Superfund Record of Decision Fort Devens-Sudbury Training Annex Areas of Contamination A4 A7 A9 Middlesex County MA


                                    EPA/ROD/R01-97/160
                                    1997
EPA Superfund
     Record of Decision:
     FORT DEVENS-SUDBURY TRAINING ANNEX
     EPA ID: MAD980520670
     OU 01, 02, 03
     SUDBURY, MA
     09/30/1997

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                                RECORD OF DECISION
                              AREA OF CONTAMINATION A4
                        AND AREAS OF CONTAMINATION A7 AND A9
                       MANAGEMENT OF MIGRATION OPERABLE UNITS
                              U.S. ARMY SUDBURY ANNEX
                        MIDDLESEX COUNTY, MASSACHUSETTS

                                 SEPTEMBER  1997

                                TABLE OF CONTENTS


Figure                                              Title                                   Page No.

1.0  SITE NAME, LOCATION, AND DESCRIPTION	1-1

2 . 0  SITE HISTORY AND ENFORCEMENT ACTIVITIES  	2-1
     2 .1  LAND USE AND RESPONSE HISTORY 	2-1
          2.1.1  AOC A4-Waste Dump  	2-2
          2-1.2  AOC A7-01d Gravel Pit Landfill  	2-3
          2.1.3  AOC A9-POL Bum Area 	2-6
     2.2  ENFORCEMENT HISTORY 	2-8

3.0  COMMUNITY PARTICIPATION 	3-1

4 . 0  SCOPE AND ROLE OF RESPONSE ACTION 	4-1

5 . 0  SUMMARY OF SITE CHARACTERISTICS 	5-1
     5.1  AOC A4 	5-1
     5.2  AOC A7 	5-3
     5.3  AOC A9 	5-7

6. 0  SUMMARY OF SITE RISKS 	6-1
     6.1  SUMMARY OF RISKS AT AOC A4 	6-2
          6.1.1  Human Health Risk Assessment Summary for AOC A4  	6-3
          6.1.2  Ecological Risk Assessment Summary for AOC A4  	6-5
     6.2  SUMMARY OF RISKS AT AOC A7 	6-6
          6.2.1  Human Health Risk Assessment Summary for AOC A7  	6-6
          6.2.2  Ecological Risk Assessment Summary for AOC A7  	6-8
     6.3  SUMMARY OF RISKS AT AOC A9 	6-10
          6.3.1  Human Health Risk Assessment Summary for AOC A9  	6-10
          6.3.2  Ecological Risk Assessment Summary for AOC A9  	6-12

7.0  DESCRIPTION OF THE NO ACTION ALTERNATIVE 	7-1

8 . 0  DOCUMENTATION OF NO SIGNIFICANT CHANGES  	8-1

9 . 0  STATE ROLE 	9-1

APPENDICES
APPENDIX A   -    FIGURES
APPENDIX B   -    TABLES
APPENDIX C   -    RESPONSIVENESS SUMMARY
APPENDIX D   -    ADMINISTRATIVE RECORD INDEX
APPENDIX E   -    MASSACHUSETTS DEPARTMENT  OF ENVIRONMENTAL
                  PROTECTION LETTER OF CONCURRENCE
APPENDIX F   -    GLOSSARY OF ACRONYMS AND  ABBREVIATIONS

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Figure                                         Title
1    Location Map U.S.  Army Sudbury Annex
2    Location of AOCs A4,  A7,  and A9
3    Site Map for AOC A4
4    Site Map for AOC A7
5    Site Map for AOC A9
Table                                          Title

1    Human Health Risk Assessment Chemicals of Potential Concern at AOC A4
2    Summary of Human Health Baseline Risk Assessment for AOC A4
3    Human Health Risk Assessment Chemicals of Potential Concern At AOC A7
4    Summary of Human Health Baseline Risk Assessment for AOC A7
5    Human Health Risk Assessment Chemicals of Potential Concern At AOC A9
6    Summary of Human Health Baseline Risk Assessment for AOC A9

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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION

Areas of Contamination A4, A7, and A9
U.S. Army Sudbury Annex
Middlesex County, Massachusetts

STATEMENT OF PURPOSE AND BASIS

This decision document presents the U.S. Army's selected remedial action decision for Area of
Contamination (AOC) A4 - Waste Dump and the Management of Migration Operable Units (OUs) at AOCs A7-01d
Gravel Pit Landfill and A9-POL Burn Area, at the U.S. Army Sudbury Annex, Middlesex County,
Massachusetts. It was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) as amended, 42 USC °° 9601 et seg. and the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP) as amended, 40 CFR Part 300, to the extent
practicable. The Sudbury Annex Base Realignment and Closure (BRAG) Environmental Coordinator; the Devens
Reserve Forces Training Area (RFTA) Installation Commander; and the Director of the Office of Site
Remediation and Restoration, U.S. Environmental Protection Agency (USEPA) New England have been delegated
the authority to approve this Record of Decision.

This decision document is based on the Administrative Record that has been developed in accordance with
Section 113(k) of CERCLA. The Administrative Record is available for public review at the Devens BRAG
Environmental Office, Building 666, Devens RFTA, Massachusetts, and at the Sudbury, Massachusetts Town
Hall. 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 U.S. Army and USEPA, with concurrence of the Massachusetts Department of Environmental Protection
(MADEP) , have determined that no action is necessary to ensure protection of human health and the
environment at AOC A4 and the Management of Migration OUs at AOCs A7 and A9. Therefore, the Army's
selected remedy is No Action Under CERCLA. At AOCs A7 and A9, previous removal and containment actions
have eliminated underground storage tanks and removed or contained contaminated media which would
otherwise be a continuing source of groundwater contamination.

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DECLARATION

The U.S. Army and the USEPA, with concurrence of the MADEP, have determined that No Action Under CERCLA
is necessary for protection of human health and the environment at AOC A4 and the Management of Migration
OUs at AOCs A7 and A9. The selected remedy is consistent with CERCLA and to the extent practicable the
NCP. Based on previous source area removal and containment actions and the results of the Site
Investigation and Remedial Investigation, no action is necessary for AOC A4 and the Management of
Migration OUs at AOCs A7 and A9 to ensure protection of human health and the environment.

Because this is a decision for No Action Under CERCLA, the statutory reguirements of CERCLA Section 121
for remedial actions are not applicable, and no five-year review will be undertaken as part of this
remedy. The Army will conduct long-term groundwater monitoring at AOC A7 as part of the remedy for the
AOC A7 Source Control OU and will conduct five-year site reviews as part of that remedy.

The foregoing represents the decision for No Action Under CERCLA 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

Concur and recommend for immediate implementation:

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1.0 SITE NAME, LOCATION, AND DESCRIPTION

The U.S. Army Sudbury Annex (the Annex) is a National Priorities List (NPL) site under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The Annex occupies
approximately 4.3 square miles (2,750 acres) in the Massachusetts towns of Hudson, Marlborough, Maynard,
Stow, and Sudbury. It is located approximately 20 miles west of Boston and 12 miles northwest of Natick,
Massachusetts (Figure 1 in Appendix A). Hudson Road divides the installation into two sections: the
larger, northern section, and the smaller, southern section. The Annex became part of Fort Devens, now
the Devens Reserve Forces Training Area (RFTA), in 1982.

The Annex historically served as a munitions storage area, ordnance test area, research and development
facility, and as a troop training ground. The Annex currently contains military family housing, guest
housing, a geophysical radar station operated by the U.S. Air Force, and offices for the Federal
Emergency Management Agency (FEMA).

This Record of Decision addresses past releases of contaminants to all media at Area of Contamination
(AOC) A4-Waste Dump, and past releases to groundwater at AOC A7-01d Gravel Pit Landfill and AOC
A9-Petroleum Oil, and Lubricant (POL) Burn Area. For the purposes of site remediation, a source control
(soil) operable unit (OU) and a management of Migration (groundwater) OU was created for AOCs A7 and A9.
Source control actions are documented in the Record of Decision for the source control OUs for AOCs A7
and A9. All three AOCs are located within the northern section of the Annex (Figure 2 in Appendix A).

In September 1995, the Annex was identified for cessation of operations and closure under the Defense
Base Realignment and Closure (BRAG Act of September 1990, Closure is tentatively scheduled for November
1997. Except for a small area to be retained for Army housing within the southern section of the
installation, the Annex will be transferred to three federal agencies. The majority of the land has been
requested by the U.S. Fish and Wildlife Service (USFWS) and will become part of the Great Meadows
National Wildlife Refuge. The U.S. Air Force and FEMA have also requested small parcels to continue
their existing operations at the Annex.

A more complete description of the Annex can be found in the Site/Remedial Investigation Report, Fort
Devens Sudbury Training Annex, Middlesex County, Massachusetts, and the Addendum Site/Remedial
Investigation Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts, prepared by
OHM Remediation Services, Inc. in 1994 and 1995, respectively). These reports, referred to as the SI/RI
and SI/RI addendum reports in this Record of Decision, are both available for review at the BRAG
Environmental Office at Devens RFTA, Devens Massachusetts, and the town libraries in Hudson, Maynard, and
Stow.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.1 LAND USE AND RESPONSE HISTORY

The facility presently known as the Annex was established in the late 1930s as the Maynard Ammunition
Sub-depot. The properly was acquired by the U.S. Government in 1942 and named the Maynard Ammunition
Backup Storage Point. It was used for ammunition storage and as a loading point for ammunition being
transported overseas. Following World War II, jurisdiction over the facility was transferred from the
Chief of Transportation to the Chief of Ordnance. In 1950, control of the facility was transferred to
the First Army, as a subinstallation of Fort Devens, for storage and training.

In 1952, the facility, under control of the Chief of Ordnance, became known as the Maynard Ordnance Test
Station. From 1952 to 1957, the primary military activities at the facility involved classified research
and development by the Universal Match Corporation and the Arthur D. Little Company that may have
included rocket, pyrotechnics, and explosives testing. At the expiration of the Universal Match
Corporation contract in 1957, the Ordnance Corps transferred control of the facility to the Quartermaster
Corps to help relieve crowded conditions at the nearby Natick Laboratories. In December 1957, the
facility was designated the Maynard Quartermaster Test Activity.

From 1957 to 1982, the Annex was used as a field resource by Natick Laboratories. The Natick Laboratories
mission was research and development in the physical, behavioral, and biological sciences, and
engineering to develop commodities such as clothing and protective equipment. Physical research and
development activities included the development of air drop techniques, field shelters and equipment,
field organization equipment, fuel delivery systems, and food and food service systems. Scientific
research and development included determination of the stability of various fungicides in materials
exposed to outdoor environments, foamed plastics field tests, flame testing of clothing and equipment,
toxic fumigant effects on insects, and the study of climatic data in support of various test programs and
air drop testing.

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In 1982, operational control of the Annex was transferred to Fort Devens. From 1982 through 1994, the
Annex was used by Fort Devens to support its mission to train active duty and reserve personnel, and to
support the U.S. Army Security Agency Training Center and School, U.S. Army Reserves, National Guard,
Reserve Officer Training Corps, and Air Defense sites in New England. By agreement with Fort Devens,
Natick Laboratories retained certain use and occupancy rights after property transfer to Fort Devens.
This agreement included conditional use of approximately 8 acres of land known as the POL Burn Area, use
of a 30-acre area as an air drop zone, use of specific storage areas, and use of a field evaluation
course.

Other agencies and organizations that have used or leased portions of the Annex include the U.S. Air
Force and its contractors, Raytheon Corporation, Massachusetts Air National Guard, Massachusetts State
Police Academy, Massachusetts Army National Guard, Massachusetts Fire Fighting Academy (MFFA), and FEMA.

2.1.1 AOC A4-Waste Dump

AOC A4 is located near the Eastern Gate and the intersection of Craven Lane and Patrol Road (Figure 3 in
Appendix A). It occupies an area of approximately 1,000 by 200 feet along the northwestern side of
Craven Lane, from Patrol Road to a wetland on the site's southwestern border. The center of the site
consists of a grassy area, whereas trees and low bushes are present along the edges. The land surface
slopes gradually from Craven Lane toward the southwest. Groundwater flow is toward the west and the
wetland at the western site boundary. The site contains a surface dump near its southwest end and a
building foundation dated to the late 1600's at the northeast end. At the time of the SI/RI, the ground
surface was littered with plastic bags, empty food and beverage cans, empty paint cans, demolition
debris, and glass. The site reportedly was used for the burial of unidentified chemical wastes and drums
over a three to four year period from the late 1960s to early 1970s.

The following items summarize the history of AOC A4:

• Late 1960s to early 1970s. During this period, AOC A4 was reportedly used for the burial of
unidentified chemical wastes and drums.

• 1980. AOC A4 (then designated Location 15) was identified as a suspected waste disposal
site by the Army during a records search.

• 1983. The Army Environmental Health Agency (AEHA) performed an hydrogeologic and subsurface
assessment which included installation of one groundwater monitoring well at AOC A4.

• 1984. A pre-CERCLA investigation was performed to characterize groundwater quality
downgradient of reported dumping areas. Groundwater sampling indicated low concentrations
of inorganics, volatile organic compounds (VOCs), and semivolatile organic compounds
(SVOCs). Of the detected analytes, iron, manganese and methylene chloride exceeded U.S.
Environmental Protection Agency (USEPA) drinking water standards; however, iron and
manganese concentrations were consistent with background concentrations and methylene
chloride was concluded to be the result of laboratory contamination. It was concluded that
the presence of other analytes not attributable to background conditions or laboratory
procedures could be indicative of a low degree of groundwater contamination. Surface water
and sediment samples collected from the bordering stream did not show significant
contamination.

• 1991-1993. A two phase RI was performed to assess the nature and extent of contamination in
surface soil, groundwater, sediment, and surface water at the site. Investigations included
geophysical surveys to locate buried drums and other disposal debris, installation of
additional groundwater monitoring wells and several test pits, collection of soil and
groundwater samples, and a baseline risk assessment.

Because of seasonal dry-weather conditions, surface water samples could not be collected,
and shallow groundwater samples were substituted. This was subsequently identified as a
data gap.

• 1996. Data gap investigations were performed to assess surface water contamination. The
technical memorandum prepared to discuss the findings of the data gap activities concluded
that chemicals of potential concern in surface water were present at or below background
concentrations and did not pose unacceptable risk to human health or the environment. The
technical memorandum recommended that no further action be taken concerning soil and
groundwater at AOC A4.

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A more detailed description of AOC A4 site history can be found in the Site/Remedial Investigation
Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts; the Addendum Site/Remedial
Investigation Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts; and the Final
Technical Memorandum, Remedial (Data Gap) Investigation, Area of Contamination A4, US. Army Sudbury
Annex. These three reports are available for review at the BRAG Environmental Office at Fort Devens, and
the town libraries in Hudson, Maynard, and Stow.

2.1.2 AOC A7-01d Gravel Pit Landfill

AOC A7 is a 10-acre site located on the north side of Patrol Road along the northern installation
boundary (Figure 4). The northern edge of the site is within approximately 100 feet of the Assabet
River. The site is generally wooded, but does have a large sandy clearing near its center. The ground
surface slopes toward the north and the Assabet River from Patrol Road.

Groundwater flow is also to the north. Aerial photographs indicate the area was first used as a source
for gravel during the early 1940s.

Interviews with Natick Laboratories employees identified AOC A7 as the location of laboratory chemical
dumping from the late 1950s through 1971. Chemicals were reportedly buried in a shallow trench as well
as poured directly onto the ground. General refuse was reported buried at the site as early as 1941; a
practice which continued into the 1980s. Refuse including metal pipes, abandoned fuel tanks, drums, and
debris was observed during site investigations. Site P8, a reported transformer disposal site, is
situated along the eastern edge of AOC A7. Site P8 was identified in 1990 as the possible location of
transformer disposal within the A7 site. During the file search, no reference to transformer disposal at
the site could be located.

The following items summarize the history of AOC A7:

• Early 1940s through early 1950's. Site used as a borrow pit.

• 1940's through 1980s. AOC A7 used for general refuse dumping, burning, and burial.

• Late 1950s through 1971. AOC A7 reportedly used for disposal of waste chemicals.

• 1980. AOC A7 (then designated Location 12) was identified as a dumping, chemical disposal,
and burning ground by the Army during a records search.

• 1983. AEHA installed one groundwater monitoring well and performed groundwater sampling and
analysis for drinking water parameters as part of an investigation to evaluate the
hydrogeologic setting and groundwater guality. The only detections were low concentrations
of fluoride and nitrate.

• 1984. A second monitoring well was installed and groundwater samples collected. In
addition, surface water and sediment samples were collected from a small unnamed stream at
the eastern edge of the site. Analytical results indicated potential groundwater
contamination with phthalates and inorganics, including hexavalent chromium. Surface water
samples contained low concentrations of iron and acetone, and sediment contained arsenic at
concentrations consistent with background and low concentrations of several polynuclear
aromatic hydrocarbons (PAHs).

• 1991-1993. A two phase RI was performed to assess the nature and extent of contamination in
surface soil, subsurface soil, groundwater, sediment, and surface water at the site.
Investigations included a geophysical study, test pit excavation with subsurface soil
sampling, surface soil sampling, installation of soil borings with soil sampling,
installation of additional groundwater monitoring wells with groundwater sampling, surface
water and sediment sampling, an hydrogeologic assessment, an ecological assessment, and a
baseline risk assessment.

Although groundwater contamination was identified, the SI/RI addendum report was unable
to conclude whether it had migrated beyond the installation boundary. This was identified
as a data gap reguiring additional investigation.

• 1993. A feasibility study was performed to evaluate potential remedial alternatives for
source area (soil) and management of migration (groundwater) OUs at AOC A7.

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September 1995. The Record of Decision for the Source Control Operable Unit at AOC A7 was
signed. The selected source area remedy included removal of chemical waste debris in the
laboratory dump area, considered to be the primary source of groundwater contamination,
construction of a double-barrier (RCRA Subtitle C) landfill cap to contain remaining site
contaminants, operation and maintenance, institutional controls and land use restrictions to
limit future use of the land at AOC A7, long-term groundwater monitoring, and five-year
site reviews to assess whether the remedy remains protective of human health and the
environment.

• July-November 1996. A part of the source area cleanup, chemical waste debris in the
laboratory dump area, was excavated for off site disposal, and a double-barrier (RCRA
Subtitle C) landfill cap was constructed to contain remaining site contaminants. The
two-acre landfill cap was used to contain approximately 6,200 cubic yards of waste material
from AOC A7 as well as 5,800 cubic yards of non-hazardous material from other Annex sites
needed as fill to meet the design specifications for the cap.

• 1996. Data gap investigations were performed to assess whether groundwater contamination
had migrated beyond the installation boundary. The technical memorandum prepared to discuss
the findings of the data gap investigations concluded that although groundwater
contamination was present beyond the installation boundary, it did not pose an unacceptable
risk to human health or the environment. The technical memorandum recommended that no
further action be taken concerning groundwater at AOC A7.

February 1997. The Final Operations and Maintenance Plan For The Landfill At Area Of
Concern A7 outlined the long-term monitoring program for AOC A7. The initial program
includes semi-annual sampling of 13 monitoring wells located to enable assessment of
contaminant migration from AOC A7. These monitoring wells include wells along the site
perimeter and three wells located near the Assabet River to monitor potential contaminant
migration toward the river. Samples will be analyzed, at a minimum for the following
parameters: VOCs, pesticides, metals, phosphate, sulfate, chloride, nitrate, ammonia, total
dissolved solids, chemical oxygen demand, dissolved oxygen, and cyanide.

A more detailed description of AOC A7 site history can be found in the Site/Remedial Investigation
Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts, the Addendum Site/Remedial
Investigation Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts; and the Final
Technical Memorandum, Remedial (Data Gap) Investigation, Area of Contamination A7, U.S. Army Sudbury
Annex. These three reports are available for review at the BRAG Environmental Office at Fort Devens, and
the town libraries in Hudson, Maynard, and Stow.

2.1.3 AOC A9-POL Burn Area

AOC A9 is an eight acre site located on the north side of Patrol Road along the northern installation
boundary, approximately 600 feet north of AOC A7 (Figure 5 in Appendix A). The northern edge of the site
is within approximately 100 feet of the Assabet River. The site is level and predominately grassy with
some pine and oak trees along the western and northern edge. Groundwater in the area flows toward the
Assabet River.

AOC A9 was used for flame testing of fire regardant clothing, POL testing and/or storage, MFFA training,
and destruction of confiscated fireworks. Testing of fire regardant clothing involved exposing clothing
to a JP-4 jet fuel fire in an asphalt lined pit. A 1,000 gallon underground storage tank (UST) (Site
P-12) was used to store JP-4 at the site, presumably to supply fuel for this testing. Testing reportedly
occurred during a two week period each year from the late 1950s to the 1980s.

Starting around 1970, the MFFA used the area to conduct training on flammable liguid fires. This training
reportedly involved extinguishing fires of No. 2 fuel oil and JP-4 tank bottoms floating on water in a
shallow concrete pit. Other fire training was conducted in unlined pits and trenches. This training
continued until at least 1994 and also included control of flames and smoke associated with the testing
of fire regardant clothing by Natick Laboratories. Natick Laboratories also performed some POL testing
at the site.

The Massachusetts State Police burned confiscated fireworks at AOC A9 from the early-to-mid 1970s until
1991.

During a 1986 site inspection by representatives by the Massachusetts Department of Environmental Quality
Engineering (MADEQE), numerous drums of unidentified material were being stored at the site.

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The following items summarize the history of AOC A9:

• Late 1950s-1986. Natick Laboratories conducted fire regardant clothing testing at the site.

• 1962. Natick laboratories began POL testing and continued for an unknown length of time.
• 1970-1984. MFFA conducted fire training exercises at the site.

• Mid 1970s-1991. Massachusetts State Police burned confiscated fireworks at the site.

• 1980. AOC A9 (then designated Location 4) was identified as a fire test facility by the
Army during a records search.

• 1984. Investigation of the site begins. Samples collected between 1984 and 1987 indicate
that surface soil is contaminated with PAHs, phthalates, and hydrocarbons. Groundwater is
contaminated with chlorinated VOCs and fuel related hydrocarbons including ethylbenzene,
toluene, and xylenes.

• March 1986. Representatives of the MADEQE observed standing oil in trenches, oil stained
soils, and unmarked drums at the site.

• June 1986. All above ground tanks and drums are removed.

• 1987-1988. Approximately 1,100 cubic yards of contaminated soil are removed up to a depth
of approximately 26 feet below ground surface (bgs) and disposed of under manifest.

• 1991-1993. A two phase RI was performed to assess the nature and extent of contamination in
surface soil, subsurface soil, and groundwater at the site. Investigations included a
geophysical study, soil-gas study, surface and subsurface soil sampling, installation of
additional groundwater monitoring wells with groundwater sampling, an hydrogeologic
assessment, an ecological assessment, and a baseline risk assessment.

The SI/RI addendum report identified both petroleum-related and chlorinated solvent
contamination in groundwater. Although free-phase chlorinated solvents were not
encountered during SI/RI activities, the inability to rule out the presence of a dense non-
agueous phase liguid (DNAPL) plume was considered a data gap.

1992. The 1,000 gallon UST (Site P-12) and approximately 31 cubic yards of contaminated
soil were removed.

• 1993. A feasibility study was performed to evaluate potential remedial alternatives for
source area (soil) and management of Migration (groundwater) OUs at AOC A9.

• 1996. As part of the source area cleanup, approximately 11 cubic yards of contaminated soil
from hot spot locations were excavated and transported to AOC A7 for containment under a
landfill cap.

• 1996. Data gap investigations were performed to assess the presence or absence of DNAPL at
AOC A9. The technical memorandum prepared to discuss the findings of the data gap
investigations concluded that DNAPL plumes were not present and recommended that no further
action be taken concerning groundwater at AOC A9.

A more detailed description of AOC A9 site history can be found in the Site/Remedial Investigation
Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts; the Addendum Site/Remedial
Investigation Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts; and the Final
Technical Memorandum, Remedial (Data Gap) Investigation, Area of Contamination A9, U.S. Army Sudbury
Annex. These three reports are available for review at the BRAG Environmental Office at Fort Devens, and
the town libraries in Hudson, Maynard, and Stow.

2.2 ENFORCEMENT HISTORY

On January 29, 1987, the Annex was classified as a Federal Facility under the jurisdiction, custody, and
control of the U.S. Department of Defense, within the meaning of Executive Order 12580, and within the
meaning of the Defense Environmental Restoration Program (DERP) , 10 U.S.C., Section 2701 et seg.

On February 21, 1990, the Annex was placed on the NPL under CERCLA, as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), to evaluate and implement response actions to cleanup
past releases of hazardous substances, pollutants, and contaminants. A Federal Facility Agreement (FFA)

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to establish a procedural framework for ensuring that appropriate response actions are implemented at the
Annex was developed and signed by the U.S. Army and the USEPA Region I on May 13, 1991, and finalized on
November 15, 1991. AOCs A4, A7, and A9 are considered subsites to the entire installation.

In 1991, the U.S. Department of Defense, through the U.S. Army Environmental Center  (USAEC),  initiated an
SI/RI for AOCs A4, A7, and A9, and the final SI/RI report was issued in January 1994.  An addendum to the
report was issued in September 1995.  The purpose of the SI/RI was to determine the nature and extent of
contamination, assess human health and ecological risks, and assess whether additional response actions
were necessary.  A feasibility study to develop and evaluate candidate alternatives to protect human and
ecological receptors from unacceptable risks associated with potential exposure to contaminated media at
AOCs A7 and A9 was completed in 1995.

The Proposed Plan detailing the Army's plan of No Action Under CERCLA for AOC A4 and the Management of
migration OUs at AOCs A7, and A9 was issued in June 1997 for public comment.  Technical comments
presented during the public comment period are included in the Administrative Record.  The Responsiveness
Summary, Appendix C to this Record of Decision, contains a summary of these comments and the Army's
responses, and describes how these comments affected the No Action Under CERCLA decision.

3.0  COMMUNITY PARTICIPATION

The Army has held guarterly public Technical Review Committee (TRC) meetings, issued newsletters and
press releases, and held a number of public meetings to keep the community and other interested parties
informed of activities at the Annex.

In April 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 the Annex.  As part of this plan, the Army established a TRC, which first met May 13, 1991.
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), U.S. Army Corps of
Engineers  (USAGE) , local officials, and the community.  The TRC meets guarterly to review and provide
technical comments on schedules, work plans, work products, and proposed activities for the study areas
at Sudbury Annex.  The SI/RI, SI/RI addendum, and feasibility study reports, technical memoranda,
Proposed Plan, and other related support documents were submitted to the TRC for their review and
comment.

During the week of June 9, 1997, the Army published a public notice announcing the Proposed Plan, public
informational meeting, and public hearing in the Sudbury Town Crier, the Middlesex News, the
Marlborough-Hudson Enterprise, the Stow Villager, and the Maynard Beacon.  The Army also made the
Proposed Plan available to the public at the information repositories at the libraries in Stow, Hudson,
Sudbury, and Maynard, and at Devens RFTA.

From June 9 through July 8, 1997, the Army held a 30-day public comment period to accept public comments
on the Proposed Plan.  On June 10, 1997, the Army held an informal public hearing at the Stow Town
Building, in Stow, Massachusetts to discuss the Proposed Plan and to accept verbal or written comments
from the public.  Verbal comments were received from the Four Town Focus and subseguently were elaborated
upon in writing.  Public comments and the Army's response to comments are included in the Responsiveness
Summary  (Appendix C of this Record of Decision).

All supporting documentation for the No Action Under CERCLA decision for AOC A4 and the Management of
Migration OUs at AOCs A7 and A9 is contained in the Administrative Record The Administrative Record is a
collection of all the documents considered by the Army in making the No Action Under CERCLA decision.  On
March 20, 1994, the Army made the Administrative Record available for public review at the Sudbury Annex
BRAG Environmental Office, and at the Sudbury Town Hall, Sudbury, Massachusetts.

4.0  SCOPE AND ROIiE OF RESPONSE ACTION

This No Action decision addresses all media at AOC A4 and the management of migration  (i.e.,  groundwater)
OUs at AOCs A7 and A9 at the U.S. Army Sudbury Annex.  The risk assessments contained in the SI/RI and
SI/RI addendum reports for these AOCs indicate that environmental media at AOC A4 and groundwater
contamination at AOCs A7 and A9 does not pose an unacceptable risk to human health or the environment.
Technical memoranda for AOCs A4, A7, and A9 completed subseguent to the SI/RI reports provide additional
support for this conclusion. Based on this conclusion, the U.S.  Army and the USEPA, with the concurrence
of the MADEP, have determined that No Action Under CERCLA is reguired for AOC A4 and the Management of
migration OUs at AOCs A7 and A9.

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Potential risks to human health and the environment posed by AOC A4 have not previously been addressed by
a Record of Decision. Potential risks to human health and the environment posed by source area OUs
(i.e., contaminated soil and waste material) at AOCs A7 and A9 were addressed in the final Record of
Decision for source control OUs for A7 and A9 signed in September 1995. No other OUs or known sources of
contamination of concern exist at these AOCs.

USEPA has the authority to revisit the No Action Under CERCLA decision if future conditions indicate that
an unacceptable risk to human health or the environment would result from exposure to contaminants at
AOCs A4, A7, and A9. Such a review could occur even if the Annex is removed from the NPL.

5.0 SUMMARY OF SITE CHARACTERISTICS

The Army performed SI/RI activities in 1992 and 1993 and data gap activities in 1996 to characterize the
nature and distribution of contaminants at AOCs A4, A7, and A9. Detailed descriptions of the
investigations and available data are presented in the SI/RI and SI/RI addendum reports as well as
technical memoranda. The following subsections summarize significant findings of the contamination
assessments from those reports.

5.1 AOC A4

Soils. During the Phase I and Phase II RI sampling, eight surface soil and 23 subsurface soil samples
were collected for analysis. In general, target analytes included Target Compound List (TCL) VOCs,
SVOCs, pesticides, polychlorinated biphenyls (PCBs), chlorinated herbicides, explosives, and Target
Analyte List (TAL) metals. Several samples were also analyzed for organophosphorus pesticides and total
petroleum hydrocarbons (TPH).

VOCs were detected at low concentration in several Phase I samples; however, all were attributed to
laboratory contamination or to naturally occurring turpenes. Only one SVOC, chrysene, was detected above
soil screening concentrations. Because it was found in only one sample of 24, it was not considered a
chemical of potential concern (COPC).

All pesticide detections were at concentrations less than Massachusetts Contingency Plan (MCP) S-l/GW-1
standards. TPH was detected at a maximum concentration of 35 Ig/g. PCBs and explosives were not
detected. With the exception of lead and zinc, all metals were detected at concentrations less than
screening criteria or at concentrations representative of background.

Groundwater. A total of 17 groundwater samples were collected from six monitoring wells during Phases I
and II of the SI/RI. In general, target analytes included TCL VOCs, SVOCs, pesticides, PCBs, chlorinated
herbicides, explosives, and TAL metals. Several samples were also analyzed for organophosphorus
pesticides.

VOCs were not detected above screening criteria in any samples. Toluene was detected at a low
concentration in the Phase I sample from one monitoring well; it was not detected in Phase II samples.
Only one SVOC was detected; however, its presence was attributed to laboratory contamination. Pesticides
were detected in samples from two monitoring wells at concentrations below federal drinking water Maximum
Contaminant Levels (MCLs). PCBs and explosives were not detected.

Several inorganics were detected in groundwater. Of these, lead in one unfiltered Phase I sample showed
the greatest potential to be a contaminant of concern. Analysis of unfiltered and filtered samples from
the same monitoring well in Phase II showed unfiltered concentrations well below the federal drinking
water action level of 15 micrograms per liter (Ig/L). Lead was not detected in the filtered sample.
Aluminum, iron, and manganese were detected in several samples at concentrations greater than federal
drinking water Secondary Maximum Contaminant Levels (SMCLs). No other metals were detected at
concentrations above screening criteria.

Surface Water. Characterization of surface water during the Phase I and Phase II SI/RI included
collection and analysis of seven surface water samples. Most of the samples were analyzed for TCL VOCs,
SVOCs, pesticides, PCBs, chlorinated herbicides, explosives, and TAL metals. Several samples were also
analyzed for organophosphorus pesticides.

There were no positive identifications of VOCs and SVOCs or confirmations of explosives in the samples.
The pesticides endrin aldehyde and 2,2-bis(para-chlorophenyl)-1,1,1-trichloroethane (DDT) and the
herbicide dacthal were each reported once. No other pesticides or herbicides were reported.

Concentrations of metals, including lead, aluminum, chromium, copper, and zinc, exceeded aguatic life
screening criteria at several locations. With the exception of zinc, exceedances were attributed to the

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presence of high suspended particulate concentrations in the samples. Elevate concentrations of zinc
were attributed to laboratory contamination. Concentrations of arsenic were below screening criteria for
aguatic life, but exceeded human health screening criteria.

As part of data gap activities to assess surface water contamination, three surface water samples were
collected in 1996 and, based on evaluation of previous data, analyzed for lead. Lead was not detected in
two of the samples and was present at a concentration below background in the third.

Sediment. Sediment samples were collected from eleven locations during the Phase I and Phase II SI/RI.
Most of the samples were analyzed for TCL VOCs, SVOCs, pesticides, PCBs, chlorinated herbicides,
explosives, and TAL metals. Phase II samples were also analyzed for organophosphorus pesticides.

Several VOCs and SVOCs were detected in sediment samples, but all were common laboratory contaminants and
were not considered site-related. The pesticides 2,2-bis(para-chlorophenyl)-1,1-dichloroethane (DDD) and
2,2-bis(para-chlorophenyl)-1,1-dichloroethene (DDE) were both detected once at low concentrations. The
explosive HMX was detected in one Phase I sample.

Concentrations of several metals, including arsenic, beryllium, barium, copper, lead, nickel, and
selenium, were detected at concentrations exceeding screening criteria. However, the SI/RI addendum
report concluded that detected concentrations were consistent with concentrations in the Assabet River
and that distribution patterns did not suggest that AOC A4 was a significant contributor to sediment
metal concentrations.

Summary. Surface and subsurface soil data are consistent with previous dumping of organic chemicals at
the site. Elevated concentrations of lead were present at isolated locations. Groundwater data show
concentrations of aluminum, iron, and manganese above SMCLs. Although concentrations of metals in SI/RI
surface water samples appear high, this is likely the result of high concentrations of suspended matter
in the samples. Surface water samples collected during data gap investigations had concentrations of
lead which were less than background. AOC A4 does not show widespread contamination and does not appear
to be a source of sediment or surface water contamination.

A complete discussion of AOC A4 site characteristics can be found in Section 2.0, of the SI/RI addendum
report and the AOC A4 Technical Memorandum.

5.2 AOC A7

Soils. Characterization of soil during the SI/RI included collection of 14 surface soil samples,
collection of 53 soil samples from 19 test pit locations, and collection of 27 soil boring and 2
hand-auger subsurface soil samples. In general, these samples were analyzed for TCL VOCs, SVOCs,
pesticides, PCBs, chlorinated herbicides, explosives, and TAL metals. A portion of Phase II samples were
also analyzed for organophosphorus pesticides.

At the laboratory waste disposal area soil contaminants exceeding screening criteria were primarily
pesticides and chlorinated VOCs. The organochlorine pesticides dieldrin, lindane, DDD, and DDT were
detected at concentrations greater than screening criteria. Chlordane, heptachlor, heptachlor epoxide,
DDE, and PCBs were also detected. The organophosphorus pesticides Demeton-0, Fenthion, and methyl
parathion were also detected at concentrations greater than screening criteria. In the VOC analyses,
1,1,2-trichloroethane, 1,2-dichloroethane, chloroform, and tetrachloroethene were detected at
concentrations greater than screening criteria. Acetone, chlorobenzene, ethylbenzene, trichloroethene,
and xylenes were also detected. Lead was detected in all 10 subsurface soil samples from this area.

At the solid waste landfill, exceedances of screening criteria for were noted for DDT, DDD, and DDE only
in the south-central portion of AOC A7. Within this small area, DDT, DDD, and DDE were detected at
concentration above screening criteria. The only other compound detected above screening criteria in
this area was the SVOC 2-methylnaphthalene.

In the southeastern portion of AOC A7, exceedances of screening criteria for the pesticides endrin,
heptachlor epoxide, and total chlordane were noted in samples from test pit A7TPS. An exceedance of
total chlordane was also noted in the sample from soil boring A7B12. Lead was detected in test pit
A7TPS.

SVOCs were detected at concentrations greater than screening criteria at two closely spaced sampling
locations in the north-central portion of AOC A7. Chrysene was detected at a depth of 2.0 to 4.0 feet
bgs in test pit A7TPE. 2-Methynaphthalene, benzo(a)anthracene, and benzo(a)pyrene were detected at
surface soil sampling location A7S06.

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Groundwater. Groundwater sampling during the SI/RI included collection of 30 samples from 10 monitoring
wells. Target analytes generally consisted of TCL VOCs, SVOCs, pesticides, PCBs, chlorinated herbicides,
explosives, phosphate, and TAL metals.

Groundwater quality in the vicinity of the laboratory waste disposal area was assessed with data from
monitoring wells OHM-A7-8, OHM-A7-45, and OHM-A7-46. The groundwater quality downgradient (north) of
this source area was assessed with data from monitoring wells OHM-A7-51 and OHM-A7-52. Exceedances of
groundwater screening criteria were primarily noted in source area wells OHM-A7-8 and OHM-A7-46, and in
downgradient monitoring well OHM-A7-51. The majority of the contaminants detected in the groundwater
were also present at elevated concentrations in area soils.

The pesticides lindane, DDD, and dieldrin and the VOCs 1,1,2-trichloroethane, acetone, carbon
tetrachloride, chloroform, and tetrachloroethene, all detected at elevated concentrations in area soils,
were also detected in source area groundwater at concentrations exceeding screening criteria. Lead was
not detected above screening criteria in any of the monitoring wells.

During the ground water sampling event performed in December 1993, both unfiltered and filtered
groundwater samples were submitted for pesticide and PCB analysis for all monitoring wells in, and
downgradient of, the laboratory waste disposal area. Pesticides were detected at similar concentrations
in both the unfiltered and filtered samples from several monitoring wells.

Groundwater quality downgradient of the solid waste landfill area was assessed with data from ground
water samples collected from monitoring wells OHM-A7-9, OHM-A7-10, OHM-A7-11, and OHM-A7-12. An
exceedance of the drinking water action level for lead in one sampling round was not confirmed during two
other sampling rounds. Lead is therefore not considered to be a contaminant of concern in groundwater in
this area. Methylene chloride was detected a total of 5 times in these monitoring wells at
concentrations slightly exceeding the MCL. Four of these detections occurred during the October 3, 1991
sampling event, while the fifth occurred during the June 25, 1992 sampling event. None of the methylene
chloride detections were confirmed during other sampling events, and SI/RI report considered the positive
detections laboratory artifacts. These analytical results indicate that buried solid waste in the
central and eastern portions of AOC A7 is not significantly affecting groundwater quality at this time.

Data gap activities to assess contaminant migration in groundwater included installation of three new
monitoring wells and collection and analysis of two rounds of groundwater samples from the three new and
six existing monitoring wells. Target analytes consisted of VOCs and pesticides. The analytical results
showed that contamination with VOCs and lindane did extend beyond the installation boundary, however,
comparison of data from existing monitoring wells with previous data indicated that concentrations were
generally lower than in earlier samples collected from those monitoring wells.

Surface Water. Characterization of surface water was based on seven surface water/sediment pair samples
collected during the SI/RI and two surface water/sediment pair samples collected during earlier studies.
In general, the surface water samples were analyzed for TCL VOCs, SVOCs, pesticides, PCBs, chlorinated
herbicides, explosives, and TAL metals. Phase II samples were also analyzed for phosphorus and
organophosphorus pesticides.

VOCs and SVOCs were only detected in one sample collected in 1984. The reported organic compounds were
all common laboratory contaminants, and the lack of confirmatory results from subsequent sampling led to
the SI/RI conclusion that they are not contaminants of concern in the stream.

Arsenic was detected at A7SW2 and E3-BCK-D03 at concentrations below the freshwater chronic Ambient Water
Quality Criteria (AWQC), but above the human health AWQC. Although arsenic, lead, zinc and aluminum were
detected in several surface water samples from AOC A7 and Study Area (SA) P9 at concentrations above
USEPA Region I Environmental Services Assistance Team (ESAT) surface water and freshwater chronic AWQC
criteria, all concentrations were below maximum background values. Elevated zinc concentrations were
attributed to laboratory contamination, as the rinseate blank concentrations were comparable to the field
sample concentrations. Aluminum exceeded ESAT criteria at A7SW2 and A7SW3. In general, there were no
significant differences in metal concentrations between the upstream and downstream sample locations.

Sediment. Sediment characterization was based on seven surface water/sediment pair samples collected
during the SI/RI and two surface water/sediment pair samples collected during earlier studies. Sediment
samples were analyzed for TCL VOCs, SVOCs, pesticides, PCBs, chlorinated herbicides, explosives, total
organic carbon, and TAL metals. Phase II samples were also analyzed for phosphorus and organophosphorus
pesticides.

VOCs were only detected in samples collected during the RI The three detected VOCs (acetone, methyl ethyl
ketone, and methylene chloride) are common laboratory contaminants and were not considered site-related
contaminants. Several PAHs were detected at one sampling location in 1984. PAHs were not detected in

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the sediment sample which was collected immediately downstream of that location in 1993.

Pesticides and PCBs were not detected in the sediment samples from AOC A7. DDE and DDT were detected at
concentrations above ESAT sediment criteria in one background sample. DDT, ODD, and DDE were also
detected at concentrations above screening values in sediment samples collected from upstream locations
at SA P9.

Arsenic, barium, nickel, and selenium were all detected at concentrations above ESAT sediment criteria.

Summary. Although several chemicals identified as soil contaminants of concern at AOC A7 were also
detected in surface water or sediment samples, there was no significant difference in concentrations
between samples collected upstream of the site and those collected downstream of the site. Therefore,
the SI/RI concluded that site-related activities have not affected stream guality and that the stream is
not acting as a pathway for contaminants to migrate from AOC A7 to the Assabet River. Groundwater data
from data gap activities shows that concentrations of groundwater contaminants are decreasing.

A complete discussion of AOC A7 site characteristics can be found in Section 3.0, of the SI/RI addendum
report. Supplemental information regarding 1996 groundwater sampling can be found in the AOC A7
Technical Memorandum.

5 . 3 AOC A9

Soils. A total of 11 surface soil and 46 subsurface soil samples were collected to characterize soil
contamination during the SI/RI. In general, these samples were analyzed for TCL VOCs, SVOCs, pesticides,
PCBs, explosives, and TAL metals. Soil samples from Phase II borings were also analyzed for
organophosphorus pesticides.

Chemicals detected above screening levels in AOC A9 soil samples were primarily metals. Arsenic was
detected at concentrations above background at the upstream end of the culvert at the southwest corner of
AOC A9; however, additional samples from the vicinity of the culvert indicate that it is not migrating
downgradient. Its presence may have been related to past agricultural use. Lead was detected above
background in one sample collected near the drum storage area, but not at several nearby locations,
suggesting that lead contamination was not widespread. Thallium was also detected above background at
one location.

Several VOCs and SVOCs were detected in surface and subsurface soil samples from AOC A9. Of these,
acetone, methylene chloride, 2-methyl naphthalene, and di-n-butylphthalate exceeded screening criteria.
Acetone and methylene chloride were attributed to laboratory contamination. Detected pesticide and PCB
concentrations were less than local background upper confidence limits.

Data gap activities included the drilling of an additional soil boring along the interpreted migration
pathway of a chlorinated VOC DNAPL plume and collecting split spoon samples at 5-foot intervals. Field
screening of sample container headspace with a photoionization detector did not indicate the presence of
any VOCs. In addition, no stains or odors suggesting the presence of DNAPLs were observed. Gas
chromatograph screening of four samples and confirmatory analysis of two samples did not detect any VOCs.

Groundwater. Groundwater characterization during the SI/RI included review of data from 25 samples from
a total of 15 monitoring wells. Target analytes generally consisted of TCL VOCs, SVOCs, pesticides,
PCBs, explosives, phosphate, and TAL metals. The ten groundwater samples analyzed during Phase II
investigations were also analyzed for organophosphorus pesticides.

Several chlorinated and petroleum related VOCs were detected in AOC A9 groundwater at concentrations
above MCLs. Chlorinated VOCs (1,1,1-trichloroethane, 1,1-dichloroethene, methylene chloride, and
trichloroethene) appear limited to an area downgradient of the fire-pit area. The petroleum-related
compounds ethylbenzene and toluene were detected in monitoring wells downgradient of the former UST
location. The SVOCs naphthalene and 2-methylnaphthalene and the explosives 3-nitrotoluene and
1,3,5-trinitrobenzene were also detected in monitoring wells in areas downgradient of the former UST
location.

The only metal detected above drinking water standards was lead in a sample from downgradient of the
former UST location. Its presence was considered consistent with the presence of petroleum compounds at
the site.

Data gap activities included the collection and analysis of samples from four monitoring wells located
within the area of historic chlorinated VOC groundwater contamination. Analysis was for VOCs only.
Analytical results for three of the four wells showed VOC concentrations consistent with or less than
previous results. Concentrations were somewhat higher than previously observed at the fourth monitoring

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well, but provided no indication of a DNAPL plume.

Summary. Primary soil contaminants at AOC A9 include arsenic and lead at isolated locations, but do not
appear widespread. Two groundwater plumes exist at the site: one containing chlorinated compounds
downgradient of the fire-pit, and one containing petroleum-related compounds downgradient of the former
UST location. Concentrations decrease with increasing downgradient distance, suggesting that
degradation/attenuation is occurring. Data gap activities did not identify a DNAPL plume at AOC A9.

A complete discussion of AOC A9 site characteristics can be found in Section 4.0, of the SI/RI addendum
report. Additional groundwater data can be found in the AOC A9 Technical Memorandum.

6.0 SUMMARY OF SITE RISKS

A Baseline Risk Assessment was completed for AOCs A4, A7, and A9 in 1994 during the Phase I SI/RI. A
subseguent addendum to the risk assessment was prepared to evaluate whether data collected during the
Phase II SI/RI modified the findings of the 1994 risk assessment. The risk assessments contained in the
SI/RI and SI/RI addendum reports evaluate the probability and magnitude of potential adverse human health
effects associated with exposure to contaminated media at AOCs A4, A7, and A9. 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
Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts,
and the Addendum Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex, Middlesex
County, Massachusetts.

The human health risk assessments prepared in 1994 evaluated current and future exposure pathways which
included, respectively, site trespassers and site residents. Since then, the reasonably foreseeable
future use scenario of the majority of the Annex has changed from residential development to wildlife
refuge, and the anticipated human exposure pathway for AOCs A4, A7, and A9 has changed from a residential
pathway to a recreational pathway, however, the risk assessments were not revised and potential future
risks under the new future use were gualitatively evaluated in the SI/RI addendum report. Under the base
closure process, the Annex property will be transferred to three agencies, with the USFWS receiving
approximately 2,000 acres of land. Therefore, the residential future use scenario evaluated in the risk
assessments provides a conservative estimate of risk from exposure to site contaminants. Human exposure
under a recreational use scenario would be much more limited than exposure under a residential use
scenario.

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level
by the chemical-specific cancer slope factor. Cancer slope factors have been developed by USEPA 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 predicted
risk. The resulting risk estimates are expressed in scientific notation as a probability (e.g., 1x10 -6
for 1/1,000,000) and indicate (using this example) that an individual has a one-in-a-million chance of
developing cancer as a result of site-related exposure over 70 years to the particular compound at the
stated concentration. Current USEPA practice considers cancer risks to be additive when assessing
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-carcinogenic health effects. The HI is the sum of the hazard guotients (HQs) for individual
chemicals with similar exposure pathways and toxic endpoints. A HQ is calculated by dividing the
exposure level by the reference dose (RfD) or other suitable benchmark for non-carcinogenic 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 epidemiological or animal studies
and incorporate uncertainty factors to help ensure that adverse health effects will not occur. The HQ is
often expressed as a single 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 given chemical). The HQ is only considered additive for chemicals that have the
same or similar toxic endpoint. (For example, the HQ for a chemical known to produce liver damage should
not be added to a second whose toxic endpoint is kidney damage).

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Under the current USEPA Superfund policy, acceptable exposures to carcinogens are those that represent an
excess upper bound lifetime cancer risk of between 1 x 10 -4 and 1 x 10 -6. For noncarcinogenic effects,
acceptable exposure levels are those with an HI of 1.0 or less.

A basewide ecological risk assessment that was not specific to individual AOCs was finalized in January
1994 as part of the SI/RI. The SI/RI addendum report supplemented the basewide assessment by including
individual ecological risk assessments that focused on AOCs A4, A7, and A9.

The results of the human health risk assessments, followed by a discussion of the ecological risk
assessment, are discussed below for AOCs A4, A7, and A9,.

6.1 SUMMARY OF RISKS AT AOC A4

The following subsections summarize the results of the baseline risk assessment and ecological risk
assessment for AOC A4.

6.1.1 Human Health Risk Assessment Summary for AOC A4

The COPCs listed in Table 1 in Appendix B of this Record of Decision were selected for evaluation in the
AOC A4 baseline human health risk assessment of the SI/RI report. These COPCs were selected to represent
potential site-related hazards based on toxicity, concentration, frequency of detection, and mobility and
persistence in the environment.

Potential human health effects associated with exposure to the COPCs were estimated quantitatively or
qualitatively through the development of 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 detailed discussion of the human health risk assessment approach and results is presented in the
SI/RI report and the SI/RI addendum report.

Current Land Use

• Soil: Adolescent trespasser exposure to soil contaminants through direct contact and
subsequent ingestion or dermal exposure.

Future Land Use

• Soil: Residential exposure through dermal exposure or ingestion

• Sediment: Residential exposure through dermal exposure or ingestion

• Groundwater: Residential exposure through ingestion

Table 2 in Appendix B of this Record of Decision summarizes the human health risks at AOC A4 identified
in the baseline risk assessment of the SI/RI report. This table also shows which exposure pathways are
most responsible for the estimated risks.

Review of Table 2 shows that for an adolescent under current land use conditions the estimated potential
cancer risk for soil exposure is 2 x 10 -8 for Reasonable Maximum Exposure (RME) conditions and 1 x 10 -8
for central tendency or average exposure conditions. These values are below the USEPA 1 X 10 -4 to 1 x
10 -6 target risk range. The RME case assumes that all of a receptor's exposure is to the maximum
contaminant concentrations observed at the site, and is therefore a conservative estimate. His for
potential RME to noncarcinogenic COPCs in soil are well below USEPA's benchmark value of 1.0. There is
no current use or exposure to groundwater.

Under the evaluated future residential scenario, the estimated potential cancer risks for soil are 3x10
-7 under RME conditions and 1x10 -7 under average conditions, both less than the USEPA target risk range
of 1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to soil contaminants are 0.3
and 0.1 under RME and average conditions, respectively.

Under the evaluated future residential scenario, the estimated potential cancer risks for sediment are
3x10 -5 under RME conditions and 1x10 -5 under average conditions, both within the USEPA target risk
range Of 1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to sediment contaminants
are 0.1 and 0.07 under RME and average conditions, respectively.

The estimated potential cancer risks for groundwater under the evaluated future residential scenario are
6x10 -5 under RME conditions and 2x10 -5 under average conditions, both within the USEPA target risk

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range Of 1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to groundwater
contaminants are 0.5 and 0.1 under RME and average conditions, respectively.

The total estimated potential cancer risks for exposure to soil and groundwater under the evaluated
future residential scenario are 6x10 -5 under RME conditions and 2x10 -5 under average conditions, both
within the USEPA target risk range Of 1x10 -4 to 1x10 -6. Noncancer His associated with residential
exposure to soil and groundwater contaminants are 0.8 and 0.2 under RME and average conditions,
respectively.

Potential risks from exposure to lead were evaluated using the USEPA Uptake/Biokinetic (UBK) model.
Assuming continuous consumption of groundwater with the maximum observed concentration of 190 Ig/L, the
model predicts that blood lead levels in children would exceed the target level of 10 micrograms per
deciliter after two years. Excluding this single value, lead concentrations at AOC A4 do not produce
blood lead levels above the USEPA target value.

Chemicals with the greatest contribution to the baseline risk estimates were lead,
bis(2-ethylhexyl)phthalate, and arsenic in groundwater and lead and arsenic in soil. Actual risks are
likely to be substantially lower than indicated by the baseline risk assessment. Arsenic was present at
background concentrations in soil and was detected only once in AOC A4 groundwater; the reported
concentration, 3 Ig/L, was well below the MCL of 50 Ig/L. Lead concentrations were high in the October
1992 sampling round (190 Ig/L), but were not detected in other samples.

The SI/RI addendum report reviewed the data obtained during the Phase II SI/RI to evaluate whether
modification of the baseline risk assessment was appropriate. The Phase II data were generally
consistent with Phase I data. The data confirmed that high concentrations of lead do not appear
widespread in soil or groundwater. Lead was not considered a concern in groundwater. Beryllium was
detected at greater concentrations in soil, but still at concentrations considered indicative of
background. Sediment concentrations of beryllium were also higher during Phase II sampling. Maximum
detected concentrations beryllium resulted in a cancer risk of 1x10 -5, within the USEPA target range.

Using both Phase I and Phase II data, the Army concluded that contaminants at AOC A4, and groundwater
contaminants in particular, do not pose an unacceptable risk to human health risk.

Surface water data collected during data gap activities showed that the data evaluated during the SI/RI
were not representative of surface water conditions and that lead in surface water at and near AOC A4
poses no human health risk beyond background conditions.

6.1.2 Ecological Risk Assessment Summary for AOC A4

A number of chemicals were detected in samples from AOC A4 during the Phase I and II investigations. The
ecological risk assessment of the SI/RI addendum report compared detected concentrations with background
concentrations and with screening level toxicity criteria to assess whether the chemicals were COPCs.
Tables 3-1 through 3-6 of the ecological risk assessment (Appendix C of the SI/RI addendum report)
provide those comparisons. The tabulated chemicals include the following:

Soil

• metals, organochloride pesticides, herbicides, explosives, SVOCs, and chlorinated and non-
chlorinated solvents

Groundwater

• chlorinated solvents, organochlonide pesticides, and acetone

Surface Water

• iron

Sediment

• metals, solvents, nitrosamine, and an insect repellent

The risk assessment concluded that there is no significant risk to ecological receptors.

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6.2 SUMMARY OF RISKS AT AOC A7

The following subsections summarize the results of the baseline risk assessment and ecological risk
assessment for AOC A7.

6.2.1 Human Health Risk Assessment Summary for AOC A7

The COPCs listed in Table 3 in Appendix B of this Record of Decision were selected for evaluation in the
AOC A7 baseline human health risk assessment of the SI/RI report. These COPCs were selected to represent
potential site-related hazards based on toxicity, concentration, frequency of detection, and mobility and
persistence in the environment.

Current Land Use

• Soil: Adolescent trespasser exposure to soil contaminants through direct contact and
subsequent ingestion or dermal exposure.

Future Land Use

• Soil: Residential exposure through dermal exposure or ingestion

• Sediment: Residential exposure through dermal exposure or ingestion

• Groundwater: Residential exposure through ingestion

Table 4 in Appendix B of this Record of Decision summarizes the human health risks at AOC A4 identified
in the baseline risk assessment of the SI/RI report. This table also shows which exposure pathways are
most responsible for the estimated risks.

Review of Table 4 shows that for an adolescent under current land use conditions the estimated potential
cancer risk for soil exposure is 3x10 -5 for RME conditions and 3x10 -6 for central tendency or average
exposure conditions. These values are within the USEPA 1x10 -4 to 1x10 -6 target risk range. The RME
case assumes that all of a receptor's exposure is to the maximum contaminant concentrations observed at
the site, and therefore a conservative estimate. His for potential RME to noncarcinogenic COPCs in soil
are well below USEPA's benchmark value of 1.0. There is no current use or exposure to groundwater.

Under the evaluated future residential scenario, the estimated potential cancer risks for soil are 3x10
-4 under RME conditions, slightly greater than the USEPA target range of 1x10 -4 to 1x10 -6, and 4x10 -5
under average conditions, within the USEPA target risk range. Noncancer His associated with residential
exposure to soil contaminants are 4 and 0.4 under RME and average conditions, respectively.

Under the evaluated future residential scenario, the estimated potential cancer risks for sediment are
2x10 -5 under RME conditions and 1x10 -5 under average conditions, both within the USEPA target risk
range of 1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to sediment contaminants
are 0.7 and 0.6 under RME and average conditions, respectively.

The estimated potential cancer risks for groundwater under the evaluated future residential scenario are
2x10 -4 under RME conditions, slightly greater than the USEPA target risk range of 1x10 -4 to 1x10 -6,
and 3x10 -5 under average conditions, within the USEPA target risk range. Noncancer His associated with
residential exposure to groundwater contaminants are 1 and 0.2 under RME and average conditions,
respectively.

The total estimated potential cancer risks for exposure to soil and groundwater under the evaluated
future residential scenario are 5x10 -4 under RME conditions, slightly greater than the USEPA target risk
range of 1x10 -4 to 1x10 -6, and 7x10 -5 under average conditions, within the USEPA target risk range of
1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to soil and groundwater
contaminants are 5 and 0.6 under RME and average conditions,
respectively.

-------
Potential risks from exposure to lead were evaluated using the USEPA UBK model. Based on the UBK model,
lead does not pose a health risk at AOC A7.

Much of the risk estimated for AOC A7 in the baseline risk assessment was associated with areas of
localized contamination. As a result, for risks of the estimated magnitude to occur, freguent contact
with these hotspots would be reguired. Such contact would be unlikely, even in the event of residential
development. Conseguently, actual risks would be lower, guite possibly substantially lower, than the
estimated risks based on maximum concentrations.

The SI/RI addendum report reviewed the data obtained during the Phase II SI/RI to evaluate whether
modification of the baseline risk assessment was appropriate. The Phase II data were generally
consistent with Phase I data, although several chemicals were found at somewhat higher concentrations in
Phase II samples. The SI/RI addendum report concluded that source area controls and incorporation of AOC
A7 into the Great Meadows National Wildlife Refuge would lower potential exposure to levels within or
below the USEPA target risk range. Source area controls consisting of removal of laboratory waste,
construction of a RCRA Subtitle C multi-layer cap, institutional controls, and long-term groundwater
monitoring were implemented in 1996. There is no current human health exposure pathway associated with
groundwater at AOC A7. In addition, the property downgradient of AOC A7, between the site and the
Assabet River, is zoned Recreation-Conservation and is classified as unbuildable by the Town of Stow.
Following incorporation of AOC A7 into the Great Meadows National Wildlife Refuge, future residential
exposure will not be a realistic exposure scenario.

6.2.2 Ecological Risk Assessment Summary for AOC A7

A number of chemicals were detected in samples from AOC A7 during the Phase I and II investigations. As
a preliminary step, the ecological risk assessment of the SI/RI addendum report compared detected
concentrations with background concentrations and with screening level toxicity criteria to assess
whether the chemicals were COPCs. Only chemicals of potential ecological concern, as identified through
screening, were carried through the ecological risk assessment. Tables 4-1 through 4-8 of the ecological
risk assessment (Appendix C of the SI/RI addendum report) provide those comparisons. The tabulated
chemicals include the following:

Soil

• metals, organochloride pesticides, VOCs, and SVOCs

Groundwater

• trace concentrations of solvents, pesticides, and an insect repellent (probably introduced
during sampling)

Surface Water

• one pesticide

Sediment

• solvents and metals

As a result of the screening comparisons, the SI/RI addendum report identified the following chemicals of
potential ecological concern at AOC A7:

Soil

• the pesticides DDT, dieldrin, endrin, and chlordane

PCBs

• the PAHs benzo(a)anthracene, benzo(a)pyrene, and phenanthrene

• lead

Sediment

• the inorganics arsenic, barium, copper, and nickel

-------
Groundwater

• the pesticides DDT, lindane, and heptachlor epoxide

• the chlorinated VOCs chloroform, tetrachloroethene, 1,1,2,2-tetrachloroethane, and
trichloroethene

Potential risks to aquatic ecosystem were evaluated by comparing detected groundwater concentrations to
Ambient Water Quality Criteria with consideration given to the dilution offered by surface water in the
Assabet River and the ability of river sediments to bind contaminants and reduce their mobility. The
SI/RI addendum report concluded that chemicals in site affected groundwater were likely to have an
insignificant effect on aguatic life.

Potential risks to terrestrial ecosystems were evaluated by comparison of detected soil concentrations to
dietary benchmark values for voles, shrews, and robins. With the exception of a very high HQ for
exposure of the robin to DDT, all calculated HQs were less than 5. Although the HQ for the robin was
high, the benchmark value was inconsistent with other data and considered suspect. The SI/RI addendum
report concluded that chemicals in soil affected by the site do not pose a substantial risk to
terrestrial receptors.

Although comparison of sediment data to available criteria suggested that potential adverse effects were
possible, the results of a Rapid Bioassessment Protocol evaluation showed that conditions in the site's
stream were typical of what would expected in the absence of contamination. Therefore, it was concluded
that site conditions were not adversely affecting stream organisms.

In summary, the risk assessment concluded that there is no significant risk to ecological receptors at
AOC A7.

6.3 SUMMARY OF RISKS AT AOC A9

The following subsections summarize the results of the baseline risk assessment and ecological risk
assessment for AOC A9.

6.3.1 Human Health Risk Assessment Summary for AOC A9

The COPCs listed in Table 5 in Appendix B of this Record of Decision were selected for evaluation in the
AOC A9 baseline human health risk assessment of the SI/RI report. These COPCs were selected to represent
potential site-related hazards based on toxicity, concentration, frequency of detection, and mobility and
persistence in the environment.

Current Land Use

• Soil: Adolescent trespasser exposure to soil contaminants through direct contact and
subsequent ingestion or dermal exposure.

Future Land Use

• Soil: Residential exposure through dermal exposure or ingestion

• Groundwater: Residential exposure through ingestion

Table 6 in Appendix B of this Record of Decision summarizes the human health risks at AOC A9 identified
in the baseline risk assessment of the SI/RI report. This table also shows which exposure pathways are
most responsible for the estimated risks.

Review of Table 6 shows that for an adolescent under current land use conditions the estimated potential
cancer risk for soil exposure is 7x10 -6 for RME conditions and 2x10 -6 for central tendency or average
exposure conditions. These values are within the USEPA 1x10 -4 to 1x10 -6 target risk range. The RME
case assumes that all of a receptor's exposure is to the maximum contaminant concentrations observed at
the site, and is therefore a conservative estimate. His for potential RME to noncarcinogenic COPCs in

-------
soil are well below USEPA's benchmark value of 1.0. There is no current use or exposure to groundwater.

Under the evaluated future residential scenario, the estimated potential cancer risks for soil are 1x10
-4 under RME conditions, and 3x10 -5 under average conditions, both within the USEPA target risk range of
1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to soil contaminants are 0.6 and
0.2 under RME and average conditions, respectively.

The estimated potential cancer risks for groundwater under the evaluated future residential scenario are
2x10 -4 under RME conditions, slightly greater than the USEPA target risk range of 1x10 -4 to 1x10 -6,
and 3x10 -5 under average conditions, within the USEPA target risk range of 1x10- 4 to 1x10 -6.
Noncancer His associated with residential exposure to groundwater contaminants are 10 and 1 under RME and
average conditions, respectively.

The total estimated potential cancer risks for exposure to soil and groundwater under the evaluated
future residential scenario are 2x10 -4 under RME conditions, slightly greater than the USEPA target risk
range of 1x10 -4 to 1x10 -6, and 6x10 -5 under average conditions, within the USEPA target risk range Of
1x10 -4 to 1x10 -6. Noncancer His associated with residential exposure to soil and groundwater
contaminants are 10 and 1 under RME and average conditions, respectively.

Potential risks from exposure to lead were evaluated using the USEPA UBK Model. Based on the UBK model,
lead does not pose a health risk at AOC A9.

It is likely that the baseline risk assessment provided a conservative estimate of the risks at AOC A9.
Much of the baseline risk estimate was associated with sporadic detection of single chemicals and
freguent repeated contact with these hotspots is unlikely. The chemical posing the greatest risk at AOC
A9 was arsenic, which was detected in a single water sample at 4 Ig,/L, well below the MCL of 50 Ig/L.
Several other chemicals which contributed to risk were also present in only a single sample.

The SI/RI addendum report reviewed the data obtained during the Phase II SI/RI to evaluate whether
modification of the baseline risk assessment was appropriate. Because several VOCs were detected in
Phase II groundwater data at concentrations greater than reported in the Phase I data, additional
guantitative evaluation was performed under the residential exposure scenario. The re-estimate of cancer
risks was somewhat greater (maximum risk of 1x10 -3) than reported in the baseline risk assessment,
primarily as a result of higher 1,1-dichloroethene concentrations. However, the SI/RI addendum report
stressed that AOC A9 groundwater does not meet MADEP criteria for a domestic water source and that its
use as drinking water was unlikely. The potential for domestic use of groundwater is eliminated by
incorporation of AOC A9 into the Great Meadows National Wildlife Refuge. The SI/RI addendum report
concluded that natural attenuation processes would likely reduce contaminant concentrations and further
reduce the evaluated exposure risks.

6.3.2 Ecological Risk Assessment Summary for AOC A9

A number of chemicals were detected in samples from AOC A9 during the Phase I and II investigations. As
a preliminary step, the ecological risk assessment of the SI/RI addendum report compared detected
concentrations with background concentrations and with screening level toxicity criteria to assess
whether the chemicals were COPCs. Only chemicals of potential ecological concern, as identified through
screening, were carried through the ecological risk assessment. Tables 5-1 through 5-6 of the ecological
risk assessment (Appendix C of the SI/RI addendum report) provide those comparisons. The tabulated
chemicals include the following:

Soil
• metals, organochloride pesticides, VOCs, and SVOCs

Groundwater
• explosives, pesticides, VOCs, SVOCs, chlorinated solvents, and an insect repellent (probably
introduced during sampling)

As a result of the screening comparisons, the SI/RI addendum report identified the following chemicals of
potential ecological concern at AOC A9:

Soil
• the inorganics arsenic, lead, and thallium

Groundwater
• the VOCs ethylbenzene, toluene, xylene, and 1,1,1-trichloroethane

-------
Potential risks to aquatic ecosystems were evaluated by comparing detected groundwater concentrations to
Ambient Water Quality Criteria. The only chemicals exceeding criteria (i.e., ethylbenzene, toluene, and
lead) were in samples collected close to the center of the site and not in downgradient monitoring wells
closer to the Assebet River; conseguently, it appears that the chemicals are not migrating to the river
and are not posing a risk to aguatic life. Furthermore, dilution provided by the river would reduce
significantly any potential effect. The SI/RI addendum report concluded that chemicals in site-affected
groundwater were likely to have an insignificant effect on aguatic life.

Potential risks to terrestrial ecosystems were evaluated by comparison of detected soil concentrations to
dietary benchmark values for voles, shrews, and robins. Under the assumptions of the risk assessment,
inorganics at AOC A9 may pose risks to small mammals and birds such as vole, shrews, and robins.
However, based on the conservative nature of the screening level assessment; the SI/RI addendum report
concluded that chemicals in soil affected by the site do not pose a substantial risk to terrestrial
receptors.

In summary, the risk assessment concluded that there is no significant risk to ecological receptors at
AOC A9.

7.0 DESCRIPTION OF THE NO ACTION ALTERNATIVE

Based on the results of the Baseline Risk Assessments and ecological risk assessments in the SI/RI and
SI/RI addendum reports and the technical memoranda, No Action Under CERCLA is necessary to reduce
contaminant concentrations or control human health or ecological exposure for AOC A4 and the Management
of Migration OUs at AOCs A7 and A9. No five-year site reviews will be performed as part of this remedy.

Although there are no actions associated with the No Action Under CERCLA decision, the Army will continue
to monitor groundwater at and conduct five-year site reviews for AOC A7 as part of the remedy for the AOC
A7 Source Control OU. The Final Operations and Maintenance Plan for the Landfill Area of Concern A7
details the groundwater monitoring program. Land use restrictions associated with the source-area remedy
will be described in the Environmental Condition of Property report and included in the property transfer
documents.

8.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES

The U.S. Army presented a Proposed Plan for AOC A4 and the Management of Migration OUs at AOCs A7 and A9
on June 10, 1997. The Proposed Plan described the Army's plan to pursue No Action Under CERCLA at AOC A4
and the Management of Migration OUs for AOCs A7 and A9. There have been no significant changes made to
the No Action Under CERCLA proposal stated in the Proposed Plan.

9.0 STATE ROLE

The Commonwealth of Massachusetts has reviewed the SI/RI, SI/RI addendum, and feasibility study reports,
technical memoranda, and Proposed Plan and concurs with the No Action Under CERCLA decision. The
Commonwealth has also reviewed these documents to determine if the decision complies with applicable or
relevant and appropriate laws and regulations of the Commonwealth. A copy of the Declaration of State
Concurrence is attached as Appendix E of this Record of Decision.

-------
                                          APPENDIX B
                                            TABIiES

                                 TABLE 1
   HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN AT AOC A4

                          U.S. ARMY SUDBURY ANNEX
                  RECORD OF DECISION AOCs A4, A7, AND A9
CHEMICAL
VOLATILES
Acetone
Benzene
Methylene chloride
Methyl ethyl ketone
Toluene
alpha-Pinene
SEMIVOLATILES
Anthracene
Benzo(a)anthracene
Benzo(a)Pyrene
Benzo(g,h,i)perylene
bis(2-ethylhexyl)phthalate
Chrysene
Di-n-butylphthaiate
Fluoranthene
Indeno(1,2,3-c, d)pyrene
Phenanthrene
PESTICIDES AND PCB
DDE
DDT
Heptachlor epoxide
DEBT
alpha-Endosulfan
beta-Endosulfan
EXPLOSIVES
HMX
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
SOIL

 X

 X
 X
 X
 X
 X
 PHASEI

SEDIMENT

   X

   X
                                                     GROUND-
                                                      WATER
                        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
X
X
                                                                 SOIL
                        X
                        X
                        X
                        X
                        X
                        X

                        X
                        X
                        X

                        X
                        X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
PHASEII

SEDIMENT

   X
   X
                                                     GROUND-
                                                      WATER
                                   X
                                   X
                                             X
                                             X
                                             X

-------
                                             TABIiE 1
               HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL  CONCERN AT AOC A4

                                     U.S. ARMY SUDBURY ANNEX
                               RECORD OF DECISION AOCs A4, A7, AND  A9


CHEMICAL
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
MISCELLANEOUS
TOG
TPH


SOIL
X
X


X
X

X

PHASE I

SEDIMENT
X
X


X
X

X


GROUND-
WATER
X
X

X

X





SOIL
X
X

X
X
X

X
X
PHASE II
GROUND-
SEDIMENT WATER

X
X
X
X
X

X

Notes:

TOG  =   total organic carbon
TPH  =   total petroleum hydrocarbons
DDE  =   2,2-bis(para-chlorophenyl)-1,1-dichloroethene
DDT  =   2, 2-bis(para-chlorophenyl)-1,1,1-trichloroethene
DEBT =    N,N-Diethyl-3 methylbenzamide
HMX  =   Cyclotetramethylenetetranitramine

-------
                                       TABIiE 2
           SUMMARY OF HUMAN HEALTH BASELINE RISK ASSESSMENT FOR AOC A4
                             U.S. ARMY SUDBURY ANNEX
                   RECORD OF DECISION FOR AOCs A4,  A7, AND A9
Exposure Pathway

Current Land Use
Soil
       Adolescent exposure to soil contaminants
       through ingestion and dermal adsorption

Future Land Use
Soil
       Residential exposure to soil contaminants
       through ingestion and dermal adsorption

Sediment
       Residential exposure to soil contaminants
       through ingestion and dermal adsorption
                                                     Central Tendency
                                                     Cancer
                                                      Risk
1E-08
1E-07
IE-OS
Groundwater
       Residential exposure to contaminants through   2E-05
       groundwater use
         Hazard
         Index
          0.02
          0.1
          0.07
          0.1
    Reasonable
    Maximum
    Exposure
Cancer     Hazard
 Risk      Index
                     2E-C
                               0.05
                     3E-07     0.3
                     3E-05     0.1
                     6E-05     0.5
Total Future Risk:  Soil and Groundwater
                                                      2E-05
                                                                0.2
                                                                           6E-05     O.i

-------
                                          TABIiE 3
        HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN AT AOC A7

                                  U.S. ARMY SUDBURY ANNEX
                          RECORD OF DECISION AOCs A4, A7, AND A9
CHEMICAL                       SOIL
VOLATILES
cis-1, 2-Dichlorethylene
1,1,1-Trichlorethane
1,1,2-Trichloroethane           X
1,2-Dichlorethane               X
Acetone                         X
Carbon tetrachloride
Chlorobenzene                   X
Chloroform                      X
Chioromethane
Ethylbenzene
Methylene chloride              X
Methyl ethyl ketone
Nonane                          X
Octane                          X
Propylbenzene                   X
Tetrachloroethylene             X
Toluene                         X
Trichlorethylene                X
Trichlorfluoromethane           X
Xylenes (total)                 X
alpha-Pinene                    X
SEMIVOLATILES
1,2,3,4-Tetramethylbenzene      X
1, 3,5-Trimethylbenzene          X
l-Ethyl-2-methylbenzene         X
2-Methylnaphthalene             X
Anthracene                      X
Benzo(a)anthracene              X
Benzo(a)pyrene                  X
Benzo(b)fluoranthene            X
Benzo(g,h,i)perylene            X
bis (2-ethylhexyl)phthalate      X
Chrysene                        X
Di-n-butylphthalate             X
Fluoranthene                    X
Fluorene                        X
Hexadecanoic acid               X
Indeno(1,2,3-c,d)pyrene         X
N,N-bis(2-hydroxyethyl)
   dodecanamide
N-Nitrosodi-N-propylamine
Naphthalene                     X
                                         PHASE I
                                         SEDIMENT
                                                     GROUND-
                                                      WATER
            X
            X
            X
            X
            X
X

X
X

X
                                                                SOIL
                             PHASE II

                             SEDIMENT
X
X

X
X
X
GROUND-
 WATER

   X
   X
   X

   X
   X
   X
   X
                      X

                      X
X

X

-------
                                         TABIiE 3
          HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN AT AOC A7

                                 U.S. ARMY SUDBURY ANNEX
                         RECORD OF DECISION AOCs A4, A7, AND A9
CHEMICAL
Octadecanoic acid
Phenanthrene
Pyrene
PESTICIDES AND PCB
ODD
DDE
DDT
Dieldrin
Endrin
Endrin aldehyde
Endosulfan sulfate
Heptachlor
Heptachlor epoxide
Lindane
PCB 1242
PCB 1248
PCB 1254
PCB 1260
alpha-Benzenehexachloride
beta-Benzenehexachloride
alpha-Chlordane
gamma-Chlordane
alpha-Endosulfan
beta-Endosulfan
Demeton-0
Fenthion
Methyl parathion
EXPLOSIVES
Cyclonite  (RDX)
INORGANICS
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
SOIL
 X
 X
 X

 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X

 X
 X
 X
 X
 X
                                       PHASE I
                                       SEDIMENT
                                                   GROUND-
                                                    WATER
X
X
X
X
X
X
X

X
        SOIL

         X
X
X
X
X
                                         PHASE II

                                         SEDIMENT
                             GROUND-
                              WATER
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
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

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                                      TABLE 3
    HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN AT AOC A7

                             U.S. ARMY SUDBURY ANNEX
                    RECORD OF DECISION AOCs A4, A7, AND A9


CHEMICAL
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
MISCELLANEOUS
Dacthal (DCPA)
Silvex
Phosphate
Sulfur
TOG


SOIL
X
X
X

X

X
X

X
X

X
X
PHASE I PHASE II
GROUND- GROUND-
SEDIMENT WATER SOIL SEDIMENT WATER
X
X X
X XX
X
X
X X
X XX
X XXX



XX X

X XX
Notes:

ODD
DDE
DDT
TOG
2,2-bis(para-chlorophenyl)-1,1 -dichloroethane
2,2-bis(para-chlorophenyl)-1,1 -dichloroethene
2, 2-bis(para-chlorophenyl)-1,1,1 -thrichloroethene
total organic carbon

-------
                                         TABLE 4
                SUMMARY OF HUMAN HEALTH BASELINE RISK ASSESSMENT FOR AOC A7
                                U.S. ARMY SUDBURY ANNEX
                      RECORD OF DECISION FOR AOCs A4,  A7, AND AS
Exposure Pathway

Current Land Use
Soil
        Adolescent exposure to soil contaminants
        through ingestion and dermal adsorption

Future Land Use
Soil
        Residential exposure to soil contaminants
        through ingestion and dermal adsorption
Sediment
        Residential exposure to soil contaminants
        through ingestion and dermal adsorption
                                                       Central Tendency
                                                       Cancer
                                                        Risk
3E-06
4E-05
IE-OS
Groundwater
        Residential exposure to contaminants through    3E-05
        groundwater use
                      Reasonable
                        Maximum
                        Exposure
          Hazard   Cancer
          Index     Risk
           0.09
           0.4
           0.6
           0.2
                    3E-05
                    3E-04
                    2E-05
                    2E-04
Hazard
Index
                               0.9
                               0.7
Total Future Risk:  Soil and Groundwater
                                                        7E-05
                                                                   0.6
                                                                            5E-04

-------
                                     TABIiE 5
     HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN AT AOC A9

                            U.S. ARMY SUDBURY ANNEX
                   RECORD OF DECISION ACOCs A4, A7, AND A9
                                   PHASE I
                                                            PHASE  II
CHEMICAL                        SOIL
VOLATILES
cis- 1, 2-Dichlorethylene
1,1,1-Trichlorethane             X
1,1, 2-Trichloroethane
1,1-Dichlorethylene
1, 2-Dichlorethane
1,1,3-Trimethylcyclohexane       X
1,3-Dimethylclohexane            X
1,4-Dimethycyclohexane           X
Acetone                          X
Carbon tetrachloride
Chlorobenzene
Chloroform
Chioromethane
Ethylbenzene                     X
Ethylmethyl benzene
Methylene chloride               X
Methyl ethyl ketone              X
Nonane
Octane
Tetrachloroethylene
Toluene
Trichlorethylene
Trichlorfluoromethane
Xylenes (total)                  X
alpha-Pinene                     X
SEMIVOLATILES
1, 2, 3, 4-Tetramethyl benzene
1,2,3-Trimethylbenzene
1,3,5-Trimethylbenzene
l-Ethyl-2-methylbenzene
1-Methylnaphthalene
2-Methylnaphthalene              X
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene                   X
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
bis (2-ethylhexyl)phthalate       X
Chrysene                         X
Dibenzofuran                     X
Di-N-butylphthalate              X
GROUNDWATER


     X

     X
     X
     X
     X
     X
     X
     X
     X

     X
     X
     X
SOIL     GROUNDWATER


 X             X

               X
               X
               X
                 X

                 X

-------
                                        TABIiE 5
        HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF POTENTIAL CONCERN AT AOC A9

                               U.S. ARMY SUDBURY ANNEX
                       RECORD OF DECISION AOCs A4, A7, AND A9
                                   PHASE I
                                                           PHASE II
CHEMICAL
Di-N-octylphthalate
Fluoranthene
Fluorene
Hexadecanoic acid
Indeno(1,2,3-c,d)pyrene
N,N-bis(2
hydroxyethyl)dodecanamide
N-Nitrosodi-N-propylamine
Naphthalene
Octadecanoic acid
Phenanthrene
Pyrene
PESTICIDES AND PCB
DEBT
ODD
DDE
DDT
Endrin aldehyde
Heptachlor epoxide
PCB 1254
alpha-Chlordane
beta-Endosulfan
EXPLOSIVES
2, 6-Dinitrotoluene
1,3, 5-Trinitrobenzene
2,4, 6-Trinitrotoluene
3-Nitrotoluene
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
SOIL
 X
 X
 X
                                         GROUNDWATER
           SOIL    GROUNDWATER

            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
X
X
X
                           X

                           X
X
X
X

X
X
X
X
X
X
X
                                       X

                                       X
X
X
X

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                                             TABIiE  5
          HUMAN HEALTH RISK ASSESSMENT CHEMICALS OF  POTENTIAL CONCERN AT AOC A9

                                   U.S. ARMY SUDBURY ANNEX
                          RECORD OF DECISION AOCs  A4, A7,  AND A9

                           PHASE I                 PHASE  II

CHEMICAL             SOIL     GROUNDWATER      SOIL    GROUNDWATER
Nickel                X                        X
Potassium             X            X           X             X
Selenium                                       X
Sodium                             XXX
Thallium                                       X
Vanadium              X                        X
Zinc                  X            X           X             X
MISCELLANEOUS
Phosphate                          X
TOG                   X                        X

Notes:

ODD  =   2, 2-bis(para-chlorophenyl)-1,1-dichloroethane
DDE  =   2,2-bis(para-chlorophenyl)-1,1-dichloroethene
DDT  =   2,2-bis(para-chlorophenyl)-1,1,1-thrichloroethene
DEBT =   N,N-Diethyl-3 methylbenzamide
TOG  =   total organic carbon

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                                 TABIiE 6
       SUMMARY OF HUMAN HEALTH BASELINE RISK ASSESSMENT FOR AOC A9
                        U.S. ARMY SUDBURY ANNEX
              RECORD OF DECISION FOR AOCs A4,  A7, AND A9
Exposure Pathway

Current Land Use
Soil
        Adolescent exposure to soil contaminants
        through ingestion and dermal adsorption

Future Land Use
Soil
        Residential exposure to soil contaminants
        through ingestion and dermal adsorption

Groundwater
        Residential exposure to contaminants through
        groundwater use
                                                       Central Tendency
                                                       Cancer
                                                        Risk
2E-06
3E-05
3E-05
          Hazard
          Index
           0.03
           0.2
   Reasonable
    Maximum
    Exposure
Cancer     Hazard
 Risk      Index
                      7E-06
                      1E-04
                      2E-04
                                  0.1
                                  0.6
                                  10
Total Future Risk:  Soil and Groundwater
                                                        6E-05
                                                                              2E-04
                                                                                          10

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                                     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 of 1980  (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act of 1986  (SARA) ,  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) A4 and the management of migration operable units (OUs)  for AOCs A7 and A9 at the
U.S. Army Sudbury Annex.

The Army held a 30-day public comment period from June 9 through July 8, 1997, to provide an opportunity
for interested parties to comment on the site investigation/remedial investigation (SI/RI) reports,
feasibility study, technical memoranda, Proposed Plan, and other documents developed to address
contamination at AOCs A4, A7, and A9 at the U.S. Army Sudbury Annex A4,  A7,  and A9 and evaluated
potential human health and ecological risks.  In addition, data The SI/RI characterized soil, sediment,
groundwater, and surface water contamination at AOCs gap activities were performed to fill in data gaps
identified in the SI/RI and SI/RI addendum reports. Based on the results of the SI/RI, SI/RI addendum,
and technical memoranda summarizing data gap activities, the Army concluded that AOC A4 and management of
migration OUs at AOCs A7 and A9 did not pose unacceptable risks to human health or the environment.  The
Army identified its proposal for No Action Under CERCLA in the Proposed Plan issued on June 9, 1997.

All documents considered in arriving at the No Action Under CERCLA 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 AOCs A4, A7, and A9.  The Administrative Record is
available for public review at the U.S. Army Sudbury Annex BRAG Environmental Office, and at the Sudbury
Town Hall, Sudbury, Massachusetts.  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 this 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 Action Under CERCLA.

II.    Background on Community Involvement-This section provides a brief history of community involvement
       and Army initiatives in informing 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 during the public
       comment period. A transcript of the public meeting consisting of all comments received during this
       meeting and copies of written comments are also provided in Attachment C of this Responsiveness
       Summary.

I.     STATEMENT OF WHY THE ARMY RECOMMENDED NO ACTION UNDER CERCLA

The Army recommended No Action Under CERCLA because the risk assessments of the SI/RI indicate no
unacceptable risks to human health under the evaluated exposure scenario of future residential
development or to the environment.  Actual future use of AOCs A4, A7, and A9 will be as part of the Great
Meadows National Wildlife Refuge, and future residential exposure will not occur.  Because of this
potential risks would be lower than those estimated in the risk assessment.

II.    BACKGROUND ON COMMUNITY INVOLVEMENT

The Army has held quarterly public Technical Review Committee (TRC) meetings, issued newsletters and
press releases,  and held a number of public meetings to keep the community and other interested parties
informed of activities at the Annex.

In April 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 the Annex.   As part of this plan, the Army established a TRC,  which first met May 13, 1991.
The TRC, as required by SARA Section 211 and Army Regulation 200-1, included representatives from USEPA,
U.S. Army Environmental Center (USAEC), Fort Devens, Massachusetts Department of Environmental Protection

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 (MADEP) ,  U.S. Army Corps of Engineers  (USAGE), local officials, and the community.  The TRC generally met
guarterly to review and provide technical comments on schedules, work plans, work products, and proposed
activities for the study areas at the Annex.  The SI/RI, SI/RI addendum, and feasibility study reports,
technical memoranda, Proposed Plan, and other related support documents were submitted to the TRC for
their review and comment.

During the week of June 9, 1997, the Army published a public notice announcing the Proposed Plan, public
informational meeting, and public hearing in the Sudbury Town Crier, the Middlesex News, the
Marlborough-Hudson Enterprise, the Stow Villager, and the Maynard Beacon. The Army also made the Proposed
Plan available to the public at the information repositories at the libraries in Stow, Hudson, Sudbury,
and Maynard, and at Devens Reserve Forces Training Area  (RFTA).

From June 9 through July 8, 1976, the Army held a 30-day public comment period to accept public comments
on the Proposed Plan.  On June 10, 1997, the Army held an informal public hearing at the Stow Town
Building, in Stow, Massachusetts to discuss the Proposed Plan and to accept verbal or written comments
from the public.  Verbal comments were received and subseguently confirmed in writing.  Attachment C
contains a transcript of the public hearing.

All supporting documentation for the No Action Under CERCLA decision for AOC A4 and Management Of
Migration OUs at AOCs A7 and A9 is contained in the Administrative Record. The Administrative Record is a
collection of all the documents considered by the Army in making the No Action Under CERCLA decision.  On
March 20, 1994, the Army made the Administrative Record available for public review at the U.S. Army
Sudbury Annex BRAG Environmental Office, and at the Sudbury Town Hall, Sudbury, Massachusetts.

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

The Army received verbal comments from one citizen representative of the Four Town Focus during the
public hearing  (see Attachment C).  These comments were subseguently confirmed in writing in a letter
dated June 23, 1997 from Cambridge Environmental, Inc.  (Attachment A). Because of the similarities of the
verbal and written comments, the Army has prepared written responses for only the written comments.
These responses are contained in Attachment B.

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APPENDIX C

ATTACHMENT A - WRITTEN COMMENTS

June 23, 1997

Thomas Strunk
Sudbury Annex BEG
43 Buena Vista Street
P12 Box 224
Devens, MA 01433

Dear Mr. Strunk:

In response to the public meeting held on June 10, 1997, Four Town Focus (Focus) would like to offer the
following additional comments concerning the proposed determination of no further action for site A7.
These comments are intended to augment (and not replace) the comments submitted on June 6, 1997. At this
time, Focus is not convinced that all necessary steps have been taken to ensure that contamination from
this landfill will not cause a threat to human health and/or the environment.

1. The potential risk to the environment from contaminated groundwater at site A7 has not been fully
evaluated. The Ambient Water Quality Criteria (AWQC) and/or the Maximum Contaminant Levels (MCLs)
for several VOCs, metals, and lindane have been exceeded by concentrations measured in groundwater.
In the most recent sampling rounds, the pesticide lindane, for example, has been detected at
concentrations 14 times the MCL on site and 1.6 times the MCL down-gradient of the site.

The Remedial (Data-Gap) Investigation reports that adsorption of chemicals by sediments and dilution
of contaminants by the river would reduce contaminant concentrations in the surface water and thus
it is unlikely that site A7 may pose a significant ecological risk. As stated in our letter dated
June 6, 1997, sampling in the Assabet River would confirm that contaminant migration is not posing a
risk to environmental receptors. A guantitative justification of the adsorption and dilution of all
contaminants that exceed AWQC should also be provided to further demonstrate your position of no
significant risk. Further, if these contaminants are discharging to the Assabet, and have in the
past, is there a possibility that these chemicals have accumulated in the sediments? Again, Focus
would like a guantitative analysis of this matter.

2. The historical groundwater data presented in Table 1 shows that manganese exceeds the federal MCL
in all analyzed samples. Other metals including lead, iron, and aluminum also exceeded the MCLs.
Given these exceedences, why were the metals not sampled in subseguent groundwater testing? The
potential risk to human health and the environment from metals in the groundwater have not been
fully evaluated.

3. Groundwater was sampled between the Annex and the Assabet River. Who owns this property? What
zoning exists on this property? Is residential development feasible? Since the groundwater sampled
in this area has been shown to be unfit for human consumption, residential development should be
restricted. Are any measures being taken to ensure that residential development will not occur in
the future on this property?

4. Impacts to the bedrock aguifer have not been fully investigated. One bedrock well, OHM-A7-11, was
sampled in earlier rounds only. Incidently, Figure 3 incorrectly depicts the screen elevation for
this well. Dichloromethane and manganese concentrations exceeded the MCLs. Thus, potential
off-site migration of these contaminants should be considered, especially if there are homes using
private drinking water wells down-gradient of the site (see comment #5). Further, OHM-A7-11 is
located northeast of the contaminant plume and would not capture contaminant migration from this
disposal area.

-------
Thomas Strunk
Page 2
June 20,  1997

    Additional bedrock wells should be installed and sampled to determine if contaminated groundwater is
    reaching the bedrock aguifer that may then migrate off-site.   The Data-Gap Investigation report
    states that a planned well to be screened at the top of bedrock was not installed because bedrock
    was encountered at 10 feet below ground surface. Please elaborate on this point.   Where was this
    proposed well?  Why could it not be installed?  Why wasn't a well considered for the bedrock itself?
    Is there sufficient information to determine flow in the bedrock aguifer?  During the public
    meeting, the ABB consultant noted that the bedrock aguifer could not be influenced by contamination
    located above this aguifer due to pressure pushing the groundwater up.   What data were
    collected to support this claim?

5.  Focus would like more information concerning the homes, if any,  located down-gradient of site A7,
    across the Assabet River.  Where does their water come from (groundwater wells or public water)?  If
    private wells are being used, is public water available for these homes and were any of these wells
    sampled?  Is the bedrock aguifer being used as the water source?  If no homes currently exist across
    from A7, is the land zoned for residential development?  If so,  what measures are being taken to
    ensure that future private wells will be safe for human consumption?  We note that Massachusetts
    regulations call for the protection of groundwater in areas where a public water supply line is not
    available (within 500 feet).



Focus opposes the proposed no further action for site A7,  the Old Gravel Pit Landfill.  Additional
sampling both in the bedrock aguifer and the Assabet River and suitable justifications to the guestions
posed concerning site A7 are reguested at this time.  Focus awaits your response to these and previously
submitted comments either formally or informally, by June 27, 1997.   This deadline is reguested to
provide Focus with ample time prior to the comment submission deadline of July 8, 1997 to elicit
additional support if needed.  We see no need to involve our Federal and State Senators and
Representatives at this time if a reasonable solution can be agreed upon amongst the TRC members.

Thank you for your consideration.

Sincerely,

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APPENDIX C

ATTACHMENT B - RESPONSES TO PUBLIC COMMENTS

RESPONSE TO COMMENTS BY
CAMBRIDGE ENVIRONMENTAL, INC.
PREPARED ON BEHALF OF FOUR TOWN FOCUS
DATED JUNE 23, 1997
CONCERNING THE PROPOSED DETERMINATION OF NO FURTHER ACTION AT
AREA OF CONTAMINATION A7

Comment# Comment/Response

1. Comment: The potential Risk to the environment from contaminated groundwater at site A7 has not
been fully evaluated. The Ambient Water Quality Criteria (AWQC) and/or the Maximum Contaminant Levels
(MCLs) for several VOCs, metals, and lindane have been exceeded by concentrations measured in
groundwater. In the most recent sampling rounds, the pesticide lindane, for example, has been detected
at concentrations 14 times the MCL on site and 1.6 times the MCL down-gradient of the site.

The remedial (Data-Gap) Investigation reports that adsorption of chemicals by sediments and dilution of
contaminants by the river would reduce contaminant concentrations in the surface water and thus it is
unlikely that site A7 may pose a significant ecological risk. As stated in our letter dated June 6, 1997,
sampling in the Assabet River would confirm that contaminant migration is not posing a risk to
environmental receptors. A quantitative justification of the adsorption and dilution of all contaminants
that exceed AWQC should also be provided to further demonstrate your position of no significant risk.
Further, if these contaminants are discharging to the Assabet, and have in the past, is there a
possibility that these chemicals have accumulated in the sediments? Again, Focus would like a
quantitative analysis of this matter.

Response: The RI Data-Gap investigations were conducted in accordance with an approved Work Plan that
was specifically intended and designed to address gaps in the RI data-base (ABB-ES, 1996c). The draft
Work Plan for the Data-Gap investigations was prepared and distributed for public comment in March 1996
(ABB-ES, 1996b), and recommendations and comments on that document were considered prior to conducting
that work.

Please note that MCLs are standards developed to protect human receptors, and AWQCs are surface-water
guidelines for evaluating risks to ecological receptors.

In downgradient monitoring well JO-A7-M61, the pesticide lindane was detected at a maximum concentration
of 0.326 Ig/L. However, in monitoring well JO-A7-M63, which is farther downgradient and is the well
closest to the river (ABB-ES, 1997, Figures 5 and 6), the maximum detected concentration of lindane was
0.0979 Ig/L. Several rounds of sampling in these wells indicate that lindane concentrations are being
attenuated significantly between the source area and the Assabet River. The downgradient decrease in
lindane concentrations, as measured in groundwater samples collected in October 1996, is shown on
Attachment 1-A. The relationship between lindane concentration and distance from the source area is
calculated as y = 3.6014e -O.Olx where "y" (Ig/L) = concentration of lindane at distance "x" (feet) from
the source area.

At the Assabet River (410 feet from the source area), a lindane concentration of approximately 0.06 Ig/L
would be expected. This is below the AWQC of 0.08 Ig/L.

Typically, a dilution/attenuation factor of 10 is conservatively assumed for groundwater discharging to
surface water (i.e., the concentration of a contaminant in groundwater is assumed to be 10 times greater
than in the surface-water body into which the groundwater discharges.) For example, a factor of 10 was
applied to surface-water standards in deriving the GW-3 groundwater standards for the Massachusetts
Contingency Plan (310 CMR 40) (refer to MADEP, 1994). The GW-3 groundwater standards are designed to be
protective of ecological receptors in downgradient surface-water bodies. For AOC A7, a dilution factor
of 10 from the groundwater concentration would represent a lindane concentration of 0.006 Ig/L in the
Assabet River.

Actual dilution at AOC A7, where the plume of contaminated groundwater is discharging at a rate of 3.78 x
10 -3 cubic feet per second (ft 3/sec) (OHM, 1995b, Appendix C) into a river with an average annual flow
at the Maynard gauging station, between 1941 and 1996, of 189 ft 3/sec (U.S. Geological Survey, 1996),
would be substantially greater and would be expressed as:

-------
where
D = Dilution factor
V 1 = Flow of groundwater plume
V 2 = Flow of Assabet River

standard (5,000 Ig/L). Even without allowing for the effects of dilution and volatilization in the
river, these concentrations would not be considered a problem for aguatic organisms. No other VOCs were
detected above AWQCs in groundwater near the river.

Concentrations of metals in groundwater are addressed in response to Comment #2.

In May 1992 the Army collected nine sediment samples from the Assabet River at locations upstream,
downstream, and adjacent to AOC A7. Lindane and trichloroethylene were not detected in any of the
samples. Tetrachloroethene was detected only at sampling location FWISD15, at a concentration of 0.016
Ig/g. Sediment sampling location FWISD15 was in the Assabet River near the mouth of the unnamed stream
at the downstream boundary of AOC A7 (OHM, 1994). That concentration is substantially lower than the
applicable apparent effects threshold (AET) for aguatic organisms of >8.1 Ig/g. (This specific AET is
derived from Barrick and Seller's [1989] reported AET of >22 Ig per gram of organic carbon, corrected for
the detected organic carbon content of 37% in the Assabet River sediment sample.) These results indicate
that partitioning of the chemicals of concern from groundwater into sediments of the Assabet River does
not present a potential risk to aguatic organisms.

In 1996, the Army implemented remedial measures at AOC A7 in accordance with the Record of Decision for
the "Source-Control" Operable Unit. These measures included removal and off-site disposal of laboratory
wastes excavated from the identified source area and design and construction of an extensive landfill
cap. The principal objective of these measures has been to reduce the migration of contaminants, and it
is expected that contaminant concentrations in groundwater will decline. As part of the operation and
maintenance provisions of the Record of Decision, the Army is committed to conduct long-term monitoring
of groundwater guality in wells installed at the landfill and between the landfill and the Assabet River.

2. Comment: The historical groundwater data presented in Table 1 shows that manganese exceeds the
federal MCL in all analyzed samples. Other metals including lead, iron, and aluminum also exceeded the
MCLs. Given these exceedances, why were the metals not sampled in subseguent groundwater testing? The
potential risk to human health and the environment from metals in the groundwater have not been fully
evaluated.

Response: The Army has developed an extensive analytical data-base for metals in groundwater at AOC A7
(ABB-ES, 1997).

The MCLs for aluminum (200 Ig/L) , iron (300 Ig/L), and manganese (50 Ig/L) are actually secondary MCLs
(USEPA, 1996) . Secondary MCLs are unenforceable federal drinking-water guidelines that are based on
factors such as taste, odor, and color. They are not health-related. Furthermore, because there are no
current or potential future human groundwater receptors at AOC A7 or on the land located downgradient
from the facility (refer to responses to Comments #3, #4, and #5), there are no human-health risks from
ingestion of groundwater.

Concentrations of aluminum, iron, and manganese commonly exceed secondary MCLs in groundwater in New
England. These metals were also detected above the secondary MCLs upgradient from the site, in well
OHM-A7-13. The observed concentrations of these metals at AOC A7 do not represent site-related
contamination.

The baseline risk assessment for AOC A7 was prepared before the decision was made to transfer Sudbury
Annex to the Department of Interior and manage it as part of the Great Meadows National Wildlife Refuge.
Conseguently, the risk assessment was based on the earlier assumption that there would be future human
ingestion of groundwater at the site. Even with that restrictive assumption, the baseline risk assessment
concluded that lead in groundwater at AOC A7 does not pose a risk (OHM, 1994 and 1995a).

The maximum concentration of lead detected in groundwater in wells along the downgradient perimeter fence
at AOC A7 was 4.57 Ig/L. This is below the MCL of 15 Ig/L for groundwater but is slightly greater than
the AWQC for surface water (3.2 Ig/L, at 100 mg/L hardness as CaCO 3). Attenuation between the perimeter
fence and the river, plus dilution in the river as calculated in response to Comment #1, would reduce the
lead concentrations to levels far below the AWQC.

-------
The maximum concentration of lead detected in the sediment samples collected in 1992 from the Assabet
River was 8.2 Ig/g, at sampling location FWISD15 (adjacent to AOC A7). The low effects range for lead in
sediment is 35 Ig/g (Long and Morgan, 1990). These data indicate that lead in groundwater at AOC A7 does
not pose a risk to aquatic organisms in the Assabet River.

Based on the considerations summarized above, groundwater samples from the long-term groundwater
monitoring program will not be analyzed for metals.

3. Comment: Groundwater was sampled between the Annex and the Assabet River. Who owns this property?
What zoning exists on this property? Is residential development feasible? Since the groundwater sampled
in this area has been shown to be unfit for human consumption, residential development should be
restricted. Are any measures being taken to ensure that residential development will not occur in the
future on this property?

Response: Records of land ownership are available at the Assessors' Office in Stow. The subject
property is undevelopable for residential use because of its zoning classification
(Conservation-Recreation), wetland restrictions, and proximity to the Assabet River. Further use
restrictions are not necessary.

4. Comment: Impacts to the bedrock aquifer have not been fully investigated. One bedrock well,
OHM-A7-11, was sampled in earlier rounds only. Incidentally, Figure 3 incorrectly depicts the screen
elevation for this well. Dichloromethane and manganese concentrations exceeded the MCLs. Thus,
potential off-site migration of these contaminants should be considered, especially if there are homes
using private drinking water wells down-gradient of the site (see comment #5). Further, OHM-A7-11 is
located northeast of the contaminant plume and would not capture contaminant migration from this disposal
area.

Additional bedrock wells should be installed and sampled to determine if contaminated groundwater is
reaching the bedrock aquifer that may then migrate off-site. The Data Gap Investigation report states
that a planned well to be screened at the top of bedrock was not installed because bedrock was
encountered at 10 feet below ground surface. Please elaborate on this point. Where was this proposed
well? Why should it not be installed? Why wasn't a well considered for the bedrock itself? Is there
sufficient information to determine flow in the bedrock aquifer? During the public meeting, the ABB
consultant noted that the bedrock aquifer could not be influenced by contamination located above this
aquifer due to pressure pushing the groundwater up. What data were collected to support this claim?

Response: The correct elevations of the well screen in monitoring well OHM-A7-11 are 160.7 feet msl (top
of screen) and 150.7 feet msl (bottom of screen). Figure 3 of the AOC A7 Technical Memorandum (ABB-ES,
1997) has been revised to correctly depict the screen elevations for this well.

Sudbury Annex is scheduled to be transferred later this year to the U.S. Department of Interior and to
become part of the Great Meadows National Wildlife Refuge. In addition, there are no homes located
downgradient from AOC A7 (see response to Comment #5), and natural conditions and regulatory restrictions
will prevent future residential development (see response to Comment #3). Therefore, there are no
current or potential future human receptors of analytes in groundwater, there are no human-health risks
from ingestion of groundwater, and groundwater standards designed to protect human health (MCLs) do not
apply.

The potential for groundwater contaminant migration from AOC A7 has been considered for all contaminants.
Analyte concentrations in groundwater are likely to attenuate between well OHM-A7-11 and the river.
However, even if groundwater were to discharge to the Assabet River with dichloromethane at the same
concentration as detected in monitoring well OHM-A7-11 (8.4 Ig/L) , that concentration is far below the
LOEL of 11,000 Ig/L for halomethanes (USEPA, 1986).

The maximum concentration of manganese detected in monitoring well OHM-A7-11 was 114 Ig/L, which is less
than the maximum concentration detected in well OHM-A7-13 (270 Ig/L), upgradient of AOC A7. The presence
of manganese in groundwater is not related to activities or conditions at the site.

Major source-control measures taken by the Army at AOC A7 in 1996, including source removal and capping
of the landfill, were designed to further reduce analyte concentrations in groundwater.

The Army does not concur that additional bedrock wells are necessary at AOC A7. There is a strong upward
groundwater flow potential (i.e., an upward vertical hydraulic gradient) near the river, because the
Assabet River is a major regional groundwater discharge location. Hydrologically, this manifests itself
as higher water levels (heads) in deep wells than in collocated shallow wells. In the downgradient area
of AOC A7, the upward gradient is dramatically verified by the well pair OHM-A7-10 / OHM-A7-11. In the
shallow well (OHM-A7-10), the head was measured at approximately 2.3 feet below ground surface (bgs),

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whereas in the deep bedrock well  (OHM-A7-11),  groundwater flows out of the well under artesian
conditions, with a head at least 2 feet above ground.  The Army concurs that well OHM-A7-11 is not
directly downgradient of the lab waste disposal area.  Installation of the well pair JO-A7-M63 /
JO-A7-M64 was proposed as a data-gap activity to address the concern that contaminants potentially being
transported by groundwater flowing from bedrock into the surficial aquifer between the perimeter fence
and the river had not been characterized.  Monitoring well JO-A7-M64 was to be installed within the
surficial aguifer, at the top of rock or at a depth of 50 feet bgs, whichever was found to be shallower.
It was to be paired with (i.e., to be located within 10 feet of)water-table monitoring well JO-A7-M63.
Together, these wells were designed to assess groundwater guality at the water table and deeper within
the surficial aguifer.  The requirements and rationale are presented in the approved Task Order Work Plan
(ABB-ES, 1996c, Section 3.2.3.1, Figure 3-2, and Table 3-2).

In the boring for monitoring well JO-A7-M63, the water table was encountered at 1.5 feet bgs, and bedrock
was encountered at 10 feet bgs.  A standard 10-foot well-screen could not be used in well JO-A7-M63 under
these conditions  (ABB-ES, 1996c, p. 3-9; ABB-ES, 1995, pp. 4-18 - 4-21).  ABB-ES installed a 5-foot
screen from 2 feet bgs to 7 feet bgs and placed the filter pack from 1.5 feet bgs to the bottom of the
borehole at 10 feet bgs.  Hence, groundwater data obtained from monitoring well JO-A7-M63 are sufficient
to represent the entire saturated thickness of the surficial aquifer, and well JO-A7-M64 was not needed.

Downward gradients beneath the landfill at AOC A7 may have introduced contaminants into the underlying
bedrock, but as the groundwater flows toward the river it moves upward into the surficial aquifer.
Several rounds of groundwater samples in water-table wells and stratigraphically deeper wells near the
perimeter of the facility have adequately characterized the downgradient groundwater quality.

5.   Comment:  Focus would like more information concerning the homes, if any, located down-gradient of
site A7, across the Assabet River.  Where does their water come from  (groundwater wells or public water)?
If private wells are being used, is public water available for these homes and were any of these wells
sampled?  Is the bedrock aquifer being used as the water source?  If no homes currently exist across from
A7, is the land zoned for residential development?  If so, what measures are being taken to ensure that
future private wells will be safe for human consumption?  We note that Massachusetts regulations call for
the protection of groundwater in areas where a public water supply line is not available (within 500
feet).

Response:  There are no homes located downgradient from AOC A7.  Areas that are across the Assabet River
from AOC A7 are not downgradient from AOC A7.   The Assabet River is a regional hydraulic boundary, with
surface water and groundwater discharging into it, from both sides, along its entire length.  Natural
hydraulic gradients prevent groundwater from flowing beneath the river, from one side of the river to the
other.  This well-known hydrogeologic principal is shown conceptually in the accompanying illustration
(Attachment 5-A) and is discussed, for example, by Freeze and Cherry  (1979, pp. 195-196).  For
discussions of general groundwater flow characteristics at Sudbury Annex, refer to HydroGeoLogic  (1994),
OHM (1995b, Appendix C, and ABB-ES (1996a, Section 2.2.6).

-------
References:

ABB Environmental Services, Inc.  (ABB-ES), 1995.  Final Project Operations Plan, Fort Devens Sudbury
Training Annex, Middlesex County, Massachusetts", Portland, ME; prepared for the U.S. Army Environmental
Center, Aberdeen Proving Ground, MD; April.

ABB Environmental Services, Inc.  (ABB-ES) , 1996a.  "Final Supplemental Site Investigation Report for
Study Areas A3, A5, A10, All, P5, P6, P9, P16, P23, P27, P28, P38, P41, P45, and P54, U.S. Army Sudbury
Training Annex, Middlesex County, Massachusetts; Wakefield, MA.; prepared for U.S. Army Environmental
Center, Aberdeen Proving Ground, MD; October.

BB Environmental Services, Inc.  (ABB-ES), 1996b. "Draft Task Order Work Plan, Remedial  (Data-Gap)
Investigations of Area of Contamination A4 and Areas of Contamination A7/A9  (Management-of-Migration
Operable Unit) and Supplemental Site Investigations of Selected Study Areas, Fort Devens Sudbury Training
Annex, Middlesex County, Massachusetts"; Portland, ME; prepared for U.S. Army Environmental Center,
Aberdeen Proving Ground, MD; March.

ABB Environmental Services, Inc.  (ABB-ES), 1996c.  "Final Task Order Work Plan, Remedial  (Data-Gap)
Investigations of Area of Contamination A4 and Areas of Contamination A7/A9  (Management-of-Migration
Operable Unit) and Supplemental Site Investigations of Selected Study Areas, Fort Devens Sudbury Training
Annex, Middlesex County, Massachusetts"; Portland, ME; prepared for U.S. Army Environmental Center,
Aberdeen Proving Ground, MD; May.

ABB Environmental Services, Inc,  (ABB-ES), 1997.  "Technical Memorandum, Remedial  (Data-Gap)
Investigation, Area of Contamination A7, U.S. Army Sudbury Annex; Wakefield, MA.; Wakefield, MA; prepared
for U.S. Army Environmental Center, Aberdeen Proving Ground, MD; March.

Barrick, R.C., and H.R. Beller, 1989.  "Reliability of Sediment Quality Assessments in Puget Sound"; in
Oceans  '89,  An International Conference Addressing Methods for Understanding The Global Ocean; Seattle,
WA; pp. 421 - 426; September.

Freeze, R.A. , and J.A. Cherry, 1979.  Groundwater; Prentice-Hall, Inc.; Englewood Cliffs, NJ.

HydroGeoLogic, Inc., 1994.  "Groundwater Flow Model for Sudbury Training Annex and Vicinity,
Massachusetts"; in Final Phase I Site Investigation Report, Appendix H; Herndon, VA; prepared for Ecology
& Environment, Inc., Arlington, VA; September.

Long, E.R.,  and L.G. Morgan, 1990.  "The Potential for Biological Effects on Sediment-Sorbed Contaminants
Tested in the National Status and Trends Program"; National Oceanic and Atmospheric Administration
Technical Memorandum NOS OMA 52.

Massachusetts Department of Environmental  (MADEP), 1994.  "Background  Documentation for the Development
of the MCP Numerical Standards", Bureau  of Waste Site Cleanup and Office of Research and Standards;
April.

OHM Corporation (OHM), 1994.  "Final Site/Remedial Investigation Report, Fort Devens Sudbury Training
Annex, Middlesex County, Massachusetts", Pittsburgh; PA; prepared for U.S. Army Environmental Center,
Aberdeen Proving Ground, MD; January.

OHM Corporation (OHM) , 1995a.  "Final Addendum Report, Site/Remedial Investigation, Fort Devens Sudbury
Training Annex, Middlesex County, Massachusetts"; Pittsburgh, PA; prepared for U.S. Army Environmental
Center, Aberdeen Proving Ground, MD; September.

OHM Corporation (OHM), 1995b.  "Final Feasibility Study Report for the Fort Devens Sudbury Training
Annex, Areas of Contamination A7 and A9, Middlesex County, Massachusetts"; Pittsburgh, PA; prepared for
U.S. Army Environmental Center, Aberdeen Proving Ground, MD; May.

U.S. Environmental Protection Agency (USEPA), 1986.  "Quality Criteria for Groundwater 1986"; EPA
440/5-86-001, Office of Water Regulations and Standards; Washington, D.C.; May.

U.S. Environmental Protection Agency (USEPA), 1991.  "Water Quality Criteria Summary"; Office of Science
and Technology; Washington, D.C.

U.S. Environmental Protection Agency (USEPA), 1996.  "Drinking Water Regulations and  Health Advisories",
Office of Water; EPA 822-B-96-002; October.

-------
U.S. Geological Survey, 1996.  "Water Resources Data, Massachusetts and Rhode Island, Water Year 1996",
Prepared in cooperation with the States of Massachusetts and Rhode Island and other agencies; MA-RI-96-1.

-------
                      ATTACHMENT C - PUBLIC HEARING TRANSCRIPT

                           DORIS 0. WONG ASSOCIATES, Inc.

  50 FRANKLIN STREET, BOSTON, MASSACHUSETTS  02110  TELEPHONE  (617)  426-2432


                                                                     Volume I
                                                                     Excerpt

                                    U.S. ARMY

                          BASE REALIGNMENT AND CLOSURE

                       FT. DEVENS SUDBURY TRAINING ANNEX
PUBLIC HEARING ON PROPOSED PLAN
FOR AOC ' s A4 ,  A7,  and A9

BEFORE:  Thomas Strunk, Environmental Coordinator

                                     -held at-
                                Stow Town Building
                                  380 Great Road
                                Stow, Massachusetts
                              Tuesday, June 10, 1997
                                     7:25 p.m.
                 (Anne H. Bohan, Registered Diplomate Reporter)
                            DORIS 0. WONG ASSOCIATES

-------
 1                                       INDEX





 2





 3





 4   PRESENT:  Thomas Strunk,  Devens Sudbury BEG





 5





 6             Thomas R.  Eschner,  ABB Environmental





 7             Services Inc.





 8





 9             Jeff Waugh,  Army Environmental Center





10





11             Robert LIM,  U.S. EPA





12





13             Jim Murphy,  U.S. EPA





14





15             Scott Greene, Massachusetts DEP





16





17             Severely Lawrence,  U.S. Army Corps of





18             Engineers





19





20             Deborah Schumann,  FOCUS





21





22             Lorna Nichols,  FOCUS





23




24                          * * *  *





                   DORIS  0. WONG ASSOCIATES

-------
 1                       PROCEEDINGS





 2             MR.  STRUNK:   But after listening to ABB's





 3   presentation of what the rationale was behind the





 4   record of decision that we're talking about,  I can





 5   open this up for public comments.   We'll record your





 6   comments, and then we won't answer them tonight,  but





 7   they will be responded to in the appendix to the





 8   ROD, which we have a responsiveness summary





 9   section.   And also feel free to mail in comments if





10   you have those, and we'll get those out and have





11   those responded to as well.





12            So if there's anything anyone would like to





13   have addressed any more than we have tonight, this





14   is your opportunity to do it.





15            MS. SCHUMANN:  Well, I think FOCUS'S letter





16   pretty much covers the same identical territory that





17   Lorna covered here, and maybe I caused a couple of





18   diversions in possible ways to go after it,  but it





19   was the same issue.  One way or another, determine





20   what that drinking water risk to a residential





21   housing development on the other side of that river





22   is going to be.  Now,  I don't know, I'm torn at this





23   point.  On the one hand, I'd like you to come back





24   and say,  you know, it's horrendous, because it would








                   DORIS 0. WONG ASSOCIATES

-------
 1   be absolutely ideal to stop a development.   On the





 2   other hand,  obviously I don't want to see any





 3   contaminants leaving that site at all.   But I think





 4   we got to know either way,  yeah?





 5            MR. GREENE:  Again,  even if there's —





 6   we're not supposed to respond today.  Sorry.





 7            MR. STRUNK:  No comments tonight,  Scott.





 8   Certainly everyone will have a chance to look at the





 9   comments as  they come in and respond to them.





10            MS. NICHOLS:  There actually are houses





11   like right across the road from the golf course





12   right next to the river.  Why would you say there





13   are no existing wells?  Are they on some other





14   system?





15            MR. GREENE:  I don't know if there's





16   existing wells or not.  They were going to say the





17   golf course  was going to be developed.





18            MS. NICHOLS:  Do you know if there are





19   existing wells?





20            MR. LIM:  No.





21            MS. NICHOLS:  Do you know if there are





22   existing wells?





23            MR. ESCHNER:  I do not.





24            MS. LAWRENCE:  I think he was  saying the





                   DORIS 0. WONG ASSOCIATES

-------
 1   water on the side.   I think that they were just





 2   trying to say the wells that they installed were not





 3   used in that area.





 4            MS. NICHOLS:  Earlier he said to me,  I'm





 5   not sure if he just repeated it then,  that even if





 6   contamination was found on the other side of the





 7   river, since there are no existing residential





 8   wells, the State wouldn't consider that a protected





 9   aguifer.





10            MR. GREENE:   I'm saying unless there's a





11   private well there already in existence,  and





12   contamination is detected within 500 feet, we





13   wouldn't predict that as a GW1 resource,  within 500





14   feet of that well.





15            MS. NICHOLS:  So whose job would it be to





16   determine whether or not there are residential





17   wells?  No volunteers?





18            MR. WAUGH:  The Town of Stow has been





19   provided with all the documents, and they would have





20   notified -- I would hope the Public Health would





21   know of any wells there.  I do know there are some





22   wells on the Annex side of the river just east of





23   A9.





24            MR. STRUNK:   Off the record.   We'll end the





                   DORIS 0. WONG ASSOCIATES

-------
 1   public comment period now so we can take a break.





 2            (Discussion off the record)





 3                 (Whereupon, at 8:40 p.m. the hearing





 4                 was concluded)





 5





 6





 7





 8





 9





10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





                   DORIS 0. WONG ASSOCIATES

-------
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 June

6 10, 1997.

9
-------
APPENDIX D
ADMINISTRATIVE RECORD INDEX

Fort Devens - Sudbury Annex
Record of Decision
Area of Contamination A4 and
Areas of Contamination A7 and A9
Management of Migration Operable Units

Prepared for

New England Division
Corps of Engineers
Prepared by
ABB Environmental Services, Inc
Corporate Place 128, 107 Audubon Road, Wakefield, MA 01880 (617) 245-6606
-------
Introduction

This document is the Index to the Administrative Record for the Record of Decision, Area of Contamination
A4 and Areas of Contamination A7/A9, Management of Migration Operable Units, at the Fort Devens Sudbury
Annex. Section I of the Index lists site-specific documents and Section II lists guidance documents used
by U.S. Army in selecting response actions at the site. Some documents in this Administrative Record
File Index have been cited but are not physically included in the Administrative Record for this Record
Of Decision. 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. Efforts were made to
include all appropriate comments and responses individually. In come cases, however, comments were only
included as part of the response package.

The Administrative Record is available for public review at the office of the BRAG Environmental
Coordinator, Fort Devens, Massachusetts, and at the Sudbury Town Hall, Sudbury, Massachusetts.
Supplemental/Addendum volumes may be added to this Administrative Record File. Questions concerning the
Administrative Record should be addressed to the BRAG Environmental Coordinator.

The Administrative Record is reguired by the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) , as amended by the Superfund Amendment and Reauthorization Act (SARA) .
-------
ADMINISTRATIVE RECORD INDEX

for

Record of Decision

Area of Contamination (AOC) A4 and AOCs A7 and 9

Management of Migration Operable Units

Fort Devens - Sudbury Annex Sites

Updated: September 25, 1997

1.0 Pre-Remedial

1.2 Preliminary Assessment

Reports

1. "Analysis of Existing Facilities/Environmental Assessment Report," Natick Research and
Development Command (MARADCOM) (November, 1977).
2. "Analysis of Existing Facilities/Environmental Assessment Report," NARADCOM (1978).
3. "Installation Assessment of U.S. Army Natick Research and Development Command (NARADCOM),
Report 170," United States Army Toxic and Hazardous Materials Agency (USATHAMA) (1980).
4. "Installation Assessment NARADCOM Research and Development Laboratory, Massachusetts," EPA
Environmental Monitoring Systems Laboratory (March 1982).
5. "Burn Pit Remediation - Study Area A9," U.S. Army (November 21, 1986).

1.3 Site Inspection

Reports

1. "Final Site Inspection Report, Sudbury Annex, Sudbury, Massachusetts," NUS (1987).
2. "Draft Expanded Site Inspection (ESI) of Natick Research, Development, and Engineering
Center," Dames & Moore (December 1990).
3. "Final Report - Site Investigation - Natick Lab Annex Property," GZA Associates
(March 4, 1991).
4. "Final Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex, Middlesex
County, Massachusetts, Vol I-VI," OHM Remediation Services Corp. (January 1994).
5. "Final Site Investigation/ Remedial Investigation Addendum Report for AOCs A4, A7, and A9
and SAs A3/P5, P4, P7, P17, P19, P20, P25, P35, P49, P51, P59, and P60, Ft. Devens Sudbury
Training Annex" OHM Remediation Services Corp. (September 22, 1995).
6. "Ft. Devens, Sudbury Training Annex Remedial Investigations of AOC A4 and AOCs A7/A9 and
Supplemental Site Investigation of Selected SAs Final Work Plan," ABB Environmental
Services, Inc. (May 24, 1996).

1.7 Correspondence Related to Proposal of a Site to the NPL

1. Letter from Daniel J. Hannon, Commonwealth of Massachusetts, Department of Environmental
Protection to Fort Devens Installation Commander (May 24, 1991), concerning notification
that Fort Devens in considered a priority disposal site.

2.0 Removal Response

Correspondence

Memorandum from Timothy Prior, U.S. Army for the Record (August 16, 1991) concerning
contaminated soil disposal.
Memorandum from Joseph Pierce, U.S. Army to Fort Devens Installation Commander (August 19,
1991) concerning Air Force noncompliance issues at the Sudbury Annex.
"Record of Environmental Consideration," (November 9, 1992).
Bills of Lading," (May 6, 1993).

Removal Response Reports
-------
1. "Removal of Underground Storage Tanks," Environmental Application, Inc. (May 1989).

2.6 Work Plans and Progress Reports

Comments

1. Comments dated July 15, 1996 from Robert Lim, USEPA, on "Work Plan for Source Control
Remediation SA A7 with Removal Actions at SAs Al, A2, A9, P2, P16, P23, P28, P29, and P41,
Ft. Devens Sudbury Training Annex (WESTON).

2.9 Action Memoranda

Reports

1. "Final Technical Memorandum: Consolidation of Soils from SAs P16, P23, and P41 at AOC A7,
Ft. Devens Sudbury Training Annex, MA," Stone & Webster (June 1996).

Comments

2. Comments dated March 26, 1996 from Robert Lim, USEPA, on the Draft Technical Memorandum,
Consolidation of Soils from Areas P16, P23, and P41 as Subgrade at AOC A7, Ft. Devens
Sudbury Training Annex, MA.

3.0 Remedial Investigation (RI)

3.1 Correspondence

1. Memorandum from NUS to Nancy Philigan, EPA (1985), concerning Dames & Moore Technical Plan
for Sudbury Annex Site.
2. Meeting Notes, July 8, 1993 meeting at Environmental Office, Fort Devens. OHM Remediation
Services Corp. (July 16, 1993).
3. Draft Notes of Site Walk on July 13, 1993, at Sudbury Training Annex. OHM Remediation
Services Corp. (July 19, 1993).
4. Meeting Notes, Ecological Assessment Meeting on June 8, 1993, at EPA Region I, Boston, MA.

OHM Remediation Services Corp. (July 28, 1993).
5. Meeting Notes, Pre-Drill Site Walk on August 10, 1993 at Sudbury Training Annex, Areas A4,
A7, and A9. OHM Remediation Services Corp. (August 20, 1993).
6. Letter from D. Lynne Chappell, MADEP-CERO, to Ron Ostrowski, Fort Devens EMO (August 23,
1993). Concerning Pre-Drill Site Walk on August 10, 1993.
7. Meeting Notes, November 18, 1993 Meeting at Fort Devens to review/respend to comment on
Initial Screening of Remedial Technologies and Process Options Report, and Comments on
Site/Remedial Investigation Report. OHM Remediation Services Corp. (December 2, 1993).

3.4 Interim Deliverables

1. "Rationale for Not Installing Proposed Monitoring Well OHM-A4-51," OHM Remediation,
Services Corp. (August 19, 1993).
2. "Initial Screening of Remedial Technologies and Process Options Fort Devens Sudbury
Training Annex, Middlesex County, Massachusetts," OHM Remediation Services Corp.,
(September 23, 1993).
3. "Development and Screening of Remedial Alternatives Fort Devens Sudbury Training Annex,
Middlesex County, Massachusetts," OHM Remediation Services Corp., (October 28, 1993).
4. "Technical Memorandum, Remedial (Data-Gap) Investigation, Area of Contamination A7, U.S.
Army Sudbury Training Annex," ABB Environmental Services, Inc. (March 1997) .
5. "Technical Memorandum, Remedial (Data-Gap) Investigation, Area of Contamination A9, U.S.
Army Sudbury Training Annex," ABB Environmental Services, Inc. (March 1997).
6. "Final Technical Memorandum, Remedial (Data-Gap) Investigation, Area of Contamination A4,
U.S. Army Sudbury Training Annex," ABB Environmental Services, Inc. (August 13, 1997).
7. "Final Technical Memorandum, Remedial (Data-Gap) Investigation, Area of Contamination A7,
U.S. Army Sudbury Training Annex," ABB Environmental Services, Inc. (August 13, 1997).
8. "Final Technical Memorandum, Remedial (Data-Gap) Investigation, Area of Contamination A9,
U.S. Army Sudbury Training Annex," ABB Environmental Services, Inc. (August 13, 1997).

Comments
-------
9. Comments Dated October 25, 1993 from D. Lynne Welsh, Commonwealth of Massachusetts
Department of Environmental Protection on the Initial Screening of Remedial Technologies
and Process Options, Fort Devens, Sudbury Training Annex, Middlesex County, Massachusetts,
OHM Remediation Corp. (September 23, 1993).
10. Comments Dated October 26, 1993 from Robert Lim, USEPA, on the Initial Screening of
Remedial Technologies and Process Options, OHM Remediation Corp. (September 23, 1993).
11. Comments Dated October 27, 1993 from Cindy Svec Ruzich, Four Town Focus on the "Draft
Initial Screening of Remedial Technologies and Process Options".
12. Comments Dated December 10, 1993 from Robert Lim, USEPA, on the October 1993 "Draft
Development and Screening of Remedial action Alternatives, Fort Devens Sudbury Training
Annex," OHM Remediation Services Corp.
13. Comments Dated December 22, 1993 from Jay Naparstek, Commonwealth of Massachusetts
Department of Environmental Protection on the October 1993 "Development and Screening of
Remedial Alternatives: Fort Devens Sudbury Training Annex, Sudbury Massachusetts," OHM
Remediation Services Corp.
14. Comments Dated January 9, 1997, from Robert Lim, USEPA Region I, on the "Draft Technical
Memorandum, Remedial (Data-Gap) Investigation, Area of Contamination A4, U.S. Army Sudbury
Annex," ABB Environmental Services, Inc.
15. Comments Dated April 17, 1997, from Robert Lim, USEPA Region I, on the March 1997
"Technical Memorandum, Remedial (Data-Gap) Investigation Area of Contamination A7, U.S.
Army Sudbury Annex," ABB Environmental Services, Inc.

Responses to Comments

16. Responses Dated August 11, 1997, from ABB Environmental Services, Inc., to USEPA Region I
Comments Dated January 9, 1997, on the December 1996 "Technical Memorandum, Remedial
(Data-Gap) Investigation, Area of Contamination A4, U.S. Army Sudbury Annex," ABB
Environmental Services, Inc.
17. Responses Dated August 11, 1997, from ABB Environmental Services, Inc., to Comments Dated
April 17 and April 23, 1997, on the March 1997 "Technical Memorandum, Remedial (Data-Gap)
Investigation, Area of Contamination A7, U.S. Army Sudbury Annex," ABB Environmental
Services, Inc.
18. Responses Dated August 12, 1997, from ABB Environmental Services, Inc., to Comments Dated
April 2, 1997, on the March 1997 "Technical Memorandum, Remedial (Data-Gap) Investigation,
Area of Contamination A9, U.S. Army Sudbury Annex," ABB Environmental Services, Inc.

3.6 Remedial Investigation (RI) Reports

The records cited below as entries number 1 and 2 may be reviewed, by appointment only, at the
Fort Devens Environmental Management Office.

1. "Final Remedial Investigations of the Sudbury Annex," Dames & Moore (November 1986).
2. "Final Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex, Middlesex
County, Massachusetts, Vol I-VI," OHM Remediation Services Corp. (January 1994).
3. "Final Site Investigation/ Remedial Investigation Addendum Report for AOCs A4, A7, and A9
and SAs A3/P5, P4, P7, P17, P19, P20, P25, P35, P49, P51, P59, and P60, Ft. Devens Sudbury
Training Annex" OHM Remediation Services Corp. (September 22, 1995).
Comments
Comments Dated April 12, 1993 from Cindy Svec Ruzich, Four Town FOCUS on the February 1993
"Draft Site/Remedial Investigation - Volumes I-IV," OHM Remediation Services Corp. with
the attached Comments Dated March 19, 1993 from Cambridge Environmental, Inc. on the
February 1993 "Draft Site/Remedial Investigation - Volumes I-IV," OHM Remediation Services
Corp.
Comments Dated April 12, 1993 from James P. Byrne, EPA Region I on the February 1993
"Draft Site/Remedial Investigation - Volume I-IV," OHM Remediation Services Corp.
Comments Dated April 13, 1993 from Molly J. Elder for D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the February 1993 "Draft
Site/Remedial Investigation - Volume I-IV, OHM Remediation Services Corp.
Comments Dated May 18, 1993 from Kenneth C. Carr for Gordon E. Beckett, U.S. Department of
the Interior Fish and Wildlife Services on the February 1993 "Draft Site/Remedial
Investigation - Volume I-IV," OHM Remediation Services Corp.
Comments Dated August 6, 1993 from Cindy Svec Ruzich, Four Town Focus, on the Comment Time
Extension on the "Draft Final RI/SI Report" and Army Response to FOCUS Comments on 'Draft
RI/SI Investigation Report".
-------
9. Comments Dated August 20, 1993 from James P. Byrne, USEPA, on the "Draft Final
Site/Remedial Investigation Report," OHM Remediation Services Corp.
10. Comments Dated September 2, 1993 from D. Lynne Welsh, Commonwealth of Massachusetts
Department of Environmental Protection on the July 1993 "Draft Final Site/Remedial
Investigation Report," OHM Remediation Services Corp.
11. Update of Comments Dated September 12, 1993 from Cindy Svec Ruzich of Four Town Focus on
the Draft SI/RI Investigation Report.
12. Comments Dated September 14, 1993 from Robert Lim, USEPA on the Comment Time Extension on
"Draft Final SI/RI Investigation Report and Army Response to Comments on "Draft SI/RI
Investigation Report".
13. Comments Dated October 3, 1994 from Jay Naparstek, Commonwealth of Massachusetts
Department of Environmental Protection on the August 1994 "Draft Addendum Final
Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex," OHM Remediation
Services Corp.
14. Comments Dated October 5, 1994 from Robert Lim, USEPA, on the Draft SI/RI Addendum Report,
Fort Devens Sudbury Training Annex.
15. Comments Dated October 13, 1993 from Cindy Svec Ruzich of Four Town Focus on the Draft
Final RI/SI Phase I Investigation Report, Volume I.
16. Comments Dated October 17, 1994 from Robert Lim, USEPA, on the August 1994 Draft SI/RI
Addendum Report, Fort Devens Sudbury Training Annex (OHM Remediation Services Corp.).
17. Comments Dated November 1, 1994 from Jay Naparstek, Commonwealth of Massachusetts
Department of Environmental Protection on the August 1994 Draft Addendum Final
Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex.
18. Letter Dated November 7, 1994 from Robert Lim, USEPA, to the Ecological Risk Assessment
Issues in the Remedial Investigation of Areas of Contamination A4, A7, and A9.
19. Follow-up Letter Dated November 21, 1994 from Robert Lim, USEPA, to the Ecological Risk
Assessment Issues in the Remedial Investigation of Areas of Contamination A4, A7, and A9.
20. Comments Dated May 19, 1995 from Robert Lim, USEPA, on the Draft Final Site/Remedial
Investigation Addendum Report, Fort Devens Sudbury Training Annex (OHM Remediation).

Responses to Comments

21. Responses Dated July 16, 1993, July 19, 1993 and July 28, 1993 from OHM Remediation
Services Corp to the April 12, 1993 Four Town FOCUS, the April 12, 1993 EPA Region I, the
April 13, 1993 Commonwealth of Massachusetts Department of Environmental Protection and
the May 18, 1993 U.S. Department of Interior Fish and Wildlife Service Comments on the
February 1993 "Draft Site/Remedial Investigation - Volumes I-IV," OHM Remediation Services
Corp.
22. Responses Dated October 14, 1993 from U.S. Army Environmental Center on the Draft
Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex (OHM Remediation
Services Corp.).
23. Responses Dated October 28, 1993 from U.S. Army Environmental Center on the Draft Final
Site/Remedial Investigation Report, Fort Devens Sudbury Training Annex (OHM Remediation
Services Corp.).
24. Responses Dated November 4, 1994 from OHM Remediation Services Corp. on the USEPA Comments
on the "Draft SI/RI Addendum Report.
25. Responses Dated June 21, 1995 from OHM Corporation to the U.S. Army Environmental Center
on the Draft Final Addendum to the Final Site/Remedial Investigation Report, Fort Devens;
Sudbury Training Annex.

Responses to Responses to Comments

26. Rebuttals Dated November 15, 1994 from Robert Lim, USEPA, on the Responses to the Army's
Responses to Comments on the Draft SI/RI Addendum Report.
27. Correction Letter Dated November 22, 1994 from Robert Lim, USEPA, on November 15, 1994
letter.

3.7 Work Plans and Progress Reports

Reports

1. "Final Work Plan, Fort Devens Sudbury Training Annex," OHM Remediation Services Corp.
(April 1992).
2. "Final Field Sampling Plan," OHM Remediation Services Corp. (April 1992).
3. "Final Health and Safety Plan," OHM Remediation Services Corp (April 1992).
4. "Final Quality Assurance Project Plan - Volume I-II," OHM Remediation Services Corp.
(April 1992).
-------
5. "Ft. Devens Sudbury Training Annex Remedial Investigations of AOC A4 and AOCs A7/A9 and
Supplemental Site Investigation of Selected SAs Final Work Plan," ABB Environmental
Services, Inc. (May 24, 1996).
6. Final Draft Project Closeout Report. (Five Vol.) Weston. February 1997.

Comments

7. Comments Dated August 21, 1991 from Todd S. Alving, Organization for the Assabet River on
the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health and Safety
Plan, Draft Quality Assurance Plan, "OHM Remediation Services Corp.
8. Comments Dated August 21, 1991 from Anne D. Flood, Town of Maynard on the June/July 1991
"Draft Work Plan, Draft Field Sampling Plan, Draft Health and Safety Plan, Draft Quality
Assurance Plan, " OHM Remediation Services Corp.
9. Comments Dated August 22, 1991 from Gregory M. Ciardi, Maynard Public Schools on the
June/July 1991 "Draft Work Plan, Draft Filed Sampling Plan, Draft Health and Safety Plan,
Draft Quality Assurance," OHM Remediation Services Corp.
10. Comments Dated February 12, 1992 from Todd S. Alving, Organization for the Assabet River
on the December 1991 "Draft Final Work Plan, Draft Final Field Sampling Plan, Draft Final
Health and Safety Plan, Draft Final Quality Assurance Plan, " OHM Remediation Services
Corp.
11. Comments Dated May 13, 1992 from James P. Byrne, EPA Region I on the April 1992 "Final
Work Plan, Final Field Sampling Plan, Final Health and Safety Plan, Final Quality
Assurance Project Plan," OHM Remediation Services Corp. and the April 1992 "Final
Community Relations Plan," Dames & Moore.
12. Comments Dated May 18, 1992 from Ken Raina, Lake Boon Association on the April 1992 "Final
Work Plan, Final Field Sampling Plan, Final Health and Safety Plan, Final Quality
Assurance Project Plan," OHM Remediation Services Corp.
13. Comments Dated May 19, 1992 from Deborah Schumann and Cindy Svec Ruzich Four Town FOCUS on
the April 192 " Final Work Plan, Final Field Sampling Plan, Final Health and Safety Plan,
Final Quality Assurance Project Plan," OHM Remediation Services Corp.
14. Comments dated July 7, 1993 from Jack McKenna, Metcalf & Eddy on the June 1993 "Draft
Technical Plan Addenda, Phase II Site Inspections, Remedial Investigations," Ecology and
Environment, Inc. and the June 1993 "Draft Final
Addendum to the Final Technical Plans - Phase II Feasibility Study," OHM Remediation
Services Corp.
15. Comments dated April 16, 1996 from Robert Lim, USEPA, on "Remedial (Data Gap)
Investigations of AOC A4 and AOCs A7/A9 and Supplemental Site Investigations of Selected
SAs, Draft Task Order Work Plan, Data Item A005."

Responses to Comments

16. Response Dated October 1991 from OHM Remediation Services Corp. to Regulatory Agency
Comments on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health
and Safety Plan, Draft Quality Assurance Project Plan," OHM Remediation Services Corp.
17. Response Dated November 19, 1991 from Joseph Pierce, U.S. Army to the August 21, 1991
Comments from Todd S. Alving, Organization for the Assabet River on the June/July 1991
"Draft Work Plan, Draft Field Sampling Plan, Draft Health and Safety Plan, Draft Quality
Assurance Project Plan," OHM Remediation Services Corp.
18. Response Dated November 20, 1991 from Dennis R. Dowdy, U.S. Army to the August 22, 1991
Comments from Gregory M. Ciardi, Maynard Public Schools on the June/July 1991 "Draft Work
Plan, Draft Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance
Project Plan," OHM Remediation Services Corp.
19. Response Dated November 25, 1991 from Ronald J. Ostrowski, U. S. Army to the August 21,
1991 Comments from Anne D. Flood, Town of Maynard on the June/July 1991 "Draft Work Plan,
Draft Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance Plan,"
OHM Remediation Services Corp.
20. Response Dated November 1991 from OHM Remediation Services Corp. to the Four Town FOCUS
Comments on the June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health
and Safety Plan, Draft Quality Assurance Plan," OHM Remediation Services Corp.
21. Responses from OHM Remediation Services Corp. to EPA Region I, Four Town FOCUS, and the
U.S. Department of the Interior Fish and Wildlife Service Comments on the December 1991
"Draft Final Work Plan, Draft Final Field Sampling Plan, Draft Final Health and Safety
Plan, Draft Final Quality Assurance Plan," OHM Remediation Services Corp.
22. Draft Responses to Four Town FOCUS Comments on the April 1992 "Final Work Plan," OHM
Remediation Services Corp.
-------
23. Response dated May 21, 1996 from ABB Environmental Services, Inc. to comments dated April
16 and 26, 1996 on Draft Work Plan for Remedial (Data-Gap) Investigations of AOC A4 and
AOCs A7/A9 (Management of Migration Operable Unit) and Supplemental Site Investigations of
Selected Study Areas, Ft. Devens Sudbury Training Annex, MA..

Responses to Responses to Comments

24. Response Dated October 21, 1991 from D. Lynne Chappell, Commonwealth of Massachusetts
Department of Environmental Protection to the Response Dated October 1991 from OHM
Remediation Services Corp. to Regulatory Agency Comments on the June/July 1991 "Draft Work
Plan, Draft Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance
Plan," OHM Remediation Services Corp.
25. Response Dated October 22, 1991 from James P. Byrne, EPA Region I to the Response Dated
October 1991 from OHM Remediation Services Corp. to Regulatory Agency Comments on the
June/July 1991 "Draft Work Plan, Draft Field Sampling Plan, Draft Health and Safety Plan,
Draft Quality Assurance Pan," OHM Remediation Services Corp.
26. Response Dated October 22, 1991 from Steven E. Mierzykowski, U.S. Department of the
Interior Fish and Wildlife Service to the Response Dated October 22, 1991 from OHM
Remediation Services Corp. to Regulatory Agency Comments on the June/July 1991 "Draft Work
Plan, Draft Field Sampling Plan, Draft Health and Safety Plan, Draft Quality Assurance
Plan," OHM Remediation Services Corp.
27. Response Dated January 2, 1992 from Four Town FOCUS to the Response Dated November 1991
from OHM Remediation Services Corp. to the FOCUS Comments on the June/July 1991 "Draft
Work Plan, Draft Field Sampling Plan, Draft Quality Assurance Plan," OHM Remediation
Services Corp.

3.9 Health Assessments

1. "Final Site-Specific Risk Assessment for the Sudbury Training Annex Facility, Sudbury,
Massachusetts," OHM Remediation Services Corp. (January 1994).

4.0 Feasibility Study (FS)

4 .1 Correspondence

1. Meeting Notes, November 18, 1993 Meeting at Fort Devens to review/respend to comments on
Initial Screening of Remedial Technologies and Process Options Report, and Site/Remedial
Investigation Report. OHM Remediation Services Corp., December 2, 1993.
2. Memorandum from Robert Lim, USEPA Region I, to Tom Strunk, Fort Devens (July 27, 1994),
regarding issues related to the Feasibility Study for Areas A4, A7, and A9.

4.4 Interim Deliverables

1. "Preliminary Draft Screening of Alternatives," OHM Remediation Services Corp.(May 25,
1993).

4.6 Feasibility Study (FS) Reports

1. "Final Feasibility Study at Fort Devens Sudbury Training Annex Areas A7 and A9, Middlesex
County," OHM Remediation Services Corp. (May 1995).

Comments

2. Comments Dated January 30, 1995 from Robert Lim, USEPA, on the Source Control Record of
Decision Proposal for Fort Devens Sudbury Training Annex Areas of Contamination - A7 and
A9.
3. Comments Dated March 2, 1995 from Robert Lim, USEPA, on the Draft Final Feasibility Study
Report at Fort Devens Sudbury Training Annex Area A7 and A9," (OHM Remediation Services
Corp.).
4. Comments Dated April 3, 1995 from Robert Lim, USEPA, on the Fort Devens Sudbury Training
Annex Feasibility Study for Area A7, 100-Floodplain Location Specific ARAR," (OHM
Remediation Services Corp.).

Responses to Comments

5. Responses Dated September 20, 1994 from U.S. Army Environmental Center on the Draft Final
Feasibility Study (OHM Remediation Services Corp.).
-------
6. Responses Dated May 2, 1995 from U.S. Army Environmental Center on the Draft Final
Feasibility Study Report, Sudbury Training Annex (OHM Remediation Services Corp.).

Responses to Responses to Comments

7. Rebuttals Dated October 4, 1994 from Robert Lim, USEPA, on the Army's Response to Comments
on the Feasibility Study.

4.7 Work Plans and Progress Reports

Reports

1. "Final Addendum to the Final Technical Plans for the Phase II Feasibility Study at the
Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts," OHM Remediation
Services Corp. (November 10, 1993).

Comments

2. Cross Reference: Preliminary Comments Dated July 7, 1993 from Jack McKenna, Metcalf &
Eddy on the June 1993 "Draft Technical Plan Addenda, Phase II Site Inspections, Remedial
Investigations," Ecology & Environment, Inc on the June 1993 "Draft Final Addendum to the
Final Technical Plans - Phase II Feasibility Study," OHM Remediation Services Corp.
[Filed and listed in 3.7 Work Plans and Progress Reports in this Administrative Record
Index.
3. Comments Dated July 22, 1993 from D. Lynne Chappell, Commonwealth of Massachusetts
Department of Environmental Protection on the June 1993 "Draft Final Addendum to the
Final Technical Plans - Phase II Feasibility Study," OHM Remediation Services Corp.
4. Comments Dated July 23, 1993 from D. Lynne Chappell, Commonwealth of Massachusetts
Department of Environmental Protection on the "Addendum to the Final Technical Plans
Phase II Feasibility Study, Fort Devens Sudbury Training Annex, Sudbury, Massachusetts, "
OHM Remediation Services Corp.
5. Comments Dated August 6, 1993 from James P. Byrne, USEPA, on the June 1993 "Addendum to
the Final Technical Plans, Phase II Feasibility Study, Fort Devens Sudbury Training
Annex, " OHM Remediation Services Corp.
6. Comments Dated August 6, 1993 from Cindy Svec Ruzich of Four Town Focus on the "Draft
Addendum to the Final Technical Plans Phase II Feasibility," OHM Remediation Services
Corp.

Responses to Comments

7. Responses Dated September 7, 1993 from OHM Remediation Services Corp. on USEPA Comments
on the "Addendum to the Final Technical Plans, Phase II Feasibility Study, Fort Devens
Sudbury Training Annex.

Responses to Responses to Comments

8. Rebuttal Dated October 1, 1993 from D. Lynne Welsh, Commonwealth of Massachusetts
Department of Environmental Protection on the June 1993 Army Responses to MADEP's
Comments on the Draft Final Addendum to the Final Technical Plans Phase II Feasibility
Study, Fort Devens Sudbury Training Annex, Sudbury, Massachusetts (OHM Remediation Corp).

4.8 Cost Reports and Invoices

1. Cost Estimates for Capping Alternatives at Area A7, OHM Remediation Services Corp.
(October 18, 1994) .

4.9 Proposed Plan for Selected Remedial Action

Reports

1. "Proposed Plan AOC A7, the Old Gravel Pit Landfill, AOC A9, the POL Burn Area, Fort
Devens Sudbury Training Annex, Middlesex County, Massachusetts," OHM Remediation Services
Corp. (June 1995).
2. "Proposed Plan, No Further CERCLA Action at Sites A4, A7, and A9, U.S. Army Sudbury
Annex," Sudbury Annex BEG, Devens, MA (June 1997).

Comments
-------
3. Comments Dated April 12, 1995 from Robert Lim, USEPA, on the March 1995 Draft Proposed
Plan, Sudbury Training Annex (OHM Remediation Services Corp.).
4. Comments Dated May 18, 1995 from Robert Lim, USEPA on the April 1995 Draft Final Proposed
Plan, Fort Devens Sudbury Training Annex (OHM Remediation Services Corp.).
5. Comments Dated April 17, 1997, from Robert Lim, USEPA Region I on the March 1997 "Draft
Proposed Plan, No Further CERCLA Action at Sites A4, A7, and A9, U.S. Army Sudbury
Annex," Sudbury Annex BEG.

5.0 Record of Decision (ROD)

5.2 Applicable or Relevant and Appropriate Reguirements (ARARs)

1. Letter from D. Lynne Chappell, Commonwealth of Massachusetts Department of Environmental
Protection to Jeff Waugh, U.S. Army (January 6, 1993). Concerning transmittal of the
attached potential ARARs.
2. "Draft Preliminary Applicable or Relevant and Appropriate Reguirements for the Fort
Devens Sudbury Training Annex," OHM Remediation Services Corp. (January 21, 1993) .

5.4 Record of Decision

1. "Final Record of Decision, Source Control Operable Unit AOC A7, the Old Gravel Pit
Landfill, AOC A9, the POL Burn Area, Fort Devens, Sudbury Training Annex, Middlesex
County, Massachusetts," OHM Remediation Services Corp. (September 1995).

Comments

2. Comments Dated July 21, 1995 from Robert Lim, USEPA Region I, on the June 1995 Draft
Record of Decision, Source Control Operable Unit AOC A7, the Old Gravel Pit Landfill, AOC
9, the POL Burn Area, Fort Devens Sudbury Training Annex, Middlesex County, Massachusetts
(OHM Remediation Services Corp.).
3. Comments Dated August 25, 1995 from Robert Lim, USEPA Region 1, on the August 1995 Draft
Final Record of Decision, Source Control Operable Unit AOC A7, the Old Gravel Pit
Landfill, and AOC A9, the POL Burn Area, Fort Devens Sudbury Training Annex, Middlesex
County, Massachusetts (OHM Remediation Services Corp.).
4. Comments Dated September 8, 1997, from Robert Lim, USEPA Region I, on the August 1997
"Draft Record of Decision, Area of Contamination A4 and Areas of Contamination A7 and A9
Management of Migration Operable Unit, U.S. Army Sudbury Annex," ABB Environmental
Services, Inc.

6.0 Remedial Design (RD)

6.1 Correspondence
1. Approval to Consolidate Soil Piles from Study Area P28 to Area Of Contamination A7, USEPA
Region I (June 5, 1995).
2. Letter dated June 20, 1996 from Robert Lim, USEPA, on Ft. Devens Sudbury Training Annex
Remedial Design.

6.4 Remedial Design Documents

Reports

1. "Site Safety and Health Plan for Source Control Remedial Design work to be performed at
SA A7 and A9, Ft. Devens Sudbury Training Annex, MA," Stone & Webster (August 1995).
2. "Concept Design, Source Control Remediation SA A7 and A9 at Ft. Devens Sudbury Training
Annex, MA," Stone & Webster (September 1995).
3. "Draft Final Basis of Design/Design Analysis (BD/DA) Volumes I and II for Source Control
Remediation at SA A7 with Removal Actions at SAs Al, A2, A9, P2, P16, P23, P39, and P41
at Ft. Devens Sudbury Training Annex, MA," Stone & Webster (April 11, 1996).
4. "Draft Final Contract Specification and Design Drawings for Source Control Remediation at
SA A7 with Removal Actions at SAs Al, A2, A9, P2, P16, P23, P39, and P41 at Ft. Devens
Sudbury Training Annex, MA," Stone & Webster (April 11, 1996).
5. Inserts to "Draft Final BD/DA and Contract Specification, Source Control Remedial/Removal
Actions, Ft. Devens Sudbury Training Annex, MA, SAs Al, A2, A7, A9, P2, P16, P23, P39,
and P41," Stone & Webster (April 29, 1996).
-------
6. Inserts for "Final Basis of Design/Design Analysis (BD/DA) Volumes I and II for Source
Control Remedial Design at SAs A7 and A9 with Removal Actions at SAs Al, A2, P2, PI 6,
P23, P39, and P41, Ft. Devens Sudbury Training Annex, MA," Stone & Webster (July 29,
1996).
7. Inserts for "Final Contract Specification and Design Drawings for Source Control Remedial
Design at SAs A7 and A9 with Removal Actions at SAs Al, A2, P2, P16, P23, P39, and P41,
Ft. Devens Sudbury Training Annex, MA," Stone & Webster (July 29, 1996).

Comments

8. Comments Dated December 20, 1995, from Robert Lim, USEPA Region I, on the November 1995
"65% Remedial Design," Stone & Webster Environmental Technology & Services.
9. Comments Dated March 18, 1996 by Robert Lim, USEPA, on the Pre 95% Remedial Design
Package for the landfill design at A7, Ft. Devens Sudbury Training Annex, MA.
10. Comments Dated May 29, 1996 from Robert Lim, USEPA, on Draft Final Basis of Design/Design
Analysis and Draft Final Contract Specification and Design Drawings, Sudbury Training
Annex, Ft. Devens, MA.

Responses to Comments

11. Response dated January 17, 1996 from Stone & Webster to comments on the 65% Draft BD/DA
and Specification for Source Control Remedial Design at SAs A7 and A9, Ft. Devens Sudbury
Training Annex, MA.
12. Response dated June 14, 1996 from Stone & Webster to comments on 95% Draft BD/DA and
Specification for Source Control Remedial Design, SAs A7/A9, Ft. Devens Sudbury Training
Annex, MA.

7.0 Remedial Action (RA)

7.5 Remedial Action Documents

Reports

1. "Final Technical Memorandum: Consolidation of Soils from SAs P16, P23, and P41 at AOC
A7, Ft. Devens Sudbury Training Annex, MA," Stone & Webster (June 1996).

Comments

2. Comments Dated March 26, 1996, from Robert Lim, USEPA Region I, on Draft Technical
Memorandum, Consolidation of Soils from Areas P16, P23, P41 as Subgrade at AOC A7, Ft.
Devens Sudbury Training Annex, MA.
3. Comments Dated March 20, 1997, from Robert Lim, USEPA Region 1, on the February 1997
"Draft Project Closure Report, Sudbury Training Annex," Roy F. Weston.

7.6 Work Plans and Progress Reports

Reports

1. "Final Technical Memorandum: Consolidation of Soils from SA A2, P2, and P39 as Subgrade
at AOC A7, Ft. Devens Sudbury Training Annex, MA," Stone & Webster (December 1995).
Comments
Comments Dated July 15, 1996 from Robert Lim, USEPA, on "Work Plan for Source Control
Remediation SA A7 with Removal Actions at SAs Al, A2, A9, P2, P16, P23, P28, P2 9, and
P41, Ft. Devens Sudbury Training Annex, MA."
Comments Dated July 31, 1996, from Robert Lim, USEPA Region I on the following: Letter
from Roy F. Weston (July 26, 1996) which summarizes Work Plan to address Lab Waste
Staging, Decon Water, Geonet/Geotextile Comments, and Emergency Response Plan.
Comments Dated August 12, 1996, from Robert Lim, USEPA Region I, on the August 8, 1996
"Substitution Reguest for Replacement of the Sand Drainage Layer with a Geonet," Roy F.
Weston, Inc.
8.0 Site Closeout

8 .1 Correspondence
-------
1. Acceptance Dated April 18, 1991, from Robert Lin, USEPA Region I, of the Responses to
USEPA Comments on "Method Detection Limit Study" prepared as part of the "Final Operation
and Maintenance Plan," Roy F. Weston, Inc.

8.3 Operations and Maintenance

1. Comments Dated December 23, 1996, from Robert Lim, USEPA Region I, on the November 1996
"Draft Operations and Maintenance Plan for the Landfill at Area of Contamination A7," Roy
F. Weston, Inc.

10.0 Enforcement

10.16 Federal Facility Agreements

Reports

The document cited below as entry number 1 may be reviewed, by appointment only, at Fort Devens.

1. "Final Federal Facility Agreement Under CERCLA Section 120," EPA Region I and U.S.
Department of the Army (November 15, 1991).

Comments

2. Comments Dated July 12, 1991 from Edmond G. Benoit, Commonwealth of Massachusetts
Department of Environmental Protection on the March 1991 "Draft Federal Facility
Agreement Under CERCLA Section 120," EPA Region I and U.S. Department of the Army.

Responses to Comments

3. Response Dated September 5, 1991 from James P. Byrne, EPA Region I to the Comments Dated
July 12, 1991 from Edmond G. Benoit Commonwealth of Massachusetts Department of
Environmental Protection on the March 1991 "Draft Federal Facility Agreement Under CERCLA
Section 120," EPA Region I and U.S. Department of the Army.

13.0 Community Relations

13.2 Community Relations Plans

Reports

The document cited below as entries 1 and 2 may be reviewed, by appointment only, at Fort
Devens.

1. "Final Community Relations Plan," Dames & Moore (April 1992).

Comments

2. Comments Dated September 30, 1991 from Cindy Svec Ruzich and Deborah Schumann, Four Town
FOCUS on the August 1991 "Draft Community Relations Plan," Dames & Moore.
3. Comments Dated February 14, 1992 from Cindy Svec Ruzich and Deborah Schumann, Four Town
FOCUS on the December 1991 "Draft Final Community Relations Plan," Dames & Moore.
4. Comments Dated March 17, 1992 from D. Lynne Chappell, Commonwealth of Massachusetts
Department of Environmental Protection on the December 1991 "Draft Final Community
Relations Plan," Dames & Moore.
5. Comments from James P. Byrne, EPA Region I on the December 1991 "Draft Final Community
Relations Plan," Dames & Moore.
6. Cross Reference: Comments Dated May 13, 1992 from James P. Byrne, EPA Region I on the
April 1992 "Final Work Plan, Final Field Sampling Plan, Final Heath and Safety Plan,
Final Quality Assurance Project Plan," OHM Remediation Corp. and the April 1992 "Final
Community Relations Plan," Dames & Moore. [Filed and listed in 3.7 Work Plans and
Progress Reports in this Administrative Record Index.]

Responses to Comments

7. Response to the EPA Comments on the August 1991 "Draft Community Relations Plan,"
Dames & Moore.
8. Response to the Commonwealth of Massachusetts Department of Environmental Protection
-------
Comments on the August 1991 "Draft Community Relations Plan," Dames & Moore.

13.5 Fact Sheets

1. "Installation Restoration Program Fact Sheet: Phase II Work Plan Addendums," U.S. Army,
Fort Devens (June 1993).

13.11 Technical Review Committee Documents

1. Technical Review Committee Meeting Summary, List of Attendees, and Handouts (May 14,
1991).
2. Technical Review Committee Meeting Summary and List of Attendees (July 31, 1991) .
3. Technical Review Committee Meeting Summary and List of Attendees (October 23, 1991).
4. Technical Review Committee Meeting Summary and List of Attendees (January 15, 1992).
5. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads, and List of
Attendees (April 28, 1992).
6. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads, and List of
Attendees (July 14, 1992).
7. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads, and List of
Attendees (October 27, 1992).
8. Agenda and Attendance List for Sudbury Annex Working Meeting (November 23, 1992).
9. Technical Review Committee Meeting Summary, List of Attendees, and Handouts (February 2,
1993).
10. Letter from Richard D. Dotchin, U.S. Army to James P. Byrne, EPA Region I (March 3,
1993).
Concerning follow-up to the February 2, 1993 Technical Review Committee Meeting.
11. Technical Review Committee Meeting Summary, List of Attendees, and Handouts (June 9,
1993).

17.0 Site Management Records

17.6 Site Management Plans

The document cited below as entries number 1 and 2 may be reviewed, by appointment only,
at the Fort Devens Environmental Management Office.

Reports

1. "Final Master Environmental Plan," OHM Remediation Services Corp. (January 1992).
2. "Draft Master Environmental Plan, Fort Devens Sudbury Training Annex, Massachusetts,"
Ecology & Environment, Inc. (May 1994).
3. "Final Project Operations Plan, Fort Devens Sudbury Training Annex, Sudbury,
Massachusetts, Volume I & II," ABB Environmental Services, Inc. (April 1995).
4. "Draft Master Environmental Plan, Ft. Devens Sudbury Training Annex, MA," ABB
Environmental Services, Inc. (December 1995).

Comments

5. Comments Dated July 11, 1991 from James P. Byrne, EPA Region I on the May 1991 "Draft
Master
Environmental Plan, " OHM Remediation Services Corp.
6. Comments Dated July 15, 1991 from D. Lynne Chappell, Commonwealth of Massachusetts
Department of Environmental Protection on the May 1991 "Draft Master Environmental Plan,"
OHM Remediation Services Corp.
7. Comments from James P. Byrne, EPA Region I on the January 1992 "Final Master
Environmental Plan," OHM Remediation Services Corp.
8. Comments Dated June 27, 1994 from Robert Lim, USEPA, on the May 1994 "Master
Environmental Plan, Update, Fort Devens Sudbury Training Annex, Massachusetts," Ecology
and Environment, Inc.
9. Comments Dated January 3, 1997, from Mary Sanderson, USEPA Region I, on the "Draft Final
Environmental Baseline Survey and CERFA Letter Reports, Sudbury Training Annex."

Responses to Comments

10. Response Dated August 28, 1991 from OHM Remediation Services Corp. to the Comments Dated
July 11, 1991 from James P. Byrne, EPA Region I on the May 1991 "Draft Master
Environmental
-------
Plan," OHM Remediation Services Corp.
11. Response Dated August 28, 1991 from OHM Remediation Services Corp. to the Comments Dated
July 15, 1991 from D. Lynne Chappell, Commonwealth of Massachusetts Department of
Environmental Protection on the May 1991 "Draft Master Environmental Plan, " OHM
Remediation Services Corp.

Responses to Responses to Comments

12. Response Dated September 12, 1991 from James P. Byrne, EPA Region I to the Response Dated
August 28, 1991 from OHM Remediation Services Corp.

17.7 Reference Documents

1. "Criteria for Evaluating Sites for Hazardous Waste Management," Clark-McGlennon
Associates (no date).
2. "Ground-Water Geology and Hydrology of the Maynard Area, Massachusetts," N. M.
Perlmutter, U.S. Geological Survey Water-Supply Paper 1539-E (1962).
3. Real Estate File, Survey Inspection and Utilization of Government Property, List of
Bunkers (1973).
4. "Report on Water Supply Investigation - Tuttle Hill Area," Dufresne-Henry, Inc.(April
1982).
5. "Element Concentrations in Soils and Other Surficial Materials of the Contemporaneous
United States," H. T. Shacklett and J. G. Boergen (1984).
6. "Middlesex County Soil Survey, A Resource Planner's Guide," United States Department of
Agriculture (June 1989).
7. "Endangered Species Survey, Phase I. An Environmental Inventory of Wildlife Species and
Their Habitats," Anaptek Corporation (1991).
8. Compilation of information on Natick Laboratory and land management obtained through
information search, including draft documents and document edits, notes correspondence,
etc., OHM Remediation Services Corp. (1990-1991).
9. "Fort Devens Sudbury Annex Inventory Summary Report," Brian 0. Butler (1992).

17.8 Federal and Local Technical and Historical Records

The document cited below as entry number 1 may be reviewed, by appointment only, at the
office of the Fort Devens BRAG Environmental Coordinator, Fort Devens, Massachusetts.

1. "An Intensive Archeological Survey of the Sudbury Training Annex," The Public Archaeology
Laboratory, Inc. (April 1985).
2. "Defense Base Closure and Realignment Commission, Archives Search Report for Ordnance and
Explosives, Chemical Warfare Materials, Sudbury Annex," U.S. Army Corps of Engineers, St.
Louis District (February 1997).
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GUIDANCE DOCUMENTS

The following guidance documents were relied upon during the Fort Devens - Sudbury Annex cleanup. These
documents may be reviewed, by appointment only, at the Environmental Management Office at Foil 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 Reguirements for Drilling, Monitor Wells, Data Acguisition, 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 QA-1, May 1984.
7. U.S. Environmental Protection Agency. Office of Research and Development. Interim
Guidelines and Specifications for Preparing Quality Assurance Project Plans: AMS-005/80, 1983.
8. U.S. Environmental Protection Agency. Test Methods for Evaluating Solid Waste: EPA SW-
846 Third Edition, September 1986.
9. 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 9355.5-01, EPA/540/3-89/004), 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 A),
EPA/1-89/002), 1989.
11. U.S. Environmental Protection Agency. Hazardous Waste Management System:
Identification and Listing of Hazardous Waste: Toxicity Characteristic Revisions, (Final
Rule, 40 CFR Part 261 et al, Federal Register Part V), June 29, 1990.
12. U.S. Army. Environmental Quality - Environmental Protection and Enhancement, (Army
Regulation 200-1), April 23, 1990.
13. U.S. Environmental Protection Agency, 1991. Design and Construction of RCRA/CERCLA
Final Covers; Office of Research and Development; Washington, DC; EPA/625/4-91/025; May.
14. U.S. Environmental Protection Agency, 1991. Risk Assessment Guidance for Superfund:
Volume I - Human Health Evaluation Manual (Part B, Development of Risk-Based
Preliminary Remediation Goals) Interim; Office of Emergency and Remedial Response,
Washington, DC; Publication 9285.7-01B, October.
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APPENDIX F
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
AEHA Army Environmental Health Agency
AOC area of contamination
AWQC Ambient Water Quality Criteria
bgs below ground surface
BRAG Base Realignment and Closure
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
COPC chemical of potential concern
DDD 2,2-bis(para-chlorophenyl)-1,1-dichloroethane
DDE 2, 2-bis(para-chlorophenyl)-1,1-dichloroethene
DDT 2,2-bis(para-chlorophenyl)-1,1,1-trichloroethane
DERP Defense Environmental Restoration Program
ESAT USEPA Region I Environmental Services Assistance Team
FEMA Federal Emergency Management Agency
FFA Federal Facility Agreement
HI Hazard Index
HQ Hazard Quotient
MADEP Massachusetts Department of Environmental Protection
NADEQE Massachusetts Department of Environmental Quality Engineering
MCL Maximum Contaminant Level
MCP Massachusetts Contingency Plan
MFFA Massachusetts Fire Fighting Academy
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
OU operable unit
PAH polynuclear aromatic hydrocarbons
PCB polychlorinated biphenyl
POL petroleum, oil, and lubricants
RCRA Resource Conservation and Recovery Act
RfD Reference Dose
RFTA Reserve Forces Training Area
RME reasonable maximum exposure
RI remedial investigation
SA study area
SARA Superfund Amendments and Reauthorization Act of 1986
SI site investigation
SMCL Secondary Maximum Contaminant Level
SVOC semivolatile organic compound
TAL Target Analyte List
TCL Target Compound List
TPH total petroleum hydrocarbons
TRC Technical Review Committee
Ig/g micrograms per gram
Ig/L micrograms per liter
UBK Uptake/Biokinetic
USAEC U.S. Army Environmental Center
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
UST underground storage tank
VOC volatile organic compound
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