression in the ground is probably
because a lot of  ice was stranded there,  surrounded
with sand and melted,  and where the ice melted, it
left a depression.
         This shows the effects of  the explosive
disposal and  the  surface;  it blew holes in it,
basically.
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         What we  did  was  we  tried  to  determine  the



depth of bedrock,  to  choose  the  locations  to  put  the



monitoring wells,  since we believed the  bedrock



determined the flow of groundwater, as  it  appeared



to do.  We installed  bore- holes, took surface soil



samples and subsurface soil  samples.  And  we  did



take one surface  water and sediment sample, but it



turned out to be  in an area  that could not possibly



be impacted by the site.



         This gives you an idea of the actual site



itself.   The only  real impact has been the removal



of the natural vegetation to a large extent.



         There were no human health risks  found from



exposure to the soils.  There was no potential for



exposure to the groundwater and therefore no risks.



         And small areas of the soil were obviously



affected,  but they were so small that the ecological



effects  were minimal, and the surface water and



sediment is not affected by this site, period.



         Zulu Range consists of two side-by-side



ranges.   This is  the  spur of a hill seen from the



east;  from an aerial  view looking west towards the



wetlands along Slate  Rock Brook, the forested



wetlands.   There's a  wetland to the north,  a wetland
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to the south.  This  spur  was modified with a berm



and a couple of amphitheaters of sand here, and



there are a couple of positions here, concrete boxes



that you could throw grenades from safely.  This is



the range control.



         Here is Zulu I,  which is the demolition



practice area.  They have a bunker here where they



hide when they're letting off explosives; but



basically, they construct things and then demolish



them to show people how to practice demolitions.



         What we found on investigating this,  we



installed about seven wells, one here,  two, three,  a



pair here at different depths,  and two here.   All



the downgradient wells were contaminated with



explosives.   So the groundwater flow is from the



south to the north.  Here's a SPIA well over here,



and it appears to indicate the flow is going north



to Slate Rock Brook.   But these.wells that monitor



the groundwater on the range are all contaminated on



the north side,  which shows that the groundwater is



contaminated on the range and is discharging to this



wetland on the north side.  The soil effects are
less .
         This is a wetland which receives the flow
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                                                     29
of  contaminated  groundwater.  This  is  a  wetland  on



the south  side which appears to be  less  affected.



         This is a view of the grenade range with



the berm and the two grenade-throwing  positions.



         This is a shot of the mock bridge that  was



erected for demolition as a practice exercise on



Zulu I.  These are just to give you a  feeling of the



nature of  the country.  It's been largely open,  and



of course  there's been disturbance where the



explosives and the construction modifications have



taken place.



         We did a seismic survey to determine the



depths of bedrock and where to put in monitoring



wells.  We took a number of surface soil samples, we



did a number of test pits, and we took a lot of



surface water and sediment samples around the two
ranges
         One well showed manganese slightly
elevated, and this seems to be pretty certainly of



natural .origin.  We found high manganese in a number



of wells around Fort Devens which are clearly not



affected by any site activities.



         The soils have shown some polynuclear



aromatic hydrocarbons,  PAHs,  soot, you might call
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 ic, probably as a  result  of  their  burning  on-site.



 They did dispose of  some  explosives by burning.  One



 soil sample showed Cyclonite  (RDX), as well as DDT



 and its derivatives, and  some TPH, total petroleum



 hydrocarbons, and  toluene.



         MR. BIRTWELL:  Toluene?



         MR. ALOIS:  Yes,  from fuels.  Gasoline



 contains benzene-toluene-xylene, BTX.



         MR. BIRTWELL:  That's highly --



         MR. ALOIS:  Not  highly; we deal with it



 every day.   We breathe it  in every time we gas up
our cars.
         MR. BIRTWELL:  We had toluene and they shut
our plant down.
         MR. ALOIS:  Because of the exposure of the
workers to toluene?
         MR. BIRTWELL:  Air.  We moved it and then



put in a recovery system.



         MR. ALOIS:  However, it's not particularly



toxic in comparison to many other compounds; it just



depends on the concentration.



         We did find some explosives in the soil,



and this was particularly during the RI,  but there



were none we discovered during the SI aside- from
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                                                     31
that slight trace  of Cyclonite.



         There were impacts on  sediments but  not  on



surface water.  There were low  level  hits  of



explosives, particularly  in the northern wetlands;



again, some other  compounds you might  or might not



recognize.  Where  these came from,  it's not clear.



Some of them might be breakdowns of explosives; some



might be originating in phenolic herbicides;  the



trichloroethylene might have come from some solvent,



perhaps used for cleaning something.  But we  have no



reason to suppose that these are widely used  there.



         There were lead  levels in  the sediment that



were above background,  but these did not seem to



come from range activities, and they may be of



natural origin.



         When w.e looked at the risks for that lead,



just to continue with the same thought, the elevated



lead levels in the sediment were tested with  aquatic



organisms,  and they were  found to have no



discernible impact.  So they're not bioavailable,



and they're not toxic to  the aquatic invertebrates



that were living in the sediment.



         The ecosystems around the ranges appear to



be in good shape;  in fact, the turtles may benefit
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 from  the disturbance  of  the  soil  and the  creation  of



 open  sandy areas,  because  they  like  to  bury  their



 eggs  in sand,  even though  they  live  themselves  in



 wetlands.  The wildlife  risks as  a whole  were



 minimal.  There  is no human  health impact  of any



 discernible level,  because the  groundwater is not



 being used a,nd will not  be used as long as the  Army



 has the area.  And the soils levels  are well below



 those that would affect  people  working  on  the ranges



 or visiting the  ranges or  trespassers or  sportsmen.



         Hotel Range,  as I said,  was an impact  area



 for small arms.  Right now they use  it  for machine



 gun firing; but prior to its extensive modification



 and creation for its  present use, it was  the site of



 disposal of explosives by open  burning and open



 detonation.



         The Cranberry Pond, which is right next to



 it --  this is a map showing their relationship.



This is an embankment in the hill with banks of



gravel,  natural banks of gravel surrounding it.



This is used as a  target area for Hotel Range.   And



 formerly at the foot  of these gravels banks there



was an area where  they disposed of explosives by



open burning or open  detonation, but they  also
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                                                     33
 1   apparently  took  explosives  out  onto  the  ice  in



 2   winter in Cranberry Pond and detonated there.  So



 3   once this was discovered during the  course of the



 4   RI, the Army asked us to take sediments  and  surface



 5   water samples within Cranberry  Pond  to investigate



 6   those possible impacts also.



 7            This is a view of  the  southwest corner of



 8   Cranberry Pond.  You can see it's really a lovely



 9   place.



10            North of the range there is a small stream



11   beginning in a wetland.  This area is kept cleared



12   of vegetation, because it's part of  the area over



13   where the machine guns were fired; but you can see



14   the stream which starts in  this wetlands, and this



15   is the point where the groundwater appears to



16   discharge.



17            The range of our investigation is much the



18   same as the others.  We did a seismic survey to try



19   and determine depth of bedrock,  to select locations



20   for installing monitoring wells.  We did do a



21   geophysical survey looking  for scrap metal that had



22   been dumped in Cranberry Pond,  and we found quite a



23   bit,  primarily steel drums.  We did  a large number



24   of borings and took a large number of soil samples









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                                                     34
over the  former  disposal  and burning area.  We



installed  several monitoring wells.  There were



already four  from the  site  investigation.



         MR.  CHRISTOPH:   The drums that you found  in



Cranberry  Pond,  where  are they now?



         MR.  ALDIS:  They are mostly rotted out and



still lying right there.



         MR.  CHRISTOPH:   In the pond?



         MR.  ALDIS:  In the pond.



         DR.  CRAMER:   What's in the drums?



         MR.  ALDIS:  Nothing.



         DR.  CRAMER:   What was in them?



         MR.  ALDIS:  What was in them,  we have no



idea.  I mean, there are several of them that I have



seen photographs of.   I didn't take part in this,



but several photographs are just rotted steel



drums.   Mainly you just have the hoops and a few



bits of rusted metal between them.  I have no idea



how they got  there or  what they contained,  but they



certainly have not had, as you'll see,  an impact on



the pond that we can discern.  We did collect the



surface water and sediment within the pond, and that



was the basis for our  conclusions.



         There were no impacts from metals on the
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                                                     35
 1   groundwater, but all  the wells within the Hotel



 2   Range itself, all of  them have some level of



 3   explosives  in them.



 4            Because of the location of the disposal



 5   area right  at the foot of the steep slope we could



 6   not put any wells upgradient of them within the



 7   range, but  we did have a well here which was part of



 8   the South Post Impact Area well monitoring system,



 9   and this is completely uncontaminated.   So all of



10   these wells in this area are either within or



11   downgradient of the disposal area,  and they did show



12   low levels  of explosives.



13            The same sort of thing,  RDX and HMX,  as we



14   saw elsewhere.  The sediment samples from the bottom



15   of Cranberry Pond did show elevated metals,  but they



16   also had a much higher level of organic carbon than



17   the sediments to which we compared them around the



18   South Post.  There was no contamination in the



19   surface water, and I'll discuss the risk from the



20   sediments in the next slide.



21            The soils themselves had no trace beyond



22   the very lowest levels of any of  the disposal



23   activities.  So evidently significant accumulations



24   of either the fuels that we use for burning or the
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                                                     36
explosives from South Post were not  found  in  the
soil.
         MRS. vom EIGEN:  Florence vom Eigen,
Lancaster.  Could you please explain  the difference



between "sediment" and  "soil."



         MR. ALDIS:  Well, sediment is found



underwater, basically.  And the thing that we found



around the South Post Impact Area is  that most of



the sediments have high organic carbon, they have a



lot of plant material, rotting plant material in



them, leaves and aquatic plants, stems and twigs,



and so on.  These have an impact on the way in which



metals or organics can accumulate in them,  because



organic carbon tends to absorb materials,  and the



difference is simply where they're found.



         MRS. vom EIGEN:  Okay.  Essentially --



         MR. ALDIS:  In the bottoms of ponds or



streams,  they're sediment; elsewhere they're soils.



         MRS. vom EIGEN:  Thanks.



         MR. ALDIS:  The human, health risk was found



to be negligible as far as the soils were



concerned.  The groundwater exposure doesn't exist



and will  not exist as long as the Army retains the



base.
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         The ecological risks were found  to be



possible, certainly several of the metals were high



enough and certainly one sediment sample  from



Cranberry Pond.  They weren't uniformly high,.and



there was 4 -amino-2,6 -dinitrotoluene, which I think



is a derivative from explosives,  which was found in



the sediment.  The only metal that was found to be



of concern in the sediment was the copper was high



enough it might have some effect on mallards,



although we did find mallards nesting around



Cranberry Pond.



         And this is a clutch of mallard eggs



photographed by the biologist.



         The whole point around our investigation



was we spent a great deal of time,  effort and money;



and we did a very intensive investigation of the



entire area,  particularly the ranges, and the levels



of contamination that we found were very slight.



Particularly the explosives, which were disposed of



and have been disposed of and are being used t-here



in large quantities,  we found minuscule amounts of



them in the groundwater, in the soils, in the



sediment.  And certainly they do not  appear to have



a significant impact,  they can't  have on human
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                                                     38
health at present usage.  They don't appear  to have



a significant impact on  the wildlife.  Some  other



slight impacts were noted, but on the whole  the



ecological situation in  South Post is excellent, and



the wildlife are flourishing.



         MR. LIDSTONE:   The Cranberry Pond made me



think, because of a finding of drums in there, that



opens up the point that  we don't know what it was



that was in those drums.  But were there tests done



of a wide range of potential contaminants, or were



tests only done for the  things that we were



expecting, like explosives and heavy metals?



         MR. ALOIS:  A wide range of analyses were



done.  And you see that  we took -- these were taken



during the site investigation; the other samples



were taken during the RI.  We did both surface water



and sediment samples.  Considering the area of the



pond, which is only 12 acres,  we took a f.airly



intensive series of samples there.  And this sample



showed high levels of metals,  and that was basically
it.
         MR. LIDSTONE:  But you tested for a wide
                                    •5
range of potential contaminants?



         MR. ALDIS:  We did, yes, we did.
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         MR. LIDSTONE:   Good.



         MR. ALDIS:  The wells, as you see,  the



groundwater enters  the pond  from the south and exits



from the north;  it's basically an outcrop of  the



water table, you might say.  It's another kettle



pond; that is to say, it's the result of a block of



ice being stranded  there and then melting.  And this



is in effect an  outcrop  of the water table.   This



flows out on the west side and discharges through



Hotel Range, so  these wells are in fact measuring



the water quality coming out of Cranberry Pond.



         They're also measuring the water quality of



the groundwater which is affected by the soils in



the area of the disposal.  And yes,  they do show.



contamination.   But most of it is discharging to



this wetland and stream  north of here,  and whatever



is not is going to  end up in Slate Rock Pond.  So



all of it is going  to enter the surface water before



it exits South Post.



         MR. LIDSTONE:    And that stream flows into



Slate Rock Pond also.



         MR. ALDIS:  This also flows into Slate Rock



Brook and then to Slate  Rock Pond.   And as I  said,



the biological  surveys  that we did seem to suggest
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                                                     40
that the ecology in South Post is flourishing.   it's



really a wildlife refuge in many ways.



         MR. CHRISTOPH:  In the report that I have



read -- and I'm in the process of rereading a second



or third time to make sure I can get on top of it --



I keep hearing repeatedly that the Army is going to



stay here,  the Reserves, for the foreseeable



future.



         MR. ALOIS:  Yes



         MR. CHRISTOPH:  I doubt that anybody in the



room, or perhaps in Northern Worcester County, would



have guessed five years ago that Fort Devens would



have been closing,  since at that time the Congress



had voted to enlarge the Intelligence School by



bringing facilities here; and all of a sudden, bang,



we're on the hit list and Main Post and North Post



are vacated.



         Now,  if in fact the Reserves left here in



the next five years,  for whatever reason,



unforeseeable tonight,  obviously,  what shape would



South Post  be in?  For example, Lancaster's



willingness to tap into the big aquifer on South



Post related to the Nashua River,  so that we could



sell that 3 1/2 million gallons a day to Main Post
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                                                     41
for industrial purposes or to Boston, as has been



discussed with the Fish & Wildlife Service.  Could



you enlighten me at all.



         MR. ALDIS:  As far as the groundwater is



concerned, I think I'd be the one to answer that.



The Army may want to respond to other issues.
         MR. CHRISTOPH:  That's what I'm after, your
response.



         MR. ALDIS:  As far as the groundwater is



concerned, as I mentioned in the course of



describing this work, there is not a very good basis



for estimating the toxicity of explosives in



drinking water sources.  Because of the EPA's



methodology in estimating risks, they always tend to



overestimate them, because they take conservative



values at  every stage of the risk investigation.



These levels that have been found in the groundwater



may conceivably have some effect on someone drinking



them for a lifetime; but the issue is,  are these



just the declining residual amounts that are there



as a result of past activities?



         In this case of EOD Range, for example,  it



was very clear during the course of our



investigation the explosives levels in the
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                                                     42
groundwater were  declining.



         MR. CHRISTOPH:  That's good.



         MR. ALDIS:  Yes.   In the case of Hotel



Range, there were  only samples taken twice, and  it's



not clear that they are declining, but they are  at.



such low levels it's extremely unlikely they would



see any human health impact.



         The other issue is, of course, the Army



maintains responsibility for this no matter what



happens to the land in the  future, and I think



really the Army needs to sort of address the issue



of land use.



         MR. CHRISTOPH:  I'm more concerned with



water quality,  because the Army is less predictable



than the water is, I think.



         MR. ALDIS:  None of the water in the South



Post is contaminated to a level that I would think



is significant.  As I said, there may be excedences



of no detectable effect levels as derived from



certain approaches used by the EPA in estimating



risks; but these are very conservative approaches,



and they tend to overestimate risk.



         MR. CHRISTOPH:  I'm glad to hear it's a



conservative approach,  because you mentioned in one
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                                                     43
of the wells there have been  two  tests.  Over how



long a period of time was  that?




         MR. ALOIS:  In the case  of Hotel Range, EPA



took the samples during the SI, and we took samples



during the RI,  and I think they were separated by



about a year and a half.



         MR. CHRISTOPH:  In your  customary area of



expertise, would that year and a  half two samplings



be sufficient to give you satisfaction that the



water there is not contaminated?



         MR. ALDIS:  But it is contaminated.  And



it's because very similar levels  were found in both



samplings that we are satisfied that we have a good



understanding of what the levels  are based on.



         MR. CHRISTOPH:  And  they are not



increasing?



         MR. ALDIS:  They're  not  increasing, and



there are no additional sources.  The results that



we found are consistent with  the  historical disposal



of explosives there,  not with the current use.



         MR. CHRISTOPH:  That current use doesn't



concern me; it's the future use at some point in



time when the Department of Defense vacates South



Post.  Now, the foreseeable future, as I said, it
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                                                     44
may be five years,  it may be ten,  it may  be  fifty;



but I'm concerned,  will we be able to market  that



water for drinking  purposes, whenever it  is
vacated?
Byrne.
         MR. ALDIS:  I would refer you  to Mr.
         MR. BYRNE:  My name is from James Byrne
from the EPA Regional Office in Boston.  Basically,



right now the reason we're making this decision to



basically leave things be is because it's under the



current foreseeable future use as we discussed.



When and if the property changes hands, what we



would require under law is that another assessment



take place on the status of the water at that point



in time, whether it be tomorrow or ten years from



now.  And at that time we would look at those



contaminants, and in fact the record of



contaminants.



         I'm kind of jumping the gun here,  but part



of this record of decision we.'re signing here is to



sign a long-term monitoring plan to measure those



contaminants from the Army explosives ordnance



disposal.   What we plan to do is look at that data



and make sure,  number one,  it is staying on South
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                                                     45
Post.   If  it were to migrate  off  Post  during  the



next  five  years, say, when  the Army  still owns  the



land, the  Army again would  be obligated  to do



something  about that.



         So there were basically  two trigger points



here.   Point one, for the foreseeable  future the



Army  is using the land, and we're instituting a type



of long-term groundwater monitoring plan to take a



look  at this to make sure that none of these



contaminants migrate off Post and cause any harm in



the drinking water supplies.



         Point two would be if sometime in the near



future  the Army leaves this area, and  the property



is going to be transferred or sent to  another agency



or back into private hands.  We would  take a look at



that  library of groundwater data, we would take a



look  at groundwater data at the current situation



and make an assessment at that point as to whether



this  water is safe for Lancaster, for  instance,  to



tap into and start marketing,  or is additional



clean-up or something needed before you could



undertake that activity.



         MR. CHRISTOPH:  Okay.  You can understand



my concern.
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                                                     46
         MR. BYRNE:   Yes,  I  can.



         MR. CHRISTOPH:  With decreasing



availability of  good  water,  especially  in  this area,



our understanding, at  least  verbally, is that it is



the Fish & Wildlife Service  on a federal basis who



would probably be assuming the property.   It is



obviously to our advantage and interest to ascertain



that enough will be done in  the way of monitoring to



make sure that we do  have in fact a marketable
source.
         MR. BYRNE:  What we would do is similar to
what we did now.  We would look at the situation at



the point, what you people intend or something like



that, and run these risk numbers, exposure numbers



based on the contamination we see.  And what would



come out of that is, in a sense, a yes, go ahead and



use it with no problem; or a maybe, let's hold on,



this water might need some additional treatment



before you can use it; or worst case, no, forget
about it.
         MR. CHRISTOPH:  Well, if worst case ever
                            •>
occurred,  who do we sue?



         MR. BYRNE:  The Army would come back;



they'd be  obligated to do something.  The worst case
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                                                     47
is  if  the  Federal  Government  goes  broke.



         MR. CHRISTOPH:   You  wouldn't  sue.



         DR. CRAMER:   Two questions.   Actually,



three  questions.   Number  one,  if,  let's say,  the



water  is to be sold  today to  Boston  or tomorrow,




given  the  information  you have, would  they buy  it?



Could  they drink it?




         MR. BYRNE:  That's a  tough  question,



because we really  didn't  look  at that.  Basically,



we'd have  to look  at that  scenario.  That's one we



did not look at.



         MS. WELSH:  I can answer  that question.



Lynne Welsh from the Massachusetts Department of



Environmental Protection.  I've worked with Jim and



Jim on evaluating  the  results  of testing that



they've done.  We're three different agencies; we



have three slightly different  ways of evaluating the



data that  came in.



         We have concurred with the  EPA and the Army



that,  for  right now, this  is  the best way to handle



the situation at Fort  Devens.  A lot of study has



been done,  but because the activities are going to



continue on at the Post,  they're going to somehow



slightly alter the results that we have from today
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                                                     48
 1   to year one and year two on out.  And  the Army  is



 2   going to be here, and they have to have training



 3   facilities.  But we did some calculations of our own



 4   on the water -- the risk from the contamination



 5   levels at the worst case that the Army found in



 6   their investigations and found that they did exceed



 7   our l-in-100,000 cancer risk factors.



 8            So to answer your question, yes.  But also



 9   the good news is, you can treat this water, these



10   chemicals can be treated.  So that if you did need



11   to use the water today,  which is not likely and is



12   not going to happen, you could treat it to make it



13   safe.



14            MR. LIDSTONE:   I think I'm missing



15   something here.  There are no suggestions that



16   there's a substantial aquifer that this water is



17   involved with,  correct?



18            MS. WELSH:  No, there are.



19            MR. LIDSTONE:   We're talking about water on



20   top of slate here.



21            MS. WELSH:  No.



22            MR. LIDSTONE:   This water could contaminate



23   significant aquifers?



24            MR. ALDIS:  May I answer that.  For the
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most part the South  Post  Impact Area has only a  thin



and not very productive aquifer, but there is a



fairly productive aquifer under the Nashua River,



and part of this is  under the eastern margin and on



the northern side of the South Post Impact Area.  So



there's a similar --.



         MR. LIDSTONE:  So while the contamination



would likely get into this aquifer through the



river --or could'it get in there -- I guess my



question is, can the aquifer be contaminated without



this water leaving the South Post?



         MR. ALDIS:   The answer to that is an



aquifer that could be usable and is used in the



South Post water point well could be impacted by



some of the water off the South Post Impact Area,



yes .



         MR. LIDSTONE:  So there is some significant



aquifer that is at risk.



         MS. WELSH:   There is glacial  outwash sand



and gravel,  what we  call an aquifer,  running through



the South Post,  and  it does have samples indicating



contamination.   One  of the things that  we have



worked on with the EPA,  and we're discussing with



the Army,  is to tighten up the monitoring that's
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going on, so that we have assurances  that  that



contamination is not moving off Post  and is  not



going to impact either private wells  in the  area, or



we have other wells besides Fort Devens, we  have



MCI-Shirley that is a significant water supply for



this area.  So that while there is contamination,



the monitoring is going to ensure that it's  not



going to affect people.



         MR. LIDSTONE:  That it could be getting



worse, that it could be spreading.



         MS. WELSH:  That's correct.



         MR. LIDSTONE:  Not to push everyone aside,



but are there,  I guess, some procedures to be



changed,  so that this contamination would be reduced



in the future compared to what's happened so far, or



should we expect this aquifer to remain contaminated



for the foreseeable future and we'll simply have to



watch it closely as it spreads?



         MS. WELSH:  That is what we hope long-term



monit.oring will tell us.   There is contamination



because of training, but  there's also, we think,



contamination because of  concentrated disposal in



the areas that  Hussein identified for you.   And we



have asked and  are working with the Army to change
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those concentrated disposal activities so that  they



are more environmentally  -- happen in a more




environmentally sound way and those are concentrated



areas of emissions disposal.  And the Army staff  --



and Jim should speak to this - - is looking at the



way they do training, so that it has less



environmental impact than past activities.  So  this



long-term monitoring plan, again with Army




procedures and with the change of the concentrated



munitions disposal, hopefully doesn't make the



matter worse.



         MR. LIDSTONE:  And those procedural changes



will be documented in the near future?



         MS. WELSH:  They will be in some cases.



         CHAIRMAN CHAMBERS:   I'm not sure I



understand "procedural changes."



         MR. LIDSTONE:  In the disposal of



munitions.   Since there appears to have been some



contamination from past practices,  will there be any



attempt to change .future practices so that we reduce



the contamination going into the aquifers?



         CHAIRMAN CHAMBERS:   Okay.   Well,  first of



all,  yes,  past practices is  that there were disposal



of munitions.  Current practice is there is only
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disposal  in  the  event  of  an  emergency  or  something.



Typically, waste munitions are not  disposed  of.



          MR.  LIDSTONE:  Oh,  is that  right?   That's a



big change.   I have  to  admit, I haven't heard  any



bangs lately.



          CHAIRMAN CHAMBERS:  Another thing to  be



aware of  is  that  there  has been a change  of  activity



on the South  Post.   It  continues to be a  training



area and  will continue  to be a training area,  but we



don't have the same  type  of military units training



there.  So that  a majority of the type of training



that involves munitions is small arms training now,



rifles and handgun-type training, not so much  of



explosive munitions.



          MR.  LIDSTONE:  Less total explosives  to be



disposed  of?



          CHAIRMAN CHAMBERS:  Yes.  The other thing



is, you said  spreading.  There is no evidence  of



this spreading.   That's one of the reasons that



we're proposing  the  groundwater .monitoring,   to



ensure that there  is no spreading.   But if that had



been the  case --  and that will probably be not what



we would be proposing -- there will probably be some



more proactive action being taken.
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         In answer  as  far  as  future  use  of  the



water, I can't  really  speak to  that.  But I can say,



from my experience,  that the  locating of the wells,



we're talking about  the impact  area  here, and where



the location of the  well is,  whoever does that type



of hydrogeological  study that needs  to be done to



locate a well probably would  have to take into



account Massachusetts  regulations as far as where to



locate it -- not probably  but we'd certainly have



to - - and where.  They would  seek the point where



they could get  the most production out of that well



but would have  to be at a  certain distance away and



probably would  be minimally impacted by the activity



that's here.



         DR. CRAMER:  Question  i-B.  Or A,  because



you made a statement.  You say  the water as is can



be made fit to  drink.  In  Pennsylvania I had a home



with a water purification  system, supposedly we



didn't need it, but  for the money I spent,  it was



peace of mind.  So basically,  it was an activated



charcoal system for  organics and halogens,  and then



there was a three-way system  for heavy metals and a



polishing filter and stuff for  bacteria,  whatever.



So I can relate to that.   But on a commercial basis,
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                                                     54
how does that water  -- let's say, for example,



you've got organic pollutants, for lack  of  a  better



word.  How does that get taken care of?



         MS. WELSH:  Lynne Welsh from the



Massachusetts DEP.  The same things you  did on  your



individual home, activated carbon; there's  also air



stripping, because these are volatile compounds,



which can be done on a commercial basis.  In  fact,



several towns also already do that.   Acton, for one,



has - -



         DR. CRAMER:  Really.



         MS. WELSH:  They have air strippers  on



their water supply, because there has been past



contamination.  I'm sorry,  I can't speak to the  cost



of that,  but they are available commercially.



         The statement I was trying  to make is  that



these chemicals, while they are explosive and



exotic,  have chemical reactions that can be dealt



with under present technology.



         DR. CRAMER:  Okay.



         MR. ALOIS:  May I  point  out that these



compounds also naturally biodegrade  as a result  of



bacterial action in the groundwater  and in surface



water.
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                                                     55
         DR.  CRAMER:   Question  number  two.



Fantasyland.   I'm  President  of  the  United



States  -- okay, we're  all  laughing,  okay  --  and  I



say to  you folks,  "I'm the boss,  executive order,



clean it up.   I don't  want to take  anything  -- I



won't take no  for  an answer, just do it."  Okay.



What do you do to  change it?  What  are  the



alternatives  to leaving this the way it is?  What's



the opposite?



         CHAIRMAN  CHAMBERS:  Well,  first of  all,



then,  as the  - -



         DR.  CRAMER:   I'm not running, by the way.



         CHAIRMAN  CHAMBERS:  - - as  I guess the



supreme commander, he  would have to say he's not



going to have military training here any longer,



because in order for there not  to be this problem,



we would not be able to use the ranges at all down
there.
         Now, once that happened, then if that were
to happen, then we would go through it.  We would



probably have a good sense of history here, with all



the studies that we've done so far, but now we would



have to go into a process that we call a remediation



investigation feasibility study.  The intent of that
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                                                     56
is to look at the technology  that's available  and



see how it may be applied  to  the situation  that we
have.
         So that if it  involves monitoring, if it
involves air stripping, we will evaluate all those



alternatives.  We would look to evaluating a variety



of things, cost being one of them, and not a primary



but a parameter to evaluate.  We would evaluate risk



to human health, risk to ecology,  community



acceptance.  We would be going through the same



process that we're doing here this evening,



eventually to select a particular remedial action



that would allow us to clean the water, if it was



deemed necessary.



         But it would have to be shown that there is



a certain level of risk, that there is a certain



benefit to having this water available, and then we



would choose a remedy.  And then we would have to



present it to the public and say,  "This is how we've



chosen to clean this up, this is how much we intend



to spend,  this is what the results will be."  And we



would come up with a record of decision then that



the Army would be bound by that record of decision



to implement that action.
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          DR.  CRAMER:   It  would  be  something like



strip-mining  for  coal;  you  just bulldoze  the whole



area and  take  the stuff away?



          CHAIRMAN CHAMBERS:  Hypothetically,  it



would probably  involve  - - if it was  deemed




necessary,  it might  involve a pump-and-treat  system



where we  would  pump  the water out  of  the  ground,



treat it, and then discharge it back  to the ground.



And then  the ground  is  nature's best  filter,  and by



the time  the water was  redrawn  out for  consumption



purposes, it would probably be  tested again,  but it



would prove suitable  for human  consumption.



          MR. CHRISTOPH:  I won't play President, but



I would like to play  Speaker of  the House for a



minute.   How comfortable are you that the EPA budget



will not  be sliced to ribbons so that your  function



will cease  to exist?  Any assurances at all?



          MR. BYRNE:   Call your-  Congressman.



          MS. WELSH:   I  think what you have  are three



agencies, the Army,  the EPA and  the State;  we all



have individual budgets, and we're all working on



this.   If EPA, Jim, were to go  away tomorrow, I



would still be here.  And if the Army were  to go



away tomorrow, we'd still be here.  I mean, we are
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                                                     58
public servants  for  the Commonwealth of



Massachusetts, not the Federal Government  or  the
Army.
         MR. CHRISTOPH:  Gotcha.  And you're  fairly
comfortable?



         MS. WELSH:  I'm fairly comfortable that



Governor Weld is not going to do anything



problematic.



         MR. BIRTWELL:  Again, first of all, let me



preface my remark by saying most of us over the



years from the Spec Pond area have been comfortable



with Fort Devens and hated very much to see them



go.  We test our pond every year.  I have given



copies of that to the Commandant when he was here;



the last one went to a ranger.  Does anybody know



who controls the access to South Post now for



fishing or whatever?



         CHAIRMAN CHAMBERS:  Well,  there's range



control.  We also have the natural  resources



manager; his name is Tom Poole.



         MR. BIRTWELL:  It was this year,  I know,



limited to the Fort Devens personnel.  Prior to that



other people would come in, which is fine, and we



haven't had any problems;  we have handouts on file
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                                                     59
 or whatever..   The  thing  that  kind  of  surprises  me  is



 that South  Post  does border Spec Pond.   Apparently



 no testing  has been done on Spec Pond.




         MR. ALOIS:  The flow  is from  Spectacle  Pond



 to South Post, not the other way around.




         MR. BIRTWELL:   I understand  the aquifer



 goes east to west.



         MR. ALDIS:  The flow  is - -



         MR. BIRTWELL:  We have that little stream



 going through, if  that's what  you mean.



         MR. ALDIS:  Spectacle Pond is an outcrop  of



 the water table, but it overflows as a small steam,



 as you say.  But even so, the  water at Spectacle



 Pond is from rainfall and snow melt right there, and



 the discharge is going away from the pond.



         MRS. BIRTWELL:  And springs.



         MR. ALDIS:  Well,  the springs, of course,



 themselves are generated from  rainfall.



         MR. ALDIS:  Infiltrating through the so'il .
deep.
         MR. BIRTWELL:  You have a well 65 feet
         MR. ALDIS:  The water circulates; depending
on where it falls, it goes deeper or shallower into



the ground.  The point is, though, that South Post
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                                                     60
 1   cannot contaminate Spectacle Pond; Spectacle  Pond



 2   can contaminate South Post.



 3            MR. BIRTWELL:  How about the wells in the



 4   people's homes?  There must be 100 homes in the



 5   general Spec Pond area.



 6            MR. ALDIS:  Only if they pump an enormous



 7   amount of water could they possibly draw anything



 8   out from under the South Post.  The volume of water



 9   that falls on the average acre around here and



10   infiltrates into the ground I think is of the order



11   of 500,000 gallons per acre per year.



12            MR. BIRTWELL:  So what you're saying is,



13   there's absolutely no problem relative to drinking



14   water in the wells surrounding the Spec Pond area.



15            MR. ALDIS:  As for being impacted by South



16   Post,  yes, there is no problem at all.



17            CHAIRMAN CHAMBERS:  Sir.



18            DR. vom EIGEN:  I'm thinking about the list



19   of chemicals and contaminants that you mentioned.



20   It seems to me that there are by-products of



21   explosives, and since they are rapidly oxidized



22   chemicals to cause the explosion, they are also



23   probably oxidized in the soil, maybe at a slower



24   rate,  but they certainly are.









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 I            MR. ALOIS:   They  are  affected by bacterial



 2   decay, yes, they are  acted on  by  organisms.




 3            DR. vom EIGEN:  This  is  completely



 4   different if you have  contamination with lead or



 5   zinc or heavy metal,  right,  they  cannot be



 6   destroyed.




 7            DR. vom EIGEN:  So  I  think any idea of



 8   digging this up or treating  it chemically or



 9   anything else would be  foolish, because it would



10   probably improve itself  in .time,  unless you're going



11   to start shooting a lot  of heavy  stuff in there



12   again.



13            MR. ALOIS:  That's  correct.  The points we



14   investigated with the greatest detail .were all areas



15   which in the past had been used for open burning or



16   open detonation.  Either they bought explosives or



17   munitions there, and they  covered them with wood and



18   saturated them with kerosene or something .similar



19   and set fire to them, or they detonated them, and



20   those were the areas that  were most suspect and the



21   ones that were most intensely evaluated.   The



22   additional work that we  did  around the South Post



23   Impact Area was really because the Army just raised



24   the question that perhaps  the overall impact of










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firing weapons produces a detectable level  of



contamination, not  from concentrated disposal, but



just general  impact areas on the ranges.  And we did



find that  there were detectable levels, but they



were simply not significant.  There is certainly no



smoking gun,  no public health or ecological concern.



         DR.  vom EIGEN:  They would be more likely



to be at the  point  of firing than at the point of



impact of  the bullet or shell.



         MR.  ALDIS:  That I don't know; it depends



if they're explosive shells or just projectiles.



         DR.  vom EIGEN:  I don't think if they used



explosive  shells here, perhaps they did,  or like



bazookas.  But I think that the results I've heard



sound very encouraging that this is going to be a



contained  area with minor contamination and will



improve in time.  But are you going to be able to,



or do you  feel that you should,  retest all these



areas over periods of time,  in a year or two years?



         MR. ALDIS:  That is the intention.



         CHAIRMAN CHAMBERS:   Yes,  sir.   That is what



we've proposed to do,  that we will have a long-term



monitoring plan.  We're going to test these wells.



And I just want to make the point clear that these
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                                                     63
wells are not used  on a  continuing basis,  it's  not




like what we think  of as wells at our home where



we're constantly pumping water out of them.  These



wells pretty much have no activity at all  until we



test them, so the water  that's there, it's not  like



we're cleansing this water by getting fresh water



out of it all the time,  these are wells that are



actually -- we're grabbing samples of what's



actually there at that particular time.



         DR.  vom EIGEN:  Will there be reports put



in these places in  cities and towns that you



described of  these  results when they're done?



         CHAIRMAN CHAMBERS:  Yes, sir.



         DR.  vom EIGEN:  So it will be available,



and if they show improvement, everything goes well.



If they start showing things are getting worse, then



we have to find out why,  I guess.



         CHAIRMAN CHAMBERS:  Any other?



         MR.  JANELL:  John Janell, Lancaster.  You



talked a lot  about  groundwater.   I guess I'm



concerned about what hasn't gotten in.  Has anyone



looked at the landfills?  I know it wasn't that many



years ago we  thought lead paint was safe,  PCBs,



people would  just take transformers and throw them
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                                                     64
away.  Today you have  to drain  out  the  PCBs.   Has



anyone ever looked what's  in  the  landfills?



         CHAIRMAN CHAMBERS:   Yes, sir,  there have



been studies done, that's  another action that  we



plan to take.  Some of the landfills, there's  about



half a dozen landfills or  so  that we've identified



on the South Post.  Most of them are from



homesteaders or people that lived there prior  to the



Army taking over the land.  We  found old farm  dumps,



things like that, where we found the pots and  pans



from whoever lived there were thrown out the back



forty,  and there they are.  But there are a couple



of sites from Army activity as well, and we have



identified those.  The Army is working with US EPA



and the Massachusetts Department of Environmental



Protection right now to develop a plan on what we're



going to do about those landfills, and it could



involve excavating those landfills,  or we're looking



at what other alternatives there are.  But that's



one of  the ones we're considering right now.



         MRS.  vom EIGEN:   Florence vom Eigen,



Spectacle Pond.  I have a couple incidental - type



questions,  I think.   You haven't mentioned deer, and



I've seen deer in the area.  I mean, you allow
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                                                     65
hunters to go into the area.  Have any  studies  been



done on them to know whether they're  contaminated  in



any way, and should and can people who  hunt  take



them home and butcher them and eat them?



         MR. ALDIS:  I think you have to ask someone



else about that, because I'm not familiar with  that,.



         MR. BYRNE:  As part of my former life  I did



some wildlife biology work; basically,  we performed



ecological assessments.  Basically what we did, the



short answer is, no,  we didn't take any deer and cut



them up and analyze their tissues.  What we did is



more or less start at the bottom of the food chain,



stuff deer might be eating.  And what we found



there,  as you have seen mentioned in the summary,



was minimal impacts to the wildlife populations here



at Fort Devens.   I mean,  there are some contaminants



in the soils but not at high enough levels that it



would make it all the way to a deer and perhaps make



a deer unsafe to eat.



         MRS. vom EIGEN:   It's my understanding that



they eat leaves  and twigs.



         MS.  MCCARTNEY:  I'm Sheila McCartney with



the Army Environmental Center.  I'm from Aberdeen,



Maryland,  and our agency works with many
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                                                     66
installations like Fort Devens.  And work has been



done at the Aberdeen and Jefferson Proving Grounds



with the deer, specifically during hunting season.



And we'll have hunters give us some of their deer,



and they've done studies on them at those



installations, which have similar contamination as



South Post here, and they haven't found any risks.



         MS. vom EIGEN:  Another thing that concerns



me is that you think nothing of disposing or



detonating on ice,  which then goes into the water,



and you say you tested the sediment.



         MR. ALOIS:  This was a former practice,



remember.   This was a practice that was discontinued



maybe 20 years ago; I don't know.



         CHAIRMAN CHAMBERS:  I can't  speak to that.



         MR. ALDIS:  The whole point  about these



areas that we investigated was that they were areas



of heavy disposal of explosives and ordnance of



various kinds, and the Army has completely stopped



doing this,  with the solid exception  of emergencies



like,  for example,  a bomb squad wishes to dispose of



something suspicious and things like  that.  The Army



is not  disposing of explosives; they're simply using



them as firing ranges now.
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                                                     67
         MRS.  vom EIGEN:   All  right.   Then are  there



geodetic maps  available  showing  which  way the



aquifers flow  in  this  area,  and  do  those  arrows



indicate surface  water?



         MR. ALDIS:   I tried to  simplify  this to



show you the directions  of  flow, but the  individual



remedial investigation reports show specific



groundwater contours.  Now,  in a sand  and gravel



aquifer, the water  flows  at  right angles  to the



contours, and  we  indicate on our maps  the



groundwater with  arrows  showing  the direction flow



•down the contours;  and you  can have a  look at those



in detail.  I  know  that  this is  true in general.  If



you were to point to any  one particular arrow and



say, What's the basis for the evidence, I would



simply have to say  that  it's higher on the left, and



it's lower on  the right,  and it  flows  from left to
right.
         MRS. vom EIGEN:  That's not the underwater
aquifer that.you're. talking about?



         MR. ALDIS:  No, I'm talking about the



aquifer.   This is groundwater.  All of the



groundwater in South Post definitely goes into the



Nash.ua River or over here into the North Nashua
                   DORIS 0. WONG ASSOCIATES

-------
                                                     68
 1   River.  Now, before  it gets to the Nashua River,



 2   most of it  discharges to smaller streams which



 3   themselves  discharge to the Nashua.  And that we



 4   know as just a matter of physical behavior of water



 5   in  the kind of environment.  There's no question



 6   about it, in my mind.  That's where it goes, it goes



 7   into the surface water on South Post, and that



 8   drains into the Nashua River.



 9            MRS. vom EIGEN:  And Spec Pond is a



10   different entity.



11            MR. ALDIS:  Spec Pond is up here.



12            MRS. vom EIGEN:  And you described that as



13   a different type of water.



14            MR. ALDIS:  No, I'm not saying that, I'm



15   saying that Spectacle Pond is full of water which is



16   generated at and immediately around Spectacle Pond,



17   and it is not coming off South Post,  it is going on



18   to South Post.  As I said, Spectacle Pond could



19   contaminate South Post,  but South Post could not



20   contaminate Spectacle Pond.



21            MRS. vom EIGEN:  I'm thinking of Spectacle



22   Pond wells and wondering if there's an underwater



23   flow direction that's different.



24            MR. ALDIS:  No.  The water around Spectacle










                   DORIS 0.  WONG ASSOCIATES

-------
  1
  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
 13
 14
 15
 16
 17
 18
19
20
21
22
23
.24
                                                     69
 Pond  is  flowing  into  Spectacle  Pond,  so  it's  the




 area  immediately adjacent  to  the pond and  the  pond



 itself which  is  supplying  those wells.



         MRS. vom EIGEN:   My  last question  has  to do



 with  your terminology of  "no  action."  Now, I




 understand from  reading these that the Army is  going



 to recommend  no  action, which puts on hold  --



         MR.  ALDIS:   What  they're doing  is



 recommending  no  clean-up action.  What they are



 recommending  is  continued  monitoring, which is  an



 action,  if you like,  but it's not a clean-up



 action.  It's simply  observation.



         MRS. vom EIGEN:   When you say "no action,"



 it doesn't mean  a  closure  of the whole thing.



         MR.  ALDIS:   It doesn't mean that nothing is



 going to happen  in the future; it means  that only



monitoring,  no clean-up.



         MRS. vom  EIGEN:   My understanding in



perusing the  fact  sheets was that no action might
mean
exactly.
         MR. ALDIS:  Literally that.



         MRS. vom EIGEN:  -- literally that, right,
         MR. ALDIS:  That is a little misleading,
                   DORIS  0.  WONG  ASSOCIATES

-------
 1
 2
 3
 4
 5
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
                                                     70
but what it means  is  that no  clean-up action  will be



taken, just monitoring.



         MRS. vom  EIGEN:  Thank you very much;  it's



been very informative.



         CHAIRMAN  CHAMBERS:   Okay.  I'd like  to



close this public  hearing.  Then I guess you  have



the poster session down here; we could spend  a  few



more minutes there.   If anyone else would like  to



say anything for the  record,  please do.



         MR. CHRISTOPH:  I would like to thank  the



Department of Defense and the other organizations



for what I consider to be an  openness, a willingness



to talk to us.  I  appreciate  that.



         CHAIRMAN  CHAMBERS:   You're welcome.



         DR. CRAMER:  He stole my thunder.



         CHAIRMAN  CHAMBERS:   One more thing,  if I



might add,  please.  The public comment period is



open to March 1st, so if you  would like to submit



any comments in written form, the address is  on the



fact sheet and the proposed plan; you have until



March 1st to submit it in writing.



              (Whereupon, at  8:40 p.m.



              the hearing was concluded)
                   DORIS O. WONG ASSOCIATES

-------
                                                     71
 1                       CERTIFICATE




 2            I, Anne H. Bohan,  Registered Diplomate




 3   Reporter, do hereby certify that  the foregoing




 4   transcript, Volume  I,  is a  true and accurate




 5   transcription of my stenographic  notes taken on




 6   February 21, 1996.




 7




 8




 9




10                             Anhe H. Bohan




11                      Registered Diplomate Reporter




12




13




14




15




16




17




18




19



20




21




22




23




24










                   DORIS 0. WONG ASSOCIATES

-------
This page intentionally left blank

-------
 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25, 26, & 27
                   RECORD OF DECISION SUMMARY
                    SOUTH POST IMPACT AREA AND
            AREA OF CONTAMINATION 41 GROUNDWATER AND
                AREAS OF CONTAMINATION 25,26, AND 27
                   FORT DEVENS, MASSACHUSETTS
                            APPENDIX E

                             TABLES
C:\PP A ROD\DEUVER\SPIA\FINALIK>D\FROD30.WPD                               Mmy30.1996

-------
This page intentionally left blank

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E- 1
Table 1
SUMMARY OF ANALYTICAL RESULTS
FOR SPIA WELL D-l
(MR/I)
Anatyte
Mctab
Arsenic
Barium
Calcium
Copper
Iron
Lewi
Magnesium
MangaiKtc
Potassium
Sodium
Zinc

Detection
Frequency

2/4
1/4
4/4
1/4
4/4
2/4
4/4
3/4
4/4
3/4
1/4
Range
Minimum

3.80
-
3,480
-
113
2.17
1.360
3.18
368
2,470
-
Maximum

4.56
2.12
6,200
6.73
188
4.23
1,760
4.02
1.380
2,640
40.5
Local
Background
25M-92-05X
Frequency of
Exceedance of
Background
Region m RBC
for Tapwater
Frequency of
Exceedance of
RBC and
Background

<2.54
13.2
2,745
<8.09
2,640
1.85
914
68.6
1.575
2.105
<21.1
2/4
0/4
4/4
0/4
0/4
2/4
4/4
0/4
0/4
3/4
1/4
Hk
0.37«
2,600
NR
1,400*
NR
IS1
NR
I80»
NR
NR
11,000'
0/4
2/4
0/4
-
0/4
-
0/4
-
0/4
-
-
0/4
PestieMe*
EndosuUan nilfate
EndosulTane. B
1/4
1/4
-
-
0.260
0.006
NA
NA
-
-
220*'
220'
0/4
0/4
 C:\PP ft ROD\DELIVER\SPIA\FINALROD\TABLES.WPD
  May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groundwater and AOCi 25,26, & 27
Page E- 2
Table 1
SUMMARY OF ANALYTICAL RESULTS
FOR SPIA WELL D-l
(Mfe>
AnaJyte
SCMfVMflHte OlfflMtt
2-Eltiyf-l-liexanol
Bi*2-«thyftwxyl)phdttUU
HdCMCdMNC ACM
TABLES.WPD
                                                                                                                      May 30. 1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Ground water and AOCs 25,26, & 27       Page E - 3
Table 2
SUMMARY OF GROUND WATER ANALYTICAL RESULTS (FILTERED)
AOC 25- EOD RANGE
(ug/L)
Chemical*
Local Background Concentration
Detection
Frequency
Metab
Aluminum
Barium
Calcium
Lead
Magnesium
Manganese
Pou»um
SDver
>odnnn
Zinc
0/1
0/1
1/1
0/1
0/1
1/1
0/1
0/1
0/1
0/1
Range
Minimum
Maximum
Downgradient Wells
Detection
Frequency
Range
Minimum

-
-
1,830
-
-
114
•
-
-
-
-
-
1,850
-
•
12.4
•
-
-
•
119
2/9
9/9
1/9
8/9
6/9
419
1/9
4/9
1/9
31.6
153
1280
1.41
537
5.1
1.190
2.44
1,950
129
Maximum

36
16.8
4,020
1.41
711
35.8
U70
2.44
2,510
129
Source: Ecology and Environment, Inc. 1994.
C:\PP A ROD\DEUVER\SPIA\FINALROI>TABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27       Page E - 4

Table 3 1
SUMMARY OF GROUNDWATER ANALYTICAL RESULTS (UNFILTERED)
AOC 25- EOD RANGE
ta/L)
Chemical
M**
Afcnriu*
A-«*/
AIMBC*
B«u*
BffyOMn*
CUciiM*
Ore-urn'
CotaT
C«ff«*
InaT
LMT
M^wuni*
MM***
Nioktf
1UUM-
fetan.
So**
VMMfi||B.
ZBC
Ittf»\ Rarkv rnunH fnnf

DetoctkM


3/3
0/3
0/3
3/3
00
3/3
on
00
00
3/3
20
3/3
3/3
00
2O
1/3
20
00
00
EipMv*
2.4^
CydoMte(IU>Xr
HMX*
PETN"
00
oo
0/3
00
cntratkm
Ruge
MfainuBi

S30
•
•
7.61*
•
XI70»
•
•
-
1400
1.79»
«93
33.1
•
•01'
X41»
1^90*
•
•

•
-
.
•
Maiimom

1.690*
•
-
13.2*
-
2.730*
-
-
-
2^40*
1.13*
914
61.6*
»
IW
141*
2.110*
•
•
Downgrmdient Welb

Detection
Frequency

19/19
4/19
11/19
IS/19
2/19
IS/19
14/19
10/19
13/19
19/19
13/19
19/19
19/19
10/19
17/19
0/19
16/19
12/19
14/19
Range
AUDIBIIII&

390
3.04
2.93
3.64
6.27
2.7W
7.48
11.4
16.2
1.060
1J2
396
13J
23.1
WTO
•
1.930
113
22.1
Mumimum

920.000
S.12|
S7
2.440
9J7
119.000
1JOO
610
1^00
1400.000
400
230.000
24.000
1.900
104.000
-
11.100
1.100
3.000

•
-
-
-
1/19
4/19
1/19
1/19
1.62
0.67
1.01
19.5
1.62
7.88
1.01

Source: Ecology and Environment, Inc. 1994

•Selected as a COPC
k Avenge of field duplicate samples
C:\PP_A_RODM)EUVER\SP1A\FINALROI>TABLES.W?D
Mmy 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27        Page E - 5
Table 4
SUMMARY OF GROUNDWATER RESULTS (FILTERED)
AOC 26 -ZULA RANGE
(ug/L)
Chemical
Local Background Concentration
Detection
Frequency
Mctab
Aluminum
Arsenic
Btfiutn
Calcium
Iron
Lead
Magnesium
Mangaooe
toutnum
Selenium
Sodium
Zinc
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
0/1
Range
Minimum
Maximum
Downgradient Welk
Detection
Frequency
Range
Minimum
Maximum

-
•
•
U60
-
-
•
•
-
-
-
•
-
•
-
1.260
-
-
•
-
-
-
-
•
1/8
1/8
2/8
8/8
2/8
1/8
3/8
7/8
2/8
2/8
7/8
3/8
35.8
J.07
3.92
656
48.2
1.74
589
3.8T
704
1.65'
2.070
20.3
35.8
5.07
16.4
7.920
65.6
1.74
1.080
62
1.010
3.56
3.850
76.7
Source: Ecology and Environment, Inc. 1994

• Average of field duplicate samples
C:\PP & ROD\DEUVER\SPIA\nNALRODVTABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 6
TabkS J
SUMMARY OF GROUNDWATER RESULTS (UNFILTERED)
AOC-26- ZULU RANGE
L)
Chemical
MM*
Ataowm-
AfMHC-
Bran*
ICdcfcu1
__._.
CotaT
Co«W
taoT
LMd*
lh»lli.«.'
II.IH '
Nick*
FMMiym-
Sttohm'
Sodium*
YMdJUOl*
Zmc-
En**.
13-Dinatrobcazaie'
2,6-DitnXoluMe'
2-NtoMoliMM'
* ^l^H^4kfk*^B^*
J«NlBvlOliMBir
4-AoMK>-2,6.
CyetonileOUBXr
HMX*
NiMRhno*
Backfroind WcU 26M-92-01X
Detectkw
FraqocBcy

l/l
l/l
l/l
l/l
0/1
0/1
on
1/1
I/I
1/1
1/1
on
0/1
1/1
0/1
0/1
0/1
Ranfc
Minimum

6,600
2.16
14
1.110
-
-
•
1.600
14.9
591
4X9
-
-
Ill
-
-


0/1
0/1
1/1
0/1
0/1
O/I
0/1
0/1
-
•
6.02"
-
•
-
•
-
Maximum

6.600
ZS6
14
M10
-
-
-
1.600
14.9
391
4X7
-
-
2.11
-
-
-

-
-
6.02°
-
-
•
_
-
DowBfradient Well

DetecttoB
Frequency

it/ii
12/11
16/18
11/18
6/18
2/18
3/18
18/18
12/18
18/18
18/18
2/18
14/18
1/18
16/18
2/18
•

2/18
3/18
2/6
1/6
1/6
10/18
9/18
1/18
Range
Minimum

116*
2.88
3.36*
1.240
4.9»
42.4
7.72*
236*
1.41
330*
17.8
10.7
1.173*
Z05
1,900
13
10/18

0.326
0.9
10
1.86
0.301*
3.33
2J5»
36.7*
Maximum

24.200
100 1
93.8
18.100
26.6
44.8
32
31.300
27
4.830
U10
57.6
5.470
2.05
6.010
24.9
99J

1.65
5.42
27
1.86
OJOI*
390
23
36.7*
C:\PP * ROIW)EUVER\SP1A\FINALRODMABLES.WPD
M«y30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27        Page E - 7
TabkS
SUMMARY OF GROUNDWATER RESULTS (UNFILTERED)
AOC-26- ZULU RANGE
(ug/L)
Chemical
PETN-
Background Well 26M-92-01X
Detection
Frequency
0/1
Range
Minimum
-
Maximum
-
Downgradient Well
Detection
Frequency
1/18
Range
Minimum
17.4'
Maximum
17.4'
ScaUvobtUeOrfMks
Bu(2
-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27       Page E - 8
Table 6
SUMMARY OF GROUNDWATER ANALYTICAL RESULTS (FILTERED)
AOC 27 - HOTEL RANGE
(M*/L)
Chemical
AM*
Mmmm
Me
Bmn
HiiuM'iiii
PV/WHI
C*MB
Copp-
boa
>!.„.»•.
Mi*.-
PMMta
Sote
Zinc
Background Well
SPM-93-13X
Frequency
of
Detection

l/l
0/1
0/1
0/1
1/1
0/1
1/1
1/1
1/1
1/1
1/1
0/1
CoaceatratioB

90.1
-
•
-
3.360
*
375
156
45.4
UMO
W30
-
DowngradfentWelb
Freqaeocy
of Detection

3/7
1^
1/7
5/7
7/7
1/7
4/7
7/7
7/7
6/7
7/7
6/7
Raofe
Minimum

9 JO
4.96
5.76
O.OS7
4,530-
3.040
21.6
1.170
1.46
1.020
X290
7.54
Maximum

713
456
6.10
0.315
11.400
3.045*
37J3'
2410
74.1
X330
10500
112
Frequency of
Excecdance of
Backfround
CoBceatration

0/7
1/7
VJ
5/7
7/7
1/7
on
7/7
VI
5/7
7/7
6/7
Source. Ecology and Environment, Inc. 1994

* Average of field duplicate samples
C:\PP * ROD\DELIVER\SPIA\FINALROI>TABLES.WPD
M*y30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 9
                                     Table?
SUMMARY OF GROUNDWATER ANALYTICAL RESULTS (UNFILTERED)
AOC 27 - HOTEL RANGE
(W/L)
Chemical
Background WeU
SPM-93-13X
Frequency
of
Detection
Mctab
AluouDum
Antimony*
1 Annie*
Barium*
Beryllium*
Calcium*
Qjmumim*
Cobalt*
Copped
Iran*
Lead*
Magnesium*
ManganeK*
Nicker
PoUBhon'
SUvo*
Sodium'
Vanadium*
Zinc*
l/i
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
l/l
O/l
1/1
1/1
1/1
Concentration
Downgradient Wells |
Frequency
of Detection
Range
Minimum

34,000
3.06
250
272
1.68
7,820
77.7
106
147
66,000
88.3
10300
2,400
154
6.860
-
2,860
53.7
272
14/14
3/14
11/14
14/14
6/14
14/14
11/14
5/14
12/14
14/14
11/14
14/14
14/14
8/14
14/14
1/14
14/14
9/14
14/14
148
6.92
3J1»
2.62
0.123
4.250*
5.44'
5.53»
1.62
175
2.95
U40
29.6
7.7»
1.050
1.49
2020
3.89*
15.1
Maximum
Frequency of
Exceedance of
Background
Concentration

164,000
12.9
300
806
73
2X500
288
282
553
305,000
270
48300
6.540
522
26300
1.49
11.100
264
795
3/14
3/14
1/14
3/14
2/14
9/14
3/14
2/14
2/14
2/14
3/14
3/14
3/14
2/14
6/14
1/14
12/14
3/14
2/14
EiBtoriva
CyckmiU'
13-
UiniUuucuuuc
HMX«
0/1
0/1
0/1
.
-
•
12/14
2/14
5/14
0.967
0.288
0.699
17.9
1.82
4.74
12/14
2/14
5/14
C:\PP & ROD\DEUVER\SPIA\FINALROO\TABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E -10

Table?
SUMMARY OF GROUNDWATER ANALYTICAL RESULTS (UNFILTERED)
AOC 27 • HOTEL RANGE
(ug/L)
Chemical
BackfrouBd Well
SPM-93-13X
Frequency
oT
Detection

Downgradient Wells
FreqaeBcy
Range
Minimum
Maximum
Frequency of
Eiceedance of
Background
Concentration
Mktt.
dtto-BHC*
OUMrOrp-fcCh.
Total Nrobun
• • * 	 *- »
ityBOQVTCnr
0/1
-
2/6
•lob
0/1
-
3/6
0.16
0.26
2/e

350*
3,790
3/6
 Source: Ecology andEnviraomeat, me. 1994

 •Selected as COPC
 k Average of duplicate samples
C:\PP ft RCHM)ELIVER\SPIA\FINALROrATABLES.WPD

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Ground water and AOCs 25,26, & V      Page E -11
T*bk8
CHEMICAL SUMMARY REPORT FOR SURFACE WATERS
AOC 25 - EOD RANGE
(MS/L)



Test
TAL METAL













WQP




She ID
Field Sample ID
Sample Date
Parameter
Aluminum
Arsenic
Barium
Calcium
Chromium (total)
Copper
Iron
Lead
Magnewm
Manganese
Potaagium
Sodium
Van«ii«m
Zinc
Screening Values
N/A
0.018 ug]
N/A
N/A
11
12
N/A
3.2
N/A
N/A
N/A
N/A
N/A
110
HankiCiW N/A
Nitrogen, Kjeldahl Method
Nitrogen, NO3/NO2
Phoaphate
Total mipf fined aofids
N/A
N/A
N/A
N/A
25D-92-01X
WX2501X1
10/26/92

19,600
19.4
40.1
2J40
24.9
29.7
27.000
18.8
4450
417
2,430
2,880
24.7
65.6
10,400
2,000
39.5
590
996,000
Source: USAECIRDMIS Level 3/E & E, 1994 - Codes following values indicate data uscability. (See key above)
C:\PP A ROD\DELIVER\SPIA\FINALROD\TABLES.WPD
May 30,1996

-------
RECORD OF DECISION
Sooth Post Impact Area & AOC 41 Gronndwater and AOCs 25,2*, A 27
Page E- 12
Table 9
SUMMARY OP SURFACE WATER RESULTS
AOC 26 - ZULU RANGE (ftg/L)
Chemical
t.^-j_«-
VIC1MH
Aluminum*
Anemc*
Barium*
nniiHiiini
DCIJF uimn
Cadmhim
Calcium
fHj rmiSimi*
V4« UHHUin
Copper
"f j« ••
Iron*
LtMf
Map»fam
MantMe*
Mercury
Nickd
PoteMiuin
Sdcnfcm

Loral
BackgrmnMl
ConcentrMiOM

773
«.72
40.1
3
4.01
20600
6.02
1.1
1630
16S
3340
3S7
0.24
34.4
3150
3.02
RID ATA

Detecnon
Fiv^HCBcy

7/13
4/13
3/13
0/13
0/13
13/13
1/13
1/13
13/13
12/13
9/13
13/13
0/13
0/13
13/13
1/13
Rufe
Mhkawn

162
3.73
5.26
-
-
1.200
7.153
10.4725
«IJ
1.63
667
6.65
•
-
560
3.W3
Mftxfaran

3.7SO
rir
309"
-
-
19400*
7.15*
I0.5»
11.500*
106*
236*
101
»
-
ZS60*
3.19*
F •TMfVC.My Of
Exccedaaceof
Badcgt«MMl

3/13
1/13
1/13
0/13
0/13
0/13
1/13
1/13
2/13
2/13
0/13
0/13
0/13
0/13
0/13
1/13
SI DATA

Detection
rnE^ttCttcjr

mo
mo
10/10
6/10
5/10
10/10
9/10
9/10
10/10
9/10
10/10
10/10
1/10
5/10
10/10
2/10
Range
MMBmi

1620
S.09
2.5
0.403
2.91
2400
4.99
t.OI
174
6.54
730
9.5J
8.2
11.9
J7J
4.95
Maitemi

31000
5 M
2200
2S
170
75000
410
3100
50000
9400
47000
15000
1.2
300
14000
5.54
Frequency of
Esceedence
of
Background

mo
mo
7/10
1/10
4/10
1/10
mo
mo
mo
mo
3/10
3/10
1/10
I/IO
1/10
2/10
 C:\PP A ROD\DEUVER\SP1A\FINALROEKTABLES WPD
   May 30.1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E- 13
Table 9
SUMMARY OF SURFACE WATER RESULTS
AOC 26 - ZULU RANGE (ng/L)
Chemical
Silver
Sodium
Vanadium*
Zinc-

Local
Background
Concentration
4.6
36300
11
33.4
Eiptoriva
1 ,3.5*Tnnitrobefiz€ne
1,3-Dinhrobenzcne
Cyclonhe'
HMJP
-
-
-
•
RID AT A

Detection
Frequency
0/13
13/13
1/13
2/13
Range
Minimum

2.040
17
33.2
Maximum

3.840
17*
90.3»

0/13
0/13
3/13
1/13
•
-
5.76
1.8625
-
-
26.7*
1.86*
Frequency of
Eiceedance of
Background
0/13
0/13
1/13
2/13
SI DATA

Detection
Frequency
5/10
9/10
8/10
7/10
Range
Minimum
0.745
2380
5.16
78
Maximum
14
3110
340
9100
Frequency of
Exceedence
of
Background
1/10
0/10
7/10
7/10

-
-
-
-
3/10
2/10
3/10
0/10
0.495
0.321
1.46
-
0.747
1.13
21.3
-
.
-
.
-
Pesticide*
p,p'-DDiy
-
1/13
0.086
0.086
-
0/10
-
-
-
SemivotBtile Orpuilcs
4-Mrthylphenol
Bis(2-ethy1exyl)
phttotate'
-
-
0/13
6/13
-
4.6
-
15
•
-
1/10
0/10
15
-
15
-


 C:\PP ft ROD\DELIVER\SPIA\FINALROD\TABLES.WPD
                                                                                                      May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Gronndwater and AOCi 25,26, A 27
Page E- 14
Tabk9
SUMMARY OF SURFACE WATER RESULTS
AOC 26 - ZULU RANGE 0»g/L)
Chevied
VoMfeOrgMto
1,1,2-TricMofoctfiuie*
Tohne
Load
ftMifcaiMMii«|
DwCKgiwnii


-
•
RID AT A
rW^MMCjT

1/13
0/13
Ravgc
Mtahnm

3
-
Maitaam

3
-
Frequency of
ExccedaMcof
Backgramd

*
»
SI DATA
Fw^jvuicy

0/10
2/10
Range
Minimum

-
13
Maximum

-
13
M?———. -•

Eiccedcnce
of
Backgrovnd

-
-
 Source: Ecology and Environment, Inc. 1994

 Note:   SI surface water samples contained elevated levels of suspended sediment resulting in artificially high metals concentrations. Metals were selected as COPCs
        based on the RI data only.

 •Selected as a COPC
 ' Average of field duplicate samples
 * Single exeedance is an average of duplicates from location 26D-92-096X; high result is due to elevated concentration of suspended sediments in one of these
  duplicates. Concentrations found in the other duplicates were well below background value.
 4 Attributed to laboratory or sampling contamination
 C:\PP * ROD\DEUVER\SPIA\FINALROOVTABLES WPD
    MiyJOJ996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 15
Table 10
SUMMARY OF SURFACE WATER ANALYTICAL RESULTS
AOC 27 - CRANBERRY POND
0»g/L)
Chemical
Detection
Frequency
Mctab
Alumiouin
Barium
Beryllium
Calcium
Copper
Iran
Lead1
Magnesium
Manganese
Hfl^^nnn
Silver
Sodium
Zinc
8/9
619
219
919
619
919
919
619
919
619
1/9
919
619
Range
Minimum

10.5
3.1
0.105
760
1.21
482
5.11
249
7.21
579
2.34
854
6.02
Maximum
Local
Background
Concentration
Frequency of
Exceedance
of Background

274
4.79
0.110
931
2.85
819
18.2
280
11.5
797
234
1030
24.5
773
40.1
5
20.600
8.1
1,630
8.68
3340
357
3.150
4.6
36,300
33.4
0/9
0/9
0/9
0/9
0/9
0/9
119
0/9
0/9
0/9
0/9
0/9
0/9
Source: Ecology and Environment, Inc. 1994

• Selected as a COPC
C:\PP & ROD\DELIVER\SPIA\FINALROr>TABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E -16
1 Table 11
CHEMICAL SUMMARY REPORT FOR SURFACE WATERS
AOC 25- EOD RANGE
Oic/c)
•


Tart
TAL METAL

















TCLFM
TOC
Site ID 29D-92-01X
Field Sample ID DX2501X1
Smote Dhtfc 10/76/92
PanmeUr
ScraaBBUjValuei |
Aluminum 1,000,000 10,500
AlMBJC
Barium
Beryutum
Calcium
CaranMum (total)
Cobalt
Copper
boa
30 200
72,000 19.6
3.0 1.19
N/A 996
9.000 19.9
N/A 4.64
31.000 14J
N/A 24.100
Lead 900 11.0
Maanemm N/A 3.100
Maopaaae 9.100 291
Nickel
700 11.6
Poteeuum N/A 240
Stlaaium 2400 0.990
Sodium
Vanadium
Zinc
DDT
Total Oraoic Gaiton
N/A 171
7.200 13.3
9.000 95.5
9.0 0.013
N/A 15.800
Source: USAECIRDMIS Level 3/E A E, 1994 - Codes following values i
data useability. (See key above)
C:\PP * ROD\DEUVER\SP1A\FTNALROD\TABLES.WPD
                   May 30.1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page E- 17
Table 12
SUMMARY OF HI AND SI SEDIMENT RESULTS
AOC 26 -ZULU RANGE
QtR/K)
Chemical
Mctd*
AlunuflUtn
Arsenic
Btfium
Beryllium
Cadmium
Calcium
Chromium
Cobilt
Copper
Iron
Lead
Magnesium
Manganese
1 Mercury
Nickel

Detection
Frequency

23/23
18/23
23/23
8/23
2/23
21/23
8/23
6/23
19/23
23/23
22/23
21/23
23/23
1/23
8/23
Range
Minimum

2.400
0.643
9.3
0.153
1.2
304
838
2.24
1.33
1.070
3.66
257
15.56
0.094
4.89
Maximum

33,100
26
177
2.48
2.4
10.600
35.3
11.4
43.2
24.500
too
4,180
303
0.094
29.5
Local
Sediment
Background
Concentration

10,500
26
26.2
0.5
0.5
1.100
15.9
7.2
14.3
7,900
12.5
3.100
600
0.05
18.6
Frequency of
Exceedance of
Sediment
Background
Local
Soil
Background
Concentration
Frequency of
Exceedance
of Soil
Background

5/23
0/23
12/23
2/23
2/23
8/23
2/23
1/23
6/23
4/23
13/23
3/23
0/23
1/23
2/23
18,000
19
54
0.81
1.28
810
33
4.69
13.5
18.000
48
5.500
380
0.108
14.6
1/23
2/23
5/23
1/23
1/23
11/23
1/23
2/23
6/23
2/23
4/23
0/23
0.23
0/23
2/23
 C:\PP & ROD\DELIVER\SP1A\FINALROD\TABLES.WPD
   May 30, 1996

-------
RECORD OF DECISION
Sooth Post Impact Area A AOC 41 Gronndwater and AOCs 25,26, A 27
Page E- 18
Table 12
SUMMARY OF RI AND SI SEDIMENT RESULTS
AOC 26 -ZULU RANGE

Chemical
FOUMMI
Sdcnhm
Sodium
VamdJom
Zinc

n^AAMAiMM
•FdVCIPPB
rTM|WW7
1M3
tO3
1403
1503
13/23
ElplMlVM
2*406*11 Mbitf utotucM
Cydomle(ROX)
Ttiil 1 •!•! •••!!
Mnofiycain
rotkMc*
P4.--DDD
pj'-DDT
9CHMV GMnHV UI^JMOCS
Btt(2-c(kylwxyl) -
•dtflMl^A
rfc'iit lit -i^t, •!•••
UKinyi pvpnuBw
1/22
1/22
1/22

4/23
203
Rnf*
Mbfaram
190
0.6
SS.2
2.34
K.5
Maiham
1.300
4.»
1.700
31.7
M.I
Local
9CQBBCMI
Backgramd
292
0.13
2S9
I3J
55.6
Frequency of
Exceedance of
Sediment
Backcroand
11/23
103
703
303
2O3
Local
Sod
Background
Concentration
2.400
0-992
234
32.3
43.9
Frequency of
Exceedance
of SoU
Background
0/23
6/23
IOO3
OO3
4/23

3.71
10.6
10.7

O.OM
0.016

3O3
103
0.4*2
0.765
3.71
10.6
10.7

0.105
0.035
-
-
-

-
-

5.9
0.765
-
-
-
-
-
-
-
-
-
-
-

-
-
-
-
-


-
#
•
•


 C:\PP * ROCW)EUVER\SPIA\F1NALRODMABLES.WPD
                                                                                                     May 30.1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E- 19
Table 12
SUMMARY OF RI AND SI SEDIMENT RESULTS
AOC 26 - ZULU RANGE
(MR/R)
Chemical
Volatile Ortmnlc*
Acetone*
Ethylbenzcne*
Toluene*
Trichlorofluorometfune
Other Orfuiks
Total Petroleum
llyarocuMti
Detection
Frequency

3/23
1/73
4/23
3/23

6/23
Range
Minimum

0.12
0.205
0.012
0.01

52
Maximum

0.505
0.205
0.6
0.052

397
Local
Sediment
Background
Concentration

-
-
-
•

-
Frequency of
Exceedance of
Sediment
Background
Local
Soil
Background
Concentration
Frequency of
Exceedance
of Soil
Background

-
-
-
-
-
-
.
-
-
.
-
•

-
-
-
 Source: Ecology and Environment, Inc. 1994

 1 Selected as a COPC
 • Average of field duplicate samples
 • Elevated above the sediment background value but not above the soil background value; selected as a COPC, but was not carried
  through the human health risk assessment
 4 Attributed to sampling or laboratory contaiment
 CAPP & ROD\DELIVER\SPIA\F1NALROD\TABLES.WPD
                                                                                                                         May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 20
Table 13
SUMMARY SEDIMENT ANALYTICAL RESULTS
AOC 27 - CRANBERRY POND
(ratt
f*L , ... t, ,1
VBCIMCW
Mctab
Aluminum*
Anthony*
Ancmc*
f\m B1..^P
tMnonr
IBefyffiMri*
Calcium
CLwOfiMMnr
Cobalf
CoppW
wonr
U»*
Mtgtnnm
Manpneae
Metcwy*
NickeT
1 "*•"""•


Detection
FnfHCMjr

9/9
1/9
9/9
5/9
C«
2/9
6^9
1/9
9/9
9/9
9/9
3/9
9/9
1/9
9/9
1/9
1/9
Range
MW«.

2,630
S.59
4.77
«.OI
OJI5
192
5.67
9.35
7.36
5.060
27
925»
43.7
1.01
4.7
345
16
Maximal

11,600
5.59
2S.I
76.1
0.730
474
33.6
9.33
139
16.100
1.400
2.110
137
l.Ot
5.09
343
2J6
Local
T ••!•••• mmt
0woDwn
BackgroviKl
CMMmtranoB

10.300
0.3
26
26.2
0.3
1.100
13.9
7.2
14.3
7.900
115
3.100
600
0.05
1S.6
292
0.13
Frequency of
Eicccdanceof
Sediment
BackgnHind

6/9
1/9
1/9
2/9
2/9
0/9
2/9
1/9
7/9
4/9
9/9
0/9
0/9
1/9
5/9
1/9
1/9
Local
Son
Background
(*OBCtBtr8tlOII

18,000
0.5
19
34
O.SI
• 10
33
4.69
13.5
IS.OOO
4S
5.300
3*0
0.10*
14.6
2.400
0.992
Frequency of
Exceedance
of Son
Background

1/9
1/9
1/9
IP)
0/9
0/9
1/9
1/9
7/9
0/9
S/9
0/9
0/9
1/9
6/9
0/9
1/9
 C:\Pr * RODNDEUVERVSPIAVFINALROOMABLES.WPD
   May J1L1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 21
Table 13
SUMMARY SEDIMENT ANALYTICAL RESULTS
AOC 27 • CRANBERRY POND
0»g/g)
Chemical
Sodium*
Vanadium*
Zinc*

Detection
Frequency
3/9
9/9
9/9
Range
Minimum
170
4.85
12.6
Maximum
3.8
68.5
396
Local
Sediment
Background
Concentration
289
13.3
55.6
Frequency of
Excecdance of
Sediment
Background
1/9
6/9
6/9
Local
Soil
Background
Concentration
234
32.3
43.9
Frequency of
Exceedance
of SoU
Background
1/9
1/9
6/9
Eipfoftvc*
4-tmino-2,6-dinhrotohiene'
2/6
1.90*
3.45
-
•


Volatile Oifuik*
Acetone*
2-Butanone*
TetracMoroelhene*
ScmtvoUfflc Orfink*
Btnzo(b)flour»irthane*
Fyiciie
119
2/9
1/3

1/9
1/9
PcsttcMe*
p,p'-DDD*
p.p'-DDE*
8p,p'-DDT
Methoxychlot*
2/9
119
1/9
1/9
0.81
0.143*
0.002

0.33
0.33

0.017
0.017
0.019
0.088
0.960*
0.160
0.002

0.33
0.55

0.090
0.090
0.019
0.088
-
-
-
-
-
-
-
-
-
.
-
-

•
-

-
-
-
-
-
-
-
-
-
-

•
-
•
-
-
-
-
•
-


-
 C:\PP & ROD\DEL1VER\SPIA\FINALROD\TABLES.WPD
                                                                                                        May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Gronndwater and AOCi 25,26, A 27
Page E - 22
Table 13
SUMMARY SEDIMENT ANALYTICAL RESULTS
AOC 27 - CRANBERRY POND
(fig/D
Chemical
FfCqVtney
Range
M,— .
Oder OifMfc CMe*
ToUlfttrofcom
ItiiaVwiraati «i»a*
••jr™"™*^™™™***'1™*
t/9
4«.4
Maifann

7W
Local
BMfcgrmmd
Concentration
Frequency of
ExceedaaccaT
7ailfal_>iii
0WBnff5D»
Bacfcf round
Local
Soft*
Background
Concentration

-
•
-
Frequency of
Eiceedance
ofSoH
Background

-
 Source:  Ecology and Environment, Inc. 1994

 • Selected tsaCOPC
 k Average of field duplicate samples
 • Elevated above the sediment background value, but not above the soil background value
 ' Single exceedance is less than 35% greater than the background value
 ' Concentration believed to be attributable to blank contamination
 C:\PP * ROD\DEUVER\SPIA\FINALRODVTABLES WPD
   May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27       Page E - 23
Table 14 1
SUMMARY OF SURFICIAL SOIL ANALYTICAL RESULTS
AOC 25 - EOD RANGE (ug/g)
Chemical
Detection
Frequency
Range
Minimum
Maximum
Local
Background
Concentration
Metab
AhttnttutfH*
Antinomy*
Anode
Barium'
Beryllium*
Ctlfhim
Owmium'
Cobalt*
I*rtJHw*
M
Le*f
MagDcrium
Mngnett*
Mercury*
Nicker
Potaanum
Selenium*
Sodium*
Vanadium
Zinc*
1/11
1/11
li/ll
11/11
3/11
4/11
10/11
8/11
11/11
11/11
11/11
11/11
11/11
2/11
11/11
S/H
11/11
11/11
11/11
11/11
5.1701
2.74
539
10.9
0.602
123
5.49
1.87
3.55
5,550
3.26
476
93.5
0.082
5.00
194
0.412
138
5.12
16.1
32,000
2.74
12.4
65.4
1.85
301
25.6
6.62
54.8
24,200
54
2360
809
0.397
203
669
1.74
252
29.1
92.9
18,000
0.5
19
54
0.81
810
33
4.69
13.5
18,000
48
5,500
380
0.108
14.6
2,400
0.992
234
323
43.9
Frequency of
Exceedance of
Background

l/ll
l/ll
0/11
1/11
2/11
0/11
1/11
1/11
3/11
1/11
1/11
0/11
2/11
1/11
1/11
0/11
2/11
1/11
0/11
3/11
Exptaatva
NhnceUulow*

luugiyvaui
OrfMfc*
ToUl Petroleum
nyui u-u UWB
2/11
1/11
*
7/11
25.8
7.18

31.1
5550
7.18

45.2
-
-

-
-
-

-
Source: Ecology and Environment, Inc. 1994
• Selected as COPC
• Single exeedance is less than 25% greater than the background value.
 and not site related contamination.
' Average of field duplicate samples
This probably reflects natural variability in soil
C:\PP A ROD\DEUVER\SP1A\FINALROD\TABLES.WPD
                           May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 24
                                    Table 15
SUMMARY OF HI SURFICIAL SOIL RESULTS
AOC 26 - ZULU RANGE (ug/g)
Chemical
Met*
Alunmn
AoftMiy
AfMWC*
Mm
flinitlTiMi*
oaywuflr
C^toum-
CalCMOl*
Orate
Cetak
ccnw
ban
LM*
MM**.
NtaVMK
Nkkd
POM~»
feM»
SodilM
V««fa«
ZiK*
Biptalvw
Cyetonite1
HMX1
Dctectkw
FreqacBcy

M
1/9
9^9
9/9
7/9
2/9
9/9
9/9
7/9
9/9
9/9
9/9
99
9/9
9/9
4/9
99
9/9
919
9/9

3/15*
1/15*
Range
Minimum

3,130
1.1*
7.03
13
0.5M
1.44
146
531
112
5J2
5.710
S3
474
33.7
4.25
341
0.421
164
Ml
115

0.654
1.2
Mailman

7,710
l.lf»
20»
35.5
0.945
1.99
2520
10.9
4.25
30.1
10.600
».5»
1.400
167
9.16
4K
0.771
227
10.9
143

1.1
1.2
Local SoU
Background
Concentration

11.000
0.5
19
54
O.S1
13*
•10
33
449
12.5
11,000
4S
5.500
3W
14.6
2.400
0.992
234
32J
43.9

•
-
Frequency of
Eiceedance of
Background

0/9
1/9
1/9
0/9
2/9
2/9
2/9
0/9
0/9
V)
019
1/9
0/9
0/9
0/9
09
0/9
0/9
0/9
2/9

-
-
C:\PP * ROD\DELIVER\SPIA\FINALRODMAflLES.WPD
May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27        Page E - 25
TablelS
SUMMARY OF RI SURFICIAL SOIL RESULTS
AOC 26 - ZULU RANGE (ug/g)
Chemical
Detection
Frequency
Range
Minimum
Maximum
Local Soil
Background
Concentration
Frequency of
Exceedance of
Background
PCB.
PCB-1254*
1/9
0.161'
Pecttddcs
mp-DDE*
M»-DDr
Accnipnthyicoe*
1/9
3/9
1/9
0.032
0.006*
0.064
ScMtvobtUeOrfulei
AflUnoeae*
Benzo(>)iflthncene'
Bcozo(ft)pyROCl
BeraoO^uonathene*
Benzo^yiuanntbene*
Chryieoe*
Di-o-butyH)hlh«UU'
•luonoAbeoe'
_._.,.
Ilvauiiiniaie
Pyiene*
2/9
1/9
1/9
1/9
2/9
2/9
3/9
2/9
1/9
2/9
VoWBeOifuIci
Acetone*
Toluene*
Other Orruia
'ottl Petroleum
iyw 4Mv*U u*um
1/9
1/9

«*
O.OS5»
0.29
OJ8
0.81
0.1S
0.24
0.08S
0.24
0.1
0.13

0.029
0.001

25.1'
0.161"

0.032
0.037
0.064

0.06S
0.29
0.38
0.81
0.18
0.3
0.143*
0.29
0.1
0.26
-
•

-
•
-

-
•
-
•
-
-
-
-
-
-
•
.
.

-
-
-
-
•
•
•
-
-
-

0.029
0.001

34.2
•
•

-
-
-

-
Source: Ecology and Environment, Inc. 1994

• Selected as a COPC
k Average of field duplicate samples
' Single exceedance is less than 25% greater than the background value.  This probably reflects natural variability in the
 soil and not site-related contamination.
* Includes six surface soil samples from the SI that were analyzed for explosives only
' Attributed to sampling or laboratory contamination
C:\PP & ROD\DELIVER\SP1A\FINALROI>TABLES.WPD
Mty30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 26
                                     Table 16
SUMMARY OF SI SUBSURFACE SOIL SAMPLES
AOC 26 - ZULU RANGE (ug/g)
Chemical
M*ab
Afamaum
AMic*
•«--' —
ovum
Beryllium
C**.
<**«•
Ckro.ua,
C«PP*
baa
LMf
Uip.iin.if
Itapam
Mrary
Nkfcd
*»•*«
saw*
s«*»
V^diym
2mtf
Detectkw
Frc<|ttCBCjr

65/W
«4/66
64/66
36/66
1/K6
64/66
4t«6
64/66
66/66
3*/66
66AC6
66«6
W6
7/66
66^6
4AC6
60«6
66/66
42/66
EqtaKw
Cyckwte(!RDXr
HMX>
TdryT
6/66
2/66
1/66
Range
Mininuun

3.900
4J
4.69
0.097
0.713
130
4.5
2J1
260
3.14
940
66
0.037
3.25
24S
0.124
55.S
2J2
10.7
MaibniUB

18.000
23
27
0.269
0.715
1JOO
29.5
41
18,000
190
5.900
370
0.046
10J
1.400
0.61
195
26.3
220

1J9
1.29
2.54
38
3.11
2.54
Local SoU
Background

18.000
19
54
0.81
1.28
810
33
13.5
18.000
48
5^00
380
0.108
14.6
2.400
0.086
234
32J
43.9
Frequency of
Exceedance of
Background

0/66
H
0/66
0/66
0/66
10/66
0/66
7/66
0/66
4*6
1/66
0/66
0/66
0/66
0/66
4/66
0/66
0/66
3*6

-
-
-
-
•
-
C:\PP * RODM)ELIVER\SPIA\FINALROD\TABLES.WPD
May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27       Page E - 27
Table 16
SUMMARY OF SI SUBSURFACE SOIL SAMPLES
AOC 26 - ZULU RANGE (ug/g)
Chemical
Detection
Frequency
Range
Minimum
Maximum
Local Soil
Background
Concentration
Frequency of
Exceedance of
Background
PtrtkUc*
Alpha cUotdaof
alpha-
Bcracncfacxschlorklc'

beU-Benzendiexachloride*
Hepttchloc-
w»'-Diyp
1/66
1/66
1/66
1/66
3/66
0.003
0.05
0.015
0.001
0.023
0.005
0.05
0.015
0.001
0.173
-
•
•
-
•
-
-
-
-
•
SoalvoUtile OrpMlo
2,4-Dimdbylphcaor
4-M«hytphenor
Aatfaneene*
l^^lhylhexyljphtlialate'
Di^^MtytpbUuUle*
Fluormheae*
Pyrene*
1/66
1/66
1/66
3/66
2/66
2/66
3/66
1.06
1.12
0.353
0.186
0.495
0.251
0.135
1.06
1.12
0.353
0.465
138
0.351
0.239
-
-
-
•
•
.
•
•
-
•
-
•
-
-
VobtOeOrtuto
Toluene"
2/66
0.014
0.027
•
-
Source: Ecology and Environment, Inc. 1994

•Selected as a COPC
k Single exceedance is less than 25% greater than the background value. This probably reflects natural variability in the
 soil and not site-related contamination.
* Attributed to sampling or laboratory contamination
C:\PP & ROIW)EUVER\SPIA\FINALROD\TABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 28
Table 17 I
SUMMARY OF SOIL BORING ANALYTICAL RESULTS
AOC 27 - HOTEL RANGE
(M/t)
Chemical
Mttnh
AlwnBua'
Antinomy*
AMHC*
Barium*
BnTyflmn*
Calcium*
CMynf
Cater
Capp*
Iran*
LMd
H.g.mmm*
limpid
tJnririini*
PMVwW^T
NicktT
Pou-un,'
S*nten>
Sodium*
VMMbun*
Zinc*
Detection
Frequency

22/22
1/22
22/22
22/22
9/22
12/22
20/22
22/23
12/22
2202
22«
20/22
22/22
2/22
22/22
22/22
7/22
11/22
22/22
22/22
Range
Minimum

USD*
2.t4
3J3
7.04*
0.514
201
2J*
2.07
110
2*X»>
1.59*
791
SSjf
0.073
9.69
3.69
0.402
161
3.4
7.JI
Maximum

20.000
XI4
24.0
106
1.7S
1.770
314
60
31.4
29,600
24
«J30
525
0.163
29.9
3.010
0.956
360.0
41.1
71.2
Local
Backf round
Concentration

11,000
0.5
19
54
0.11
tio
33
4.69
I3.J
11,000
41
5,500
310
0.10S
14.6
1400
0.992
234
32J
43.9
Frequency of
Exceedance of
Background

1/22
1/22
2/22|
1/22
3/22
4/22
202
15/22
10/22
2/22
0/22
1/22
5/22
1/22
1002
1/22
0/22
2/22
1/22
5/22
V.MfeOffn*.
TAKMofortta**
-
•
-
-
-
C:\IT_4_RODSDEUVER\SPU\FINALROIKTABIXSWPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27       Page E - 29
Table 17
SUMMARY OF SOIL BORING ANALYTICAL RESULTS
AOC 27 - HOTEL RANGE
G»g/g)
Chemical
Toluene1
SorivoUtileOriMlcs
Di-o-butyipblhiUte*
Tricfaloroflourotnethioe*
PottcUct
EodoiulfmneA'
p.p'.DOD*
w>'-Drjrr


ToUl Petroleum
ttuulijLj ••Kruia*

Detection
Frequency
-

1/72
3-22

1/22
1/72
1/72
Range
Minimum
-

1.4
0.008

0.006
0.003
0.007
Muimum
-
Local
Background
Concentration
-

1.4
0.01

0.006
0.003
0.007

S/22
29.3
75.6
•
•

•
•
-
Frequency of
Exceedance of
Background
-

-
•

-
-
-

-
-
Source: Ecology and Environment, Inc. 1994

•Selected as COPC
* Single execdance is less dun 30% greater than the background value. This probably reflects natural variability in soil
 and not site related contamination.
c Average of field duplicate samples
C:\PP & RODyDEUVER\SPIA\nNALRODVTABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27     Page E - 30
                                   Table 18

                       CHEMICALS OF POTENTIAL CONCERN
                              AOC 25- EOD RANGE
1 . Chemical
Mrt*
Ahnnutt
Aflteoty
Amok
Bra»
fJMiilliiim
ovyMn
felon
CMu.
Cotak
CORMT
Iran
LMd
Ihy.*™
ftfaopow
M«wy
Nickd
fettwn
&.!.*»
g^ii^nn
Vwdte,
Z«e
EHM~
NteeotUuloM
Nittvflyora
2.4^-TriMlraloliMae
Cycta>le(RDX)
PETN
HMX
SHlfaccSoib

X
X


X


X
X
X


X
X
X

X


X
Subfurface Soils





X


X
X
X


X

X




X

X
X












X
X
X
X
X
X
X
X
x
x
X
X
X

X
X

X
X
X



X
X
X
X
C:\PP A RODM)ELIVER\SPIA\FINALROI>TABLES.WPD
May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 31

Tablets
CHEMICALS OF POTENTIAL CONCERN
AOC 25- EOD RANGE
Chemical
Vobtik Orpaks
TdradjJoroethcne
Other Oifuria
Tottl petreoluon hydrocubons
Surface Soils
Subsurface Soib
Groundwater

X
X


X
X

 Source: Ecology and Environment, Inc. 1994

 Note:   Groundwater COPC selection is based on unfiltered groundwater data.

 Key: X = Selected as a COPC for the human health risk assessment
C:\PP ft ROD\DEUVER\SPIA\FINALROD\TABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 32

                                    Table 19

                        CHEMICALS OF POTENTIAL CONCERN

Chemical
ItfmmmBi
AMoun
Antimony
Amok
Bwwn
•* 	 M-
DWyUMBI
Catafa.
Calcfa*
Orate.
Cobalt
Off*
ta
Uad
illlMi«n
H.r 	
Ikfamy
Niekd
MMte.
Sd^uo.
Silver
Sod-n
V«*fc»
Zinc
EiplMivM
4.AMM-X«-
14-DiaitralohMae
2^-DMrolooliMie
2-NilraloliMM
3-Nimioluaie
Surface
Soil


X


X

X


X

X









X
Subsurface
Soil







X


X

X






X


X
Sediment


X


X
X
X
X
X
X
X
X
X
E

E
X
E
X

X
E
X
















Surface
Water

X


X






X
X
















Groundwater

X

X
X


X
X

X

X
X
X

X
X
X

X
X
X

X
X
X
X

C:\PP * RODU>EUVER\SP1A\FINALJIO!>TABLES.WPD
May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Ground water and AOCs 25,26, & 27      Page E - 33
                                    Table 19

                       CHEMICALS OF POTENTIAL CONCERN
                              AOC 26 - ZULU RANGE
Chemical
2,4,6 Trinitrotoluene
Nitiuglycei m
Cydaahe (RDX)
HMX
ITdryl
PETN
PatkUa/PCBi
PCB1254
p.p'-DDD
p.p'-DDE
fcp'-DDT
HepUcUor
alpha-Benzene
bcxadilorMfc
beU-Benzene
hexacnloride
SeMivolatfleOrcMla
2,4-Dimdhytpbenol
4-Methy»pheool
Accnaphthyicoc
Anthracene
Benzo(a)antBncene
Benzo(a)pyrene
Benzo(b)fluonntbene
Benzo(k)fluonalhene
Fluofinthcnc
Pbeninthrene
Pyrene
Vobdlc Orfula
Acetone
Surface
Sod


X
X



X

X
X



Subsurface
Soil


X
X
X





X
X
X
X



X
X
X
X
X
X
X
X
X
X
X

X




X

X
Sediment
X
X
X





X

X















Surface
Water


X
X




X





Groundwater f

X
X
X

X


































X


C:\PP & ROD\DELIVER\SP1A\FINALROD\TABLES.WPD
May 30,1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 34
Table 19
CHEMICALS OF POTENTIAL CONCERN
AOC 26- ZULU RANGE
Chemical
Etfaylbaiaae
l.U-TrictOoroelhme
Toluene
TricUorofluorcaMthttK
CHIMB attuifiat
— _. . . «_, .^

OthtrOrfMric*
Total pdrottun
fciiifainrarfiii »•
•ywomTDQiw
Bu^rl^irMol
3>Ediy|.14wanol
tartta*
TiMoa^
Surface
Soil


X




X




Subiurface
SoU


X



Sediment
X

X
X








X




Surface
Water

X




Groundwater




X
X






X
X
X
X
X
 Source: Ecology and Environment, Inc., 1994.

 Note:  Groundwater COPC selection is based on unfiltered groundwater data.

 Key:   E = Elevated above sediment background levels but not soil background levels
       X * Selected as a COPC for the human health risk assessment
C:\PP * ROD\DEUVER\SPU\FINALROr>TABLES.WPD
Mcy 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27      Page E - 35
Table 20
CHEMICALS OF POTENTIAL CONCERN
AOC 27 - HOTEL RANGE
Chemical
SoUi
Mcteb
Aluminum
Antimony
Arsenic
Barium
Beryllium
Calcium
Oranium
Cotwh
Copper
Iran
Lad
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc

X

X
X
X
X
X
X
X


X
X
X
X


X
X
X
Sediment

E
X
X
X
E

E
X
X
E
X


X
X
E
X

X
X
X
Surface
Water
Groundwater











X










X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

X
X
X
X
Explodva
Cycloahe (RDX)
1 ,3-DiiiiU ubeozcne
HMX









X
X
X
C:\PP & ROD\DEUVER\SPIA\FINALROD\TABLES.WPD
May 30,1996

-------
  RECORD OF DECISION
  South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27      Page E - 36
Table 20
CHEMICALS OF POTENTIAL CONCERN
AOC 27 - HOTEL RANGE
Chemical
V«fadkOrfMk>
Aflrtooe
2-BulHaoe
TiljirL |n i ii rfli MI •
i wiBBiKJiudiMDc
TofaM
Soib



X
X
Sediment

X
X
X

s^.M.om^.
BmoQOfluoiMllMae
Pyr«e
TricUontfroMlte.
MMto
dtte-BHC
EndawlfaA
Mctfaoxydilor
W.--DDE
i^'-DDT
M>'-DOD
OtWrOrf-fcON-c-i
TouJpMrolMm
kt«kMM^«lM^H
lyvnwvmiv


X


X

X
X


X
X
X




X
X
X
X

X
Surface
Water


















Groundwater










X






X
Source: Ecology and Environemot, Inc. 1994

Note:   Groundwtter COPC selection is baaed on unfiltered groundwatcr data

Key:   E - Elevated above sediment background levels but not soil background levels.
       X * Selected as a COPC lor the human health ride assessment.
C:\PP A RODNDEUVER\SPIA\FINALROI>TABLES.WPD
May 30.1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwatcr and AOCs 25,26. & 27      Page E - 37
Table 21
RISK FROM USE OF WELL D-l GROUNDWATER
AOC 41 - UNAUTHORIZED DUMPING SITE (SITE A)
Analyte
Arsenic
Barium
Copper
Manganese
Zinc
Bis(2-
ethylhexyljphthalate1
Endosulfane Sulfate
Endosulfane B
*
Chloroform
Maximum
Concentration
Detected
G»e/L)
4.56
2.12
6.73
4.02
40.5
53.0
0.26
0.006
1.7
Non-carcinogenic
Risks
1.7x10-'
3.3 x 10-5
2.0x10"
8.8 x 10"
1.5x10"
2.9 x 10°
4.8 xlO"5
1.1 x 10*
1.9x10"
Carcinogenk Risks
10 Year Exposure
Duration
1.3x10.,
•
-
-
-
UxlO'7


1.6x10*
2 Year Exposure
Duration
2.6 x 10-7
-
-
-
-
2.3 x 10*
-
-
3.2xlO-'°
Source: ABB 19%.

1 Bis(2-ethylhexyl)phthalate is thought to result from sampling or laboratory error.
C:\PP & ROD\DEUVER\SPIA\DFTFLROD\TABLES21.WPD
May 30. 1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26. & 27
         PageE- 38
Table 22
SUMMARY OF EXCESS CANCER RISKS ASSOCIATED WITH
AOC 25- EOD RANGE
Pathway
Worker Soil Contact
TraoMMT Soil Contact
Cue
RME
Avmae
RME
AvmiM
Receptor
Adult
UxlO*
ajxio*1
UxlO*
4.1x10*
Adok*ce.t
-
-
Ox 10*
1.2x10*
Risk Cootribution by
Exposure Route*
SoUta»«*ioo-76H
Oral Contact -34*
Particle Inp»»itioo-
-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
PageE- 39
Table 24
SUMMARY OF EXCESS CANCER RISKS ASSOCIATED WITH
AOC 26- ZULU RANGE
Pathway
Worker Soil Contact
Titspaner Soil Contact
Contact
Recreational Fiabenaan.
Conurnpuon
Case
RME
Avenge
RME
Average
RME
Avenge
RME
Average
Receptor
Adult
53 x 10*
1.5 x 10*
5.2x10*
1.4 x 10*
13 x Iff'
2.9x10*
8.9 x 10*
2.1x10*
Adolescent
•
-
13x10*
3.5 x 10*
3.1 x 10*
7.0 x 10*
2.0 10*
5.2x10*
Risk Contribution by
Exposure Route*
SoilIngertion-78%
Dermal Contact -21%
Particle Inhalation - <1%
Soil Insertion -80%
Dermal Contact -19%
Particle Inhalation - 
-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25.26. & 27
PageE- 40
Table 26
SUMMARY OF EXCESS CANCER RISKS ASSOCIATED WITH
AOC 27 - HOTEL RANGE
Pathway
Water Soil Contact
TrapMMr Soil Contact
Contact
CaM
RME
AWBflB
RME
Avmae
RME
Avenge
Receptor
Aduh
19x10*
XI xlO*
1.7 xlO4
1.2 xlO*
UxlO*
7.7x10*
Adotoceot
*
•
4.1 x 10*
3.0x10*
XI xlO*
1.9x10*
Risk Contribution by
Exposure Route*
SoiIIncatfian-71*
Dmnal Contact '22%
Partkfelahalatioii.TK
SoillBflMioa-76%
Daraial Contact -22%
PattidelBiMlatiao.TS
DMMlCaBUet-22S
 Source: Ecology and Environment, be. 1994

 •RME case far receptor showing greatest risk
Table 27
SUMMARY OF ESTIMATED HAZARD INDICES FOR
NONCARCINOGENIC EFFECTS ASSOCIATED WITH
AOC 27 - HOTEL RANGE
Pathway
Work* Soil CoMad*
TrMpMtr Soil Coat***
Contort'
Caee
RME
Avanee
RME
Avamfe
RME
A-^k^H^M
"r1^™^1* •
Receptor
A**
1.9 xlO4
UxlO*
7.7x10*
4JXHT1
3.0x10*
7.9 xlO*
Adok^t
*
-
7.9x10*
4.4x10^
5.9 x 10*
9.3 x 1O*
RbkCoatribfjtkMby
EzpoMR Route*
Soil li^irti nil -O%
IteMl Contact. 19H
ParticMjiahalatioD.liH
So81latiainB.7
-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25.26", & 27
Page E- 41
Table 28
SUMMARY OF HAZARD QUOTIENTS FOR ENDPOINT SPECIES
AVERAGE EXPOSURE CASE
AOC 25 -EOD RANGE
Chemicals
Mercury
Zinc

White-footed Mouse
EE
1.38 x 10*
9.93
1.79
TRY
7.0 * 10*
8x10'
1.72
HQ
1.97 x 10*
1.24 xlO*
1.04
KUldeer
EE
8.38 x 10"
5.47 xlO"1
7.43 x 10*
TRV
1.6x10*
1.09 x I01
NA
HQ
5.24 x 10*
3.02 x 10*
NA
Red Foi
EE
2.93 x 10*
3.32 x 10*
1.74 x 10"
TRV
5.0 x 10'
4.0 x 10'
4.3 x 104
HQ
3.86 x 10*
8.81 x 10*
4.04 x 10"
 Source: Ecology and Environment, Inc. 1994

 Key:  EE « Estimated exposure (mg/kg-day)  HQ « Hazard quotient  TRV = Toxicity refemce value (mg/kg-day)  NA = Not available
Table 29
SUMMARY OF HAZARD QUOTIENTS FOR ENDPOINT SPECIES
RME CASE
AOC 25 -EOD RANGE
Chemicals
Mercury
Zinc

i^ iii u£i j>m ui
White-footed Mouie
EE
8.54 x 10*
2.87 x 10'
5.21
TRV
7.0 x 10*
8x10'
1.72
HQ
1.22
3.59 x 10"
3.03
KIDdeer
EE
5.2 x 10*
1.58
2.45 x 10*
TRV
1.6 x 10*
1.09 x 10*
NA
HQ
3.25 x 10'
1.45x10*
NA
Red Fox
EE
1.82x10"
1.02 x 10*
5.06 x 10"
TRV
5.0 x 10*
4.0 x 10'
4.3 x 10*
HQ
3.63 x 10*
2.54 x 10"
1.18x10*
 Source: Ecology and Environment, Inc. 1994

 Key: EE = Estimated exposure (mg/kg-day)  HQ = Hazard quotient  TRV = Toxicity refemce value (mg/kg-day) NA = Not available
  C:\PP & ROD\DELIVER\SPIA\FINALROD\TABLES22.WPD
                                                                                                                       May 30, 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCi 25.26. A 27
Pace E - 42
SUMMARY OF HAZAI

Cheated
LMd
Zinc
<* * f i, ^Ami^rAiMif
A, ^f *9 •nfJVIIVWIWCn'c
Cydonte
(RDX)
HMX

Nnwgjyewm
p,p--DDD
W»'-DDT
TabkM
Ml QUOTIENTS FOR Ail
AVERAGE EXPOSURE
AOC 26 -ZULU RANI
Aejwrtk Invertebrates
BE
I.ICxIO*
NC
i.wxio*
6.34x10*
NC
3.36x10*
5.00 x 10'
NC
TRY
MS
NC
4.00x10*
2.59x10*
NC
160x10'
6.00 x 10*
NC
HO
134
NC
4.50
2.45
NC
4.14
133 x 10"
NC
UATIC ENDPOINT SPECIES
CASE
BE
•landtag's Turtle
BE
3.77 xl«*
4.01 x I04
I.*4xl0*
9.70x10*
3.69x10*
4.24x10*
7.6txlO"
IJ9X104
TRY
1.54
1.09 x!0>
NA
NA
NA
NA
1.60 x I04
1.60x10*
HQ
2.51 x IO*
3.6Sxl04
NA
NA
NA
NA
4.80 xlO4
1.03 x 10"
Mink
EE
1.17x10'
3.47
1.94 x I04
2.2t x 10*
1.09x10'
3.75 x IO4
3.37 x 10"
4.Wxl04
TRY
6.25
4.00 x 10'
1.00
5.00
1.25 x 10'
4.30 x 10 '
1.25x10'
1.25 x IO4
HO
ISSxIO-*
« 6« x IO4
1.94 x 10 '
4.56 x 10 *
1.69 x 10"
«.73 x 10 *
2.70 x 10 '
3.S4 x 10 '
 Source: Ecology and Environment, Inc. 1994

 Key:   EE - Estimated exposure (mg/kg-dcy)  HQ * Hazard quotient TRY « Toxkity refemoe value (mg/kg-day)
       NA - Not available NC - Not a COPC, therefore, values were not calculated
 C:\PP * RODU>EUVERVSnA\FINALROO\TABLES22.WPD

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 43
Table 31
SUMMARY OF HAZARD QUOTIENTS FOR TERRESTRIAL ENDPOINT SPECIES
AVERAGE EXPOSURE CASE
AOC 26 - ZULU RANGE
Chemical
Lead
Zinc
Cyclonitc
(RDX)
HMX
Dtp'-DDT
Herbaceous Vegetation
EE
117x10'
S.OTxIO1
l.«2
4.17 x la1
105 xlO1
TRV
100x10"
7.00x10'
NA
HA
NA
HQ
Il7*lfr'
7.14x10'
NA
NA
NA
White-footed Mouse
EE
140x10'
1.57x10*
1.26
I.69xlO!
1.03 xlO*
TRV
3.90
1.00x10'
l.ll
150x10'
150x10'
HQ
6.13x10*
1.96x10-'
1.07
6.77x10-'
4.11 x I04
Grasshopper Sparrow
EE
604x10'
1.72x101
1.21
J.7S xlO-'
3.76 x Iff1
TRV
1.50
1.09x10*
NA
NA
190 x W
HQ
4.03 x Iff'
1.51x10-'
NA
NA
1.30x19'
Killdeer
EE
1.02x10'
3.44
2.37x10'
3.24 slO1
6.67x10'
TRV
1.50
1.09x10'
NA
MA
190 x Iff1
HQ
6txl&'
3.1 x 10'
NA
NA
13x10*
Red Foi
EE
3.29 x Iff"
232x10'
4*9x10*
6.73x10'
1.93x10'
TRV
6.25
40x10'
2.50
1.25 x!0'
1.25x10'
HQ
5.26x10'
5.«lxlO*
1.96x10-
5.3Ss!0*
1.54x10*
 Source: Ecology and Environment, Inc. 1994

 Key:    EE «* Estimated exposure (mg/kg-day)  HQ = Hazard quotient  TRV = Toxicity refemce value (mg/kg-day)
        NA = Not available  NC = Not a COPC, therefore, values were not calculated
  C:\PP ft ROD\DEUVER\SPIA\nNALROD\TABLES22.WPD
                                                                                                                    Miy30, 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Grouiidwatcr and AOCi 25,26, A 27
Page E - 44
SUMMARY OF HAZARD Ql
A
Chemical
Lett
Zinc
2.4.6 rtnilrololuene
Cycta*
(RDX)
HMX
*•«- * 	 »._
raMpjmm
M>--ODD
Mt'-DOT
AqMtfc Invertebrates
EE
IM*I*
NC
1. 35x10"
4.19 x ID1
NC
1.43 XlO1
5.00x1045
NC
TRY
1.61
NC
4.00x10*
159* 10"
NC
1.60 XlO1
600x10*
NC
HQ
1.22x10*
NC
131 xlff
119 xlO1
NC
IMxIO1
IJJxIO^
NC
T.bk33
UOTULNTS FC
RMECAi
OC 26 -ZULU
»R AQUATIC ENDPOINT SPECIES
IE
RANGE
MaiHllig'* Turtle
EE
llSxl»'
1.74
i.wxur1
1.09
136* I04
l.ltxIO-'
SJIxlO4
1 39x I04
TRY
ISO
1.09x10*
NA
NA
NA
NA
l.60«l»'
1.60x10'
HQ
1.90x10-'
I60XI04
NA
NA
NA
NA
J.JJ xlO-1
1.61x10'
Mink
EE
1.95 xlfr'
I.SIxlO1
l.43xia'
2.53x10-'
6.94 xl»'
1.50 x MX'
JJ3xia'
4.05 xKT4
TRY
6.25
4.00x10'
1.00
5.00
1.25 x I01
4.JO xlfr'
1.25 xlfr1
1.25 xl*1
HQ
1.43 xlO-1
3.77 xia1
145x10'
506x10'
5.5Sx1V
3.50 xllT1
IK XlO4
3.14x10-
 Source: Ecology and Environment. Inc. 1994

 Key:   EE • Estimated exposure (mg/kg-day)  HQ • Hazard quotient TRV - Toxicity refemoe value (mg/kg-day)
       NA = Not available NC - Not a COPC, therefore, values were not calculated
  C:\PP * ROIW)ELIVER\SPIA\FINALRODMABLES22 WPD
                                                                                                                      . 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25.26, & 27
Pace E-45
Tabte-33
SUMMARY OF HAZARD QUOTIENTS FOR TERRESTRIAL ENDPOINT SPECIES
RME CASE
AOC 26 - ZULU RANGE
Chemical
Lead
Zinc
Cyclonite
(RDX)
HMX
p.p'-DDT
Herbaceous Vegetation
EE
1.90 xlO1
2.20 xlO1
3 W it 10'
3.11
1.73x19'
TRY
1.00x10*
7.00x10'
NA
NA
NA
HQ
1.90
3.14
NA
NA
NA
White-footed Mouse
EE
1.60
610x10'
163x10'
I.OS
eeSxHT1
TRY
3.90
1.00x10*
Ml
2.50x10'
150x10
HQ
409x10'
I50xl»'
2.23x10'
4.32 xia1
3.47 xia'
Grasshopper Sparrow
EE
4.00
7.41x10'
161x10'
1.12
3.17 xia'
TRY
1.50
1.09x10*
NA
NA
190 x Iff1
HQ
2.«7
6.14 x la'
NA
NA
1.09XI04
Killdeer
EE
6.71 xia1
1.49x10'
4.94
2.07 xlO1
5.63 XlO'
TRY
1.50
1.09x10*
NA
NA
2.90 xia'
HQ
4.52x19'
1.37x10-'
NA
NA
1.94 xia'
Red Fox
EE
in xia'
I.OI x 10-'
1.02x10'
4.30x10-
1. 63x10*
TRY
6.25
4.00x10'
2.50
1.25x10'
1.25x10'
HQ
3.49x10-
2.52x10'
4.09x10'
3.44x10'
1.30x10'
 Source: Ecology and Environment, Inc. 1994

 Key:    EE = Estimated exposure (mg/kg-day)  HQ » Hazard quotient TRV = Toxicity refemce value (mg/kg-day)
        NA = Not available  NC = Not a COPC, therefore, values were not calculated
  C:\PP & ROD\DEL1VER\SPIA\FINALROD\TABLES22.WPD
                                                                                                                    May 30, 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groimdwater and AOCi 25.26. & 27
Page E - 46
Table 34
SUMMARY OF HAZARD QUOTIENTS FOR AQUATIC ENDPOINT SPECIES
AVERAGE EXPOSURE CASE
AOC 27 - HOTEL RANGE
Chemical
Antimony
Copper
LMd(Mdimcnls)


Macwy
Nkfcd
4HMunoM2to-wiirtn]i0iti€ftB
Aquatic Invertebrates
EE
1.01
1.05 x 10*
ruxio1
S.64(|it/L)
1.97 K HP
2.04x10'
•.20x10*
tat/L)
TRY
3.00
7.00 x W
3.10 x 10*
«.6«fef/L)
6.90x10*
3.50x10*
4.00 x 10*
tart.)
HQ
3J7xlO*
1.50
7.03 x 10*
9.95 x I04
2.*6xlO*
5.13 x 10*
2.05
MaUarri Dock
EE
7.9* x 10*
1.45x10*
4.69x10*
NC
6.09x10"
5.64x10*
6.49x10*
TRY
NA
1.20x10*
6.00
NC
6.40x10*
3.36x10*
NA
HQ
NA
1.21
7.«2 x W
NC
9.51 x 10*
I.6«xl0*
NA
Raccoon
EE
1.61 x 10*
4.70x10*
7.04 x 10*
NC
7.7f x 10*
1.17x10*
5.SI x 10*
TRY
2.60
3.00 x 10*
6.25
NC
1.00x10*
1.56
6.90
HQ
6.21 x 10*
1.57x10'
1.13x10*
NC
7.7«xlO*
7.52 x 10*
•.41 x 10*
 Source: Ecology and Environment, Inc. 1994

 Key:    EE » Estimated exposure (mg/kg-day)  HQ • Hazard quotient  TRY - Toxkity refemce value (mg/kg-day)
        NA- Not available  NC - Not a COPC. therefore, values were not calculated
 C:\PP A ROD\DELIVER\SPIA\JTNALROD\TABLES22 WPD
   M«y30, 1996

-------
           OF DECISION
South Post Impact Area & AOC 41 Ground water and AOCs 25,26, & 27
Page E - 47
Table 35
SUMMARY OF HAZARD QUOTIENTS FOR AQUATIC ENDPODST SPECIES
RME CASE
AOC 27 - HOTEL RANGE

Chemical
Antimony
Copper
Le*d(wdiincnli)
te»d(furtoe inter)
Merrtwy
Nickel
4-mino-2.6-dinitrofotuene
Aquatic Invertebrates
EE
559
1.39x10*
1.40 xlff5
i.ttxio1
(nM
I0«
5.09x10'
I.69xl0»
0«/L)
TRV
3.00
7.00 x 10'
3.10XI01
•.MX to*
Gfl)
690x10'
3.50x10'
4.00x10'
(Mfl.)
HQ
1.16
1.20x10'
4.52
2.10
1.57
1.45
4.23
Mallard Duck
EE
4.40 xlff'
1.16
3.02 x Iff1
NC
3.34 x Iff'
1.41 x Iff*
I.TOxIff'
TRV
NA
iMxicr'
6.00
NC
6.40 x Iff'
3.36x10'
NA
HQ
NA
9.66
5.03 x Iff'
NC
5.22 x Iff1
4.20 xlO"
NA
Raccoon
EE
2.17xlff*
2.63 x Iff1
4.21 x Iff1
NC
S.«5 x 10-1
l.64xlff*
l.OTxIff1
TRV
2.60
3.00x10,
6.25
NC
l.OOxIff'
1.56
680
HQ
US x Iff4
l.77xlff'
6 MX 10'
NC
J.SS 8 iff'
1.05 x Iff'
1 58x10-
 Source: Ecology and Environment, Inc. 1994

 Key:    EE = Estimated exposure (mg/kg-day)  HQ « Hazard quotient  TRV = Toxicity refernce value (mg/kg-day)
        NA = Not available NC = Not a COPC. therefore, values were not calculated
  C:\PP ft ROD\DELIVER\SPIA\FINALROD\TABLES22.WPD
                                                                                                                      M«y30. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 48
Tafttott
SUMMARY OF ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







HELD
EVENT
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI








MATRIX
Water
Water
Soil
Soil
Water
Water
Water
Water
Water
Water
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soy
Soil
Soil
Soil
Soil
Water
Water
Water



*




MEDIUM
Surface Water
Surface Water
Sediment
Sediment
Sump Water
Sump Water
Sump Water
Sump Water
rtMMIMlwat**
ufounownvr
M M
unNtnowaicr
Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Sediment
Sediment
Sediment
Sediment
Scoiinent
Surface Water
Surface Water
GfOMMWMcc








EXPLORATION ID
4ID-92-OIX
4ID-92-02X
4ID-92-OIX
4ID-92-02X
41D-W-03X
4ID-92-04X
4ID-9245X
41D-9246X
4IM-92-OIX
4IM-924IX
41M-92-01X
4IS-92-OIX
4IS-92-02X
4IS-92-03X
4IS-92-04X
41S-92-05X
4IS-92-06X
4ID-9243X
4ID-92-04X
4ID-92-05X
4ID-924KX
4ID-W-07X
4ID-93XMX
4ID-93-09X
4ID-93-IOX
4ID-93-IIX
4ID-93-IOX
4ID-93-IIX
4IM-92-OIX








DEPTH










26-21


























ROUND









2


















3
PARAMETERS
OFF-SITE LABORATORY. PAL ANALYSES




V
O
A
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X



s
V
O
A








X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X




p
/
p
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X


1
N
O t
R •
. t
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X


1
N 4
O i
R f
. a









X


















X



T
c
L
p
































T
P
H
C
X
X
X
X




X
X

X
X
X
X
X
X














w
AQ
T U
E A
R L
X
X


X
X
X
X


















X
X





T
O
{


X
X






X






X
X
X
X
X
X
X
X
X







E
X
p
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X











X




T
s
s,




X
X
X
X
X
X







X
X
X
X







X




c
/
A.








X
X



















HELD ANALYTICAL



B
T
E
X,































C
H
L
0
J\





























T
P
H
C
/
I
R





























 A:\TABLE36.WPD
  May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25.26. & 27
Page E - 49
Table 36
SUMMARY OF ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







HELD
EVENT
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
SSI
Rl
RI
Rl
Rl
Rl
Rl
Rl
Rl
RI
Rl
Rl
II Rl








MATRIX
Water
Wiler
Water
Water
Water
Soil
Soil
Soil
Water
Water
Soil
Water
Water
Soil
Water
Water
Soil
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water








MEDIUM
Oroundwaier
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Soil
Soil
Soil
Oroundwater
Oroundwater
Soil
Oroundwater
Oroundwater
Soil
Oroundwater
Oroundwater
Soil
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S_Auger
S Auger








EXPLORATION ID
4IM-92-OIX
41M-93-02A
4IM-93-O2A
41M-93-O2B
41M-93-02B
41M-93-02B
4IM-93-02B
4IM-93-02B
4IM-93-03X
4IM-93-03X
4IM-93-03X
4IM-93-04X
4IM-93-04X
4IM-93-04X
41M93-05X
4IM-9345X
4IM-93-05X
SA4IOI
SA4102
SA4I03
SA4I04
SA4I05
SA4I06
SA4I07
SA4I08
SA4I09
SA4IIO
SA4I11
SA4II2








DEPTH





2-4
44
30-32


45-47


5-7


5-7
38-43
41-46
37-42
37-42
40-45
39-44
35-40
19-24
26-31
19-24
36-41
31-43








ROUND
4
3
4
3
4



3
4

3
4

3
4













PARAMETERS
OFF-SITE LABORATORY. PAL ANALYSES




V
O
A
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
















S
V
O
A
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

















p
/
f
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X















1
N
O t
R •
- 1
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X















1
N d
O 1
R *
' •
X
X
X
X
X



X
X

X
X

X
X
















T
c
L
r
































T
p
H
C.































w
A Q
T U
E A
R L

































T
O
C.







X


X


X


X
















E
X
f
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

















T
S
s
X
X
X
X
X



X
X

X
X

X
X

















c
/
\





























HELD ANALYTICAL



B
T
E
X

















X
X
X
X
X
X
X
X
X
X
X
X


c
H
L
O
R

















X
X
X
X
X
X
X
X
X
X
X
X
T
P
H
C
/
1
R





























  A:\TABLE36.WPD
   May 30. 1996

-------
RECORD OF DECISION
South Port Impact Area & AOC 41 Groundwater and AOC* 25.26. A 27
Pate E - SO
TaMeM
SUMMARY OF ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







HELD
EVENT
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl








MATRIX
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
SoU
Soil








MEDIUM
S_Au|cr
SJtaier
S_An|tr
S_Anfer
S_Aut«r
S_Aug*r
3~_Augu
S_Aufer
S.Anger
S_Attfer
SJUiter
S_ Auger
S_Auger
S_An(«r
S_Au(cr
~Soil
Soil
Soil
SoH •
Soil
Son
SoH
Soil
Soil
Soil
Soil
Soil
Soil
Soil








EXPLORATION ID
SA4II3
SA4II4
SA4IIS
SA4I16
SA41I7
SA4IIS
SA4II9
SA4I20
SA4I2I
SA4122
SA4I23
SA4I23
SA4I23
SA4I23
SA4I23
4IB-944IX
41E-944IX
4IE-944IX
4IE-9442X
4IE-94-02X
4IE-94-03X
4IE-94-03X
4IE-94-04X
4IE-94-04X
4IE-9445X
4I&4445X
4IE-94-OSX
4IE-94-06X
4IE-94-06X








DEPTH
40-45
44-49
25-30
4
-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26. & 27
Page E - 51
                                                     Table 36

                                           SUMMARY OF ANALYTICAL PROGRAM
                                       AOC 41 - UNAUTHORIZED PUMPING AREA (SITE A)
...






FIELD
EVENT
Rl
Rl
RI
Rl
RI
RI
RI
RI
Rl
Rl
Rl
RI
RI
Rl
RI
RI
Rl
Rl
RI
RI
Rl
Rl
Rl
RI
Rl
Rl
Rl
RI
1 RI








MATRIX
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Witer
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
. Water
Water
Water
Water








MEDIUM
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Oroundwatcr
Oroundwater
Oroundwater
Ground water
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Oroundwater
Groundwater
Groundwater
Oroundwater
Oroundwater








EXPLORATION ID
4IE-94-07X
4IE-9447X
41E-94-08X
41E-94-08X
41E-94-08X
4IE-94-09X
4IE-94-09X
41M-92-01X
41M-92-01X
4IM-93-02A
4IM-93-02A
4IM-93-02B
4IM-93-02B
4IM-93-02C
4IM-93-02C
4IM93-03X
4IM-93-03X
4IM-93-04X
4IM-93-04X
4IM-93-OSX
4IM-93-OSX
4IM-94-03B
41M-94-03B
41M-94-06X
4IM-94-06X
41M-94-07X
4IM-94-07X
41M-94-08A
41M-94-0SA








DEPTH
4
10
4
10
12
4
9






























ROUND







5
6
5
6
5
6
5
6
5
6
5
6
5
6
S
6
5
6
5
6
5
6
PARAMETERS





V
0
A
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X




S
V
0
A
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
OFF-SITE LABORATORY. PAL ANALYSES




P
/
P































I
N
O t
R e
- t
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X


1
N d
O I
R i
' I







X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X



T
c
L
r
































T
P
H
c
X
X
X
X
X
X
X
























w
AQ
T U
E A
P L







X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X




T
O
t;
X
X
X
X
X
X
X


























E
X
P

































T
S
«}







X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X




c
/
A





























FIELD ANALYTICAL



B
T
E
X































C
H
L
O
P





























T
P
H
C
/
1
R





























 A:\TABLE36.WPD
                                                                                                       May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groandwater and AOCi 25,26, A 27
Page E - 52
1Mb 3*
SUMMARY OP ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







HELD
EVENT
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl

Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
1 Rl
1 Rl








MATRIX
Water
Water
Water
Water
Water
Water
Water
Water
Ufttf**
wMer
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Water
Oaa .
Ou
Oat
Gas
On
Oa*
OM








MEDIUM
Groundwater
Orowdwater
GrowMwatar
OrwmdwaKr
OrotfiMwater
Oraundwaur
QftMmdwflter
_ •
wfvttlMWMCr


Gfoundwvtcr
Oroundwaur
Gtoundwtter
OtomiJwrtitf
n —-.—j -,•*••
UCOUQflwMtr
~_ JM..««-

n J™.Bi««

n J • • •••

Onwndwater
Onmndwater
Oranadwaur
OiMMdwater
fm *
Ufoundwater
T_Probe
T~Pn*«
TJM*
tlProbe
T_Prob«
T~Pwbe
T Probe








EXPLORATION ID
4IM-94-OIB
4IM-94-MB
4IM-94-09A
4IM-94-09A
4IM-94-09B
41M-94-09B
4IM-94-10X
4IM-94-IOX
4IU.O1.I IV
^IWI'T^IiA
4IM-94-I1X
4IM-94-I2X
4IM-94-I2X
4IM-94-I3X
41M-94-I3X
4IM-94-I4X
4IM-94-14X
4IM-944IX
4IM-944HA
4IM-94-02B
4IM-94-03X
4IM-94-04X
4IM-94-05X
TS-OI
TMI
TS-OI
TS-OI
TS-OI
TS-OI
TS-02








DEPTH






















5-7
7-9
9-11
11-13
13-15
19-21
5-7








ROUND





























PARAMETERS
OFF-SITE LABORATORY- PAL ANALYSES




V
O
^
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
















s
V
O
A
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X

















p
/
f































1
N
0 t
R •
- t
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X















1
N 4
O 1
R s
- 1
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
















T
c
L
P
































T
P
H
r































W
AQ
T U
E A
R L
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X

















T
O
r

































E
X
r

































T
S
fj

X
X
X
X
X
X
X

X
X
X
X
X
X
X

















c
/
A,





























FIELD ANALYTICAL



B
T
E
ffi
















X
X
X
X
X
X









c
H
L
0
fl
















X
X
X
X
X
X
x»
x»
x»
x»
x»
X*
x»
T
p
H
C
/
1
R!
















X
X
X
X
X
X







 A:\TABLE36.WPD
  May 30^ 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25.26, & 27
Page E - S3
Table 36
SUMMARY OF ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







FIELD
EVENT
RI
Rl
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI
RI








MATRIX
On
Oat
On
0»
Oat
On
Oat
On
Oaa
On
Gaa
On
On
Oat
Oat
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil








MEDIUM
T_Probe
T_Probe
T~Pro6e
TJ>robe
T~Probe
T_Probe
T~Pn*e
T^Probe
T~Probe
T^Probe
T~Probe
T_Probe
TJProb*
T~Piob«
T~Pfo6e
T~Probe
T~Prob«
T_Probe
TJ>robe
T_Probe
T~Probe
T_Prob«
T_Probe
T_Probe
T_Probe
T_Probe
T~Probe
T_Probe
T~Probe








EXPLORATION ID
TS-03
TS-04
TS-04
TS-04
TS-04
TS-05
TS-06
TSX)7
TS-08
TS-09
TS-IO
TS-II
TS-12
TS-13
TS-I3
TS-OI
' TS-OI
TS-OI
TS-OI
TS-O2
TS-02
TS-03
TS-03
TS-04
TS-04
TS-04
TS-04
TS-05
TS-05








DEPTH
5-7
5-7
10-12
15-17
20-22
5-7
5-7
5-7
5-7
5-7
5-7
5-7
5-7
5-7
5-7
18-20
23-25
30-32
35-37
30-32
35-37
30-32
35-37
18-20
23-25
30-32
35-37
30-32
-2








ROUND





























PARAMETERS
OFF-SITE LABORATORY. PAL ANALYSES




V
0
A
































S
V
0
A.

































P
/
f































1
N
0 t
R •
- t































I
N 4
0 i
R t
- ^
































T
C
L
P
































T
P
H
g































W
A Q
T U
E A
R L

































T
0
^

































E
X
P

































T
S
S.

































C
/
A





























FIELD ANALYTICAL



B
T
E
x^































C
H
L
O
R
X»
X*
X»
x»
X*
X*
x»
X*
X*
X*
X*
X*
X*
X*
x«
X*
x»
X*
x»
x»
x»
x»
x»
x»
X*
X*
X*
x«
x»
T
P
H
C
/
I
11





























  A:\TABLE36.WPD
  May 30, 1996

-------
RECORD OF DECISION
South Port Impact Area A AOC 41 Groundwater and AOCt 25,26, A 27
Page E - 54
TaUttt
SUMMAftY OF ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







HELD
EVENT
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
IRI
Rl
Rl








MATRIX
Soil
Soil
Soil
Soil
Soil
SoU
Soil
Soil
Sod
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
' Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil








MEDIUM
T Prate
TJ«rob«
T_Prob«
T_Prab*
T_Prob«
OH*.
T_Pratw
Tlprobe
T_Prab«
T~Pwbe
TJVooe
T~Ptobe
T~Pn*«
TlProbe
TJ«rob»
TPn*M
S.Borint
S.Borinf
S.Borinf
S.Borint
S.Borint
S.Boriaf
S.Borint
S.Borint
S.Borint
S.Borint
S.Borint
S.Borint
S.Boriot








EXPLORATION ID
TS-M
TS-06
TS-07
TS-07
TS-IO
TS-IO
TS-II
TS-II
TS-12
TS-12
TS-M
TS-14
TS-IS
TS-15
TS-I«
TS-K
4IM-94XOB
4IM-9443B
4IM-94-03B
4IM-944»B
4IM-94-03B
4IM-944UB
4IM-94-03B
4IM-94-03B
4IM-944OB
4IM-944HB
4IM-94413B
4IM-94-03B
4IM-9443B








DEPTH
•2
-2
-2
-2
-2
-2
-2
-2
•2
-2
-2
-2
-2
-2
•2
-2
-2
-2
-2
-2
-2
-2
-2
-2
-2
-2
-2
-2
-2








ROUND





























PARAMETERS
OFF-SITE LABORATORY- PAL ANALYSES




V
0
A,
































S
V
O
A

































P
/
P































1
N
O t
R •
. t































1
N 4
0 1
R t
- *
































T
C
L
P
































T
P
H
jg































W
AQ
T U
E A
R L

































T
O
£

































E
X
P

































T
S
jj

































C
/
A,





























FIELD ANALYTICAL



B
T
E
X
















X
X
X
X
X
X
X
X
X
X
X
X
X


C
H
L
O
J£
X*
X*
X*
X*
x»
x»
X*
x»
x»
x«
X*
X*
x«
x»
x»
x»
X
X
X
X
X
X
X
X
X
X
X
X
X
T
P
H
C
/
1
R





























 A:\TABLE36.WPD
                                                                                                 1996

-------
RECORD OF DECISION
South Post Imoact Area & AOC 41 Groundwater and AOCs 25, 26, & 27 Page E - 55
Table 36
SUMMARY OF ANALYTICAL PROGRAM
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)







HELD
EVENT
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl
Rl








MATRIX
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil








MEDIUM
S. Boring
S. Boring
S. Boring
S. Boring
S. Boring
S. Boring
S. Boring
S. Boring
S. Boring
S.Boring








EXPLORATION ID
4IM-94-07X
4IM-94-08A
4IM-94-08B
4IM-94-09A
41M-94-09B
4IM-94-IOX
4IM-94-11X
4IM-94-I2X
4IM-94-13X
4IM-94-14X








DEPTH
-2
-2
-2
-2
-2
-2
-2
-2
-1
-2








ROUND










PARAMETERS
OFF-SITE LABORATORY- PAL ANALYSES




V
0
Al













S
V
0
A














p
/
p












I
N
o t
R o
. t












I
N 4
O 1
R t
- §













T
C
L
P













T
P
H
£












W
A Q
T U
E A
R f.














T
O
c
X
X
X
X
X
X
X
X
X
X




E
X
P














T
S
$














C
/
A










HELD ANALYTICAL



B
T
E
x












C
H
L
O
R










T
P
H
C
/
I
R










Source: ABB Environmental Services, Inc. 1996

Notes:

VOA = Volatile Organic Analysis
SVOA  = SemiVolatile Organic Analysis
P/P =  Pesticide/PCBs
Inorg.  = Inorganics
TOC = Total Organic Carbon
EX = Explosives
TSS = Total Suspended Solids
TDS « Total Dissolved Solids
TPHC=Total Petrolium Hydrocarbons
WATER QUAL-Sulfate, Alkalinity, Phosphate, Nitrite as Nitrogen.Total Kjeldhal Nitrogen
BTEX=Benrene,Toluene,ethylbenzene,M/P/O-Xylenes
CHLOR=Chlorinated VOCs
TCLP=» Toxicity Characteristics Leachate Procedure
TPHC/IR=Total Petrolium Hydrocarbons by Infared Spectrophotometry
X*=The chlorinated VOCs t-l,2-DCA, C-1.2-DCA, TCE only
     C:\PP A ROD\DEUVER\SPIA\FINALROD\TABLE36.WPD
                                                                        May 30. 1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26. & 27
Page E - 56
                                           Table 37
SOIL GAS FIELD ANALYTICAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Location
ID
TS-01
TS41
TS-01
TS-01
TS-01
TS-01
TS-02
TS-03
TS-04
TS-04
ITS-04
TS-04
TS-05
TS-06
TS-07
1 TS-01
1 TS-09
TS-IO
TS-11
TS-12
TS-13
TS-13
Sample
Depth
5
7
9
11
13
19
5
5
5
10
15
20
5
5
5
5
5
5
5
5
5
5
RL
(PUb)
1
1
1
1
1
1
1
1
I
1
1
1
1
1
1
1
1
1
1
l
1
1
MJ-DCE
(ppb)
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 57
                                     Table 38
TERRAPROBE SOIL FIELD ANALYTICAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Location
ID
TS-01
TS-01
TS-01
TS-01
TS-02
TS-02
TS^B
TS-03
TS-04
TS-04
TS-04
TS-04
TS-05
TS^5
TS-06
TS-06
TS-07
TS-07
TS-10
TS-10
TS-11
TS-11
TS-12
TS-I2
TS-14
TS-14
TS-15
T*C 1 <
Sample
Depth
IS
23
30
35
30
35
30
35
18
.23
30
35
30
35
30
35
30
35
30
35
30
35
30
35
30
35
30
1<
RL
(PPD)
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
t-l>DCE
(ppb)
<1.4
<1J
<1.3
<1.3
<1.2
<1.2
2.2
<1J
<1.4
<1.2
<1J
<1J
2.2
<1.2
<1.4
<1.2
<1.0
<1.2
<1J
<1J
<1.4
4.3
2.6
<1.2
<1.4
<1.2
9.1
1 A
c-l^DCE
(ppb)
<1.4
<1J
<1J
<1.3
<1.2
/o<
Comments II
Soil
SoU
SoU
Soil
SoU
Soil
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
SoU
Tnil
C:\PP & ROD\DEUVER\SP1A\FINALROD\TABLE36.WPD
 M*y30, 1996

-------
 RECORD OF DECISION
 South Post Impact Area & AOC 41 Groundwater and AOCs 25,26. & 27
Page E - 58
Table 38
TERRAFROBE SOIL FIELD ANALYTICAL RESULTS
AOC 41 • UNAUTHORIZED DUMPING AREA (SITE A)
Location
ID
TS-16
TS-16
Sample
Depth
30
30
RL
(ppb)
1
1
M.2-DCE
(ppb)
4.5
1.5
c-U-DCE
(ppb)

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 59
Table 39
TEST PIT SAMPLE FIELD ANALTYCAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Aulyte
tol/U
Vfayl chlorite
1-1.2-DCE
c-l.J-DCE
Benzene
• nefuonuilimfl
Toluene
Ttfjpdiwiofflvc*^
TTlti \j luj 1 1 Jim '
n/p-xylene
o-xyleoe
1.1.2.2-TCA
1 t2*oicnl(MOo^*y^oc
4IE-94-OIX
02FT
rnoinr
<4.4
<2.2
<2.2
<2.2
<2.2
<2.2
<2.2
<2.2
<4.4
<2.2
<4.4
<2.2
41E-M41X
MFT
TP401MF
<4:«
<2.4
<2.4
<2.4
<2.4
<2.4
<2.4
<2.4
<4.B
<2.4
<4.S
<2.4
41E-M4IX
It FT
TT40IKF
<5.4
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
O.4
<2.7
<5.4
<2.7
4IE44-02X
«FT
TP402«r
<4.4
<2.2
<2.2
<2.2
<2.2
<2.2
<2.2
<2.2
<4.4
<2.2
<4.4
<2.2
4IE-M-MX
I»FT
TT402MF
<5.6
<2.»
<2.l
<2.<
<2.R
<2.l
<2.l
<2.t

-------
RECORD OF DECISION
South Port Impact Area & AOC 41 Groundwater and AOCt 25.26. A 27
Page E - 60
TaMe*
SOIL BORING FIELD ANALTYCAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Anlyte
(*«/L)
VbricUori*
t-IO-DCB
C-1.2-DCE
BOOM*
f ^.fcj ,,— . aifc •••
• imuim^Nnmv
Tofam*
TrtncMonetiwae
EdnrbMBM*
mfe-xytaM
o-xrkn*
I.I.2.2-TCA
.^^chWo*^,.
41M9443B
•2FT
SB40302F
<4.2
<2.l
<2.1
<2.l
<2.l
<2.i
<2.I
<2.l
<4.2
<2.1
<4.2
<2.l
41M-94-03B
7FT
SB40307F
<4.l

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 21
Pace E - 61
Table 40 (continued)
SOIL BORING FIELD ANALTYCAL RESULTS
AOC 41 • UNAUTHORIZED DUMPING AREA (SITE A)
Analyte
Gtft/L)
Vinyl chloride
1-1.2-DCE
C-1.2-DCE
Benzene
Trichloroethene
Toluene
Tetrtchloroeihene
Elhybenzene
m/p-xylene
o-xylene
1,1,2,2-TCA
1 ,2-dichlorobenzene
41M-9443B
37 FT
SB40337F
<5.0
<2.5
<2.5
<2.5
5.3
<2.5
<2.5
<2.5
<5.0
<2.5
<5.0
<2.5
41M-94-03B
42 FT
SB40324F
<5.l
<2.5
<2.5
<2.5
8.6
<2.5
<2.5
<2.5
<5.1
<2.5
<5.I
<2.5
41M9443B
47 FT
SB40347F
<5.4
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
<5.4
<2.7
<5.4
<2.7
41M-94-03B
52 FT
SB40352F
<5.l
<2.5
<2.5
<2.5
<2.5
<2.5
<2.5
<2.5
<5.l
<2.5
<5.1
<2.5
41M-94-03B
57 FT
SB40357F
<5.0
<2.5
<2.5
<2.5
<2.5
<2.5
<2.5
<2.5
<5.0
<2.5
<5.0
<2.5
41M-94-03B
62 FT
SB40362F
<5.1
<2.6
<2.6
<2.6
<2.6
<2.6
<2.6
<2.6
<5.1
<2.6
<5.l
<2.6
41M-94-03B
67 FT
SB40367F
<5.1
<2.6
<2.6
<2.6
<2.6
<2.6
<2.6
<2.6
<5.1
<2.6
<5.l
<2.6
  C:\PP & RODVDEUVERVSPIA\FINALROD\TABLE36.WPD
                                                                                                       May 30. 1996

-------
RECORD OF DECISION
South Pott Impact Area & AOC 41 Grotmdwatcr and AOCs 25,26, A 27
Pate E - 62
Takfe41
SOIL BORING orr-SITE LABORATORY ANALYTICAL RESULTS

1 SITE ID:
1 DEPTH:
1 FkMSMpkNMber:

•Annrfc
iBariM
DiijBJ»n
CaldM
ChrMriwN
C*Wl
Copper
•IfMI
|L*«I
jMtfttttu*
•MangMMtt
•Nickel
IpotaMhMi
PU<|M»
•VWMrftaN
Iztee
|rAL 5&IY1I VOLATILE OKUANK.
IjtftMpliHljUiif
|PiM«|Hn«»r«iitliciM
iBriiMflilFfcmraMMieN*
pBb (l-«*yB«S7f) PMkaMc
IchrjvriM
•fliM L^H| ri ii ii 1 1
blMfMMlMW
phcWMdMK
jPjrttM
PAL, VOLATILE mkuANK.^ (M}
il,l,Zll-lt>»cM«r«tilMm
pAcetm*
BJ ftfl A •••• failBilili
potae^
|*TrirMdr»









0





AOC 41 • UNAUTHORIZED DUMPING AREA (SITE A)
4IE-94-41X
XR
EX4IOIM
ooyw
8.83
7.94
<3
259
143
3.07
6.9
7990
4.2
1390
81.1
9.03
331
314
7.8
17.4

<.033
<2I
<.066
<62
<.I2
<.06I
<.06t
<.033
<.033

<.0024

<.00078
0.0084*
41E-9441X
10ft
EX410I09
NA
<2.34 1
542
NA
NA
<6.02
NA
NA
NA
TABLE36.WPD

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Ground water and AOCs 25, 26, & 27
Page E - 63
Tible41
SOIL BORING OFF-SITE LABORATORY ANALYTICAL RESULTS

SITE ID:
DEPTH:
FIcM Sample Number:
Aluminum
Arsenic
^ifafli
leryWant
.sJctam
^iromluni
Cobalt
Copper
ran
Lead
Magnesium
Aanganese
Nickel
Potassium
Sodlom
Vanadhun
Zinc
PAL SEMIVOLATILE ORGANIC
Aeenaphthylene
Beitto|b)Fhranuithene
Bcnzo|k|FInoran(htftc
•Bb (2-ethytheiyl) Phthalate
Chrjsene
•DL«-botyl Phlhalate
FInonnthene
rneiMntlirciw
Gyrene
FORT DEVENS
BACKGROUND
CONCENTRATIONS
IBUUU
19
94
0.81
810
33
4.7
13.5
18000
48
5300
380
14.6
2400
234
32.3
43.9
5 (PC/I)









41E-94-OJX
an
EX410201
ZJMJ
4.68
<5.I8
<.S
318
<4.05
1.96
5.24
3770
2.09
633
70.3
4.97
338
344
<3.39
<8.03
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
4IE-94-02X
9R
EX410209
V4JU
13
30.7
<3
1930
18.1
6.5
14.5
15100
6.5
3490
276
19.5
1300
505
15
34.9
41E-94-02X
9ft
EX4I0209
NA
5.12 I
347
NA
NA
«.02
NA
NA
NA
<18.6
NA
NA
NA
NA
NA
NA
NA

<033
<2I
<.066
<62
<12
<.06I
<.068
<033
<.033
<-033
<.2I
<.066
<62
<.I2
<.06I
<.068
<.033
<033
NA
NA
NA
NA
NA
NA
NA
NA
NA
PAL VOLATILE ORGANICS (fi(/|)
1,1,2,2 -Id nchloroctlune
•Acetone
•Methjrlene Chloride
Toluene
•TrlcMoroflaoramelhuie
OTHER We)
Total Orgudc Carbon
Total Petroleum Hydrocarbons








<.0024
<.017
<.012
<.00078
0.0059*

1330
<28.5
<0024

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Gronndwatcr and AOCs 25.26, & 27
Page E - 64
                                                      MML BORING OFF-SITE LABORATORY ANALYTICAL RESULTS
                                                          AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
SITE ID:
DEPTH:

L^T""
Malta*
InTijBfcm
ICalctaM
|tlMia**M
KttaN
•Copper
ElM
•Lewi
IJVIiipmtan
•MMfMMM
|Ntekei
•PMaMMm
fTllJta*
IvMMtfHN
KhM
gPAL SltMIVOLATILB ORGANIC

Bill •! o|>|n»»f mtfuat
ifftmi^t|naniMrtii«i
I^Bkn •ihiBwiifimhMMk
Ichrj^T' '
IftTftfl BwM^wl ft It aJarf
IrkuiMitiiiiii
HlmMalhiiBi
|PyRM
PAL VOLATILE ORGAN1CS (W
fcjJJ IHHlM»l«llfcWM
l*Acetww
••Matfcvb^ fVnrUb
ll-MMM*
|~Tilihltrtfl»»r»«irttiMH
FORT DEVENS
BACKGROUND
CONCENTRATIONS
IMRI
19
54
0.81
810
33
4.7
13.5
18000
48
3500
380
14.6
2400
234
32.3
43.9
SOIC/K)















41E-944MX
1ft
EX4I04M
NA
2.541
260
NA
NA
<6.02
NA
NA
NA

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25,26. & 27
Page E - 65
T.Me 41
SOIL BORING OFF-SITE LABORATORY ANALYTICAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
SITE ID:
b DEPTH:
FleM Sample Number:
nm


mm
•n
Caktam
Cnfonuuin
Cobalt
Copper
ln»
IJLead
UMifnethmi
HMMiganeM
NNkkd
yPotetfhnn
feodmn
uVuiMUmn
HZmc
||PAL SEMTVOLATILE ORGANIC
lUceiuphthylene
|Beitfo|b)fltK>ranthene
|Bemo(li)Freormnlhene
|«Bb (2-ethyOieiyl) PMhalate
Hchryien*
({•Dl-a-btityt Phthalate
llFhiontrthene
||Pliciuuithrenc
llPjrrene
FORT DEVENS
BACKGROUND
CONCENTRATIONS
IBUW
19
34
0.81
810
33
4.7
13.3
18000
48
3300
380
14.6
2400
234
32.3
43.9
S(pf/f)









41E-94-05X
3ft
ED410S02
NA
< 2.43
268 D
NA
NA
<6.02 D
. NA
NA
NA
33.2 D
NA
NA
NA
NA
NA
NA
NA
4IE-94-QSX
5ft
EX410504
234U
3.8
6.71
<3
163
<4.03

-------
RECORD OF DECISION
South Pott Impact Area A AOC 41 Groundwatcr and AOC» IS, 26, A 27

TaM*4l
SOIL BORING OTF-S1TE LABORATORY ANALYTICAL RESULTS
AOC 41- UNAUTHORIZED DUMTINC AREA (SITE A)
SITE ID:
1 DEfTH:
I n u IT !• MUM! !•


JAmrtr
pMtai
pcfyRtaa
IciMM
IctnariMi
|C*hril
|c«pp*r
DIM
mLttt
•Til Hainan
iMMfMCM
•NkM
•PetaMhM
IsWkMi
c^""
PAL SEMIVOLATILE OK&ANie
lAMMpMhylciie
•BeMomFtaMWitkni*
|niM«|>|n«iii M*IU«I


rM*taril rtMlnhrti
VhwrMthtM
plMMMlhrMI*
pJmM
FORTDEVENS 1 41E-94-06X
BACKGROUND 1 3ft
CONCENTMATIONS 1 EX4IOM3
^ iHfiT^i Btir i nn n m i ^ • BM%^B^^^M>
IWUVI 23 JV
191 3.96
54J lO.t
O.SI
tio
33
4.7
13.5
ItOOO
41
5500
3SO
14.6
2400
234
32J
43.9
(fft)








<.5
29t
<4.05
1.9
3J2
4470
2.2
719
151
4.52
422

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25.26, & 27
Page E-67
Table 41
SOIL BORING OFF-SITE LABORATORY ANALYTICAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
SITE ID:
DEPTH:
Field Sample Namfcer
Aluminum
Anenk
Barhan
Beryflmm
Calchtm
Ckromhm
CobaH
Copper
Iran
Lead
Mafitettam
Manganese
llNlckH
||Potaialinn ,
llsodlmn
liVaiiadhan
||Zlnc
||PAL SEMI VOLATILE ORGANIC
llAcenaphthylene

I iBeRtoi a| r norantnene
||Benxo|kJFl»onuiOieite
•Bb (2-ethyOieiyl) Phthalate
||Ckr}»ene
IpDI-n-batyl Phthalate
llFloonuithene
||Phenanthrene
||pjn**e
FORT DEVENS
BACKGROUND
CONCENTRATIONS
18UUU
19
54
0.81
810
33
4.7
13.5
18000
48
5500
380
14.6
2400
234
32.3
43.9
50*8/8)









4IE-94-09X
4ft
EX4I0904

3.76
10.4
<.S
229
5.17
2.26
3.57
5280
2.54
1100
80.3
5.29
614

-------
RECORD OF DECISION
South Port Impact Area A AOC 41 Groaadwatcr and AOCi 25,26, A 27
Page E - 68
TaMe4l
SOIL BORING OFF-SITE LABORATORY ANALYTICAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
1 SITE ID:
1 DEPTH:
1 FltM S«BpW Nwfctr:

•AnMrte
•BarioM
•ttyBhMi
|T||| 1MB
PCfcfaMrimi
|c*Mt
|c»fpcr
proa
p^t^i
IniUBlrfMM
fctMUMIIir
•MIL.!
P«taMtaN
•MtaB
IVMWMM
khw
|TAI> taini VOLATILE OKCANH.
•ACI •••fcllljll •«
P*T~j>|ria»i Millu HI
JniBMJUrhMIMllllliu
|~Ph Q itlijBiiijI) HiltnVti
•CktyMM
FM • laljl nrtdrti
•FtaMMllMii*
tktWMdMMM
JPfiHM
PVU. VOLATILB UKUAJtlul (pf/
HJJj ijtmfciatmifcMM
I'jUllMM
I*M Ik 1 •• rVaiWi
|r«taHit
|-TiLMiiilhiromtltmn
|DTHER(pf't)

FORT DEVENS
BACKGROUND
OONCXNTRATIONS
IWUU
19
54
O.tl
110
33
4.7
13.5
ItOOO
4t
5500
3W
14.6
2400
234
32.3
43.9
(Iff)









D





41M-93-MB 1 41M-93-03X
3*-32R 1 45-47*
BX4I0232 | BX41U4S
OOUU L>| 4lllU
It Dl 13
29J Ol 23.4
<.3 D
20W D
17.7 D
6.44 D
II. 1 D
12400 D
7.93 D
2900 D
in D
16.9 D
1570 D
497 D
12.4 D
34.3 D
<.s
1200
11.7
5.21
7J9
7900
3.94
2050
147
13.1
159
3tt
1.21
22.4
41M-93-04X
SR
BkW 4«A^Atf
BX41048S
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

<.03J
<2I
<.066
<.62

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25,26, & 27
Page E - 69
Table 41
SOIL BORING OFF-SITE LABORATORY ANALYTICAL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
SITE ID:
DEPTH:
Field Sample Namber.
Aluminum
Anenk
Barhmt
Beryttom
Cakhm
Zfinwnlunt
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
PoUnhon .
Sodium
liVanadMni
IJZlnc
||PAL SEMIVOLATILK UKUAWU
IIAcenaphUiylene
l||l____ IklBI IJlMHttlffMl
Sen«o|k|FhM>ranlhene
• Bb (2-ethylheiyl) PMhabte
Chrytene
•M-n-botyl Fhthalate
Flnoranthene
Phenanlhrene
[Pyrene
FORT DEVENS
BACKGROUND
CONCENTRATIONS
lolnH)
19
54
0.81
810
33
4.7
13.5
18000
48
5500
380
14.6
2400
234
32.3
43.9
S(ug/g)









41M-94-08B
39-41 ft
BX4I8B40
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
[PAL VOLATILE ORGANICS (pg/|)
l,1.2.24etraehloroetliane
•AcHone
•Methytene ChlorMe
Toluene
•Trkhlorofluoromethane
OTHER (pt't)
ToUl Organic Carbon
|[ToUl Petroleum Hydrocarbon*








NA
NA
NA
NA
NA

25*
NA
41M-94-09A
35-37 ft
BX419A3S
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
41M-94-09B
40-42 ft
BX419B40
IN A
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4IM-94-10X
40-42 ft
BX411040
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
41M-94-1IX
34-36 ft
BX411135
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
41M-94-I2X
40-42 ft
BX411240
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4IM-94-I3X
19-21 ft
BX41I320
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
f*r*
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA

RoT
NA
NA
NA
NA
NA
NA

1880
NA
NA
NA
NA
NA
NA

1530
NA
NA
NA
NA
NA
NA

1070
NA
NA
NA
NA
NA
NA

1590
NA
NA
NA
NA
NA
NA

1390
NA
 C:\PP & ROD\DELIVER\SPIA\FINALROD\TABLE36.WPD
                                                                                                    May 30. 1996

-------
RECORD OF DECISION
South Port Impact Area & AOC 41 Gronndwatcf and AOCi 25.26, A 27
                                                                                                      Page E- 70
                                                           SOIL BORING DTP-SITE LABORATORY ANALYTICAL RESULTS
                                                               AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
                                  TORT DBVETIS
                                  BACKGROUND
                                CONCENTRATIONS
                                              19
                                              54
                                             O.tl
                                             tlO
                                              33
                                              4.7
                                             13.5
                                              41
                                             5500
                                             310
                                             14.6
                                             2400
                                             334
                                             32.3
                                             43.9
                                                                      41M-94-14X
                                                                        4-Cft
                                                                       BX411404
         •ALSEMIVOLATILE OKCANICS (M/g)
         'AL VOLATILE OKCANICS (p*0
         urnen (n't)
p«*r
 T«MOifHicCwfcM
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          NA
                                                                                                          N
                                                                                                          N
                                                                                                          N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  N
                                                                                                                  I T
                                                                                                                  N
 C:\PP ft RODM)EUVER\SPIAVnNALROD\TABLE36.WPO

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCs 25.26, & 27
Page E - 71
Table 42
SCREENED AUGER AND EXISTING MONITORING WELL RESULTS
AOC 41 • UNAUTHORIZED DUMPING AREA (SITE A)
Aaalyte
fea/L)
Vinyl chloride
1-1,2-DCE
C-I.2-DCE
Benzene
Trichlotoethene
Toluene
Telnchloroethene
ElhybeiKene
m/p-xyfene
o-xylene
1.1.2,2-TCA
1 ,2-4ichlofobenzene
41M-92-01X
MW401X2W
<4.0
<2.0
<2.0
<2.0
16
<2.0
<2.0
<2.0
<4.0
<2.0
13
<2.0
41M-93-02A
MW402AXW
<4.0
<2.0
<2.0
<2.0
28
<2.0
<2.0
<2.0
<4.0
<2.0
14
<2.0
41M-9342B
MW402B2W

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwatcr and AOCi 25,26, A 27
Pace E - 72
T«Me42(coadMed)
SCREENED AUGER AND EXISTING MONITORING WELL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Anfyte
(MIL)
Vinyl chloride
1-1.2-DCB
C-1.2-DCE
Benzene
TricMofwdieM
Tote"-
Ito-sUo-octeM
Elhrbenzene
nVp-xylnte
o-xrleiM
l.l,2T2-TCA
1,2-dfcUorotwnzene
SA4102
41 FT
SA40241W
<40
<20
<20
<20
«7
<20
<20
<20
<40
<20
<40
<20
SA4103
37 FT
SA4Q337W
<4.0
<2.0
<2.0
<2.0
30
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4104
37 FT
SA40437W
<100
<50
<50
<50
496
<50
<50
<50
TABLE42.WPD

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 73
Table 42 (continued)
SCREENED AUGER AND EXISTING MONITORING WELL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Anatyte
(jtft/L)
Vinyl chloride
1-1,2-DCE
C-1.2-DCE
Benzene
Trichtofoeihene
Toluene
Tetnchloroetbene
Ethybenzene
m/o-xylene
o-xylene
1,1,2,2-TCA
1,2-dichtorobenzene
SA4109
26 FT
SA40926W
<40
<20
<20
<20
48
<20
<20
<20
<40
<20
<40
<20
SA4110
19 FT
SA41019W
<40
<20
<20
<20
54
<20
<20
<20
<40
<20
43
<20
SA4111
36 FT
SA41136W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4H2
38 FT
SA41238W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4113
40 FT
SA41340W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4114
44 FT
SA41444W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4115
25 FT
SA41525W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
 C:\PP ft ROD\DELIVER\SPIA\FINALROD\TABLE42.WPD
  M«y30. 1996

-------
RECORD OF DECISION
South Port Impact Area A AOC 41 Groundwatcr and AOCi 25,26. A 27
Page E - 74
T*Me 42 (eoatimed)
SCREENED AUGER AND EXISTING MONITORING WELL RESULTS
AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
Aulyte
(Ml/L)
VinrlcMofid*
t-i.2-DCE
C-I.2-DCB
Beam.
TiicUoratfMM
TohMM
TMneUoradhcM
Ethybcnzew
ra/p-xyleae
o-xylea*
1,1.2.2-TCA
1 •2'wCllIOtOOftllZMtt
SA4I16
40 FT
SA41640W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4117
45 FT
SA41445W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4118
24 FT
SA41824W
<20
TABLE42.WPD
   May 30t 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27
Page E- 75
Table 42 (continued)
SCREENED AUGER AND EXISTING MONITORING WELL RESULTS
AOC 41 -UNAUTHORIZED DUMPING AREA (SITE A)
Anatyte
(m/L)
Vinyl chloride
M.2-DCE
c-U-DCE
Benzene
Trichloroethene
Toluene
Tetnchloroeihene
Ethybenzene
m/p-xylene
o-xylene
1.1.2.2-TCA
1 ,2-dichlorobenzene
SA4123
SOFT
SA42350W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4123
55 FT
SA42355W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4123
60 FT
SA42360W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4123
65 FT
SA42365W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
SA4123
70 FT
SA42370W
<4.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<2.0
<4.0
<2.0
<4.0
<2.0
  C:\PP ft ROD\DELIVER\SPIA\FINALROD\TABLE42.WPD
                                                                                                         May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groundwatcr and AOCi 25.26, & 27
Page E - 76
                          GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
 C:\PP * ROI>DEUVER\SPIA\FINALROD\TABLE42 WPD
  May 30. 1996

-------
     »RD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 77
                                                  Table 43

                           GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                 AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)

lilt ID:
l»«vl< D.I.:
Dipt:
FhM h.ri. *~»m-.
rALCATIONI/ANIONI (M/LI
run* 1
rt-ffei.
!•••» . 1
•AL METALl (M/U
Mvlt'r'M
A«IMM«|
Ann*
|g-__
•«)«<••
t4i>i>*
Ctoaam
fdfek
«
t,*4
Ms$e«f;ss
Mtqpwt*
M. lx»
iyfcM
t.l.ll-MtrlfctMlfeM
ru*«> D* JMr
Onto T«j«rlfc>ilV
•CVoW<»
•MrikrtrM CM0M
Mnk|MM «•*—.' 1-tMnw
Tf*«MaMM«M /TcMillmrtkM
•T

NA
NA
NA
NA
NA
HA
IIOUN
4IM-9I-C1B
it/it/n
n
MX4IOBI

NA
HA
HA

IMOO
1*1
141
n.i
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tii*
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NA
NA
NA
NA
NA '
inooo
p»
4IM-O-BI
IMfM
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MX4I*MI

INA
HA
NA

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114
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NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

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HA
HA
HA
NA
HA
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MX4IHI!

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NA

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NA
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NA
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NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
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NA
NA
NA
NA

4IM-II-03X
IMIWI
ft
MX4IIIXI

NA
NA
HA

4X»
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t.4
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1100
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4.11
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KB
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4IM-tl-4>K
l«/|4ft>
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MD4IOIXI

NA
NA
NA

IJ» t
101 E
111 11
M E
• • > t
tin c
• 41 t
t> c
in i
1340 t
411 C
>IM C
in c
0.141 t
141 [
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44 D
MM E
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M.1 C

0,001 C

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1 t
0,14 t
E
r
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t
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t
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0.1 t
100 E
0.4) E

NA E
HA C
NA C
NA C
NA C
1400O4 D

IIM-*I-0>X
10/14/ti
It
MO4IOIXI

NA
NA
NA

HI or
in or
15< m
1 Of
1 OF
wn OF
401 OF
» i»
lot in
M.I VI
i M nt
MM nt
m m
ai4i DI
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MM OF
41 OF
9410 OF
II OF
ll.l OF

NA

.... ....

NA

NA
NA
NA
NA
NA
NA
NA
NA
HA
NA
NA
NA
NA

NA
HA
NA
NA
NA
NA
 C:\PP ft ROD\DELIVER\SPIA\FINALROD\TABLE4Z.WPD
  May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groundwater and AOCi 25.26. A 27
                                                                                   Page E - 78
                                  GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                          AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
                                         MHJNII f
                                       i-Uk   4iti
                  »>BMSr^ 4IM

                                                  *°y*»'
                                              4-II-44X I 41k
                                                                             -S2J!
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                                     I4M
                                      44
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II
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441
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II
  C:\IT_*_ROD\DEUVER\SPIA\nNAIJlOt*TABLE4rWPD
                                                                                      Mty MLJ996

-------
RECfTOD OF DECISION
South Post Impact Area & AOC 41 Groundwtter and AOCs 25.26, & 27
Page E - 79
                                                 Table 43

                           GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                 AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)

1*4 ID:
Dtptkt
PhM *..•!. Nn»«rl

*£,.•£:
' AL CAT1ONI/ANIONI tttlU
££, 1
Mh* 1
PAL METAL* (MAI
Alii.iiim
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11.1

11*1/14
N

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1*00*

mot*
44J
in
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MB*
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NA
HA
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4n
4M P
M* P
» P
ID* P
4« P
n p
IM P
4M P
I.M P
IMI P
444 P
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NA
NA
NA

• 141
• IB
• 134 ••
• IP
• i P
111* P
• 4« r
« » p
• M* P
414 f
• I.M t
IM* P
141 P
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NA
NA
NA

• 141 p
• IB P
1.14 P
141 P
1 P
IM* P
441 P
IS P
40* P
111 P
I.M P
MM P
411 P
• 4141 p
Ml P
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41 P
4440 P
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n
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NA
NA
NA

Ml
101
4100 F
401 F
l.m F
U.I F
I.M P
441 F
«J«I F
M.I F
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• 44 F
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1 	 HA" -

NA
PAL I1MIVOLATOJ OKOANXS (M/LI
••«ll-«MWnn rMMM. 1 1-4* 1 HA I* 41 1 NA l« 41 I HA !• 41 1 NA 1 LIU
PAL VOLATILB OftOANICl tm/LI
1.1 -

IMOO
11.*
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NA
40500
11400009

NA
HA
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
41
4M
41
45
41
11
44
1.1
1
41
41
411

1009
• 10
114
NA
M400
KOO*
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
OJ
4M
4SI
41
41
OJ
11
44
1.4
as
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441

BOOO
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111
NA
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tnoMt
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HA
HA
HA
NA
HA
NA
NA
NA
NA
HA
NA
HA

HA
HA
HA
HA
HA
NA
I.I
41
41
0.1
11
44
I.I
11
41
10
• ait

41000
14.4
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HA
turn
 C:\PP & ROD\DEUVER\SPIA\FINALROD\TABLE42.WPD
  M»y30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Gr»«adw«ter «ad AOCi 25.26, A 27
Page E - 80
                           GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
 C:\PP * ROI»DEUVER\SnA\F1NALItOIftTABLE42.WrD
                                                                                                May JO. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26. & 27
Page E - 81
                                                  Table 43.

                           GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                 AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)

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 C:\PP A ROD\DEUVER\SPIA\FINALROD\TABLE42.WPD
  May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groundwater and AOO 25.26. A 27
Page E - 82
                                                  Tabfc43

                           GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                 AOC 41. UNAUTHORIZED DUMPING AREA (SITE A)
     •AL CAT1OM1MMIOH1 Itdlt
     •Mrmlr
 C:\TP * ROD\DEUVER\SMA\FINALRODMABLE42.WrD
  May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 83
                                                  Table 43

                            GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                                 AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)

IK. ID:
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  C:\PP A ROD\DELIVER\SPIA\FINALROD\TABLE42.WPD
  May 30. 1996

-------
RECORD OF DECISION
South Port Impact Area A AOC 41 Greundwater and AOCi 25.26, A 27
Page E - 84
                                                 Table 43

                           GROUNDWATER OFF-STTE LABORATORY ANALYTICAL RESULTS
                                AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)
 C:\PP * ROD\OEUVER\SPUVFINALROD\TABLE42.WPD
  May 30. 1996

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwattr and AOCs 25,26. & 27
Page E-85
                                              Table 43

                         GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                               AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)

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-------
RECORD OF DECISION
South Post Impact Area A AOC 41 Groundwatcr and AOCi 25,26, & 27
Page E - 86
                                              T*fe43

                          GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                               AOC 41 • UNAUTHORIZED DUMPING AREA (SITE A)
                                                       4IM-M-UX
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                                                        MX4IIX1U

-------
RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page E - 87
                                              Table 43

                         GROUNDWATER OFF-SITE LABORATORY ANALYTICAL RESULTS
                              AOC 41 - UNAUTHORIZED DUMPING AREA (SITE A)

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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25,26, & 27
                   RECORD OF DECISION SUMMARY
                   SOUTH POST IMPACT AREA AND
            AREA OF CONTAMINATION 41 GROUNDWATER AND
                AREAS OF CONTAMINATION 25,26, AND 27
                   FORT DEVENS, MASSACHUSETTS
                            APPENDIX F

             GLOSSARY OF ACRONYMS AND ABBREVIATIONS
C:\PP A ROD05ELIVER\SPIA\nNALROD\FROD30.WPD                               M»y30.1996

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This page intentionally left blank

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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groundwater and AOCs 25,26, & 27	


                                             LIST OF ACRONYMS

                    AOCs      areas of contamination
                    AOC 25    The Explosive Ordnance Disposal Range
                    AOC 26    The Zulu Ranges
                    AOC 27    The Hotel Range
                    AWQC     Ambient Water Quality Criteria
                    BRAC      Base Realignment and Closure
                    CAC       Citizens Advisory Committee
                    CERCLA   Comprehensive Environmental Response, Compensation, and Liability Act
                    COPCi     contaminants of potential concern
                    DCE       Dichloroethylene
                    EBS        Environmental Baseline Survey
                    EOD       Explosive Ordnance Disposal
                    FS         Feasibility Study
                    HI         hazard index
                    HMW      Hinkley-Merrimac-Windsor
                    HMX       cyclotetramethylene tetranitramine
                    IAG        Federal Facilities Interagency Agreement
                    ERP        Installation Restoration Program
                    MADEP    Massachusetts Department of Environmental Protection
                    MCL       Maximum Contaminant Level
                    MEP       Master Environmental Plan
                    MMCLs    Massachusetts Maximum Contaminant Level
                    MTJSEPA   Massachusetts Environmental Policy Act
                    NCP        National Contingency Plan
                   NPL        National Priorities List
                    OB/OD      Open burn/open detonation
                   OSWER    Office of Solid Waste and Emergency Response
                   PA         Preliminary Assessment
                   PAH        polycyclic aromatic hydrocarbons
                   PCE        Tetrachloroethylene
                   PETN       pentaerythritol tetranitrate
                   ppb        parts per billion
                   QC         Quality Control
                   RAB        Restoration Advisory Board
                   RCRA      Resource Conservation and Recovery Act
                   RDX        cyclonite
                   RID        reference dose
                   RI          Remedial Investigation
                   RME      Reasonable maximum exposure
                   ROD       Record of Decision
                   SARA       Superfund Amendments and Reathorization Act
                   SAs        study areas
                   SI          Site Investigation
                   SSI        Supplementary Site Investigation
                   SPIA       South Post Impact Area
                   SVOC      Semivolatile organic compounds
                   TAL       Target Analyte List
                   TCA       Trichloroethane
                   TCE       Trichloroethylene
                   TCL       Target Compound List
                   TCLP      Toxicity characteristic leaching procedure
C:\PP & ROD\DELIVER\SPIA\FINALROD\FROD18.WPD
June 18,1996

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 RECORD OF DECISION
 South Post Impact Area and AOC 41 Groimdwater and AOCs 25,26, & 27


                  TNT      trinitrotoluene
                  TOC      total organic carbon
                  TPHC     total petroleum hydroc?-bons
                  TRC      Technical Review Cotnmittee
                  USAEC    U.S. Army Environmental Center
                  USEPA    U.S. Environmental Protection Agency
                  VOC      volatile organic compounds
                  ftg/L      micrograms per liter
C:\PP * ROr*DELrVER\SPlA\nNALROD\FROD18.WPD                                           *«*»».

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