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.
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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-
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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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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,
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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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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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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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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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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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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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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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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
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SCALE
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Fgure 1 South Post Impact Area AOC 25, 26, and 27.
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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
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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
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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
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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
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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27
Page A - 6
UC4MU
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NOT OETCCUD
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•AUBtD WIRC ICHCE
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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.
-------
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.
-------
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
-------
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.
-------
• 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.
-------
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.
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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,
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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.
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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.
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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.
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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
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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
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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
-------
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.
-------
LEGEND
FIGURE 12
SI EXPLORATION LOCftTIONS
AOC 41-UNOUTHORIZED DUMPING AREA (SITE Al
REMEDIAL INVESTIGATION REPORT
FORT DEVENS. MA
-------
FIGURE 13
RI EXPLORATION LOCATIONS
AOC 41-UNAUTHORIZED DUMPING AREA (SITE A) •
REMEDIAL INVESTIGATION REPORT
FORT OEVENS, MA '•
-------
FIGURE M
INTERPRETIVE FIELD ANALYTICAL CONCENTRATION
CONTOURS FOR TRICHLOROETHENE IN OROUNOWATER
AOC 4J-UNAUTHORIZED DUMPING AREA (SITE Al
REMEDIAL INVESTIGATION REPORT
FORT DEVENS. MA
-------
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.).
C:\0102\DELIVER\SPtA\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 - 6
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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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25, 26, & 27 Page C - 7
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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RECORD OF DECISION
South Post Impact Area & AOC 41 Groundwater and AOCs 25,26, & 27 Page C - 8
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
C:\OI02\DEUVER\SP1A\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 - 9
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].
C:\0102\DELIVER\SPIA\FIN ALROD\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 -10
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",
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 - 11
[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
C:\0102\DEUVER\SPIA\FIN ALRODMNDEX2&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 -12
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.]
C:\0102\DELIVER\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 - 13
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.
C:\0102\DELIVER\SP1A\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 -14
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.
C:\0102\DELITOR\SPIA\nNAIJlOD\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 - 15
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,
C:\0102\DELIVER\SPlA\FIN ALRODMNDEX2&7.DOC July. 1996
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RECORD OF DECISION
South Post Impact Area & AOC 41 Ground water and AOCs 25,26, & 27 Page C -16
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
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 - 17
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
-------
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
-------
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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Since 1967
50 Franklin Street
Boston, Massachusetts 02110
Phone (617) 426-2432
Outside MA 1-800-546-WONG
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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
Upon request, ASCII and/or Min-U-Script with Word Index will be provided
at no charge to the moving party when ordered at the time of the proceedings
Remarks: All Transcripts are stored on Optical Disk for your future litigation
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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
8
9
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10
11
12
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24
DORIS 0. WONG ASSOCIATES
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1
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3
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6
7
B
9
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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
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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
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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.
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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
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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
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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
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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
-------
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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 E
TABLES
C:\PP A ROD\DEUVER\SPIA\FINALIK>D\FROD30.WPD Mmy30.1996
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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:
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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)
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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:
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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
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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)
SlulD:
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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
tanvtt
M
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-------
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)
*l« ID:
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-------
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 F
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
C:\PP A ROD05ELIVER\SPIA\nNALROD\FROD30.WPD M»y30.1996
-------
This page intentionally left blank
-------
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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