Superfund Record of Decision Fort Devens Area of Contamination 63ax Fort Devens MA


                                    EPA/ROD/R01-97/159
                                    1997
EPA Superfund
     Record of Decision:
     FORT DEVENS
     EPA ID: MA7210025154
     OU10
     FORT DEVENS, MA
     09/29/1997

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EPA/541/R-97/159



                                 RECORD OF DECISION
                             AREA OF CONTAMINATION 63AX
                        DEVENS RESERVE FORCES TRAINING AREA
                               DEVENS, MASSACHUSETTS

                                  SEPTEMBER  1997

                                 RECORD OF DECISION
                             AREA OF CONTAMINATION 63AX
                                    DEVENS RFTA
                               DEVENS, MASSACHUSETTS

                                 TABLE OF CONTENTS

    Section                        Title                      Page  No

    DECLARATION FOR THE RECORD OF DECISION  	D-l

    DECISION SUMMARY 	  1

     I.  SITE NAME, LOCATION, AND DESCRIPTION 	  1

     II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  1
         A. Land Use and Response History  	  1
         B. Enforcement History  	  4

     III.  COMMUNITY PARTICIPATION 	  4

     IV.  SCOPE AND ROLE OF THE RESPONSE ACTION  	  6

     V.  SUMMARY OF SITE CHARACTERISTICS 	  6
        A. Soils  	  7
        B. Groundwater 	  8

     VI.  SUM1MARY OF SITE RISKS  	11

     VII.  DOCUMENTATION OF NO SIGNIFICANT CHANGES  	15

     VIII. STATE ROLE 	15

    APPENDICES
    APPENDIX A - FIGURES
    APPENDIX B - TABLES
    APPENDIX C - RESPONSIVENESS SUMMARY
    APPENDIX D - ADMINISTRATIVE RECORD INDEX
    APPENDIX E - DECLARATION OF STATE CONCURRENCE
    APPENDIX F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Area of Contamination 63AX
Devens Reserve Forces Training Area
Devens, Massachusetts

STATEMENT OF PURPOSE AND BASIS

This decision document presents the U.S. Army's selected remedial action for Area of Contamination (AOC)
63AX at the Devens Reserve Forces Training Area (RFTA), Devens, Massachusetts. It was developed in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980 as amended, 42 USC °° 9601 et seg. and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) as amended, 40 CFR Part 300. The following have been
delegated the authority to approve this Record of Decision: The Devens Base Realignment and Closure
(BRAG) Environmental Coordinator; the Devens RFTA Installation Commander, and the Director of the Waste
Management Division, U.S. Environmental Protection Agency New England.

This decision document is based on the Administrative Record developed in accordance with Section 113 (k)
of CERCLA. The Administrative Record is available for public review at the Devens BRAG Environmental
Office, 30 Quebec Street, Devens, Massachusetts, and at the Ayer Town Hall, Main Street, Ayer,
Massachusetts. The Administrative Record Index (Appendix D of this Record of Decision) identifies each of
the items considered during selection of the remedial action.

DESCRIPTION OF THE SELECTED REMEDY

The Army's selected remedy at AOC 63AX is No Further Action. AOC 63AX poses no unacceptable risks to
human health or the environment. Further, previous removal actions have eliminated underground storage
tanks (USTs) and contaminated soils that would otherwise be a continuing source of groundwater
contamination.

STATE CONCURRENCE

The Commonwealth of Massachusetts has concurred with the selected remedy. Appendix E of this Record of
Decision contains a copy of the Declaration of State Concurrence.

DECLARATION

The selected remedy is consistent with CERCLA and, to the extent practicable, the NCP. Based on previous
removal actions at AOC 63AX and the results of the remedial investigation, no further action is necessary
to ensure protection of human health and the environment.

Because previous removal of the waste oil UST and the 5,000 gallon gasoline UST removed the sources of
contamination at AOC 63AX, further engineering controls are not necessary to prevent unacceptable
exposure to hazardous substance. Therefore, five-year site-reviews will not apply to this action.

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The foregoing represents the selection of a remedial action by the U.S. Department of the Army and the U.
S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts Department
of Environmental Protection.

Concur and recommend for immediate implementation:

U.S. DEPARTMENT OF THE ARMY

The foregoing represents the selection of a remedial action by the U.S. Department of the Army and the U.
S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts Department
of Environmental Protection.

Concur and recommend for immediate implementation:

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DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION

This Record of Decision addresses past releases to soil and groundwater at Area of Contamination (AOC)
63AX at Devens, Reserve Forces Training Area (RFTA) , Devens Massachusetts. The Devens. RFTA, formerly
Fort Devens, is located in the Towns of Ayer and Shirley (Middlesex County) and Harvard and Lancaster
(Worcester County), approximately 35 miles northwest of Boston, Massachusetts.

AOC 63AX is located north and near the western end of Patton Road on the southern portion of what was
formerly the Main Post at Fort Devens (Figure 1 in Appendix A). AOC 63AX consists of a large paved and
fenced area, Building 2517, currently used as a warehouse by the U.S. Bureau of Prisons, and Building
2514 which is abandoned. Contamination at AOC 63AX is attributed to a previously removed 1,000-gallon
waste oil underground storage tank (UST) adjacent to Building 2517 and a previously removed 5,000-gallon
gasoline UST adjacent to Building 2514 (Figure 2 in Appendix A).

A more complete description of AOC 63AX can be found in Section 5.0 of the remedial investigation (RI)
report.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

Fort Devens was established in 1917 as Camp Devens, a temporary training camp for soldiers from the New
England area. In 1931, the camp became a permanent installation and was renamed Fort Devens. Throughout
its history, Fort Devens served as a training and induction center for military personnel, and as a unit
mobilization and demobilization site. All or portions of this function occurred during World Wars I and
II, the Korean and Vietnam conflicts, and operations Desert Shield and Desert Storm. During World War II,
more than 614,000 inductees were processed and Fort Devens reached a peak population of 65,000.

The primary mission of Fort Devens was to command, train, and provide logistical support for
non-divisional troop units and to support and execute Base Realignment and Closure (BRAG) activities. The
installation also supported the Army Readiness Region and National Guard units in the New England area.

Fort Devens was identified for cessation of operations and closure under Public Law 101-510, the Defense
Base Realignment and Closure Act of 1990, and was officially closed in September 1996. Portions of the
property formerly occupied by Fort Devens were retained by the Army for reserve forces training and
renamed the Devens RFTA. Areas not retained as part of the Devens RFTA were, or are in the process of
being, transferred to new owners for reuse and redevelopment. AOC 63AX is located in an area planned for
transfer to the Massachusetts Government Land Bank for commercial/industrial development. The Devens
Reuse Plan designates the future use of the area as an Innovation and Business Technology Zone. Under
this classification, potential future uses could include office buildings, light industry, and academic
and institutional facilities.

The following items summarize the history of AOC 63AX

• 1940s. Building 2514 is thought to have served as a pumphouse for an historic gas station
which supported a vehicle motor pool during World War II.

• Late 1940s or early 1950s. Motor pool operations were discontinued at Building 2514. No
records are available on the decommissioning of this motor pool.

• 1966. Building 2517 was built to serve as a tactical eguipment repair shop. Subseguently,
Building 2517 served as a motor repair shop, dispatch office for the Office of Logistics,
and recreational vehicle storage facility.

• 1980. A 1,000-gallon waste oil UST was installed along the southwestern side of Building
2517.

1989. The Building 2517 waste oil UST and 100 cubic yards of contaminated soil were
removed as part of a Fort Devens initiative to replace waste oil USTs with aboveground
storage tanks. Because residual total petroleum hydrocarbon compounds (TPHCs) were observed
in soils at the bottom of the excavation, the site was recommended for additional
investigation.
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• 1992. The historic gas station associated with Building 2514, designated Study Area (SA)
43K, was investigated as part of the Groups 2 and 7 Site Investigation (SI). During the SI,
the 5,000-gallon gasoline UST was located and subseguently removed along with approximately
140 tons of contaminated soil. Soil sampling and field analysis performed following the UST
removal, indicated no detectable concentrations of benzene, ethylbenzene, toluene, xylene
(BTEX), or TPHCs in subsurface sod around the excavation. Based upon these findings, SA 43K
was recommended for No Further Action. The No Further Action Decision Document was signed by
USEPA and MADEP in January 1995.

• 1993. Buildings 2517 and 2514 were investigated as part of Area Reguiring Environmental
Evaluation (AREE) 610. A suspected drywell associated with Building 2514 and the former
waste oil UST associated with Building 2517 were identified as potential sources of
contamination.

1994. The former waste oil UST associated with Building 2517 was designated AREE 63AX, and a
field investigation was performed. To evaluate soil exposure risks under current and
potential future land-use conditions, the Army compared soil sample analytical data to
Massachusetts Contingency Plan (MCP) Method 1 S-2/GW-2 standards and identified no
exceedances. Because several volatile organic compounds (i.e., benzene, trichloroethene, and
1,1-dichloroethene) in groundwater samples exceeded federal drinking water Maximum
Contaminant Levels (MCLs) and MCP groundwater standards, an RI was recommended.

• 1995. The former waste oil UST associated with Building 2517 was designated AOC 63AX, and an
RI was performed. During the RI, the former gasoline UST associated with Building 2514 was
identified as a potential contaminant source and subseguently became part of AOC 63AX The
remedial investigation did not identify volatile organic compounds in groundwater at
concentrations exceeding federal or Massachusetts standards. No evidence of the drywell was
found during the RI.

B. Enforcement History

On December 21, 1989, Fort Devens was placed on the National Priorities List under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendments
and Reauthorization Act (SARA) to evaluate and implement response actions to cleanup past releases of
hazardous substances, pollutants, and contaminants. A Federal Facility Agreement to establish a
procedural framework for ensuring that appropriate response actions are implemented at Fort Devens was
developed and signed by the Army and the U.S. Environmental Protection Agency (USEPA) Region I on May 13,
1991, and finalized on November 15, 1991. AOC 63AX is considered a subsite of the entire installation.

In 1995, the U.S. Department of Defense, through the U.S. Army Environmental Center (USAEC), initiated an
RI for AOC 63AX, and the RI report was issued in February 1997. The purpose of the RI was to determine
the nature and extent of contamination at AOC 63AX, assess human health and ecological risks, and assess
whether additional response actions were necessary. Based on the results of the risk assessment, the
Army, along with the USEPA and MADEP, concluded that AOC 63AX did not present unacceptable risks to human
health or the environment and that a feasibility study to evaluate remedial action alternatives was not
needed.

The Proposed Plan detailing the Army's plan for No Further Action at AOC 63AX was issued in April 1997
for public comment. Technical comments presented during the public comment period are included in the
Administrative Record. Appendix C, the Responsiveness Summary, contains a summary of these comments and
the Army's responses, and describes how these comments affected the No Further Action decision.

III. COMMUNITY PARTICIPATION

The Army has held regular and freguent information meetings, issued fact sheets and press releases, and
held public meetings to keep the community and other interested parties informed of activities at AOC
63AX.

In February 1992, the Army released, following public review, a community relations plan that outlined a
program to address community concerns and keep citizens informed about and involved in remedial
activities at Fort Devens. As part of this plan, the Army established a Technical Review Committee (TRC)
in early 1992. The TRC, as reguired by SARA Section 211 and Army Regulation 200-1, included
representatives from USEPA, USAEC, Fort Devens, Massachusetts Department of Environmental Protection
(MADEP), local officials, and the community. Until January 1994, when it was replaced by the Restoration
Advisory Board (RAB), the committee generally met guarterly to review and provide technical comments on
schedules, work plans, work products, and proposed activities for the SAs at Fort Devens. The SI, AREE,
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and RI reports, Proposed Plan; and other related support documents were all submitted to the TRC or RAB
for their review and comment. The Community Relations Plan was updated to address Base Realignment and
Closure issues and reissued in May 1995.

The Army, as part of its commitment to involve the affected communities, forms a RAB when an installation
closure involves transfer of property to the community. The Fort Devens RAB was formed in February 1994
to add members of the Citizen's Advisory Committee (CAC) to the TRC. The CAC had been established
previously to address Massachusetts Environmental Policy Act/Environmental Assessment issues concerning
the reuse of property at Fort Devens. The RAB initially consisted of 28 members (15 original TRC members
plus 13 new members) representing the Army, USEPA Region I, MADEP, local governments, and citizens of the
local communities. The RAB currently consists of 19 members. It meets monthly and provides advice to the
installation and regulatory agencies on the Devens RFTA cleanup programs. 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 that are open to the
public.

On June 3, 1997, the Army issued the Proposed Plan, to provide the public with a brief explanation of the
Army's proposal for No Further Action at AOC 63AX The Proposed Plan also described the opportunities for
public participation and provided details on the upcoming public comment period and public meetings.

During the week of June 2, 1997, the Army published a public notice announcing the Proposed Plan and
public information meeting in the Lowell Sun, Worcester Telegram and Gazette, Fitchburg-Leominster
Sentinel Enterprise, and the Public Spirit. The Army also made the Proposed Plan available to the public
at the public information repositories at the Davis Public Library at the Devens RFTA, the Ayer Public
Library, the Hazen Memorial Library in Shirley, the Harvard Public Library, and the Lancaster Public
Library.

From June 3 through July 3, 1997, the Army held a 30-day public comment period to accept public comments
on the Proposed Plan and on other documents released to the public. On June 25, 1997, the Army held an
informal public information meeting at Devens RFTA to present the Army's Proposed Plan to the public and
to provide the opportunity for open discussion concerning the Proposed Plan. The Army also accepted
verbal or written comments from the public at the meeting. A transcript of this meeting, public comments,
and the Army's response to comments are included in the attached Responsiveness Summary (see Appendix C).

All supporting documentation for the decision regarding AOC 63AX is contained in the Administrative
Record for review. The Administrative Record is a collection of all the documents considered by the Army
in choosing the plan of action for AOC 63AX. On June 25, 1997, the Army made the Administrative Record
available for public review at the Devens BRAG Environmental Office, and at the Ayer Town Hall, Ayer,
Massachusetts. An index to the Administrative Record is available at the USEPA Records Center, 90 Canal
Street, Boston, Massachusetts and is provided as Appendix D.

IV. SCOPE AND ROIiE OF THE RESPONSE ACTION

This No Further Action decision addresses soil and groundwater contamination attributed to historical
releases from the former waste oil UST at Building 2517 and the former gasoline UST at Building 2514. The
waste oil UST and approximately 100 cubic yards of contaminated soil were removed in 1989. The gasoline
UST and approximately 140 tons of contaminated soil were removed in 1992. No other sources of
contamination have been identified at AOC 63AX. No evidence of a suspected drywell associated with
Building 2514 was found during the RI.

V. SUMMARY OF SITE CHARACTERISTICS

Section 5.0 of the RI report, February 1997, contains an overview of SI, AREE, and RI activities at AOC
63AX. Significant findings of the RI are summarized in the following subsections.

A. Soils

1) Building 2517 Waste Oil Underground Storage Tank

During the RI, subsurface soils in the vicinity of the waste oil UST excavation were characterized by
collecting 46 field-analytical samples from 15 TerraProbe SM points and 5 soil samples from 3 soil
borings. The results of field analysis were used to assess whether residual contaminants from the former
waste oil UST were present in subsurface soil and to provide a basis for locating subsequent soil borings
and monitoring wells from which to collect confirmatory samples for off-site analysis for BTEX, selected
halogenated compounds, and TPHC.
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A total of nine soil samples were collected from three soil borings for off-site analysis for Project
Analyte List (PAL) volatile organic compounds (VOCs), PAL semivolatile organic compounds (SVOCs), PAL
inorganics, and TPHC. The SVOCs fluoranthene (0.13 micrograms per gram [Ig/g]), phenanthrene (0.067
Ig/g) , and pyrene (0.051 Ig/g) were detected in the 6 feet below ground surface (bgs) sample from boring
AXB-95-05X, and TPHC (123 Ig/g) was detected in the 4 feet bgs sample from boring AXB-95-04X.
Bis(2-ethylhexyl)phthalate (up to 2.9 Ig/g) and toluene (up to 0.00 16 Ig/g) were reported in samples
from borings AXB-95-01X and AXB-95-04X, but were attributed to laboratory contamination. The waste oil
UST identified as the most likely source of this contamination was removed along with approximately 100
cubic yards of soil in 1989.

2) Building 2514 Gasoline Underground Storage Tank

Subsurface soil near and downgradient of Building 2514 and the former location of the 5,000-gallon
gasoline UST was characterized by collection of 29 field-analytical samples from 11 TerraProbe SM points.
Field analysis consisted of BTEX, selected halogenated compounds, and TPHC. The results of field analysis
were used to delineate contaminant distribution, assess potential sources, and provide a basis for
locating subseguent soil borings from which to collect confirmatory samples for off-site analysis.

Seven soil samples (including one duplicate) were collected from two soil borings, (AXB-95-02X and
AXB-95-03X) for off-site analysis for PAL VOCs, PAL SVOCs, PAL inorganics, and TPHC The SVOC naphthalene
was detected at 0.18 Ig/g in the 4 feet bgs sample from boring AXB-95-03X, and TPHC was detected in five
samples. The two highest TPHC concentrations, 8,840 and 885 Ig/g, were observed in the 4- and 6-feet bgs
samples, respectively, from boring AXM-95-02X. The maximum TPHC concentration in samples from boring
AXB-95-03X was 136 Ig/g in the 4-feet bgs sample. Toluene, acetone, trichlorofluoromethane, and bis (2-
ethylhexyl)phthalate were also reported in samples from borings AXB-95-02X and AXB-95-03X, but were
attributed to laboratory contamination.

One confirmatory soil sample was collected at 3 feet bgs from one of four test pits dug in an effort to
locate the suspected drywell at Building 2514. Twelve SVOCs at individual concentrations up to 0.91 Ig/g
were reported in the sample. The reported TPHC concentration was 413 Ig/g. No evidence of the drywell was
found in either geophysical or intrusive investigations; it was concluded that the reported drywell did
not exist.

B. Groundwater

Preliminary characterization of groundwater downgradient of Buildings 2514 and 2517 was accomplished by
field analysis of groundwater samples from 17 TerraProbe SM points. Field analysis consisted of BTEX,
selected halogenated compounds, and gasoline range organics. The results of field analysis were used to
delineate horizontal contaminant distribution and aid in placement of monitoring well locations.

Seven new monitoring wells were installed to supplement the three existing monitoring wells. Two rounds
of groundwater samples were collected from all ten monitoring wells and analyzed for PAL VOCs, PAL SVOCs,
total and dissolved PAL inorganics, pesticides, polychlorinated biphenyls (PCBs), TPHC, and several water
guality parameters.

The VOCs ethylbenzene, chloroform, and dichloromethane were reported at low concentrations (maximum value
of 2.9 micrograms per liter [Ig/L]) in three Round 1 samples. The presence of chloroform was attributed
to laboratory contamination. Based on laboratory guality assurance/guality control samples, other Round 1
VOC results were considered estimated and possibly biased high. Toluene was reported in five Round 2
samples at concentrations of up to 1.5 Ig/L.

One SVOC, 2-methylnaphthalene at 3.9 Ig/L, was detected in one Round 1 sample, and two SVOCs,
diethylphthalate and bis(2-ethylhexyl)phthalate, were detected in a total of four Round 1 and Round 2
samples. The presence of both phthalate compounds was attributed to laboratory contamination.

Several inorganic analytes were detected at concentrations above background in unfiltered groundwater
samples. These analytes were aluminum, arsenic, barium, calcium, copper, iron, lead, magnesium,
manganese, nickel, potassium, sodium, and zinc. Concentrations of aluminum, barium, lead, and zinc
dropped to below background in filtered samples. Arsenic exceeded its federal drinking water MCL in the
Round 1 sample from monitoring well 63AX-94-01, and iron and manganese exceeded federal secondary
drinking water guidelines in the majority of samples. Aluminum exceeded the federal secondary drinking
water guideline in the majority of unfiltered samples and appeared associated with the presence of
suspended soil particles in the samples.

The highest concentrations of arsenic were detected in monitoring wells 63AX-94-01 and 63AX-94-02 which
were located approximately 50 and 75 feet, respectively, downgradient of the waste oil UST excavation. An
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arsenic concentration of 130 Ig/L was reported for the unfiltered Round 1 sample from monitoring well
63AX-94-01, while the filtered sample had a concentration of 79.4 Ig/L. Both values exceeded the MCL of
50 Ig/L. Arsenic concentrations in unfiltered and filtered Round 2 samples from monitoring well
63AX-94-01 were 47.5 and 46.8 Ig/L, respectively. The maximum arsenic concentration in samples from
monitoring well 63AX-94-02 was 30.1 Ig/L in the unfiltered Round 2 sample. The maximum detected arsenic
concentration in the remaining monitoring wells, including wells downgradient of 63AX-94-01 and
63AX-94-02, was 17.1 Ig/L. Arsenic is not known to have been a constituent of the materials stored in the
waste oil UST, and the high arsenic concentrations of monitoring wells 63AX-94-01 and 63AX-94-02 may be
attributable to secondary mobilization caused by reducing conditions in the aguifer as a result of
aerobic degradation of fuel-related compounds.

Concentrations of iron varied widely among AOC 63AX monitoring well samples; however, the highest
unfiltered and filtered concentrations were observed in monitoring wells 63AX-94-01 and 63AX-94-02
(21,600 and 10,800 Ig/L, respectively). Similar to arsenic, the high iron concentrations of monitoring
wells 63AX-94-01 and 63AX-94-02 may be attributable to secondary mobilization caused by reducing
conditions in the aguifer as a result of aerobic degradation of fuel-related compounds.

Concentrations of manganese also varied widely, but were greatest at monitoring wells further down- and
cross-gradient than monitoring wells 63AX-94-01 and 63AX-94-02. Although less well defined than for
arsenic and iron, high manganese concentrations at AOC 63AX may also be attributable to secondary
mobilization caused by reducing conditions in the aguifer as a result of aerobic degradation of
fuel-related compounds.

No TPHC, pesticides, or PCBs were reported in the RI off-site laboratory groundwater samples.

The overburden at AOC 63AX consists of three to five feet of gravelly-sand and silty-sand overlying
increasingly dense basal till. This till extends to at least 27.7 feet below ground surface, the exact
depth is not known because bedrock was not encountered during explorations at AOC 63AX. The water table
occurs in the overburden at AOC 63AX at a depth of approximately six to eight feet below ground surface.
Groundwater flow in the overburden is primarily northwest to southeast across the site. Although flow
from northeast to southwest has also been observed, it is interpreted to be a transitory condition
resulting from the paved yard which inhibits groundwater recharge. Groundwater velocity is moderately
slow with a calculated maximum of 0.35 feet per day and a mean of 0.08 feet per day, consistent with the
glacial till observed at the site. Upward vertical gradients were observed during each groundwater
elevation measurement round at AOC 63AX. Bedrock aguifer characteristics were not monitored during the
RI. Decreasing hydraulic conductivity with depth appears to serve as an aguitard between the watertable
aguifer and deeper overburden and bedrock aguifer. Because of these upward gradients and low groundwater
velocities, groundwater transport is not considered a major contaminant migration pathway.

Groundwater at Devens RFTA is designated Class 1 under Massachusetts regulations. Class 1 groundwaters
consist of groundwaters "found in the saturated zone of unconsolidated deposits or consolidated rock and
bedrock and are designated as a source of potable water supply". However, because of the low permeability
at AOC 63AX, the aguifer is not considered capable of producing a sufficient guantity of water for use as
a water supply.

VI. SUMMARY OF SITE RISKS

The risk assessment contained in the RI report evaluates the probability and magnitude of potential human
health effects associated with exposure to contaminated media at AOC 63AX. 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 non-carcinogenic risks. A
detailed discussion of the human health risk assessment approach and results is presented in Section 9.0
of the RI report.

Eight soil chemicals of potential concern and six groundwater chemicals of potential concern, listed in
Tables 1 and 2 in Appendix B of this Record of Decision, were selected for evaluation in the human health
risk assessment of the RI report. These chemicals of potential concern were selected to represent
potential site-related hazards based on toxicity, concentration, freguency of detection, mobility, and
persistence in the environment. A summary of the health effects of each of the chemicals of potential
concern can be found in the risk assessment detailed in Section 9.0 of the RI report and associated
appendices.
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Potential human health effects associated with exposure to the chemicals of potential concern were
estimated quantitatively or qualitatively throuqh the development of several hypothetical exposure
pathways associated with current and anticipated future land use. These pathways, listed below, were
developed to reflect the potential for exposure to hazardous substances based on the present uses,
potential future uses, and location of the site. A more detailed description can be found in Subsection
9.3.1 of the risk assessment.

Current and Future Land Use

• utility/maintenance worker exposure throuqh incidental inqestion of subsurface soil and
inhalation of volatile orqanic compounds from soil and qroundwater which could collect in
excavations

• construction worker exposure throuqh incidental inqestion of subsurface soil, inhalation of
volatile orqanic compounds from soil and qroundwater which could collect in excavations, and
inhalation of particulates from soil

Future Land Use

• Commercial worker exposure throuqh inqestion of site derived qroundwater for the followinq
four pathways:

• unfiltered qroundwater from hot-spot monitorinq wells 63AX-94-01 and 63AX-94-02;

• filtered qroundwater from hot-spot monitorinq wells 63AX-94-01 and 63AX-94-02;

• unfiltered qroundwater excludinq hot-spot monitorinq wells 63AX-94-01 and 63AX-94-02;
and

• filtered qroundwater excludinq hot-spot monitorinq wells 63AX-94-01 and 63AX-94-02.

Because the area surroundinq AOC 63AX is paved and provides neither shelter nor foraqinq opportunities
for wildlife, the RI report concluded that potential ecoloqical receptors and exposure pathways were not
present, and did not evaluate ecoloqical risks associated with exposure to soil and qroundwater.

Excess lifetime cancer risks were determined for each exposure pathway by multiplyinq the exposure level
with the chemical-specific cancer slope factor. Cancer slope factors have been developed by USEPA from
epidemioloqical or animal studies to reflect a conservative "upper bound" of the risk posed by
potentially carcinoqenic chemicals. That is, the true risk is unlikely to be qreater than the risk
predicted. The resultinq risk estimates are expressed in scientific notation as a probability (e.g., 1 x
10 -6 for 1/1,000,000) and indicate (usinq this example), that an averaqe individual is not likely to
have qreater than a one in a million chance of developinq cancer over 70 years as a result of
site-related exposure to the chemical at the stated concentration. Current USEPA practice considers
carcinoqenic risks to be additive when assessinq exposure to a mixture of hazardous substances.

The hazard index (HI) was also calculated for each exposure pathway as a measure of the potential for
non-carcinoqenic health effects. The HI is the sum of the hazard quotients for individual chemicals with
similar exposure pathways and toxic endpoints. A hazard quotient is calculated by dividinq the exposure
level by the reference dose (M) or other suitable benchmark for non-carcinoqenic health effects for each
individual chemical. RfDs have been developed by USEPA to protect sensitive individuals over the course
of a lifetime, and they reflect a daily exposure level that is likely to be without an appreciable risk
of an adverse health effect. RfDs are derived from epidemioloqical 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 sinqle value (e.g., 0.3) indicating the ratio of the stated exposure to the RfD
value (in this example, the exposure as characterized is approximately one third of an acceptable
exposure level for the qiven chemical). The hazard quotient is only considered additive for chemicals
that have the same or similar toxic endpoint. For example, the hazard quotient for a chemical known to
produce liver damaqe should not be added to a second whose toxic endpoint is kidney damaqe.

Table 3 in Appendix B summarizes the carcinoqenic and non-carcinoqenic risks for soil and qroundwater
under the evaluated current and future land use conditions. Review of that table shows that estimated
excess carcinoqenic risks for exposure to soil were less than the USEPA threshold risk level of 1 x 10 -6
under current and future land use conditions. Similarly, potential noncancer risks did not exceed the
USEPA HI threshold value of 1.

There is no current use of, or exposure to, qroundwater at the site, therefore the risk assessment
evaluated potential risks associated with inqestion of qroundwater by a future commercial/industrial
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worker. Arsenic was the only detected carcinogenic chemical, and the potential carcinogenic risks are
wholly attributable to arsenic. Review of Table 3 in Appendix B shows that potential excess cancer risks
associated with commercial worker ingestion of unfiltered and filtered groundwater with the maximum
detected concentrations of arsenic at monitoring wells 63AX-94-01 and 63AX-94-02 were 7 x 10 -4 and 4 x
10 -4, respectively, which exceed the USEPA target risk range of 1 x 10 -4 to 1 x 10 -6. However,
potential cancer risks associated with worker ingestion of unfiltered and filtered groundwater, given the
average detected concentrations of arsenic at these two monitoring wells, were 6 x 10 -5 and 4 x 10 -5,
respectively, which are within the USEPA target risk range of 1 x 10 -4 to 1 x 10-6. Potential noncancer
risks associated with monitoring wells 63AX-94-01 and 63AX-94-02 ranged from an HI of 1 to an HI of 6.

The potential cancer risks associated with exposure to site-wide groundwater (excluding monitoring wells
63AX-94-01 and 63AX-94-02) were within the USEPA target risk range. Potential cancer risks associated
with commercial worker ingestion of unfiltered and filtered groundwater with the maximum and average
detected concentrations of arsenic ranged from 1 x 10 -4 to 1 x 10 -6 , respectively. Potential noncancer
risks ranged from an HI of 3 to an HI of 0.6 for unfiltered and filtered groundwater, respectively.

Based on uncertainties associated with the potential carcinogenic effects of arsenic, USEPA risk
management guidance 1 suggests that a tenfold lowering of cancer risk may be appropriate. If a downward
modifying factor of 10 is applied, cancer risk estimates associated with exposure to maximum observed
arsenic concentrations at AOC 63AX fall within or below the USEPA target risk range.

Further, the maximum detected arsenic concentration (130 Ig/L), which exceeded the federal and
Massachusetts drinking water standard of 50 Ig/L, was observed in the Round 1 groundwater sample from
monitoring well 63AX-94-01. The concentration in the Round 2 groundwater sample was below the federal and
Massachusetts standard. The average exposure point concentration of arsenic in monitoring wells
63AX-94-01 and 63AX-94-02 was 53 Ig/L, only slightly exceeding the federal and Massachusetts drinking
water standard. The maximum detected concentration of arsenic in site-wide groundwater (excluding
monitoring wells 63AX-94-01 and 63AX-94-02) was 17.7 Ig/L, well below the federal and Massachusetts
drinking water standard.

Arsenic, iron, and manganese were the primary contributors to non-cancer risk; however, as pointed out,
they do not appear to have a site-related source. In addition, because the risk assessment used a RfD for
iron which was not based on a toxic effect threshold, adverse effects from ingestion of iron at AOC 63AX
are considered unlikely.

An ecological risk assessment was not performed. The area surrounding AOC 63AX is paved and provides
neither shelter nor foraging opportunities for wildlife. Ecological receptor exposure to site
contaminants is considered unlikely.

In summary, the risk assessment did not identify potential human health risks associated with exposure to
soil at AOC 63AX exceeding USEPA target values. There is no current exposure to groundwater or an
associated risk. Potential risk was associated with future commercial worker exposure to groundwater;
however, downward modification of the carcinogenic risk estimates results in an estimate that is within
the USEPA target risk range of 1 x 10 -4 to 1 x 10 -6. Further, the property at AOC 63AX is served by the
Devens public water supply system and future worker exposure to site-derived groundwater is unlikely.
Therefore, the Army concludes that AOC 63AX does not pose an imminent or substantial endangerment to
public health, welfare, or the environment.

VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Army presented a Proposed Plan for No Further Action at AOC 63AX on June 3, 1997. This Record of
Decision contains no significant changes from the Proposed Plan.

VIII. STATE ROIiE

The Commonwealth of Massachusetts has reviewed the SI, AREE, and RI reports; Proposed Plan, and this
Record of Decision and concurs with the No Further Action decision. A copy of the Declaration of State
Concurrence is attached as Appendix E.
1 "Agency Policy on the Carcinogenic Risk Associated with Inorganic Arsenic",- memorandum from Lee M.
Thomas, Office of the Administrator for Pesticides and Toxic Substances, Washington, D.C., June 21,
1988.
-------
APPENDIX A - FIGURES

APPENDIX B - TABIiES
-------
TABLE 1
SUMMARY OF STATISTICS FOR AOC 63AX

AOC 63AX RECORD OF DECISION
DEVENS RFTA
DEVENS, MASSACHUSETTS
Maximum
Detected
Concentration
Arithmetic
Mean
Region III
MADEP
Method 1
Standards*
SUBSURFACE SOIL (1-16 feet bgs)a (mg/kg)
PAL METALS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
16 /
1 /
16 /
16 /
1 /
16 /
16 /
16 /
16 /
16 /
17 /
16 /
16 /
16 /
16 /
1 /
16 /
16 /
16 /
8788.44
0. 68
17. 11
26.93
0.33
2622.00
20.73
8.50
15.56
17171.25
11. 16
4377.50
403.34
31.57
879. 69
0. 15
321. 63
12.58
39.24
10097.
0.
21.
31.
0 .
5271.
23.
9.
18.
19930.
14
5324.
528.
35.
1164.
0.
350.
14.
43.
06
79
54
19
39
13
81
49
73
37
.3
11
48
87
45
18
72
88
82
Exceeds RBC3, Background 2
Less than RBC 1
Exceeds RBC 3
Less than RBC 1, Background 2
Exceeds RBC 3
Essential Nutrient 4
Less than RBC 1
Less than RBC 1
Less than RBC 1
Exceeds RBC 3
Background 2, Less then ARAR 5
Essential Nutrient 4
Exceeds RBC 3
Less than RBC 1
Background 2, Essential Nutrient
Less than RBC 1, Background 2
Essential Nutrient 4
Less than RBC 1, Background 2
Less than RBC 1
PAL SEMIVOLATILE ORGANICS
Acenaphthylene
Anthracene
Bis (2-ethythexyl)Phthalate
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[b]fluoranthene
Benzo[ghi]perylene
Benzo[k]fluoranthene
Chrysene
Fluoranthene
Naphthalene
Phenanthrene
Pyrene
. 11
. 17
310 j
2300
46
0.88
0. 088
0.88
310
8.8
88
310
310
310
230
Less than RBC 1
Less than RBC 1
Exceeds RBC 3
Less than RBC 1
Exceeds RBC 3
Less than RBC 1
Less than RBC 1
Less than RBC 1
Less than RBC 1
Less than RBC 1
Less than RBC 1
Less than RBC 1
Less than RBC 1
PAL VOLATILE ORGANICS
Xylenes 0.0015-0.0015
Acetone 0.017-0.017
Toluene 0.0008-0.0008
Trichlorofluoromethane 0.0059-0.0059
Less than RBC 1
Less than RBC 1
Less than RBC 1
Less than RBC 1
-------
TABLE 1
SUMMARY OF STATISTICS FOR AOC 63AX

AOC 63AX RECORD OF DECISION
DEVENS RFTA
DEVENS, MASSACHUSETTS
Concentration
Arithmetic
Mean
Region III
MADEP
Method 1
Standards*
PAL METALS
Aluminum
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
Zinc
8.63
0. 13
0.0584
51
0.0133
0.012
22.8
0.00618
10.5
5.35
5.3
41
0.0294

6.37
0.0105
0.0396
14.7
0.0147
.00809
9.1
. 00425
3.48
0.291
2.37
10. 8
0.0211
3.7
0.000045
0.26
NA
0.018
0.15
1.1
NA
NA
0.084
NA
NA
1.1
Exceeds RBC 3, Exceeds ARAR 6
Exceeds RBC 3, Exceeds ARAR 6
Less than RBC 1, Less than ARAR 5
Essential Nutrient 4
Less than RBC 1, Background 2, Less than ARAR
Less than RBC 1, Less than ARAR 5
Exceeds RBC 3, Exceeds ARAR 6
Less than ARAR 5
Essential Nutrient 4
Exceeds RBC 3, Exceeds ARAR 6
Essential Nutrient 4
Essential Nutrient 4
Less than RBC 1, Less than ARAR 5
PAL SEMIVOLATILE ORGANICS
2-Methylnaphthalene
Diethylphthalate
NA
NA
PAL VOLATILE ORGANICS
Ethylbenzene
Toluene
NC
NC
Less than RBC 1, Less than ARAR 5
Less than RBC 1, Less than ARAR 5
PAL METALS
Arsenic
Barium
C a 1 c i urn
Iron
Magnesium
Manganese
Potassium
Sodium
Exceeds RBC 3, Exceeds ARAR 6
Less than RBC 1, Background 2, Less than ARAR 5
Essential Nutrient 4
Exceeds RBC 3, Exceeds ARAR 6
Essential Nutrient 4
Exceeds RBC 3, Exceeds ARAR 6
Essential Nutrient 4
Essential Nutrient 4
-------
TABLE 1
SUMMARY OF STATISTICS FOR AOC 63AX

AOC 63AX RECORD OF DECISION
DEVENS RFTA
DEVENS, MASSACHUSETTS
Concentration
Maximum Arithmetic
Detected Mean
Region III
MADEP
Method 1
Standards*
PAL METALS
Aluminum
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
0.0067
0. 03
52.78
0.0043
0.0051
3.85
0. 0027
12. 1
4.11
3.27
39.4

0
0

6.87
.0105
.0396
14.7
.0147
.00809
9.1
.00425
3.48
.291
2.37
10.8
3.7
0.000045
0.26
NA
0.018
0.15
1.1
NA
NA
0.084
NA
NA
0 . 05
0. 05
2
NA
0.1
0 . 3
0.3
0. 015
NA
0.05
NA
NA
h
g
g

g
i
h
j

Exceeds RBC 3, Exceeds ARAR 6
Exceeds RBC 3, Less than ARAR 5
Less than RBC 1, Less than ARAR 5
Essential Nutrient 4
Less than RBC 1, Background 2, Less than ARAR
Less than RBC 1, Less than ARAR 5
Exceeds RBC 3, Exceeds ARAR 6
Less than ARAR 5
Essential Nutrient 4
Exceeds RBC 3, Exceeds ARAR 6
Essential Nutrients 4
Essential Nutrients 4
PAL SEMIVOLATILE ORGANICS
Bis (2-ethythexyl)Phathalate
Diethyl Phthalate
PAL VOLATILE ORGANICS
Methylene Chloride
Chloroform
Toluene
NC
NC
NC
Less than RBC 1, Less than ARAR 5
Exceeds RBC 3, Less than ARAR 5
Less than RBC 1, Less than ARAR 5
-------
TABLE 1
SUMMARY OF STATISTICS FOR AOC 63AX

AOC 63AX RECORD OF DECISION
DEVENS RFTA
DEVENS, MASSACHUSETTS
Concentration
Maximum Arithmetic
Detected Mean
Region III
MADEP
Method 1
Standards*
GROUNDWATER d (mg/L) - FILTERED
PAL METALS
Arsenic
Barium
C a1c i um
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
0. 00489
0. 019
53.276
0.00467
1.184
0.00069
14.153
3.366
2.896
38.97
No
No
No
No
Exceeds RBC 3, Less than ARAR 5
Less than RBC 1, Background 2, Less than ARAR 5
Essential Nutrient 4
Less than RBC 1, Less than ARAR 5
Exceeds RBC 3, Exceeds ARAR 6, Background 2
Background 2, Less than ARAR 5
Essential Nutrient 4
Exceeds RBC 3, Exceeds ARAR 6
Essential Nutrient 4
Essential Nutrient 4
NOTES
a Based on samples from AXB-05-01X (6,8 & 16 ft),-02X(4,6,15 & 15 ft dup), -03X(2,4,6ft)
-05X(6, 8, 10 ft), AXE-95-03X (3ft), 43K-92-01X (5 ft), LRS-01, -02, -03, -04 (5 ft)
b Based on unfiltered samples taken in 1995 and 1996 from 63AX-94-01 and 63AX-94-02
c Based on filtered samples taken in 1995 and 1996 from 63AX-94-01 and 63AX-94-02
d Based on unfiltered samples taken in 1995 and 1996 from 63AX-94-03, AXM-95-05X, -
e Based on filtered samples taken in 1995 and 1996 from 63AX-94-03, AXM-95-05X, -Of
f USEPA soil lead screening level (OSWER Directive 9355 4-12, 1994b)
g MCL (USEPA, 1996b)
h Secondary MCL (USEPA, 1996b)
i Action Level (USEPA, 1996b)
j Value for naphthalene used as surrogate

* Background: Maximum concentration in Fort Devens background listed;
95 percent UCL of Fort Devens background groundwater. See Appendix F for development of background
* * Region III RBCs (USEPA, 19 9 6a) : Residential RBC for soil used for subsurface soil evaluation; tap water RBC used
for groundwater evaluation. RBCs based on carcinogenic effects are associated with a 1x10 -6 cancer risk level;
RBCs based on noncarcinogenic effects are associated with an adjusted HQ of 0 1 (USEPA, 19 96a)
***MCP Method 1 Standards (MADEP, 1995) :
Lowest GW standard used for groundwater; lowest S-3 value used for soil
Chemicals selected as CPCs are shaded
RBC - Risk-based Concentration
mg - milligram
kg - kilogram
L - liter
ARAR - Applicable or Relevant and Appropriate Reguirements
MCL - Maximum Contaminant Level
CPC - chemical of potential concern
bgs - below ground surface
SQL - Sample Quantitation Limit
-- not applicable for organics
NC - 95 percent UCL not calculated for groundwater
NA - No value available
Less than RBC 1 - Maximum detected concentration less than risk-based concentration
Background 2 - Sample concentrations detected are at or below background concentrations.
Exceeds RBC 3 - Maximum detected concentration exceeds risk-based concentration
Essential Nutrient 4 - Analyte is an essential human nutrient (magnesium, calcium, potassium, sodium) and is not considered a CPC.
Less than ARAR 5 - Maximum detected concentration is less than concentration shown in ARAR column.
Exceeds ARAR 6 - Maximum detected concentration is greater than concentration shown in ARAR column.
-------
TABLE 2
CHEMICALS OF POTENTIAL CONCERN

AOC 63AX RECORD OF DECISION
DEVENS RFTA
DEVENS, MASSACHUSETTS

Groundwater
Wells 63AX-94-01,-02 Site-wide Groundwater*
Chemical Subsurface Soil Unfiltered Filtered Unfiltered Filtered
Aluminum XX X
Arsenic X XX XX
Beryllium X
Iron X XX XX
Manganese X XX XX

Chloroform X
Bis(2-ethylhexyl)phthalate X X
Benzo(a)pyrene X

Total petroleum hydrocarbons X

Notes:

* = Site-wide groundwater excludes monitoring wells 63AX-94-01 and 63AX-94-02.
-------
TABIiE 3
QUANTITATIVE RISK SUMMARY
Exposure Pathway

Current and Future Land Use
Utility/Maintenance Worker
Incidental ingestion of subsurface soil
Inhalation of volatiles from soil and groundwater
Total
Reasonable
Central Tendency Maximum Exposure
Cancer Hazard
Risk Index
Not evaluated*
Cancer Hazard
Risk Index
5E-07 0.03
5E-09 ND
5E-07 0.03
Construction Worker
Incidental ingestion of subsurface soil
Inhalation of votatiles from soil and groundwater, and
Inhalation of soil particulates
Total
Not evaluated*
3E-07 0.3
1E-09 0.0006
3E-07
0.3
Future Land Use
Commercial Worker
Ingestion of unfiltered groundwater from wells 63AX-94-01
and 63AX-94-02
Ingestion of filtered groundwater from wells
63AX-94-01 and 63AX-94-02
Ingestion of unfiltered site-groundwater (excluding wells
63AX-94-01 and 63AX-94-02
Ingestion of filtered site-groundwater (excluding wells
63AX-94-01 and 63AX-94-02
Notes:
* = Central tendency exposures were not evaluated because Reasonable
USEPA target risk range and threshold.

ND = Hazard index was not determined because toxicity values were not
concern
6E-05 2
4E-05 1
8E-06 0.9
6E-06 0.6
7E-04
4E-04
1E-04
1E-04
6
4
3
2
Maximum Exposures were below
available for chemicals of potential
-------
APPENDIX C - RESPONSIVENESS SUMMARY

This Responsiveness Summary has been prepared to meet the requirements of Sections 113(k)(2)(B)(iv) and
117(b) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 as
amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986, which requires response to
"significant comments, criticisms, and new data submitted in written or oral presentations" on a proposed
plan for remedial action. The purpose of this Responsiveness Summary is to document Army responses to
questions and comments expressed during the public comment period by the public, potentially responsible
parties, and governmental bodies in written and oral comments regarding the Proposed Plan for Area of
Contamination (AOC) 63AX.

The Army held a 30-day public comment period from June 3 through July 3, 1997, to provide an opportunity
for interested parties to comment on the remedial investigation (RI) report, Proposed Plan, and other
documents developed to address contamination at AOC 63AX, Devens Reserve Forces Training Area (RFTA),
Devens, Massachusetts. The RI characterized soil and groundwater contamination at AOC 63AX and evaluated
potential human health and ecological risks. Based on the results of the RI and risk assessment, the Army
concluded that AOC 63AX did not pose unacceptable risks to human health or the environment. The Army
identified its proposal for No Further Action in the Proposed Plan issued on June 3, 1997.

All documents considered in arriving at the No Further Action decision were placed in the Administrative
Record for review. The Administrative Record contains all supporting documentation considered by the Army
in choosing the remedy for AOC 63AX. The Administrative Record is available to the public at the Devens
Base Realignment and Closure (BRAG) Environmental Office, 30 Quebec Street, Devens RFTA, and at the Ayer
Town Hall, Main Street, Ayer. An index to the Administrative Record is available at the U.S.
Environmental Protection Agency (USEPA) Records Center, 90 Canal Street, Boston, Massachusetts and is
provided as Appendix D to the Record of Decision.

This Responsiveness Summary is organized into the following sections:

I. Statement of Why the Army Recommended No Further Action-This section briefly states why the Army
recommended No Further Action for AOC 63AX.

II. Background on Community Involvement-This section provides a brief history of community
involvement and Army initiatives to inform the community of site activities.

III. Summary of Comments Received During the Public Comment Period and Army Responses-This section
provides Army responses to oral and written comments received from the public and not formally
responded to during the public comment period. A transcript of the public meeting consisting of
all comments received during this meeting and the Army's responses to these comments is provided
in Attachment A of this Responsiveness Summary.
-k-k-k-k-k-k-k-k-k

I. STATEMENT OF WHY THE ARMY RECOMMENDED NO FURTHER ACTION

The Army recommended No Further Action because the risk assessment did not identify potential human
health risks associated with exposure to soil at AOC 63AX exceeding USEPA target values. There is no
current exposure to groundwater or an associated risk. Potential risk was associated with future
commercial worker exposure to groundwater; however, downward modification of the carcinogenic risk
estimates results in an estimate that is within the USEPA target risk range of 1x10 -4 to 1x10 -6.
Further; the property at AOC 63AX is served by the Devens public water supply system, and future worker
exposure to site-derived groundwater is unlikely. An ecological risk assessment was not performed. The
area surrounding AOC 63AX is paved and provides neither shelter nor foraging opportunities for wildlife.
Ecological receptor exposure to site contaminants is considered unlikely.

Based on these facts, the Army concluded that AOC 63AX does not pose an imminent or substantial
endangerment to public health, welfare, or the environment.

II. BACKGROUND ON COMMUNITY INVOLVEMENT

The Army has held regular and frequent information meetings, issued fact sheets and press releases, and
held public meetings to keep the community and other interested parties informed of activities at AOC
63AX In February 1992, the Army released, following public review, a community relations plan that
outlined a program to address community concerns and keep citizens informed about and involved in
remedial activities at Fort Devens. As part of this plan, the Army established a Technical Review
Committee (TRC) in early 1992. The TRC, as required by SARA Section 211 and Army Regulation 200-1,
included representatives from USEPA, USAEC, Fort Devens, Massachusetts Department of Environmental
-------
Protection (MADEP), local officials, and the community. Until January 1994, when it was replaced by the
Restoration Advisory Board (RAB), the committee generally met quarterly to review and provide technical
comments on schedules, work plans, work products, and proposed activities for the study area at Fort
Devens. The Site Investigation, Area Requiring Environmental Evaluation, and RI reports; Proposed Plan;
and other related support documents were all submitted to the TRC or RAB for their review and comment.
The Community Relations Plan was updated to address Base Realignment and Closure issues and reissued in
May 1995.

The Army, as part of its commitment to involve the affected communities, forms a RAB when an installation
closure involves transfer of property to the community. The Fort Devens RAB was formed in February 1994
to add members of the Citizen's Advisory Committee (CAC) to the TRC. The CAC had been established
previously to address Massachusetts Environmental Policy Act/Environmental Assessment issues concerning
the reuse of property at Fort Devens. The RAB initially consisted of 28 members (15 original TRC members
plus 13 new members) representing the Army, USEPA Region I, MADEP, local governments, and citizens of the
local communities. The RAB currently consists of 19 members. It meets monthly and provides advice to the
installation and regulatory agencies on the Devens RFTA cleanup programs. 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 that are open to the
public.

On June 3, 1997, the Army issued the Proposed Plan, to provide the public with a brief explanation of the
Army's proposal for No Further Action at AOC 63AX. The Proposed Plan also described the opportunities for
public participation and provided details on the upcoming public comment period and public meetings.

III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND ARMY RESPONSES

No comments were received during the public comment period.
-------
ATTACHMENT A - PUBLIC MEETING TRANSCRIPT

1 PROCEEDINGS

2 MR. CHAMBERS: Good evening. Thanks for

3 coming out this very hot evening.

4 I'm James Chambers. I'm the BRAG

5 Environmental Coordinator for the U.S. Army Devens

6 Reserved Forces Training Area.

7 Tonight we're here to have the public

8 meeting on the proposed plan for the Area of

9 Contamination 63AX. The proposed plan was sent out

10 May 27, for a 30-day comment period. The comment

11 period ends this Friday, June 27. I invite you to

12 either make public comment — oral comments this

13 evening or written comments and submit them to us by

14 the 27th of June.

15 So we'll hold this meeting open till 7:30;

16 and, then, if we receive no comments by that time,

17 then we'll close the meeting.

18 (Discussion off the record)

19 MR. CHAMBERS: The public comment

20 period -- I'm sorry -- is from June 3 through

21 July 3. So we'll solicit written comments till the

22 3rd of July.

23 (Discussion off the record)

24 MR. CHAMBERS: All right. Everyone. There

DORIS 0. WONG ASSOCIATES
-------
1 being no further comment on this proposed plan, I'm

2 going to close the public hearing. I'd like to

3 remind you again to please sign the attendance

4 sheet, and thank you for coming.

5 (Whereupon the proceedings were

6 adjourned at 7:31 p.m.)

DORIS 0. WONG ASSOCIATES
-------
1 CERTIFICATE

2 I, William J. Ellis, Registered

3 Professional Reporter, do hereby certify that the

4 foregoing transcript, Volume I, is a true and

5 accurate transcription of my stenographic notes

6 taken on June 25, 1997.

DORIS 0. WONG ASSOCIATES

-------
APPENDIX D - ADMINISTRATIVE RECORD INDEX

1.0 Pre-Remedial
1.2 Preliminary Assessment

Work Plans
1. Draft Supplemental Work Plan BRAG EE, AREEs 61, 63, 66, 69 Fort Devens,
Massachusetts, Arthur D. Little, Inc., (April 30, 1993). Filed in Group AREE.

2. Underground Storage Tank (AREE 63) Memorandum Work Plan Base Realignment and
Closure Environmental Evaluation (BRAG EE), Fort Devens, Massachusetts, Arthur D.
Little, Inc., (February 17, 1994). Filed in Group AREE.

3. Final Supplemental Work Plan - Appendix B, BRAG EE, Fort Devens, Massachusetts,
Arthur D. Little, Inc., (June 17, 1994). Filed in Group AREE.

Reports

1. Final Master Environmental Plan for Fort Devens, Argonne National Laboratory,
(April, 1992). Filed in Group 1A.

2. Preliminary Zone II Analysis for the Production Wells at Fort Devens, MA, Draft
Report, Engineering Technologies Associates, Inc., (January, 1994). Filed in Group
1A.

3. Final Maintenance and Waste Accumulation Areas (AREE 61) Report, Base Realignment
and Closure Environmental Evaluation, Fort Devens, Massachusetts, Volume I and II,
Arthur D. Little, Inc., (June, 1995). Filed in Group AREE.

4. Final Previously Removed Underground Storage Tank (AREE 63) Report, Base
Realignment and Closure Environmental Evaluation (BRAG EE), Fort Devens,
Massachusetts, Volume I and II, Arthur D Little, Inc., (June, 1995). Filed in Group
AREE.

5. Final Previously Removed Underground Storage Tank (AREE 63) Report, Base
Realignment and Closure Environmental Evaluation (BRAG EE) , Fort Devens,
Massachusetts, Volume I and II, Replacement Pages, Arthur D. Little, Inc.,
(September, 1995). Filed in Group AREE.

6. Final Maintenance and Waste Accumulation Areas (AREE 61) Report, Base Realignment
and Closure Environmental Evaluation, Fort Devens, Massachusetts, Volume I and II,
Replacement Pages, Arthur D. Little, Inc., (September, 1995). Filed in Group AREE.

Comments

1. Comments dated May, 1992 from Walter Rolf, Montachusett Regional Planning Commission on the April,
1992 "Final Master Environmental Plan for Fort Devens," Argonne National Laboratory. Filed in Group
1A.

2. Comments dated May 7, 1992 from James P. Byrne, USEPA Region I on the April, 1992 "Final Master
Environmental Plan for Fort Devens," Argonne National Laboratory. Filed in Group 1A.

3. Comments dated November 23, 1993 from Molly J. Elder, MADEP on the October 8, 1993 "Draft
Underground Storage Tank (AREE 63) Memorandum Work Plan, Base Realignment and Closure Environmental
Evaluation (BRAG EE), Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in Group AREE.

4. Comments dated December 28, 1993 from James P. Byrne, USEPA Region I on the November 15, 1993
"Previously Removed Underground Storage Tank (AREE 63) Draft Report, Base Realignment and Closure
Environmental Evaluation (BRAG EE) , Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in
Group AREE.

5. Comments dated December 28, 1993 from James P. Byrne, USEPA Region I on the February 15, 1993
"Draft Maintenance and Waste Accumulation Areas (AREE 61) Report, Base Realignment and Closure
Environmental Evaluation, Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in Group AREE.
-------
6. Comments dated December 28, 1993 from James P. Byrne, USEPA Region I on the April 30, 1993 "Draft
Supplemental Work Plan BRAG EE, AREEs 61, 63, 66, 69 Fort Devens, Massachusetts," Arthur D. Little,
Inc. Filed in Group AREE.

7. Comments dated December 30, 1993 from Molly J. Elder, MADEP on the December 30, 1993 "Comments on
the November 1993 Draft Maintenance and Waste Accumulation Report, Draft Work Plan, Draft Protocol
Data Sheet and Data Base, Fort Devens, Massachusetts," Molly J. Elder, MADEP. Filed in Group AREE.

8. Comments dated January 6, 1994 from Molly J. Elder, MADEP on the November 15, 1993 "Previously
Removed Underground Storage Tank (AREE 63) Draft Report, Base Realignment and Closure Environmental
Evaluation (BRAG EE), Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in Group AREE.

9. Comments dated May 6, 1994 from D. Lynne Welsh, MADEP on the February 17, 1994 "Underground Storage
Tank (AREE 63) Memorandum Work Plan Base Realignment and Closure Environmental Evaluation(BRAG EE),
Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in Group AREE.

10. Comments dated May 23, 1994 from D. Lynne Welsh, MADEP on the January, 1994 "Preliminary Zone II
Analysis for the Production Wells at Fort Devens, MA, Draft Report," Engineering Technologies
Associates, Inc. Filed in Group 1A.

11. Comments dated September 18, 1995 from D. Lynne Welsh, MADEP on the June, 1995. "Final Maintenance
and Waste Accumulation Areas (AREE 61) Report, Base Realignment and Closure Environmental
Evaluation, Fort Devens, Massachusetts, Volume I and II," Arthur D. Little, Inc. Filed in Group
AREE.

12. Comments dated October 20, 1995 from D. Lynne Welsh, MADEP on the June, 1995 "Final Previously
Removed Underground Storage Tank (AREE 63) Report, Base Realignment and Closure Environmental
Evaluation (BRAG EE), Fort Devens, Massachusetts, Volume I and II," Arthur D. Little, Inc. Filed in
Group AREE.

Responses to Comments

1. Responses dated June 29, 1992 from Carrol J. Howard, Fort Devens to the comments on the
April, 1992 "Final Master Environmental Plan for Fort Devens, " Argonne National Laboratory.
Filed in Group 1A.

2. Meeting Notes and Responses dated January 13, 1994 from Arthur D. Little to the comments on
the "Draft Maintenance and Waste Accumulation Areas Report AREE 61 (BRAG EE)", Arthur D.
Little, Inc. Filed in Group AREE.

3. Responses dated January 21, 1994 from Arthur D. Little, Inc. to the comments on the October
8, 1993 "Draft Underground Storage Tank (AREE 63) Memorandum Work Plan, Base Realignment and
Closure Environmental Evaluation (BRAG EE), Fort Devens, Massachusetts," Arthur D. Little,
Inc. Filed in Group AREE.

1.3 Site Inspection

Work Plans

1. Final Task Order (Site Investigations) Work Plan - Historic Gas Stations, ABB Environmental
Services, Inc., (December, 1992). Filed in Group 2&7.

2. Work Plan - Maintenance and Waste Accumulation Areas (AREE 61) Base Realignment and Closure
Environmental Evaluation (BRAG EE), Fort Devens, Massachusetts, Arthur D. Little, Inc.,
(February 17, 1994). Filed in Group AREE.

Reports

1. Final SI Report, Groups 2 & 7 and Historic Gas Stations, Volume I - IV, ABB Environmental
Services, Inc., (May, 1993). Filed in Group 2&7.

2. Underground Storage Tanks (AREE 63) Supplemental Site Evaluation Data Package Base
Realignment and Closure Environmental Evaluation (BRAG EE), Fort Devens, Massachusetts,
Arthur D. Little, Inc., (October, 1994). Filed in Group AREE.
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3. Maintenance and Waste Accumulation Areas (AREE 61) Supplemental Site Evaluation Data Package
Base Realignment and Closure Environmental Evaluation (BRAG EE), Fort Devens, Massachusetts,
Arthur D. Little, Inc., (October, 1994). Filed in Group AREE.

4. Revised Final Site Investigation Report, Groups 2 & 7 and Historic Gas Stations, Volumes I,
II, III and IV, ABB Environmental Services, Inc., (October, 1995). Filed in Group 2&7.

Comments

1. Comments dated January 12, 1993 from James P. Byrne, USEPA Region I on the December, 1992 "Final Task
Order (Site Investigations) Work Plan - Historic Gas Stations," ABB Environmental Services, Inc. Filed
in Group 2&7.

2. Comments dated January 11, 1993 from D. Lynne Chappell, MADEP on the December, 1992 "Final Task Order
(Site Investigations) Work Plan - Historic Gas Stations," ABB Environmental Services, Inc. Filed in
Group 2&7.

3. Comments dated July 9, 1993 from D. Lynne Chappell, MADEP on the May, 1993 "Final SI Report, Groups 2
& 7 and Historic Gas Stations, Volume I - IV," ABB Environmental Services, Inc. Filed in Group 2&7.

4. Comments dated July 15, 1993 from James P. Byrne, USEPA Region I on the May, 1993 "Final SI Report,
Groups 2 & 7 and Historic Gas Stations, Volume I - IV," ABB Environmental Services, Inc. Filed in
Group 2&7.

5. USEPA Comments on the AREE 61 Work Plan, AREE 63 Memorandum Work Plan and AREE 69 Work Plan, Arthur D.
Little, Inc. Filed in Group AREE.

6. Comments dated April 4, 1994 from Molly J. Elder, MADEP on the February 17, 1994 "Work Plan -
Maintenance and Waste Accumulation Areas (AREE 61) Base Realignment and Closure Environmental
Evaluation (BRAG EE), Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in Group AREE.

7. Comments dated December 9, 1994 from D. Lynne Welsh, MADEP on the October, 1994 "Maintenance and Waste
Accumulation Areas (AREE 61) Supplemental Site Evaluation Data Package Base Realignment and Closure
Environmental Evaluation (BRAG EE) , Fort Devens, Massachusetts," Arthur D. Little, Inc. Filed in Group
AREE.

Responses to Comments

1. Responses dated September, 1993 from U.S. Army Environmental Center to the comments on the May, 1993
"Final SI Report, Groups 2 & 7 and Historic Gas Stations, Volume I - IV," ABB Environmental Services,
Inc. Filed in Group 2&7.

2. Responses on the Final Work Plan (AREE 61), Final Memorandum Work Plan (AREE 63) and Final Work Plan
(AREE 69). Filed in Group AREE.

3. Responses on the Supplemental Site Evaluations (SSE) Data Packages for AREE 61, AREE 63, AREE 66, and
AREE 69 (Arthur D. Little, Inc.). Filed in Group AREE.

Comments on Responses to Comments

1. MADEP Rebuttals on the Comment Response Package of the Final Work Plan for AREE 61, 63 and 69. Filed
in Group AREE.

3.0 Remedial Investigation (RI)
3.4 Interim Deliverables

Work Plans

1. Final Projects Operations Plan - Volume I - III, ABB Environmental Services, Inc.,
(December, 1992) . Filed in Group 1A.

2. Final (Revised) Project Operations Plan, Fort Devens, Massachusetts, Data Item
A004/A006, Volumes I-III, ABB Environmental Services, Inc., (May, 1995). Filed in Group
1A.

Reports
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1. Final Ground Water Flow Model at Fort Devens, Engineering Technologies Associates,
Inc., (May 24, 1993). Filed in Group 1A.

2. Risk Assessment Approach Plan, Remedial Investigation Reports, AOCs 57 and 63AX, Fort
Devens, MA, ABB Environmental Services, Inc., (March 12, 1996). Filed in Group 2&7.

Comments

1. Comments dated January 12, 1993 from James P. Byrne, USEPA Region I on the December,
1992 "Final Projects Operations Plan - Volume I - III," ABB Environmental Services,
Inc. Filed in Group 1A.

2. 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,". Filed in Group
1A.

3. Comments dated February 17, 1993 from D. Lynne Chappell, MADEP on the December, 1992
"Final Projects Operations Plan - Volume I - III," ABB Environmental Services, Inc.
Filed in Group 1A.

4. Comments dated April 15, 1996 from James P. Byrne, USEPA Region I on the March 12, 1996
"Risk Assessment Approach Plan, Remedial Investigation Reports, AOCs 57 and 63AX, Fort
Devens, MA," ABB Environmental Services, Inc. Filed in Group 2&7.

5. Comments dated April 23, 1996 from Christopher J. Knuth, MADEP on the March 12, 1996
"Risk Assessment Approach Plan, Remedial Investigation Reports, AOCs 57 and 63AX, Fort
Devens, MA," ABB Environmental Services, Inc. Filed in Group 2&7.

3.5 Applicable or Relevant and Appropriate Reguirements (ARARs)

Reports

1. Draft Applicable or Relevant and Appropriate Reguirements (ARARs) for CERCLA Remedial
Actions, U.S. Army Toxic and Hazardous Materials Agency, (May 21, 1992). Filed in Group
3,5 and 6.

3.6 Remedial Investigation (RI) Reports

Reports

1. Final Remedial Investigation Report for Area Of Contamination (AOC) 63AX, ABB
Environmental Services, Inc., (February, 1997). Filed in Group AREE.

Comments

1. Comments dated October 8, 1996 from Christopher J. Knuth, MADEP on the August, 1996
"Draft Remedial Investigation Report for Area Of Contamination (AOC) 63AX," ABB
Environmental Services, Inc. Filed in Group AREE.

2. Comments dated November 7, 1996 from Jerome C. Keefe, USEPA Region I on the August, 1996
"Draft Remedial Investigation Report for Area Of Contamination (AOC) 63AX," ABB
Environmental Services, Inc. Filed in Group AREE.

Responses to Comments

1. Responses dated February, 1997 from ABB Environmental Services, Inc. to the comments on
the August, 1996 "Draft Remedial Investigation Report for Area Of Contamination (AOC)
63AX," ABB Environmental Services, Inc. Filed in Group AREE.

3.7 Work Plans and Progress Reports

Work Plans

1. Final Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item A002, ABB Environmental
Services, Inc., (January, 1996). Filed in Group 2&7.
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Comments

1. Comments dated August 18, 1995 from Jerome C. Keefe, USEPA Region I on the July, 1995
"Draft Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item A002," ABB Environmental
Services, Inc. Filed in Group 2&7.

2. Comments dated September 15, 1995 from D. Lynne Welsh, MADEP on the July, 1995 "Draft
Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item A002," ABB Environmental
Services, Inc. Filed in Group 2&7.

3. Comments dated February 27, 1996 from Christopher J. Knuth, MADEP on the January, 1996
"Final Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item A002," ABB Environmental
Services, Inc. Filed in Group 2&7.

4. Comments dated February 27, 1996 from Jerome C. Keefe, USEPA Region I on the January,
1996 "Final Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item A002," ABB
Environmental Services, Inc. Filed in Group 2&7.

Responses to Comments

1. Responses dated January, 1996 from ABB Environmental Services, Inc. to the comments
on the July, 1995 "Draft Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item
A002," ABB Environmental Services, Inc. Filed in Group 2&7.

Comments on Responses to Comments

1. Comments dated February 27, 1996 from Christopher J. Knuth, MADEP on the responses on
the July, 1995 "Draft Task Order Work Plan, AOCs 57, 63AX and 69W, Data Item A002,"
ABB Environmental Services, Inc. Filed in Group 2&7.

4.0 Feasibility Study (FS)

4.9 Proposed Plans for Selected Remedial Action

Reports

1. Proposed Plan for AOC 63AX, ABB Environmental Services, Inc., (June, 1997). Filed
in Group AREE.

Comments

1. Comments dated May 9, 1997 from James P. Byrne, USEPA Region I on the April, 1997
"Draft Proposed Plan for AOC 63 AX," ABB Environmental Services, Inc. Filed in
Group AREE.

2. Comments dated May 12, 1997 from Christopher J. Knuth, MADEP on the April, 1997
"Draft Proposed Plan for AOC 63 AX," ABB Environmental Services, Inc. Filed in
Group AREE.

Responses to Comments

1. Responses dated June, 1997 from ABB Environmental Services, Inc. to the comments
on the April, 1997 "Draft Proposed Plan for AOC 63 AX," ABB Environmental
Services, Inc. Filed in Group AREE.

5.0 Record of Decision (ROD)

5.4 Record of Decision (ROD)

Reports

1. 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). Filed
in Group 2&7.
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2. No Further Action Decision Under CERCLA, Study Area 43K, Historic Gas Station Sites,
Fort Devens, Massachusetts, ABB Environmental Services, Inc., (January, 1995). Filed
in Group 2&7.

3. Final No Further Action Decision Under CERCLA, AREE 61, 63 and 69 Sites, Fort Devens,
Massachusetts, Arthur D. Little, Inc., (November, 1995). Filed in Group AREE.

4. Final Record of Decision for AOC 63AX, ABB Environmental Services, Inc., (September,
1997). Filed in Group AREE.

Comments

1. Comments dated November 3, 1993 from D. Lynne Welsh, MADEP on the September, 1993
"Draft 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. Filed in Group 2&7.

2. Comments dated November 17, 1993 from James P. Byrne, USEPA Region I on the September,
1993 "Draft 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. Filed in Group 2&7.

3. Comments dated July 16, 1997 from Christopher J. Knuth, MADEP on the June, 1997 "Draft
Record of Decision for AOC 63AX," ABB Environmental Services, Inc. Filed in Group AREE.

4. Comments dated July 17, 1997 from Jerome C. Keefe, USEPA Region I on the June, 1997
"Draft Record of Decision for AOC 63AX," ABB Environmental Services, Inc. Filed in Group
AREE.

5. Comments dated August 22, 1997 from David M. Salvadore, MADEP on the June, 1997 "Draft
Record of Decision for AOC 63AX," ABB Environmental Services, Inc. Filed in Group AREE.

Responses to Comments

1. Responses dated January, 1995 from U.S. Army Environmental Center to the comments on the
September, 1993 "Draft 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. Filed in
Group 2&7.

10.0 Enforcement

10.16 Federal Facility Agreements

1. Final Federal Facility Agreement Under CERCLA Section 120, EPA Region I and U.S.
Department of the Army with attached map. Filed in Group 1A.

13.0 Community Relations

13.2 Community Relations Plans

1. Final Community Relations Plan, Ecology and Environment, Inc., (February, 1992).
Filed in Group 1A.

Reports

1. Fort Devens Community Relations Plan for Environmental Restoration, 1995 Update,
ABB Environmental Services, Inc., (May, 1995). Filed in Group 1A.

Comments

1. Comments dated March 19, 1992 from James P. Byrne, USEPA Region I on the
February, 1992 "Final Community Relations Plan," Ecology and Environment, Inc.
Filed in Group IB.
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APPENDIX E - DECLARATION OF STATE CONCURRENCE

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

ARGEO PAUL CELLUCCI TRUDY COXE
Governor Secretary

DAVID B. STRUHS
Commissioner

September 26, 1997

Mr. Harley F. Laing, Director
U.S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, MA 02203

RE: Record of Decision for Area for Contamination 63AX, Devens, Massachusetts

Dear Mr. Laing:

The Massachusetts Department of Environmental Protection (MADEP) has reviewed the Record of Decision
(ROD) proposed by the United States Army and the U.S. Environmental Protection Agency (EPA) for the Area
of Contamination (AOC) 63AX and concurs with the proposed remedy.

The MADEP has evaluated this no action ROD for consistency with M.G.L. c. 21E (21E) and the Massachusetts
Contingency Plan (MCP).

The MADEP's concurrence is based upon the documented site remediation and assessment conducted by the
Army in the immediate location of Buildings #2514 and #2517. These actions include the removal of a waste
oil underground storage tank (UST) and 100 cubic yards of impacted soil in 1989, the removal of a
gasoline UST and an additional 140 tons of impacted soil in 1992.

Along with these remedial activities, a Site Investigation was conducted in 1992 and a more complete
Remedial Investigation (RI) report was initiated in 1995. The purpose of the RI was to determine the
nature and extent of contamination at AOC 63AX and assess the human health and ecological risks.

The RI concluded that AOC 63AX did not present unacceptable risks to human health or the environment and
that a feasibility study to evaluate remedial actions alternatives was not needed.

The MADEP concurs with the ROD for AOC 63AX and would like to thank the US Army, particularly Jim
Chambers BRAG Environmental Coordinator, and Jerry Keefe, EPA, the Fort Devens, Remedial Project Manager,
for their efforts to ensure that the reguirements of the MADEP were met. We look forward to continuing
to work with the EPA at other sites at Devens.

If you have any guestions, please contact Lynne Welsh at (508) 792-7653, ext. 3851.

CC: Edward Kunce, MADEP
Jay Naparstek, MADEP
Informational Repositories
Fort Devens Mailing List (Cover Letter Only)
Ron Ostrowski, DCC
Jim Byrne, EPA
Jeff Waugh, AEC
Patricia Momm, ABB
Mark Applebee, ACOE

627 Main Street • Worcester, Massachusetts 01608 • Telephone (508) 792-7692
Fax (508)792-7621 TTD #(508)767-2788
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APPENDIX F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS

AOC Area of Contamination
AREE Area Requiring Environmental Evaluation
bgs below ground surface
BRAG Base Realignment and Closure
BTEX benzene, ethylbenzene, toluene, and xylenes
CAC Citizen's Advisory Committee
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CMR Code of Massachusetts Regulations
HI hazard index
MADEP Massachusetts Department of Environmental Protection
MCL Maximum Contaminant Level
MCP Massachusetts Contingency Plan
NCP National Oil and Hazardous Substances Pollution Contingency Plan
PAL Project Analyte List
PCB polychlorinated biphenyl
RAB Restoration Advisory Board
RfD reference dose
RI remedial investigation
RFTA Reserve Forces Training Area
SA Study Area
SARA Superfund Amendments and Reauthorization Act
SI site investigation
SVOC semivolatile organic compound
TPHC total petroleum hydrocarbon compounds
TRC Technical Review Committee
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