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 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
  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,
0,

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

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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

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        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

3

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.




17




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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