Superfund Record of Decision Otis Air National Guard USAF OU 3 Falmouth MA


                                    EPA/ROD/R01-98/132
                                    1998
EPA Superfund
     Record of Decision:
     OTIS AIR NATIONAL GUARD BASE/CAMP EDWARDS
     EPA ID: MA2570024487
     OU03
     FALMOUTH, MA
     09/30/1998

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EPA 541-R98-132


                                    INSTALLATION RESTORATION PROGRAM

                                           RECORD OF DECISION
                                      AOC CS-3 (USCG)  3~in~l Store


                                   MASSACHUSETTS MILITARY RESERVATION
                                         CAPE  COD, MASSACHUSETTS

                                                  FINAL

                                              Prepared for:

                             Air Force Center for Environmental Excellence
                              Otis Air National  Guard Base, Massachusetts

                                              Prepared by:

                          Stone & Webster Environmental  Technology  &  Services
                                         Boston,  Massachusetts
                                     Contract No. DAHA90-94-D-0008

                                             September 1998

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AOC CS-3 (USCG) RECORD OF DECISION
MASSACHUSETTS MILITARY RESERVATION

TABLE OF CONTENTS

Section Title Page No.

DECLARATION FOR THE RECORD OF DECISION D-l

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

2 . SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2 .1 Land Use and Response History 2-2
2 . 2 Enforcement History 2-3

3. COMMUNITY PARTICIPATION 3-1

4 . SCOPE AND ROLE OF RESPONSE ACTION 4-1

5 . SUMMARY OF SITE CHARACTERISTICS 5-1
5 .1 Source Contamination Assessment 5-1
5.2 Groundwater Contamination Assessment 5-1

6. SUMMARY OF SITE RISKS ASSESSMENT 6-1
6 .1 Human Health Risk Assessment 6-1
6.2 Ecological Risk Assessment 6-12
6.3 Risk Uncertainties and Conclusions 6-15

7. DESCRIPTION OF THE NO ACTION ALTERNATIVE 7-1

8 . DOCUMENTATION OF NO SIGNIFICANT CHANGES 8-1

9 . COMMONWEALTH ROLE 9-1

GLOSSARY OF ACRONYMS AND ABBREVIATIONS

REFERENCES

APPENDICES

APPENDIX A- ADMINISTRATIVE RECORD INDEX
APPENDIX B- COMMONWEALTH CONCURRENCE LETTER
APPENDIX C- TRANSCRIPT OF PUBLIC HEARING

LIST OF FIGURES

Section Title Page No.

1-1 Location of AOC CS-3 (USCG) 1-2
2-1 AOC CS-3 (USCG) Site Features 2-4

LIST OF TABLES

Table Title Page No.

6-1 Human Health and Ecological Contaminants of Concern: Surface Soil (0 to 2 feet
below ground surface) 6-2
6-2 Human Health Contaminants of Concern: Subsurface Soil (0 to 10 feet) 6-3
6-3 Human Health Contaminants of Concern: Groundwater 6-4
6-4 Summary of Potential Exposure Pathways: Human Health 6-7
6-5 Exposure Parameters Ingestion, Dermal Contact, and Inhalation for Soil 6-8
6-6 Total Site Risks Under Current Land Use 6-9
6-7 Total Site Risks Under Future Land Use 6-10
6-8 Summary of Risks to Terrestrial Vertebrates: Surface Soils (0 to 2 feet) 6-13
6-9 Estimation of Phytotoxicity Risk: Surface Soils (0 to 2 feet) 6-14

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

The Massachusetts Military Reservation (MMR) on Cape Cod, Massachusetts, lies within the boundaries of
the towns of Falmouth, Mashpee, Sandwich, and Bourne. The Area of Contamination (AOC) known as Chemical
Spill 3 United States Coast Guard [CS-3 (USCG)] is located on Lee Road, in the south central portion of
the MMR.

STATEMENT OF BASIS AND PURPOSE

This document presents the selected No Action decision for the MMR AOC CS-3 (USCG), chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, as amended by the Superfund Amendments and Reauthorization Act of 1986. To the extent
practicable, the National Oil and Hazardous Substances Contingency Plan (NCP), 40 CFR Part 300 et seq.,
as amended, was considered. The selection of the No Action alternative is based on the administrative
record file for this AOC, which was developed in accordance with Section 113(k) of CERCLA and is
available for public review at the information repositories located at: (1) the Falmouth Public
Library, Falmouth, Massachusetts; and (2) the Air Force Center for Environmental Excellence (AFCEE)
Installation Restoration Program Office at Otis Air National Guard (ANG) Base, Massachusetts. The
attached index (Appendix A) identifies the items in the Administrative Record upon which the selection
of a remedial action is based. The AFCEE selected the alterative, which was approved by USEPA. The
Commonwealth of Massachusetts concurs with the selected remedial action (see Appendix B).

DESCRIPTION OF THE SELECTED REMEDY

The AFCEE, acting as executive agent of the USCG, and the USEPA, with concurrence of the Commonwealth
of Massachusetts, have determined that No Action is necessary to address the contamination at AOC CS-3
(USCG). Total petroleum hydrocarbons (TPH), volatile organic compounds (VOCs), semivolatile organic
compounds (SVOCs), pesticides, and metals were detected in soil samples collected at the site. These
compounds were detected at concentrations below applicable action levels. Because the chemicals at this
AOC are at concentrations below those considered to present human health or ecological threats, no
further action is necessary.

DECLARATION

The AFCEE, USCG and USEPA, with concurrence of the Commonwealth of Massachusetts, have determined that
no remedial action is necessary at AOC CS-3 (USCG). As this is a decision for No Action, the statutory
requirements of CERCLA Section 121 for remedial actions are not applicable and no five-year review will
be undertaken.

Concur and recommend for immediate implementation:

1. SITE NAME, LOCATION, AND DESCRIPTION

The MMR is a National Priorities List (NPL) site. There are currently 77 areas within the MMR that are
under investigation. Some of these areas have been grouped into operable units for remediation
purposes. This Record of Decision (ROD) describes the No Action decision for AOC CS-3 (USCG).

The MMR, which lies within the boundaries of the towns of Bourne, Falmouth, Mashpee. and Sandwich,
Massachusetts, occupies approximately 22,000 acres (Figure 1-1) and consists of several cooperating
command units: Massachusetts ANG, Massachusetts Army National Guard (ARNG), United States Air Force
(USAF), Veterans Administration (VA), United States Marine Corps, United States Department of
Agriculture, USCG, and the Commonwealth of Massachusetts. The USAF managed the base until 1973, when
base management was transferred to the ANG. The site is described in more detail in the AOC CS-3 (USCG)
Remedial Investigation (RI) report (COM Federal Programs Corp., 1997).

Property usage in each of the towns surrounding the MMR is primarily residential and light industrial.
The AOC is located outside the Zone II contribution area for Bourne water supply wells PS-2 and PS-5
(Whitman & Howard, Inc., 1992).

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In response to environmental contamination that has occurred as a result of the use, handling, storage,
or disposal of hazardous materials at military installations across the United States, the Department
of Defense (DoD) initiated investigation and clean-up activities under the Installation Restoration
Program (IRP). The IRP parallels the Superfund program and is conducted in the following seven stages:

• identification of potential hazardous waste sites
• confirmation of the presence of hazardous materials at the site
• determination of the type and extent of contamination
• evaluation of alternatives for clean up of the site in the focused feasibility study (FFS)
• proposal of a clean-up remedy in the Proposed Plan
• selection of a remedy
• implementation of the remedy for clean up of the site

Both private sector and federal facility sites are eligible for placement on the USEPA NPL, which is
used to prioritize investigations and responses at hazardous waste sites. The MMR was added to the NPL
on November 21, 1989 (USEPA, 1989). Private sector sites placed on the NPL are eligible to receive
funding from the nation's environmental trust fund (i.e., Superfund), and are often called Superfund
sites. Federal military facilities such as the MMR receive funding; from the DoD Defense Environmental
Restoration Account.

2.1 LAND USE AND RESPONSE HISTORY

AOC CS-3 (USCG) occupies approximately 3.5 acres in the south central portion of the MMR, north of Lee
Road. The AOC is the former location of an automobile service and gasoline station. Currently, the site
is mostly paved with a landscaped grassy area, a gravel parking lot in the eastern portion of the site,
and above ground storage tanks in the west northwest corner of the site (Figure 2-1). The site is
currently a gasoline station, convenience store, and garden shop known as the "3-in-l." Access to the
site is unrestricted. Areas north, east, and west of AOC CS-3 (USCG) are grassy and wooded. The south
side of Lee Road includes an open grassy space, several buildings, and a paved parking area. The base
hospital is located approximately 1,000 feet northwest of the site.

Available documentation shows that activities may have introduced hazardous substances to the AOC
occurred from 1951 to 1979. Leaded motor gasoline was stored and dispensed, and maintenance operations
were performed generating petroleum, oil and lubricant (POL) wastes. These waste materials were
temporarily stored in an underground storage tank (UST), Abandoned Tank (AT)-23. Grease, oil, and other
wastes were reportedly disposed of in a leaching well located at the eastern edge of Building 5202.
Unleaded, regular and premium grades of gasoline are currently dispensed at the fuel island, and waste
oil is stored in an AST located behind the "3-in-l".

In 1985, AT-23 was found to be leaking. The UST and associated petroleum contaminated soils were
removed from the site, and a replacement above ground tank was installed. Testing of the soil and
groundwater at AOC CS-3 (USCG) identified that levels of TPH, VOCs, SVOCs, pesticides, and metals were
low (below base action levels). However, due to the detection of contaminants in a water supply well
downgradient of the AOC, across Lee Road, the AOC received a Hazard Assessment Rating Methodology score
sufficient to gualify it for further investigation (E.G. Jordan Co., 1986).

In 1994, three former gasoline USTs [Current Product Tank (CPT)-40, 41, and 42] were removed and
replaced with aboveground tanks as part of the Fuels Upgrade Program in 1994. Approximately 340 cubic
yards of contaminated soils were removed from the tank grave, and clean soils were backfilled

The RI recommended "removal of the leaching well, and the associated discharge pipes" and "removal of
subsurface soils and sediments associated with the leaching well as part of the Drainage Structure
Removal Program (DSRP)." Sediment and sludge inside the leaching well were removed during the DSRP, but
the leaching well and associated discharge pipes (Orangeburg pipes) were not removed because they are
partly buried beneath Building 5202, and removal of them would cause structural damage to the building.
The leaching well was filled with concrete. Surface soil and subsurface soil samples collected around
the pipes and the pipes' out-fall area showed limited contamination (see Tables 6-1 and 6-2). A
stockpile of soils that had been excavated during trenching for the construction of an optical cable
line through another AOC on the Base, FS-27, is located north of Building 5202. As a precaution, this
area was sampled during the RI. Sampling confirmed that the stockpile was not contaminated.

2.2 ENFORCEMENT HISTORY

The AFCEE has followed USEPA guidelines for all investigations completed since 1989. However, upon
formalization of the NPL status, the IRP under management of the ANG entered into an Interagency
Agreement with USEPA and USCG on July 17, 1991, to define responsibilities, documentation reguirements,
and future regulatory interaction regarding remedial activities at the MMR under CERCLA authority. The
management and signatorial authority of the IRP was transferred from the ANG to the AFCEE in 1996 at
which time the federal facilities agreement was revised and resigned. The AFCEE is responsible for
carrying out activities under this agreement.

3. COMMUNITY PARTICIPATION

Throughout the MMR's history, community concern and involvement has been high. The National Guard
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Bureau (NGB), the AFCEE, the AMG, and USEPA have kept the community and other interested parties
appraiser of site activities through informational meetings, fact sheets, news releases, public
hearings, and Technical Environmental Affairs Committee (TEAC) meetings. The TEAC was organized in 1986
by the NGB to provide a forum for public input on the MMR remedial response activities. Membership on
the TEAC consists of the USEPA, Massachusetts Department of Environmental Protection (MADEP), and
representatives from local, regional, and state groups. Beginning with the October 7, 1992 TEAC
meeting, members of the public could attend these bimonthly meetings.

During May 1991, an MMR community relations plan was released that outlined a program to address
community concerns and keep citizens informed and involved in the remediation process at the MMR. In
July 1994, an updated draft community relations plan was issued to incorporate additional concerns and
feedback provided by the community, and to document changes in NGB policy, such as the public
attendance at TEAC meetings.

In October 1993, the NGB created three Process Action Teams (PATs) to address specific issues at the
MMR: Plume Containment, Long-Range Water Supplies, and Innovative Technologies. The PAT's have
representation from the community, local business, regulatory agencies, and the IRP. A Senior
Management Board was also created to review the work of the PATs. A selectperson from each of the four
towns surrounding the MMR are among the Board members, along with the regulatory agencies and the
Adjutant General's office of the Commonwealth of Massachusetts. The PATs and the Board advise the IRP
on activities at the MMR.

In 1989, the administrative record for MMR was established. This document is constantly updated as the
Installation Restoration Program progresses. The administrative record is available for public review
at the IRP Office, Otis ANG Base, Massachusetts; USEPA's offices in Boston, Massachusetts; and the
Falmouth Public Library, Falmouth, Massachusetts. The AFCEE published a notice and brief analysis of
the Proposed Plan in the "Cape Cod Times" on March 19, 1998 and in the "Falmouth Enterprise," "Bourne
Enterprise," "Mashipee Enterprise," and "Sandwich Enterprise" on March 20, 1998. The AFCEE made the RI
report and Proposed Plan available to the public at the Falmouth Public Library and the administrative
records locations.

From April 2 to May 1, 1998, the AFCEE held a 30-day public comment period to accept public comments on
the No Action alternative and several other remedial alternatives presented in the Proposed Plan. The
AFCEE held a public meeting on April 1, 1998, and a public hearing on April 22, 1998, both in the
Administration Building of the Barnstable County Fairgrounds in Falmouth, Massachusetts, to discuss the
Proposed Plan and to accept any verbal comments. One member of the community attended and provided no
verbal comments. A transcript of this hearing is included as Appendix C. Since no comments were
received, a Responsiveness Summary was not prepared.

4. SCOPE AND ROLE OF RESPONSE ACTION

AFCEE and USEPA have determined that no further CERCLA action is reguired at AOC CS-3 (USCG). Because
levels of chemicals detected in the soil and groundwater at this AOC do not pose an unacceptable risk
to human health or the environment, no further action will be undertaken.

USEPA has the authority to revisit the No Action decision even if the MMR is removed from the NPL. This
could occur if future conditions indicate that an unacceptable risk to human health or the environment
would result from exposure to contaminants at AOC CS-3 (USCG).

5. SUMMARY OF SITE CHARACTERISTICS

The preliminary records review for AOC CS-3 (USCG) was conducted and issued as the Site Investigation
in 1986. The remedial investigation was conducted to characterize the nature and distribution of
contaminants at AOC CS-3 (USCG) during 1991. Sections 2.0 and 6.0 of the AOC CS-3 (USCG) RI report (COM
Federal Programs Corp., 1997) provide an overview of the AOC CS-3 (USCG) environmental contamination
assessment. The significant findings of these contamination assessments are summarized in the following
subsections.

5.1 SOURCE CONTAMINATION ASSESSMENT

Several source areas were investigated at AOC CS-3 (USCG), including: the embankment (soil pile from
FS-27), the former USTs CPT-40, 41, and 42, the former UST CPT-43, the former UST AT-23, and the
abandoned leaching well with Orangeburg pipes. Orangeburg pipes are perforated clay tile pipes that
serve as overflow drainage for the leaching well during high flow episodes. These areas are presented
on Figure 2-1. Surface and subsurface soil samples were collected from these locations.

Compounds detected sporadically in surface and subsurface soil samples included TPH, VOCs (i.e., 1,2
dichloromethane, toluene, xylenes, and ketones), SVOCs (i.e., bis-2(ethylhexyl) phthalate,
benzo(a)pyrene, benzo(b)fluoranthene), and pesticides [i.e., chlordane, dichlorodiphenyltrichloroethane
(DDT)]. Detected concentrations of these compounds and metals, were below the MMR soil action levels.

A ground-penetrating radar (GPR) survey was conducted to locate the former UST, CPT-43. This
10,000-gallon tank was reportedly installed in the 1970s for storing diesel fuel. However, there is no
record that the tank was ever used. The GPR survey could not locate this tank.

5.2 GROUNDWATER CONTAMINATION ASSESSMENT
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Groundwater was sampled from 5 borings and 6 wells in the vicinity of AOC CS-3 (USCG) during the RI
field effort, in 1993 and 1994. Groundwater samples contained sporadic detections of VOCs (i.e., 1,2
dichloromethane, ethylbenzene, toluene, xylenes, and ketones), SVOCs (i.e., trimethylbenzenes), and
metals (i.e., mercury, lead, and thallium). Detected concentrations of these compounds and metals were
below the MMR groundwater action levels.

6. SUMMARY OF SITE RISKS

A risk assessment was conducted to estimate the probability and magnitude of potential adverse human
health and environmental effects from exposure to contaminants associated with AOC CS-3 (USCG). The
risk assessment was conducted using a phased approach, as described in the MMR IRP Risk Assessment
Handbook (Automated Sciences Group, Inc., 1994).

6.1 HUMAN HEALTH RISK ASSESSMENT

The human health risk assessment followed a four-step process:

1. Contaminant identification, which identified those hazardous substances that, given the
specifics of the AOC, were of significant concern.

2. Exposure assessment, which identified current and future 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.

4. Risk characterization, which integrated the three earlier steps to summarize the potential
and actual carcinogenic and noncarcinogenic risks posed by hazardous substances at the AOC.

Thirteen contaminants of concern (COCs) in soil and twenty-two COCs in groundwater, listed in Tables
6-1 through 6-3, were selected for evaluation in the risk assessment. These contaminants constitute a
representative subset of the compounds detected at this AOC during the Site Investigation (SI) (E.G.
Jordan Co., 1986) and RI (CDM Federal Programs Corp., 1997). Chemicals detected in at least one sample
in each medium have been addressed. The COCs were selected to represent potential site-related hazards
based on toxicity, concentration, freguency of detection, and mobility and persistence in the
environment. The health effects of each COG are sOummarized in the AOC CS-3 (USCG) RI Report (CDM
Federal Programs Corp., 1997).

Potential human health effects associated with exposure to the COCs were estimated guantitatively
through the development of hypothetical exposure pathways. These pathways were developed to reflect the
present uses, potential future uses, and location of AOC CS-3 (USCG). The area surrounding this AOC and
adjacent off-Base areas are residential and light industrial. On-Base property is used by the ARNG for
training exercises. The exposure pathways and scenarios evaluated in the human health risk assessment
are presented in Table 6-4. For each pathway, an average (i.e., mean) and a reasonable maximum exposure
(RME) risk was calculated corresponding to exposure to the average and maximum concentration detected
in that particular medium. The specific exposure parameters for each receptor and exposure scenario are
presented in Table 6-5. A detailed discussion can be found in Subsection 8.3 of the AOC CS-3 (USCG) RI
Report (CDM Federal Programs Corp., 1997).

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 carcinogenic risks to be additive when assessing
exposure to a mixture of hazardous substances.

The hazard guotient (HQ) was also calculated for each pathway as the USEPA's measure of the potential
for noncarcinogenic health effects. The HQ is calculated by dividing the exposure level by the
reference dose (RfD) or other suitable benchmark for noncarcinogenic health effects. RfDs have been
developed by the USEPA to protect sensitive individuals over the course of a lifetime, and 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 is
approximately one third of an exposure level for the given compound for which adverse health effects
are not likely to occur). HQs are summed, resulting in a hazard index (HI) for each pathway. If the HI
is greater than 1.0, the predicted intake could potentially cause adverse health effects. This
determination is necessarily imprecise because the derivation of dose-response values (i.e., RfDs)
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involves the use of multiple safety and uncertainty factors. In addition, the Hqs for individual
compounds should be summed only if their target organs or mechanisms of action are identical.
Therefore, the potential for adverse effects from a mixture having an HI in excess of 1.0 must be
assessed on a case-by-case basis.

Tables 6-6 and 6-7 summarize the total carcinogenic and noncarcinogenic risks for current and future
hypothetical exposure, respectively, to contaminated soil and groundwater at AOC CS-3 (USCG). More
detailed risk assessment tables are in Subsection 8.3 of the AOC CS-3 (USCG) RI Report (CDM Federal
Programs Corp., 1997).

Carcinogenic risks are compared to the USEPA target carcinogenic risk range of one in ten thousand to
one in a million (1 x 10 -4 to 1 x 10 -6). Noncarcinogenic risks are compared to the USEPA target
noncarcinogenic HI of 1 (USEPA, 1990).

Under the current land use scenario, utility workers and child trespassers were considered to be
exposed to soil. The maximum carcinogenic risk value was approximately 2.5 x 10 -7, based on exposure
of a child trespasser to primarily benzo(a)pyrene, arsenic, and beryllium in soil. The maximum HI was
approximately 0.009, based on exposure of a utility worker to primarily arsenic in soil. The maximum
estimated cancer and noncancer risks were within the acceptable risk range.

Under the future land use scenario, based on the assumed receptors, exposures to soil and groundwater,
the maximum carcinogenic risk value was approximately 1.7 x 10 -4. This cancer risk exceeds the
acceptable risk range (1 x 10 -4 to 1 x 10 -6) and is primarily due to potential child and adult future
residents exposed to total arsenic and beryllium in groundwater. The total maximum detected
concentrations of these metals in groundwater were above MMR background concentrations but below the
federal Maximum Contaminant Level (MCL) drinking water standards. Dissolved arsenic and beryllium were
not detected in filtered groundwater samples, the resulting maximum carcinogenic risk value was
approximately 1.7 x 10 -5 (within the acceptable risk range). USEPA guidance provides that the upper
boundary of the target risk range is not a discrete line at 1 x 10 -4 and that risk estimates slightly
greater than 1 x 10 -4 maybe considered acceptable, if justified.

The maximum noncarcinogenic HI was estimated to be approximately 16. This HI was associated with
residential exposure to maximum concentrations of total inorganic compounds and VOCs, particularly
manganese, 1,2,4-trimethylbenzene, and 1,3,5-trimethylbenzene, in groundwater. Because the risk
assessment for CS-3 (USCG) was conducted using toxicity factors from 1995, it does not reflect more
recent changes to reference doses for manganese, and provisional reference doses for
1,2,4-trimethylbenzene and 1,3,5-trimethylbenzene(2 x 10 -2, 5 x 10 -2, and 5 x 10 -2 mg/kg/day,
respectively). If these were to be incorporated into the analysis the risk attributed to each of these
chemicals at the maximum concentration observed would be less than 1.0, EPA's benchmark for
non-carcinogenic effects. The maximum detected concentrations of total manganese and arsenic exceeded
MMR background concentrations. No MCLs are available for manganese, 1,2,4-trimethylbenzene, or
1,3,5-trimethylbenzene. The maximum total concentration of arsenic in groundwater was below the MCL.
The maximum total concentration of antimony in groundwater was above the MCL.
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TABIiE 6-4: SUMMARY OF POTENTIAL EXPOSURE PATHWAYS
HUMAN HEALTH
POTENTIALLY
EXPOSED
POPULATION

CURRENT LAND USE

Construction/Utility Worker

Child Trespasser

FUTURE LAND USE

Resident
Utility Worker
EXPOSURE ROUTE
AND
MEDIUM
Ingestion of surface soil; inhalation of fugitive dust

Ingestion of surface soil; inhalation of fugitive dust

Ingestion and dermal contact with groundwater, and inhalation
of vapors from groundwater

Ingestion of surface soil; inhalation of fugitive dust
REASON FOR SELECTION
Utility maintenance and/or construction may be conducted at the site

Area is accessible to trespassers

Future residents may contact soils if houses are built within or downgradient of the site

Future residents may be exposed to groundwater if houses are built within or downgradient of the site

Future excavation in the area is possible
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TABIiE 6-5: EXPOSURE PARAMETERS
INGESTION AND INHALATION FOR SOIL
VALUES
PARAMETER
Age
Soil Ingestion Rate (IRsoil)
Fraction Ingested From Site
Relative Absorptioin Factors (ABS)
Exposure Freguency (EF)
Exposure Duration (ED)
Body Weight (BW)
Averaging Time (AT)
Cancer
Noncancer
CHILD
TRESPASSER
7 to 12 years
100 mg/day
100%
*
52 days/year
6 years
36.2 kg

70 years
6 years
FUTURE CHILD
RESIDENT
1 to 6 years
200 mg/day
100%
*
350 days/year
6 years
15 kg

70 years
6 years
FUTURE
RESIDENT
7 years to adult
100 mg/day
100%
*
350 days/year
24 years
70 kg

70 years
24 years
UTILITY
WORKER
adult
480 mg/day
100%
NA
42 days/year
1 year
70 kg

70 years
1 year
Inhalation Rate (IRair)

Particulate Emission Factor (PEF)
20 m 3/day

4.63 x 10 9m 3/kg
20 m 3/day

4.63 x 10 9m 3/kg
Notes:
Source: MMR Risk Assessment Handbook (Automated Sciences Group, 1994)
mg = milligrams
kg = kilograms
cm 2 = sguare centimeters
m 3 = cubic meters
NA = not applicable for this scenario
* = chemical specific
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Table 6-6: TOTAL SITE RISKS UNDER CURRENT LAND USE
RECEPTOR
EXPOSURE ROUTE
MEAN CONCENTRATIONS
TOTAL TOTAL
HAZARD INDEX CANCER RISK
MAXIMUM CONCENTRATIONS
TOTAL TOTAL
HAZARD INDEX CANCER RISK
"urrent Land Use:
Utility Worker
Child Trespasser
Incidental Ingestion of Soil
Inhalation of Soil
Total Utility Worker:

Incidental Ingestion of Soil
Inhalation of Particulates from Soil
1. USEPA Target Hazard Index =1.0
2. USEPA Target Cancer Risk = l.OE-04 to l.OE-6
Blank indicates that this risk was not evaluated.
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TABLE 6-7: TOTAL SITE RISKS UNDER FUTURE LAND USE
RECEPTOR

Future Land Use Exposure to Soil
Utility Worker
Child Trespasser
Resident (child 1-6 years)
Resident (7 years - adult)
Future Land Use Exposure to Groundwater
Resident (adult)
(total organics)
Resident (adult)
(dissolved organics)
Future Land Use Expoure to Soil and Groundwater
Total Lifetime Resident
total (dissolved) metals
Notes:
TOTAL
EXPOSURE ROUTE
TOTAL
Incidental Ingestion of Soil
Inhalation of Particulates from Soil
Total Utility Worker:

Incidental Ingestion of Soil
Inhalation of Particulates from Soil
Total Child Trespasser:

Incidental Ingestion of Soil
Inhalation of Particulates from Soil
Total Resident (child):

Incidental Ingestion of Soil
Inhalation of Particulates from Soil
Total Resident (7 year - adult):
Incidental Ingestion of Groundwater
Dermal contact with groundwater
Inhalation of Volatiles from Groundwater
Total Resident (7 years - adult)

Incidental Ingestion of Groundwater
Dermal contact with Groundwater
Inhalation of Volatiles from Groundwater
Total Resident (7 years - adult)
Ingestion & Inhalation of Soil
Ingestion, dermal contact, & Inhalation
of Groundwater
Total Lifetime Resident:
MEAN CONCENTRATIONS
TOTAL TOTAL
HAZARD INDEX CANCER RISK
l.OOE-05
6.5E-5 (1.5E-06)

7.5E-05 (1.2E-05)
MAXIMUM CONCENTRATIONS

HAZARD INDEX CANCER RISK
0.037

0.037
0.0042

0.0042
0.14

0.14
0.015

0.015
3.7

0.11
3.81
2.1

0.11
2.21
3
3
3
2
1
2
7
1
7
3
1
3
6
5
1
6
3
5
1
1
.30E-07
.30E-11
.3E-07
.20E-07
.10E-10
.2E-07
.30E-06
.80E-09
.3E-06
.10E-06
.50E-09
.1E-06
.40E-05
.80E-09
.20E-06
.5E-05
.10E-07
.80E-09
.20E-06
.5E-06
0,

0,
0,

0,
15,

0,
11.
.039

.039
.0045

.0045
.15

.15
.016

.016
15

.68
.68
11

.68
.68
3,
3,
3,
2,
1.
2,
8,
1.
8,
3,
1.
3,
1.
2,
4,
1.
1.
2,
4,
5,
. 60E-07
.50E-11
. 6E-07
.50E-07
.10E-10
.5E-07
.10E-06
.90E-09
.1E-06
.50E-06
.60E-09
.5E-06
.60E-04
.20E-08
.40E-06
. 6E-04
.20E-06
.20E-08
.40E-06
. 6E-06
1.20E-06
1.6E-04(5.6E-06)

1.7E-04(1.7E-05)
1. USEPA Target Hazard Index - 1.0
2. USEPA Target Cancer Risk 1.OE -4 to 1. OE
-6
-------
6.2 ECOLOGICAL RISK ASSESSMENT

An ecological risk assessment was performed at this AOC for terrestrial animals and plant life
(phytotoxicity). The COCs for the ecological assessment are presented in Table 6-8. The following
terrestrial model species were selected: white-footed mouse (Peromyscus leucopus), meadow vole
(Microtus pennsylvanicus), the northern short-tailed shrew (Blarina brevicauda), northern cardinal
(Cardinalis cardinaolis), red fox (Vulpes vulpes), upland sandpiper (Bartramia longicauda), and
short-eared owl (Asioflammeus). Risks for ecological receptors were evaluated for exposures to
contaminated surface soil, ingestion of contaminated food items, inhalation of contaminants from
surface soil, dermal contact with surface soil, and root uptake (plants only). Exposure pathways were
not identified for groundwater or subsurface soil because terrestrial organisms are not expected to
come in contact with soil deeper than two feet below grade, and few prey exist in subsurface media.

Chemicals of concern for ecological risk assessment were identified as those inorganic compounds that
exceeded MMR background concentrations. Concentrations of inorganic chemicals in surface soil were
compared to chemical-specific, receptor-specific ecological toxicity benchmark values to derive HQs.
The HQs for each pathway were summed to yield a total HI for each receptor based on exposure to mean
(average case) and maximum concentrations (worst case). Table 6-8 identifies the contribution of each
COG to the HQ computed for each terrestrial receptor. The results of the ecological risk assessment are
presented in Table 6-9. The ecological risk assessment is discussed in detail in Subsection 8.4 of the
AOC CS-3 (USCG) RI (CDM Federal Programs Corp., 1997).

The risk evaluation identified no significant risks to plants at AOC CS-3 (USCG). A maximum HI of 4.6
was estimated for terrestrial vegetation exposed to COCs in surface soil. Risk associated with exposure
to COCs at MMR background concentrations resulted in an HI of approximately 3.3. The risk to
terrestrial vegetation associated with exposure to COCs at AOC CS-3 (USCG) was determined to be
insignificant when compared with the HIS associated with risks associated with exposure to COCs at MMR
background concentrations.

The results of the ecological risk assessment for AOC CS-3 (USCG) estimated the potential risk to
terrestrial receptors from exposure to inorganic compounds in surface soil. Based on maximum detected
concentrations in surface soil, HIS for the white-footed mouse, the meadow vole, the short-eared owl,
and the northern cardinal were greater than 1.0 but less than 10. HIS for the upland sandpiper (17),
the northern short-tailed shrew (44), and the red fox (34) were above the recommended risk level of 10.
The majority of these risks were the result of exposure to metals. Maximum detected concentrations of
most metals in AOC CS-3 (USCG) soils were below corresponding MMR background concentrations.

Therefore, the risks estimated for terrestrial receptors were determined to be acceptable.

Ecological receptors are not currently assumed to be exposed to groundwater at AOC CS-3 (USCG).
However, the ecological risk assessment evaluated a future scenario in which groundwater may discharge
to downgradient surface water. This evaluation assumed that COCs in groundwater would discharge to
surface water unaltered by dilution or attenuation. The maximum estimated HI for future surface water
risk was 140. This risk was primarily the result of mercury concentrations detected in groundwater from
one of six wells at AOC CS-3 (USCG). This HI was the same order of magnitude as risk from other COCs at
MMR background groundwater concentrations and therefore was determined to be acceptable.
-------
TABIiE 6-8: SUMMARY OF RISKS TO TERRESTRIAL VERTEBRATES
SURFACE SOILS (0-2 feet)
INDICATOR SPECIES HAZARD INDICES a
WHITE FOOTED

MOUSE
MEADOW VOLE
SHORT-TAILED

SHREW
RED FOX
UPLAND

SANDPIPER
SHORT-EARED

OWL
CARDINAL
CHEMICALS
INORGANICS
Arsenic
Cadmium
Chromium
Cyanide
Vanadium
Zinc
MAXIMUM

0.13
0.79
1.37
0.86
0.55
0.62
MEAN

0.12
0.47
1.26
0.69
0.55
0.47
MAXIMUM

0.0031
0.081
0.140
0.56
0.34
0.24
MEAN

0.0028
0.049
0.128
0.45
0.33
0.18
MAXIMUM

10.91
12.11
14.29
0.37
1.09
4.83
MEAN

10.11
7.27
13.07
0.29
1.08
3.70
MAXIMUM

0.03
0.08
0.21
0.004
0.18
34
MEAN

0.03
0.05
0.19
0.003
0.18
26
MAXIMUM

1.42
5.25
0.20
4.00
NA
6.23
MEAN

1.32
3.15
0.18
3.20
0.0
4.77
MAXIMUM

0.00025
0.0019
0.00017
0.0016
0.11
2.43
MEAN

0.00023
0.0012
0.00016
0.0013
0.11
1.86
MAXIMUM

0.10
0.37
0.014
4.1
0.2
0.5
MEAN

0.092
0.22
0.013
3.3
0.19
0.42
HAZARD INDEX b:
4.3
3.6
1.4
1.1
4.36
35.5
34.0
26.1
17.1
12.6
2.5
2.0
5.3
4.2
[a] Hazard Quotient = Total Body Dose/Benchmark Dose. HQ>1 = possible effects, HQ>10 = probable effects.
[b] Hazard Index = Sum of HQs.
NA = Not Applicable; Not evaluated in the RI
-------
TABIiE 6-9: ESTIMATION OF PHYTOTOXICITY RISK
SURFACE SOILS (0-2 Feet Below Ground Surface)
Surface Soil 0-2 feet
Volatile Organics
Carbon Bisulfide
Toluene

Semi-Volatile Organics
2-Methylnaphthalene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(B)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Butylbenzylphthalate
Carbazole
Chrysene
Dibenz(a,h)anthracene
Dibenzofuran
Di-n-butylphthalate
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
Phenanthrene
Pyrene

Pesticides/PCBs
4,4'-DDD
4,4'-DDE
4,4 '-DDT
alpha-Chlordane
gamma-Chlordane
Dieldrin
MAXIMUM

CONCENTRATION
(mg/kg)
0.001
0.001
0.028
0.039
0.009
0.044
0.2
0.14
0.32
0.32
0.069
0.058
0.039
0.18
0.055
0.013
0.13
0.33
0.03
0.1
0.023
0.29
0.26
0.0035
0.0048
0.015
0.011
0.0076
0.006
PV BENCHMARK
VALUE
(mg/kg)
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
CRITICAL SOIL

CONCENTRATION
(mg/kg)
NA
33,600
8.6
2.5
5.77
6.59
7.82
8.48
8.46
8.46
8.98
11.21
NA
7.82
9
6.21
38.7
7.26
6.26
8.98
10
4.16
7.08
50
50
50
NA
38.95
1.39
HAZARD QUOTIENT[**1

MAXIMUM MEAN

NE NE
0.00003 0.00003
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
.003
.016
.002
.007
.026
.017
.038
.038
.008
.005
NE
.023
.006
.002
.003
.045
.005
.011
.002
.070
.037
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,

0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
.003
.016
.002
.007
.013
.010
.019
.019
.006
.005
NE
.013
.006
.002
.003
.020
.005
.008
.002
.033
.019
0.00007
0.0001
0.0003
NE
0.00020
0.0043
0.00005
0.000067
0.00018
NE
0.00005
0.0023
-------
Inorganic Analytes
Aluminum
Arsenic*
Barium
Beryllium
Cadmium*
Calcium
Chromium*
Cobalt*
Cyanide
Iron
Lead*
Magnesium
Manganese*
Nickel*
Potassium
Sodium
Vanadium
Zinc*
7060
3.4
12.8
0.3
1.1
388
10
2.2
0.2
8730
9.6
1120
57.9
4.2
601
239
15.2
24.8
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
PV
NA
5.0
NA
NA
5.0
NA
5.0
15
NA
NA
30
NA
300
10
NA
NA
NA
100
HI =
NE
0.68
NE
NE
0.22
NE
2.0
0.15
NE
NE
0.32
NE
0.19
0.42
NE
NE
NE
0.25
4.595
NE
0.63
NE
NE
0.13
NE
1.83
0.13
NE
NE
0.28
NE
0.19
0.4
NE
NE
NE
0.19
3.999
Notes:
*Lesser of Maximum detected concentration and Mean concentration
** Arithmetic mean considered duplicates averaged and non-detects 1/2 of SQL
HI = Hazard Index, sum of hazard guotients
NA = Not Available
PV = Phytotoxicity Value. (MMR Risk Assessment Handbook, Volume 1,
NE = Not Evaluated
mg/kg = milligrams per kilogram
1994.)
(For some metals the Phytotoxicity value is given as a range, HI calculated using lowest value)
-------
6. 3 Risk Uncertainties and Conclusions

Risk estimates are subject to a wide variety of uncertainties. Risk assessments do not calculate
absolute risks, but rather provide conservative analyses to evaluate the potential for adverse impacts.
In most risk assessments, uncertainties tend to err on the side of conservatism. Therefore, the
calculated risks usually provide an upper bound of risks which may be encountered at the AOC. Actual
risks will probably be much lower than these calculated risks. There are uncertainties involved in
adding risks from individual chemicals to estimate total risks. Many individual chemicals act through
different mechanisms on different target organs; therefore, the risks are not necessarily additive.

In selecting benchmark values, the lowest toxicity value reported in available literature was
selected. Often these conservative values result in an overestimation of ecological risk.

The USEPA has a CERCLA mandate to manage risk resulting from actual or potential exposure to hazardous
substances. The USEPA's target cancer risk range resulting from exposure to a hazardous substance is 1
x 10 -4 to 1 x 10 -6. Non-carcinogenic risks with His below 1.0 are also considered acceptable. The
USEPA's decision as to whether action is warranted when the cancer risk range is not exceeded is based
upon site-specific conditions.

Analytical data collected during the SI and RI have adeguately characterized surface soil, subsurface
soil, and groundwater guality at the AOC CS-3 (USCG). These data suggest that widespread disposal of
hazardous substances has not occurred on-site. Human health risks were evaluated for exposure to
surface soil, subsurface soil, and groundwater. Carcinogenic risks associated with the future resident
(1.7 x 10 -4) slightly exceeded the USEPA target range. This was primarily due to the ingestion of
total arsenic and beryllium in groundwater. Total arsenic and beryllium were detected at concentrations
above MMR background concentrations but below the MCLs, and dissolved arsenic and beryllium were not
detected.

Calculated ecological risks show elevated risk levels for the upland sandpiper (HI of 17), the northern
short-tailed shrew (HI of 44), and the red fox (HI of 34). The majority of these risks were associated
with metals concentrations in soil below MMR background concentrations. Ecological risks based on
exposure to background soil conditions yielded risks nearly as high as for AOC CS-3 (USCG) soils. Given
the number of extremely conservative measures used in the analyses (i.e., conservative benchmark
values) the ecological risk assessment likely overestimates risk by several orders of magnitude and
does not suggest that risks at AOC CS-3 (USCG) are significantly higher than those expected at
background conditions. Therefore, excessive risks are not considered to result from site-related
activities.

On the basis of this information, it is believed that human health and ecological risks due solely from
site-related contaminants are not considered to be significantly higher than those associated with
background risk. Therefore, the AOC CS-3 (USCG) was recommended for a No Action decision and formal
removal from the MMR IRP.

7 . DESCRIPTION OF THE NO ACTION ALTERNATIVE

Based on the results of the SI and RI, no remedial alternative is considered necessary for AOC CS-3
(USCG). There are no construction activities associated with the No Action decision.

The risk assessment concluded that no significant risk or harm to potential receptors exists at the
site and therefore no further remedial action is recommended. The RI concluded that there was no risk
to human health and the environment; therefore, a Feasibility Study was not prepared and five-year site
reviews will not be conducted.

The USEPA has the authority to revisit the No Action decision even if the MMR is removed from the NPL.
This could occur if future conditions indicate that an unacceptable risk to human health or the
environment would result from exposure to contaminants at AOC CS-3 (USCG).

8. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The AFCEE prepared a Proposed Plan for AOC CS-3 (USCG)(1998). The Proposed Plan described the AFCEE's
decision to pursue no further action at AOC CS-3 (USCG). There have been no significant changes made to
the No Action decision stated in the Proposed Plan.

9. COMMONWEALTH ROLE

The MADEP, on behalf of the Commonwealth of Massachusetts, reviewed the RI Report and Proposed Plan and
indicated its support for the selected remedy. The MADEP concurs with the selected remedy for AOC CS-3
(USCG). A copy of the declaration of concurrence is in Appendix B.
-------
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
AFCEE Air Force Center for Environmental Excellence
ANG Air National Guard
AOC Area of Contamination
ARNG Army National Guard
AT Abandoned Tank

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
COG contaminant of concern
CPT Current Product Tank
CS-3 Chemical Spill No. 3

DoD Department of Defense (U.S.)

FFS focused feasibility study

GPR ground-penetrating radar

HI hazard index
HQ hazard guotient

IRP Installation Restoration Program

MADEP Massachusetts Department of Environmental Protection
MCL Maximum Contaminant Level
MMR Massachusetts Military Reservation

NCP National Contingency Plan
NGB National Guard Bureau
NPL National Priorities List

PAT Process Action Teams
POL Petroleum, oil, and lubricant

RfD Reference Dose
RI remedial investigation
RME reasonable maximum exposure
ROD Record of Decision

SI site inspection
SVOC semivolatile organic compound

TEAC Technical Environmental Affairs Committee
TPH total petroleum hydrocarbons

USAF United States Air Force
USCG United States Coast Guard
USEPA United States Environmental Protection Agency
UST underground storage tank

VA Veterans Administration
VOC volatile organic compound
-------
REFERENCES

CDM Federal Programs Corp., 1997. "Remedial Investigation Report, Area of Contamination CS-3 (USCG),"
Installation Restoration Program; Massachusetts Military Reservation; prepared for HAZWRAP;
March 1997.

Air Force Center for Environmental Excellence, 1998. "Proposed Plan, Area of Concern (AOC) CS-3 United
States Coast Guard;" Installation Restoration Program; Massachusetts Military Reservation; Fact
Sheet #98-1; March 1998.

Automated Sciences Group, Inc., 1994. "Risk Assessment Handbook, Comprehensive Plan, Appendix C;"
Installation Restoration Program; prepared for HAZWRAP Support Contractor Office.

E.G. Jordan Co., 1986. "U.S. Air Force Installation Restoration Program, Phase I: Records Search, Air
National Guard, Camp Edwards (ARNG), U.S. Air Force, and Veterans Administration Facilities at
Massachusetts Military Reservation, Task 6," prepared for Oak Ridge National Laboratory; Oak
Ridge, Tennessee; December 11, 1986.

U.S. Environmental Protection Agency (USEPA), 1989. "40 CFR Part 300, National Priorities List of
Uncontrolled Hazardous Waste Sites, Final Rule," Federal Register; Vol. 54, No. 223; p. 48187;
November 21, 1989.

U.S. Environmental Protection Agency (USEPA), 1990. "National Oil and Hazardous Substance Pollution
Contingency Plan," 40 CFR Part 300; Washington, DC; March 8, 1990.

Whitman and Howard, Inc., 1989. "Computer Model and Groundwater Management Study for Sandwich Water
District, Sandwich, Massachusetts," Wellesley, Massachusetts; July 1989.
-------
APPENDIX A

ADMINISTRATIVE RECORD INDEX

MASSACHUSETTS MILITARY RESERVATION

Administrative Record Files
CS-3 (USCG)

1.01 PRE-REMEDIAL

1.2 Preliminary Assessment

5969 "Final Report, Task 7, Phase I: Records Search, U.S. Coast Guard Facilities at Massachusetts
Military, Reservation, Massachusetts", E.G. Jordan Company, Inc. prepared for Hazardous Waste
Remedial Actions Program (HAZWRAP) (December 11, 1986). Twelve sites were identified as having
potential for environmental contamination. (200 pages).

4943 Comments dated January 20, 1988 on the June 1987 "Phase II/AVA Remedial
Investigation/Feasibility Study Work Plan" and the December 1986 "MMR Phase I Records Search
Reports (Tasks 6 and 7)", Tilden, Christopher, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (January 20, 1988), (3 pages)

7286 Letter from Marchessault, Paul, U.S. Environmental Protection Agency. Region I to Santos,
Daniel W., IRP Office MMR (May 16, 1994). The Phase I Records Searches for ANG, Camp Edwards,
USAF, and Veteran's Administration Facilities at MMR, and the Phase I Records Search for the
USCG Facilities at MMR (both dated December 11, 1986) have been accepted as final by EPA. (1
pages)

1.3 Site Inspection

148 "Draft Interim Site Investigation Report, Priority 2 and 3 Study Areas, Phase I
Results/Proposed Phase II Investigation," E.G. Jordan Company, Inc., prepared for Hazardous
Waste Remedial Actions Program (HAZWRAP) (October 1990). Study classifies sites as (1) those
reguiring a full RI/FS, (2) those which could move to an IRM/FS stage, and (3) areas clear of
contamination, potentially appropriate for a DD. (490 pages).

149 "Draft Site Investigation, Priority 2 and 3 Study Areas; Volume I," ABB Environmental Services,
Inc., prepared for Hazardous Waste Remedial Actions Program (HAZWRAP) (August 1992). Two areas
(FS-12 and FS-13), originally included in Priority 2 and 3 sites, are not included in this
investigation because it was determined that a pipeline to be investigated at those study areas
is owned by a private contractorand does not fall under the IRP. (151 pages).

63 "Draft Site Investigation, Priority 2 and 3 Study Areas; Volume 11," ABB Environmental
Services, Inc., prepared for Hazardous Waste Remedial Actions Program (HAZWRAP) (August 1992).
Contains Section 5.0 through Appendices and includes discussion of USCG FS-2 and USGS LF-1
(unprioritized areas). (356 pages).

224 "Final Work Completion Report, Sump Removal Action Program, Phase I Sump Investigation Program;
Volume I - Text," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial
Actions Program (HAZWRAP) (October 1992). The purpose of Phase I was to (1) characterize
contamination associated with 106 identified sump and sump-like structures, and (2) determine
the locations of previously unidentified sumps or sump-like structures at MMR. (157 pages).

225 "Final Work Completion Report, Sump Removal Action Program, Phase I Sump Investigation Program;
Volume II - Appendices A through C," ABB Environmental Services, Inc., prepared for Hazardous
Waste Remedial Actions Program (HAZWRAP) (October 1992). The purpose of Phase I was to (1)
characterize contamination associated with 106 identified sump and sump-like structures, and
(2) determine the locations of previously unidentified sumps or sump-like structures at MMR.
(265 pages).

226 "Final Work Completion Report, Sump Removal Action Program, Phase I Sump Investigation Program;
Volume III - Appendix D," ABB Environmental Services, Inc., prepared for Hazardous Waste
Remedial Actions Program (HAZWRAP) (October 1992). Purpose of Phase I was to (1) characterize
contamination associated with 106 identified sump and sump-like structures, and (2) determine
the locations of previously unidentified sumps or sump-like structures on MMR. (463 pages).

227 "Final Work Completion Report, Sump Removal Action Program, Phase I Sump Investigation Program;
Volume IV - Appendices E through F," ABB Environmental Services, Inc., prepared for Hazardous
Waste Remedial Actions Program (HAZWRAP) (October 1992). Purpose of Phase I was to (1)
characterize contamination associated with 106 identified sump and sump-like structures, and
(2) determine the locations of previously unidentified sumps or sump-like structures at MMR.
(427 pages).
-------
5312 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume I - Sections 1 through
5," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions Program
(HAZWRAP) (October 1993). This report presents the results of the Sis conducted on 20 study
areas at MMR, 11 Priority 2 sites, six Priority 3 sites, and two unprioritized sites. (149
pages).

5308 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume II - Sections 6 through
24: Text," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions
Program (HAZWRAP) (October 1993). This volume contains the text for all of the sites. (237
pages).

5307 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume III - Sections 6 through
24: Figures," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions
Program (HAZWRAP) (October 1993). This volume contains figures on all of the sites. (148
pages).

5306 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume IV - Sections 6 through
24: Tables," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions
Program (HAZWRAP) (October 1993). This volume contains tables on all of the sites. (393 pages).

5305 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume V - Appendices A through
K," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions Program
(HAZWRAP) (October 1993). This volume contains information on sump and dry well construction,
additional exploration and sampling technigues, soil boring logs, test pit logs, screened auger
boring logs, monitoring well installation diagrams, groundwater monitoring records, piezometric
levels, ISIS codes, monitoring well locations and elevations, and GC screening results. (625
pages).

5304 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume VI - Appendix L-l," ABB
Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions Program (HAZWRAP)
(October 1993). This volume contains laboratory chemical data tables. (482 pages).

5303 "Draft Site Investigation Report, Priority 2 and 3 Study Areas; Volume VII - Appendices L-2
through R," ABB Environmental Services, Inc., prepared for Hazardous Waste Remedial Actions
Program (HAZWRAP) (October 1993). This volume includes tentatively identified compound data,
chemical data from previous investigations, a data guality report, validation checklists, HECs
for human health and ecological risk assessment, ecological setting and risk evaluation
exposure parameters and eguations, and identified location of SA FS-14.(324 pages).

6614 EPA's comments dated December 20, 1993, on the October 1993 "Draft Priority 2 and 3 Study Areas
Site Investigation", Marchessault, Paul, U.S. Environmental Protection Agency Region I
(December 20, 1993) . (32 pages) .

6613 MADEP's comments dated January 25, 1994, on the October 1993 "Draft Priority 2 and 3 Study
Areas Site Investigation", Begley, James F., Commonwealth of Massachusetts Department of
Environmental Protection (January 25, 1994). (11 pages).

6213 Site Investigation Report and Site Status Table, Priority 2 and 3 Study Areas, Carl Wheeler and
Roger D. Ray, Hazardous Waste Remedial Actions Program (HAZWRAP) (February 8, 1994). This table
represents the disposition recommended for each site in the Priority 2 and 3 SI (Rework) Report
(ABB, 1993). (2 pages).

5385 Summary of Discussions and Agreements on the Priority 2 and 3 Study Areas, Santos, Daniel W.,
IRP Office MMR Paul Marchessault, U.S. Environmental Protection Agency. Region I (February 15,
1994). Re summary of discussion with NGB personnel at RPM meeting on agreements on the study
areas (with transmittal letter from D. Santos to P. Marchessault dated March 24, 1994). (9
pages).

1.18 FIT Technical Direction Documents (TDDs) and Associated Records

155 "Final Report, Site Inspection Work Plan, Priority 2 and 3 Sites, Task 2-4," E. C. Jordan
Company, Inc., prepared for Hazardous Waste Remedial Actions Program (HAZWRAP) (February 1990).
Investigation at 19 sites has been designed to detect source area contamination, if any, by
evaluating both soil and groundwater guality. (125 pages).

2623 Comments dated September 10, 1990 on the February 1990 "Final Report: Site Inspection Work
Plan, Priority 2 and 3 Sites, Task 2-4", Marchessault, Paul, U.S. Environmental Protection
Agency Region I (September 10, 1990) . (2 pages) .

2419 Response dated March 2, 1992 to EPA's Comments on the February 1990 "Final Report: Site
Inspection Work Plan, Priority 2 and 3 Sites, Task 2-4", Santos, Daniel W., IRP Office MMR
(March 2, 1992). (4 pages).

5743 Letter from Marchessault, Paul, U.S. Environmental Protection Agency Region I to Santos, Daniel
W., IRP Office MMR (June 24, 1992). Responses to EPA's comments are acceptable to EPA on the
following reports: "Site Inspection Work Plan, Priority 2 and 3 Sites, Task 2-4;" "Briarwood
Subdivision Groundwater Public Health Risk Assessment;" and "Site Inspection Report Addendum,
Results of Additional SI Sampling Conducted Summer 1989, Task 2-3C (August 1990)." (1 pages).
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3.0 REMEDIAL INVESTIGATION(RI)

3.1 Correspondence

624 Letter from Marchessault, Paul, U.S. Environmental Protection Agency Region I to Watson, Ronald
M., National Guard Bureau (March 8, 1990). Concerning EPA's opinion that the removal actions
proposed at SD-5 and CS-10 are classified as time-critical, with additional information on the
conduct of RIs and FSs at USCG sites LF-1, CS-7, LF-2, LF-3, CS-5, FS-1, FS-2, CS-1, CS-2,
CS-3, CS-4 and CS-6. (3 pages).

3 .2 Sampling and Analysis Data

1482 Leak Detector Report, Hoffman, John, Tanknology Corporation International (July 13, 1990). With
attached note dated April 12, 1991 from George to D. Santos. (7 pages).

5997 "Draft Remedial Investigation Field Sampling Plan, Area of Contamination CS-3 (USCG)," COM
Federal Programs Corporation, (April 1993). This RIFSP presents the proposed RI activities for
CS-3 (USCG). With attached transmittal letter dated April 27, 1993; comments due to CDM by June
14, 1993. (106 pages).

5993 "Draft Addendum #5 to the Draft Quality Assurance Project Plan for Field Investigations," CDM
Federal Programs Corporation, (April 1993). This is an addendum to the QAPP for the RI of AOC
CS-3 (USCG). (15 pages).

6152 EPA's comments dated June 21, 1993 on the April 1993 "Draft Remedial Investigation Field
Sampling and Analysis Plan for AOC CS-3 (USCG)", Marchessault, Paul, U.S. Environmental
Protection Agency Region I (June 21, 1993) . (9 pages) .

6141 NGB's response elated July 23, 1993 to MADEP/EPA comments on the April 1993 "Field Sampling
Plan for AOC CS-3 (USCG), including Addendum 95 to the Draft QAPP and the HSP", Santos, Daniel
W., IRP Office MMR (July 23, 1993). (30 pages).

6160 EPA's comments dated August 24, 1993 on NGB's response to EPA comments on the "Remedial
Investigation Field Sampling Plan for CS-3 (USCG)", Marchessault, Paul, U.S. Environmental
Protection Agency Region I (August24, 1993) . (2 pages) .

5333 "Final Remedial Investigation Field Sampling Plan, Area of Contamination CS-3 (USCG)," CDM
Federal Programs Corporation, prepared for Hazardous Waste Remedial Actions Program (HAZWRAP)
(September 1993). This plan presents the proposed remedial investigation activities for AOC
CS-3 (USCG). (141 pages).

9500 Mr. LaPoint's comments dated October 22, 1993 on the September 1993 "Final Remedial
Investigation Field Sampling Plan for CS-3 (USCG)", LaPointe, Rick, KELCO Group, Inc. (October
22, 1993). With attached response from Doug Karson (dated December 6, 1993). (8 pages).

3.6 Remedial Investigation (RI) Reports

6552 "Draft Remedial Investigation Report, Area of Contamination CS-3 (USCG); Volume I - Text," CDM
Federal Programs Corporation, prepared for Hazardous Waste Remedial Actions Program
(HAZWRAP)(August 1994). Based on the RI, no further action is recommended (with transmittal
letter from Julia Nault, CDM, to E.T. Grostick, HAZWRAP dated August 31, 1994).

Volumes II-IV (Figures, Tables & Appendices) are filed with the March 1997 "Final Remedial
Investigation Report, Area of Contamination CS-3 (USCG)."

6818 NGB's comments dated October 5, 1994 on the August 1994 "Draft Remedial Investigation Report,
Area of Contamination CS-3 (USCG)", Minior, Michael E., IRP Office MMR (October 5, 1994). With
transmittal letter to Carl Wheeler, HAZWRAP. (4 pages).

6817 MADEP's comments dated October 7, 1994 on the August 1994 "Draft Remedial Investigation Report,
Area of Contamination CS-3 (USCG)", Begley, James F., Commonwealth of Massachusetts Department
of Environmental Protection (October 7, 1994). With transmittal letter dated October 14, 1994
from Mike Minior, MMR, to Carl Wheeler, HAZWRAP, reguesting responses. (3 pages).

6790 EPA's comments dated October 23, 1994 on the August 1994 "Draft Remedial Investigation Report,
Area of Contamination CS-3 (USCG)", Marchessault, Paul, U.S. Environmental Protection Agency
Region I (October 23, 1994). With transmittal letter dated November 2, 1994 from Mike Minior,
MMR, to Carl Wheeler, HAZWRAP, reguesting responses.. (11 pages).

6784 MADEP's comments dated April 5, 1995 on the August 1994 "Draft Remedial Investigation Report,
Area of Contamination CS-3 (USCG)", Begley, James F., Commonwealth of Massachusetts Department
of Environmental Protection (April 5, 1995). (1 pages).

9788 Memorandum of Resolution dated March 1996 on the August 1994 "Draft Remedial Investigation
Report, CS-3 (USCG)", Minior, Michael E., IRP Office MMR (March 1996). (6 pages).

9789 EPA's comments dated April 4, 1996 on the March 1996 Memorandum of Resolution on the August
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1994 "Draft Remedial Investigation Report, CS-3 (USCG)", Marchessault, Paul, U.S. Environmental
Protection Agency Region I (April 4, 1996). With transmittal dated April 9, 1996 from Mike
Minior to Carl Wheeler. (2 pages).

9790 MADEP's comments dated April 10, 1996 on the March 1996 Memorandum of Resolution on the August
1994 "Draft Remedial Investigation Report, CS-3 (USCG)", Pinaud, Leonard J., Commonwealth of
Massachusetts Department of Environmental Protection (April 10, 1996). With transmittal dated
April 11, 1996 from Mike Minior to Carl Wheeler. (4 pages).

9796 Final Memorandum of Resolution dated April 1996 on the August 1994 "Draft Remedial
Investigation Report, CS-3 (USCG)", Wheeler, Carl, Hazardous Waste Remedial Actions Program
(HAZWRAP) (April 1996). With transmittal dated May 8, 1996 from Carl Wheeler to Mike Minion (5
pages).

9797 "Revised Draft, Remedial Investigation Report, AOC CS-3 (USCG); Volume I - Text," COM Federal
Programs Corporation, Prepared for Hazardous Waste Remedial Actions Program (HAZWRAP)
(September 1996). Based on the findings and conclusions of the RI, removal of the leaching well
(during the DRSP) is recommended, in addition to subsurface soils and sediments associated with
the well. No further action is recommended for the remainder of the site's soils. With
transmittal dated October 10, 1996 from Julia Nault to Carl Wheeler. (245 pages).

Volumes II-IV (Figures, Tables & Appendices) are filed with the March 1997 "Final Remedial
Investigation Report, Area of Contamination CS-3 (USCG)."

9802 AFCEE's comments dated November 13, 1996 on the September 1996 "Revised Draft, Remedial
Investigation Report, CS-3 (USCG)", Snyder, Jim F., IRP Office MMR (November 13, 1996). AFCEE
does not have any comments on the revised draft RI. (1 pages).

9801 MADEP's comments dated November 19, 1996 on the September 1996 "Revised Draft, Remedial
Investigation Report, CS-3 (USCG)", Pinaud, Leonard J., Commonwealth of Massachusetts
Department of Environmental Protection (November 19, 1996). With transmittal dated November 21,
1996 from Jim Snyder to Carl Wheeler. MADEP concurs with the revised report. (2 pages).

9803 EPA's comment: 3 dated November 25, 1996 on the September 1996 "Revised Draft, Remedial
Investigation Report, CS-3 (USCG)", Marchessault, Paul, U.S. Environmental Protection Agency
Region I (November 25, 1996). With transmittal dated November 27, 1996 from Jim Snyder to Carl
Wheeler reguesting preparation of responses. (3 pages).

9804 USCG's cocomments dated December 13, 1996 on the September 1996 "Revised Draft, Remedial
Investigation Report, CS-3 (USCG)", Mills, C. D., U.S. Coast Guard (December 13, 1996). USCG
has no comments on the report (with transmittal dated December 30, 1996 from Jim Snyder to Carl
Wheeler. (2 pages).

9805 AFCEE's responses dated December 30, 1996 to EPA's comments on the September 1996 "Revised
Draft, Remedial Investigation Report, CS-3 (USCG)", Snyder, Jim F., IRP Office MMR (December
30, 1996) . (2 pages) .

9806 EPA's responses dated January 31, 1997 on the September 1996 "Revised Draft, Remedial
Investigation Report, CS-3 (USCG)", Marchessault, Paul, U.S. Environmental Protection Agency
Region I (January 31, 1997). EPA concurs with the responses (with transmittal dated February 3,
1997 from Jim Snyder to Carl Wheeler). (2 pages).

9764 "Final Remedial Investigation Report, Area of Contamination CS-3 (USCG); Volume I - Text," COM
Federal Programs Corporation, Prepared for Hazardous Waste Remedial Actions Program (HAZWRAP)
(March 1997). Based on the results on soil sampling, impacts to soils due to contaminant
releases are limited to subsurface soils in the vicinity of the leaching well (which will be
removed in the DSRP). Analytical results for groundwater indicate concentrations were generally
below ARARs for organics and inorganics (with transmittal letter dated March 18, 1997 from
Julia Nault to Carl Wheeler). (169 pages).

9765 "Final Remedial Investigation Report, Area of Contamination CS-3 (USCG); Volume II - Figures
and Tables," COM Federal Programs Corporation, Prepared for Hazardous Waste Remedial Actions
Program (HAZWRAP) (March 1997). Based on the results on soil sampling, impacts to soils due to
contaminant releases are limited to subsurface soils in the vicinity of the leaching well
(which will be removed in the DSRP). Analytical results for groundwater indicate concentrations
were generally below ARARs for organics and inorganics (with transmittal letter dated March 18,
1997 from Julia Nault to Carl Wheeler). (142 pages).

9766 "Final Remedial Investigation Report, Area of Contamination CS-3 (USCG); Volume III -
Appendices," COM Federal Programs Corporation, Prepared for Hazardous Waste Remedial Actions
Program (HAZWRAP) (March 1997). Based on the results on soil sampling, impacts to soils due to
contaminant releases are limited to subsurface soils in the vicinity of the leaching well
(which will be removed in the DSRP). Analytical results for groundwater indicate concentrations
were generally below ARARs for organics and inorganics (with transmittal letter dated March 18,
1997 from Julia Nault to Carl Wheeler). (258 pages).

9767 "Final Remedial Investigation Report, Area of Contamination CS-3 (USCG); Volume IV -
Appendices," COM Federal Programs Corporation, Prepared for Hazardous Waste Remedial Actions
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Program (HAZWRAP) (March 1997). Based on the results on soil sampling, impacts to soils due to
contaminant releases are limited to subsurface soils in the vicinity of the leaching well
(which will be removed in the DSRP). Analytical results for groundwater indicate concentrations
were generally below ARARs for organics and inorganics (with transmittal letter dated March 18,
1997 from Julia Nault to Carl Wheeler). (862 pages).

4.0 FEASIBILITY STUDY (FS)

4 .2 Feasibility Reports

9884 Screening of Remedial Alternatives Letter, "Feasibility Study for AOCs CS-3 (USCG), FS-17, CS-
16/CS-17, FS-9 and FS-19", Stone & Webster Environmental Technology & Services, (September 13,
1996). The purpose of the letter is to present preliminary screening of remedial alternatives
for the above AOCs. Comments on the letter will be included in the draft final FS report. (38
pages).

9885 NGB-ARE's comments dated November 13, 1996 on the September 1996 "Screening of Remedial
Alternatives Letter, Feasibility Study for AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-
19", Hilyard, Scott G., National Guard Bureau (November 13, 1996). With transmittal dated
November 13, 1996 from Jim Snyder to Allen Ikalainen, Stone & Webster, reguesting preparation
of responses., (3 pages).

9886 NGB-ARE's comments dated November 14, 1996 on the September 1996 "Screening of Remedial
Alternatives Letter, Feasibility Study for AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-
19", Hill, Dave, Bregman & Company, Inc. (November 14, 1996). With transmittal dated November
18, 1996 from Jim Snyder to Allen Ikalainen, Stone & Webster, reguesting preparation of
responses (2 pages).

9883 "Draft Feasibility Study Report, AOCs CS-3 (USCG), FS-17, CS-16/CS- 17, FS-9, and FS-19," Stone
& Webster Environmental Technology & Services, (September 1996). The FS describes the
evaluation of potential alternatives for remediation of surface soil contamination at the above
five AOCs and sediment at one AOC. (378 pages).

AFCEE-MMR's comments dated November 19, 1996 on the September 1996 "Draft Feasibility Study for
AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-19", Snyder, Jim F., IRP Office MMR (November
19, 1996). AFCEE has no comments on the document. (1 pages).

9887 MADEP's comments dated November 19, 1996 on the September 1996 "Draft Feasibility Study for
AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-19", Pinaud, Leonard J., Comnmonwealth of
Massachusetts Department of Environmental Protection (November 19, 1996). With transmittal
dated November 20, 1996 from Jim Snyder to Allen Ikalainen, Stone & Webster, reguesting
preparation of responses.. (4 pages).

9890 USCG's comments dated December 13, 1996 on the September 1996 "Draft Feasibility Study for AOCs
CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-19", Mills, C. D., U.S. Coast Guard (December 13,
1996). USCG has no comments on the report (with transmittal dated December 30, 1996 from Jim
Snyder to Allen Ikalainen, Stone & Webster, reguesting preparation of responses). (2 pages).

9891 AFCEE-MMR's comments dated March 19, 1997 on the September 1996 "Draft Feasibility Study for
AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-19", Snyder, Jim F., IRP Office MMR (March
19, 1997). AFCEE reguests that all references to sites CS-3 (USCG), FS-9, FS-17, and FS-19 be
deleted from the report. These sites will proceed to a NFA Proposed Plan without any further
consideration. (2 pages).

9930 EPA's comments dated April 14, 1997 on the September 1996 "Draft Feasibility Study" and the
September 13, 1996 "Draft Technical Evaluation of Screening of Remedial Alternatives Letter
Feasibility Study AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9 and FS-19", Marchessault, Paul,
U.S. Environmental Protection Agency. Region I. (April 14, 1997). With transmittal letter dated
April 16, 1997 from Jim Snyder to Allen Ikalainen reguesting preparation of responses. (8
pages).

10216 AFCEE's responses dated July 2, 1997 to MADEP, NGB-Army, USCG, EPA, and AFCEE MMR's comments on
the September 1996 "Draft Feasibility Study for AOC's CS-3 (USCG), FS-17, CS 16/CS- 17, FS-9
and FS-19", Snyder, Jim F. , IRP Office MMR (July 2, 1997). With transmittal letter dated July
2, 1997 from Jim Snyder to commentors. (19 pages).

10801 EPA's comments dated October 14, 1997 to AFCEE's responses on the September 1996 "Draft
Feasibility Study Report, AOCs CS-3 (USCG), FS-17, CS-16/CS-17, FS-9, and FS-19" and the
September 1996 "Screening of Remedial Alternatives Letter. "Feasibility Study for AOCs CS-3
(USCG), FS-17, CS-16/CS-17, FS-9 and FS-19". Marchessault. Paul, U.S. Environmental Protection
Agency Region I (October 14, 1997). With transmittal letter dated October 20, 1997 from Jim
Snyder to Allen Ikalainen reguesting preparation of responses. (7 pages).

4 . 3 Proposed Plan

11159 "Draft Proposed Plan for Cleanup of Area of Contamination CS-3 (USCG)" (December 1997). This
Proposed Plan summarizes the RI, and presents the justification for no further remedial action
-------
to protect human health and the environment or to comply with environmental laws and
regulations (with transmittal letter dated December 30, 1997 from Alan Ikalainen of Stone &
Webster to Jim Snyder). (8 pages).

11163 MADEP's comments dated January 29, 1999 on the December 1997 "Draft Proposed Plan for Cleanup
of Area of Contamination CS-3 (USCG)", Pinaud, Leonard J., Commonwealth ofletter dated February
3, 1998 from Jim Snyder to Alan Ikalainen of Stone & Webster reguesting preparation of
responses. (4 pages).

11162 EPA's comments dated January 30, 1998 on the December 1997 "Draft Proposed Plan for Cleanup of
Area of Contamination CS-16/CS-17" and the December 1997 "Draft Proposed Plan for Cleanup of
Area of Contamination CS-3 (USCG)", Marchessault, Paul, U.S. Environmental Protection Agency
Region I (January 30, 1998). With transmittal letter dated February 3, 1998 from Jim Snyder to
Alan Ikalainen of Stone & Webster reguesting preparation of responses. (10 pages).

11161 AFCEE's comments dated February 3, 1998 on the December 1997 "Draft Proposed Plan for Cleanup
of Area of Contamination CS-16/CS-17" and the December 1997 "Draft Proposed Plan for Cleanup of
Area of Contamination CS-3 (USCG)", Snyder, Jim F., IRP Office MMR (February 3, 1998). With
transmittal letter dated February 3, 1998 from Jim Snyder to Alan Ikalainen of Stone & Webster
reguesting preparation of responses. (9 pages).

11164 AFCEE's responses dated March 3, 1998 to EPA and MADEP's comments on the December 1997 "Draft
Proposed Plan for Cleanup of Area of Contamination CS-3 (USCG)", Snyder, Jim F., IRP Office MMR
(March 3, 1998). With transmittal letter dated March 3, 1998 from Jim Snyder to Paul
Marchessault of EPA and Paul Taurasi of MADEP. (6 pages).

10187 "Proposed Plan for Area of Contamination (AOC) CS-3 United States Coast Guard (CS-3 USCG),"
Stone & Webster Environmental Technology & Services (March 1998). AFCEE is proposing that all
activities associated with the investigation and cleanup of the source area are complete and no
further action is necessary (with transmittal letter dated March 27, 1998 from Jim Snyder to
Community Members). (10 pages).
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James F. Snyder, Program Manager
HQ AFCEE/MMR
East Inner Road, Box 41
Otis ANG Base, Massachusetts 02542

Dear Mr. Snyder:
APPENDIX B
COMMONWEALTH CONCURRENCE LETTER
September 29, 1998
BOURNE--BWSC-4-0037
Massachusetts Military
Reservation(MMR),CS-3(USCG)
Record of Decision, Concurrence
The Department of Environmental Protection (the "Department") has reviewed a document entitled
"Record of Decision U.S. Coast Guard Exchange System Gas Station AOC CS-3 (USCG)" (the "ROD"), dated
September 1998 and prepared by Stone & Webster Environmental Technologies & Services of Boston,
Massachusetts, for the Air Force Center for Environmental Excellence (AFCEE).

The Area of Contamination (AOC) CS-3 (USCG) is located on Lee Road, in the south central portion
of the MMR. A full automobile service station was operated at the AOC from 1951 to 1979. It is
currently a gasoline station, convenience store, and garden shop. In 1994, three (3) underground
storage tanks (USTs) were removed and replaced by above ground storage tanks. Approximately 340 cubic
yards of contaminated soils were removed from the UST area, and clean soils were back filled. Wastes
were reportedly disposed of in a leaching well located at the eastern edge of Building 5202, an on-site
building. The contents of the leaching well were removed, but the leaching well and associated pipes
were not removed because they are partly buried beneath the building. The leaching well was filled with
concrete. The ROD presents a No Action decision for the AOC CS-3 (USCG).

The Department concurs with the ROD. The Departments concurrence for this ROD is based upon
representations made to the Department by the Air Force Center for Environmental Excellence and assumes
that all information provided is substantially complete and accurate. Without limitation, if the
Department determines that any material omissions or misstatements exist, if new information becomes
available, or if conditions at the Study Area change, resulting in potential or actual human exposure
or threats to the environment, the Department reserves its authority under M.G.L. c. 21E, and the
Massachusetts Contingency Plan, 310 CMR 40.000 et seq., and any other applicable law or regulation to
require further response actions.

Please incorporate this letter into the Administrative Record for the AOC CS-3 (USCG). the
Department looks forward to working with you to expedite the cleanup at the MMR. If you have any
questions regarding this letter, please contact Leonard J. Pinaud at (508) 946-2871.

T/LP/HC

cc: DEP-SERO
ATTN: Mildred Garcia-Surette, Deputy Regional Director
Leonard Pinaud, Chief, Federal Facilities Remediation Section
Distributions:
SERO
SMB
Plume Containment Team
Program Implementation Team
Long Range Water Supply PAT
Boards of Selectmen
Boards of Health
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APPENDIX C

TRANSCRIPT OF PUBLIC HEARING

CHEMICAL SPILL -3

COAST GUARD SITE

PUBIC HEARING

WEDNESDAY

APRIL 22, 1998

Barnstable Fairgrounds
Administration Building
Falmouth, Massachusetts
PAUL T. WALLACE
46 Meredith Way
Weymouth, Massachusetts 02188
(781) 337-4988
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Page 2
1 Wednesday

2 April 22, 1998

4 PROCEEDINGS

5 MS. MUSGRAVE: Good evening. I'd like to

6 welcome you to the public hearing on the CS-3 Coast

7 Guard site and the proposal that the Air Force has

8 put out for how to close it out and to discuss the

9 cleanup that has been done there already.

10 At this point in time, we don't have any

11 members of the public here. With everyone's

12 concurrence, what I would like to do is to just hold

13 the meeting open for a half an hour, and if no one

14 shows up, then we will just close it. If somebody

15 shows up in the meantime, then we'll go ahead and

16 make a presentation. Is that agreeable?

17 AUDIENCE MEMBERS: (Answer affirmatively)

18 MS. MUSGRAVE: We'll just sit here and wait

19 for another half an hour.

20 Just for the record, there was a member of

21 the public that showed up earlier. He had been here

22 to the previous public meeting, and he talked to

23 people and has left. So there was one person that

24 signed in.
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Page 3

1 So with that, we'll just wait and see if

2 anyone else arrives.

3 (Pause)

4 MS. MUSGRAVE: It is 7:30, and we don't

5 have any members of the public that have arrived. We

6 have Henry Cui and Len Pinaud from DEP; we have

7 Johanna Hunter from EPA; we have Lee Perry, Bruce Roy

8 from the Air Force, and myself from the Air Force.

9 So I think if we have a consensus, we will

10 just adjourn the hearing.

11 We would like for everybody to sign in if

12 you haven't signed in the, back, so we do have a

13 record of the people that did attend. Is that

14 agreeable to everyone?

15 AUDIENCE MEMBERS: (Answer affirmatively)

16 MS. MUSGRAVE: I will adjourn the meeting.

18 (Whereupon the public hearing adjourned

19 at or about 7:34 p.m.)
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Page 4
CERTIFICATE

COMMONWEALTH OF MASSACHUSETTS

BRISTOL, SS.

I, MAUREEN D. PIRES, a Professional Court

Reporter and Notary Public in and for the Commonwealth of

Massachusetts, do hereby certify:

That the following transcript, consisting

of pages 1 through 4, is a true and accurate recording

and transcription to the best of my knowledge, skill and

ability.

IN WITNESS WHEREOF, I hereunto set my hand

and notarial seal this 30th day of April, 1998.

My Commission Expires
July 31, 1998
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